Before you decide that you do not need it or will train in house, make certain you are aware of OSHA’s rules regarding spills, spill prevention and spill containment which are found within the Federal Regulations, Title 29, Occupational Safety and Health Standards. Specifically, subpart H, Hazardous Materials, pertains to the hazardous waste site cleanup efforts. OSHA’s direct rules pertain to requirements for safety, training and disposal programs. This part of 29 CFR is broken down into nine basic sections:
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- Occupational safety and health program: Each hazardous waste site cleanup effort requires a site-specific occupational safety and health program, which must be completed by the site coordinator or the employer’s representative. This program aims to protect the overall health and safety of site employees by providing means for planning and implementing appropriate training and orientation, including methods of identifying and controlling workplace hazards.
Site safety and health programs must include policy statements; the development of procedures for controlling hazards; means or methods of communicating the rules and procedures to employees; means to anticipate emergency situations; and means for obtaining feedback to improve the program. Accidents on job sites must be investigated to provide insight for future programs.
- Training: Training programs should address what sorts of hazards employees might find on hazardous waste cleanup sites; effective control measures; effective monitoring procedures; hands-on equipment training; and clear outlines of employee duties. These programs should also address competencies required for different levels of response to hazards, from employees to leaders to hazardous materials specialists.
- Decontamination: Decontamination procedures must be detailed to site-specific hazards, in terms of their complexity and number of required steps.
- Emergency response plans: Employees and employers should utilize state- and district-designated emergency response plans as standard policy when dealing with hazardous materials.
- Personal Protective Equipment programs: OSHA defines personal protective clothing and equipment (PPE) as gear meant to “shield or isolate individuals from the chemical, physical and biologic hazards that may be encountered at a hazardous substance site.”
Because PPE can generate hazards of its own, such as heat stress, impaired vision or reduced mobility, OSHA recommends that PPE programs aim to protect the wearer from safety and health hazards, while preventing injury from the misuse of PPE equipment itself.
- Incident command system: This section requires the implementation of an incident command system. ICS is an organized approach to emergency incidents in which a senior official is in charge of a basic command post and delegates responsibility for various tasks to subordinate officers in the event of an emergency.
- Site safety and control plans: The safety and security of response personnel and others related to the emergency response must be the primary importance. Site safety and control plans must include a summary of on-site hazards and risks; site maps and sketches; work zone layouts; buddy system usage; hazard monitoring plan; and full, detailed decontamination procedures.
- Medical surveillance programs: When workers handle hazardous substances or are exposed to toxic, biologic or radiation-related hazards, a medical surveillance program is necessary to monitor employee health, provide emergency treatment and keep accurate records. In this section, OSHA recommends the Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities from the National Institute for Occupational Safety and Health (NIOSH) and a few other guides as references for medical surveillance programs that are up to snuff.
- New technology and spill containment programs: As new products enter the marketplace, new and modern methods for emergency response to hazardous products should be used alongside traditional techniques.
Wonder if your job site needs to meet OSHA regulations for hazardous materials. If the site contains any material that requires a Safety Data Sheet (SDS) the answer is yes.
OSHA Spill Containment Requirements
Outside of procedures, programs and safety training, some of OSHA’s spill containment requirements get a little more hands-on, such as the required inspection and labeling of drums and containers containing hazardous materials. Particularly related to the prevention, containment and cleanup of spills, OSHA-required measures include, but are not limited to:
- Drip pans must be kept under all drum faucets.
- Drip pans must be kept under all leaks.
- Large-diameter funnels must be used to transfer liquids into drums.
- Drum covers must be used to protect the integrity of drums stored outside.
- Movement of drums or containers of hazardous materials should be kept to a minimum to the extent feasible.
- EPA-approved ground-penetrating devices must be used for determining the location and depth of any improperly discarded drums or containers.
- When opening a drum or container, all equipment must be kept outside of the explosion barrier, and air-line respirators and approved electrical equipment must be protected from possible contamination.
- Only tools and equipment that prevent ignition shall be used when dealing with hazardous materials.
- Standing on or working from drums or containers is prohibited.
- Nonessential employees should be evacuated from transfer areas.
- Equipment operators require a barrier between themselves and potentially explosive containers.
- Containers exhibiting bulges, swelling or crystalline materials on the outside must not be moved until appropriate containment procedures are performed.
- Temporary work sites require a supply of tightly closed, clearly labeled potable water and a tap.
Still not convinced that the training needs to be in place?
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