Training Spotlight: Hazardous Materials
By Jeffrey C. Camplin - September 2007
Regulations governing the storage, handling and disposal of hazardous materials are increasingly complex. From paint solvents and pesticides to laboratory chemicals and cleaning supplies, organizations must account for and handle these materials properly to ensure the safety of staff and building occupants.
The most effective way to address these concerns is to implement an environmental management system (EMS). An EMS helps organizations comply with regulations consistently and effectively. It also can help managers identify and capitalize on environmental opportunities that go well beyond compliance.
Training Strategies
A major component of an EMS is employee training and competency related to hazardous materials and wastes. While managers tend to focus on regulatory compliance as the main reason for providing employee training, two other important reasons exist for doing so.
First, every employee can have a potential impact on the environment. Second, any employee can have good ideas about ways to improve environmental management efforts. Maintenance and engineering staff members should be aware of their organization’s environmental policy. This basic awareness includes understanding the significant environmental impact of work activities, key environmental roles and responsibilities, procedures that apply to their work, and the importance of complying with environmental regulations.
Employees also should understand the potential consequences of not following environmental regulatory requirements, including those that result from spills, releases, fines and other penalties.
Evaluating Needs
Because training can require a significant investment of time, money and effort, managers should not start from scratch. An important initial step in developing an environmental training program is assessing workers’ skills and competency, and then identifying training needs.
Managers can start by looking at an organization’s existing training. Such training efforts can go a long way toward satisfying the requirements of an EMS.
Training usually addresses hazard communications, fire safety, emergency response, bloodborne pathogens, integrated pest management and confined spaces. Many employees might meet EMS requirements based on their work experiences. EMS competencies acquired through on-the-job training often include:
- handling leaks and spills from boilers, tanks and other equipment
- filling out a waste manifest form during special and hazardous-waste pickups
- disposing of all used oils, paints and batteries
- identifying less-hazardous materials to substitute hazardous items used in lighting systems and in cleaning
- investigating odors and smells.
Maintenance workers learn to perform many environmentally related jobs over the course of their work, and managers need to identify and capture all of the formal and informal training that employees receive on the job related to these activities.
Implementing an EMS ensures that all employees receive the same documented training and skills for all environmental issues, but formal training is not the only way to deliver environmental knowledge to employees. Managers have many alternative methods, including newsletters, intranet, e-mail, staff meetings, bulletin boards and brown-bag lunch discussions.
Information to be communicated with employees should cover hazardous material storage, spill response and leak detection, and safe handling. Other topics include exposure monitoring and the use of personal protective equipment as well as recycling and waste disposal.
Broader Compliance
Managers should understand the role of regulatory compliance in developing an EMS and providing worker training. Most managers focus on the broad and confusing requirements of the U.S. Environmental Protection Agency (EPA) for environmental training needs.
This focus is appropriate for some categories of hazardous materials because the EPA has numerous regulations covering spills and emissions. Be aware, however: The agency also has rules for categorizing and disposing of solid and liquid wastes. Among the EPA’s regulations with which managers must be familiar are:
- Emergency Planning and Community Right-to-Know Act (EPCRA) Section 302, related to extremely hazardous substances
- EPCRA Section 313, related to toxic chemicals
- Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), related to hazardous substances
- Clean Air Act (CAA) 112(r), pertaining to regulated chemicals to prevent accidental release.
Most requirements for training related to hazardous materials are found in worker protection standards from the Occupational Safety and Health Administration (OSHA). Some standards relate to: hazard communications; laboratory safety; exposure to asbestos, lead, cadmium, formaldehyde and other toxic materials; compressed gases; process safety management; hazardous waste operations and emergency response (HAZWOPER); and bloodborne pathogens.
Institutions defined as hazardous-material employers must comply with specific training requirements found under the federal hazardous materials regulations at Title 40 of the Code of Federal Regulations (CFR) 173.1. A hazardous materials employer is defined as a company that uses one or more employees in connection with transporting hazardous materials in commerce, causing hazardous materials to be transported or shipped in commerce, or representing, marking, certifying, selling, offering, reconditioning, testing, repairing, or modifying packaging.
For more information on developing an EMS, as well as additional regulatory resources, see the accompanying article.
Managers can be overwhelmed with training and regulatory requirements that pertain to environmental issues in their facilities. Developing a strategic and comprehensive approach provides structure and formalizes the process for evaluating and managing environmental issues related to hazardous materials.
Jeffery C. Camplin, CSP, CPEA — mundycamp@aol.com — is president of Camplin Environmental Services Inc. in Rosemont, Ill.
Hazmat Issues and Resources
Information is essential in developing and implementing a successful environmental management system, and managers can tap into an array of web sites offering information to get the process started. For example, managers can learn more about the structure and content of an EMS at www.epa.gov/OW-OWM.hmtl/iso14001/emsrepor.pdf. Among the other important topics and resources are these: |
