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Minimizing Risk, Maximizing Safety
Fluorescent lamps, refrigerants, paints, solvents and pesticides are just a few of the many hazardous materials in institutional and commercial facilities that pose health threats to occupants, employees and visitors. Because of these threats and growing scrutiny by law enforcement, hazardous-materials management is becoming a higher priority for managers.
Recent advances in the use of environmentally friendly products, combined with mounting regulatory attention to hazardous materials, have made proper management of these products a top priority. Managers who take proactive steps in managing hazardous material use are in the best position to evaluate options for minimizing risks they pose.
Evaluating the purchase, storage, use and disposal of hazardous materials in a facility not only makes good common sense. It also makes good business sense. Managers can ensure the success of this process by understanding their options for managing, reducing, or eliminating hazardous materials in all phases of operations.
The federal government has reclassified several categories of hazardous materials and wastes as universal wastes. These changes have streamlined the standards for hazardous- waste management for the federal universal wastes, including batteries, pesticides, thermostats, and lamps.
In August 2005, mercury-containing equipment became a new universal waste category. Among the many products in this new category are switches, barometers, meters, temperature gauges, pressure gauges, and sprinkler-system contacts.
Institutional and commercial facilities that generate hazardous waste that falls into federal universal waste categories can use the more streamlined requirements under the universal waste rule (UWR). The rule eases the regulatory burden on organizations that generate these wastes.
Specifically, the UWR has streamlined requirements for notification, labeling, marking, prohibitions, accumulation time limits, employee training, response to releases, offsite shipments, tracking, exports, and transportation.
Managing hazardous materials has several preferred levels — prevention, reduction, recycling, and evaluation and management.
Prevention. This method is preferred for reducing the total amount of hazardous waste within a facility. Prevention addresses the design, purchase, manufacture and use of products and materials as a way to eliminate the amount or toxicity of solid waste generated.
Many examples exist of products and industries in which potentially harmful chemicals and materials have been phased out in favor of more benign materials. Prevention has many positive environmental effects, including the production of wastes with lower hazard potential.
Source reduction. When managers cannot eliminate hazardous chemicals, the next preferred option for managing these materials and wastes is reduction. As with prevention, this step involves the design, purchase, manufacture and use of products and materials that reduce the amount or toxicity of solid waste generated. Both prevention and source reduction actually reduce the amount of material used and, as a result, the amount discarded.
Recycling. Even after managers have reduced the amount of hazardous chemicals in facilities, they still must deal with generated wastes. Recycling aims to further reduce hazardous wastes once they are created. The U.S. Environmental Protection Agency (EPA) has developed regulations for waste recycling to promote the reuse and reclamation of useful materials in a way that is safe and protects health and the environment.
Under the hazardous-waste recycling regulations, materials that are recycled may be: excluded from the definition of solid waste and fall completely out of the requirements under the Resource Conservation and Recovery Act (RCRA); subject to less-stringent regulatory controls; or required to comply with the full universe of hazardous-waste treatment, storage and disposal regulations.
Excluded hazardous wastes can be recycled and reused. Therefore, they are no longer considered waste. Among the most typical examples of these materials are lead and mercury. Other materials are specifically excluded from the definition of solid waste or hazardous waste. These exclusions are found in the federal regulations at 40 CFR §261.4 and can be industry specific.
Materials subject to less stringent rules include universal wastes, used oils, and spent lead-acid batteries. For those materials not specifically excluded or subject to less-stringent standards, full hazardous waste regulations might apply. The requirements for facilities that store or recycle hazardous wastes are outlined in 40 CFR §261.6.
Evaluation and Management
The first step in managing and reducing hazardous chemicals and wastes is to perform an inventory. Workers can perform these inventories by area, department or operation. Managers should maintain material safety data sheets (MSDS) on hazardous substances in buildings. Creating an inventory offers a good opportunity to make sure MSDSs are available and appropriately filed.
Managers also should review chemicals used in their departments and during maintenance activities. The first step is to generate a list of chemicals purchased for use in the department.
Next, perform a walk-through of each department, focusing on storage areas, tool kits and carts. Once inspectors have identified chemicals, they should obtain and review all MSDS to determine if the chemicals are hazardous.
Next, they should review hazardous chemicals to make sure:
• labels clearly identify original product names, or full chemical names, and hazards
• containers of all non-hazardous substances, such as water, are labeled explicitly in order to avoid confusion
• incompatible chemicals, including solids, are segregated by U.S. Department of Transportation hazard classes
• segregated liquid chemicals are kept in secondary containment
• hazardous materials are not stored next to or above sinks
• containers are capped and sealed, except when actively adding or removing materials
• flammable liquids, including liquid wastes, are not stored outside of a storage cabinet if more than 5-10 gallons
• employees have completed hazard communication training
• full-sized compressed gas cylinders are chained or strapped one third of the way up the container and two-thirds of the way up the container.
Once inspectors have identified hazardous chemicals and wastes, managers must ensure workers properly label and store these items. Among the most common problems generally noted with hazardous materials and wastes are these:
• The inventory is not up to date.
• The label is missing or is not complete.
• The labeling of hazardous materials and chemicals is insufficient. Chemical containers must be labeled legibly with the full chemical or trade name.
• Hazardous chemicals used in laboratories do not have secondary containment. The secondary containment area should be free of spilled material.
• Technicians fail to recognize and separate incompatible hazardous materials.
Hazardous wastes have been regulated for 25 years under RCRA. In this time, waste-management practices within facilities have improved tremendously.
The uncontrolled dumping of hazardous industrial wastes has decreased dramatically, the number of facilities that handle hazardous wastes has shrunk by about one-half, and post-consumer recycling rates have risen dramatically during these years.
But the number and amount of human-made chemicals that are produced, used and disposed of has increased dramatically over the past several decades. This trend is expected to continue, and it is likely that advances in chemistry, biology and other fields will create tens of thousands of new chemical compounds, and many of these materials will be derived from genetically engineered organisms.
While many of these products represent important improvements, some of the new substances undoubtedly will have the potential to cause harm to human health and ecological systems. The knowledge of risks posed by new chemicals is not likely to keep pace with their development.
For example, nanotechnology is an evolving field in which extremely small particles are used in coatings, lubricants, pesticides, biocides and other products. The EPA is researching how to regulate the more toxic forms of this emerging technology.
The EPA also has identified three areas where managers can expect hazardous-waste regulations to impact them:
• reducing the volume of waste generated
• preventing exposure hazardous chemicals among humans and in the ecosystem
• managing wastes and clean-up chemical releases in a safe, environmentally sound manner.
Regulators especially are emphasizing the reduction of the volume of wastes generated. Evidence of this effort includes the EPA’s reclassification of hazardous wastes as universal, as well as the promotion of waste reduction and recycling.
Risks created by a hazardous chemical can occur at any point in its life cycle, regardless of whether it is considered a product, raw material, or waste. Hazardous forms of materials and wastes have properties that are inherently dangerous or potentially harmful to human health or the environment.
But by paying proper attention to the problem and using proactive and comprehensive management strategies, managers will be able to eliminate, reduce and recycle hazardous chemicals, resulting in reduced operating costs and safer workplaces.
Jeffery C. Camplin — firstname.lastname@example.org — is president of Camplin Environmental Services Inc. in Rosemont, Ill. He is a certified safety professional, certified professional environmental auditor.
The North American Hazardous Materials Management Association (NAHMMA) is an established group of hazardous materials management professionals founded in 1993.