Make a List, Check it Twice
Managing hazardous materials in institutional and commercial facilities has become a higher priority in recent years. Thee change comes as federal, state and local authorities have stepped up both inspections of facilities’ hazardous materials management activities and enforcement efforts. Maintenance and engineering managers often find themselves at the center of organizations’ efforts to more effectively manage these materials because of the nature of their activities and their knowledge of facility operations.
Taking control of the issue begins with knowing on-site materials that require closer attention. By identifying and cataloging all hazardous materials, and monitoring their use, storage and handling, managers can develop strategies that incorporate online resources and training requirements to protect building occupants, workers and the public from hazardous materials.
About three-fourths of hazardous material releases occur at fixed sites, and one-fourth occur during transportation. Data from a study by the U.S. Environmental Protection Agency (EPA) of nearly 7,000 release incidents showed that 50 percent of the releases involved less than 1 percent of the chemicals. In order of incidents, these chemicals are polychlorinated biphenyls, sulfuric acid, anhydrous ammonia, chlorine, hydrochloric acid, sodium hydroxide, methanol/methyl alcohol, nitric acid, toluene, and methyl chloride.
While chlorine ranked fourth in this study, it accounted for the most human fatalities.
While most of these occurrences occurred in the chemical and petroleum industries, they accounted for only 30-35 percent of releases. Large numbers of incidents occurred in commercial, government and private-industry operations.
Depending on a facility’s location, size, purpose and surrounding community, other threats might exist, including those associated with asbestos, lead, dioxin, insecticides, and hydrocarbons containing volatile organic compounds (VOC). This is all the more reason for maintenance and engineering managers to take a closer look at not only materials in an in-house inventory, but also those in the neighbors’ inventory.
Catalog, Monitor, Store
The hazard communication standard from the U.S. Occupational Safety and Health Administration (OSHA) contains the following requirements:
- Material inventory. Record and communicate all hazardous materials.
- Material safety data sheets (MSDS). All MSDS must be accessible to employees for all hazardous materials.
- Labeling. Label all materials properly.
- Training. Provide hazardous material training to all employees, complete with testing and certification.
- Written program. Combine these features to develop an integrated program.
One particular challenge posed by the millions of chemicals being manufactured and distributed to facilities occurs because the same chemical often is sold under a variety of different names. At fixed sites, plans to control hazardous materials must include not only the material’s use but also its transportation within the site, handling, storage and disposal. Accidental release could occur during any one of these activities over the life of the product.
These two conditions suggest a strategy for cataloging, as well as monitoring the use, storage and handling of materials.
First, managers must be able to identify and catalog not only the chemical that is present, but also all similar products, including the specific manufacturers and the product brand names that apply.
Second, managers must have a plan to monitor, record use, handling and applying the material safely during all stages. Also, plans that are carefully and thoroughly thought out — and that are specifically designed for each type of material — must exist for dealing safely with spills, fires or other accidents.
A proper approach to the inventorying of all the materials on hand can satisfy both of these needs. “All” means not just the chemicals someone believes are hazardous or that are obviously hazardous, but all materials.
If an inventory management system exists, this a good place to start by printing an item list to help define the hazardous materials. Some verification also should be done during this phase because the materials database might not be entirely up to date.
Once inspectors have identified all the material and updated the hazardous material inventory, the next step is to verify quantities on hand, container sizes, storage locations, manufacturer names, product contents and product brand names.
With the product information at hand, workers can check the MSDS database or catalog and locate an MSDS for each product. If a facility contains two different brands of the same basic product, the system must have two MSDS.
For some time, manufacturers have been required to issue these information sheets with each product, but many do not automatically provide them. Product specifiers have to request them, which usually can be done easily through an automatic fax-back arrangement. A good practice is to have the purchasing department place a line item for an MSDS on the purchase order and have it delivered with every new product purchased. This step ensures the hazardous material inventory stays up to date.
An MSDS is particularly effective for planning a hazardous materials program beyond the inventory stage. At an OSHA-required minimum, it contains the following information sections as:
- Chemical name, chemical formula, common synonyms, chemical family, manufacturer name, and manufacturer’s emergency phone number. Some sheets also contain hazard information in this section.
- Hazard ingredients and regulatory exposure limits, such as parts per million considered safe for humans.
- Physical properties, such as the freezing point and melting point.
- Fire and explosion hazards. Data given include the flash point — the temperature at which the product bursts into flame — and extinguishing means, such as water or carbon dioxide.
- Health hazards. This information aids in selecting proper personal protective equipment, such as respirators, face shields, and gloves.
- Reactivity data, or how the chemicals react with other materials.
- Spill or leak procedures, essential for developing emergency action plans.
Since the required format and contents are not very specific, managers can benefit from some proactive contact with local manufacturers or representatives. In some cases, managers might need to supplement the standard MSDS information with additional data based on how the organization plans to use the product and its characteristics under site-specific conditions.
In 2003, ANSI MSDS Z400.1 expanded the OSHA format by adding 16 sections containing information on such topics as guidelines for documenting transportation, ecological data, and toxicological data.
Containers with defaced, lost or changed labels or containers that were used without changing the label pose particularly large risks. Risk management here begins with making sure that label contents are complete, securely attached and protected and clearly state the policy of using containers only for their original purpose.
A comprehensive hazardous materials management program also must include a proper medical plan. This plan begins with pre-employment screening and includes periodic medical exams. It is essential that managers know if workers have pre-existing conditions, such as asthma or other respiratory problems, that would make the permissible exposure limits set by OSHA and contained on the MSDS for certain chemicals too high for these individuals.
The medical plan also would contain standard procedures for treating emergency and non-emergency incidents, maintaining complete and accurate medical records of exposure, and review and audit practices that will keep the plan up to date as regulatory or material coverage changes occur.
For managers who don’t believe their employees need training for hazardous material management, consider one recent troubling incident. Hospital housekeeping workers put paint thinner in empty containers with labels for antiseptic soap. Subsequently, others saw the soap label and used the paint thinner to clean surgical instruments for some time before the switch was detected. While neither material is particularly hazardous, accidental use for a purpose not intended poses a serious health threat.
Since managers are the matter experts about what materials facilities contain and how workers use them, managers must customize hazardous material training to minimize the chances of accidents such as this one from happening. Representatives from every department should contribute information about chemicals they use and how they use it. If none speaks up for some chemicals contained in the inventory, dig deeper for the users. Otherwise, recycle or properly dispose of these items so they don’t become a future hazard looking for a place to happen.
Agencies that are recommended for obtaining information on specific hazardous materials and HazMat training programs are U.S. Centers for Disease Control and Prevention, OSHA and EPA. These groups have their own training course information, course material, instructors and links with other similar groups.
Most course providers have in-house, in center, distance learning, instructor-led classroom courses, and self-paced materials and courses. Some demonstrations, course materials, freeware and course development tools also are available.
Finally, managers can consider the benefits of “train the trainer” courses for developing customized in-house training courses for hazardous material management.