Chemical Safety

Biennial Reports Are Due March 1, 2020!

 

If your facility is registered with the MA DEP as a Large Quantity Generator (LQG) of hazardous waste, don’t forget that 2020 is a year when biennial reports must be filed.  Biennial reports are due by March 1st of even numbered years for any facility that exceeded the LQG threshold during the preceding odd numbered year, even if your facility is no longer registered as an LQG.  Treatment, Storage, and Disposal Facilities (TSDFs) are also required to report every two years.

Biennial reports provide the DEP with information on the quantity and nature of the hazardous waste that was generated in the previous year and whether the waste was sent for recycling, treatment, storage, or disposal. As of 2018, biennial reports need to be filed electronically using the RCRAInfo Industry Application. The electronic submission includes the following:

  • RCRA Subtitle C Site Identification Form
  • Waste Generation and Management (GM) Form
  • Waste Received From Off-Site (WR) Form, and […]

How to Protect Your Company From OSHA HazCom Violations

Did you know that violations related to the OSHA Hazard Communication standard ranked #2 in the OSHA top 10 list for most frequently cited violations in 2018? Common citations included not having a written program or safety data sheets (SDS) for all chemicals, lack of employee training, and deficiencies related to secondary container labels.

What can you do to protect your company from HazCom violations? Employers are responsible for ensuring that the labels and SDSs are readily available to all employees.  They are also responsible for training employees on how to properly recognize the hazards associated with chemicals and how to properly handle the chemicals based on the hazards conveyed.  For laboratories that use chemicals this specifically means that employers must ensure that:

  • Labels on incoming containers of hazardous chemicals are not removed or defaced. Incoming container labels must include the identity of the hazardous chemical(s), appropriate pictograms and signal word, and hazard and precautionary statements.
  • Labels […]

Reconcile Safety Data Sheets

Be sure to reconcile the Safety Data Sheets at your facility to verify that you have an SDS for all hazardous chemicals present on site.

29 CFR 1910.1200 Appendix D stipulates the minimum information required to be contained on a SDS, and specifies each section number and heading.  Hazard identification, first-aid measures, proper handling and storage requirements, appropriate personal protective equipment, exposure limits, and toxicological information are all covered on a SDS.  Information on the likely routes of exposure, symptoms of exposure, and immediate and delayed effects from short-term and long-term exposure are reported.  All of this information should be known by each individual working with a particular chemical.

It is the responsibility of the manufacturer, distributor, or importer to provide a SDS for each chemical.  It is the responsibility of the employer to make a SDS for each chemical in the workplace readily available to all employees.  And it is the responsibility of each individual […]

OSHA Announces Safe + Sound Week 2019

OSHA has announced that Safe + Sound 2019 will be held August 12-18, 2019.  This national event is intended to promote the value of workplace health and safety programs.

OSHA is encouraging employers to share the safety successes they have enjoyed over the past year during this week.  Employers are encouraged to hold events and activities that highlight the elements of their health and safety program during this week.  Developing fun interactive activities can engage employees and remind them of the established policies in a creative way.  Even though it is a long way away, take advantage of the long lead time to develop daily activities to highlight the importance of your EHS program!  You have plenty of time to prepare and think about the daily themes to cover during this week.

Updated MA Law for Public Workplaces

The updated Law M.G.L. Chapter 149 § 6 ½ requiring public sector workplaces to comply with OSHA regulations went into effect on February 1, 2019.  While this is a significant change for public workplaces, OSHA does continue to have jurisdiction over private employers. The Massachusetts requirements found in this updated law are as strict as the OSHA regulations.

The update clarifies that the definition of public sector workplace includes counties, municipalities, all state agencies, quasi-public independent entities, courts, bureaus, commissions, divisions or authorities of the commonwealth, political subdivisions, and public colleges and universities.  The Massachusetts Department of Labor Standards is responsible for enforcing this law at public sector workplaces.

If you have not heard about this update, know that public workplaces are now responsible for complying with OSHA regulations.

 

 

Remember to Conduct Chemical Inventories

OSHA’s Hazard Communication Standard, 29 CFR 1910.1200 requires that employers maintain a list of the hazardous chemicals known to be present in the workplace.  While conducting chemical inventories, it is prudent to ensure that the SDS files are up to date for all chemicals found during the inventory.  The Lab Standard, 29 CFR 1910.1450, applies to laboratory scale use of hazardous chemicals, and requires the implementation of a Chemical Hygiene Plan.  The Chemical Hygiene Plan in place at your institution should specify how the chemical inventory will be maintained and how the SDS system works.

Safety Partners recommends conducting physical chemical inventories on an annual basis, at a minimum.  There are several chemical inventory barcode software systems available for companies choosing to maintain on-going chemical tracking.  These systems track chemicals from receipt to disposal, relying on the users to track their use using the barcoding system.  If a full bar coding system is not an […]

Making Safety Training Fun

“I Love Safety Training!”

Wait…what?  Have you heard many people utter these words before?

It is easy to say that the importance of developing an effective safety training program should not be overlooked, but how do you put a fun and therefore effective safety training program into practice?

Developing a robust new employee safety orientation that encompasses a safety tour of the facility and interactive sessions to demonstrate the safety policies will likely improve material retention.  If new hires are forced to sit through hours of lectures to cover material that checks the boxes for various regulations, the details will be lost in the myriad of information given to them on their first day at a new job.  Encourage questions, ask questions, and get to know the new hires’ previous experiences with safety.  Start to build trust that a collaborative environment will be fostered from day one.

Even though annual refresher trainings are mandatory, this does not mean […]

Gap Analyses Benefit Everyone

If you have never conducted a gap analysis or if it has been some time since the last one, consider investing in this invaluable process.  Even if you have established a robust program, a gap analysis can provide input into what areas could use improvement or redefined focus.

A gap analysis should start with a thorough review of your EHS needs and an evaluation of the regulatory standards that are applicable to your site based on the work being conducted. This should include taking a deep dive into the hazardous materials present and how they are being stored, manipulated, and disposed of. When reviewing compliance with permit and license requirements, consider any permits or licenses that may have been overlooked due to changing needs or regulatory updates.

Gap analyses almost always produce a list of action items. Nice to have or do items that fell off the radar may be re-identified during the gap analysis and […]

Reporting Year 2018 Tier II Reports Due March 1, 2019

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The Emergency Planning and Community Right to Know Act (EPCRA) is authorized by Title III of the Superfund Amendments and Reauthorization Act (SARA).  In an effort to keep communities aware of the hazardous chemicals present at facilities exceeding certain thresholds, Section 311 and 312 of EPCRA stipulate requirements for the reporting of hazardous chemical storage.  These reporting requirements allow State and Local emergency response and planning committees to be aware of the hazardous materials present within their jurisdiction.

Facilities that possess more than 500 pounds of an extremely hazardous substance (EHS), 10,000 pounds of any other hazardous chemical, or greater than the threshold planning quantity (TPQ) for a chemical at any time during the year, are required to file a Tier II report annually.  40 CFR 355 codifies the chemicals that are considered extremely hazardous substances, and the EPA publishes the List of Lists that can be referenced to find TPQs.

If a full EPCRA applicability review of the hazardous chemicals […]

January 30th, 2019|Categories: Insights|Tags: , , |

Be Prepared for Chemical Spills

 

Do you know how to determine if a spill is controlled or uncontrolled?  If a hazardous chemical was spilled in your lab right now, would the researchers know if they could clean it up themselves or not?  Do you know what measures to take to handle a controlled or uncontrolled spill scenario?

There are many factors to consider when evaluating spill situations and planning for emergency response. 

Generally speaking; a controlled spill is a spill that can be cleaned up with a buddy, using the contents of the spill kit readily available. It also poses little risk to the health and safety of the knowledgeable personnel cleaning the spill and there is no risk of an environmental release.

An uncontrolled spill poses risk to the personnel involved in spill clean-up and/or has the potential risk for release to the environment.

There may also be a risk of fire or explosion or a reaction.

Because of the potential risks […]