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Introduction Many operations and activities conducted at Air Force bases require the use of products containing hazardous chemicals. The use of these products often generates wastes that are also hazardous. In order to protect workers, the public, and the environment from exposure to these hazards, it is critical that these products and wastes be used and managed in a safe manner. This requires knowledge on the part of personnel handling these materials, who must be aware of which materials are hazardous, what the hazards are, and how to prevent releases, accidents, and exposures. There are numerous Federal and State regulations that are designed to ensure personnel have this knowledge. This fact sheet covers the basic information requirements for managing hazardous products and hazardous wastes, including the transportation of hazardous wastes, with specific emphasis on packaging, labeling, marking, and paperwork requirements.
Products Containing Hazardous Chemicals Hazardous Chemicals While some products are clearly dangerous, most seem relatively harmless under normal conditions. Unfortunately, common sense is not always an adequate guide in determining the hazards posed by many products. The Occupational Safety and Health Administration (OSHA) assists workers in obtaining the information they need to accurately assess the hazards associated with the materials they work with. OSHA has defined a hazardous chemical as any chemical which is a physical hazard or a health hazard (Title 29 of the Code of Federal Regulations (CFR) Part 1910.1200). OSHA has further defined the criteria for physical and health hazards: If a chemical is a physical hazard, then there is scientifically valid evidence that it is a combustible liquid, a compressed gas, explosive, flammable, an organic peroxide, an oxidizer, pyrophoric, unstable (reactive), or water-reactive. These chemicals are capable of physically damaging tissues through heat, pressure, or chemical reaction. Chemicals that pose health hazards may cause either acute or chronic effects on the health of exposed employees. These chemicals include carcinogens, toxic or highly toxic agents, reproductive toxins (mutagens and teratogens), irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, agents which act on the hematopoietic system, and agents which damage the lungs, skin, eyes, or mucous membranes. A single study conducted in accordance with established scientific principals which provides statistically significant evidence for health effects is enough to warrant classifying a chemical as a health hazard. It is the responsibility of the chemical manufacturer (or importer) to conduct the required scientific testing to determine if a chemical poses a physical or health hazard. The end user is not required to make this determination. OSHA has also established criteria for hazardous chemicals in mixtures. Products which contain a hazardous chemical at a concentration greater than one percent (by weight or volume) are regulated as hazardous chemicals, unless testing of the mixture as a whole has shown that it is not a physical or health hazard. If a constituent chemical is classified as a carcinogen, and is present at a concentration greater than 0.1%, then the mixture is assumed to present a carcinogenic hazard. There are a number of important exemptions from the hazard communication standards promulgated by OSHA. These exemptions are listed in 29 CFR 1910.1200(a)(6), and include: hazardous wastes, tobacco products, wood products, most foods and drinks, medicines and cosmetics, consumer products used in a duration and frequency of exposure not greater than what consumers experience when using the product. Additionally, articles, manufactured items (not fluid or particle) formed to a specific shape or design during manufacture (where the shape or design is integral to their use), and which do not release more than trace amounts of hazardous chemicals during normal use are exempt from 29 CFR 1910.1200 requirements. If installation personnel are uncertain about the applicability of the standard to a particular product, they should contact Bioenvironmental Engineering.
The OSHA Hazard Communication Standard
Labeling Requirements
Material Safety Data Sheet (MSDS) Requirements
The preparation of MSDSs is the responsibility of the chemical manufacturer or importer. According to 29 CFR 1910.1200 (g) (6), chemical manufacturers must provide the MSDS with the first shipment of the hazardous chemical, and with the first shipment made after the MSDS is revised. The chemical manufacturer must also provide the MSDS upon request. It is the responsibility of the installation to request a MSDS if one is not provided with the initial shipment. If the installation has lost an MSDS, or has illegible copies, a new MSDS must be requested from the manufacturer or distributor.
Installations must maintain copies of MSDSs for each hazardous chemical in the workplace, and must ensure that they are readily accessible to employees when they are in their work areas. It is not sufficient to have a central collection of MSDSs where employees must leave their work area to view them. Paper copies of the MSDS are not required if electronic access, microfiche or another alternative format exists and does not create any barriers to employee access in each work area. If employees must travel between work areas during a shift, MSDSs need only be kept in the primary work area, provided that there is immediate access to them in an emergency. It is permissible to change the form of a MSDS to include them in operating procedures or manuals, and they may be designed to cover groups of hazardous chemicals where it may be more appropriate to address the hazards of a process. Again, the information must be complete and readily accessible. MSDSs must be provided upon request to OSHA inspectors.
Employee Information and Training Requirements
Installations must inform each employee of the training requirements of 29 CFR 1910.1200 (h); any operations in their work area involving hazardous chemicals; and the location and availability of the written hazard communication program, the list of hazardous chemicals, and the required MSDSs.
After generation, hazardous wastes are transferred to either containers, most commonly 55-gallon drums, or tanks. This transfer typically takes place at or near the point of generation in an area known as a satellite accumulation point. When the container is full, it is then transferred to an accumulation site. Different regulations apply to the containers at the satellite points and accumulation sites.
Initial Accumulation (Satellite) Points
The containers being filled in an initial accumulation point must be in good condition, compatible with the wastes, and kept closed except when waste is being added to the container. Each container must be labeled either with the words "Hazardous Waste" or with other words that identify the contents of the container. It is good management practice to include both of these on the label. Within three days after the volume limit for the initial accumulation point is reached, the container must be transferred and marked with the date that the volume limit was reached. This date is the beginning of the 90-day accumulation period for large quantity generators of hazardous wastes.
Containers in Accumulation Sites (90-Day Storage Area)
In addition to these requirements, accumulation sites are required to have a containment system which includes: an impervious base free from cracks or gaps; a means of draining and collecting precipitation and leaks and spills; a capacity to hold 10% in excess of the combined volume of all the containers or the volume of the largest container, whichever is greater; and a means of preventing run on into the containment system or the capacity to contain all of the run on. As a good management practice, large and small quantity generators should adopt these measures for their accumulated sites to minimize the potential for releases.
After transferring containers from the initial accumulation point to an accumulation site, requirements for managing the containers become somewhat more rigid. The containers must be tightly sealed, and they must not be leaking, bulging, rusting, or badly dented. The containers must be compatible with the wastes, and containers of incompatible wastes must be separated. If a container was used previously, the waste must not be incompatible with the former contents and residue in the container. The containers must be stored in a manner that allows for access for inspection and emergency response, and they must be moved about and handled in a safe manner. Containers should not be stacked more than two high, and have pallets between them. Containers of highly flammable wastes must be electrically grounded. At least three feet of aisle space should be provided between rows of containers. Containers holding ignitable or reactive wastes must be placed at least 50 feet from the installation property line.
The EPA has recently codified additional requirements for containers of volatile organic hazardous wastes in order to control air emissions. These containers are required to be closed with covers that permit no detectable organic emissions. Volatility testing for each waste is required, or the cover must meet Department of Transportation (DOT) standards. If the covers are equipped with safety devices for venting, there must be no detectable emission, and they must be kept closed except when inspecting the container or adding waste. Routine venting is not permitted.
All containers in accumulation sites must be marked with the words "Hazardous Waste." The accumulation start date (the date the container reached the 55-gallon limit for satellite accumulation and was required to be transferred to the accumulation site or storage area) must also be on the label.
Containers or liners that contain residues of materials that are hazardous wastes when discarded are subject to all the above requirements, unless the containers meet the RCRA standard as "empty" as defined in 40 CFR 261.7. A container or liner is empty if all materials that can be removed through normal procedures (pouring, pumping, etc.) have been removed, and the residue is less than 1 inch deep or is no more than 3% of the total original weight (0.3% for container over 110 gallons). If the material is an acutely hazardous waste, the container or liner must be triple rinsed with an appropriate solvent or cleaned with an equivalent method.
Tanks Used to Accumulate Wastes
Container Requirements
Labeling and Marking
The EPA further requires that each container be marked with the following words and information (40 CFR 262.32 and 49 CFR 172.304):
HAZARDOUS WASTE Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.
Generator's Name and Address:
________________________________________
Manifest Document Number:
________________________________________
Commercially available stickers include these requirements, and have spaces for the DOT marking requirements, the EPA waste codes, and the accumulation start date. These stickers are generally applied when the container is first transferred to the accumulation area, well before transport off base. Some States have additional unique marking requirements that must also be met.
The DOT has additional marking requirements described in 49 CFR 172.301 and 172.302. These include the Proper Shipping Name of the waste (see 49 CFR 172), and the appropriate United Nations (UN) or North American (NA) 4-digit identification code (see Table 172.101). These markings are also required for bulk shipments in tankers.
Shipping Papers
The manifest may be used to ship more than one type of waste, but the form must include the Proper Shipping Name, Hazard Class, ID Number, EPA waste codes, and Emergency Response Guide Number for each waste. The number and type of containers, and the total quantity of each waste must also be included on the form. This information must match the markings and labels on the containers, and must include all the waste streams and account for the full volume of the wastes.
The EPA also requires that Land Disposal Restriction (LDR) notification forms accompany the hazardous waste manifests (40 CFR 268.7). These forms are intended to inform the destination TSD facility of the appropriate treatment standards for the wastes required prior to land disposal. If no treatment is required, the form includes a signed certification to that effect.
Waste Hauler Requirements
In addition to general transporter requirements listed in 49 CFR 171 to 179, waste haulers must display the appropriate placards on each side and end of the vehicle. The placards must meet detailed DOT specifications and correspond to the wastes being transported. If more than one waste type is in the shipment, the transporter may include all the appropriate placards or use the "DANGEROUS" placard (49 CFR 172.504).
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