Practical Facility Management of Hazardous Chemicals
Proper management of hazardous chemicals is often overlooked by team members using a chemical, with management assuming proper information of hazards was communicated. Agency requirements for handling storing and reporting are an additional complication because it is not always known which agency requirements apply. Environmental requirements depend on the regulating program including Superfund Amendment and Reauthorization Act, (SARA) Clean Air Act (CAA), Emergency Planning and Community Right to Know Act (EPCRA) or others. Agency regulations also often defer to industry standards published by organizations like the National Fire Protection Association (NFPA), American Petroleum Institute (API) and others. Chemical hazards must be summarized in a Safety Data Sheet (SDS). The SDS summarizes various important information that is used to properly manage chemicals. Some summary information on practical facility management of hazardous chemicals are presented below.
The agency requirements depend on where the chemical is. The table below provides a good preliminary understanding on which agency requirements apply.
|Facility||Occupational Safety and Health Administration (OSHA)|
|Fence Line||Department of Homeland Security (DHS)|
|Offsite||Environmental Protection Agency (EPA)|
|Roads, Rails, Transportation||Department of transportation (DOT)|
While the above table is a good summary, there are some additional cross-over requirements. OSHA requirements are well understood unless the chemical exceeds certain threshold quantities that requires Process Safety Management (PSM). PSM is another more complex regulatory requirement for chemicals listed in 1910.119 App A – List of Highly Hazardous Chemicals, Toxics and Reactives. Tier 2 reports must be submitted for certain hazardous chemicals with an SDS stored onsite greater than 10,000 pounds and Extremely Hazardous chemicals over agency required amounts to state environmental agencies, Local Emergency Planning Committees (LEPC’s) and local fire departments. US EPA publishes a summary document titled, “List of Lists,” for certain chemicals that is very helpful identifying EPA regulatory requirements. Chemicals used for food production do not always need to be listed on a Tier 2. Other EPA reporting requirements to be aware of for example, include the CAA for Risk Management Plans (RMP) or 313 reports. The important nexus to understand is EPA requires these reports for chemicals stored and/or used on site that could potentially get offsite.
Chemical hazards can usually be grouped into two practically facility understandable categories:
- Hazardous chemicals that have been used for years with the hazards sometimes taken for granted because of the common use without any accidents.
- New hazardous chemicals often used to replace or add to a process where the unfamiliarity and disclosures on a SDS throws up a red flag to team members.
Hazard Communication (HazCom) is an OSHA requirement where all team members must be trained on use of hazardous chemicals. Experience indicates that team members handling a hazardous chemical daily know some of the hazards related to their specific use while others peripherally engaged may lack knowledge. For example, is the hazardous chemical handled correctly at the loading dock, transit from the loading dock to the storage or end use? Storage includes all aspects once the hazardous is unloaded or its end use.