Is your Hazard Communication Program up to date? We visited a manufacturing plant with several people dedicated to the environment, health and safety efforts. And they had a lot to be proud of. They also had a Hazardous Communication Program (HazCom), but it had not been reviewed recently. Reviewing your written plans periodically is more important than you might imagine.

 

Does your company need a HazCom Program?  Manufacturers use a variety of chemicals; sales, servicing, and use of auto/truck/forklift batteries involves sulfuric acid and lead; laboratories store and use many chemicals, including solids, liquids and compressed gases; and drycleaners typically use tetrachloroethylene (also called PERC) or other cleaning chemicals to name just a few examples where a hazard communication program is required.

Since the mid-1980's, OSHA has required employers to provide hazardous communication to employees: information regarding the hazards of the chemicals they work with or may contact and how to protect themselves (also known as the "Right-to-Know" requirement). 

In order to achieve a safer working environment and comply with OSHA, the implementation of a HazCom Program is mandatory when employees are or have the potential to be exposed to hazardous chemicals.  A HazCom Program assists the owner/operator to avoid potential citations, violations, and related compliance costs. HazCom is among the first programs OSHA looks for when they audit a facility and one of the top 10 most often cited violations. 

 

A successful HazCom Program is more than a bulletin board notice or sign.  Its main purpose is to ensure that the hazards of all chemicals located in the facility are assessed, that all information regarding the potential for physical and/or health hazards associated with those chemicals is conveyed to the employees, and that employees know how to protect themselves.  It is the owner/operator's responsibility to comply with OSHA and to provide this information and training to each employee. The HazCom Program should be clearly written, comprehensive, and include lists of hazardous materials in every work area, material safety data sheets (MSDS) for each, container labeling, and other key employee information and training. 

 

Regardless of the level of care when handling chemicals, there is the potential for spills or leaks.  By having a HazCom Program in place, with trained employees who understand it, a business reduces significantly its risk of serious injury and potential contamination from spills or leaks.

 

If you need assistance in developing, preparing or implementing a HazCom Program contact GEC at 781-356-9140, ext. 112.

 

 

UST Regulations

Approximately 7,000 new UST releases are still discovered each year, mainly because of poor operation and maintenance. Although releases from tanks are less frequent, releases from piping, spills and overfills associated with deliveries are a common problem, especially at the dispenser. EPA says data show that release detection equipment only detects about half the releases they are designed to detect.

 

Revisions to the regulations were adopted by Massachusetts in February 2012. Claiming sensitivity to the future costs of operating USTs, EPA minimized requirements for retrofitting existing UST systems while focusing on proper operation and maintenance of equipment. However, new UST systems will be subject to additional release prevention requirements.

  

UST Operator Training

Effective August 8, 2012 operators of underground storage tank systems must designate a Class A, B, or C, operator capable of and knowledgeable about the tanks, piping, leak detection and alarms, spill prevention, emergency procedures, registration, and reporting (310 CMR 80.02). Training and certification requirements are also outlined.

 

Secondary Containment

EPA proposes that owners and operators install secondary containment (including interstitial monitoring) for new or replacement tanks and piping installed after the effective date of the final UST regulation. However, EPA is not proposing secondary containment for suction piping nor piping associated with field-constructed tanks or airport hydrant fuel distribution systems.

 

Under the proposal, secondarily contained tanks and piping must meet certain performance standards and be monitored for a leak at least once every 30 days using interstitial monitoring. In addition, pressurized piping must have an automatic line leak detector.

 

Under-Dispenser Containment

The proposal requires under-dispenser containment (UDC) beneath new dispenser to prevent dispenser system leaks from reaching soil or groundwater. A dispenser system is considered "new" when both the dispenser system and equipment needed to connect the dispenser system to the UST system (e.g., check valves, shear valves, unburied risers or flexible connectors, or other transitional components beneath the dispenser that connect it to underground piping) are installed. UDC must be liquid tight and allow for visual inspection and access to the components in the containment system, or must be continuously monitored for leaks from the dispenser system.

 

Operation and Maintenance

EPA proposes documented, monthly walkthrough inspections to verify that UST system components, including the following, are being properly operated and maintained: spill prevention equipment; sumps and dispenser cabinets; monitoring/observation wells; cathodic protection; and release detection. Walkthrough inspections must follow an inspection protocol detailed in the proposed regulation; a comparable standard code of practice developed by a nationally recognized association or independent testing laboratory; or a comparable inspection protocol developed by the implementing agency. EPA proposes that written inspection records be maintained for one year.

 

There are also testing requirements and inclusion of emergency power generators that use USTs for their fuel to operate.If you have questions, please call GEC at 781-356-9140, extension 112.