How to Keep Waste in Its Place

There are five hazardous waste management regulations that improve worker safety.

To help preserve and protect the environment, the Environmental Protection Agency has stringent regulations governing the proper storage, use, and handling of hazardous wastes generated in facilities throughout the nation. Although EPA’s focus is to guard against anything that would harm the nation’s air, land, and waters, complying with these regulations also can help to enhance worker safety.

Facilities with hazardous wastes must handle those wastes in a manner that prevents leaks, spills, and emissions. Properly identifying hazardous wastes, having plans in place to handle spills, and training workers are also among the EPA requirements that promote environmental safety.

Reviewing appropriate EPA hazardous waste storage and handling regulations and incorporating applicable practices into facility safety plans will increase workers’ safety.

Closed Container

Hazardous wastes need to be collected properly for recycling or disposal. This often involves pouring liquid wastes into collection drums, totes, or tanks. When wastes are not being added or removed, EPA requires that the hazardous waste collection container to be kept closed (40 CFR 264.173). Keeping containers closed helps to prevent spills, should the container be knocked over or bumped. If a spill is prevented, cleanup won’t be required, and workers will not be further exposed to the wastes inside the container.

A closed container is also required for the collection and storage of waste materials that have VOC content (40 CFR 264.1086). Containers with continuous seals that are kept closed will help to prevent fugitive emissions while the wastes are in storage. This improves indoor air quality and helps to prevent worker exposure to harmful vapors.

Providing containers with fast-latching lids and funnels with easy-to-close features helps workers collect wastes more efficiently and promotes safer handling in waste collection areas.

Container Labeling and Segregation

Like OSHA, EPA wants to know what’s in a container. Proper labeling helps workers quickly identify hazardous wastes on site so that these can be managed efficiently and safely.

Under the Hazard Communication Standard, OSHA requires hazardous materials to be properly identified so that workers are aware of hazards and can take proper precautions. Similarly, containers of hazardous waste need to be marked with the words “Hazardous Waste,” as well as the date when waste first began accumulating in the container [40 CFR 262.34(a)]. This helps to ensure that workers are aware of hazards, storage time limits are not exceeded, and wastes are recycled or disposed of in a timely manner.

Labels also help workers to segregate waste streams. Wastes that are properly segregated can often be recycled more efficiently and at a lower cost. EPA allows the use of markers, paint, stenciling, stickers, or other means for marking containers. The marks must be legible and should not easily come off of the container.

Labeling containers also helps workers to segregate incompatible wastes and avoid potentially dangerous reactions resulting from unintentional mixing. Establishing separate storage areas for incompatible wastes that are physically divided by berms, dikes, or other barriers further promotes safety and limits the chance for mixing wastes (40 CFR 265.177).

Satellite Accumulation

Transporting small containers of waste from a processing area to a centralized waste collection area can be time consuming and also can increase the chance of leaks and spills while the waste is being transferred between the two locations.  To help minimize this, EPA allows up to 55 gallons of hazardous waste or 1 quart of acutely hazardous waste to be accumulated at or near the point of its generation [40 CFR 262.34(c)(1)].

These smaller waste collection sites are known as Satellite Accumulation Areas (SAAs) and must be under the control of an operator. Wastes accumulated in SAAs must be in properly managed containers that are correctly labeled and kept closed when wastes are not being added or removed from the container. When 55 gallons of hazardous waste or 1 quart of acutely hazardous waste has accumulated in any of these areas, the excess must be removed within three days.

Utilizing SAAs helps to promote worker safety because wastes can immediately be transferred to collection containers that are kept closed and properly managed, minimizing exposure and the chance for leaks and spills.

Secondary Containment

Sometimes, containers fail. At a minimum, the resulting spill is a nuisance, but when hazardous wastes are involved, a spill can result in environmental damage if it is released into the air, soil, or water. Providing secondary containment (40 CFR 264.175) helps to ensure that spills are contained and environmental damage is eliminated or minimized.

By containing spills, secondary containment systems also keep liquids out of walkways where they can be a slip-and-fall hazard. Contained spills are also typically easier and faster to clean up, reducing the amount of time that workers are exposed to the hazardous waste during cleanup.

Contingency Planning

Small- and large-quantity generators of hazardous wastes must have contingency plans to address the actions that the facility will take in the event of a spill or release of hazardous wastes (40 CFR 262.34). These plans should address potential emergencies due to container failures, natural or man-made disasters, and any other circumstance that may result in a spill of hazardous wastes.

In addition to this regulation, other EPA regulations, such as the Stormwater and Spill Control and Countermeasures (SPCC) regulations (40 CFR 122.26 and 112.7), also require spill preparedness. Plans should outline training requirements for responders, discuss what steps those persons will take during spill emergencies, and list the tools, equipment, and resources that are available to the responders.

OSHA’s Hazardous Waste Operation and Emergency Response (HAZWOPER) regulation helps responders to safely recognize, contain, control, and clean up spills. Coordinating HAZWOPER requirements with EPA spill preparedness and contingency plan requirements helps to ensure that any worker who responds to spills is well equipped to perform his duties safely and effectively.

Good Housekeeping

Many of EPA’s storage and handling requirements for governing hazardous wastes echo good housekeeping and other requirements that OSHA has promulgated to promote worker safety. By minimizing emissions, handling materials safety, and quickly cleaning up leaks and spills using both EPA and OSHA regulations, facility and worker safety are increased.

 

Karen Hamel is the technical education manager for New Pig Corp. She is a graduate of the University of Pittsburgh and has over twelve years of experience helping EHS professionals find solutions to their environmental, health and safety issues. She is HAZWOPER technician level certified and serves in the Blair County, Pa. LEPC. She can be reached at 1-800-HOT-HOGS® (800-468-4647) or by e-mail to karensp@newpig.com.

This article originally appeared in the July 2013 OHS issue of Occupational Health & Safety.

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