Environmental Daily Advisor

SDS Problem Solving

Kelly Lagana — Fri, 24 May 2013 14:24:16 +0000

Include information from your hazard communication (HazCom) Plan. Your Hazcom Plan must describe the process for ensuring that employees have immediate access to SDSs. The description must include all the following information:

The person(s) responsible for obtaining and maintaining the SDSs
How they are accessed by employees
How and where they are kept in the workplace
Procedures to follow when the SDS has not been received
A description of alternatives to obtaining SDS information (the backup system)

Describe your process for “immediate” access to SDSs. Make sure the Plan describes how employees can immediately obtain the required SDS in an emergency. “Immediately” generally means, in emergencies, during the work shift and in the work area of the person who requested the SDS; in nonemergency situations, by the next work shift after the SDS is requested. Reading SDSs over the phone is not an option, except when employees must travel between workplaces during the work shift and require the information in an emergency.

Forget expensive calls to lawyers and consultants. With Enviro.BLR.com, you get instant access, 24/7. Try it out today and get an EHS Recordkeeping Checklist, absolutely free. Download Now.

Describe your SDS access backup system. If a fax-back service or computer terminal is your primary system, another electronic system may serve as a backup as long as it is not subject to the same barriers as the primary system. If a power outage will render the fax machine and computer inoperable in an emergency, make sure other arrangements to contact the chemical manufacturer, distributor, or other SDS provider by cell phone or other means have been made to obtain the SDS. Otherwise, an on-site paper filing system may be necessary. Either way, document the access procedure.

Document that your SDS access system works. Periodically test your primary and backup systems. Run through an emergency access scenario with your access provider and your employees. Record the results of SDS access system tests and put them with your written HazCom Plan.

Establish a multiemployer policy for accessing SDSs. A multiemployer worksite exists any time employees of different employers are on the same site (e.g., a cleaning crew comes into your workplace, or a welding contractor performs work). Also, any employer that hires the services of an outside contractor or vendor is responsible for ensuring compliance by the contractor with the requirements of OSHA’s hazard communication standard if the contractor exposes any employees at the site to chemical hazards.

Need an answer fast? Relax. Our editors guarantee a personalized response to your questions within 3 business days. Take a free trial of Enviro.BLR.com and see what everyone is talking about. For a limited time, also receive an EHS Recordkeeping Checklist. Download Now

According to OSHA citation procedures for agency safety and health inspectors (CPL 02-02-038), if the controlling employer at a worksite uses a general contractor or other employer as an intermediary for storage of the SDS(s), and that intermediate employer has agreed to hold and provide ready access to the SDS(s), then the intermediate employer becomes the controlling employer, and is responsible for ensuring the availability of the SDS(s).

Looking for an easy SDS plan template? Check out this one on Enviro.BLR.com.

Easy UST Compliance Check

Kelly Lagana — Thu, 23 May 2013 14:23:45 +0000

Corrosion Protection

All tanks and piping must be protected from corrosion, but USTs installed before December 22, 1988 can use some retrofit approaches not allowed for USTs installed on or after December 22, 1988. Be sure you know the corrosion protection requirements for each of your USTs.

For tanks:

Tank is fiberglass?
Tank is coated and cathodically protected steel?
Tank is steel clad (or jacketed) with noncorrodible material?
Tank retrofitted with cathodic protection?
Tank retrofitted with interior lining?

Specify any other method used to achieve tank’s corrosion protection.

Forget expensive calls to lawyers and consultants. With Enviro.BLR.com, you get instant access, 24/7. Try it out today and get an EHS Recordkeeping Checklist, absolutely free. Download Now.

For piping:

Piping is fiberglass?
Piping is coated and cathodically protected steel?
Piping retrofitted with cathodic protection?
Specify any other method used to achieve piping’s corrosion protection:

Records for Cathodic Protection

If you have impressed current systems or sacrificial anodes, you have the documentation of the last two inspection results conducted by a qualified cathodic protection tester within 6 months of installation, at least every 3 years thereafter, and within 6 months of a repair?

If you have an impressed current system, you have documentation of the last three rectifier readings that need to be taken every 60 days to show that the rectifier is working properly? (Most USTs will share one rectifier.)

Spill Protection

All USTs must be protected from spills by having devices such as “spill buckets” or catchment basins that can contain spilled product.

UST has spill protection equipment, such as catchment basin?

Overfill Protection

All USTs must be protected from overfills by using such devices as automatic shutoff devices, overfill alarms, or ball float valves.

UST has automatic shutoff device?
UST has overfill alarm?
UST has ball float valve?

Other Requirements

You have filed notification forms with the appropriate authority?
You keep records of all UST system repairs for the operating life of the UST system?
If you have permanently closed any USTs, you satisfy the requirements for permanent closure and keep site assessment results for 3 years?
If you have temporarily closed any USTs, you satisfy the requirements for temporary closure?
You have evidence of “Financial Responsibility”?

Please note that filling out this checklist does not guarantee that you are in fact in compliance with UST requirements. Only an official site inspection can confirm your compliance status. Be sure to check with State/local agencies that may have additional/different requirements or their own checklists.

State DOT Pays $30K for UST Violations

Kelly Lagana — Wed, 22 May 2013 14:23:09 +0000

EPA cited the Agency for not complying with federal and state safeguards designed to prevent, detect, and control leaks of petroleum and other hazardous substances from USTs. EPA alleged that the agency failed to perform and/or document required release detection activities at a total of 17 USTs used to store diesel fuel and used oil at Division of Highway facilities.

In addition to the $30,000 penalty, the Agency has agreed to improve release detection procedures at 43 underground fuel tank facilities statewide by upgrading to a more sophisticated monitoring system which complies with regulatory requirements.

According to EPA, the settlement penalty reflects the agency’s cooperation with EPA in correcting the alleged non-compliance and resolving this matter.

Forget expensive calls to lawyers and consultants. With Enviro.BLR.com, you get instant access, 24/7. Try it out today and get an EHS Recordkeeping Checklist, absolutely free. Download Now.

Check Your UST Compliance

Don’t take the chance of getting fined by EPA, use the checklist to see how closely you meet the federal regulations for USTs (40 CFR Part 280).

Keep in mind though, this is for the federal regulations only — your state may have stricter regulations.

Release Detection

Long-term “Monthly Monitoring” methods: These methods include interstitial monitoring, automatic tank gauging systems, groundwater monitoring, vapor monitoring, and other methods approved by an implementing agency to work equally well, such as statistical inventory reconciliation (SIR).

Temporary release detection methods: For 10 years following installation of a new UST or the upgrading of an old UST, you can often use a combination of periodic tank tightness testing with either inventory control or manual tank gauging.

There may be additional requirements for your UST’s piping. Pressurized piping and suction piping have different requirements.

UST uses Interstitial Monitoring at least monthly?
UST uses Automatic Tank Gauging at least monthly?
UST uses Vapor Monitoring at least monthly?
UST uses Groundwater Monitoring at least monthly?
UST uses Manual Tank Gauging alone (only for tanks less than 1001 gallons (gal))?
UST uses Manual Tank Gauging & Tank Tightness Testing (only for tanks less than 2001 gal and 10-year maximum use)?
UST uses Inventory Control and Tank Tightness Testing (10-year maximum use)?

Specify any other release detection method, such as SIR.

Pressurized Piping

Piping has automatic flow restrictor?
Piping has automatic shutoff device?
Piping uses continuous alarm system?
Piping uses annual line tightness testing?
Piping uses monthly monitoring?

Suction Piping

Piping uses monthly monitoring?
Piping uses line tightness testing every 3 years?
Piping has no release detection requirements?

Records of Release Detection

You keep records at least 1 year showing the results of repairs and of monthly sampling, testing, and monitoring of release detection (except for tank tightness testing records, which you keep until the next test)?
You keep records at least 5 years of calibration and maintenance of release detection equipment? (Note: This may not be applicable if you use manual tank gauging, inventory control, or tank tightness testing.)
You keep vendor’s performance claims and results of third-party evaluations for 5 years for interstitial monitoring, automatic tank gauging, vapor monitoring, groundwater monitoring, tank tightness testing, or other applicable approved methods?

Please note that filling out this checklist does not guarantee that you are in fact in compliance with UST requirements. Only an official site inspection can confirm your compliance status. Be sure to check with state/local agencies that may have additional/different requirements or their own checklists.

See tomorrow’s Advisor for more of the UST compliance checklist.

RCRA Training Records Checklist

Kelly Lagana — Tue, 21 May 2013 14:22:18 +0000

Does the facility maintain personnel training and other records required in 40 CFR Part 265.16? Y/N

If yes, do these records include:
265.16(d)(1)

Job title for each position related to hazardous waste management and the employee filling each job? Y/N
265.16(d)(2)
A written job description for each position? Y/N
265.16(d)(3)
A written description of the type and amount of training that will be given to each person? Y/N
265.16(d)(4)
Records that document that the training or job experience required by facility personnel to effectively respond to emergencies and otherwise manage hazardous waste in a proper manner has been successfully completed? Y/N

Deliver fast and effective Environmental, DOT, and OSHA training with Environmental Training Library. Try it at no cost or risk. For a limited time, also receive a free special report. Download Your Free Report

265.16(b)

Have facility personnel successfully completed the required training or job experience within 6 months after occupying the position? Y/N

265.16(c)

Do facility personnel take part in an annual review of the initial training requirements and update them as necessary? Y/N

Download your FREE special report, Hazwaste Container Management: Where EPA Inspectors Look First, and receive a 30-day trial of Environmental Training Library at no cost or obligation. Download Your Free Report

262.34(a)(4)

Does the facility maintain an adequate preparedness and prevention program as required in 40 CFR Part 265 Subpart C? Y/N

More resources on RCRA training:

RCRA Training Requirements Review

Kelly Lagana — Mon, 20 May 2013 14:21:13 +0000

The alleged violations are:

Failure to properly date, label, and manage hazardous waste containers;
Failure to maintain records indicating the job title of each position at the facility related to hazardous waste management, and the name of the employee filling each job;
Failure to obtain the signature from a representative of the disposal facility on four hazardous waste manifests within 60 days of shipment;
Failure to conduct weekly inspections of its hazardous waste storage area;
Failure to provide training to employees responsible for handling hazardous waste; and
Failure to have a required contingency plan in place for a period of 2 years.

EPA says the settlement penalty reflects the company’s compliance efforts, and its cooperation with EPA in the resolution of this matter. As part of the settlement the company has not admitted liability for the alleged violations, but has certified its compliance with applicable RCRA requirements.

Review of RCRA Training Requirements
It seems that these enforcement stories always include failure to train hazardous waste personnel. Why is this part of the regulation so difficult for companies to follow? Maybe it is because the rules on RCRA training are so complicated! Here’s the breakdown of what you have to do as a TSDF or by generator type.

Treatment, Storage, and Disposal Facilities (TSDFs)
(40 CFR 264.16 and 40 CFR 265.16)
TSDF personnel: Within 6 months of commencement of employment, or assignment to a new position at the facility (whichever is later), classroom instruction or on-the-job training relevant to the individual’s job and including emergency procedures, emergency equipment and systems; HAZWOPER training suffices if it meets all the RCRA emergency response training requirements. The program must include all the elements described in the facility’s written description of the type and amount of training given to each person in the facility record that lists each employee and his or her job title.
When transporting waste off-site or receiving waste, review the training requirements for Department of Transportation (DOT) Hazardous Materials Employees.
Refresher: Annually
Trainer qualifications: The person conducting the training must be trained in hazardous waste management procedures.

Remediation Waste Management Sites (RWMS)
(40 CFR 264.1(j))
RWMS personnel: Classroom or on-the-job training on how to respond effectively to emergencies and on how to perform their duties in a way that ensures the RWMS complies with the hazardous waste TSDF requirements that also apply to an RWMS. The training requirements of 40 CFR 264.16 are not applicable unless the RWMS is also subject to a traditional RCRA permit.
Refresher: Not specified
Trainer qualifications: Not specified

Large Quantity Generators (LQGs)
40 CFR 262.34(a)(4) and 40 CFR 265.16
Same training requirements as TSDF personnel. When transporting waste off-site, see the training requirements for DOT Hazardous Materials Employees.
Refresher: Annually
Trainer qualifications: The person conducting the training must be trained in hazardous waste management procedures.

Small Quantity Generators (SQGs)
40 CFR 262.34(d)
Ensure facility personnel are thoroughly familiar with proper waste-handling procedures and emergency response procedures relevant to their responsibilities.
When transporting waste off-site, see the training requirements for DOT Hazardous Materials Employees.
Refresher: Not specified
Trainer qualifications: Not specified

Generators: Academic Laboratory Personnel
(40 CFR 262.207)
Training is required for all individuals working in a laboratory at the eligible academic entity. Training for laboratory workers and students must be commensurate with their duties so they understand the requirements of the Academic Laboratory Rule and can implement them.
Training methods can include: formal classroom training, electronic/written training, on-the-job training, instruction by the professor or laboratory manager before or during an experiment, or written or oral exams.
Refresher: Not specified
Trainer qualifications: None

Low Level Mixed Waste (LLMW)
40 CFR 266.230
The training of personnel who manage stored conditionally exempt LLMW must ensure that the conditionally exempt waste is safely managed and include training in chemical waste management and hazardous materials incidents response that meets the personnel training standards of 40 CFR 265.16(a)(3).
Refresher: Not specified
Trainer qualifications: None
These are the federal regulations. Your state may have stricter RCRA training requirements.

You have to keep records, too! See tomorrow’s Advisor for a training records checklist to make sure you are showing your work.

Good Samaritans and NPDES Permits

Kelly Lagana — Fri, 17 May 2013 15:49:15 +0000

The EPA has addressed this concern in several memoranda, the most recent issued in December 2012, which discussed conditions under which a Good Samaritan would not be required to obtain a National Pollutant Discharge Elimination System (NPDES) permit covering discharges either during the cleanup project or after the project is completed.

Qualifying Good Samaritans

A 2007 memo from multiple EPA offices (Office of Enforcement and Compliance Assurance, Office of Solid Waste and Emergency Response, Office of Water, and Office of General Council) presents guiding principles for Good Samaritan projects at orphan mine sites. The guidance notes that nothing in the Good Samaritan initiative alters the Comprehensive Environmental Response, Compensation, and Liability Act’s (CERCLA) polluter-pays principle. Also, according to the guidance, to qualify as a Good Samaritan, an entity would need to meet certain criteria, including:

Not being a past owner or current owner of the property and having no intention of purchasing the property in the future,
Not being potentially liable under CERCLA for remediation of the existing contamination, and
Not being potentially liable under any other federal, state, or local law for remediation of the existing contamination.

Forget expensive calls to lawyers and consultants. With Enviro.BLR.com, you get instant access, 24/7. Try it out today and get an EHS Recordkeeping Checklist, absolutely free. Download Now.

CERCLA Tools

The 2007 guidance also emphasizes the need for CERCLA tools. These are comfort/status letters or settlement agreements that spell out the government’s assurances that legal action will not be taken against the Good Samaritan except in circumstances specifically stated in the tools. These tools will also describe the cleanup goals the Good Samaritan agrees to work toward. The memo states that the CERCLA tool will, “as a general matter,” require the Good Samaritan project “to the extent practicable as determined by EPA considering the exigencies of the situation to attain applicable or relevant and appropriate requirements (ARARs) under federal or state environmental facility siting laws.”

NPDES Permitting

In the 2012 follow-up memo, the same four EPA offices attempt to resolve concerns Good Samaritans raised about the possible obligation to obtain NPDES permits for work at orphan hard rock mining sites. As a general matter, the memo notes that Good Samaritans performing work under a CERCLA tool would be exempt from NPDES permitting requirements both during the cleanup and after it is completed. The exemption holds provided the Good Samaritan does not perform additional work at the mine.

The memo specifically addresses the Clean Water Act provision that states that any person who discharges or proposes to discharge pollutants has the duty to apply for a NPDES permit. In its regulations the EPA has elaborated on this provision by clarifying that permitting obligations apply to either owners or operators of sites. The 2007 memo already clarified that a site owner may not be a Good Samaritan. However, could a Good Samaritan meet the definition of an operator and therefore be required to obtain a permit? The EPA states that the CERCLA tool should specify the Good Samaritan’s exemption from permitting during the project. The question after the CERCLA action is satisfactorily completed is whether the Good Samaritan would be considered an operator of any discharges that continue at the site.

Five Questions

“The initial question to be considered is whether the Good Samaritan successfully completed the work described in their CERCLA tool,” says the EPA. If the answer is “yes,” the Agency then provides the following five questions, answers to which determine whether the Good Samaritan is an operator for NPDES permitting purposes.

Does the Good Samaritan have access and authority to enter the site?
Does the Good Samaritan have an ongoing contractual agreement or ongoing relationship with the owner of the site to control any remaining discharge(s)?
Does the Good Samaritan have the power or responsibility to make timely discovery of any changes to the discharge(s)?
Does the Good Samaritan have the power or responsibility to direct any activities of persons who control the mechanisms, if any, causing the ongoing discharge(s)?
Does the Good Samaritan have the power or responsibility to prevent and abate the environmental damage caused by the remaining discharge(s)?

If the Good Samaritan answers "no" to each of these questions, the Good Samaritan should not be considered an operator responsible for obtaining NPDES permit coverage even where a discharge continues from a passive treatment system.

Incorporating FRPs into Your SPCC Plan

Kelly Lagana — Thu, 16 May 2013 15:35:38 +0000

If you fall under federal Spill Prevention, Control, and Countermeasure (SPCC) Plan requirements and are also required to have an FRP, here are a few things you should know to streamline your efforts.
An FRP must:

Be consistent with the National Contingency Plan and applicable Area Contingency Plans.
Identify a qualified individual having full authority to implement removal actions, and require immediate communication between that person and the appropriate federal authorities and responders.
Identify and ensure availability of resources to remove, to the maximum extent practicable, a worst-case discharge.
Describe training, testing, unannounced drills, and response actions of persons on the vessel or at the facility.
Be updated periodically.
Be resubmitted for approval of each significant change.

EPA’s SPCC regulation affects over 630,000 facilities. Is yours one? Download your EHS Essentials Kit—SPCC Plan Compliance now for all the tools you need to be in compliance. Download Now

Facility Response Plan Format

EPA allows an FRP to be part of a facility’s integrated contingency plan (ICP). But, EPA hates it this way because it is more difficult to inspect. They prefer the model format provided in Appendix F of 40 CFR 112.
Key elements include:

Emergency Response Action Plan, which serves as both a planning and action document and should be maintained as an easily accessible, stand-alone section of the overall plan
Facility information, including its name, type, location, owner, andoperator information
Emergency notification, equipment, personnel, and evacuation information
Identification and analysis of potential spill hazards and previous spills
Discussion of small, medium, and worst-case discharge scenarios and response actions
Description of discharge detection procedures and equipment
Detailed implementation plan for response, containment, and disposal
Description and records of self-inspections, drills and exercises, and response training
Diagrams of facility site plan, drainage, and evacuation plan
Security (e.g., fences, lighting, alarms, guards, emergency cut-off valves and locks)
Response plan coversheet

Don’t risk an EPA fine! Stay in compliance with our EHS Essentials Kit—SPCC Plan Compliance. Download now for instant access to comprehensive checklists, common violations, training materials, forms, and more. Download Now

Heads up! EPA is looking to put out new FRP guidance by the end of 2013 or early 2014. You can be sure that the Environmental Daily Advisor will let you know when it is out.

Be certain your SPCC plan is compliant with EHS Essentials Kit–SPCC Plan Compliance. This kit covers all the latest regulation changes with expert analysis, important FAQs, and comprehensive checklists. Create or update your SPCC plan with confidence. A sample plan will guide you in the development of a finished, usable document to achieve and sustain compliance.

Looking for Training Materials?

With EHS Essentials Kit–SPCC Plan Compliance, you’ll have them immediately. There’s no shipping cost or wait for delivery. With one instant download, you’ll have all you need to keep your staff fully prepared and trained for their safety and protection – as well as the protection of your company.

Download your Essential Kit now for all the tools you need to be in compliance!

Download Now

Region 10 Busy with SPCC/FRP Enforcement

Kelly Lagana — Wed, 15 May 2013 15:15:25 +0000

Three individual fuel companies in Oregon have settled with EPA for Spill Prevention, Control, and Countermeasure (SPCC) violations and will pay fines and invest in facility upgrades at their facilities. EPA inspections of each facility from 2007 and 2011 found multiple violations of federal spill prevention rules and spill response requirements under the Clean Water Act (CWA).
"Companies storing large amounts of fuel must be prepared to prevent and respond to fuel spills to protect people’s health and the environment," said the manager of EPA Region 10 wastewater permits compliance unit. “With strong spill prevention and response plans in place, accidental fuel spills are far less likely to occur.”

Secondary Containment Issues and Spills

One company failed to install sufficient containment to prevent and contain fuel spills at its North Bend and Eugene facilities and failed to develop a federal Facility Response Plan (FRP) at its North Bend facility. The company also spilled nearly 300 gallons (gal) of diesel fuel at its Eugene facility, some of which reached a nearby river. The company will pay a $27,920 federal fine, a $2,080 state fine, and complete secondary containment system upgrades, costing $200,000, to their transload facility in Eugene.

Another failed to install sufficient containment to prevent and contain fuel spills at its North Bend facility. The company also spilled 29 gallons of diesel fuel, some of which reached Coos Bay. The company will pay a $29,843 federal fine and complete $35,000 in stormwater control upgrades to their facility.

Another company failed to install sufficient containment to prevent and contain fuel spills at its facility in Klamath Falls. This company will pay a $28,200 federal fine.

SPCC and FRP

Federal law requires that facilities with the potential for oil spills take every possible step to prevent discharges to rivers, lakes, or oceans by implementing SPCC plans. Facilities with more than 1,320 gal of aboveground fuel storage capacity must have plans to prevent and contain spills, such as installing secondary containment around fuel storage tanks and transfer areas.

Facilities are also required by federal law to minimize environmental damage if oil spills do occur. FRP rules under the CWA require facilities that store and distribute oil be prepared for containing and cleaning up spills. To safely respond to a spill, a facility must have adequate employee training, spill response equipment, and a contingency plan for containing and cleaning up a release.

Should You Have an FRP?

According to EPA, about 4,400 of the more than 650,000 SPCC-regulated facilities also need to write and maintain an FRP. These are facilities that, according to Appendix F of 40 CFR 112, could reasonably be expected to cause "substantial harm" to the environment by discharging oil into or on navigable waters.

If you answer "yes" to any of the following questions, your facility is required to prepare an FRP.

Does this facility transfer oil over water with a total oil storage capacity greater than or equal to 42,000 gal?
Does this facility have a total oil storage capacity of greater than or equal to 1 million gal and the facility lacks sufficient secondary containment?
Does this facility have a total oil storage capacity of greater than or equal to 1 million gal and is located at a distance that a discharge could harm fish, wildlife, and/or sensitive environments?
Does this facility have a total oil storage capacity of greater than or equal to 1 million gal and, because of the facility’s location, would such a spill event shut down a public drinking water intake?
Does this facility have a total oil storage capacity of greater than or equal to 1 million gal, and has this facility had a reportable oil spill in an amount of greater than or equal to 10,000 gal within the last 5 years?

Check Your Lab Safety Compliance

Kelly Lagana — Tue, 14 May 2013 13:48:58 +0000

(29 CFR 1910.1450) (also known as the Laboratory Standard). Here’s the rest of the checklist.

Training

Do you provide all employees with information and training to ensure that they are aware of the hazards in their work area? [(f)(1)]
Is training provided when an employee is first assigned to work in the lab and before assignments involving new exposure situations? [(f)(2)]
Do you provide refresher training for all employees at reasonable intervals? [(f)(2)]

Your one-stop safety management resource, available 24/7. Go here to take a no-cost site tour or here to try it in your own office! Plus, for a limited time, receive the NEW 2013 EHS Salary Guide.

Does your employee training include:

Methods and observations that may be used to detect the presence or release of hazardous chemicals? [(f)(4)(i)(A)]
Physical and health hazards of chemicals in the lab? [(f)(4)(i)(B)]
Precautions employees can take to protect themselves from hazards, including specific procedures you have implemented to protect employees? [(f)(4)(i)(C)]
Applicable details of your Chemical Hygiene Plan? [(f)(4)(ii)]

Medical

Do you provide all employees who work with hazardous chemicals an opportunity to receive medical attention under the following circumstances:

Whenever an employee develops signs or symptoms of chemical exposure? [(g)(1)(i)]
When monitoring reveals an exposure level above the action limit (or in the absence of an action limit, the PEL)? [(g)(1)(ii)]
Whenever there is a spill, leak, explosion, or other event resulting in the likelihood of a hazardous exposure? [(g)(1)(iii)]

Great news! BLR’s renowned Safety.BLR.com^® website now has even more timesaving features. Take our no-cost site tour! Or better yet, try it at no cost or obligation for a full 2 weeks. Plus, for a limited time, receive the NEW 2013 EHS Salary Guide.

Are medical examinations performed under the direct supervision of a licensed physician at no cost to the employee? [(g)(2)]
Do you provide the physician with all information needed to make a diagnosis? [(g)(3)]
Do you obtain a written opinion from the examining physician that includes the results of the examination and any tests as well as any recommendation for medical follow-up? [(g)(4)]
Do you ensure that labels on incoming containers of hazardous chemicals are not removed or defaced? [(h)(1)(i)]
Do you maintain an SDS for each hazardous chemical used in your laboratory? [(h)(1)(ii)]
Do you provide employees with respirators when necessary to maintain exposure below permissible exposure limits? [(i)]
Do you maintain records for each employee that include any monitoring of the employee’s exposure to hazardous chemicals as well as any required medical consultation and examinations? [(j)(1)]

Lab Safety Compliance Checklist

Kelly Lagana — Mon, 13 May 2013 13:47:24 +0000

The Laboratory Standard requires that the employer designate a Chemical Hygiene Officer and have a written Chemical Hygiene Plan (CHP), and actively verify that it remains effective. The CHP must include provisions for worker training, chemical exposure monitoring, where appropriate, medical consultation when exposure occurs, criteria for the use of personal protective equipment (PPE) and engineering controls, special precautions for particularly hazardous substances, and a requirement for a Chemical Hygiene Officer responsible for implementation of the CHP.

Laboratory personnel must receive training regarding the Laboratory Standard, the CHP, and other laboratory safety practices, including exposure detection, physical and health hazards associated with chemicals, and protective measures.

Use the following compliance checklist to review your policies and procedures in light of the requirements of the Laboratory Standard (29 CFR 1910.1450).

General

Do you monitor employee exposure to any substance regulated by an OSHA standard if there’s reason to believe that exposure levels for that substance routinely exceed the action level (or in the absence of an action level, the PEL)? [(d)(1)]
If initial monitoring discloses exposure over the action level (or PEL), do you comply with the monitoring requirements of the relevant standard and conduct periodic tests as required? [(d)(2)]
Do you notify employees in writing of monitoring results within 15 days of receipt of such results either by individual letter or posting? [(d)(4)]
Do you have a written Chemical Hygiene Plan that spells out the provisions for protecting employees from health hazards associated with chemicals in the laboratory? [(e)(1), (e)(1)(i)]
Is your Chemical Hygiene Plan readily available to employees? [(e)(2)]

Chemical Hygiene Plan

Does your Chemical Hygiene Plan contain the following elements?

Standard operating procedures relevant to safety and health considerations to be followed when lab work involves the use of hazardous chemicals? [(e)(3)(i)]

Criteria you use to determine and implement control measures to reduce employee exposure to hazardous chemicals, including engineering controls, PPE, and hygiene practices? [(e)(3)(ii)]
A requirement that fume hoods and other protective equipment are functioning properly?[(e)(3)(iii)]
Provisions for employee information and training? [(e)(3)(iv)]
Circumstances under which a particular laboratory procedure or activity requires prior approval from a supervisor? [(e)(3)(v)]
Provisions for medical consultation and examinations for employees whenever called for under paragraph g (see below)? [(e)(3)(vi)]
Procedures for safe removal of hazardous waste? [(e)(3)(viii)(C)]
Decontamination procedures? [(e)(3)(viii)(D)]

Do you review and evaluate the effectiveness of your plan at least once a year? [(e)(4)]

But wait, there’s more! See tomorrow’s Advisor for the rest of the checklist.