Occupational Safety: Material & Waste Hazards

• Basic Occupational Safety and Health discusses physical material and waste hazards control

Course Learning Outcome

• The Goal is to understand the nature and be aware of the controls of physical hazards
• Goal is to Recognize the source, existence and impact of hazardous materials and wastes.

Topic Learning Outcome

• A goal is to describe the fire tetrahedron (elements) thereby enhances understanding on how fire is extinguished
• A goal is to explain how physical hazard controls puts equipment and machineries safe for operations

Hazardous Materials & Wastes

• The hazardous waste management program uses the term solid waste to denote something that is a waste
• The EPA developed hazardous waste regulations defining what materials are solid waste for the purposes of RCRA Subtitle C (hazardous waste) regulation
• A hazardous waste is a waste with properties that make it dangerous or capable of having a harmful effect on human health or the environment
• Hazardous waste can be generated from many sources, ranging from industrial manufacturing process wastes to batteries in many forms including liquids, solids gases, and sludges.

Solid Wastes Which Are Not Hazardous

• Solid wastes that are not hazardous include Household Hazardous Waste
• Solid wastes that are not hazardous include Mining Overburden Waste
• Solid wastes that are not hazardous include Oil, Gas, and Geothermal Wastes
• Solid wastes that are not hazardous include Mining and Mineral Processing Wastes
• Solid wastes that are not hazardous include Injected Groundwater Refrigerants
• Solid wastes that are not hazardous include Used Oil Filters
• Solid wastes that are not hazardous include Used Oil Distillation Bottoms Condensate
• Solid wastes that are not hazardous include Listed wasges
• Solid wastes that are not hazardous include Agricultural wastes
• Solid wastes that are not hazardous include Fossil Fuel Combustion
• Solid wastes that are not hazardous include Trivalent Chromium Wastes
• Solid wastes that are not hazardous include Petroleum Contaminated Media & Debris from Underground Storage Tanks
• Solid wastes that are not hazardous include Spend Chloroflurcarbon
• Solid wastes that are not hazardous include Used Oil Filters
• Solid wastes that are not hazardous include Landfill Leachhate or Gas
• Solid wastes that are not hazardous are Derived from certain listed wastes

Precautionary Measures for Emergencies:

• Warning Devices: Install suitable warning devices to alert personnel in case of the liberation of dangerous quantities of substances
• Training of Personnel: Workers shall be trained on procedures to control liberation of hazardous substances, eliminate pollution, and evacuate appropriately

Mitigations

• Mitigation measures could be applied to reduce hazardous 7naterials and waste management impacts of a project depending upon site- and project-specific conditions
• Hazardous materials and waste management impacts are related to the types and amount of equipment and machinery used for the project
• Impacts can be reduced or avoided when siting and design are taken into consideration
• Develop a final set of mitigation measures for any project in consultation with the appropriate federal resource management agencies and stakeholders
• Conduct these consultations early in the project development process, preferably prior to final project siting and design

General mitigation practices for oil and gas projects include:

• Implement plans for hazardous materials management, waste management, spill prevention and response, stormwater management, and pesticide management
• Provide secondary containment for all on-site hazardous materials and waste storage, including fuel
• Fuel storage should be temporary and removed immediately upon completion of construction and decommissioning phases
• Containerize and periodically remove wastes for disposal at appropriate off-site permitted disposal facilities
• Document accidental releases as to cause, corrective actions taken, and resulting environmental/health and safety impacts

OSH Standards Rule no. 1093.04 : Marking of Containers

• All containers with hazardous substances must be properly labeled.
• No employer can accept containers without labels for use, handling, or storage
• There is a rule for Specific Labelling Requirements.
• There is a rule for Other Aspects of Labelling
• There is a rule for Marking of Labels

What is hazardous waste?

• The EPA defines all waste as a “solid” waste including (solids, liquids, gases, and semi-solids)
• 40 CFR 261.2 provides the definition of "solid waste:"
• A solid waste is any discarded material that is not excluded under § 261.4(a) or that is not excluded by variance granted under §§ 260.30 and 260.31 or that is not excluded by a non-waste determination under §§260.30 and 260.34.
• A discarded material is any material which is Abandoned, as explained in paragraph (b) of this section
• A discarded material is Recycled, as explained in paragraph (c) of this section
• A discarded material is Considered inherently waste-like, as explained in paragraph (d) of this section
• A discarded material is A military munition identified as a solid waste in 40 CFR 266.202

EPA Definition of a Hazardous Waste (cont.)

• If the waste material meets certain criteria and is not somehow exempted or excluded from regulation, it might be a RCRA-regulated HW
• The legal definition of HW is found in 40 CFR 261.3
• A solid waste, as defined in §261.2, is a hazardous waste if It is not excluded from regulation as a hazardous waste under §261.4(b) and also meets any of the following criteria
• It exhibits any of the characteristics of hazardous waste identified in subpart C of this part
• Any mixture of a waste from the extraction, beneficiation, and processing of ores and minerals excluded under § 261.4(b)(7) and any other solid waste exhibiting a characteristic of hazardous waste under subpart C is a hazardous waste only if it exhibits a characteristic that would not have been exhibited by the excluded waste alone if such mixture had not occurred, or if it continues to exhibit any of the characteristics exhibited by the non-excluded wastes prior to mixture.
• Applying the Toxicity Characteristic to such mixtures, the mixture is also a hazardous waste if it exceeds the maximum concentration for any contaminant listed in table I to § 261.24 that would not have been exceeded by the excluded waste alone if the mixture had not occurred or if it continues to exceed the maximum concentration for any contaminant exceeded by the nonexempt waste prior to mixture.

Categories of Hazardous Waste

• Hazardous waste determinations are based upon whether the material is a: Characteristic waste
• Characteristic waste is Listed on the D-list or TCLP (Toxicity Characteristic Leaching Procedure)
• There are also listed waste
• Listed waste is Materials specifically identified on one of the following lists: F, K, U or P lists
• There is also Universal Waste
• Universal waste is Batteries, lamps, pesticides, mercury from thermometers

Characteristic Wastes

• D001 - Ignitable Wastes (flashpoint is less than 140° F) including oxidizers
• D002 - Corrosive Wastes (pH less than or equal to 2 or greater than or equal to 12.5)
• D003 - Reactive Wastes (water reactive, normally unstable materials, cyanides and sulfides, etc)
• D004 - TCLP Wastes

Listed Wastes

• F-listed wastes are from non-specific sources, for example, halogenated solvents used to degrease equipment
• K-listed wastes are from specific sources, for example, petroleum refining or pesticide manufacturing
• U-listed wastes are toxic wastes
• P-listed wastes are acute hazardous wastes

Examples of U-Listed Wastes

• U-Listed Wastes examples are Acetaldehyde, Acetone, Acetonitrile, Aniline, Benzene, Bromoform
• 1-Butanol, Chloroform, 1,4-Dioxane, Ethyl acetate, Ethyl ether, Formaldehyde
• Methyl alcohol, Methylene chloride, Phenol, Toluene

Examples of P-Listed Wastes

• P-Listed Wastes examples are Allyl alcohol, Ammonium Vanadate, Arsenic acid, Arsenic trioxide
• P-Listed Wastes examples are Carbon disulfide, 2,4-Dinitrophenol, Fluorine, Nitric oxide
• P-Listed Wastes examples are Osmium tetroxide, Phenylthiourea, Potassium cyanide, Sodium azide
• P-Listed Wastes examples are Sodium cyanide, Thiosemicarbazide, Vanadium oxide, Vanadium pentoxide

Universal Wastes

• Universal wastes are materials commonly found in the workplace
• Batteries are a type of Universal waste.
• Fluorescent lamps are a type of Universal waste.
• Pesticides are a type of Universal waste.
• Thermometers (containing mercury) are a type of Universal waste.

Other Waste: Aerosol Cans

• Aerosol cans are considered hazardous waste under the definition of "Characteristic Reactivity".
• 40 CFR Part 261.23 states aerosol cans are capable of detonation or explosive reaction if subjected to a strong initiating source or heated under confinement
• They often contain hazardous materials, either as the product or as the propellant.
• Most aerosol cans, regardless of contents, can never be completely emptied of propellant
• Aerosol cans become a waste when their contents are used up
• Aerosol cans become a waste when they malfunction e.g. fail to spray
• Aerosol cans become a waste when the contents are no longer needed

Other Wastes: Used Oil

• Used oil means any oil that has been refined from crude oil, or any synthetic oil, that has been used and as a result of such use, is contaminated by physical or chemical impurities (40 CFR 279.1)
• Used oil must be collected in clean containers in good condition (no leakers).
• Storage and transfer containers must be marked with the words "Used Oil".
• Never add solvents, part washer fluids, carb cleaners, or glycol to used oil.
• Keep the "used oil" container closed (lid in place and secured) except when adding or removing used oil
• If you use a funnel for transfers, the funnel must be removed when not in use and the container capped
• See slide #45 to make on online request to have your used oil removed

Wastes: Containers and Storage

• Only use containers that are compatible with the materials to be collected
• Always label containers with a description of their contents
• Do not store incompatible materials together
• Do not store wastes in the fume hood. However, store in the appropriate storage cabinet, e.g., flammable, acid
• Provide secondary containment for liquid wastes
• Always keep the container closed (lid firmly secured)
• A funnel in an open bottle is NOT a lid
• Check waste storage areas regularly (weekly) and inspect containers to make sure they aren't getting brittle or starting to crack

Emergency Response Chemical Spills

• Report all spills to ERT if there is an immediate threat of harm to life or property
• Dispatch will call DENR-EMB Hazmat Section or the FNSB Hazmat Team, if necessary, to request assistance with spill cleanup
• Depending on the nature of the spill, you may be asked to complete the UAF Oil and Hazardous Substance Spill Reporting Form available from DENR-EMB