TRAINING IS REQUIRED BY LAW
Workers are required to receive proper training if they work with, near or have the potential to encounter chemical hazards in the workplace, whether in the normal course of business or in the event of an accidental spill and/or chemical release.
OSHA requires employees to be trained about the hazardous chemicals stored, processed, and used on-site, something named OSHA Hazardous Waste Operations and Emergency Response HAZWOPER training. (29 CFR 1910.120) LINKhttp://www.osha-slc.gov/OshStd_toc/OSHA_Std_toc_1910.html HAZWOPER was passed by the U.S. Congress in 1989. Hazardous waste sites, hazardous waste transfer, storage, and disposal (TSD) facilities, and Superfund Sites are also regulated by this HAZWOPER standard.
Any facility required to file reports under EPCRA is governed by the HAZWOPER rule. The reasoning behind this is that if hazardous substances are located at a facility, they might spill or leak, requiring a cleanup. Once these hazardous substances have spilled or leaked, they must be quickly and safely cleaned up by trained personnel. So these cleaned up chemicals must be disposed of at that point, making the cleaned-up chemicals a hazardous waste or a nonhazardous waste depending on the chemical and the circumstances. Employees at the facility must have training on how to handle a spill of any size. Training is a legal requirement.
OSHA HAZWOPER regulation 29 CFR 1910.120 is designed to protect health and safety of the worker. In any workplace, even in an emergency response, the employer under the General Duty Clause of the Occupational Safety and Health Act is:
"(a) Each Employer....
The OSHA HAZWOPER is a 40 hour initial class with an annual eight hour refresher. This class can only be taught by a qualified instructor and must be paid for by the employer. The HAZWOPER class gives employees the basic knowledge they need to safely work in a chemical environment. This class is not optional, but mandatory for employees who work with chemicals or have to respond to potential chemical emergencies. To locate where OSHA HAZWOPER classes are being conducted in an area, inquire at a local university, trade association, State Emergency Response Commission, Local Emergency Planning Committee, or environmental agency.
Various instruments are used to measure chemical air contamination as well as oxygen levels. The results of these readings will determine the level of protection needed to work safely in that environment. The two most important instruments to use when entering an area with unknown chemicals or unknown quantities of chemicals are the Oxygen Meter and the LEL Meter (Lower Explosive Limit). When entering an area with unknown chemicals or unknown quantities of chemicals, Level A protection should be used if possible, but no lower than Level B protection shall be used until initial environmental hazards are fully recognized and quantified. The Oxygen Meter will determine if there is enough oxygen (19.5% to 25%) to support life safely or if there is to much oxygen creating a fire/explosion hazard (over 25%). The LEL Meter (Lower Explosive Limit) will measure the concentration of chemical(s) in the atmosphere. If the concentration is too high (greater than 25% of the LEL outside, or greater than 10% of the LEL in a confined area) than a fire/explosion hazard exists.
OTHER INSTRUMENTS:
Other instruments include Direct Reading Instruments which measure the level of a specific chemical(s) in the air. Direct Reading Instruments can be designed for one particular contaminant or multiple contaminants, however, with multiple reading instruments the probability of them being out-of-service because of calibration or other problems is greater. If the contaminant is at levels above the Permissible Exposure Limit (PEL) then appropriate measures of Personal Protective Equipment (Level A,B,C) shall be utilized. This type of instrumentation is available for about 100 chemicals and generally has a cost in the thousands of dollars.
Colorimetric tubes, commonly referred to as Drager Tubes, are relatively inexpensive ($10 average) and when exposed to a particular chemical cause a chemical reaction by a color change in the tube. Different tubes have different reaction and color scales. If the contaminant is at levels above the Permissible Exposure Limit (PEL) then appropriate measures of Personal Protective Equipment (Level A,B,C) shall be utilized. Colorimetric tubes are available for approximately 300 chemicals.
Photo Ionization Detector/Flame Ionization Detectors can detect a large range of unspecified chemicals and are often used when the chemical contaminant is unknown. High humidity can create false/positive readings with these detectors and positive readings should be evaluated by experienced personnel. In general for unknown contaminants the following applies:
0 - 5 ppm* detected = Level C Personal Protection Equipment (PPE)
5 - 500 ppm* detected = Level B Personal Protection Equipment (PPE)
greater than 500 ppm* detected = Level A Personal Protection Equipment (PPE)
* Parts Per Million
If the air monitoring shows sufficient oxygen (19.5% to 25%), and any chemical contaminants are below Permissible Exposure Limits (PEL), then the area is considered safe to work in without Personal Protection Equipment (PPE).
| A WORKER WORKING WITH CHEMICALS WHO DOES NOT THINK THERE HAS BEEN ADEQUATE TRAINING SHOULD CONSULT THE EMPLOYER. IF THAT D OES NOT WORK, CONTACT THE Occupational Safety and Health Administration (OSHA). Link to OSHA Complaint Site. |
SPECIAL CAUTION ON HANDLING DRUMS AND OTHER CONTAINERS OF CHEMICALS
| Accidents may occur during handling of drums and other hazardous chemical containers. Hazards include detonations, fires, explosions, vapor generation, and physical injury resulting from moving heavy containers by hand and working around stacked drums, heavy equipment and deteriorated drums. While these hazards are always present, proper work practices such as minimizing handling and using equipment and procedures that isolate workers from hazardous substances can minimize the risks to personnel. DO NOT HANDLE DRUMS WITH UNKNOWN CONTENTS. Proper labeling of drums is a must to avoid unintended exposure and the mixture of incompatible wastes or chemicals. DO NOT HANDLE DRUMS WHICH ARE BULGING. BULGING DRUMS CAN PRESENT AN EXTREME DANGER. Pressurized drums can be explosive upon opening and should only be opened by trained professionals with the proper equipment, including remote control devices, that provides the necessary shielding. Do not use picks, chisels or firearms to open drums. |
| Extreme caution should be used when handling unfamiliar chemicals or wastes. Workers should not handle or move chemicals or chemical containers until the worker has the proper training and knowledge about those chemicals and chemical containers are properly labeled and identified as prescribed by law. |