Safety and Preparedness

MoDNR Topics

Safety and Preparedness

From the archives of the Enforcement and Compliance Listserv for Hazardous Waste Generators

Feb. 20, 2007

Information on spills and equipment in the archive.

As the last few years have pointed out, it is reasonable for businesses to plan for disasters that can damage facilities and shut down operations for days or longer. Severe weather such as Missouri's recent winter storms, fire, or other disasters can strike at any time. In addition to dealing with the immediate evacuation or response to hazardous waste spills, facilities may find it is worthwhile to develop a plan for assessment and recovery in the event of a disaster. Having a plan can help a facility recover faster and better, and pre-planning can help avoid wasted or redundant efforts, protect your business's assets, and help you qualify for insurance or government disaster payments. The Department of Homeland Security's Ready Business Web site can provide some advice on this kind of recovery planning.

Jan. 8, 2007

The next few issues of this listserv are going to focus on safety and emergency situations. While reviewing this listserv, try to picture how your employees would react to an emergency. Are they prepared?

1. Communication

Small Quantity Generator and Large Quantity Generator facilities must have a device in the hazardous waste operations area capable of summoning emergency assistance. The device can be a telephone, intercom, cell phone, two-way radio, air horn, whistle, cow bell, whatever, as long as it is capable of summoning assistance and employees are trained to recognize the signal and act appropriately. Test it! If someone is in trouble in the operations area, can they summon assistance with the device? If your business has more than one hazardous waste operations area (i.e. containerization or storage area) then there must be a device capable of summoning emergency assistance located in EACH area.

Conditionally Exempt Small Quantity Generators (those that generate or accumulate 220 lbs of non-acute hazardous waste or less a month or less than 2.2 lbs of acutely hazardous waste) are NOT required to have such a device in their hazardous waste area but it is still a good, low cost way to protect you and your employees.

2. Training

What, if any, training must a Conditionally Exempt Small Quantity Generator provide to its employees? Although training requirements are not spelled out for Conditionally Exempt Small Quantity Generators, if you fall in this category you must be capable of making a hazardous waste determination and properly managing your wastes so they do not threaten human health or the environment or create a public nuisance. There are several training options, including attending formal training, taking a course on-line, or reviewing information available to you at the library or on the Internet. Review making a hazardous waste determination.

Small Quantity Generators are not required to have formal training records for their employees, however, it is important that each employee involved with hazardous waste be familiar with waste handling and emergency procedures. This protects your workers from injury and your facility from damage. Inspectors can evaluate if employees are familiar with waste handling and emergency procedures by speaking with employees. Inspectors will ask employees that are responsible for a specific waste stream direct questions about hazardous waste management. Establishing and periodically reviewing proper training and procedures at your business helps make sure your employees can not only answer an inspector's questions but that they know what to do in an emergency situation.

For Large Quantity Generators training and documentation requirements are more formal. Large Quantity Generators must provide training to their employees on how to respond to an emergency, have their training reviewed annually, and be sure employees don't work in unsupervised positions until their training is completed. The documentation required includes:

maintaining personnel training plans onsite that include the information below;
listing the name, job title and description of each employee filling a hazardous waste position (this must include requisite skill, education or other qualifications, and duties of facility personnel assigned to each position);
a written description of introductory and continuing training for each position (including type and amount of training);
documentation of training completed by personnel, this may include the title of the training offered and a dated sign in sheet or the duration and description of on the job training each employee receives;
maintaining the records of current employee's training until the business' closure and retaining former employee records for at least three years.

Large Quantity Generator's program director must be trained in hazardous waste management procedures. Employees that manage, move, label, inspect, consolidate, prepare for transport, etc. hazardous waste must have training relevant to their position. Inspectors will often quiz employees about the training they received, emergency contingency plans, and other safety matters.

Oct. 23, 2006

Is your company prepared for an emergency? It's a good idea to review the Preparedness Prevention and Emergency Procedures in Section D of the department's Small Quantity Generator Inspection Record and Checklist PDF. The checklist reviews the important emergency preparedness information that is required by 40 CFR 262.34(d)(5)(ii) and 10 CSR 25-5.262(1) for small quantity generators. Although this information is not required for large quantity generators and conditionally exempt small quantity generators, it is always a good idea to put safety first and prepare in advance for emergencies. Small Quantity Generators must post the required emergency information at the main office telephone and at each hazardous waste operational area. It is also recommended that you post the emergency information by the telephone in the office of the supervisor in charge of hazardous waste operations.

For Small Quantity Generators the information must include:

1. Name and phone number of the company's Emergency Coordinator(s). The emergency coordinator(s) must be on-site or on-call 24 hours a day, seven days a week.
2. Location of fire extinguishers and spill equipment and if applicable, fire alarm.
3. Fire department phone number, even if it is 911.

Although not required by regulation, you may also want to post:

employee evacuation routes.
a designated safe meeting area away from the building in case of an emergency.

All of this information can be shown on a simple map of the building. To ensure its durability you may want to laminate the emergency information or even place it in a frame. Make sure it is easy to see in the areas of hazardous waste operation. For example, the information should be displayed at eye level and you should use a large font and clear print.

Large quantity generators are required to maintain a contingency plan to deal with emergency situations on-site. We suggest that large quantity generators print multiple copies of the contingency plan and make it easily accessible to employees that work in the hazardous waste areas. Large quantity generators may review their list of preparedness, prevention and emergency procedures and the contingency plan requirements in Sections D and H of the Large Quantity Generator Inspection Record and Checklist PDF.

Dec. 16, 2005

1. At the end of the work day, we all want to go home to our family and friends. Preventing injury or harm is the basis for many Hazardous Waste Laws and regulations. Storing reactive chemicals separately, closing hazardous waste containers, having proper spill equipment on-hand, and providing training for your employees on what to do in an emergency are all requirements based on protecting the health and safety of you and your workers. Take some time to review your workplace, procedures, and training. Use the department's Small Quantity Generator Inspection Record and Checklist PDF or the Large Quantity Generator Inspection Record and Checklist PDF. Both checklists go over basic safety preparedness, prevention, and emergency response for hazardous waste generators. For additional information on reactive chemicals and preventing accidental reactions, please visit the Occupational Health and Safety Administration (OSHA) web site on Chemical Reactivity Hazards. From there, check out "How can I recognize chemical reactivity hazards in my workplace?" for a free online version of Essential Practices for Managing Chemical Reactivity Hazards manual.

2. Ever heard of the Hazard Communication Standard (HCS), Code of Federal Regulations 1920.1200? Under the authority of OSHA, the HCS requires that employers alert employees to the potential hazards and management of individual chemicals. Specific assistance on which chemicals to include and how to transmit this information to employees is available from OSHA's Frequently Asked Questions web site.

For information on which employees, if any, should have the 40 hour Hazardous Waste Operations and Emergency Response Training, please review the information available at OSHA's Frequently Asked Questions on Hazwoper web site.

And for basic information on OSHA requirements for training, jobsite safety, record keeping and more, visit OSHA's Quick Start Guide.

If you would like updates and information on hazardous waste or know of anyone else who would like to be added to this listserv, visit MoDNR Enforcement and Compliance Assistance Newsletter Generators Subscription to sign up.

If you need further assistance, please e-mail or contact the Department of Natural Resources' Hazardous Waste Program at 573-751-7560 or 800-361-4827.

Return to listserv topics at MoDNR Hazardous Waste Generator Archive.