C04_Attachment_4_AppSHAZMATPLAN_May 2024.pdf

Allegheny National Forest Hazardous Materials and Waste Management Plan Rev May 2024

United States Department of Agriculture

Forest Service

Hazardous Materials and Waste Management Plan

Prepared for: Jamie Davidson, Forest Supervisor 4 Farm Colony Drive

Warren, PA 16365

Approved By:

for Jamie Davidson, Forest Supervisor Date

HAZARDOUS MATERIALS AND WASTE MANAGEMENT PLAN

Table of Contents

UNITED STATES DEPARTMENT OF AGRICULTURE

FOREST SERVICE

ALLEGHENY NATIONAL FOREST

HAZARDOUS MATERIALS AND WASTE MANAGEMENT PLAN

PREPARED FOR: JAMIE DAVIDSON, FOREST SUPERVISOR

HAZARDOUS MATERIALS AND WASTE MANAGEMENT PLAN

ALLEGHENY NATIONAL FOREST

SECTION 1.0 - INTRODUCTION

1.1 INTRODUCTION

1.2 OVERALL PLAN PURPOSE

1.3 HOW THIS PLAN SHOULD BE USED AND BY WHOM

SECTION 2.0 – HAZARDOUS MATERIALS

2.1 HOW TO CLASSIFY HAZARDOUS MATERIALS FOR PROPER STORAGE

CORROSIVE MATERIALS

2.2 PRODUCT TYPES/NAMES

2.3 STORAGE REQUIREMENTS

2.4 SPILL RESPONSE

HAZARDOUS MATERIAL SPILL RESPONSE PLAN

I. GENERAL

II. PURPOSE

III. SCOPE

IV. ROLES, RESPONSIBILITIES, AND RESPONSE ACTIONS

Forest Service Emergency Releases Contractor and Permit User Spills Incidental Releases

2.5 TRANSPORTATION REQUIREMENTS

Shipping Papers

2.6 PROCUREMENT CONTROLS

SECTION 3 – WASTES [LIKELY TO BE FOUND/GENERATED BY UNIT]

3.1 ABSORBENTS

3.2 ANTIFREEZE

3.3 BATTERIES - UNIVERSAL WASTE

3.4 GARBAGE, TRASH, DUMPS, TIRES & BONEYARDS

3.5 CLEANING SOLVENTS

3.6 ELECTRONICS

3.7 LIGHT BULBS AND TUBES - UNIVERSAL WASTE

3.8 MERCURY CONTAINING EQUIPMENT - UNIVERSAL WASTE

3.9 USED OIL & FILTERS

3.10 PAINTS - AEROSOL

3.11 PAINTS - WATER BASED AND OIL BASED

3.12 STANDARD OPERATING PROCEDURE FOR HAZARDOUS WASTE ACCUMULATION AREA (HWAA)

STORAGE CONTAINERS

LABELING

SPILLS/SPILL CONTROL EQUIPMENT

INSPECTION/TRAINING

3.13 STANDARD OPERATING PROCEDURE FOR SATELLITE ACCUMULATION AREA (SAA)

LABELING

SPILLS/SPILL CONTROL EQUIPMENT

INSPECTION/TRAINING

3.13 STANDARD OPERATING PROCEDURE FOR UNIVERSAL WASTE ACCUMULATION AREA (UWAA)

STORAGE/CONTAINERS

LABELING

SPILLS/SPILL CONTROL EQUIPMENT

INSPECTION/TRAINING

SECTION 4 – POLLUTION PREVENTION

4.1 PRODUCT SUBSTITUTION

4.2 CONSERVATION

4.3 REUSE

4.4 CHANGE PROCESSES

SECTION 5 - REFERENCES AND REGULATIONS

SECTION 1.0 - INTRODUCTION

1.1 INTRODUCTION

This plan was developed for the Allegheny National Forest (ANF). Waste generation in most cases is a direct result of improper management of hazardous materials. Cost to manage hazardous waste is exorbitant due to regulatory oversight, loss of Forest Service productivity, loss of usable product, and storage, transportation and disposal of wastes. A Conditionally Exempt Small Quantity

Generator (CESQG) of hazardous waste generates less than 100 kg (approximately 220 lbs.) of hazardous waste, or less than 1 kg of acutely hazardous waste per month. A Small Quantity

Generator (SQG) generates between 100 kg and 1,000 kg of hazardous waste per month (between

220 lbs. and 2204 lbs.). Management costs, health issues, and safety issues are improved as an entity such as the Forest Service moves from a SQG to a CESQG. A goal of the Allegheny National

Forest is to attain the lowest category of hazardous waste generation, a rate of 0 lbs. per month.

For the purposes of this plan, it is assumed that all Region 9 forests are presently either a CESQG or a SQG.

To assist the Safety and Occupational Health Specialist and the users of this plan, reference the

Region 9 Guidelines, Checklists, and Appendix documents, which cover specific waste streams (i.e.

Used Oil & Filters District Guidelines and Checklist). These are excellent resources for management of the wastes. The Everyday Hazmat User’s Training Guide is an easy to use reference and guideline for hazardous waste and hazardous material generation. This document will provide additional management tips on management techniques of hazardous materials and waste issues. These documents should be used by the ANF in conjunction with this plan to enhance the efficiency of the purpose of this plan.

1.2 OVERALL PLAN PURPOSE

The purpose of this plan is to assist the ANF with managing their hazardous materials and hazardous wastes.

The plan should be used as a “living document” and reviewed and revised frequently in order to help the

ANF understand compliance issues, the economics of waste generation, and initiatives needed to reduce and eventually eliminate hazardous waste generation.

1.3 HOW THIS PLAN SHOULD BE USED AND BY WHOM

This plan should be adopted by the Forest Supervisor and delegated to Line Officers with specific responsibilities and controls for purchasing hazardous materials and managing hazardous waste. If hazardous waste is generated, a specific person (Hazardous Waste/Material Program Manager) should be identified and trained to handle hazardous material issues and hazardous waste management. The Forest

Safety and Occupational Health Specialist should review this plan annually, at a minimum, to update it as needed, arrange necessary training, and develop goals for the ANF to provide for continuous improvement in the principals presented in the plan; namely the reduction of hazardous waste generation and the proper management of hazardous materials.

SECTION 2.0 – HAZARDOUS MATERIALS

What is a hazardous material?

A hazardous material is any item or agent (biological, chemical, physical) that has the potential to cause harm to humans, animals, or the environment, either by itself or through interaction with other factors.

Hazardous materials are defined and regulated in the United States primarily by laws and regulations administered by the U.S. Environmental Protection Agency (EPA), the U.S. Occupational Safety and Health

Administration (OSHA), the U.S. Department of Transportation (DOT), and the U.S. Nuclear Regulatory

Commission (NRC). Each has its own definition of a “hazardous material.”

OSHA’s definition includes any substance or chemical which is a “health hazard” or “physical hazard,” including: chemicals that are carcinogens, toxic agents, irritants, corrosives, sensitizers; agents that act on the hematopoietic (blood cell formation) system; agents which damage the lungs, skin, eyes, or mucous membranes; chemicals that are combustible, explosive, flammable, oxidizers, pyrophorics, unstable-reactive or water-reactive; and chemicals that in the course of normal handling, use, or storage may produce or release dusts, gases, fumes, vapors, mists or smoke, which may have any of the previously mentioned characteristics. (Full definitions can be found at 29 Code of Federal Regulations (CFR) 1910.1200.)

The EPA incorporates the OSHA definition, and adds any item or chemical that can cause harm to people, plants, or animals when released by spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping or disposing into the environment. (40 CFR 355 contains a list of over

350 hazardous and extremely hazardous substances.)

USDOT defines a hazardous material as any item or chemical which, when being transported or moved, is a risk to public safety or the environment, and is regulated as such under the following regulations: Hazardous

Materials Regulations (49 CFR 100-180); International Maritime Dangerous Goods Code; Dangerous Goods

Regulations of the International Air Transport Association; Technical Instructions of the International Civil

Aviation Organization; and U.S. Air Force Joint Manual, Preparing Hazardous Materials for Military Air

Shipments.

The NRC regulates items or chemicals which are “special nuclear source” or by-product materials or radioactive substances. (See 10 CFR 20).

A few examples of hazardous materials typically stored and used in the USDA Forest Service include:

• Gasoline • Drip Torch Fuel • 2-Cycle Engine Oil • Fuses

• Fertilizers • Pesticides/herbicides • Propane • Bar & Chain Oil

• Household-Type Cleaning Products

• Potassium permanganate

(“ping pong balls”)

• Automotive-Type Fluids

• Various Types of Paints

2.1 HOW TO CLASSIFY HAZARDOUS MATERIALS FOR PROPER STORAGE

The purpose of this section is to identify and classify hazardous materials that are commonly found in the

USDA Forest Service. Once identified, the initiative is established to provide the proper storage, handling, use and, when needed, removal of these hazardous substances.

Safety Data Sheets (SDSs)

In order to safely and properly handle and store hazardous materials, it is important for employees to first know the hazards of those materials. Although the label on a container may appear to be an ideal place to start, the label may not necessarily contain enough data to inform the user on how to properly store, transport or handle that material. Instead, the best source of information for the specific type, purity and hazards of a material is its Safety Data Sheet (SDS), (formerly Material Safety Data Sheet or MSDS). The

Hazard Communication Standard (HCS) (29 CFR 1910.1200(g)), revised in 2012, requires the chemical manufacturer, distributor, or importer to provide a user-friendly, 16-section SDS for each hazardous material. Commencing June 1, 2015 the 16 sections of an SDS, which must be in English and in a uniform format, will include the following headings and associated information:

• Section 1: Identification product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restrictions on use.

• Section 2: Hazard(s) identification includes all hazards regarding the chemical.

• Section 3: Composition/information on ingredients includes information on chemical ingredients;

trade secret claims.

• Section 4: First-aid measures includes important symptoms/ effects, acute, delayed; required treatment.

• Section 5: Fire-fighting measures lists suitable extinguishing techniques, equipment; chemical hazards from fire.

• Section 6: Accidental release measures lists emergency procedures; protective equipment;

proper methods of containment and cleanup.

• Section 7: Handling and storage lists precautions for safe handling and storage, including incompatibilities.

• Section 8: Exposure controls/personal protection lists OSHA's Permissible Exposure Limits (PELs);

Threshold Limit Values (TLVs); appropriate engineering controls; personal protective equipment

(PPE).

• Section 9: Physical and chemical properties lists the chemical's characteristics.

• Section 10: Stability and reactivity lists chemical stability and possibility of hazardous reactions.

• Section 11: Toxicological information includes routes of exposure; related symptoms, acute and chronic effects; numerical measures of toxicity.

• Section 12: Ecological information*

• Section 13: Disposal considerations*

• Section 14: Transport information*

• Section 15: Regulatory information*

• Section 16: Other information includes the date of preparation or last revision.

• *Note: Since other Agencies regulate this information, OSHA will not be enforcing Sections 12 through 15(29 CFR 1910.1200(g)(2)).

OSHA requires that manufacturers and distributors provide SDSs to all purchasers and furnish new SDSs information upon request. Employees shall not handle hazardous materials that do not have an SDS. SDSs must be readily accessible to employees at all times. If an SDS is not provide or cannot be located, contact the manufacturer or distributor immediately to obtain one prior to handling or storing the product.

Compatibility

Information in an SDS pertaining to a hazardous material’s physical and chemical characteristics

(flammability, explosiveness, ignitability, flashpoint, and corrosiveness), stability and reactivity, toxicology and handling and storage precautions should be closely reviewed. These elements of the SDS should provide the user with the basic knowledge and information needed for properly and safely storing and handling hazardous materials.

When classifying hazardous materials for storage, the first consideration should be to store them based on their compatibility, not randomly or in alphabetical order. Generally, chemicals of the same hazard characteristic are typically stored together (i.e. flammables with flammables {gasoline – drip torch fuel} and oxidizers with oxidizers {“ping pong balls” – ammonium nitrate fertilizer}, and incompatibles such as flammables and oxidizers must be segregated.

Incompatible materials must not be stored such that they may come in contact with each other. If incompatible materials are allowed to mix, dangerous conditions will result. Combining these materials may result in the following: increased heat or pressure; fire or explosion; violent reaction; toxic dusts, mists, vapors, or gases; and flammable vapors or gases. The specific SDS should always be consulted when doubts arise concerning chemical properties and associated hazards.

Segregation of Hazardous Materials Families

Upon reviewing the information provided in the SDS, the material should be first classified into a primary segregation category based upon compatibility hazard characteristics. Materials within each major classification can also be classified for storage within subcategories (also known as secondary segregation).

The following hazard classes used for primary segregation pertain to items typically used in the USDA Forest

Service:

• Flammable and Combustible Chemicals: Flammable items post a serious threat of fire if stored improperly. Many of these items indicate “Do not store near heat” or “Keep in cool, dry place.” US

DOT is responsible for determining what constitutes a flammable material, and has offered the following definitions for ignitable chemicals:

Flammable Liquid (Class II Combustible) - Any liquid with a flash point greater than or equal to or 100°F (37.8°C) C and less than or equal to 140°F (60°). Common examples used in the Forest Service include: gasoline and drip torch fuel.

Flammable Liquid (Class IIIA Combustible) - Any liquid with a flash point greater than

140°F (60°C) and below 200°F (93.3°C), and does not meet the definition of any other hazard class. Common examples used in Forest Service include: motor oils and bar/chain oil.

Flammable Liquid (Class IIIB Combustible) – Any liquid with a flash point great than 200°F

(93.3°C).

Flammable Gas - A compressed gas that satisfies the criteria for flame projection, lower flammability limit and flammability range. A common example used in the Forest Service is propane (also known as liquefied petroleum gas or LPG).

Flammable Solid - A non-explosive material that is capable of producing fire as a result of friction, heat retained from production or which, if ignited, produces a serious transportation hazard (a common example used in the Forest Service are fusees).

The flash point of a liquid is the lowest temperature at which the liquid can vaporize in sufficient concentration to form an ignitable mixture in air. Within the flammability category, flammable liquids (e.g. gasoline), flammable solids (e.g. fusees), and flammable gases (e.g. propane) are further subcategorized when storing (secondary segregation), as these materials if stored together could act as an accelerant to one another if an incident were to occur.

• Corrosive Materials (acids/bases): Corrosive materials can dissolve or wear away a container. Also, most of the chemicals that are corrosive to containers are potentially dangerous to the skin and eyes of humans and animals. A few common corrosives include metal cleaners with phosphoric acid, drain cleaners that contain sulfuric acid (battery acid), rust removers with hydrofluoric acid, and drain cleaners containing sodium hydroxide or lye.

Within the corrosive classification, acids (pH <7) and bases (pH >7) are further subcategorized for storage (secondary segregation), as these materials can become reactive with one another. An example is mixing bleach (a base) with muriatic acid (more commonly known as hydrochloric acid), which will release toxic chlorine gas. Mixing muriatic acid and potassium permanganate (contents of “ping pong balls”, an oxidizer) will also be reactive and release toxic chlorine gas. Even within the same pH category, exceptions to this rule can exist and require further segregation. An example is the incompatibility of bleach (a strong base) and ammonia (a weak base), both of which are commonly used cleaning solutions. Although they are both bases, the mixing of aqueous ammonia with bleach is exceedingly dangerous and produces a toxic and carcinogenic mixture of chloramine and hydrazine.

• Toxic or Poisonous Materials - Toxic materials are those materials that, in sufficient quantities, pose a hazard to human health. They are sometimes identified with the symbol of skull and crossbones.

Most janitorial supplies potentially contain toxic materials, from air fresheners and carpet deodorizers to mothballs, rodenticides and pesticides. Toxic materials can often be used safely if used as directed by the manufacturer. Common toxic or poisonous materials used in the USDA

Forest Service include herbicides, insecticides, fungicides, fumigants, and rodenticides.

• Oxidizing Materials (Oxidizers): Oxidizers are compounds which are capable of reacting with and oxidizing (i.e., giving off oxygen) other materials. A well-known example of oxidation is the process of corrosion, where metal reacts with air to form metal oxides referred to as “rust”. The primary hazard associated with this class of compounds lies in their ability to act as an oxygen source, and thus to readily stimulate the combustion of organic materials. Common oxidizers used in the USDA

Forest Service include ammonium nitrate fertilizer, and potassium permanganate (“ping pong balls”). Oxidizers are highly incompatible with flammable materials. Oxidizing chemical products often end in -ite, -ate, or -ide.

• Other Chemical Families: Compressed gasses, cryogens, pyrophorics, water reactives and explosives are other common hazardous chemical families.

One problem with the implementation of the segregation system based on hazard classification is that many chemicals have multiple hazards as they belong to more than once chemical family or hazard class. For example, some chemicals may be both corrosive acids and combustible liquids. In such cases, the chemical must be stored away from both corrosive bases and oxidizing acids.

When establishing a storage scheme, the number one consideration should be the flammability characteristics of the chemicals. If a chemical is flammable, it should be stored in a flammable liquids storage cabinet. If a chemical will contribute significantly to a fire (e.g. oxidizers), it should be isolated from all flammable chemicals. In the event of a fire involving a water-reactive chemical in which response with water would exaggerate the situation, isolate the water-reactive chemical from contact with water, steam or moisture. Next look at the corrosivity of the material, and store accordingly. Finally, consider the toxicity of the material, with particular attention paid to regulated materials. In some cases, this may mean that certain chemicals will be isolated within a storage area. For example, a material that is an extreme poison but is also flammable, should be locked away in the flammable storage area to protect it against accidental release. There will always be some chemicals that will not fit neatly in one category or another, but with careful consideration of the hazards involved, most of these cases can be handled in a reasonable fashion.

The chart below provides a visual diagram of primary and secondary segregation control areas.

Flammable / Combustible Liquids

(gasoline/oils)

Toxic or Poisonous materials

(herbicides/pesticides) Corrosive Materials

Oxidizers (fertilizers/”ping pong balls”)

In general, incompatibles are stored in control areas that are separated by a physical means of at least

20 feet or by a 1-hour firewall (example - flammables and oxidizers), and in some cases a minimum of a

4-foot aisle way between secondary segregation areas (example – flammable liquids, solids, and gases).

Relative to indoor storage, no more than four segregated control areas should be allowed for each structure.

Some materials, such as flammable and combustible liquids, have further requirements for storage; see 2.3

(Storage Requirements) below for further discussion.

Section III of the USDA Everyday Hazmat User’s Training Guide is an excellent resource and should also be consulted in assistance with the classification of a unit’s hazardous materials prior to storage.

2.2 PRODUCT TYPES/NAMES

OSHA has updated hazardous material labeling requirements under its Hazard Communication Standard

(HCS), bringing it into alignment with the United Nations’ Globally Harmonized System of Classification and

Labelling of Chemicals (GHS). Taking effect on June 1, 2015, all hazardous materials shipped by

Ammonia

Flammable Solids (Fusees)

Flammable Gases (Propane)

Acids

Bases

Bleach (sodium hypochlorite) manufactures must be labeled according to the GHS, which requires labels to contain the following elements:

• Name, Address and Telephone Number of importer, manufacturer of other responsible party;

• Product Identifier includes, but is not limited to, chemical name, code, or batch number;

• Signal Words consist of only 2 possible words: “Danger” and “Warning”. Danger is for more severe hazards, and Warning for less severe. Only one signal word warrants Danger while another warrants

Warning, Danger should appear on the label;

• Hazard Statements are specific to hazard classification categories. Examples may include, o May cause fire or explosion - strong oxidizer o Causes sever skin burns and eye damage

• Precautionary Statements describe recommended measures to be taken to minimize or prevent adverse effects. Precautionary statements may include prevention, response, specific treatment, in case of fire, storage, and disposal. They may also include precautionary pictograms;

• Supplemental information (if needed) such as recommended Personal Protective Equipment (PPE);

and

• Pictograms are red square frames set at a point and contain a hazard symbol. The GHS uses 9 pictograms. OSHA will enforce the use of 8 of these. The environmental pictogram is not mandatory, but may be used as supplementary information.

Employers must be fully compliant with the GHS by June 1, 2016. A sample HCS label is shown below. As mentioned in section 2.1 above, the label itself may not contain enough information to the user to properly allow for classification and, therefore the SDS must be relied upon as the best source of information when classifying materials for storage.

Sometimes found on labels of containers and on SDSs, two forms of hazardous materials identification that had become popular as a rapid identification system are the NFPA 704M sign (NFPA hazard diamond) and the basic HMIS® hazard warning label. The following sections describe NFPA and HMIS, neither of which fully conform to the GHS labelling system but will continue to be encountered for years and possibly decades on chemical containers. Until December 1, 2015, distributors may continue to ship containers labelled by manufactures or importers (but not by the distributor themselves) in compliance with the Hazard

Communications Standard of 1994 (HazCom 1994).

NFPA

The National Fire Protection Association (NFPA) is a voluntary standard setting organization that has addressed hazard recognition through labeling. The NFPA label is diamond-shaped, with four color-coded quadrants, and contains numbers and special symbols to denote degrees of hazards.

Color Codes Blue = health hazard Red = fire hazard Yellow = reactivity hazard White = other hazard information

NFPA “Diamond”

Numbers (degree of hazardous):

4 = extreme hazard 3 = serious hazard 2 = moderate hazard 1 = slight hazard 0 = no or minimal hazard

Special Symbols

= reactive to water SA = simple asphyxiant OX = oxidizer Acid = corrosive with pH lower than 7.0 ALK = corrosive with pH higher than 7.0 COR = corrosive (either acid or base)

= symbol for corrosive

= symbol for poison or highly toxic

= symbol for radioactivity

= symbol for explosive

HMIS®

The Hazardous Materials Identification System (HMIS®) was developed by the National Paint & Coatings

Association (NPCA), now known as the American Coatings Association, to help employers comply with

OSHA’s HazCom 1994 (29 CFR 1910.1200), prior to the updated revision HazCom 2012. HMIS® utilizes colored bars, numbers and symbols to convey the hazards of materials used in the workplace. At first glance, the HMIS® and NFPA labeling systems appear quite similar. Both have four sections colored blue, red, yellow and white. HMIS® uses colored bars, while NFPA uses colored diamonds. HMIS® attempts to convey full health warning information to all employees, while NFPA is meant primarily for fire fighters and other emergency responders. Do not confuse HMIS® labels (colored bars) with NFPA labels (colored diamonds).

The two systems are similar, but not identical. The HMIS® has gone through three versions, known as HMIS®

I, II, and III. The newest version, which has integrated more OSHA elements, is HMIS® III, and is described below.

Health (blue) According to NPCA, the numeric hazard assessment procedure is different than that used by NFPA.

4 Life-threatening, major or permanent damage may result from single or repeated overexposures 3 Major injury likely unless prompt action is taken and medical treatment is given 2 Temporary or minor injury may occur 1 Irritation or minor reversible injury possible 0 No significant risk to health

* In the latest version of HMIS®, the blue Health bar has two spaces, one for an asterisk and one for a numeric hazard rating. If present, the asterisk signifies a chronic health hazard, meaning that long-term exposure to the material could cause a health problem such as emphysema or kidney damage.

Flammability (red) The flammability criteria are defined according to the OSHA standard classes.

4 Flammable gases, or very volatile flammable liquids with flash points below 73 °F, and boiling points below 100 F. Materials may ignite spontaneously with air. (Class IA) 3 Materials capable of ignition under almost all normal temperature conditions. Includes flammable liquids with flash points below 73 °F and boiling points above 100 °F, as well as liquids with flash points between 73 °F and 100 °F. (Classes IB & IC) 2 Materials which must be moderately heated or exposed to high ambient temperatures before ignition will occur. Includes liquids having a flash point at or above 100 °F but below 200 °F. (Classes II & IIIA).

1 Materials that must be preheated before ignition will occur. Includes liquids, solids and semi solids having a flash point above 200 °F. (Class IIIB).

0 Materials that will not burn

Physical Hazard (orange) Reactivity hazards are assessed using the OSHA criterion of physical hazard - Hazard classes: Water Reactive, Organic Peroxides, Explosives, Compressed gases, Pyrophoric materials, oxidizers, and unstable reactive.

4 Materials that are readily capable of explosive water reaction, detonation or explosive decomposition, polymerization, or self-reaction at normal temperature and pressure.

3 Materials that may form explosive mixtures with water and are capable of detonation or explosive reaction in the presence of a strong initiating source. Materials may polymerize, decompose, self-react, or undergo other chemical change at normal temperature and pressure with moderate risk of explosion.

2 Materials that are unstable and may undergo violent chemical changes at normal temperature and pressure with low risk for explosion. Materials may react violently with water or form peroxides upon exposure to air 1 Materials that are normally stable but can become unstable (self-react) at high temperatures and pressures.

Materials may react non-violently with water or undergo hazardous polymerization in the absence of inhibitors 0 Materials that are normally stable, even under fire conditions, and will not react with water, polymerize, decompose, condense, or self-react. Non-explosives.

Personal Protection (white) In the NFPA system, the white area is used to convey special hazards whereas HMIS® uses the white section to indicate what personal protective equipment (PPE) should be used when working with the material.

HMIS® uses a letter coding and icon system for this section.

A safety glasses B safety glasses, gloves C safety glasses, gloves, protective apron D face shield, gloves, protective apron E safety glasses, gloves, dust respirator F safety glasses, gloves, protective apron, dust respirator G safety glasses, gloves, vapor respirator H splash goggles, gloves, protective apron, vapor respirator I safety glasses, gloves, dust respirator, vapor respirator J splash goggles, gloves, protective apron, vapor respirator, dust respirator K airline mask or hood, gloves, full suit, boots L through Z site specific label (ask supervisor or safety specialist for handling instructions) *In most instances, in order to avoid confusion with the lettering system, it is recommended that if utilize by the USDA Forest Service that the personal protective section be completed by simply spelling out the protective equipment needed on the label.

As previously mentioned, the NFPA diamond and the HMIS® bars do not fully satisfy the OSHA labeling requirements. For example, a number “4” category for health on a NFPA label tells you nothing about how to protect yourself with respect to inhalation, absorption, or digestion hazards. HMIS® labels also come available with additional information that meets the OSHA labeling requirements.

Inventory

Other than ensuring all hazardous materials are properly labeled and all SDSs are available, a hazardous material inventory must be maintained and must be readily accessible to all employees. The Office of

Inspector General (OIG) has recommended the development and implementation of Department-wide policies and procedures to ensure hazardous material inventories are conducted and all department agencies compile a secure, comprehensive inventory of chemicals. OIG further recommended that these inventories be completed quarterly and reported to the department at least annually. As a result, USDA has required its agencies to complete a quarterly inventory and certification report of all hazardous materials by the 15th of the month following the end of each quarter. The unit’s hazardous materials coordinator should ensure that inventories are kept up-to-date with this policy. Each unit’s hazardous materials inventory is maintained in Appendix A of their Hazardous Communications Plan.

2.3 STORAGE REQUIREMENTS

Many of the storage requirements presently recommended have been learned through experience and incorporated from codes and regulations. Others are more in the form of recommended practices. Storage guidelines are included for materials that are flammable, oxidizers, corrosives, and highly toxic (items which would more commonly be found in use with the USDA Forest Service). Always review the SDS, and / or consult with an expert when in doubt about proper segregation and storage.

Additional information for storage of hazardous materials can be found in the USDA Everyday Hazmat User’s

Guide, Section III (Hazardous Materials Management), pages 37 – 101.

GENERAL

The following are some general rules that must be practice with respect to safe hazardous materials storage:

• The quantities of materials that are stored should be minimized, as specified by NFPA 45 and OSHA.

Many authorities recommend that the NFPA guidelines for maximum quantities and sizes of containers should be reduced to one-half or even one-third of the recommended values.

• Hazardous substances should be stored in an orderly manner with older products most accessible

(so they will be used and depleted first) and the newer products least accessible.

• Good housekeeping must be practiced in areas where hazardous products are stored.

• All hazardous materials must be properly labeled including their exact contents, hazardous properties (routes of exposure, target organs, and personnel protective equipment), manufacturer of the product, date of receipt, and if appropriate, date of expiration.

• Hazardous substances should be stored in original containers in which they were packaged at the manufacturing plant. If this is not practical, these products should be transferred according to manufacturers’ recommendations into containers that are constructed to withstand the effects of the product over the maximum storage time.

• Materials must be stored at an appropriate temperature and humidity level. This can be especially problematic in hot, humid climates. As a rule, chemicals should not be stored near heat sources, such as steam pipes. Chemicals should never be stored in direct sunlight.

• Visual inspection of the material and its container should be conducted routinely. Indications for disposal include: cloudiness in liquids, material changing color, evidence of liquids in solids or solids in liquids, “puddling” of material around outside of container, pressure build-up within bottle, and obvious deterioration of container.

• Incompatible materials must not be stored in a manner for which they may come in contact with each other (a minimum of 20 feet between control areas {or 1-hr. firewall} and maximum of 4 control areas per building).

Flammable Liquids

To prevent fires, hazardous liquids need special precautions taken for their storage, handling and use. NFPA and the International Code Council (ICC) have developed guidelines for the safe storage and use of flammable and combustible liquids under the Uniform Fire Code (UFC). These guidelines are not mandatory unless a federal, state or local authority chooses to use them.

Mandatory regulations have been developed, however, by OSHA. They have specified safe handling practices under three separate mandatory regulations for: General Industry (29 CFR 1910.106), Construction

Industry (29 CFR 1926.152), and Shipyard Industry (29 CFR 1915.36).

For the purpose of this document, only the requirements of the General Industry will be discussed.

Defining Flammable and Combustible Liquids To understand OSHA requirements for the safe storage of flammable and combustible liquids, we must begin by defining the two. The flashpoint and boiling point determine the class of a liquid.

Category Criteria

1 Flashpoint < 23 °C and initial boiling point ≤ 35 °C

2 Flashpoint < 23 °C and initial boiling point > 35 °C

3 Flashpoint ≥ 23 °C and ≤ 60 °C

4 Flashpoint > 60 °C and ≤ 93.3 °C

A flammable liquid is any liquid having a flashpoint below 100 °F (37.8 °C) (except any mixture having components with flashpoints of 100°F (37.8°C) or higher, the total of which make up 99 percent or more of the mixture). Flammable liquids are categorized into three groups, as follows:

• Class IA Flammable Liquid: Liquids having flashpoints below 73 °F (23 °C) and having boiling points below 100°F (37.8°C) Examples: ethyl ether, ethylene oxide, some light crude oils.

• Class IB Flammable Liquid: Liquids having flashpoints below 73 °F (23 °C) and having boiling points at or above 100° F (37.8°C). Examples: motor and aviation gasoline, toluene, lacquers, lacquer thinner.

• Class IC Flammable Liquid: Liquids having flashpoints at or above 73 °F (23 °C) and below 100° F

(37.8°C). Examples: xylene, some paints, some solvent-based cements, and turpentine.

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A combustible liquid is any liquid having a flashpoint at or above 100 °F (37.8 °C). Combustible liquids are divided into two classes:

• Class II Combustible Liquid: Liquids having flashpoints at or above 100 °F (37.8 °C) and below 140

°F (60 °C), except any mixture having components with flashpoints of 200 °F (93.3 °C) or higher, the volume of which make up 99 percent or more of the total volume of the mixture

(1910.106(a)(18)(i)). Examples: diesel fuel, paint thinner, Stoddard solvent.

• Class III Combustible Liquid: Liquids having flashpoints at or above 140 °F (60 °C). Class III liquids are subdivided into two subclasses:

o Class IIIA Combustible Liquid: Liquids having flashpoints at or above 140°F (60°C) and below

200°F, except any mixture having components with flashpoints of 200 °F (93.3 °C) or higher, the total volume of which make up 99 percent or more of the total volume of the mixture.

Examples: home heating oil.

o Class IIIB Combustible Liquid: Liquids having flashpoints equal to or greater than 200 °F

(93.3 °C). Examples: cooking oils, lubricating oils, motor oils.

Flammable and Combustible Liquids – Safety Cans One technique to reduce the hazards associated with flammable and combustible liquids is the use of safety cans. OSHA defines a safety can as: “An approved container, of not more than 5 gallons capacity, having a spring-closing lid and spout cover and so designed that it will safely relieve internal pressure when subjected to fire exposure”.

This definition allows a wide variety of containers to be considered safety cans.

However, many local laws and insurance carriers require safety cans to be Underwriter Laboratory (UL) approved. OSHA also recognizes UL.

In addition, OSHA limits the amount of liquid in a single safety can. The following chart shows the allowable amounts for each class of liquid.

Maximum Allowable Size of Containers and Metal Portable Tanks

Container Type Flammable Liquids Combustible Liquids

Class IA Class IB Class IC Class II Class III Glass or approved plastic 1 pint 1 quart 1 gallon 1 gallon 1 gallon Metal (other than DOT drums) 1 gallon 5 gallon 5 gallon 5 gallon 5 gallon Safety Cans 2 gallon 5 gallon 5 gallon 5 gallon 5 gallon Metal Drum (DOT spec.) 60 gallon 60 gallon 60 gallon 60 gallon 60 gallon Approved Metal Portable Tanks 660 gallon 660 gallon 660 gallon 660 gallon 660 gallon

OSHA also limits the total amount of a liquid kept outside of a safety cabinet or storage room. The quantity of liquid that may be stored outside of an inside storage room or flammable liquid storage cabinets in any one fire area of a building cannot exceed:

• 25 gallons of Class IA liquids in containers http://www.labsafety.com/refinfo/ezfacts/Flammable-Combustible-Liquids-Safety-Cans-179.htm

• 120 gallons of Class IB, IC, II or III liquids in containers

• 660 gallons of Class IB, IC, II or III liquids in a single portable tank

The amount of liquid storage and location of cabinets is also regulated by OSHA. Regulations state “Not more than 60 gallons of Class I or Class II liquids, nor more than 120 gallons of Class III liquids may be stored in a storage cabinet.” Also, according to NFPA 304.3.2, not more than three (3) such cabinets may be located in a single fire area.

Flammable and Combustible Liquids – Storage Cabinets Another fundamental means of fire protection is the use of flammable storage cabinets.

NFPA, OSHA, and UFC require flammable cabinets to be designed and constructed to specific requirements. OSHA regulations state that metal cabinet shall be constructed in the following manner:

• Bottom, top and sides of cabinet shall be at least No. 18 gage sheet steel

• Cabinet must be doubled walled with 1½” airspace

• Joints shall be riveted, welded or made tight by some equally effective means

• Door shall have a three-point latch

• Door sill shall be raised at least 2” above the cabinet bottom to retain spilled liquid within the cabinet

• Cabinet shall have a “FLAMMABLE—KEEP FIRE AWAY” legend

In addition to the requirements listed above, the UFC also requires self-closing doors. Most local authorities use one or more of these standards as a foundation for establishing local codes.

Flammable Solids (Fusees)

Fusees (also known flares) should not be stored with flammable liquids. These two together could act as an accelerant thus potentially defeating the design of a flammable liquids cabinet which is intended to protect from fire for 10 minutes to allow for safe evacuation. Flammable solids should be segregated from flammable and combustible liquids, with a minimum of a 4 foot aisle space. They should be stored in a cool dry place within a sound cabinet or on sound shelving. No more than 100 pounds of flammable solids should be kept onsite (>100 lbs. may exceed local fire code requirements). Other important requirements include: floors in the storage area should be noncombustible, shelves should be noncombustible, materials labeled as a flammable solid, and a sign indicating flammable and “no smoking” in the control area.

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Flammable Gases (Portable Propane - stored for use)

Propane cylinders must not be stored with flammable liquids. Propane is not a flammable liquid, it is a flammable liquefied gas. This difference is very important and the reason that the two must not be stored improperly. A flammable liquids storage cabinet is designed to protect flammable liquid containers from fire for 10 minutes to allow for safe evacuation. Propane storage is severely restricted in buildings because of its rapid evolution of gas from leaking containers, which is in orders of magnitude greater than the evolution of flammable vapors from flammable liquids. NFPA limits the storage of propane in buildings:

1) buildings frequented by the public are limited to cylinders with a propane capacity of 1 pound and the total quantity stored is limited to 200 pounds of propane and 2) buildings not frequented by the public are limited to a maximum quantity of 300 pounds of propane (the cylinder size is not restricted). Storage of propane containers indoors is not recommended, it is therefore USDA Forest Service’s position to keep propane stored outdoors.

The following storage requirements for propane must be followed:

• Cylinders must be stored in well-vented enclosure or rack that is secured (lockable).

• Consumer-type propane cylinders (type typically used in the Forest Service) must be stored upright (vertically).

• No smoking and danger flammable gas signs must be placed on the storage area.

• Storage should be in a manner that minimizes exposure to the excessive temperatures and physical damage, stored in a location that would prevent damage by vehicles.

• The storage container must be at least 20 feet from any doorway or building opening, and can be stored next to a building provided that the storage area contains 500 lbs or less of propane.

• Flammable materials and combustible materials such as weeds or wood must be removed within 10 feet of the propane storage enclosure.

• No smoking, no open flames, no welding, or no sources of ignition should be enforced within 20 feet of the storage area.

• Cap all valves when storing.

• Empty containers should always be treated as though they were full.

Corrosives (Acids and Bases)

Corrosives used in the USDA Forest Service most typically pertain to cleaning products and batteries. Corrosives can be stored outdoors or indoors; however, it is highly recommended that they be stored indoors whenever possible to prevent degradation to the quality of the product and its container. Control areas can be in offices, basements, or garages.

As previously discussed in Section 2.1 above, corrosives are further subcategorized into acid and base control areas. However, as also previously discussed above, the SDS must be given close attention as incompatibilities may exist even within a secondarily segregated control area (example - ammonia and bleach, both are bases, but can be dangerously reactive if mixed).

It should be noted that aqueous liquids, especially those with a <2 or >12.5 pH, are capable of corroding steel very rapidly. The fumes of these corrosives in the presence of humidity will also condense predominately on metal surfaces. When the water evaporates, you are left with a very corrosive residue.

Therefore, it is recommended that shelving for storing of corrosives to be construction of a polyethylene material (when possible), which is impervious to the detrimental effects of harsh acids and other corrosive chemicals. Wood cabinets with a laminate finish also work well for chemical durability. Long-lasting wood core construction provides exceptional strength, and stainless steel handles and hinges resist the corrosive effects of harsh acids and bases.

The following storage requirements for corrosives must be followed:

• Each control area should have a “corrosive” hazard identification and “no smoking” sign;

• All products must have a corrosive label;

• All containers must to stored sound with tight lids; and

• Store no more than a total 5,000 lbs. of a solid corrosive or no more than a total of 500 gallons of a liquid corrosive per control area.

Oxidizers

Oxidizers used in the USDA Forest Service typically include ammonium nitrate fertilizer and potassium permanganate “ping pong balls”.

Oxidizers may be grouped into 4 classes based on their ability to affect the burning rate of combustible materials or undergo self-sustained decomposition. This classification system was established by the NFPA as a means to provide information on safe storage of oxidizing materials. These materials are classified according to the following guidelines shown in below.

NFPA Classification System for Oxidizing Materials

Class Rating Hazard Description

Class 1 An oxidizing material whose primary hazard is that it may increase the burning rate of combustible material with which it comes in contact. (ammonium nitrate fertilizer is an example)

Class 2 An oxidizing material that will moderately increase the burning rate or which may cause spontaneous ignition of combustible material with which it comes in contact. (“ping pong balls” is an example)

Class 3 An oxidizing material that will cause a severe increase in the burning rate of combustible material with which it comes in contact or which will undergo vigorous self-sustained decomposition when catalyzed or exposed to heat. (calcium hypochlorite >50% wgt. is an example)

Class 4 An oxidizing material that can undergo an explosive reaction when catalyzed or exposed to heat, shock or friction. (ammonium perchlorate is an example)

The primary consideration in the storage of these materials is that they must be isolated from all flammable or combustible materials (a minimum of at least 20 feet). Small quantities (total of less than 200 pounds) of

Class 1, 2 or 3 oxidizers can be stored. Stringent storage requirements are levied against Class 4 oxidizers in quantities greater in 10 pounds (combined, all Class 4 materials). These materials may not be stored, for quantities above 10 pounds within a building. However, it must be noted that the local fire marshal may require permits for smaller quantity thresholds than those suggested by the NFPA.

Corrosives can be stored outdoors or indoors; however, it is highly recommended that they be stored indoors whenever possible to prevent degradation to the quality of the product and its container. Storage can be in offices, basements, and garages.

The following storage requirements for corrosives must be followed:

• Stored on non-combustible shelving and liquid tight floors;

• All products labeled with an oxidizer label;

• Each control area labeled with an “oxidizer” hazard identification and “no smoking” sign; and

• All containers must to stored sound with tight lids.

Toxic or Poisonous Materials

Toxic or poisonous materials used in the USDA Forest Service include: insecticides, herbicides, fungicides, and repellents. Storage of such items can be highly variable depending on the specific ingredients of the material. The SDS should always be review to determine proper storage requirements, as well as proper application and personal protective measures. Pages 72 through 79 of the USDA Everyday Hazmat User’s Training Guide provide further information on storage of toxic and poisonous materials.

2.4 SPILL RESPONSE

Each unit should have a separate Hazardous Materials Spill Response Plan in place. The plan should provide step-by-step actions to take in the event of a hazardous materials spill, including: information gathering and reporting, establishing who is in charge, knowing who to contact, and which governmental agencies to whom the incident must be reported.

HAZARDOUS MATERIAL SPILL RESPONSE PLAN

I. GENERAL

An agency-wide Environmental Management System (EMS) was developed for the USDA Forest Service that is compliant with the ISO 14001 International Standard. The intention of the EMS is to enable the Forest Service to identify important activities, products, and services with environmental interactions, and consistently provide environmental protection measures as well as achieve objectives for environmental performance. Element 4.4.7 of the ISO standards contains requirements for the creation of a Hazardous Material Spill Response Plan. This section fulfills the hazardous spill requirements of the Element 4.4.7 of the ISO standards.

II. PURPOSE

This plan outlines procedures for emergency awareness, preparation, and response with the purpose of preventing, minimizing and/or mitigating environmental impacts. The procedures listed provide a framework for proper response to emergency situations that occur and may have environmental impacts.

The Hazardous Material Spill Response Plan should be synchronized with the procedures of the Forest Service emergency plans that are created to focus on human safety and health.

III. SCOPE

This plan applies to emergency release situations that could have significant environmental impacts to resources found on the applicable administrative unit of the Forest Service. Spills or discoveries of hazardous materials are emergencies, for which employees may lessen, mitigate, or prevent undesired environmental effects by taking prompt action as described in this plan.

The procedures outlined in this plan apply to activities conducted by Forest Service employees and volunteers, working for the appropriate administrative unit. Contractors and permitees follow emergency procedures as they are identified in the contract or permit, as appropriate.

IV. ROLES, RESPONSIBILITIES, AND RESPONSE ACTIONS

Forest Service Emergency Releases

Use this section when there…