Section_J_-_Atch_71_-_FLETC_OAO_HMWMP.pdf

FEDERAL LAW ENFORCEMENT TRAINING CENTER

OFFICE OF ARTESIA OPERATIONS

(FLETC-OAO)

HAZARDOUS MATERIAL AND

WASTE MANAGEMENT PLAN

Artesia, New Mexico

May 2015 “This is an UNCONTROLLED DOCUMENT printed for reference only May 2015”

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FLETC-OAO Hazardous Material and Waste Management

Table of Contents

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Chapter 1. Introduction 1 Purpose and Scope 1 Reviews and Revisions 1 Applicable Regulations 1

Federal Regulations 1 State Regulations 2

Department of Homeland Security Policies and Directives 2 Responsibilities 2

Environmental Specialist (ES) 2 Safety Specialist 3 FLETC-OAO Health Unit 4 Other Organizations, Activities, Students and Contractors 4 Environmental Coordinator (EC) 5

Chapter 2. Managing Hazardous Materials (HM) 7 Identifying Unwanted and Unserviceable HM 7 Obtaining and Cataloging Safety Data Sheets 7 Determining Hazardous Material Compatibility 8

Method 1: Determining Compatibility Using HMIRS Generated SDSs 8 Method 2: Determining Compatibility Using DOT Hazard Labels 14 Method 3: Determining Compatibility Using OSHA Precautionary Labels 16

Maintaining and Extending Shelf Life 17 Selecting HM Storage Units (Including Compressed Gases) 17

Storage Cabinets 17 Storage Rooms and Buildings 19 Storage Racks 20 Storage for Compressed Gases 20 Moving Cylinders 21

Stocking an HM Storage Locker 22 Conducting an HM Inventory 22 Creating Authorized Use List (AUL) 23

AUL Change Procedures 24 Requesting New or Replacement HM 25 Receiving HM onto the Facility 26

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Hazardous Material Control Point (HMCP) HM Receiving Procedures 26 HM Pick-up and Issue Procedures 27 Ordering Bulk Materials 27

Chapter 3. Managing Waste 29 Waste Management Made Easy – Waste Protocol Sheets 29 Waste Categories 29 Hazardous Waste (HW) 29 Universal Hazardous Waste (UW) 30 Non-Hazardous Industrial Waste (NHIW) 30 Special Waste (Non-RCRA Regulated Waste) 31 General Refuse 31 Generating and Accumulating Waste 31 HW Satellite Accumulation Points 31 Non-HW Accumulation Points 32 Rules for Managing SAPs 32 Obtaining a Waste Accumulation Container 32 Adding Waste to Containers 33 Using Overpack Drums 33 Managing Empty Drums 33 Metal Drums 34 Plastic Drums 34

Chapter 4. Turning in HM and Waste 34 Funding Requirements 34 Turning in HM and Waste to the 270 Day HWSF 34 Turning in Used Oil 36 Transporting HM/HW on FLETC-OAO 36

Chapter 5. Training, Inspections, and Recordkeeping 36 Hazardous Waste Training Regulatory Drivers 36

Federal Regulations 37 State Regulations 37

FLETC-OAOl Hazardous Waste Training Program 37 Who Needs Hazardous Waste Training 37 When Hazardous Waste Training is Required 38 How Hazardous Waste Training Should be Conducted 38

Required Inspections 38 Inspecting Satellite Accumulation Areas 38

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Required Recordkeeping 38 Training Records 38 Inspection Records 39 Other Records 39

Chapter 6. Spill Response 41 Spill Response Actions 41

Chemical Spills Immediately Dangerous to Life or Health 41 Chemical Spills Minimal Hazard/Controlled 41 HM/HW Emergency Resulting in Injury, Fire or Explosion 42 Reporting 42

Arrangement with Local Authorities 42 Emergency Response Equipment 43

Chapter 7. Glossary and Acronyms 45 Glossary 45 Acronyms 45

List of Tables

Table 1-1. EC Compliance Table 5 Table 2-1. Storage Segregation Matrix 9 Table 2-2. DOT Labels 15 Table 2-3. Precautionary Labels 16 Table 5-1. Hazardous Waste Training Category and Associated Regulatory Agency/Body 36

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List of Figures Figure 2-1. Sample Globally Harmonized System (GHS) Labels 14 Figure 2-2. Example Precautionary Label 16 Figure 2-3. Flammable Storage Cabinet 18 Figure 2-4. Store Building 19 Figure 2-5. Storage Rack 20 Figure 2-6. Cabinet Set 22

List of Forms Quarterly Hazardous Materials Storage Inventory Form 28 Sample Individual Hazardous Waste Training Record 40 Spill or Incident Report Record 44

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Introduction

Chapter 1. Introduction This Hazardous Material and Waste Management Plan prescribes responsibilities, policies, and procedures for managing hazardous materials and wastes at the Federal Law Enforcement Training Center, Office of Artesia Operations (FLETC-OAO), and to facilitate compliance with applicable Federal, State, and local laws and regulations.

Purpose and Scope This Plan documents the FLETC-OAO hazardous materials and waste management program. It applies to the following:

• All organizations and activities including partner organizations (PO), students and contractors located on FLETC-OAO which encompasses both the Main Campus and the Range Complex, hereafter referred to as the Facility; and

• Any outside organization or activity training at the Facility.

Reviews and Revisions The FLETC-OAO Administration and Support Division (ASD), Master Plan and Construction Branch (MCB), Environmental Specialist (ES) will review and update this plan every two years or as necessary. Environmental Coordinators (ECs), as well as any other FLETC-OAO personnel directly involved in hazardous material (HM) or hazardous waste (HW) management, are encouraged to provide comments and input to this Plan. To do so, submit recommended changes in writing to the ES at the Facility Environmental Office, Building 70.

Applicable Regulations and Directives

Federal Regulations

In order to comply with the Federal Facilities Compliance Act, the Facility must manage its waste in accordance with (IAW) the Resource Conservation and Recovery Act (RCRA), as amended by the Hazardous and Solid Waste Amendments (HSWA).

Federal waste management regulations are codified in Title 40 of the Code of Federal Regulations (CFR). This Plan provides procedures for complying with the following parts of 40 CFR:

• Part 260 through Part 272 for the regulation of hazardous waste

• Part 273 for the regulation of universal waste

• Part 279 for the regulation of used oil The Facility must also comply with the following:

• Department of Transportation (DOT) Regulations which are incorporated by reference to 49 CFR Parts 170 through 177 regarding hazardous materials transportation; and

• Occupational Safety and Health Act (OSHA) regulations 29 CFR Part 1910 regarding employee safety.

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State Regulations

The New Mexico Environmental Department (NMED) has obtained primacy from the Environmental Protection Agency (EPA) to enforce hazardous and solid waste management standards. These standards are contained in NMED Hazardous Waste Management Regulations, New Mexico Administrative Code (NMAC) 20.4.1, and the New Mexico Solid Waste Act (NMSA), 74-9-1 to §74-9-43.

Department of Homeland Security (DHS) Policy and Directives

FLETC-OAO personnel must comply with the following DHS Management Directives:

• 023-01 Environmental Planning Program;

• 023-02 Environmental Management Program (Revision 01); and

• 025-01 Sustainable Practices (Revision 01)

Responsibilities The following responsibilities are organized according primacy of function.

MCB, ES

The ES will:

• Coordinate, inspect, or manage all aspects of Facility actions relative to environmental regulations.

• Serve as the single point of contact for Federal, State, and local agencies with regard to environmental permits, interpretation of regulatory requirements, and coordination and resolution of noncompliance issues or findings.

• Monitor Facility compliance with Federal, State, and local environmental requirements, including activities of Partner Organizations (PO) and outlying facilities, and recommend to the Site Director necessary or advisable changes in policies to improve program management.

• Prepare all required status and compliance reports relative to solid and hazardous waste management, in accordance with applicable Federal, State, and local regulatory requirements.

• Advise all waste generating activities of Federal, State, local, and DHS requirements for managing solid and hazardous waste, including requirements for permits, reporting, and recordkeeping to ensure compliance.

• Advise the Site Director on the most cost-effective and efficient means of waste storage, treatment, and disposal, to include the sighting of new waste management facilities and storage areas.

• Provide technical assistance and guidance to hazardous waste generating activities, tenants, and operators of RCRA hazardous waste storage facilities (HWSF).

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• Ensure hazardous wastes are properly identified, segregated, and weighed pursuant to

Federal, State, and DHS requirements prior to release for transportation or disposal.

• Coordinate the analysis of waste to determine if it is hazardous and provide copies of waste analysis prior to release for off-site transportation or disposal.

• Coordinate a Facility-wide inventory of all hazardous waste generated and identify the waste generating activities annually.

• Establish, monitor, and execute programs in waste management, including waste minimization, resource recovery, reutilization, and recycling.

• Immediately advise the Site Director of the receipt of enforcement notices of violation, consent orders, or compliance agreements.

• Exercise staff responsibility for directing and coordinating the Hazardous Waste Management Program.

• Monitor the use of hazardous materials to achieve progress in meeting federal and DHS hazardous waste minimization goals and requirements and provide progress reports as required.

• Provide an annual report to the Site Director recommending opportunities for, and progress in achieving, a reduction in the use and toxicity of hazardous materials, following the concurrence of ASD, Chief.

• Advise FLETC-OAO activities on proper requirements for packaging, labeling, and shipping of solid and hazardous material.

• Monitor supply items to identify those that may be categorized as hazardous and/or toxic.

Safety Specialist The Safety Specialist will:

• Assist ES, Health Unit, and other activities of FLETC-OAO in applying safety procedures and standards.

• Conduct field investigations and special studies to support environmental management programs and recommend measures required for protection of health.

• Provide technical assistance in the identification of wastes and guidance on the health and safety aspects of the management and disposal of hazardous and toxic materials.

• Provide work place guidance on daily use of personal protective equipment, including respirators required for personnel involved in surveys, spill response, confined space entry, and abatement actions.

• Provide expertise in compliance matters associated with Occupational Safety and Health Administration (OSHA) health-related Federal, State, and local requirements.

• Exercise staff responsibility for administrative monitoring and medical surveillance of all personnel working on the Facility for hazardous and toxic occupational health hazards.

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FLETC-OAO Health Unit The Health Unit will:

• Provide for the disposal of non-RCRA regulated medical supplies and infectious waste in accordance with federal and state laws and regulations, and this plan.

• Provide the ES with the solid waste and hazardous waste management implications of new and revised Health Unit practices for review and concurrence.

• Prepare and maintain a management plan for the disposal of medical wastes.

• Perform physical examinations before placement, annually during employment, and at the termination of employment for personnel working with asbestos, lead-based paint, or other hazardous materials, as required by DHS Management Directive 248- 01 Medical Quality Management (Revision 00).

• Maintain health records of all personnel and former employees involved in working with asbestos, lead-based paint, and hazardous materials.

Other Organizations, Activities, Students and Contractors Other organizations, activities, students, and contractors will:

• Integrate environmental protection, conservation, and preservation into the planning and execution of the FLETC-OAO training mission to the fullest extent feasible.

• Establish an organizational structure to plan, execute, and inspect established environmental and conservation requirements within their area of responsibility.

• Appoint in writing an Environmental Coordinator (EC), and alternate as required, to assure compliance with this plan.

• Provide required input to Facility Environmental Status Reports.

• Be fully aware of and comply with all applicable Federal, State, and local laws and regulations, both substantive and procedural, for generating, treating, storing, disposing of, and transporting solid and hazardous waste, including the terms and conditions of state and federal solid and hazardous waste permits and reporting requirements.

• Ensure that program and budget requests identify resource requirements to manage solid and hazardous waste programs, including waste minimization, and to achieve and maintain compliance.

• Encourage the use of joint or regional resource recovery with federal and nonfederal agencies (including commercial waste treatment) when advantageous, cost-effective, or more efficient to the Facility.

• Minimize the generation and land disposal of solid wastes and hazardous wastes by promoting waste minimization.

• Generate, transport, store, and dispose of wastes such as pesticides; hazardous chemical stocks; medical supplies; propellants; explosive and pyrotechnic materials;

explosive ordnance; or chemical agents in a manner that protects public health and the environment.

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Environmental Coordinator (EC) The EC will:

• Implement the procedures established by this Plan.

• Conduct inspections (or ensure that inspections are conducted) of waste accumulation areas.

• Implement hazardous waste spill procedures when necessary.

• Function as a liaison on all environmental issues between the organization/activity or contractor and the ES.

• Notify the ES of changes to operations, including process changes, new waste streams, materials used, and materials stored.

• Ensure that personnel receive the proper level of waste management training.

• Ensure that unit regulated waste is turned in to ES in a timely manner, to include wastes generated during training exercises.

Table 1-1 contains a list of the EC required functions, where the information concerning these functions is located in this plan, and the frequency in which these activities must take place.

Table 1-1 EC Compliance Table

Function Information Location

Frequency

Weekly Monthly Quarterly Annually Hazardous Materials

Inventory Chapter 2

X and whenever new supplies are obtained and old supplies depleted

Shelf Life Update Chapter 2 X

Inspection Chapter 2 X

Hazardous Waste Satellite Accumulation Area Inspection

Chapter 3 X

Training Hazardous Communication Chapter 5 X*

Hazardous Waste Chapter 5 X*

HAZMAT (Dept. of Transportation [DOT]) Personnel

Chapter 5

Every three years*

Environmental Coordinator Chapter 5 X*

* Initial training also required upon assignment.

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Managing Hazardous Materials

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Chapter 2: Managing Hazardous Materials Nearly all facilities on FLETC-OAO use HMs, which are essentially those items requiring a Safety Data Sheet (SDS) (formerly known as Material Safety Data Sheet or MSDS). The ES with the Facility Safety Specialist is responsible for the proper management of HMs to minimize safety hazards, prevent spills, and reduce hazardous waste generation. This chapter provides detailed guidance for managing HM. It addresses the following topics in the order one should follow to meet the requirements of the FLETC-OAO, Hazardous Material Management Program (HMMP):

• Identifying unwanted or unserviceable HM

• Obtaining and cataloging SDSs for each HM

• Determining HM compatibility

• Maintaining and extending HM shelf life

• Selecting HM storage units (includes Storing Compressed Gases)

• Stocking HM storage locations

• Conducting HM inventories

• Creating Authorized Use List (AUL)

• Requesting new or replacement products

• Receiving HM onto the Facility

Follow the procedures outlined in this chapter as a minimum requirement for hazardous materials management. While each of the steps may not be required by regulation, they comprise a system that allows the user to prevent and/or reduce waste generation (i.e., pollution prevention (P2)), and ensure the safety of facility personnel working with HMs.

Identifying Unwanted and Unserviceable HM Removing unwanted and unserviceable HM from facilities is key to minimizing safety hazards, preventing spills, and reducing/eliminating hazardous waste generation. To identify and remove unwanted and unserviceable HM, complete the following steps:

1. Walk around the entire facility and check closets, wall lockers, storage rooms, etc., for HM. Collect containers that are:

• Unwanted (excess) or unserviceable HM

• Unlabeled or unidentifiable material that may be hazardous

• Damaged, leaking, or subject to leaking

• Expired and cannot be used for their intended purpose

2. Obtain SDSs, as described in the next section, for all the unwanted and unserviceable HM and process them for turn-in IAW Chapter 4.

Obtaining and Cataloging Safety Data Sheets SDSs provide compatibility information for HMs. They also contain information about the manufacturer, the chemical ingredients, associated hazards, specific handling procedures, and spill response measures. All organizations/activities must maintain a master binder that contains SDS

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May 2015 8 for all the HM being stored at each of their facilities. This section explains how to obtain and catalog required SDSs.

1. Obtain an SDS for each HM in a facility. SDSs can be obtained from the Hazardous Materials supplier or the manufacturer of the product. SDSs can also be obtained by accessing:

http://hazard.com/. If the SDS is not available through either of these sources you may request assistance from the ES. The SDS must be specific to the product's National Stock Number (NSN) and CAGE number (manufacturer's code), (These numbers are printed on the SDS and on the HM container). The SDS must also be for the specific concentration, container type and formulation of the material on hand.

2. Create a binder for each facility with SDSs for each HM stored, and centrally locate it so it is available to all personnel, and that it is readily accessible at all times for review by employees or emergency personnel in the event of a spill or accidental exposure.

3. Create an index in the front of the binder(s) listing the SDSs. Place all SDSs in the binder in an order such that they can be easily found. A preferred method for managing SDSs is to assign a unique number to each SDS and write the number on every container of that HM. This step allows an SDS to be placed in a binder in sequential order, making it easier for employees to find and easier to insert new SDSs.

EXAMPLE: There are five HMs in a facility, and you have ten containers of each. Starting with any one of the HMs, write a “1” on the SDS and on all containers of that HM. For the next HM, write a “2” on the SDS and on all containers of that HM. For the next HM, assign the number 3, and so on. Place the SDSs in the binder in numerical order (i.e., 1, 2, …).

Determining Hazardous Material Compatibility Once the SDSs are obtained for all the HM at the facility, the EC must determine compatibility of the material. Flammables, for instance, must not be stored with oxidizers. The easiest way to determine compatibility is to use SDS. There are two other ways to determine compatibility, as well. All three are discussed in this section.

Method 1: Determining Compatibility Using HMIRS Generated SDSs

When using the HMIRS SDSs method for determining compatibility, complete the following steps:

1. From the SDS, find the Hazard Characteristic Code (HCC) under Physical Chemical Properties.

2. Using the Storage Segregation Matrix in Table 2-1, find the matching HCC located in the far left column.

3. Follow the row across the table and locate the * marking.

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4. Follow the column up from the * marking to the Primary Segregation Letter. These letters stand for the following:

A Radioactive C Corrosive D Oxidizer E Explosive F Flammable G Gas, Compressed

L Low Hazard (General Purpose) P Peroxide, Organic R Reactive T Poison

5. Segregation Letter. For example, store Fs with other Fs (flammables with other flammables) and Cs with other Cs (corrosives with other corrosives).

6. Return to the HM's HCC row and find the "Note" under the Secondary Segregation column.

Go to the back end of the table and read the note for any additional segregation requirements.

7. For example: A facility has an HM with a HCC of F7 (a corrosive alkali that is flammable) and an HM with an HCC of F6 (a corrosive acid that is flammable). Because they are both Fs, it first appears that they could be stored together. However, they both have a Secondary Segregation Note L, which states, “Separate from other flammables and flammables with secondary hazards by at least one four-foot aisle width."

8. Once compatibility is determined, the EC must store the HM accordingly. Go to “Selecting HM Storage Units” section in this chapter for more guidance.

Table 2-1 Storage Segregation Matrix

HCC Hazard Characteristics Group Name

Primary Segregation Secondary Segregation

A C D E F G L P R T

A1 Radioactive, Licensed

* Note A

A2 Radioactive, License Exempt

* Note A

A3 Radioactive, License Exempt, Authorized

* Note A

B1 Alkali, Corrosive Inorganic

* Note B

B2 Alkali, Corrosive Organic

* Note C

B3 Alkali, Low Risk * Note F

C1 Acid, Corrosive & Oxidizer, Inorganic

* Note D

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Group Name

Primary Segregation Secondary Segregation

A C D E F G L P R T

C2 Acid, Corrosive, Organic

* Note E

C3 Acid, Low Risk * Note F

C4 Acid, Corrosive & Oxidizer, Organic

* Note E

C5 Acid, Corrosive & Oxidizer, Organic

* Note E

D1 Oxidizer * None

D2 Oxidizer & Poison * Note G

D3 Oxidizer & Corrosive Acidic

* Note G

D4 Oxidizer & Corrosive Alkali

* Note G

E1 Explosive, Military *

E2 Explosive, Low Risk

* Note A

F1 Flammable Liquid

DOT

PG I, OSHA IA

* Note J

F2 Flammable Liquid

DOT

PG II, OSHA IA

* Note J

F3 Flammable Liquid

DOT

PG III, OSHA II

* Note J

F4 Flammable Liquid

DOT

PG III, OSHA II

* Note J

F5 Flammable Liquid & Poison

* Note L

F6 Flammable Liquid & Corrosive, Acidic

* Note L

F7 Flammable Liquid & Corrosive, Alkali

* Note L

F8 Flammable Solid * Note K

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Group Name

Primary Segregation Secondary Segregation

A C D E F G L P R T

G1 Gas, Poison (Nonflammable)

* Note M

G2 Gas, Flammable * Note N

G3 Gas, Nonflammable

* Note P

G4 Gas, Nonflammable, Oxidizer

* Note R

G5 Gas, Nonflammable, Corrosive

* Note S

G6 Gas, Poison, Corrosive (Nonflammable)

* Note T

G7 Gas, Poison, Oxidizer (Nonflammable)

* Note U

G8 Gas, Poison, Corrosive (Flammable)

* Note V

G9 Gas, Poison, Flammable

* Note W

K1 Infectious Substance

* Note X

K2 Cytotoxic Drugs * Note Y

M1 Magnetized Material

* None

N1 Not Regulated as Hazardous

* None

P1 Peroxide, Organic, DOT Regulated

* None

P2 Peroxide, Organic (Low Risk)

* None

R1 Reactive Chemical, Flammable

* Note Z

R2 Water Reactive Chemical

* Note AA

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Group Name

Primary Segregation Secondary Segregation

A C D E F G L P R T

T1 DOT Poison – Inhalation Hazard

* None

T2 UN Poison, Packing Group I

* None

T3 UN Poison, Packing Group II

* None

T4 UN Poison, Packing Group III

* Note BB

T5 Pesticide, Low Risk

* None

T6 Health Hazard * None

T7 Carcinogen

(OSHA, NTP,

IARC)

* Note CC

V1 Miscellaneous Hazardous Materials – Class 9

* None

V2 Aerosol, Nonflammable

* Note EE

V3 Aerosol, Flammable

* Note EE

V4 DOT Combustible Liquid, OSHA IIIA

* None

V5 Hi-Flash Point Liquids, OSHA

IIIB

* None

V6 Petroleum Products * None

V7 Environmental Hazard

* None

Z1 Article Containing Asbestos

* None

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Group Name

Primary Segregation Secondary Segregation

A C D E F G L P R T

Z2 Article Containing Mercury

* None

Z3 Article Containing Polychlorinated Biphenyls (PCB)

* None

Z4 Article, Battery, Lead Acid, Non-spillable

* None

Z5 Article, Battery, Nickel Cadmium, Non-spillable

* None

Z6 Article, Battery, Lithium

* Note DD

Z7 Article, Battery, Dry Cell

* None

DEFINITION OF NOTES

NOTE A Security Storage – must be well ventilated with limited access.

NOTE B Inorganic Alkali Storage – store away from acids by at least one 4-foot aisle width and away from organic alkalis by at least one 4-foot aisle width.

NOTE C Organic Alkali Storage – store away from acids by at least one 4-foot aisle width and away from inorganic alkalis by at least one 4-foot aisle width.

NOTE D Inorganic Acid Storage – store away from alkalis (caustics) by at least one 4-foot aisle width and away from organic acids by at least one 4-foot aisle width. Separate from other acids with subsidiary risk labels by at least one 4-foot aisle width.

NOTE E Organic Acid Storage – store away from alkalis (caustics) by at least one 4-foot aisle width and away from inorganic acids by at least one 4-foot aisle width. Separate from other acids with subsidiary risk labels by at least one 4-foot aisle width.

NOTE F Further separate into Acid and Alkali storage within the low hazard storage area to keep potentially incompatible products from mixing.

NOTE G Separate from other oxidizers and oxidizers with secondary hazards by at least one 4-foot aisle width.

NOTE H Magazine Storage.

NOTE J Segregate into Flammable Liquid storage separate from flammable solids by at least one 4-foot aisle width.

NOTE K Segregate into Flammable Solid storage separate from flammable liquids by at least one 4-foot aisle width

NOTE L Separate from other flammables and flammables with secondary hazards by at least one 4-foot aisle width.

NOTE M Further segregate into Poison Gas storage within compressed gas area.

NOTE N Further segregate into Flammable Gas storage within compressed gas area.

NOTE P Further segregate into Non-flammable Gas storage within compressed gas area.

NOTE R Further segregate into Oxidizer Gas within the Non-flammable Gas storage that is within the compressed gas area.

NOTE S Further segregate into Corrosive Gas within the Non-flammable Gas storage that is within the compressed gas area.

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NOTE T Further segregate into Corrosive Gas within the Poison Gas storage that is within the compressed gas area.

NOTE U Further segregate into Oxidizer Gas within the Poison Gas storage that is within the compressed gas area.

NOTE V Further segregate into Corrosive Gas and Poison Gas within the Flammable Gas storage that is within the compressed gas area.

NOTE W Further segregate into Flammable Gas within the Poison Gas storage that is within the compressed gas area.

NOTE X Further segregate into Biomedical storage within the Poison storage area.

NOTE Y Further segregate into Medical Security storage within the Poison storage area.

NOTE Z Further segregate into Spontaneously Combustible storage within the Reactive storage area.

NOTE AA Should not store in areas protected with water sprinkler system. Fire protection should be non-water based.

NOTE BB Store away from food.

NOTE CC Further segregate within Poison storage area may be necessary if secondary hazards exist (i.e. flammable, corrosive, etc.).

NOTE DD Separate from other products within the Reactive storage area.

NOTE EE Store aerosols from flammables by placing in separate room or barrier such as floor to ceiling wire mesh, chain link fence, etc. to protect personnel from aerosols that can become self-propelled projectiles.

Method 2: Determining Compatibility Using DOT, Sample Globally Harmonized System (GHS) Hazard Labels

1. If an SDS is not immediately available, look for a DOT Hazard Label on the container or the box the HM was shipped in.

Figure 2-1 Sample Globally Harmonized System (GHS)

Labels

2. If a GHS label is present, use Table 2-2 below to obtain an Interim HCC.

3. Once you have the Interim HCC, go back to Table 2-1 and follow Steps 2 through 7 under Method 1 to determine compatibility.

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Table 2-2 DOT Labels

DOT Label Interim HCC Recommended Storage Area Primary Secondary

Explosive 1.1 E1 Explosive Magazine NA

Explosive 1.2 E1 Explosive Magazine NA

Explosive 1.3 E1 Explosive Magazine NA

Explosive 1.4 E2 Explosive Security

Explosive 1.5 E2 Explosive Security

Explosive 1.6 E2 Explosive Security

Poison Gas G1 Compressed Gas Poison Gas Cylinder

Flammable Gas (Cylinder) G2 Compressed Gas Flammable Gas Cylinder

Flammable Gas (Aerosol Non-refillable Tank or Canister)

V3 Flammable Aerosol Containers

Nonflammable Gas G3 Compressed Gas Nonflammable Gas Cylinder

Flammable Liquid F1-F4 Flammable Flammable Liquid

Flammable Solid F8 Flammable Flammable Solid

Spontaneously Combustible R1 Reactive Spontaneously Combustible

Dangerous When Wet R2 Reactive Dangerous When Wet, No Water Sprinklers

Oxidizer D1 Oxidizer None Required

Organic Peroxide P1 Peroxide Organic None Required

Poison T2 Poison None Required

Harmful Keep Away From Food T4 Low Hazard Away From Food

Infectious Substance K1 Poison Biomedical

Radioactive I A1 Radioactive Security

Radioactive II A1 Radioactive Security

Radioactive III A1 Radioactive Security

Corrosive C1, C2, C4, C5 (Acid)*

Corrosive Acid

Corrosive B1, B2, B3 (Alkali)

Corrosive Alkali

Class 9 V1 Low Hazard None Required

Magnetized Material M1 General Purpose None Required

* If it is not known whether a corrosive is an acid or an alkali, look on the SDS or contact the HMIRS for a technical determination.

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Method 3: Determining Compatibility Using OSHA Precautionary Labels

1. If an SDS is not immediately available, look on the HM container for a GHS precautionary label. Precautionary labels start with signal words followed by specific handling precautions. The three signal words used are Danger, Warning, and Caution.

Figure 2-2 Example Precautionary Label

2. If a precautionary label is present, use Table 2-3 below to obtain a Suggested Temporary HCC. Match the label with the “Signal Word” and “Statement of Hazard” in the first two columns of the table. The statement of hazard won’t always be exact. Choose the one that best describes the hazard.

3. Once you have the Suggested Temporary HCC from column 3, go back to Table 2-1 and follow Steps 2 through 7 under Method 1 to determine compatibility.

Table 2-3. Precautionary Labels

Signal Word Examples of Statements of Hazard

Suggested Temporary HCC

Recommended Primary Storage Area

Recommended Secondary Storage Area

DANGER! MAY BE FATAL IF

SWALLOWED

T2 Poison None Required

WARNING! HARMFUL IF

SWALLOWED

T3 Poison None Required

WARNING! HARMFUL IF

SWALLOWED

T4 Low Hazard* Away From Food

DANGER! MAY BE FATAL IF

ABSORBED THROUGH

SKIN

T2 Poison None Required

WARNING! HARMFUL IF ABSORBED

THROUGH SKIN

T6 Low Hazard* None Required

DANGER! CAUSES (SEVERE)**

BURNS

C1, C2, C4, C5 Corrosive Acid

DANGER! CAUSES (SEVERE)**

BURNS

B1, B2 Corrosive Alkali

DANGER! EXTREMELY

FLAMMABLE

F1 Flammable Flammable Liquid

WARNING! FLAMMABLE F2, F3, F4 Flammable Flammable Liquid

WARNING! FLAMMABLE F8 Flammable Flammable Solid

CAUTION! COMBUSTIBLE V4 Flammable None Required

WARNING! Contents under pressure. Do not puncture or incinerate. Do not store at temperatures above 120 degrees F.

Keep out of reach of children.

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Signal Word Examples of Statements of Hazard

Suggested Temporary HCC

Recommended Primary Storage Area

Recommended Secondary Storage Area

DANGER! EXTREMELY

FLAMMABLE, CATCHES

FIRE IF EXPOSED TO AIR

R1 Reactive Spontaneously Combustible

DANGER! STRONG OXIDIZER,

CONTACT WITH OTHER

MATERIALS MAY

CAUSE FIRE

D1 Oxidizer None Required

DANGER! MAY BE FATAL IF

INHALED

T1 Poison None Required

WARNING! HARMFUL IF INHALED T2 Poison None Required

WARNING! MAY CAUSE ALLERGIC

RESPIRATORY

REACTION

T6 Low Hazard* None Required

CAUTION! (VAPOR GAS)**

REDUCES OXYGEN

AVAILABLE FOR

BREATHING

T6 Low Hazard* None Required

WARNING! CAUSES EYE

IRRITATION

T6, C3, B3 Low Hazard* None Required

WARNING! CAUSES IRRITATION T6, C3, B3 Low Hazard* None Required

WARNING! MAY CAUSE ALLERGIC

SKIN REACTION

T6, T5, C3, B3 Low Hazard* None Required

Please note that “None Required” means no additional storage requirements.

* Material bearing precautionary label text will not be assigned a Low Hazard (General Purpose) location without notification and approval by the ES.

** Enter proper term as appropriate.

Maintaining and Extending Shelf Life EC’s and end users of hazardous materials may continue to use a product beyond its prescribed shelf life if it has been properly stored and determined to still be usable for its intended purpose; and where the use of the extended shelf life product does not affect the use or void the warranties for any equipment on which it may be used.

Selecting HM Storage Units (including compressed gases)

Storage Cabinets

Storage cabinets are intended for use at or near the immediate work area. They should be National Fire Protection Association (NFPA) approved and should contain only small quantities of HM that are used in the facility on a daily basis. Cabinets should not be “stuffed” with HM such that they become a tinderbox should a fire break out.

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Use the cabinets for their intended purpose. For instance, do not store non-flammables, such as oil, in a Flammables cabinet. Only store flammables (those with a flashpoint <200°F) should be stored in a Flammable cabinet. Keep cabinets clean and orderly, and maintain all structural integrity and hardware, including doors, hinges, and shelves. Do not remove the door or ventilation bungs, penetrate the wall, modify ventilation, or otherwise modify the cabinet.

Keep cabinet doors closed. To set up a cabinet, complete the following steps:

1. Select a location for the cabinet:

• Locate the cabinet indoors in a well-ventilated area near where the HM will be used, or outdoors under cover.

• Maintain easy access to the cabinet; do not block doors or place “stuff” on the cabinet.

• Do not place the cabinet near doors, break rooms, bathrooms, offices, or other occupied non-shop areas.

• Do not place the cabinet near floor drains, drainage channels, or areas with high foot or vehicle traffic.

2. Mark and label the cabinet. Coordinate with the ES or Safety Specialist to ensure that the locker is appropriately labeled. Do not place unauthorized signs, labels, stickers, or markings on the locker.

3. Ensure that an appropriately rated fire extinguisher and spill response equipment are located nearby.

NOTE: To make it easier to track HM usage, conduct inventories, and ensure that HM is stored in its proper location, consider assigning a four-character identifier to the cabinet and mark it on the front, top, right corner (See Figure 2-4). This identifier will consist of one of the three abbreviations used to differentiate cabinet contents and a two-digit sequential number (e.g., FC 01). The abbreviations are: FC – Flammable Cabinet, CC – Corrosive Cabinet, OC – Oxidizer Cabinet.

Figure 2-3 Flammable Storage Cabinet

FC-01

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Storage Rooms and Buildings

Storage rooms and hazmat buildings are intended for storage of backup supplies of HM not kept in storage cabinets and large containers of HM (>1 gallon). Locate storage rooms and hazmat building in close proximity of the work area. Keep them clean and orderly, and maintain all structural integrity and hardware including doors, hinges, and shelves. Do not remove doors, penetrate walls, modify ventilation, or otherwise modify the room or building, if it has already been approved. To set up a storage room or building, complete the following steps:

1. Have the ES or Safety Specialist approve the location chosen.

2. Provide primary and secondary containment as required by 40 CFR Part 264.175(b)(3). Secondary containment should be 10 percent of the total volume of all containers, or the volume of the largest container, whichever is greater.

NOTE: For storage rooms, the floor space itself usually provides enough secondary containment.

However, ensure that the spill cannot escape the room. For example, equip each door with a sealed threshold, or store HM in pans or tubs on the shelf, making sure the HM is compatible with the container.

3. Ensure that appropriately rated fire extinguisher/extinguisher system and spill response equipment are located nearby.

4. Mark and label the storage area. Coordinate with the ES or Safety Specialist to ensure that the storage area is appropriately labeled. Do not place unauthorized signs, labels, stickers, or markings on the storage area.

NOTE: To make it easier to track HM usage, conduct inventories, and to ensure HM is stored in its proper location, consider assigning a four-character identifier to the storage area and mark it on each storage area door (See Figure 2-5).

This identifier will consist of one of the two abbreviations used to differentiate contents and a two-digit sequential number (SB 01, SB 02 etc.). The abbreviations are: SB – Storage Building, SR – Storage Room

Figure 2-4 Storeage Building

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Storage Racks

To set up a storage rack, complete the following steps:

1. Have the ES or Safety Specialist approve the location chosen.

2. Provide primary and secondary containment. Secondary containment must be 10 percent of the total volume of containers, or the volume of the largest container, whichever is greater. If stored outside, provide enough secondary containment to contain a spill from the largest single container, plus an additional 10 percent. For instance, if the largest container is 55 gallons, provide 55 gallons of secondary containment plus 10%, or 5.5 gallons (for a total of

60.5 gallons). Place drip pans under dispensing faucets or valves.

3. Ensure that an appropriately rated fire extinguisher and spill response equipment are located nearby.

4. Mark and label the storage rack. Coordinate with the ES or Safety Specialist to ensure that the storage area is appropriately labeled. Do not place unauthorized signs, labels, stickers, or markings on the storage rack.

Figure 2-5 Storage Rack

Storage for Compressed Gases

When storing compressed gases, excluding fire extinguishers and aerosol cans, additional guidelines must be followed. A compressed gas is a gas that is packaged under charged pressure. Because compressed gases are under pressure, handle such gases with extreme care, particularly the flammable and explosive gases.

CAUTION DO NOT use cylinders as rollers or supports, or for any other unintended purpose.

DO NOT accept, issue, or use a cylinder unless the contents are identified.

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The ES or Safety Specialist is responsible for designing and approving compressed gas storage areas. The guidelines listed below will help you maintain those areas properly to protect human health and the environment.

• Ensure that only non-combustible or limited-combustible materials are used for shelves, racks, and floors.

• Ensure that the area is well-ventilated (complete change of air at least six times each hour).

• Separate storage facilities from other buildings by at least 50 feet.

• Store gases that support combustion in different sheds separated by 50 feet.

• Keep dry vegetation and combustible materials at least 15 feet away from storage areas.

• Keep cylinders out of the sun and off the ground (earth).

• Protect storage areas from vehicular traffic.

• Lock storage areas to prevent unauthorized entry.

• Post NO SMOKING signs.

• Do not allow open flames within 50 feet.

• Place hazard identification signs such as FLAMMABLE at all entrances.

• Ensure that all cylinders are properly labeled (do not alter or remove the manufacturer’s label from cylinders).

• Store cylinders with the valve protection cap secured.

• Secure cylinders you are using or storing so they do not fall over.

• Store liquefied flammable gas cylinders upright or so the pressure-relief valve directly communicates with the vapor space of the cylinder.

• Ensure that cylinders are not located where they could become part of an electrical circuit.

• Segregate incompatible or combustible materials by at least 20 feet (see

Determining Hazardous Material Compatibility in Chapter 2 for more information).

• Isolate incompatible or combustible materials with a barrier of non-combustible material at least five feet high and with a minimum fire resistance rating of 30 minutes.

Moving Cylinders

If you must move cylinders, note the following precautions:

• Only handle, ship, or store cylinders if they have valve protection caps.

• Close cylinder valves before moving cylinders.

• Do not lift cylinders by the valve protection cap.

• Do not lift cylinders by cranes or mechanical lifts unless fastened in proper containers, racks, and cradles.

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• Do not use rope and chain slings or electromagnets to lift cylinders.

• The following items do not require valve protection caps:

• Small cylinders with a capacity of less than 40 pounds

• “Ram-bottom” type cylinders

• Cylinders with less than 625 cubic inches of volumetric capacity, such as medical gases

Stocking HM Storage Locations

1. Check the compatibility of HM items before placing them in the storage cabinet.

2. Determine the amount of required shelf space needed for the storage of HM.

3. Ensure that all HM containers have labels and place them in the storage unit in an orderly fashion (see Figure 2-7). Rotate the containers so that items that expire first are in the front. Remember: FIRST in, FIRST out.

Figure 2-6 Cabinet Set

Conducting a HM Inventories All activities must conduct and maintain an inventory of all HM for each of their approved storage locations, and perform quarterly inventories thereafter based on the calendar year. It is also mandatory to update inventory whenever new HMs are obtained or old supplies are depleted. This section explains how to conduct the HM inventory.

An example Hazardous Materials Storage Inventory Form is provided at the end of this chapter. Use of this form is required so that the information captured in the inventory is consistent across the facility, and to ensure it contains the information necessary to meet regulatory reporting requirements.

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To conduct an inventory, complete the following steps:

1. Check that every container, bottle, can, box, etc., is labeled as required in the “Manufacturer and Workplace Container Labeling” guidance document provided in Appendix

2. Check the expiration, inspection, or testing dates on all HM and manage/maintain shelf-life as required in Chapter 2 of this procedure.

3. Complete Initial and Quarterly Hazardous Materials Storage Inventory Form for each HM location. An example of this form is provided at the end of this section. To obtain a computer fillable form, call the ES.

4. Submit copies of completed Initial and Quarterly Hazardous Material Storage Inventory forms to the ES for review and approval. ES approved hazardous material inventories shall become the agencies/organizations Authorized Use List for each specific process or facility and shall be included into the Facility-wide AUL for emergency response and regulatory reporting requirements. Maintain a copy of the Hazardous Materials Storage Inventory.

Finally it is also mandatory to update inventories whenever new supplies are obtained or old supplies are depleted. These inventory changes should be reflected in the annual and quarterly reports.

Creating Authorized Use Lists (AUL) An AUL is used to control acquisition, identify types of HM usage, estimate HW generation, and to support environmental reporting as prescribed by government agencies, and as a pollution prevention tool. The Facility goal is to validate automatically each HM transaction against established authorizations prior to procurement and receipt. Un- authorized requests will result in a review and decision process before acquisition. Organizations and activities should ensure that HM identified by technical manuals, equipment documentation and required for routine maintenance are included in their AULs. Each distinct operation, such as painting, using a solvent parts washer, or conducting training, constitutes a HMMP process. Processes may be activity specific but are generally not location specific. The use of the AUL facilitates:

1. Visibility of specific chemicals on the Facility.

2. Ability to restrict use of specified chemicals.

3. Facility pollution prevention opportunity assessments.

4. Identification of HM used to support specific processes.

5. Identification of waste streams generated by specific processes.

6. Identification of training requirements.

7. Identification of potential exposure information.

8. Possible HM substitution.

The ES with the Facility Safety Specialist are responsible for reviewing and approving processes and their required HMs. Key sources of information used during a processes review include equipment

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May 2015 24 technical and operating manuals, lubrication orders and standard operating procedures (SOP), as well as the SDS for each HM required for the process.

More specifically a HM is authorized, approved and tracked at the chemical constituent level, as provided by the manufacturer’s safety data sheet and other supplementary sources, and is linked to the process authorized to use the material.

The ES tracks HMs containing chemicals listed by the U.S. Environmental Protection Agency (EPA) list of lists, 29 CFR 1910.

When reviewing HM for approval, the ES concentrates on quantity, toxicity, and exposure potential of the materials. HMs are also approved, ordered, issued, and tracked by unit of use. Inventory requisitioning objectives and re-order points are established and tracked, using the AUL and establish reorder timelines that supports material substitution, regulatory reporting, process reviews, HMMP metric reporting, pollution prevention opportunity assessments, and reduces risks to personnel.

The individual activity/organization AUL will normally be created from the HM inventories they submit for approval. The ES reviews the submitted HM inventories HM and compares them to the chemical lists and manufacturers’ safety data sheets (SDSs) to determine which should be approved.

Technical manuals and processes also are also considered for HM approval and ultimate AUL development.

Processes identify what and how a material is used, potential exposure risks, and what waste streams to expect. Characterizing, or describing, processes that use HM or generate HW is a key element of a strong pollution prevention program, supports compliance reporting, and forms the basis for process improvement.

The ES and Safety Specialist will work jointly to assess local processes which can be either be detailed or generic. Detailed processes facilitate more accurate emission estimation and reporting requirements. Less detailed processes are easier to track but provide less information for compliance reporting and pollution prevention opportunity assessments. An example of a very detailed process is spray painting in a specific booth using a specific type of air filtration system and a specific spray gun. Examples of more manageable detailed processes are high-volume, low-pressure spray painting, spray painting, or roller and/or brush painting. An example of a generic process is “painting.”

As a minimum, processes will be defined by the using shops with HM linked to that shop, for example, the Operations and Maintenance (O&M) Paint Shop. This general process includes the various methods of painting (spray, brush, roller, and aerosol). All paints and materials used by the O&M Paint Shop, regardless of application method or amounts of releases, are linked to the single process of Paint Shop. This method is easy to use but significantly limits use of HMMP data for environmental reporting (toxic release inventory and air emission) and pollution prevention opportunity assessments.

AUL Change Procedures.

Request for changes to an organization/activity AUL must be coordinated with the facility ES who will verify that material and/or process is not already recorded in the Facility HM database under a different name or stock number.

If a HM is not found in the Facility HM database and it is still required the requesting organization/activity must prepare a request for authorization to use it making every effort to

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May 2015 25 describe fully the process the HM will be used in, the HM product desired, and resulting waste streams.

The Facility ES and Safety Specialist will either approve or disapprove the request based on mission, cost, supply availability, and environmental and safety considerations; or possibly identify acceptable substitutes (requests will be completed within 24 hours). More specifically the Environmental Office will with the Safety Specialist:

1. Review the HM for known restraints and/or constraints that would preclude it, or a process in which it is being used, on the Facility.

2. Identify new training, personal protection, or facility enhancements required to use new HM or process. Review is completed within 1 workday. Inform submitters of known substitutes that will reduce toxic emissions or risk to Facility personnel and environment.

3. Assist in developing waste stream information.

4. Maintain a log of all AUL requests. The log will serialize requests and track requested processes and items; and identify the requestor, date of request, date received, approval results and date the requestor was notified of approval results.

5. Return approved requests to the requesting organization/activity point of contact within 48 hours of approval.

6. Return disapproved requests to the requestor within 48 hours of action, with explanations for disapproval and recommended actions.

Supervisors, managers, section chiefs, and/or team leaders might identify a need for a material not currently approved for a process.