Industry Emergency Management
Safety
Our ExPERTS are on hand to answer your questions about safety issues related to any of the categories below.
Environmental Safety
- How do I determine what waste generated by my facility is considered hazardous?
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If by-products produced by your operation are corrosive, highly flammable, chemically reactive, or poisonous, you may be subject to RCRA regulations. Solid waste ignitable by friction, certain liquids with a flashpoint below 60 degrees Celsius, or materials that react violently with water or heat may be considered hazardous. Materials that contain small concentrations of lead, silver, or mercury fall into this category as well. The EPA offers guidance on RCRA regulations and classifying materials as hazardous in their publication
Managing Your Hazardous Waste: A Guide for Small Businesses
Link.
- Do I need an Environmental Protection Agency ID number? How do I apply for one?
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Businesses that generate hazardous waste above a certain volume are typically required to have an EPA ID number. Hazardous means that the waste generated is explosive, chemically reactive, flammable, poisonous, or corrosive. In order to report any hazardous waste activity (creation, transportation, disposal, etc.) you'll need an EPA identification number.
- During filling of an underground diesel tank, a small amount of product spilled onto the ground. Who do I need to report this to, and how long do I have to clean up and remove the contaminated dirt?
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Accidental contamination can occur when filling underground storage tanks if proper overfill measures aren't in place. Your overfill prevention setup should include audible alarms to alert the operator when the tank is close to being full to prevent overfill accidents. But, if you operate a small underground storage tank (UST) and transfer less than 25 gallons of product at a time, you may not have or be required to have these protections. Link
- Used oil from an above-ground storage tank leaked onto the containment pad below. Does this qualify as a release into the environment that requires reporting to the EPA?
- No. Even though the oil leaked out of its tank, it wouldn't be considered a "release into the environment." As long as the used oil spilled onto a containment pad or other impervious surface, you are not required to report it under 40 CFR 279.22 (d). So long as none of the oil traveled beyond the containment area, you are only required to clean up what spilled and repair or replace the above-ground tank that developed the leak. Link
Regulation
- I own a small automotive paint shop with only five employees. Am I required to have a written respiratory program?
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If your employees are required to wear respirators, you will need a written plan for their use. [29 CFR 1910.134 (c)] makes no exception for size of business, stating that any workplace where respirators are necessary shall establish and implement a written respiratory protection program with worksite-specific procedures. This may include details like emergency procedures, fit testing, medical evaluations, and training, depending on the specifics of the workplace. In addition, you will need a program administrator with adequate training or experience to oversee the respiratory program and ensure its effectiveness.
- My business just added a 30'x60' warehouse to our operation. How many fire extinguishers am I required to have on the site, and where?
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It depends on the kind of fire that could reasonably be anticipated. If you do not have a sprinkler system that covers the entire area to be protected, you will need enough extinguishers to ensure that no employee is more than 75 feet away from one at any time. If there is concern about class B fires (flammable liquids,NOW()), the furthest acceptable distance from an employee to any extinguisher is reduced to 50 feet. [29 CFR 1910.157 (d)]
- Who do I contact to perform a comprehensive asbestos survey? Is it something I can do myself?
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If your property requires a comprehensive survey for asbestos containing material (ACM,NOW()), you'll need to contact a professional who has been trained to identify and remove asbestos. Your inspector will be looking for friable and non-friable ACM, sending in samples of materials to confirm they contain asbestos, and then help you develop a plan for removal or management of these materials. The ExPERT program at ISU is one provider of these services. A list of currently licensed professionals in Iowa can be found here
- I own a small business; do I need to install fire alarms separate from the detectors?
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Most likely you do not. If ten or fewer employees occupy a given workspace, direct voice communication can serve as a warning to other employees in case of a fire as long as all employees can hear it. An appropriate number of fire detection units for the space are still required as determined by manufacturer recommendation or engineering surveys. Consult [29 CFR 1910.164] for more information.
- Is my business subject to Tier II chemical reporting?
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In general, companies that store or produce chemicals over a certain threshold, which require the maintenance of Material Safety Data Sheets, are required to report the average amount (in pounds) that was present on their property per day, as well as where it was stored. Specific guidelines for reporting in each state can be found here
- I have anhydrous ammonia at my facility, am I required to store it in a container tested by a nationally recognized laboratory?
- Maybe not. Sometimes it is necessary to store ammonia in custom-built containers that have not been certified by any national lab. To maintain OSHA compliance, however, they do need to be tested by an engineer or other expert to attest to their safety, with certification from state agencies as well. [29 CFR 1910.111 (b)]
Security
- What kind of security am I required to have around my ramset gun when not in use?
- Powder-actuated tools can pose a serious threat to workplace safety if not properly stored after use. Even in the hands of an experienced user there is the risk of malfunction, and having little to no training multiplies this. OSHA regulations forbid these tools to be "left unattended in a place where it would be available to unauthorized persons." On most work sites this means storing all powder driven tools in an area or receptacle secured with a strong lock. [29 CFR 1910.243(d)(4)(vi)]
Workplace Safety
- Why am I required to conduct lead air testing when I'm using lead-free paint?
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Paints that contained highly toxic levels of lead were banned after 1978, but even today's "lead-free" paint isn't always completely devoid of it. It only means that the paint contains less than .06% lead. If the paint is being applied in such a way that generate(s) airborne levels to which employees may be exposed, it is the employer's duty to conduct exposure monitoring.Link
- What specifics do I need to include when coming up with a comprehensive Operations & Maintenance Plan for asbestos containing material?
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If asbestos is found in your building, your Operations and Maintenance Program will include details about what staff should be trained in its handling and how they will be trained. It will also cover how often you notify others that occupy the space but may not necessarily handle ACM. Your program will establish safe work practices to minimize the release of contaminated material to the work environment, as well as recordkeeping and worker protection guidelines.
- Do I need an independent verification system in addition to lock-out/tag-out procedures?
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Depending on the circumstances and what kind of equipment is being removed or serviced, you may want to establish independent verification at your workplace. Whenever work is being performed on fire suppression systems, continuous emission monitors, or toxic gas monitoring equipment, having a second employee verify the work was completed correctly can avoid dangerous mistakes. If a piece of equipment is critical to preventing the release of hazardous materials, inspections and repairs should always be double-checked by another employee with as little interaction between the two as possible to maintain independence. DOE-STD-1036-93 pp 13-16
- Do I need a fire watch for my welding area?
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Fire watchers are responsible for monitoring a welding area for fires and are trained in the use of suppression equipment if one should occur. Working in areas where appreciable combustible materials are closer than 35 feet or easily ignited by sparks, or any other conditions where an accident could result in something larger than a "minor fire" requires a watcher. They should monitor the area while the work is being performed, and continue to do so until 30 minutes after welding stops. [29 CFR 1910.252 (a)]
- What requirements are there for re-circulating exhaust air from a dip tank operation back into the workplace?
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Dip tank facilities often use chemicals that are hazardous to breathe. Stripping agents can produce flammable vapor, and other products can release solid material into the air. If your facility recirculates exhaust air from a dip tank, there are regulations to ensure employee safety. Re-circulated air must not contain any solid particulate that creates a health or safety hazard. Its composition must remain below 25 percent of the its lowest flammable limit, with both of these factors being measured by appropriate equipment with an audible alarm. [29 CFR 1910.124]
- My company recently replaced all of our incandescent bulbs with fluorescent. What do I need to know if one breaks or needs replaced?
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Fluorescent bulbs contain a small amount of mercury, and therefore may be considered hazardous or universal waste. You can find resources here to determine whether or not your state classifies them as such. You may be required by law to find an appropriate recycling plant to send them to. Even if your state doesn't regulate how you dispose of them, recycling prevents mercury from being released into landfills and water. If a bulb breaks, don't clean it up right away. Leave the room and wait about 30 minutes for it to air out. You can put the broken glass in an airtight container to be recycled later.
Link
- Is PPE required if I am at my desk located on the testing floor?
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A company must provide employees adequate personal protective equipment where necessary in the performance of their duties. They must determine and document what constitutes adequate personal protective equipment (PPE) through completion of a job hazard assessment or development of a standard operating procedure (SOP). Adequate PPE must be provided to employees at no cost, including replacement resulting from regular use. Companies must insure that employees are adequately trained and that assigned PPE is worn when hazards are present.
Employees are expected to use assigned PPE when called for by the hazard assessment, standard operating procedure, container label or material safety data sheet. PPE shall be maintained by the employee in a clean, sanitary and usable condition.
Also, visitors must be provided appropriate PPE when visiting a hazardous area.
- What is Job Safety analysis?
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Job Safety Analysis (JSA) is a methodology that systematically analyzes the relationship between the worker, the task, the tools, and the work environment. The analysis identifies the potential impact of task related hazards on:
• the safety and health of the employees engaged in the task
• the safety and health of other employees in the workplace
• the effect of the hazard on the workplace environment
• If conducted appropriately, JSA will frequently lead to improvement in the flow
of work and serve as safe standard operating procedures for workplace tasks.
- Why Job Safety Analysis?
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Injuries, illnesses, and loss of employees have a tremendous effect on the workplace morale, the life of the employees and their families. Additionally, these losses have a very high economic impact. The National Council on Compensation, Inc. (NCCI) collected and analyzed data on workplace injuries and other national and state factors impacting workers compensation, from more than 900 insurance companies from 40 state governments. The following table was established based on the NCCI data. The table provides estimates for costs and additional sales required to cover losses due to injuries based on three profit margins (based on data from 2004). The table demonstrates the enormity of the financial impact of an injury.
(Source: http://www.osha.gov/dcsp/smallbusiness/safetypays/estimator.html?) Conducting JSAs will help in prevention of injuries and illnesses, establishing proper job procedures, and ensure that employees are trained appropriately.Type of
injuryCost
(Direct+Indirect)Additional sales
to cover costs10% Profit
Margin5% Profit
Margin3% Profit
MarginHearing loss $27,604 $276,040 $552,080 $920,133 Contusion $26,122 $498,700 $997,400 $1,662,333 Electric
shock$181,540 $1,815,400 $3,630,800 $6,051,333
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Last updated: 03/27/2012