Step 1: Communicating hazardsOSHA requires employers to communicate workplace hazards to employees (29 CFR 1910.1200). Proper training helps everyone share the safety load and is the primary way to ensure that all employees know the designated procedures for properly handing materials safely from the time they arrive on the dock until the last drop has been properly recycled or disposed. Material safety data sheets (MSDS), package labels, chemical resistance guides, and other documents from suppliers can be a great aid in this training.
Step 2: ReceivingAlthough receiving crews do not typically have to handle open containers of hazardous materials, they still need to know what types of hazardous materials are being received, and how to handle them safely.
Receiving crews can be the first line of defense in material handling safety. Allowing them the time to check packages and containers before transporting them to storage areas can help prevent damaged containers from creating leaks and spills. Train them to handle incidental spills.
These employees can also be a good resource for providing the safety department with updated MSDS, which often accompany shipments, and can also alert others to any changes that are noted on product packaging or literature.
Step 3: StorageSafe storage of hazardous materials is another area where the MSDS for products come in handy. It will list safe storage conditions as well as conditions that should be avoided. Sometimes, proper storage means that materials need to be segregated and that additional storage space needs to be allocated; but the time, energy and money spent will be well rewarded in a system that ensures employee health and safety.
Consider installing containment berms in storage areas, or storing drums on pallets with integral sumps capable of containing the entire contents of a container.
Step 4: Products in useA complete hazard communication program will address the engineering controls that are in place, as well as the correct personal protective equipment (PPE) that needs to be worn to keep employees safe while various chemicals are in use.
Because each hazardous material could have different properties, it may be necessary to have several different procedures in place for dispensing and using each material. One set of controls or one type of PPE may not be suitable for all materials in a facility. Knowing the properties of each material helps ensure that proper procedures are in place for everything onsite.
Workstations should also be designed and equipped to handle the hazardous materials used in that area. Fume hoods, waste collection containers with easy-to-close lids and other items help keep employees safe and work areas tidy. Satellite accumulation areas can help prevent long trips to centralized waste collection areas.
Step 5: DisposalPrior to wastes leaving the shipping dock for recycling or disposal, spent materials can still pose environmental and safety problems if they are mishandled or improperly stored. Establish designated areas for waste storage that are away from the most commonly used corridors or docks. Incompatible materials still need to be segregated, and leaks from containers can still occur.
Storing containers on pallets with integral sumps or in containment areas can help avoid reactions or large messes. Placing spill response kits in waste collection areas is another way to help quickly mitigate any spills that might occur.
Step 6: RecordkeepingProperly stored or filed documents can provide safety information quickly and efficiently. In addition to storing MSDS, keep a record of all safety trainings attended by each employee. Training records are something that an inspector can ask for to determine whether or not sufficient effort has been taken to protect employees and prevent accidents.
Shipping manifests are another record that provides documentation that any hazardous wastes shipped off site for recycling or disposal made it to their intended destination, and were not illegally dumped or otherwise mishandled.
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