PCBs

Polychlorinated Biphenyls (PCB's) were introduced in the 1930's and were seen as widespread use. But in the 1970's, they were banned after finding that they are toxic and posed a risk for the environment. This information was obtained by Andrew Havics', "Polychlorinated Biphenyls (PCBs)".

(https://people.uwec.edu/piercech/PCBs/)

Contamination of the Fox River from PCBs illustration.

Disposal Requirements:

The disposal requirements of PCB waste steams must be managed according to the original source of the concentration, including those of older spills. However, the redefining of PCB remediation waste most permits these wastes to be managed according to the concentration of the current medium and not from the actual source. In the winter of year 2000, the Environmental Protection Agency issues a temporary deferral of the Land Disposal Restrictions (LDR) to direct the attention of contaminated soil that exhibit toxicity levels of wastes. This deferral does not apply where the total halogens exceed 1,000 ppm in the soil. This rule was instituted to reverse the previous regulations that resulted in discouraging generators from cleaning up contaminated soils.

PCB Remediation Waste:

The Mega Rule implemented three disposal options for PCB waste: self-implementing, performance-based, and risk-based. Self-implementing waste disposal is permitted for bulk PCB remediation waste, non-porus surfaces, porous surfaces (this includes concrete), liquids, and clean-up wastes. The calculation of PCB concentrations in any new clean-up should be based on the concentration at which the PCBs are found rather than on the original source concentration. One significant aspect of this is that any soil containing <50 ppm PCB's can be placed in a municipal or more industrial, non-hazardous landfill is permitted to accept low-level PCB wastes. The performance-based disposal options are for liquids, incineration or decontamination, for solids (TSCA incineration, TSCA landfill, or decontamination), and for dredged material containing <50 ppm PCBs (management per the Clean Water Act and US Army Corps of Engineers permitting). The EPA permits petitioning of the Administrator for alternative risk-based disposal options, other those that are already discussed, as long as the proposed storage or disposal method does not pose an unreasonable risk to human health or the environment. 

Site Cleanup:

EPA's rules allow self-implementing remediation, except in "sensitive locations". These aspects include site characterization (including sampling), a 30 day notification to EPA, specified cleanup levels, site clean up protocols, clean-up verification, capping, and deed restriction. Site cleanup regulations permit on-site use of soil washing and solvent extraction systems or decontamination as well as off-site disposal. Deed restrictions may be required depending on the occupancy standard. 

Decontamination:

The rule permits decontamination of a broad array of items including building components, equipment, water, organic liquids, non-porous surfaces, concrete, and coated porous surfaces. The decontamination methods include a long list of solvents used for cleaning as well as thermal processes for metal surfaces. For any liquids, the treatment standards vary with end use. The regulations provided new standards for non-porous surfaces that are in contact with liquids containing >500 ppm PCBs. Concrete is permitted to be decontaminated within 72 hours of a spill to achieve a surface concentration of <ug/100cm^2 for reuse. Records retention of sampling and analysis data is set at a minimum three years after completion of decontamination. 

(https://www.newpig.com/caution-contains-pcbs-label/p/SGN680)

PCB caution label

Shipping 1L Tert-butyllithium

There are eight steps to conduct when shipping hazardous materials and this includes classification, naming, packaging, marking, labeling, paperwork, and placard.  Tert-butylithium is classified as an organometallic substance, a pyrophoric liquid. It can catch fire when it is exposed to air and reacts violently with water to give off flammable gases and corrosive dusts. This chemical is corrosive to the eyes (may cause blindness), skin, nose, throat, and stomach. It can catch fire when exposed to body moisture or it it is exposed to air. Inhalation of the vapors may cause dizziness, nausea, anesthesia, numbness, motor weakness in fingers and toes, in-coordination, and headaches. If it is ingestion, it may produce a lung aspiration hazard. Flying this substance is considered to be not acceptable, but for sea and road transportation, the regulations are found under 4.2 (4.3) in the Guide to Shipping Biological Materials. Under its packaging groups, this chemical compound is rated to be a group 1 or group 2 substance. This ranking means that tert-butylithium is one of the more hazardous materials. Group 3 is considered to be the least.



Naming this material is considered to be an extremely important part of shipping hazardous materials. This is also referred to the PSN and is important for shipper and receivers and also any third party involved to identify and classify exactly what material is being shipped and how extensive and important it is to put in place precautions for handling it. The proper PSN name for shipping this item would be Tertiary-butyllitium. The next step for shipping hazardous materials is the packaging aspect. This is the step that is most important for selecting the correct packaging for shipping the materials in.  For this case, shipping one liter of this material should be properly packaged in a bulk package that specifies for less than exactly 450 liters of hazardous material. One way to package this bottle would be to contain it in a glass bottle and extract the material through a syringe.

(https://www.scisale.com/SIG186198-8L.html)

Tert-butyllithium packaging

Next, marking the package is important for making clear to transporters, shippers, receivers, and third party members the classification of hazards. This step of shipping hazardous materials is recognized as markings that are the shaped hazardous signs/markings. For these markings, they must be labeled in English and attached to the top/front of the package. For shipping one liter of tert-butyllitium, the markings should state "Dangerous When Wet" and "Spontaneously Combustible". Labeling this package refers to the diamond shaped hazard sign that is most recognizable. This label should also go on the top or side of the package and near the shipping name, and if there is more than one shipping label they must be at least 6 inches apart.

Once these steps have been completed, paperwork must be completed. The paperwork must be legible and written in English. The basic description of the material must be described in order starting with the proper shipping name, hazard class, UN number, and then the packaging group. For shipping 1 liter of tert-butyllithium, the proper format would be: T - BUTYLLITHIUM, HYDROCARBON SOLUTION, 4.2 (4.3), UN 3394, PG 1/2. Finally ones this has been addressed, the last step is the placard. This is considered to be information the shipper must supply the carrier with for the hazardous material. For the shipment of one liter of tert-butyllithium, the placard would be 172.548.

(https://en.wikipedia.org/wiki/Hazardous_Materials_Transportation_Act)

Example of a shipping paper

ISO 14001, 9001, & 18001

ISO 14001:

The ISO 14001, according to Certification Europe,  is a newly revised standard that is internationally recognized environmental management standard that was originally published in 1996. It is considered a systematic framework that manages the intermediate and long term environmental impacts of an organization's products, services, and processes. The ISO 14001 is apart of the ISO 1400 standards that helps minimize the environmental footprint, diminish the risk of pollution incidents, provides operational improvements, ensure compliance with relevant environmental legislation, and develop their business in a sustainable manner. The key benefits of the ISO 14001 Standard include: identifying cost savings with greater emphasis on resource, waste, and energy management, developing the corporate image and credibility, quantify, monitor, and control the impact of operations on the environment now and in the future, ensure legislative awareness and compliance, improve environmental performance of supply chain, protect the company, assets, shareholders, and directors, potentially decrease public liability insurance costs for your organization, and growing access to business partners and potential customers.

(http://www.sustainablecitiescollective.com/david-thorpe/286801/iso-14001-revision-reaches-milestone-updating-standard-environmental-management)

ISO 14001 Process Cycle

ISO 9001:

The ISO 9001, according to the International Standard Organization, specifies requirements for a quality management system when an organization needs to demonstrate its ability to consistently provide products and services that meet customer and applicable statutory and regulatory requirements and aims to enhance customer satisfaction through the effective application of the system, including processes for improvement of the system and the assurance of conformity to customer and applicable statutory and regulatory requirements. All the requirements of the ISO 9001 are intended to be applicable to any organization, regardless of the type or size, or the products and services it provides. ACS Registrars states that the ISO 9001 ensures that the Quality Management Systems that are adopted work to improve the business as a whole and not just a set of procedures that employees find it hard to understand and manage. Some benefits the ISO 9001 will bring to the company include: providing senior management with an effective management process, sets out areas of responsibility across the organization, communicates a positive message to staff and customers, identifies and encourages more efficient and time saving processes, highlights deficiencies, reduces cost, provides continuous assessment and improvement, and marketing responsibilities. Benefits to customers include: improved quality and service, on time delivery, right time first attitude, fewer returned products and complaints, and independent audits demonstrate commitment to quality. 

(http://www.iso.org/iso/news.htm?refid=Ref1665)

ISO 9001 Benefits Flow Chart

ISO 18001:

Also referred to as OHSAS 18001,  ACS Registrars also states that it is internationally accepted as a method of assessing and auditing occupational health and safety management systems. Developed by leading trade and international standard bodies, it provides a framework for organizations to instigate proper and effective management of health and safety in the workplace. By implementing the OHSAS 18001, organizations are able to minimize risks to their workforce and visitors or external contractors on their premises. Key areas that are assessed in the OHSAS 18001 certification include: management systems, planning and risk assessment, staff training and awareness, communication of safety management systems, response to emergency situations, and monitoring and continual improvement. This is suitable for all types of organizations that want to become more efficient in managing and reducing accidents in the workplace. 

(http://www.iso.org/iso/news.htm?refid=Ref1665)

ISO 18001 (OHSAS 18001) Steps

Implementation of Chemical Facility Anti-Terrorism Standards (CFATS)

The Implementation of Chemical Facility Anti-Terrorism Standards (CFATS) regulates the security at high-risk facilities that possess one or more chemicals of interest. If the facility has more than the specified amount of a chemical, it must register with the Department of Homeland Security (DHS) and preform security-related activities. The DHS identifies a subset of high-risk chemical facilities from among those who register and of those high-risk chemical facilities, each must submit a security vulnerability assessment and a site security plan. This security vulnerability assessment and site security plan are used by the DHS to confirm their high-risk designation and to review and authorize. The DHS also inspects and approves high-risk facilities for their adherence to their submitted security plans and later inspects for compliance to the plans following its approval. The DHS regulates approximately 3,900 facilities under the CFATS program.

(http://www.chemicalsecurity.com/cfats/about-cfats)

CFATS Flow Chart

In 2006, Congress authorized the DHS to regulate chemical facilities for security purposes and in 2007, the DHS issued final regulations establishing the CFATS. These regulations provided a process whereby facilities would submit information and security plans to the DHS, the DHS would review and approve these plans, facilities would implement them, and the DHS would inspect their implementation. The DHS frequently faces challenges in implementing these regulations and has not met its own expected milestones. As of October 2014, the DHS has inspected and approved 1,192 site security plans, which is approximately 32% of all regulated facilities.

(http://slideplayer.com/slide/5696142/)

CFATS Regulation Overview Explanation

Facilities processing a chemical of interest with quantities exceeding the threshold screening quantity must submit a Top Screen. This Top Screen creates results that assist CFATS in determining whether a facility presents a high-level security risk. After the Top Screen is processed, the CFATS Program assigns the facility with a preliminary tier or determines if the facility does not meet the criteria for the CFATS regulation. When a facility receives a preliminary tier assignment notification, it must prepare and submit a Security Vulnerability Assessment (SVA) to The Department of Homeland Security. After the SVA is reviewed, the CFATS program is reviewed, the CFATS Program determines if a facility's final tier assignment or if the facility is not at a high risk. When the facility receives a final tier assignment, it must develop and submit a Site Security Plan (SSP) to the DHS.

The Infrastructure Security Compliance Division (ISCD) within the DHS National Protection Programs Directorate (NPPD) reviews the SSP's to preliminary determine if it satisfies the applicable risk-based performance standards. This process typically involves discussions between the ISCD staff and the facility. This often requires the facility to submit additional information to the ISCD and revise the Site Security Plan before it can complete its initial review and issue the facility a letter of authorization for said Site Security Plan.

After the authorization is issued, the ISCD conducts a comprehensive and detailed authorization inspection. The ISCD then reviews the inspection results, as well as any further revisions that the facility may make to the SSP. It then makes its final decision whether the facility's SSP satisfies the applicable risk-based performance standards. If so, the ISCD issues a letter of approval to the facility and it must implement applicable provisions of the SSP. If the facility fails to do so, the ISCD may disapprove of the SSP. After the inspection, facilities are usually granted 45 days to make necessary modifications to the SSP. The ISCP will then review and make a final determination as to whether the SSP warrants the issuance of a letter of approval.

OHSMS Components

Occupational Health and Safety Management Systems (OHSMS), according to the Chemistry & Industrial Hygiene Inc., establishes a systematic control of health and safety standards throughout the organization. This is a major component of corporate culture and promotes employee involvement at every level of operation. This provides outreach to all facilities and personnel. One objective of an organization is to advance the long-term risk management strategy. This can be achieved by implementing an OHSMS plan. This plan is also considered an effective tool to improve management control, reduce the incidence rate of injuries and illnesses,  and facilitate the implementation of corporate extensions concerning the management of workplace hazards and their associated risks.Once this plan is fully implemented, the management system should address all of an organization's unique processes and hazards as well as any future changes to those processes.

(http://www.slideshare.net/GajananPandit/iso-18001-57141203)

Diagram of how OHSMS works

According to Safetyworx, the components of an OHSMS program most likely will have all of the following: planning, implementation, measurement and evaluation, and management review and improvement. Planning initially includes setting objectives, targets, and establishing performance indicators to address the regular occurrence of hazards and developing the controls necessary to eliminate, isolate, or minimize the hazards in the facility or corporation. These procedures should be developed in such a way that they are used for continuing operations in the organization. Implementation is critical and adequate for the organization to achieve it's goals. Financial, human, and material resources are adequate in achieving success. Responsibilities must be defined and designated, withhold an effective reporting relationship between management, employees, contractors, subcontractors, and visitors. Having consultation and involvement of both management and employees will help establish common goals and facilitate the development and implementation of the organizations goals and objectives. Along with consultation, the training needs of the employees should be identified and procedures should be put in place to ensure the training is providing adequate information and is well documented. Measurement and evaluation is necessary for an OHSMS plan to make sure an organization is preforming adequately and the objectives are sought clearly. All details of the system, whether its positive or negative, must be recorded and available for all stakeholders to see. Audits must be conducted periodically and use for management review purposes whether they are internal or external. Accident investigations have the ability to examine the effectiveness of the OHSMS plan. These should be approached in such a way that the problem areas are identified as deficiencies in the system rather than apportioning blame. The management and review component of the OHSMS plan is essentially a foundation for an ongoing and effective system element that is necessary to make adjustments that will improve the effectiveness of the organization. This process can be strictly foreseen at the management level, or incorporate employee or other stakeholder representation. Some factors that are considered can include changes in legislation, different technologies, and lessons learned from OHS incidents and feedback from employees and stakeholders to name a few. 

(http://www.c-ih.com/ohs-management-systems/)

The continual improvement cycle enables risk management processes to evolve and address new and changing workplace hazards. 

Quantitative Fit Testing

According to OSHA, a "fit" test tests the seal between the respirator's facepiece and the face of whom is wearing it. This test takes about fifteen minutes to complete and is performed at least annually. This type of test should not be mistaken for a user seal check. A user seal check is a quick check that is preformed by the wearer each time the respirator is put on. This test assures that the respirator is properly sealed to the face or needs to be readjusted. The two types of  respirator fit testing consists of qualitative and quantitative.

Quantitative fit testing is normally used for half-face respirators.These type of respirators only cover the mouth and nose. These are often filtering facepiece respirators that are called "N95s" and elastomertic respirators. This type of testing uses a machine to measure the actual amount of leakage into the facepiece and is not reliant on taste, smell, or irritation in order to detect leakage. The respirators in this testing will have a probe attached that will connect to a machine by a hose. There are three different type of quantitative fit testing methods that are accepted by OSHA: generated aerosol, ambient aerosol, and controlled negative pressure. These types of testing can be used for any type fitting respirator. Workers must wear personal protective equipment such as safety glasses and or earmuffs while preforming their job and if so, these workers must wear the same personal protective equipment (specific make, model, style, and size of the respirator) for completing the fit testing.

(http://www.hasc.com/site/Fit_Test.htm)

Quantitative Fit Testing Example

You must be fit tested before you use a respirator in the workplace and you must be retested every 12 months to see if the respirator you use still fits you. Not every respirator passes the fit test. If it fails, another make, model, and size must be tested in order to ensure that the respirator has a perfect seal. Employers must provide a reasonable variety of different respirators in order to ensure that the respirators of their workers are fitting properly. Knowing the make, model, and size as well as when and where you need to wear the respirators is important to ensure protection. The fit of the respirator must be retested whenever there is a change in physical conditions that could affect the way the respirators fit. These physical conditions include: large weight gain or loss, major dental work (such as new dentures), facial surgery that may have changed the shape of your face, and significant scarring in the area of the seal. These physical conditions can affect the way the respirator's ability of sealing the face properly. Any facial hair can affect the ability the ability of the respirator to protect you. Anything that comes in the way of the respirator's seal or gets into the valve can allow for contaminated air to leak in and cause less protection.

(http://www.ec-si.com/fit-testing.html)

Advantages and Disadvantages of  Quantitative Fit Testing

Although fit testing can follow you from job to job, the current employer is fully responsible in ensuring the fit testing and recordkeeping requirements of OSHA are well recorded and documented . The employer must ensure that the respirator is appropriate for the hazards to your face, the respirator is properly cleaned, maintained, and stored, and the proper schedule for replacing cartridges and filters are allowed.

Process Safety Management (PSM)

Process Safety Management (PSM), according to Managing Hazardous Materials – A Definitive Text, is considered when applying management systems to identify, evaluate, and control process-related hazards with the goal of safe operation and maintenance of chemical processes. This applies to specific processes rather than entire facilities. A process is considered to be "any activity involving a highly hazardous chemical, including any use, storage, manufacturing, handling, or the on-site movement of such chemicals, or combination of these activities." Any process is subject to PSM standard if it could contain greater than a threshold quantity of a chemical listed in a standard. The PSM program elements include employee participation (availability to review processes and procedures), process safety information (must be revised and reviewed after every change in procedures), process hazard analysis (updated and revised to account for potential hazards associated with the new equipment), operating procedures (mandate steps for operators), operator training (requiring training and verification for new procedures), contractor management (installs new materials), pre-startup safety reviews (shutting down or starting processes), mechanical integrity (routine inspection of equipment), management of change (selecting and installing new nodes of materials or machinery that is effective and cost-friendly), hot work (brazing lines), incident investigation (investigating the portion of the process involved in an incident), emergency response (reviewing the response plan), audits (evaluates the whether the management of change program adequately addresses the changes made in the procedure), and trade secrets (involved in the business-confidential process). Each of these elements are critical in the overall success of Process Safety Management.

(http://www.training.dupont.com/process-safety-management-system)

DuPont's Process Safety Management

The process safety information that must be documented must include chemical information ( hazards, properties, and reactivity/incompatability), process technology (process or blow flow diagrams, process chemistry, and safe operating limits), and process equipment (piping and instrumentation diagrams, materials of construction, and design codes and standards). 

Process Hazard Analysis (PHA) is considered a formal, team-based approach that helps evaluate the risks that are associated with chemical hazards, to identify procedures and equipment where the risks aren't adequately managed, and to make recommendations to correct these issues. Examples of PHA include checklists, what-if analysis, hazard and operability analysis, failure mode and effect analysis, and fault-tree analysis. The first technique mentioned uses a checklist comprised of pre-determined questions relevant to the system. This type of process safety analysis is most applicable to the early design of processes, relatively simple processes, or a process with which the facility or industry has extensive experience or knowledge. What-if analysis is used by team-brainstorming to determine and question the potential process failures the facility or industry might have. Hazard and operability uses guidewords to focus team discussions around specific deviations (high flow, low flow, or high temperature). Failure mode and effect analysis focuses on ways in which individual process components might fail. Fault-tree analysis focuses on top events first, such as an explosion, and then identifies potential combinations of events that could have led to the top event. This process uses AND and OR logic gates when discussing possible modes of events. This event gives the most quantitative analysis of event probabilities.

An OSHA-compliant PHA must be based on thorough process safety information and must be preformed by a multi-disciplinary team. A proper PHA must address the hazards of the process, administrative, and engineering controls, the consequence of failure of these controls, human factors, facility sitting, previous incidents, and the range of effects.

Pre-Startup Safety Reviews (PSSRs) ensure that the new or modified process is constructed to the appropriate design specifications, that the appropriate operating and emergency procedures are put in place, and that employee and contractor training has effectively been completed before the start-up. They also ensure that PHA's have been modified and subject to management-of-change programs and have been conducted on new processed as well.

The management of change evaluates proposed changes or alterations to processes to identify and address potential health and safety risks. These changes include adding new/different equipment, modifying the design, changing operation parameters, or using different material for construction. A change with grades of stainless steel in the facility or industry could be catastrophic if the chemical and hazards in the area if they are not able to process the chemical and its conditions.