This letter constitutes OSHA's interpretation of the requirements discussed. Rogue work or unauthorized laboratory experimentation. Hands should be washed with soap and water immediately after working with any laboratory chemicals, even if gloves have been worn. Technically, these apply to hazardous wastes, but they may still be relevant. Third: Consider the physical and chemical characteristics of the chemicals stored onsite. Risks to laboratory security include, but are not limited to: [76 FR 33609, June 8, 2011; 77 FR 17888, March 26, 2012; 78 FR 4325, Jan. 22, 2013], Occupational Safety & Health Administration, National Research Council Recommendations Concerning Chemical Hygiene in Laboratories (Non-Mandatory), Occupational Safety and Health Administration, Outreach Training Program (10- and 30-hour Cards), OSHA Training Institute Education Centers, Severe Storm and Flood Recovery Assistance, 1910.1450 App A - National Research Council Recommendations Concerning Chemical Hygiene in Laboratories (Non-Mandatory). You can stay informed and send comments regarding these regulations by signing up for the secondary containment Listserv. Occupational Safety and Health Program. Keep chemical hood areas clean and free of debris at all times. 1. Accidents are unexpected by definition, which is why coworkers should always be present. Observe the PELs and TLVs OSHA's Permissible Exposure Limits (PELs) must not be exceeded. Conduct drills. Warnings at areas or equipment where special or unusual hazards exist. This reference, henceforth referred to as "Prudent Practices," is available from the National Academies Press, 500 Fifth Street NW., Washington DC 20001 (www.nap.edu). While the official article doesn't mention products specifically, OSHA requires hazardous material storage containers to meet minimum EPA and OSHA safety standards. A lock (LockA locked padlock) or https:// means youve safely connected to the .gov website. According to OSHA secondary containment requirements, a secondary container must be provided when the capacity of an individual primary container exceeds 55 gallons or when the aggregate total of multiple containers exceeds 100 gallons. That makes your secondary containment a BMP that fulfills the EPA's requirements for a SWPPP: containment, maintenance and operating procedures. Information Secondary Container Labels Must Contain. Secondary Containment Testing Requirements California Code of Regulations, Title 23, Division 3, Chapter 16, Section 2637 What secondary containment is required to be tested? Waste containers should be clearly labeled and kept sealed when not in use. (e) In addition to the requirements of paragraphs (b), (c), and (d) of this section, secondary containment systems must satisfy the following requirements: Responsibility and accountability throughout the organization are key elements in a strong safety and health program. So you have the liberty to build, design, install and use whatever type of systems or products you want as long as they meet the regulated criteria and are truly capable of stopping a discharge from leaving an area. The level of detail of the plan will vary depending on the function of the group and institutional planning efforts already in place. 7501 E. Lowery Blvd. Most organizations use fire alarms whenever a building needs to be evacuated-for any reason. Many of our customers use our Build-A-Berm System to achieve their secondary containment needs while allowing forklift, dolly and cart traffic to move freely in and out of the room. Thanks, Learning to participate in this culture of habitual risk assessment, experiment planning, and consideration of worst-case possibilitiesfor oneself and one's fellow workersis as much part of a scientific education as learning the theoretical background of experiments or the step-by-step protocols for doing them in a professional manner. Subpart H, Hazardous Materials, dives in to hazardous waste site cleanup efforts. Shipping Chemicals: Outgoing chemical shipments must meet all applicable Department of Transportation (DOT) regulations and should be authorized and handled by the institutional shipper. (40 CFR 112.3). If you need to provide containment for this area, and the room has a floor that is free of cracks and can be sealed, you could possibly use the room itself as containment by putting a berm near the doorway instead of using drip decks or spill pallets. Laboratory air should not be recirculated but exhausted directly outdoors. To assist employers in developing an appropriate laboratory Chemical Hygiene Plan (CHP), the following non-mandatory recommendations were based on the National Research Council's (NRC) 2011 edition of "Prudent Practices in the Laboratory: Handling and Management of Chemical Hazards." Before modification of any building HVAC, the impact on laboratory or hood ventilation should be considered, as well as how laboratory ventilation changes may affect the building HVAC. Ensure that PPE is available and properly used by each laboratory employee and visitor. Use adequate ventilation (such as a fume hood) when transferring even a small amount of a particularly hazardous substance (PHS). There are various type sealants. Its provisions are intended to reduce the hazard to a degree consistent with reasonable public safety, without undue interference with public . The laboratory supervisor or CHO is responsible for ensuring that all personnel are aware of the locations of fire extinguishers and are trained in their use. A business can plan to meet OSHAssecondary spill containment requirements by following these steps: The business should familiarize itself with the relevant OSHA regulations mentioned above, namely; the Hazard Communication Standard (HCS) and the Hazardous Waste Operations and Emergency Response (HAZWOPER) standard. The Chemical Safety Board has identified the following key lessons for laboratories that address both physical and other hazards: In addition to laboratory safety issues, laboratory personnel should be familiar with established facility policies and procedures regarding emergency situations. Download (PDF, 345KB) Loading. However, the ability to accurately identify and assess laboratory hazards must be taught and encouraged through training and ongoing organizational support. Thank you for your letter to the Occupational Safety and Health Administrations (OSHA) Directorate of Enforcement Programs (DEP). Only containers with adequate identifying labels should be accepted. Theyre part of the overallOSHA chemical storage regulations, which aim to ensure the safe handling and storage of hazardous chemicals in the workplace. OSHAs secondary containment requirements for chemicals are in place to help prevent potential harm to employees and the environment in case of a hazardous chemical spill or leak. To determine the type and level of emergency planning needed, laboratory personnel need to perform a vulnerability assessment. OSHA Record Keeping and Reporting Cheat Sheet Use this OSHA Record Keeping and Reporting Cheat Sheet to navigate the complexities of OSHA reporting. Neither organization defines what a secondary containment system should look like. Some reagents pose a risk on contact with the atmosphere. Because youre only storing one container, you would need enough capacity for 55 gallons. So, a little housekeeping is in order. The chemical hygiene program must be reviewed annually and updated as necessary whenever new processes, chemicals, or equipment is implemented. An ideal solution is our UN bag, which is UN-approved and can safely contain chemical and hazardous waste prior to and during transportation and recycling. Practice shelter-in-place, including plans for extended stays. Response: Yes. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. Workers should contact the CHO or EHS office for instructions before cleaning up a chemical spill. Kindly direct me to a good reference source which reguires a sealant/protective coating for concrete surfaces in fuel download/transfer areas. You mention choosing between 55 and 5 gallons of containment. Oxidizers, reducing agents, and fuels should be stored separately to prevent contact in the event of an accident. Please let us know if you have any other questions. Laboratory-grade, flammable-rated refrigerators and freezers should be used to store sealed chemical containers of flammable liquids that require cool storage. Chemical shipments should be dated upon receipt and stock rotated. Facilities are permitted to determine the methods, devices, etc. As such, their guidelines for spill containment are geared to ensuring that the employees involved in spill containment are not exposed to hazardous substances that could cause chronic health effects, chemical burns, sensitization, and other effects on their health and safety. Each hazardous waste site clean-up effort will require an occupational safety and health program headed by the site coordinator or the employer's representative. Each waste type should be stored in a compatible container pending transfer or disposal. Proper protective equipment and handling and storage procedures should be in place before receiving a shipment. The Laboratory's CHP must be readily available to workers and capable of protecting workers from health hazards and minimizing exposure. Seeks ways to improve the chemical hygiene program. This allows you to continue using the chemical within the primary tank until the tank system can be emptied, inspected, and repaired if necessary. Now, before you get overwhelmed thinking about containment for every single thing in your facility that has a SDS, lets put things in perspective. Your secondary containment system must be able to hold a volume greater than or equal to 110% of the largest tank or storage container and cover at least the entire surface under each dry-cleaning machine, tank or container. The OSHA Laboratory standard defines a CHP as a written program developed and implemented by the employer which sets forth procedures, equipment, personal protective equipment and work practices that are capable of protecting employees from the health hazards presented by hazardous chemicals used in that particular workplace. (29 CFR 1910.1450(b)). Wear closed-toe shoes and long pants or other clothing that covers the legs when in a laboratory where hazardous chemicals are used. Response: As explained above, when following the workplace labeling requirements at paragraph (f)(6)(ii), employers must ensure that there is other information immediately available to employees to provide specific information regarding the chemicals health and physical hazards. This letter constitutes OSHAs interpretation only of the requirements discussed and may not be applicable to issues not delineated within your original correspondence. Select appropriate controls to minimize risk, including use of engineering controls, administrative controls, and personal protective equipment (PPE) to protect workers from hazards. Know who to notify in the event of an emergency. NFPA 30 doesnt discuss transfer areas, but requires containment areas to be liquidtight (A.9.13) It also mentions that the authority having jurisdiction needs to deem the area to be acceptable, so sealing the concrete could certainly be deemed an acceptable practice. Thanks! Could employees be harmed if this tank fails? Report unsafe conditions to the laboratory supervisor or CHO. Only the minimum amount of the chemical needed to perform the planned work should be ordered. Secondary containment is typically used to contain and control the spread of hazardous chemicals, in case of a primary container failure. Secondary containment is required by OSHA when there is a possibility of a hazardous chemical spill or leak that could pose a threat to the environment or employees. This training must be at the core of every good health and safety program. Walls should be finished with a material that is easy to clean and maintain. Our Tech Team is a group of experts that is dedicated to answering all your regulation questions! Liquid Handling The handling of hazardous liquids is subject to both safety and health regulations requiring protection for employees who work with flammable, combustible . The organization's environmental health and safety (EHS) office should be consulted in determining which methods are appropriate for different types of waste. Proper waste disposal methods include incineration, treatment, and land disposal. The Code of Federal Regulations . Provide Laboratory Ventilation The best way to prevent exposure to airborne substances is to prevent their escape into the working atmosphere by the use of hoods and other ventilation devices.