With the inception of the Resource Conservation Recovery Act (RCRA,) EPA made it clear that hazardous waste generators are responsible for the wastes that they generate. In addition, EPA also has developed many other regulations and programs to minimize the environmental impact of hazardous materials used and generated by industry.
Facilities often are subject to multiple EPA regulations, depending upon the nature of their business and upon the types of hazardous materials used in or generated by their processes. As these facilities create or modify environmental plans, many find that establishing or upgrading simple housekeeping and preventative maintenance procedures often can solve a multitude of environmental woes.
IDENTIFYING AREAS FOR IMPROVEMENT
Tackling all of the potential environmental problems for the entire facility can seem overwhelming, but if each area is addressed individually, the task becomes more manageable.
First, consider using a blueprint or other drawing of the facility to help identify potential areas for environmental harm. Lobbies, conference rooms and office areas probably have minimal impact. Restrooms and cafeterias also are likely to fit in this category. A brief stroll through each of these areas should confirm whether this assessment is valid.
Next, begin at one end of the facility and work to the other. Look for areas that are dirty — for example, floors that are wet, stained or slippery — or anything else that looks untidy. Take notes or pictures in each area to provide a point of reference later.
Another way to do this is to look at the life cycle of materials at the facility, tracking them from their arrival to their departure. By doing it this way, most, if not all, areas of concern should be addressed. Although no two facilities are the same, many share these common problem areas.
Loading docks and bulk offloading areas often are busy places. Containers and other packages being received may not arrive in good condition, or may be subject to forklift damage while they are waiting to be moved to storage or processing areas. Hoses used in bulk fluid transfer often leak, creating a potential for liquids to enter storm drains.
Warehouses and storage areas are sometimes home to leaky containers or damaged packaging as well. If a system is not in place to rotate stock, they also can become an area where products and supplies are kept past their expiration date. When expired items are discovered and are no longer useful, they become wastes.
Laboratories often have small amounts of hazardous materials that present a hazard if they are not properly stored, used and disposed of. Fortunately, following a chemical hygiene plan, as outlined in OSHA regulations, can help achieve environmental stewardship in this area.
Fluid dispensing areas may have leaky pumps and faucets, nearly full drip cans and small puddles from overfills that make the area look bad. As workers walk though spilled fluids, the mess also is tracked to other areas.
Pipelines from bulk storage tanks can be another area of concern if they are not properly maintained. Leaks from joints, tees and other fittings — or failure at any of these points — not only waste valuable fluids, but also create the potential for harm if the fluids reach floor drains.
Waste collection areas and satellite accumulation areas sometimes look bad because workers a hurry to get rid of their wastes, and funnels don't seem to drain fast enough. Or, the funnel is too small for the job and the target is missed altogether. Spent rags, wipes and absorbents that are collected in these areas tend to overfill drums because bolt rings are difficult to remove, or no one can find the wrench.
After identifying the problems in each area, plans can be created for simple good housekeeping improvements that will increase environmental compliance and help make the facility safer as well.
Making changes to standard work practices is difficult. Nearly everyone is reluctant to change. One way to help encourage change is to involve a group of workers, managers and others in the process. Show them the pictures that were taken in each area or take them to the area and show them the current problems. Allow them to work together and create a plan for improvement in each area.
Just as the EPA envisioned, the results likely will be surprising. Plans may include changes that are as simple as installing self-closing faucets or creating a pipeline inspection schedule. By involving workers and others in planning, changes typically are more realistic than issuing a corporate “zero tolerance” policy that looks great on paper but is not achievable.
As plans are written, continue to gain input from this or other groups within the facility. This helps everyone become comfortable with the plans, and will help make the change seem more gradual. If plans involve a small amount of time being spent to clean up areas at the end of each shift, or to clean up messes when they are made, ensure that managers are aware of this and allow adequate time in production schedules.
Stocking tools and supplies and implementing changes are the next steps toward better housekeeping and simplifying compliance.
Spill kits or absorbents are a good safeguard in loading docks and bulk offloading areas. They easily can be tucked by the doors of the loading dock or stored in a weather-tight container outside to allow workers quickly to respond to spills before they spread over a larger area or reach a drain. Portable containment pools are another option in bulk offloading areas. Non-absorbent dikes and drain covers are additional choices to handle incidental spills.
Warehouses and storage areas may benefit from containment sumps that are designed to fit directly in storage racks. If spills occur, they are contained in that section of racking, instead of potentially damaging everything below them before the spill hits the floor. Implementing a stock rotation system — either computerized or in a hard copy form — will help prevent products from getting lost on the shelf or exceeding their expiration dates. A spill kit or ready access to absorbents also is beneficial in these areas.
Self-closing faucets, absorbents and brackets to hold pump hoses will help keep fluid-dispensing areas cleaner. Purchasing containers with lids or seals for use at workstations instead of open buckets can help minimize leaks and spills and may help improve air quality if the liquids have high vapor content or evaporate rapidly.
Pipelines can be tricky. They may look fine in a weekly or monthly inspection, only to cause problems a few days later. Maintain a stock of proper tools, including wrenches and quick-setting patch and repair items, to help minimize downtime and spills. Portable products that help divert leaks to a bucket or other holding container also are available for leaks that cannot be stopped rapidly.
Collection funnels that cover the entire head of a drum or allow for quick drainage are ideal for waste collection and satellite accumulation areas. Making bung wrenches, spare bolt rings and bungs easily accessible will help encourage compliance. As with other fluid handling areas, a small spill kit or stock of absorbents in the area will enable workers to quickly handle overfills and incidental leaks.
As new items are placed in each area, train workers on their use and ensure that everyone is comfortable using any new equipment or supplies. Workers should know who to contact when supplies are exhausted or spent materials — such as absorbents — need to be handled.
Implementing these and other housekeeping efforts will help improve environmental compliance efforts. And your employees will benefit from a cleaner, safer workplace.
Karen Hamel is a technical specialist for New Pig Corp. in Tipton, Pa. She is a graduate of the University of Pittsburgh and has more than 9 years' experience helping customers find solutions to their environmental, health and safety issues. She is hazwoper technician-level-certified and serves on her county's LEPC. She can be reached at (800)HOT-HOGS or by e-mail at [email protected].