Step 8: Implementing Procedures for Handling Drums and Containers

Date First Published on SafetySmart Compliance: February 21st, 2012
Topics: Hazwoper & Emergency Response |

Section (j) of Hazwoper (1910.120(j)) sets out precautions for the handling, transport, labeling and disposal of hazardous substances and liquid contaminants. Here’s an overview.

General Requirements for Drums & Containers

Drums and containers used during cleanup must meet appropriate DOT, OSHA and EPA standards governing the substances contained. Where “practical,” drums and containers must be inspected and their integrity verified before they’re moved. Drums and containers that can’t be inspected before moving due to storage conditions, e.g., buried in the earth or stacked behind other drums, must be moved to an accessible location and inspected before further handled.

Unlabelled drums and containers must be treated as if they contain hazardous substances unless and until the contents are positively identified and labeled otherwise.

Site operations must be organized so as to minimize drum or container movement.

Before moving drums or containers, all employees exposed to the transfer operation must be warned of the potential hazards.

US Department of Transportation specified salvage drums or containers and suitable quantities of proper absorbents must be available and used in areas where spills, leaks or ruptures may occur.

A spill containment program which is part of the employer’s health and safety program is required (See Step 1) if there’s a risk of major spills.

Drums and containers that can’t be moved without rupture, leakage or spillage should be emptied into a sound container using a device classified for the material being transferred.

A ground-penetrating system or other detection system must be used to estimate the location and depth of buried drums or containers.

Soil and ground covering removal must be done with caution to prevent drums or containers from rupturing.

There must be fire extinguishers on hand that meet the requirements of Subpart L of the General Industry Standard.

Opening Drums and Containers

 

If an airline respirator is used, connections to the air supply source must be protected from contamination and the system from damage.

Employees not involved in opening drums or containers must stay back at a safe distance during opening.

There must be a suitable shield that doesn’t interfere with work operations to protect employees working near or adjacent to drums or containers being opened from explosion.

There must also be opening control, monitoring and fire suppression equipment behind the explosion shield.

Spark-proof equipment and tools must be used where there’s a possibility of a flammable atmosphere.

Drums and containers must be opened in a way that safely relieves excess interior pressure. If pressure can’t be relieved from a remote location, there must be a shield in place.

Employees must not be allowed to stand on or work from drums or containers.

Materials handling equipment used to transfer drums and containers must be selected, operated and positioned to minimize ignition sources to prevent igniting vapors from ruptured drums or equipment.

Drums and containers of radioactive wastes may not be handled unless and until the hazards they pose are properly assessed.

Handling Drums Containing or Suspected of Containing Shock Sensitive Wastes

 

All non-essential employees must be evacuated from the transfer area. Material handling equipment with explosive containment devices or protective shields must be provided.

An alarm system that employees can perceive above surrounding light and noise must be used to signal the start and end of explosive waste handling activities.

Portable radios, hand signals, phones and/or other means of continuous communication must be maintained between the employee in charge of the immediate handling area and both the site and health supervisor and command post until the handling operation is completed. Communication equipment or methods must not be used if they can cause shock sensitive materials to explode.

Drums and containers under pressure—as evidenced by bulging or swelling—may not be moved unless and until the cause for excess pressure is determined and appropriate containment measures are implemented to protect employees.

Drums and containers of laboratory waste must be treated as containing shock-sensitive or explosive materials unless and until characterized otherwise.

Additional measures are required under Sec. 1910.120(j)(6) for handling of laboratory waste packs.

Shipping and Transport of Drums and Containers

 

Drums and containers must be identified and classified before packaging for shipment.

Drum or container staging areas must be kept to the minimum necessary to safely identify and classify materials and prepare them for transport.

Staging areas must have adequate access and egress routes.

Bulking of hazardous waste is allowed only after a thorough characterization of the materials is completed.

Tank and Vault Procedures

 

Tanks and vaults containing hazardous substances must be treated the same way as drums and containers with hazardous substances, based on the size of the tank or vault.

There must be appropriate entry procedures set out in your health and safety plan (See Step 1) for whenever employees are required to go into a tank or vault.

 

OSHA Guidelines

Compliance Guidelines (Appendix C)

 
 
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