SUB-PROBLEMS INCLUDING LEADING TO IMPAIRMENT AND BEST PRACTICES FOR HAZARDOUS MATERIALS USE, COLLECTION, STORAGE, AND TRANSPORTATION
The hazardous properties inherent in the production, storage, use, and transportation of chemicals have led to serious problems impacting workers, the community, and the environment. Major explosions and/or fires in a variety of chemical plants have contaminated land, water, and air. The release of hazardous substances to the air impacts human health and the local environment. Explosive atmospheres have been created in facilities by concentrations of dust mixed with oxygen and then a source of ignition sets off an explosion. Groundwater, surface water, and the soil have been contaminated from spills or leakage of chemicals from a series of minor leaks which have accumulated over time or a larger spill. Transportation sources have overturned and exposed the area to substantial amounts of chemicals. All these situations have had a profound effect upon communities, the personal health of individuals, and various ecosystems.
There have been recent catastrophic chemical facility incidents in the United States. President Obama, as a result of these very serious chemical exposures, issued Executive Order 13650 entitled “Improving Chemical Facility Safety and Security” on August 1, 2013. The Executive Order sets forth several tasks for the federal government agencies and their numerous partners plus industry to reduce hazards and improve community health and safety by: strengthening community planning and preparation efforts; enhancing the coordination of all operating units of the federal government; improving the collection of data, data management, and data presentation to all significant parties; modernizing all policies and regulations; and incorporating feedback from all stakeholders in the development of Best Practices to prevent and mitigate chemical accidents.
In addition, other major hazardous materials include petroleum and petroleum products and natural gas, as well as radioactive substances used for research, treatment, and nuclear explosives. An extensive discussion of petroleum and petroleum products as well as natural gases is the subject of other books. However, there are limited discussions in this area in Chapter 2, “Air Quality (Outdoor [Ambient] and Indoor)” and Chapter 5, “Environmental Health Emergencies, Disasters, and Terrorism.” An extensive discussion on radioactive substances is also the subject of other books. Some references are made to the use of radioactive tracers or material for treatment in Chapter 8, “Healthcare Environment and Infection Control” and very brief mention of this topic in the section discussing disposal of medical waste.
Another major category of hazardous materials includes a variety of biological materials. (See Chapter 8, “Healthcare Environment and Infection Control” for a discussion in this area as well as Best Practices.)
A hazardous material is any substance which could adversely affect the health and safety of the public and the individuals who produce, store, use, transport, or dispose of it.
The Department of Transportation established nine classes of hazardous materials for transportation purposes including:
- • Class 1—Explosives of all types
- • Class 2—Gases that are both flammable and non-flammable and those that are toxic through inhalation
- • Class 3—Flammable liquids and combustible liquids with a flashpoint between 140°F and 200°F
- • Class 4—Flammable solids, those that combust spontaneously, and those that combust when exposed to water and give off a dangerous gas
- • Class 5—Oxidizers and organic peroxides
- • Class 6—Toxic materials and infectious substances
- • Class 7—Radioactive materials
- • Class 8—Corrosive materials
- • Class 9—Miscellaneous dangerous goods including dry ice, asbestos, engines, materials with elevated temperatures, etc.
Each one of these classifications has its own emblem which must be displayed on the transporting vehicle.
General Best Practices for Use, Collection, Storage, and Transportation of Hazardous Materials
- (See endnote 57)
- • Industries involved in the processing, use, collection, storage, and transportation of hazardous materials should use all necessary techniques, procedures, and technologies to avoid an accidental release of hazardous materials in the industry facilities as well as contamination of the air, water, and land. This can be accomplished by: determining through ongoing studies and hazard analysis, those operations which are most risky and therefore provide the greatest opportunity for accidental releases or spills; using non-hazardous or less hazardous materials in a process where possible; training all workers in the specific skills needed to manage the hazardous materials; providing good design and installation practices; totally enclosing all processing and handling systems; using a separate ventilation system including if necessary safety cabinets; and separating the hazardous materials process, storage, and use from all other processes within the industry facilities. Excellent supervision and management by highly skilled individuals is mandatory to keep a system of this nature working properly. Spills and accidental releases must be kept at an absolute minimum and if they occur, they should be completely cleaned up immediately by highly capable individuals using appropriate equipment and wearing the proper personal protective gear.
- • Establish the position and office of Director of Environmental Health and Safety with the authority to cross all departmental lines to make necessary inspections, studies, and recommendations, and carry out enforcement actions concerning all events, spills, occupational safety and health hazards, emergency situations, etc., with the direct authority of the chief executive officer of the facility.
- • Develop a working plan with the authority of the chief executive officer and the participation of trained professional consultants, all department heads, middle-management, and representatives of the workers to prevent, mitigate, and if necessary clean up any spills or other hazardous material incidents that may occur at the facility, which may affect those present and/or the community.
- • There should be a daily visual inspection of the facility to determine if there are obvious problems that need to be immediately corrected by department managers or supervisors. Especially inspect areas where, according to records of past problems in the plant or in the industry in general, serious incidents have occurred. Be aware of the potential for fires and explosive events occurring.
- • Establish an inspection program of all pipes, valves, and containers to ensure that there is not any leakage and correct all problems immediately.
- • Use special fittings, pipes, and hoses for transfer of materials from arrival to storage, and from storage to use within the facility.
- • Use secondary containment units in the event of frequent problems of escape of materials from storage units.
- • Use flame-resistant substances on vents in areas of flammable storage.
- • Where underground storage tanks are used, they should be double-walled and specially coated to prevent corrosion and release of hazardous materials to the environment.
- • All outside contractors must follow the rules and regulations of the facility and must be overseen by facility workers with appropriate knowledge and skills.
- • Carefully measure the quantities of active ingredients needed in a formula and only utilize the amount which is necessary to make the appropriate agricultural chemical. Avoid wastage, which not only saves money but also preserves the environment.
- • Use the byproducts of the original process in an appropriate manner including selling them to other industries.
- • Reuse any raw materials that are left over from the original process instead of sending them to waste.
- • Use an automated filling system with proper alarms and shut-off systems to avoid spillage of materials.
- • Return all toxic materials packaging to the supplier for recycling or dispose of in an environmentally safe manner.
- • Minimize storage time for all products and send them out to customers as rapidly as possible to prevent deterioration of the chemicals.
- • Store all raw materials, byproducts, waste products, and final products in areas totally separate from potential stormwater contamination.
- • All facilities used to wash trucks and other equipment must have self-contained areas for the wash water, away from any potential stormwater flow. The wash water must then be treated before it can be released into any body of water or into the groundwater supply.
- • Where feasible, reuse the water from the manufacturing process.
- • Ensure that containment areas for stormwater are properly designed and constructed prior to putting into use.
- • Evaluate frequently and especially prior to heavy storms, all stormwater control structures and containment areas to determine if problems exist which may potentially cause a rupture of the containment system, affecting areas where hazardous chemicals are being stored, transferred, or used.
- • Evaluate for potential leakage or fugitive dust loading and unloading areas, elevator shafts, means of movement of the raw or finished product from one area to another, mixers, temporary holding hoppers, and wash areas.
- • Utilize dust control agents on the exterior such as oil, sprays of water, and special chemical sprays. The best techniques are those involved in preventing dust production by enclosing those plant areas where dust is frequently produced such as in loading and unloading and moving the material into other areas. These enclosed spaces need to have specially powered dust collection systems and be specially ventilated with excellent filters, and the employees need to have the proper respiratory gear for the situation. Frequent daily dust removal from surfaces using dustless techniques is essential.
- • Never store together chemicals with different hazard symbols.
- • Store all chemicals in a special enclosed facility with impermeable concrete floors and appropriate ventilation systems.
- • Prevent tanks from being overfilled and use alarm systems to warn workers of the problem and automatically shut off the filling device.
- • Install groundwater monitoring devices to determine if chemicals are seeping down to the strata in the ground.
- • Use explosion-proof, spark-proof equipment and make sure that all equipment is grounded.
- • Provide separate storage areas for pesticides from fertilizer storage and blending areas.
- • Ensure that all deliveries of chemicals are accompanied by the proper paperwork and that a responsible person receives the delivery and verifies all items listed, the expiration date of the chemicals, as well as those containers that may be leaking or damaged.
- • All communities and their leaders should be advised of the facilities involved in the production and storage of hazardous chemicals, an assessment of the potential risk involved for an accident or disaster, and how best to respond to this situation while protecting the health and safety of the citizens. Special concerns include geographic and socioeconomic issues as well as potential weather conditions and the needs of special sensitive populations.
- • Establish a local emergency planning commission as a response to potential chemical and other material hazard accidents and disasters. The committee should represent all stakeholders, while utilizing appropriate technical personnel to help in the decision-making process. These committees are most effective at the local level but must have immediate and constant support from the state and federal governments. When a plan has been made operational, it has to be tested by the governmental agencies as well as the numerous stakeholders in the community.
- • The local emergency planning commission can obtain from the Centers for Disease Control and Prevention the necessary material safety data sheet for each chemical produced or raw material used. These sheets include product identification information including the manufacturer’s name, a list of all ingredients on the label, and regular and emergency telephone numbers; a list of hazardous ingredients and the type of hazard such as toxicity, flammability, reactivity, etc.; the chemical substance using recognized nomenclature as well as common names; the approximate percentage by weight or volume of the hazardous ingredients in any mixture; hazard data such as parts per million, milligrams per kilogram, permissible exposure levels, and flashpoints; physical data such as melting points, vapor density, evaporation rate, etc.; fire and explosion data; health hazard information including permissible levels of exposure and routes of exposure such as skin contact, eye, inhalation, and ingestion; reactivity data; emergency and first aid procedures; spill or leak procedures; personal protective equipment required; and special precautions as stated on labels and warning placards. Further, information should be provided on toxic, acute, and chronic health effects, allergic and sensitizing effects, and carcinogenic, teratogenic, and mutagenic effects created by the hazardous materials.
- • Ensure that firefighting agencies have specific information on the requirements for putting out fires related to specific chemical compounds. These requirements include appropriate extinguishing agents; extinguishing agents which will not create additional hazards; special protective equipment for the firefighters; and special training for all individuals involved in the firefighting and necessary cleanup.
- • Establish accidental hazardous materials’ measures to be utilized including: immediate information to the appropriate authorities on what has been released, quantities, specific hazards to people and the environment and how to counteract these hazards; accurate structural plans showing all areas of handling, storage, and use of the hazardous materials; provision of local and general ventilation; and appropriate means of cleanup without endangering the workers or community.
- • Determine in advance who will do the clean-up work, and how there will be immediate provision of personal protective equipment to deal with the specific hazard and what will be the means of ultimate disposal of the material in a safe manner. Provide specialized training for these individuals on a continuing basis. Have very knowledgeable supervisors in charge of all operations.
- • Develop a written hazard identification and communications program involving all agencies, industries, universities, community leaders, and the general public.
- • Ensure that all information from all individuals will be funneled to a single operational headquarters where decisions can be made and responsible individuals issue necessary directives to carry out specific tasks during the emergency or disaster.
- • Integrate the industry rapid response team with the local rapid response team under a single command structure utilizing the same communications network.
- • Establish a rapid communication system between the industries which may be involved in a chemical crisis and the communities which may be the recipients of the hazards in various forms of contamination of air, water, land, shelter, and food. Provide alternate means of disseminating information in the event that the system goes down. Test the system periodically to determine how rapidly information will be disseminated and then make the plan operational including the use of appropriate equipment and trained people.
- • Improve basic training and specialized training depending on the type of emergency that is expected for all first responders and emergency management preparedness and response personnel.
- • Establish a single set of standard operating procedures for all individuals working to resolve a hazardous materials incident.
- • Develop the specifications for personal protective equipment and make it such that all individuals involved will be able to interchange equipment as needed to eliminate surpluses in some area and lack of equipment in other areas.
- • Develop a single data service that can be used by all individuals to rapidly disseminate necessary information and how best to respond to specific types of hazardous material incidents. This data service will integrate information from all federal and state governmental agencies and applicable industries.
- • Develop a team of experts from all working agencies at the state and federal level as well as industry to standardize the data collection and interpretation.
- • Develop a team of experts from all working agencies at the state and federal level to be able to respond rapidly to a situation and provide high levels of specific knowledge and experience to any given hazardous materials event.
- • Review all existing policies and regulations of all governmental agencies. Eliminate all confusing and misunderstood policies or conflicts established by different policies at different agencies on the same issue.
- • Request and utilize feedback from the stakeholders such as the facility owners and operators, the workers, people in the community and their organizations, unions, environmental organizations, universities, etc., in order to establish Best Practices in the gathering and use of data and the resolving of problems in a uniform manner. Expand and enhance training of all governmental employees, especially those working in the field responsible for chemical facilities and potential emergencies.
- • Develop online as well as other types of training sessions for all interested people.
- • Update all response teams regularly on lessons learned from actual experiences and new technologies available to prevent and mitigate the exposures from accidental chemical or other hazardous materials releases.
- • Work with Congress to develop adequate budgets that will be provided as grants to various communities to consistently upgrade the skills, knowledge, equipment, and reserves of first responders and emergency management personnel.
- • Develop a chemical facility safety and security executive committee at the national level to be responsible for maintaining high level competency in all areas, coordinating the efforts of all federal agencies, and immediately inserting appropriate staff and equipment when requested by state and local committees to help resolve specific emergency situations.
- • Prioritize potential hazards by using existing data to determine the types of chemical and other hazardous materials accidents, releases, and disasters which are most frequent and develop a timely response for the prevention of these problems. Carry out frequent inspections to enforce necessary actions to eliminate sources of problems before they occur.
- • Develop an evacuation plan for employees and the community which will be put into operation under specific conditions. Determine the lines of authority necessary to make this operational. Test the plan periodically to make sure that it works.
- • Use chemicals that are less hazardous where possible within the operation.
- • Do not allow unauthorized individuals to access oil and gas storage facilities as well as other potential hazardous materials sites.
- • Improve local and state Safe Drinking Water Act measures to prevent and mitigate chemical spills into the drinking water supply.
(See endnote 86)
There have been several very serious incidents in the transportation of hazardous materials which has affected communities and the health and safety of their residents. There are approximately 1 million shipments each day in the United States of hazardous materials by railroad, truck, pipeline, aircraft, and waterways with 99% arriving safely. Even though the rate of problems has decreased, there still are numerous accidents with potential release of hazardous materials to the air, water, or land. The sharp increase in crude oil production and ethanol production as well as movement of other bulk hazardous materials, which may be flammable, by rail and truck has led to some serious incidents affecting communities. The hazardous materials incident may cause not only a huge economic problem to the community but also social and psychological impacts that last for considerable periods of time.
Flammable liquids exceed all other categories of hazardous materials being transported. Highway traffic for total tonnage of hazardous materials exceeds all other categories put together.
There are numerous economic effects from transportation incidents with hazardous materials. They include injuries and fatalities, cost of cleanup, property damage, damage to the carrier, costs of evacuation, product loss, delay in delivery, and environmental damage.
Hazardous materials are regulated by the US Department of Transportation through use of the Hazardous Materials Regulations. These regulations apply to any commercial activity by rail, aircraft, ships, and motor vehicles. They also apply to shippers, brokers, warehouses, packaging, reconditioning centers, and independent testing agencies. The Hazardous Materials Regulations of the federal government define a hazmat employer as one who uses employees who work in various capacities in the transportation or handling of hazardous materials. A hazmat employee is a person who is directly involved in hazardous materials transportation safety. Transportation of hazardous materials is a highly regulated industry and for good cause since any type of accidental release may be catastrophic.
On January 16, 2014, the Secretary of the US Department of Transportation issued a call to action resulting in meetings with rail company executives, petroleum producers, and others to find immediate ways to reduce the potential for the unintended releases of hazardous substances.
Best Practices in Transportation of Hazardous Materials (See endnotes 46, 47)
- • Determine the type and amount of hazardous materials that will be transported and means of transportation, determine the classification of the substances, use appropriate placards, and follow all rules and regulations established by the US Department of Transportation for that particular class of hazardous materials.
- • Provide initial training to all individuals who will be involved in any aspect of transporting hazardous materials including all new rules, regulations, and Best Practices, before they are allowed to carry out their work assignments.
- • Use US Department of Transportation training modules for all employees.
- • Use frequent in-service training to bring the individuals up to date and provide complete retraining every 3 years.
- • The employer is responsible for all training, testing, maintenance of records of training, and certification of all individuals and must have the records available at any time for evaluation by governmental agencies.
- • Never ship materials that are so hazardous that they are designated as forbidden. This may apply to all forms of transportation or only special forms of transportation. This typically includes: materials that will explode in a fire; a combination of materials that will react and produce poisonous gases or vapors or cause a corrosive effect; substances which will react with air to cause a flammable reaction; and substances that will react to cause intense heat.
- • Packaging for hazardous materials is based on the level of the hazards and standards set by the US Department of Transportation. There must be no release of the contents of the package under any condition.
- • Packaging of liquids for aircraft transportation must withstand a variety of barometric pressures and rapid changes. The inner packing must prevent breakage and be leak proof.
- • Substances that may react with each other must never be placed in the same package.
- • Hazard warning information must be on all packages being transported and all shipping documents. The packages must be accompanied by the shipper’s certification and signed by an individual trained in the appropriate areas of hazardous materials transportation. This provides for emergency responders immediate information on the types of hazards encountered in the event of an accident.
- • Display all hazard warning placards and identification numbers on the outside of motor vehicles, freight containers, and bulk packaging of hazardous materials.
- • Provide all information concerning the hazardous materials to train crews, motor vehicle drivers, flight crew members, and appropriate personnel on vessels.
- • All incidents involving hazardous materials must be immediately reported on the automated Hazardous Materials Information System database. Information would include inadequate or improper packaging, problems during loading, unloading, or handling of packages; and inadequate securing of packages within transport vehicles.
- • If a hazardous material is shipped by air and a discrepancy is found in the shipment, it must be reported immediately to the closest federal aviation civil aviation security office by telephone and then in writing.
- • Hazardous materials must be properly segregated within the transportation vehicle.
- • Visually inspect all shipments to determine if they are properly packaged, labeled, and secured.
Best Practices in Local Community Recovery from Disastrous Hazardous Materials Transportation
- • Local communities need to establish a special plan concerning hazardous materials transportation incidents including the necessity and means for mass evacuation, shelter, mass care, restoration of the road system and bridges, and environmental response to contamination of air, land, shelter, water, and food supplies. (Much of this information can be found in Chapter 5, “Environmental Health Emergencies, Disasters, and Terrorism.”) The plan should include a federal role, state role, community resources, and Best Practices learned from other communities who have experienced the same type of problem. It should also cover a short-term recovery phase, intermediate recovery phase, and a long-term recovery phase which may take months or years.
- • Establish a single source of information on hazardous materials, potential health and environmental problems in the short-term and long-term, and how to deal with them through various means of decontamination.
- • Develop a public education program concerning the various types of hazardous materials that are transported through the community and how best to deal with serious incidents.
- • Determine in advance all federal and state funding sources in the event of an emergency and be prepared to instantly request assistance for the community.
- • Establish a system of instant communications of various forms to advise the citizens of the hazardous situation and what to do immediately.
- • Conduct damage evaluation studies including the safety of public and private structures.
- • Establish appropriate shelters and advise endangered residents to evacuate to the shelters including special needs shelters. Use a central system to track the evacuees.
- • Restore all essential services including electrical, water, and sewage utilities, means of communications, and transportation.
- • Medically evaluate residents who have been exposed as well as emergency management service personnel. Determine various levels of psychological problems and treat accordingly.
- • Determine if it is appropriate to close beaches and commercial fisheries as well as any farmlands or other food sources, and advise the public not to use the areas or consume the food.
- • Determine when it is safe for individuals to return to their homes, businesses, sources of recreation, and industry.