It's time to think outside the container when assessing the risks of storing hazardous materials.
It can be hard for an employee to think about a worst-case scenario when drums of flammable liquids have been kept in a corner of the plant's storage room for years without incident.
Convincing top management to expend additional resources to store hazardous materials safely can be even more difficult, especially when there are no accidents to magnify the need to exercise caution, according to Michael H. Ziskin, president of Field Safety Corp. of North Branford, Conn.
"With a material that doesn't do anything and sits there minding its own business, people may look at it and decide there are 20 years of experience with it sitting there doing nothing," Ziskin said. "Experience dictates it's a material that can be put almost anywhere, and nothing will happen to it."
The problem is that a hazardous material -- whether it be flammable, combustible or corrosive -- cannot be stored anywhere. Unfortunately, it may take a worst case, such as a toxic leak or an explosion, to convince managers and workers to focus on the safe storage of hazardous materials. A fire or explosion can result in millions of dollars of damage and claim workers' lives. In fact, improper storage and handling of flammable liquids is the leading cause of industrial fires.
Because of a low probability of an incident, the call for management to base a risk assessment on potential environmental impact and worst-case scenarios can fall on deaf ears.
Ziskin has found that to be the case in his work at Field Safety, a management and educational firm specializing in environmental health and safety. The problem, he said, is that not enough companies take a comprehensive approach to assessing the risks of storing hazardous materials.
Too often, the focus is only on storing materials according to regulations, such as OSHA's 29 CFR 1910 Subpart H and consensus standards like National Fire Protection Association Code 30 for flammable and combustible liquids. Conventional thinking is that, if the rules are followed, there will not be a problem. That thinking, however, can cause a false sense of security.
For safety's sake, it's time to widen the focus, Ziskin said, because no regulation can cover every eventuality. "You've got to get outside the box. You've got to look at how that hazardous material relates to the rest of the world."
Any issues pertaining to storage can be resolved by answering four questions: What material is being stored? Why is it being stored? Where is it being stored? How is it being stored?
What material is being stored? Understand the physical and chemical properties of a hazardous material. The material may be incompatible with some substances and conditions. For instance, flammable liquids should not be stored with an oxidizing agent.
Why is the material being stored? Any risk assessment should include ways to eliminate or reduce the risk (i.e., hazardous materials). Companies should find ways to use less hazardous substances or reduce the quantity of materials stored, Ziskin said. A just-in-time inventory approach, for example, will lower the amount of hazardous materials on site.
Where is the material being stored? Ensure that "storage" is clearly defined as a permanent, temporary or transient location. A storage location can be anywhere the container is placed, even if for a short time. "Sometimes, a storage location is nothing more than a place to put the hazardous material when the storage area is full," Ziskin said. "The most vulnerable location for a hazardous material is in a location where people don't expect it to be."
In addition, recognize the way in which the material is being moved into and out of the storage location. Would handling fewer containers reduce the chance of a spill? If so, it might be safer to move a pallet with one large container than a pallet with four smaller drums.
Stay informed of processes that take place in areas adjacent to the storage location. Changes initiated by other managers or workers could affect the integrity of safely stored materials. For example, an ignition source is created when a heater is installed near flammable liquids.
How is the material being stored? Determine intended environmental conditions under which the material should be stored. That means reviewing local, state and federal regulations and a manufacturer's specifications. For example, not more than 60 gallons of Class 1 or Class 2 liquids, nor more than 120 gallons of Class 3 liquids, may be kept in a storage cabinet, per OSHA 1910.106(d)(3)(i).
Regulations, however, will not cover all scenarios. Rules may not specify what to do if there are more containers than will fit in a storage cabinet, or what could happen if containers are exposed to heat from sunlight while temporarily stored on a loading dock. It's situations like these, as well as when a hazardous material is introduced at a work site, that call for a risk assessment, Ziskin said.
Performing a risk assessment will help provide workers with adequate information regarding hazardous substances, said Chris Kraus, CHMM, director of business development for 3E Co., a leader in hazardous materials information management.
"Too many companies don't do a thorough evaluation as to what a hazardous material means to a worker," Kraus said, "so they can't train and educate them on how to handle the material."
Larry Garcia, who teaches a hazmat course at the OSHA Region 10 Education Center in Seattle, concurs that workers often lack a proper understanding of risks surrounding hazardous materials.
"A lot of the problems with workers occur when they don't recognize the fact that a fire or explosion can happen," said Garcia, a hazmat specialist for Prezant Associates in Seattle. "They don't identify the clues."
Properly trained workers will recognize those clues and be more likely to take the time to ensure that hazardous materials are stored, moved and handled in a safe fashion.
One way to spot a clue is through observation, followed by taking immediate corrective action, said Hugh Flack, CHMM, director of health, safety and environment for Dexter Corp.'s Adhesive and Coating Systems plant in Waukegan, Ill. The facility uses flammable liquids and heavy metal pigments for the manufacture of specialty coatings for the aerospace, automotive and specialty industries.
"We work hard on training supervisors and managers to perform visual recognition of potential hazards," Flack said. "They walk their areas and look for clues like scratched paint and damaged racks, doors and walls. Those tell us that, for some reason, there was contact that potentially could become a problem." Damage to a hazardous materials storage rack, for instance, could lead to the rack collapsing.
Flack treats damage as a near-miss incident and an early warning indicator that something may need to be fixed before the condition becomes worse. "Once damage is observed, depending on its degree, we perform an investigation or a root-cause analysis to find out why there was damage," he said. Examples of solutions are additional operator training and modification of a storage room layout.
If the damage is to a hazardous material container, its contents may need to be transferred to another vessel. Damage that causes a leak would necessitate immediate action, Flack said.
Employee training regarding hazardous materials falls under OSHA's hazard communication standard, 1910.1200, the most cited regulation in OSHA's rulebook. From October 1998 through September 1999, OSHA issued 7,122 citations with proposed penalties totaling $1.5 million.
The purpose of the standard is to ensure that information concerning hazardous materials is transmitted to employers and employees through a comprehensive program that includes labeling of containers and material safety data sheets (MSDSs). If a container is incorrectly labeled or has no label, a worker may not know its contents or whether the substance is being stored safely.
During an OSHA investigation of a hazardous material incident, investigators will want to see the company's hazard communication plan and MSDSs, Kraus said. "They want to see if you're prepared and have done that risk assessment," he said. "If you haven't done that, how can you know that you should tell workers not to put incompatible materials in the same storage cabinet?"
Training of workers should involve more than ensuring they know where to find an MSDS and how to read it, Kraus said. At Dexter, Flack includes safety talks and annual hazard communication testing as part of worker training. Table tents in the cafeteria highlight a chemical of the month and include information on potential health hazards and first aid measures.
Those still having problems convincing a worker about the potential consequences of improperly storing hazardous materials may want to send the employee to one of Garcia's hazmat classes.
To drive home the point, Garcia shows students what can happen when an oxidizer is stored in a flammable liquid storage cabinet. After he mixes the incompatibles, a fire breaks out.
"I try to stress that the two materials should not be stored together. It's a pretty visual recollection for the students," he said of the controlled fire. "It's one thing to talk about what can go wrong. It's another thing to demonstrate it."