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SUBJECT: Hazardous Materials (HAZMAT)

ALPHANUMERIC IDENTIFIER:

BRIEF DESCRIPTION: All manufacturing facilities must strictly comply with the notification requirements for the handling and shipping of Hazardous Materials and the training of employees in the management of these substances.

KEYWORDS: Spill, release, regulatory, Department of Public Safety, CERCLA

OVERVIEW:

1. Hazardous Materials regulations are also known as Hazardous Worker Protection Rules. They outline the training that all personnel that is engaged with hazardous materials must have, the shipping and handling requirements for these materials, and the appropriate response and clean up activities to be undertaken in the case of an accident.

2. Policy:

The facility manager is responsible to immediately initiate actions to minimize risks to human health, safety, and the environment. Notifications to the appropriate agencies will be made as required by policies and procedures. If there is any question as to whether the incident is reportable or not it will be reported.

In the event of a spill or a release:

• Immediate action will be taken
• Immediate notification summary will be prepared including the amount released, if the release poses a threat, if the release exceeds any locality-specific reporting requirements, and whether or not it meets the reportable quantity levels established by CERCLA, EHS, CAA, and RCRA.
• The National Response Center will be notified
• All other required notifications will be made. These can include the US EPA, EPA Local Emergency Planning Committee, EPA State Emergency Planning Committee, OSHA, and the US Department of Transportation.
• The incident will be reported internally with support and contacts immediately available from Corporate Communications, Legal, Corporate Regulatory Affairs, and Manufacturing management.

3. The policies and procedures that fall under this subject apply to the training of personnel and any inadvertent and/or uncontrolled release into the environment from all domestic (USA) manufacturing plants and labs of oil or hazardous substances.

4. These policies are important to manage the liability that manufacturing and the corporation has as a result of the use of hazardous materials in manufacturing. Proper management of these issues will allow the ‘business of manufacturing’ to continue unfettered by the specter of federal or state regulatory punishment.

5. When working with hazardous materials the best plant ensures that all employees are fully and properly trained on the management of these substances and the course of action to be taken in the case of an accident. This will ensure that accidents are infrequent and that when they do occur minimal downtime will be incurred by the manufacturing facility in question.

6. The following regulations and any amendments to them are central to the requirement for managing hazardous materials:

• EPA Resource Conservation and Recovery Act (RCRA)
• Clean Air Act of 1990 (CAA)
• Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA)
• OSHA
• Superfund Amendments and Reauthorization Act of 1986, (SARA)
• Emergency Planning and Community Right to Know Act (EPCRA)

REFERENCES:

• Federal Emergency Management Agency http://www.fema.gov/
• Environmental Protection Agency http://www.epa.gov/
• Institute of Hazardous Materials Management http://www.ihmm.org/
• Center for Hazardous Materials Research http://www.chmr.org/
• Hazardous Materials Management Magazine http://www.hazmatmag.com/
• Emergency Film Group http://www.efilmgroup.com/

ACKNOWLEDGEMENT: This is a March 29, 1999 revision by Gene Goodson of an assignment for OM742 contributed by Andrew Vickers.