After hurricanes Katrina and Rita
in 2005, containers of hazardous
substances were displaced over
wide areas and had to be collected
and treated as hazardous waste at
designated facilities.
Additionally, the storms caused hazardous
substances in some locations to be
accidentally released. Furthermore, preexisting
hazardous waste sites, RCRA
corrective action sites, and RCRA TSDs,
were also affected by the storm and required
special attention as a result of the
disaster.
The following are the specific types of
sites at which following information applies:
a) emergency response operations
to stop the release of hazardous substances;
b) post-emergency response operations
to remove hazardous substances, health hazards, and materials contaminated
with them; and c) sites where HAZWOPER
already applied to site clean-up,
treatment, storage, or disposal operations.
While the requirements of OSHA’s
HAZWOPER standard apply to the incidents
and sites described above, it is important
to note that there are many other
recovery activities that will not be covered
by this standard (e.g., sand and
sludge removal; vegetative debris collection;
building assessment; mold remediation;
roof inspection, tarping, and repair).
Where the HAZWOPER standard applies,
the response, cleanup, and recovery
activity should only be performed by designated
employees who are trained and
equipped according to the requirements of
the standard.
During emergency response activities, if hazardous chemical containers are
found or leaking materials are detected,
self-protective measures must be taken
(i.e., move to a safe distance upwind) and
hazardous material response personnel
must be contacted (e.g., the EPA or U.S.
Coast Guard) for evaluation of the risk
and removal before continuing work in
the area.
OSHA requires an evaluation of the
need to revise protective clothing, respirator,
and glove selection. If personnel are
likely to witness or discover a hazardous
substance release such as a large spill of
fuel, oil, corrosives, or other chemicals,
they should be trained under the Hazardous
Waste Operations and Emergency Response
(HAZWOPER) standard, 29 CFR
1910.120(q)(6) or 29 CFR 1926.65(q)(6).
Upon arrival, response personnel
should inspect tanks, drums, and other
containers for integrity before moving
them; if they cannot be inspected in place
(e.g., because they are buried or stacked),
OSHA says move them to an accessible
location and inspect them prior to further
handling. Take the following precautions:
• Remove soil covering containers with
caution to avoid damaging the container;
• Assume that containers hold hazardous
substances until the contents can be positively
identified and labeled;
• Minimize container movement;
• Limit access to the areas and warn all
potentially exposed employees of potential
hazards associated with the contents;
• Keep absorbent and over-pack equipment
available where leaks or spills
might occur; transfer contents from damaged or unsafe containers into sound
containers to avoid ruptures and spills;
Ensure fire extinguishers are available
in the immediate area.
Opening Drums and Containers
When opening drums and containers,
restrict the area to individuals actually involved
in opening the container. Consider
the risk of explosion; provide shielding,
open drums remotely, or provide other
protection in the area where this may be a
hazard.
Use material handling equipment and
tools that prevent ignition (e.g., nonsparking,
intrinsically safe) if a flammable
atmosphere may be present in or
around the drums and containers being
moved/opened.
Open containers in a way that will allow
internal pressure to be relieved
safely; if this cannot be done remotely,
then place a shield between the employees
and the drums/containers to prevent
injury. Prevent employees from standing
on drums.
Drums and containers containing packaged laboratory wastes must be considered
shock-sensitive or explosive until
characterized one way or another.
If crystalline material is observed on
any container, handle the container as if
it is shock-sensitive until the contents are
identified. Handle shock sensitive wastes
using the following minimum additional
special precautions:
Evacuate all non-essential employees from the transfer area.
Use material handling equipment with
explosive containment devices or protective
shields to protect equipment operators
from exploding containers. Signal the
beginning and end of explosive waste
handling activities using an employee
alarm system that can be perceived above
surrounding light and noise conditions.
Maintain continuous communications (using equipment that will not cause
shock sensitive materials to explode)
between the employee-in-charge of the
immediate handling area, the site safety
and health supervisor, and the command
post throughout explosive waste
handling activities.
Do not move drums and containers under
pressure (bulging or swelling drums)
until the cause of the excess pressure is
determined and appropriate containment
procedures have been implemented to
protect employees.
Segregation of Wastes
Responders should segregate containers
of hazardous materials by expected
hazard class according to the following:
Store incompatible hazard classes
separately (e.g., oxidizers away from
flammables).
Store/stack containers securely so that
they will not break or fall and so that they
are clear of vehicular traffic and heavy
equipment.
Provide spill containment, where necessary.
Line hazardous material holding area
with plastic sheeting and build a berm
around the perimeter to contain leaking or
spilled material.
At the end of each shift, cover hazardous
materials that were not processed
with plastic and close the lids on any
drums.
Store and handle hazardous materials
in areas with natural or forced ventilation;
do not store or handle in low-lying areas.
If intact hazardous chemical containers
are found with debris, segregate them from
the waste stream before continuing work
in the area.
If broken or leaking hazardous chemical
containers are found with debris, contact a
supervisor/hazardous material personnel
for evaluation/removal before continuing
work in the area.
If material that may contain asbestos is
found with debris, contact a supervisor/hazardous
material personnel for evaluation/removal
before continuing work in the area.
Thermal system insulation (formed or
spray-on) is the asbestos-containing materials
(ACM) of greatest concern for response
and recovery worker exposure.
Other materials that may contain asbestos
include: vinyl floor tile, home siding and
shingles, transite (including cement piping), flame retardant materials (e.g.,
gloves, curtains), and roof flashing.
