Hazardous materials (hazmat) can be classified as any substance or chemical that has the potential to cause harm to humans, animals, or the environment. These can include toxic, corrosive, or carcinogenic materials and materials that can cause instant damage if they are not handled appropriately.
Occupational Safety and Health Administration (OHSA) regulations establish the principles for basic protection. Additionally, the Environmental Protection Agency (EPA), the Department of Transportation (DOT), and the Nuclear Regulatory Commission (NRC) also weigh in on hazards relating to their specific industries, which also contribute to the OHSA regulations framework. As an example, the DOT requires cargo to carry hazmat placards.
These regulations mean that if there is an incident such as a chemical or oil spill, employers must consider their responsibility when it comes to the safety of workers (covered by OHSA) and environmental issues covered by the EPA.
What are the OHSA hazardous material rules/EPA SPCC?
The EPA uses the OHSA definition of hazardous materials but adds to the list “any item or chemical which can cause harm to people, plants, or animals when released by spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping or disposing into the environment (40 CFR 261).”
EPA SPCC guidance (Spill Prevention, Control, and Countermeasure) sets out regulations regarding oil spills. The EPA ruling was originally published in 1973 to prevent, protect, and respond to oil spills under the Clean Water Act. Over the years, other hazardous materials have been added to the list of dangerous substances, but SPCC mainly relates to oil spillage and preventing hazardous chemicals from entering the water system.
Secondary containment
If you operate an SPCC facility, you must ensure secondary containment measures to prevent hazardous materials from entering the water system. How you do this will depend on the location of your facility, but you will need to show evidence of compliance to an EPA safety inspector under all circumstances.
Spill containment berms, chemical tank containment, and spill containment systems should all be in place to deal with spill control both in the case of a major emergency and in the usual course of your daily operation.
For example, a 55-gallon drum spill containment or spill pallet that holds a selection of smaller-sized storage drums is sufficient for many businesses to operate safely and should be part of OSHA spill kit requirements. Larger operations will require more significant secondary containment measures such as a spill containment berm that must be constructed on the premises.
The EPA rules require that your secondary containment facility should be able to contain at least 10% of the total volume of your primary containers or 100% of your largest container (whichever is greater in volume).
How do the OHSA hazardous material rules/ EPA SPCC apply to the transport industry?
Remember that if you are operating in a transfer area where hazardous materials are loaded and unloaded, there must be secondary containment facilities on-site sufficient to deal with the volume of material. This ruling is outlined in section 2.5.3 Loading/Unloading Activities in the SPCC guidance for EPA regional inspectors.
