By Sara Hamidovic and Elizabeth Grubb
We are not sure about you, but we are amazed that we are already heading into fall, and three-quarters through 2020! Despite the crazy year we’ve all experienced, we have managed to make it to facilities across the country for annual compliance audits. Therefore, we want to share some key safety and compliance items we look for during our audits.
- Emergency Contacts
Every facility should have a list of emergency contacts readily accessible for employees. This contact list should include the state regulatory agency, the applicable United States Environmental Protection Agency (USEPA) regional office, local fire department, local police department, nearest hospital with an emergency room, and any on-site personnel to contact in case of an emergency.
This list should be posted in the main office to ensure easy access for employees and customers. Employees should be trained on when to contact authorities regarding spills, leaks, potential contamination, and other emergencies. Reviewing this list during training will give employees the tools needed to alert the relevant authorities of an emergency.
2. Spill Kits
Every facility needs to have spill kits readily accessible throughout the facility. VET recommends keeping fully stocked oil spill kits in the dismantling, large core storage, parts storage, fluids storage, and engine/transmission storage areas. This allows employees to cleanup oil spills and leaks on occurrence.
Additionally, facilities should obtain a mercury spill kit and battery spill kit. Facilities can create their own battery spill kit with baking soda to neutralize spilled acid, gloves, safety glasses, and containment for batteries with cracked or broken housings. These particular kits provide the specific materials necessary for addressing spills from mercury switches and lead acid batteries.
3. Spill Prevention Control and Countermeasure Plan
A Spill Prevention Control and Countermeasures Plan (SPCC) is a site-specific plan that the USEPA requires many industrial facilities to implement. An SPCC establishes procedures, methods, equipment, and other requirements to help prevent oil and petroleum product discharge from a facility and to promote appropriate response to spills. Non-transportation related facilities storing at least 1,320 gallons aggregate capacity of oil or petroleum products aboveground, on site (or 42,000 gallons aggregate capacity below ground, on site) are required to have an SPCC in place.
VET’s SPCC plans outline the necessary steps to take in response to a reportable spill, provides site-specific strategies for reducing the potential for spills, and provides necessary reporting and inspection forms to maintain compliance. This is an area of concern as we often see facilities with an aggregate storage capacity over 1,320 gallons without an SPCC plan.
4. Safety Training
All facilities need to have a safety program in place with regularly scheduled meetings. During our audits, we review each facility’s safety program including topics covered and recordkeeping practices. We always recommend employees are trained annually on Fire Safety, Back Injury Prevention, Mercury Safety, Cutting Torch Protocol, and the Hazard Communication Standards (Hazcom).
Forklift operators should be trained every three years. Records of training attendees and topics covered should be maintained on-site with employees’ signatures. Implementing a safety training program ensures that employees are knowledgeable about specific safety protocols and provides tools to avoid potentially dangerous situations.
5. Essential Safety Items
When visiting a facility, we always check for essential safety items such as fire extinguishers, 15-minute emergency eyewash stations, fully stocked first aid kits, personal protective equipment (PPE), Safety Supervisor information, and necessary safety postings.
• We check to make sure fire extinguishers have current certification and that the facility has adequate supply in case of a fire. It is crucial that fire extinguisher certifications are up to date and are re-certified or replaced as necessary.
• Eyewash stations and first aid kids should be fully stocked in readily accessible locations in case of emergency.
• Employees should have PPE available for use at all times, such as PPE steel-toed boots, safety glasses, hard hats, and gloves.
• Your facility’s Safety Supervisor should be posted in a place visible for customers and employees. This allows any immediate safety issues to be brought to the supervisor’s attention and provides their contact information in case of an emergency.
We hope this information provides an overview of safety and compliance items necessary for all facilities. We want to help our clients prepare for emergencies, and maintain compliance. If you have any questions, contact VET at (812) 822-0400.
Sara Hamidovic is President/Principal Engineer of VET Environmental in Bloomington, Indiana. She is a Licensed Professional Engineer (PE) in the State of Indiana and a Certified Hazardous Materials Manager (CHMM).
Elizabeth Grubb, MS, MPA is the Storm Water Program Manager at VET Environmental Engineering, LLC.
