By Tony Rieck
T.R. Consulting, Inc.
July 2002 Safety Article
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OSHA published a performance oriented standard on handling of drums and containers that can be found at 29 CFR Part 1910.120(j). This performance standard approach means that, rather than spelling out precisely procedures for handling drums and containers, general issues are addressed and the user is left to determine the most appropriate procedures for meeting the addressed concept. OSHA also publishes the following regulations that also apply to handling drums and containers:
* 29 CFR Part 1910.106 – flammable and combustible liquid storage,
* 29 CFR Part 1915.173 – drums and containers – shipyard employment, and
* 29 CFR Part 1910.1200 – hazard communication labeling requirements.
Additionally, EPA and DOT also set forth regulations applicable to drums and containers.
Further, it is important to understand the scope of these regulations. OSHA defines “anything that holds hazardous chemicals except pipes and piping systems” as a container (48 FR 228 p. 53335). OSHA does not concern itself with non-hazardous materials; however, that does not mean that drums or containers containing non-hazardous materials cannot cause injury to workers, potentially leading to citation by OSHA for violation of other worker safety procedures. Examples of non-hazardous materials stored in drums and containers would include a drum of sand rolling or falling and striking a worker, or a metal container that had rusted causing an oxygen deficient within container resulting in asphyxiation of an employee. Thus, containers range from those that fit comfortably in the hand to massive million bbl storage tanks. This article will not attempt to address the requirements for storage tanks as the wide variety of tank structures and locations makes the topic too large for inclusion.
Most injuries to employees related to drums and containers result from the materials stored in the drums and containers or the physical properties of the stored materials. This article will divide the topic of handling drums and containers into the following categories of controls and safeguards that need to be in place to protect employees:
d) Approved drums and containers
e) Drum condition
f) Other considerations
* Unlabeled drums
* Flammable materials
* Leaking drums and containers
* Buried drums and containers
* PPE selection
* Special wastes
* Other relevant topics
Prior to any movement of drums or containers containing hazardous materials or otherwise posing a threat to the safety of employees, all employees are required to be informed of the potential hazards associated the contents of the drums or containers. The employer must conduct periodic review and discussion of information provided on material safety data sheets, or review other sources of adequate information (i.e. the NIOSH Pocket Guide to Chemical Hazards) with employees when the material of storage is routinely stored in containers on site. When the material being stored in a drum or container is not routinely handled by employees, such as at an emergency response location, the review of hazard information needs to encompass all potentially affected employees prior to handling a drum or container of known contents. Where the contents of a drum or container are unknown or unconfirmed, employees need to be instructed to wear a level of PPE corresponding to the highest level of potential exposure until the contents of the drum or container have been successfully identified.
Where spills may occur, employees need to be informed of the procedures contained in the employer’s spill containment program so that they can implement controls to contain and isolate the entire volume of any hazardous material being transferred. Additional areas requiring appropriate training of employees include:
* Sampling procedures,
* Communication methods,
* Methods for relieving pressure from drums and containers or for shielding when pressure cannot be relieved from a remote location,
* Emergency response to accidents on site,
* Characterization of wastes to be bulked,
* Use of monitoring equipment, and
* Confined space entry procedures, where required.
The training outlined above represents the minimum set of topics to be considered when employees will be required to handle drums and containers. Some of the topics may not be applicable to certain circumstances and other situations will require training in addition to the topics provided herein.
Drums and containers are required to be identified and classified prior to packaging for shipment. Manufacturer’s and other shippers and distributors are required to include information about the material being shipped on a material safety data sheet (MSDS) in addition to the requirement for labeling of drums and containers. Labeling clearly identifies the product stored within the drum or container while classification provides information about the level of fire hazard, degree of health hazard, how reactive the material is, etc.
It is important to caution that the presence of a label or other chemical information on the drum or container does not preclude the possibility that the stored material is some other substance than the one described. This is especially true with drums at abandoned waste sites or where drums have been disposed of illegally. In such instances, it is not uncommon for the entity disposing of the waste to have chosen any container based solely on availability and without any regard for proper labeling of the contents. In other instances, labels are purposely removed to make it difficult or impossible to trace the material to its source of origin.
It is important to establish standard operating procedures for handling drums and containers. Planning is an essential element necessary to minimize the amount of drum or container movement as is required by OSHA regulations and to ensure an appropriate response in the event that a spill might occur. Proper fire fighting equipment needs to be on hand and ready to use when handling drums or containers that store flammable, combustible or unknown substances in order to control any incipient fires.
One aspect of drum and container handling that often gets overlooked is the proper opening of the drum or container. It only takes a couple of pounds of pressure to cause a loosened fitting to fly into the air like a rocket. This projectile can cause injury to site workers on either the way up or the way down. The projectile can puncture adjacent containers or drums, causing rupture and leakage. If the drum or container is filled to or near the level of the opening, product can spew from the opening (think of a soda can after shaking) causing injury to site personnel, formation of hazardous/flammable atmospheres at the work site and/or environmental damage. The procedure for opening of drums and containers needs to incorporate the minimum safeguards listed below:
* Employees not actually involved in the opening of the drum or container must be kept a safe distance from the drum or container during the process of opening it.
* If an employee’s duties require him to remain in the vicinity of a drum or container that is being opened, shielding that does not interfere with the work operation must be placed between the employee and the drum or container being opened to protect that employee from any potential explosion.
* The controls for equipment (including monitoring equipment and fire extinguishing/suppression equipment) used to remotely open drums and containers must be located behind an explosion resistant barrier.
* Where there is the reasonable probability of a flammable atmosphere being present or developing on site, all equipment and tools must be of a type to prevent sources of ignition (non-sparking, explosion proof, intrinsically safe) and grounding/bonding needs to be considered.
* If the pressure within a drum or container cannot be relieved from a remote location, the employee opening the drum or container needs to be protected by an appropriate shield to reduce the risk of injury.
* Drums and containers are not step ladders. Employees are not allowed to stand on or work off of drums or containers.
* Material handling equipment used to move drums and containers needs to selected, positioned and operated in a manner that minimizes the potential for the equipment to act as a source of ignition in the event that a drum or container should rupture.
* When handling shock-sensitive wastes, all non-essential employees must be evacuated from the potential impact area.
* Equipment operators need to be protected from explosions by protective shields or containment devices.
* When a drum or container exhibits signs of over-pressurization such as swelling or bulging, the drum or container is not to be moved until the cause of the over-pressurization has been determined and proper containment procedures have been implemented.
* It is necessary to limit the number of areas where drums and containers are staged in order to identify and classify them.
* Areas where drums and containers are staged need to be provided with adequate routes for access and egress from the staging area.
Drums and containers are required to meet the appropriate DOT, OSHA and EPA regulations for the materials that they contain. Additionally, there are some instances where approval by a nationally recognized testing laboratory such as Underwriters Laboratories (UL) or Factory Mutual (FM) is recognized. As an example, under regulations of 29 CFR Part 1910.106, windshield solvents (35% methanol/65% water = class 1C flammable) must be stored in metal containers at designated volume thresholds. Since the time of the last amendments to that section of regulations, large plastic drums and containers have been approved for this purpose. These large containers or drums will carry either a DOT approval or a nationally recognized testing laboratory approval or both. The use of approved drums and containers provides some assurance that the drum or container will not fail due to incompatibility with the stored material and that the drum or container is structurally suitable for designated duty.
Improperly abandoned drums in warehouses, fields and other locations result from illegal disposal and from businesses that ceased to exist and left their wastes and process chemicals behind. When approaching such a site, one of the first concerns is whether the drum is leaking or has leaked. If the drum is found to be intact, one of the next questions is the ability of the drum to withstand movement. The following apply to the assessment of drum condition:
1) When practical, drums and containers must be inspected and their integrity assured prior to being moved. Drums and containers that cannot be inspected prior to being moved due to storage conditions (i.e. buried, in a pile, stacked several tiers high, etc.) must be moved to an accessible location and inspected prior to further handling.
2) Drums and containers that cannot be moved without risk of rupture, leakage or spillage must be emptied into a sound container using a device classified (i.e. intrinsically safe or explosion proof for the class of flammable material) for use around the material being transferred.
3) Drums and containers are to be opened in a manner that safely relieves excess internal pressure. (see procedures above).
4) If crystalline material is noted on any container, the contents of the container are to be handled as a shock-sensitive waste until positive identification of the contents determines otherwise.
Some additional requirements for the handling of drums and containers that did not fit neatly into the above categories are listed below:
Unlabeled drums and containers must be considered to contain hazardous substances and are to be handled accordingly until positive identification of the contents has been made.
Polyethylene drums and containers are not equipped with a means for electrical grounding. When transferring flammable materials, the polyethylene container (or any other container for that matter) needs to be equipped with a mechanism that allows for grounding. A grounded suction pump (approved only) or a grounded metallic self-closing faucet can be used to accomplish safe transfer of flammable materials from these containers.
Where leaking drums or containers may be present, or ruptures or spills may occur, U.S. DOT specified salvage drums or containers must be available on site along with suitable quantities of an appropriate absorbent material.
Buried drums and containers require the use of detection systems or devices that can estimate the location and depth of burial of the buried drums or containers. It is important that any soil covering be removed cautiously in order to avoid mechanical damage to the buried drums or containers.
Until the condition and contents of drums and containers has been positively identified, those approaching the site (from the upwind side where possible) are approaching an unknown hazard and must be appropriately protected. The minimum acceptable level of PPE for approaching a site of unknown toxicity is Level B. Additional information that has been gathered about the site through historical records or remote observation may indicate a potential hazard requiring Level A protection.
Drums and containers may contain special wastes. Special wastes may be radioactive, shock-sensitive, laboratory wastes or biological wastes. Each of the above special waste categories requires specialized training for potentially exposed individuals.
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