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What is the EPA's role in the regulatory process of environmental health & safety issues? (page 1-3)
Created in the early 1970's, the EPA (Environmental Protection Agency) is responsible for leading the contry's efforts to protect and clean up the environment. The EPA seeks to implement the sometimes contradictory environmental priorities and requirements contained in federal environmental law through ten regional offices.
What does the RCRA cover? (page 1-6)
RCRA (Resource Conservation and Recovery Act), the nation's basic statute for the management of solid and hazardous wastes defines those wastes, authorizes the EP to set standards for faciities that generate or manage hazardous waste, and establishes a permit program for hazardous waste treatement, storage, and disposal facilities. RCRA also establishes a program to regulate USTs (underground storage tanks). RCRA has two basic goals. The first is to provide for proper management of hazardous and nonhazardous waste materials. The second is to promote resource recovery and reuse.
What does the Federal Water Pollution Act cover? (page 1-7)
Promulgated in 1972, the Federal Water Pollution Control Act regulates wastewater discharges to suface water, publicly owned treatment works, and septic systems. It also regulates stormwater runoff and discharges of hazardous materials to navigable waterways. EPA considers "navigable waterways" to include all tributaries to such waterways. Thus, a ditch or extremely small creek could fit within their definition.
This act is a comprehensive regulatory array primarily intended to control the discharge of effluent from point sources into navigable waters. Although non-point sources are regulated, the primary concern of the act is with point sources. Recently, however, there has een more concern and focus on non-point sources such as agriculture and construction runoff.
What does the CAA cover? (page 1-8)
The Clean Air Act (CAA), promulgated in 1970, regulates air pollution and toxins and the renovation and demolition of structures with ACM (asbestos-containing material). The objective of the CAA is to protect and enhance the quality of the nation's air resources in order to promote and maintain public health and welfare and the productive capacity of the population. The CAA achieves this objective by regulating emissions into the air. Controls on stationary and mobile sources of emissions are implemented through combined federal, state, and local programs. Pursuant to the CAA, the EPA has promulgated the National Ambient Air Quality Standarsd, NESHAP (National Emission Standards for Hazardous Air Pollutants), and New Source Performance Standards, any of which may aply to the source, depending on the pollutant involved.
In 1992 Congress adopted significant changes to the CAA, further regulating industrial emissions, acid rain, and emissions of toxic materials It put into place a completely new permitting system for stationary sources of air emissions. Congress alos required the preparation of RMP's (risk management programs) at facilities that store highly hazardous chemcials above threshold quantities.
Explain the EPCRA. (page 1-9)
Title III of SARA (the Superfund Amendments and Reauthorization Acct) is a stand-alone statute titled EPCRA (the Emergency Planning and Community Right to Know Act), which creates a chemcial emergency planning and response program and impsoes new non-emergency reqporting rquirements on industry. THe purpose of the requirements is to inform local communities of the nature and amount of chemcials at each affected facility.
What is the principal function of CERCLA? (page 1-10)
Nicknamed "Suprefund," CERCLA sets procedures for responding to releases of hazardous substances to the environment and requires notification of releases above reportable quantities. CERCLA is designed as a remedial statute, authorizing both federal and state governments and, in certain situations, private parties to responde ot can clean up hazardous substances and other toxic pollutants in the water, air, and on land.
The principal thrust of cercla is to impose reporting and cleanup requirements on the private sector. Owners and operators of vessels or facilities from which there is a release of a hazardous substance in a reportable quantity are required to report to the EPA as soon as they have knowledge of the release. The responsible party may then be required to clean up the hazardous substance.
What is common law? (page 1-14)
Commonly law is an unwritten law based on custom and precedent, developed in England, that is the basis for the legal system in the United States, except for Louisiana.
What is statutory law? (page 1-14)
Statutory law is a law enacted by the legislative branch of a government.
Define nuisance. (page 1-15)
Nuisance: Generally, people ay use their own land and property as they see fit; however, they cannot use their property in any way that causes material injury or annoyance to a neighbor. Typical forms of nuisance are noise, odors, smoke, dust, and air and water pollutants.
Define trespass. (page 1-15)
Trespass: Trespass includes interfering with or injuring a person's possessions, committing an unlawful act on a person, or acting forcefully on a person's possessions. Permitting a pollution discharge to cross a boundary onto a neighbor's land (for example, a UST leaking oil onto a neighbor's property) can be considered trespass. The distiction between trespass and nuisance is often blurred.
Define negligence. (page 1-15)
Negligence occurs when a person failes to act responsibly and unintentionally causes inury to a person or their property. Often, violating a law designed to protect the environment or to promote safety is considered negligence.
Define liability without fault. (page 1-15)
For the past century, courts have created a new cause of action - strict liability, or l iability without fault. Initially, this theory was applied to hazardous activities such as the sale and storage of dynamite. Another example of liability without fault is workers' compensation, by which employers are made financially liable for injries occuring in the workplace no matter who was at fault. Starting in 1980, Congress and the courts have imposed the concept of strict liability (liability without fault or negligence) on the owners and operators of property where hazardous waste was created or stored as well as on the transporters and disposers of hazardous waste. Today, the original generators of these hazadous wastes and the owners of property on which teh wastes are located are liable without fault for the full cleanup costs.
What types of fines and civil enforcement come with government citations? (page 1-18)
Civil enforcement can take the form of imposing fines, seeking to restrain certain acts, requiring the performance of certain acts, or recovering cleanup costs incurred by the government. Normally, these actions are brought in the form of administrative proceedings with a notice of an environmental violation and a demand for certain action and the payment of fines. This is followed by a formal administrative proceedings before an administrative judge who, after a hearing, issues a decision which, under certain circumstances cn be appealed to an appropriate court. The big problem with civil enforcement is that most environmental penalties are incurred on a per-violation or per-day basis and can mount up to many dollars in a short period of time.
What is the EPA policy on self-reporting and compliance auditing? (page 1-26)
If you establish and implement a comprehensive compliance program, you gain considerable legal protection while providing a safe and healthful environment for your employees, tenants, and visitors - all of whom are important to your econoic success. In the last few years, government at all levels has promoted voluntary compliance and incentives to achieve environmental health and safety excellence. For example, the EPA has adopted a program that provides incentives for voluntary environmental audits, which encourage reporting and correction of environmental violations. The EPA policy contains a number of incentives, including:
- 1. Substantial mitigation of civil penalties for voluntary discolusre of problems that are identified by routine audit, reported, and promplty corrected.
- 2. Acknolwegement by the EPA that it will not recommend criminal enforcement and will not refer any violations discovered by the voluntary audit to the Department of Justice for criminal prosecution.
- 3. Assurance that the EPA will refrain from using a company's audit against it unless there is independent evidence that a violation has been committed.
How long should records be retained? (page 1-29)
Some regulations specify minimum time frames for retaining files. For example, the confined-space entry regulation requires that permits be kept for one year to allow for program review. The employee exposure regulation requires medical records to be retained and made available to employees and former employees for 30 years after they leave a company. As a general rule, regulatory records should be kept indefinitely. There are statutes of limitations as well as commonsense time frames afgter which the information will no longer be needed. Nevertheless, it is prudent to archive all files for as long as possible.
It has been proven time and time again that good, cear, and well-written documentation is the solid foundation on which a well-run compliance program is based. Such records will serve as the basis for managing your risks and reducing your liabilities in the future.
What is OSHA? (page 2-2)
The 1970 Occupational Safety and Health Act created OSHA (Occupational Safety & Health Administration) within the US Department of Labor. Led by the assistant secretary of labor, OSHA is responsible for developing, promulgating, and enforcing standards to reduce on-the-job injuries (safety standards) and to limit workers' risks of occupational diseases (health standards).
At a multi-employer site, what is an exposing employer? (page 2-3)
The exposing employer is the employer whose employees are exposed. At multi-employer work sites, such as an office complex or construction site, citations are normally issued to the exposing employers.
Who is the creating employer? (page 2-3)
The employer who actually creates the hazard. (May also be cited by OSHA)
Who is the controlling employer? (page 2-3)
The employer who is responsible, by contract or through actual practice, for safety and health conditions at the work site. That is, the employer who has the authority for ensuring that the hazardous condition is corrected.
Who is the correcting employer? (page 2-3)
The employer who is responsible for actually correcting the hazard.
What are OSHA's reporting requirements for an incident resulting in a fatality and/or three or more hospitalizations? (page 2-4)
OSHA requires that a work incident resulting in any fatality and/or three or more hospitalizations be reported directly and verbally to the agency within 8 hours. In addition, if the fatality or in-patient hospitalizations do not occur at the time of the incident but follow within 30 days after the incident date, OSHA still requires notification, and it must be made within 8 hours after the employer first learns of the incident's associated fatality or hospitalization.
How does OHSA handle a complaint issued by a tenant's employee? (page 2-4)
When OSHA receives a complaint, it will determine whether to immediately inspect the alleged hazards. If an investigation is appropriate, the agency will telephone the employer, describe the alleged hazards, and follow up with a fax or letter. The employer can respond in kind, identifyig any problems found and noting corrective actions taken or planned. Generally, an on-site investigation will take place thereafter.
- An on-site investigation will be conducted if an employee complaint meets one of the following criteria:
- -It is in writing and signed by a current employee, and there are reasonable grounds to believe that a violation or a safety or health standard or danger exists under the requirements of OSHA
- -It alleges that such physical harm as a disabling injury or illness has occurred and that it is believed that the hazard still exists.
- -It is based on an allegation of an imminent danger situation.
- -It identifies a hazard or establishment covered by a local or national emphasis program.
- -The employer fails to provide adequate response to a complaint, or there is evidence that the employer's response is false or does not adequately address the hazard.
- -The firm has a history of egregious, willful, or failure-to-abate citations within the subject area and within the last 3 years.
When does OSHA deem a violation to be willful? (page 2-5)
The violations that carry the highest penalties are those determined to be willful. When death or serious physical harm results from an uncorrected hazard, it may be classified as willful. And, contrary to popular belief, the violation may also be classified as willful in cases where, even though no fatality or serious injury occurs, documents show that a manager was aware of a hazard that could potentially result in serious physical harm yet took no corrective measures.
When does OSHA deem a violation to be serious? (page 2-5)
Violations that are classified as serious concern hazards that could cause death or serious physical harm, yet a complete disregard for the safety and health of the individual(s) affected is not apparent. For example, the lack of appropriate electrical protection - that is, absence of GFCI (ground fault circuit interrupter) for a person who needs to use electric power tools.
When is a violation classified by OSHA as repeat? (page 2-5)
A repeat violation indicates that a compliance officer has noted the same violation at the same place of employment within the past three years.
According to OSHA, when is a violation other-than-serious? (page 2-5)
An other-than-serious violation carries the lowest penalites and indicates that the violation - such as the lack of a written program - was less than life threatening, and that the employer did not have previous knowledge of the health/safety standard violation.
What does an OSHA inspection include? (page 2-7)
An OSHA inspection includes an opening inspection, a walk-through, and a closing conference.
How long must violations remain posted? (page 2-7)
Any citations issued as a result of the inspection report must be posted for a minimum of three (3) working days after management personnel receive them.
How does OSHA define an oxygen deficient atmosphere? (page 2-11)
In nature, the ambient concentration of oxygen in air is approximately 21%. OSHA defines an oxygen-deficient atmosphere as one that contains less than 19.5% oxygen.
How does OSHA define an oxygen-enriched atmosphere? (page 2-12)
An oxygen-enriched atmosphere - one that contains more than 23.5% oxygen - is considered hazardous because the increased oxygen may support combustion and render the area extremely flammable.. It is also a health hazard because it lowers carbon dioxide in the blood, which can stop respiration.
How is an explosive/flammable atmosphere defined? (page 2-13)
An atmosphere where a sufficient amount of fuel (vapor, gas, or airborne combustible dust) are present and may result in a flame upon contact with an ignition source. When trying to classify an atmosphere as flammable or nonflammable, the most important aspect of this triangle is the ratio of fuel to oxygen.
What is a toxic atmosphere? (page 2-14)
Toxic refers to any atmospheric concentration of any substance for which OSHA has established a PEL (permissible exposure limit) that could result in an employee being exposed to mroe than the established dose (an amount received over a specific time period) or PEL of that substance.
What is a PEL? (pages 2-14 & 2-15)
A PEL is the maximum concentration of a substance that a person may be exposed to based on a TWA (time-weighted average) or without suffering any aderse effects, although individual response may vary.
What is an air-purifying respirator? (page 2-25)
Air-purifying respiorators do not supply the user with air from a clean source; instead, they are equipped with filters to remove airborne contaminants. Before any air-purifying respoirator can be considered for use, it must first be determined that there is a sufficient concentration of oxygen, at least 19.5% but not greater than 23.5%, present in the atmosphere where the device is to be worn.
What is a negative pressure air-purifying respirator? (page 2-25)
A negative pressure air-purifying respirator requries the user to create negative air pressure inside the face piece relative to the pressure outside the mask by simply inhaling. When the user inhales, air is drawn through the selected filter, and the user is provided with uncontaminated breathing air.
What is a positive pressure air-purifying respirator? (page 2-25)
A positive pressure, air-purifying respirator, also known as a PAPR (powered air-purifying respirator), utilizes an in-line pump to transport breathing air through the cartridges to the user.
What is an air-supplied respirator? (page 2-27)
An air-supplied respirator offers the highest level of protection and must be used in oxygen-deficient atmospheres. These respirators provide the user with breathing air from a clean source, which is fed into the face piece through an air line from a stationary source or from a cylinder located on the user's back.
To meet OSHA standards, how long must records be maintained? (page 2-29)
Each year, a summary of all injuries and illnesses must be posted no later than February 1 of the successive year, and it must remain posted until April 30. All injury reports must be maintained for at least 5 years, plus the current year's report. It is important to note that 5 years is the minimum retention time. Other records, such as employee exposures to toxic materials or medical surveillance, must be kept for length of employment plus 30 years.
When must recordable injuries and illnesses be logged? (page 2-30)
If employees become ill or injured or are involved in an accident or near miss because of a work-related incident, the incident should be reported to the owner or manager as soon as possible. OSHA must be notified if a death or hospitalization of three or more employees occurs. The OSHA regulation requires reporting of these types of incidents within eight hours of the occurrence.
What is the injury summary requirement? (page 2-30)
According to the regulation, an annual summary of occupational injuries and illnesses must be posted by February 1 and remain in place until March 1 to provide employees with the record of injuries and illnesses experienced during the previous calendar year. Doing so allows all employees to review what has happened and to take steps to prevent future occurrences.
Who must be notified about hazards? (page 2-36)
All employees must be knowledgeable about the materials and equipment they work with, any assocaited hazards, and how to control such hazards. Employees also need to know that they cannot undertake a job or operate equpent if they have not received proper instructions or if the task appears unsafe.
Who must be notified of hazards? (page 3-2)
Employees of the owner have the right to know what they may be exposed to while conducting work around hazardous materias. Tenants have the right to know the hazards of the chemcials used by the maintenance staff. Contractors must be informed of hazardous materials that may harm their employees, including those used by a tenant if the cotnractor is doing work in their space. Simply stated, all building employees, tenants, and contratcors have the right to be ifnormed of all hazardous materials that they may come in contact with in the workplace, not matter who uses them.
What is HAZCOM? (page 3-3)
What is an MSDS? (page 3-4)
MSDS are Material Safety Data Sheets, documents describing the physica and chemcial properties of their products, their health and physical hazarsd, and precautions for safe handling and use.
What is a route of entry? (pages 3-7 & 3-8)
Routes of entry are means for which an exposure to a substance takes place: inhalation, ingestion, eye contact or absorption, skin absorption, skin ocntact, or injection.
What are anesthetics? (page 3-8)
Anesthetics impair body functions and the thought process. Solvents and degreasers are commone examples. They can make you drowsy, dizzy, nauseated, or giddy, or they can affect your thinking. They may also cause unconsciousness or, in severe exposures, death.
What are asphyxiants? (page 3-8)
Asphyxiants deprive the body of oxygen. Common asphyxiants are carbon monoxide and ammonia-bleach solutions. Carbon monoxide is a chemcial asphyxiant that blocks oxygen from being exchanged in the body. The resulting off-gas from combusting a strong solution of ammonia and bleach displaces oxygen, causing respiratory distress.
What are corrosives? (page 3-8)
Corrosives destroy body tissues, metals, plastics, and other substances. Acids, caustics, soaps, detergents, and lye are examples of corrosives.They are a contract hazard and, at times, an inhalation hazard.
What are irritants? (page 3-8)
Irritants cause the eyes, kin, mouth, or lungs to become dry, red, itchy, or irritated. Cleaning solvents and detergents can be irritants.
What are sensitizers? (page 3-8)
Sensitizers cause allergic reactions. Exposure to poison ivy or oak is a common example. Formaldehyde and isocyanete-based foam products can also produce sensitization. Algicides or other biological agents used in cooling towers can also be sensitizers. Common products such as aerk's yeast can similarly cause sensitivity reactions in some individuals.
What are carcinogens? (page 3-9)
Carcinogens cause cancer. Asbestos and cigarette smoke are known carcinogens. Constituents in gasoline (for example, benzene) are also carcinogens.
What are mutagens? (page 3-9)
Mutagens change a gene in a sperm or egg cell of the parent. Some insecticides and pesticides are considered mutagenic hazaards. Some restricted-use pesticides can be applied only by a certified (licensed) applicator as required under FIFRA (the Federal Insecticide, Fungicide, and Rodenticide Act) implemented by the EPA.
What are teratogens? (page 3-9)
Teratogens change the embryo or fetus and are a hazard to pregnant females. Crack cocaine and radiation are known teratogens.
What are target organ toxins? (pages 3-9 & 3-10)
Target organ toxins are those that pose health hazards that affect specific organs or specific systems within the body.
What are the physical hazard categories? (page 3-11)
- 1. Fire Hazards
- 2. Compressed Gases
- 3. Explosives
- 4. Reactive of Unstable Chemicals
What are the three steps of a hazard assessment? (pages 3-15 & 3-16)
- 1. Define hazardous materials
- 2. Consider only those chemicals known to be present in the workplace.
- 3. Determine which employees have the potential for being exposed to the chemical.
What are the minimum requirements for container labeling? (pages 3-20 & 3-21)
In general, chemical containers must be labeled with the identity of the contents and appropriate hazard warnings. The name and address of the manufacturer or other responsible party must also be listed. Labels may either appear on the container surface or be attached to the container using tags, tickets, or process sheets, for example. The identifier listed on the label must allow cross-referencing to the MSDS and the inventory.
An existing label on a container brought into the workplace can be removed or altered only if the container is immediately relabeled with the identity and hazard information. Any existing labels should be replaced if they will not remain legible of the useful life of the container.
Who is responsible for preparing and filing MSDS sheets? (pages 3-30)
The HCS requires that chemical manufacturers, importers, and distributors who prepare MSDSs Must ensure that the information listed is up to date and accurate. All employers are required to have an MSDS for each hazardous chemical used in the building or on the property.
What does OSHA requre on an MSDS? (pages 3-32 & 3-33)
- 1. Chemical identity
- 2. Hazardous ingredients
- 3. Physical & chemical characteristics
- 4. Physical hazards
- 5. Reactivity
- 6. Health hazards
- 7. Special precautions and spill & leak cleanup procedures
- 8. Control measures
What must employee training address? (page 3-35)
The HCS requires owners to provide hazard communication training for their employees. This responsibility may be given to the manager, but the owner/employer is ultimately liable. Although this training program does not have to be elaborate or extensive, the OSHA performance standard specifies that employees must receive information and training on all provisions of the HCS. This includes the types of operations in their work areas where hazardous materials are present, together with the location, availability, content, and requirements of the written hazard communication program, list(s) of hazardous materials, and MSDSs.
- In addition, training courses must address the following items:
- -methods that employees can use to detect the presence or release of toxic chemicals in the workplace, information on the visual appearance or odor of hazardsous materials that might be released and on any alarm or warning systems, and the existence of any environmental or medical monitoring systems.
- -the physical and health hazards associated with the chemicals in their work areas, including target organ effects.
- -specific measures to protect employees from the hazards in their work areas, such as engineering controls, safe work-practice guidelines, emergency procedures, and personal protective equipment.
- -specific components of the hazard communication progam, including explanations of the labeling system used in the facility and the methods employees can use to obtain hazardous chemical information
What are the requirements concerning contractor notification? (page 3-38)
All outside contractors must be informed of hazardous materials that their employees may be expoed to while working at facilities controlled by the manager, who should then suggest appropriate protective measures. Information can be conveyed to contractors as follows:
They must have access to MSDSs, which describe normal precautions and emergency procedures. Many companies use HCS software that can be tied to CAD (computer-aided design) floor plans. Contractors can then review MSDS information, chemcical locations, and special procedures fo the work involved.
Define asbestos and explain its characteristics. (pages 4-2 through 4-4)
Asbestos is the name given to a group of naturally occurring fibrous magnesium-mineral silicates. These fibers are strong and flexible and are mined from the earth. Asbestos is unique in that, when it is crushed, it breaks down into smaller and smaller fibers. The needle-like shape of an asbestos fiber allows it to bypass the body's defenses in the respiratory system and to possibly cause medical problems for people exposed to airborne asbestos fibers.
Asbestos comes in several varieties: chrysotile (long, curved, wavy, flexible); amosite (brown or gray, long, straight); crocidolite (blue, small, straight, brittle).
An asbestos product is further categorized as friable or non-friable. A friable material can be crushed, crumbled, or pulverized by hand pressure; a friable material cannot. The friable form is considered the most hazardous. Disturbing friable asbestos more readily creates airborne fibers that can be inhaled or ingested. However, nonfriable material can be rendered friable by mechanical or other means, such as sanding, grinding, cutting, or abrading.
Define the diseases associated with asbestos. (page 4-5)
Generally, asbestos diseases have a latency period of 20-40 years. This is the time between a person's initial exposure to asbestos and the development of adverse health effects.
The primary health effects of asbestos result from inhaling asbestos fibers. A person who smokes and is exposed to airborne asbestos may be 50-80 times more likely to contract lung cancer than is a nonsmoker who is not exposed to asbestos.
Three prominent diseases are associated with asbestos exposure resulting from inhalation of asbestos fibers.
- 1. Asbestosis: A chronic, nonmalignant, progressive, irreversible lung disease that reduces lung capacity.
- 2. Lung Cancer: The uncontroleld growth of abnormal cells that occurs in the lungs. There is a true dose-reponse relationship with this disease; that is, the amount and duratino of exposure affect the likelihood of the disease occurring.
- 3. Mesothelioma: A rare cancer that affeccts the chest or abdominal cavity lining. It is nearly always fatal and can occur with low levels of exposure. Asbestos is the only known cause of this disease.
What is TSI? (page 4-7)
TSI (thermal system insulation): Often an insulating cement or mud used to inhibit heat transfer or prevent condensation on pipes, boilers, tanks, ducts, and oarious other components of hot-water and cold-water systems and HVAC systems.
What are ACMs? (page 4-7)
Asbestos Containing Materials
What are miscellaneous ACMs? (page 4-7)
Miscellaneous ACMs consist mostly of nonfirable asbestos products and materials such as ceiling tiles, floor tiles, roofing felt, Transite pipesand panels, exterior siding, fabrics, and sheetrock/drywall systems.
What is a PACM? (page 4-7)
Presumed Asbestos-Containing Material. Resilient floor coverings, TSI (thermal system insulations), and spray-applied troweled-on sufacing material installed in buildings before 1981. Building owners and managers must presume that these materials are asbestos and treat them as such until inspections and tests by accredited personnel prove otherwise.
Describe the four classes of asbestos work activity. (page 4-8)
The OSHA revision established the following four classes of asbestos work activities:
Class I Activity: Removal of asbestos-containing (or potentially asbestos-containing) TSI (thermal system insulation) and sufacing materials (friable materials).
Class II Activity: Removal of asbestos-containing and/or potentially asbestos-containing materials that are not TSI or a surfacing material (non-friable materials such as floor tiles and sheeting, ACM wallboard, roofing and siding shingles, asbestos cement board, and constructino mastics).
Class III Activity: Repair and maintenance operations, or removal on a small-scale/short-duration basis, wherby damaged asbestos-containing materials and/or TSI are likely to be disturbed, and the disburbed material fits into a 60-inch glove bag.
Class IV Activity: Maintenance, custodial, or janitorial activities during which employees contact but do not disturb asbestos-containing or potentially asbestos-containig material; may involve cleaning dust, waste, and debris contaminated with asbestos dusts that result from Class I, II, and III activities.
What major areas of building management are impacted by asbestos? (pages 4-9 through 4-13)
- -Renovations & Demolition
- -Building Occupant Health Concerns
- -Emergency Disturbances & Exposures
- -Regulatory Compliance
- -Threat of Lawsuits
- -Cost Recovery
- -Buliding Devaluation
- -Tenancy Losses
Explain the testing methodologies used to detect ACM or asbestos fibers in the air. (pages 4-15 and 4-16)
Three primary testing methodologies are commonly used in the detection of bulk ACMs or asbestos fibers in the air. They are phase contrast microscopy, transmission electron microscopy, and polarized light microscopy.
PCM (phase contrast microscopy) is used to measure fibers in air. A significant limitation of PCM is that it measures all types of fibers (asbestos or otherwise) five micrometers or longer that meet a minimum aspect ratio (3:1 length to width). The OSHA exposure standards are based on this test method. PCM testing is readily available, is sometimes performed on site, and is inexpensive.
TEM (transmission electron microscopy) overcomes some of the limitations of PCM and can also be used for bulk material testing. TEM specifically identifies only asbestos fibers and detects even the thinnest and smallest fibers that PCM cannot measure. TEM testing still costs five to ten times more than PCM analysis.
PLM (polarized light microscopy) is the method used for the analysis of bulk samples (samples of building materials) to determine asbestos content. Again, the EPA and OSHA now define ACM as any material containing more than 1% asbestos.
Compare an area sample to a personal sample. (page 4-17)
An area sample differs from a personal sample because it is stationary and it targets a certain voume of air in a certain space. A personal sample, on the other hand, considers worker movement and activity over an eight-hour workday. Area sampling is used for hazard assessments and abatement clearances, whereas personal samples are used to determine exposure relative to the OSHA PEL and to verify the effectiveness of exposure controls.
What is involved in an asbestos audit or inspection? (pages 4-21 through 4-23)
Before any renovation or demolition occurs, an asbestos survey of the work area should be conducted. Auditing or inspecting for asbestos requires several steps. Note that only properly trained and accredited workers should inspect buildings for asbestos-containing materials.
First, documents such as buiding plans and specifications, mechanical drawings, and records should be reviewed. Somtimes the buidling specifications will highlight ACM that would not otherwise be discovered. In addition, accessible areas of the building should be inspected physically. This is akey step toward ensuring accuracy, because specifications may have changed and renovations may not be well documented.
The next step is to idnetify homogenous material types and applications. The building specifications and knowledgeable building personnel may help make this determination.
Bulk samples should be collected and laboratory analysis performed, usually by PLM method. Multiple samples of each homogenous material will be required, depending on the material type.
How must building occupants be notified of asbestos work? (pages 4-28 and 4-29)
Owners should inform employees, tenants, independent contractors, and any other building occupants concerning the location of any ACM or PACM they might disturb. These same parties should be made aware of asbestos abatement activities on the proeprty. The owner is also responsible for notifying the appropriate government agencies when an asbestos abatement project is planned.
- Various methods are used to alert building occupants to the presence of asbestos or the plans for abatement:
- -labeling of ACM (color coding, tagging)
- -warning signs
- -information sessions
- -availability of O&M program
- -written announcements or bulletins
The methodology selected should be consistent and designed to fit the needs of each property. Many properties use work order systems to notify the asbestos coordinator of any asbestos-related work.
What does a routine maintenance blanket on-year notification cover? (page 4-29)
Each year, the asbestos coordinator must notify the EPA of all ACM anticipated to be abated through routine maintenance during that calendar year. The notice will include all individual, small-scale abatement actions that involve less than 260 linear feet or less than 160 square feet of ACM.
This notification requirement will apply if the sum of all such small-scale abatements for the year is expected to exceed these limits. Not covered, however, is any single abatement action that exceeds 260 linear feet or 160 square feet or any demolition projects. Instead, a separate, individual notice must be sumbitted for each such project.
What notification is required for large renovation projects involving more than 260 linear feet / 160 square feet / 35 cubic feet? (page 4-29)
The EPA must be notified if the amount of RACM (regulated asbestos-containing material) to be abated or otherwise disturbed in a facility being renovated is greater than 260 linear feet on pipes, 160 square feet on other facility components, or 35 cubic feet of facility components where the length or area could not be measured previously. Notifications must be postmarked or delivered at least 10 working days before asbestos stripping or mremoval work or other activity begins (such as site preparation that would break up, dislodge, or similarly disturb asbestos material).
What notification is required for a demolition project? (page 4-30)
Demolition is defined as the wrecking or taking out of any load-supporting structural member of a facility, together with any related handling operations or the intentional burning of any facility. The EPA must be notified of lal demolition projects involving ACM. Notification postmark and delivery procedures - and the requiremetns for increased quantities of RACM - are the same as those outlined for renovation proejcts.
According to OSHA, how long must medical records be retained? (page 4-30)
OSHA requires that medical records be retained as long as a worker is employed, plus 30 years. Furthermore, the agency mandates that personal air-monitoring results be kept for 30 years and that trainig records be retained for 1 year after the date of employment. Under OSHA's Records Access Standard (29 CFR 1910.20) and Hazard Communication Standard (29 CFR 1910.200), employers must provide employees with their records of exposure and medical surveillance.
According to OSHA how long must personal air-monitoring results be kept? (page 4-30)
Personal air-monitoring results be kept for 30 years.
How long does OSHA require a compnay to keep training records? (page 4-30)
Training records must be retained for 1 year after the date of employment.
What are the three asbestos abatement techniques? (page 4-35)
Asbestos Removal: Completely removing the ACM. Full engineering controls and regulatory compliance are required.
Encapsulation: Applying a sealant to the ACM. The sealant should bind the asbestos fibers together.
Enclosure: Constructing airtight walls and ceilings around the ACM. The enclosure should reduce the chance of fibers beign released by incidental contact or other types of disturbances.
Name and describe the law regarding disclosure of the presence of lead-based paint. (page 5-2)
The most recent federal legislation - the Residential Lead-Based Paint Hazard Reduction Act of 1992, often referred to as Title X (Ten) - mandates that the presence of lead-based paint be disclosed prior to sale or lease of residential properties, making it an increasingly important factor in property transfers and negotiations..
Why is it important to check paint for lead? (page 5-4)
Of paramount cnocern is the long-standing use of lead in paints. Lead oxides, chromates, and acetate were used as pigments (chemicals that have color or properties that affect color), rust inhibitors, and drying agents prior to and during World War II. In the early 1950s, other pigment materials became more popular, but certain lead compounds were still used. Lead-based paint was regarded as a high-quality produt, widely specified and used by conscientious building owners, architects, and contractors. Red lead primer is used on all types of structural steel to inhibit rust and prevent corrosion. Buildign components requiring weather protection - such as windows, doors, siding, and trim - were often covered with lead-based paint. Before it was phased out in the late 1970s, six million tons of lead-based paint had been applied to houses alone.
How does lead enter the body? (page 5-5)
Lead enters the body in two wasy - ingestion (swallowing) and inhalation (breathing). Ingestion is the major route of exposure for the general population, and inhalation is the major exposure route in occupational settings. The health effects of lead are the same for both methods of exposure, regardless of whether the lead is ingested with food, water, or paint or is inhaled as dust or particles.
Where in the body is most of the lead stored? (page 5-6)
Approximately 95% of the total body burden of lead is in the bone. Because the body uses bone as a semipermanent storage site, it isn ot unusal for lead levels in bone to increase with age. However, metabolic processes, such as those associated with pregnancy and lactation, can increase the amount of lead released from bone.
What are the symptoms of lead poisoning? (page 5-6)
As we have seen, lead can affect the body on many levels, from individual cells to specific organs and systems including the blood, liver, kidneys, brain, nerves, bones, and reproductive system, as well as hearing and speech functions. In rare cases, severe lead poisoning can cause profound mental retardation, convulsions, coma, or even death.
Most people with lead poisoning show no symptoms. when symptoms do occur, they are usually nonspecific and difficult to identify. Symptoms of lead poisonoing can include any of the following: emotional disturbances, slowed intellectual growth, reduced IQ, inability to concentrate, dreaminess, hyperactivity, fatiuge, loss of apetite, abdominal pain, difficulty sleeping, impaired motor ability, clumsiness, and constipation or diarrhea.
When does the amount of lead in the body become unsafe? (page 5-7)
No truly safe body level of lead has been established. Lead levels previously thought safe have recently been shown to cause adverse health effects. the CDC currently defines lead poisoning in children by referring to their standard of 10 micrograms per deciliter. The CDC has repeatedly lowered its standard for the amount of lead in the blood considered excessive. In fact, studies have shown ill effects at blood levels as low as 6 micrograms per deciliter.
But, individual responses to dosages of lead vary widely, making it difficult to determine whether a particular level will cause a particular effect.
Why is blood screening important? (page 5-7)
Because symptoms are often lacking and occur only after lead poisoning is well established, it is important to test at-risk populations and individuals (for example, lead workers) periodically to determine the amount of lead in their blood. Blood screening is a key component of lead poisoning detection and prevention in medical surveillance programs.
When is LBP most dangerous? (page 5-9)
The potential for contamination and exposure form lead-based paint is particularly severe when paint is deteriorating and loos, flaking, or peeling.
What are the sources of lead in air pollution? (page 5-10)
Lead has been most notably used as an anti-knock additive in gasoline. Automobile emissions from leaded gasoline were the largest single source of environmental lead contamination. Before laws were enacted to limit its used, 4-5 million tons of lead were added to gasoline, most of which was released into the air.
Currently, the greatest sources of leaded air pollution are industrial emissions from metal smelters and refineries and ash generated by incinerators.
What are the sources of lead in soil and dust? (page 5-10)
Sources of lead in soil and dust include past automobile emissions, industrial emissions, pesticides, spent casings from shooting ranges, and flaking, chipping, or weathering of paint. If proper precautions are not taken when removing lead-based paints, both the building surfaces and the soil can become seriously contaminated.
What is the source of lead in drinking water? (page 5-11)
Significant amounts of lead are rarely found in public drinking water at its source, but water may become contaminated as it moves trhough the distribution system to and within buildings. Water also may be contaminated by lead leaching from lead pipes or service connectors, from lead-based solder used on cpper pipes, from brass fixtures, or from lead-lined tanks in water coolers.
When is lead found in food? (page 5-12)
Types of food and beverage containers made with lead include pewter, glazed ceramic ware, leaded crystal, and tin cans soldered at the seam with lead (the cans were 98% lead during World War II, when it was estaimated 15% of dietary lead came from food cans). This amount has decreased considerably since solder was removed from domestically produced cans. However, food may become contaminated through lead in water used to prepare foods and as a reulst of lead in air settling on soil where crops are grown, on the crops themselves, and/or on prepared food before it is eaten.
According to the CPSCP's regulations, how much lead can paint contain? (page 5-16)
In 1973, the CPSC (Consumer Product Safety Commission) established a maxium lead content in paint of 0.5% by weight in a dry paint film newly applied; in 1978, CPSC lowered the allowable lead level in paint to 0.06%. Some industrial paints, however, still contain 5-10% lead as a pigment.
What is the lead AL for tap water? (page 5-17)
The AL for tap water is 15 ppb.
How is lead identified and measured? (page 5-17)
Laboratory analysis for lead in paint, air, soil, dust, and water is performed using techniques such as flame or graphite furnace AAS (atomic absorption spectrometry) and ICP (inductively coupled plasma)-atomic emission spectrometry. These two instrumentation methods are commonly used to identify and quantify metals.
XRF (X-Ray Fluorescent) analysis can also e used, which measures the activity of lead electrons activated by a radioactive source. XRF technology was developed as an efficient a d portable method of identifying metals in the mining industry, and it has been recently applied to field identification of lead in dried paint film.
What are the general guidelines for a lead inspection? (page 5-21)
Lead paint inspections should be comprehensive and well defined in both scope and purpose. Depending on the purpose of inspection, all rooms and common areas, both interior and exterior, can be tested. Special attention must be given to movable components such as windows and oors that can generate dust, loose or flaking paint, and other hazardous conditions.
An appropriate sampling protocol that addresses sources of error and provides for statistical reliability should be prepared and approved before the inspection begins. Surfaces should be tested, and the readings, results, and other pertinent information should be recorded on standardized forms. Reports must be thorough and understandable. They should include results for each surface tested, floro plans, standard forms, methodologies used, analytical results, data interpretation, and conclusions.
In some situations such as real estate transactions, lead paint determinations are used. A determination is used only to confirm the presence of lead in a building and should not be confused with a full inspection. Under certain state regulations and legal requirements, reporting and notification procedures must be followed if lead paint hazards are identified.
What is personal exposure monitoring? (page 5-22)
Personal exposure monitoring is required by OSHA in both the General Industry Standard and the Construction Standard for certain work activities and when there is reason to expect that lead exposures could exceed the OSHA PEL. PErsonal exposure monitoring is used to determine the airborne lead concentrations in a worker's breathing zone to establish exposure levels to ensure that hazard controls are adequate for the work activity.
What are the limitations of environmental samples and air test results? (page 5-23)
Envirionmental area samples can provide only limited results because they reveal just those lead levels present under the specific conditions during the sampling. Since episodes involving releases of lead into the air are often transient, air test results should not be relied upon as the only indicator of safety. According to OSHA standards, environmental area sampling results cannot be used to determine employee exposure levels or to choose respiratory protection and engineering controls.
Why are O&M inspections and assessments important? (page 5-28)
Who must be identified in an O&M program? (page 5-28)
What are the employee training requirements in workplaces where there is a potential for asbestos exposure? (pages 5-30 and 5-31)
According to those standard, each employer who has a workpalce in which there is apotential exposure to airborne lead at or above the action level or for whom the possibility of skin or eye irritation exists must institute a training program. Training is alos required as an interim protective measure for certain activities conducted under construction standards. The training program shall be repeated at least annually for applicable employees.
- Training shall include, at a minimum, the following:
- -the contents of the standard and its appendixes
- -the specific nature of the OSHA operations that could result in exposure to lead above the action level.
- -the purpose, proper selection, fitting, use, and limitations of respirators
- -the purpose and a description of the medical surveillance program and the medical removal protection program, including information conerning the adverse health effects associated with excessive exposure to lead (with particular attention to the adverse reproduction effeccts on both males and females)
- -the engineering controls and work practices assocaited with the employee's job assignment
- -the contents of any compliance plan in effect
- -instructions to employees that chelating agents should not routinely be used to remove lead from their bodies and should not be used at all except under the direction of a licensed physician.
What is the public's role in lead management? (page 5-33)
The communication of lead hazards to tenants could be vital to prevent potential eposure. For example, if lead-based paint has been identified within a tenant's space, then the prudent building owner or manager should notify, in writing, the tenants who will occupy the area of the presence of LBP and the precautions to take when performing any alterations such as installing electrical wall fixtures or cutting, sawing, or sanding interior or exteriof painted surfaces.
What is a lead emergency situation? (page 5-33)
- An emergency situation is an occurrence that would cause an immediate increas in airborne fiber levels because of the distrubance of lead-based paint, which could lead to contamination of the building environment. Typical occurrences that might represent an emergency situation are:
- -major water damage from roof leakage, pipe rupture, or other means
- -construction procedures causing excessive vibration, such as coring, jack hammering, or vibrations from other mechanical construction devices
- -improperly planned or executed renovation or remodeling activities
- -earthquake, structural failure, or other catastrophic building movements.
What occurrences can cause a lead emergency situation? (page 5-33)
- -major water damage from roofl eakage, pipe rupture, or other means
- -construction procedures causing excessive vibration, such as coring, jack hammering, or vibrations from other mechanical construction devices
- -improperly planned or executed renovation or remodeling activities
- -earthquake, structural failure, or other catastrphic building movements
Explain the requirements for record keeping. (page 5-34)
The building owner or manager is required to keep all records of exposure monitoring for airborne lead. These records must include the name and job classification of employees measured, details of the sampling and analytical techniques, the results of this sampling,a nd the type of respiratory protection being worn by the person sampled. The building owner or manager is also required to keep all records of biological monitoring and medical exam,ination results. These must include the names of the employees, the physician's written opinion, and a copy o fthe reuslts of the examination. All of the above kinds of records must be kept for 40 years, or for at least 20 years after employee termination, whichever is longer.
What is involved in the removal and replacement of lead and products containing lead? (page 5-35)
The complete removal and replacement of lead-containing building components is sometimes done during building renovations. Windows, doors, and trim are typical components that are removed, and new energy-efficient windows are often installed as part of the project. Aesthetics, compatibility with existing components, and historical preservation must all be considered.
Removal and replacement does require containment and engineering controls, and it may generate substantial quantities of hazardous solid waste. Many de-leading contractors are devising waste reduction systems that can separate lead from building components and thereby reduce the amount of hazardous waste originating at the work site.
When covering, what are the surface condition requirements? (page 5-36)
Surfaces should be able to fully suport the covering. In addition, they must be properly prepared before they are covered; this is achieved by removing any loose, flaking paint and repairing any damage. Coverings must be durable, well attached, and thoroughly sealed so that lead dust or debris cannot be impacted or escape from behind the enclosure.
What is encapsulation? (page 5-37)
An encapsulant is broadly defined as a material that will forma durable coating or covering when applied to lead-painted surfaces and components, thus encasulating them. More specifically, and separate frmo the definition of covering, encapsulants are basiclaly sealants and coatings that can be applied to a number of different types and classifications of surfaces and substrates.
What is ergonomics? (page 6-2)
Ergonomics is the science of understanding the human factors requirements of work demands that may result in work-related illnesses or injuries. The goal of ergonomics is to match the job to the worker, not make the worker fit the job beyond his or her capacity.
When can an RSI occur? (page 6-2)
A mismatch between the physical requirements of the job and the physical capacity of the worker can result in RSIs (repeptitive stress injuries).
What is a CTD? (pages 6-2 and 6-8)
A CTD is a cumulative trauma disorder. This refers to any of several physical problems, including RSIs (repetitive stress injuries), that can result from repetition or overuse.
List the conditions that can create or indicate stress. (pages 6-2 and 6-4)
Repetition of the same motion throughout the workday can overuse muscle groups. Awkward postures create strain, particularly if the work is long in duration. Excessive force requirements can create sprains for workers who must repeatedly lift heavy objects. In addtision, any combination of awkward postures, repetition, excessive force, long duration, and vibration can increase risk of RSIs.
Ergonomic Stressors: Repetition, Posture, Direct Pressure, Vibration, and Temperature Extremes.
What is OSHA's ergonomic standard? (pages 6-6 and 6-7)
On February 19, 1999, OSHA released a draft standard that was to require any employer who reported even one type of RSI that led to medical intervention or lost work time to set up a comprehensive ergonomics program. Given the outrcy against that draft standard, it may be some time before a standard is ever promulgated. Currently, this agency is planning to develop comprehensive ergonomic guidelines for each industry.
- Until such time as an ergonomics standard is enacted, OSHA does have the ability to assess penalties for RSIs under the General Duty Clause, Section 5A, of the Occupational Health and Safety Act of 1970 that states:
- -Each employer shall furnish each employee with a place of employment that is free from the recognized hazards that may cause or are likely to cause death or serious harm.
- -Each employee shall comply with the Occupational Safety and Health Stnadards and all rules, regulations and orders pursuant to the act that are applicable to his or her actions or conduct.
What are the ergonomic symptoms most common among office workers? (page 6-11)
Initial complaints often include shoulder pain and upper body fatigue, arm and hand discomfort, and eyestrain and neckstrain.
How can property and facility managers identify and prevent ergonomic-related injuries? (pages 6-12 and 6-13)
Building managers should assess the health and safety of their personnel in "at risk" jobs, such as the engineering and custodial staff. Managers should likewise monitor the ergonomic-related conditions - such as lighting and HVAC - that are under the direct control of building systems operators.
The following measures are recommended to help property and facility managers identify and prevent ergonomics-related injuries.
- -Discuss reports of injuries or accidents with each tenant and find out whether there is any evidence of ergonomic problems. Check the OSHA 300 injury/illness logs posted by each employer.
- -Inventory the activities and equipment assigned to eacdh staff, and develop a chart to show workers' activity and intensity levels (posture, force, repetition, and duration) and risk. Have a safety/ergonomic professional evaluate the chart to look for ergonomic risks and recommended ways to prevent them.
- -Design and lay out work spaces for safe and efficient material transfer. For example, all material delivered to the workplace should be placed at hip height. To reduce the likelihood of ergonomics-related injuries, material should be pushed or pulled rather than lifted or lowered. Workers who do not lift and lower material should keep the material as close to and as much in front of the body as possible, avoiding twiting and bending motions. Provide appropriate material handling suports (dolly, forklift, carts, baskets).
- -Allow sufficient room for all required tasks. Set up tool operation/work areas with a wide area of mobility. Clearly, you must consider how machines will be operated. Controls operated by hand or foot should be designed to maximize overextending the arms or legs. Those controls used most frequently should be located so they are the easiest to reach and operate.
- -Prescreen workers for strength, agility, and dexterity to ensure that only those who are physically capable of manual material handling are assigned to this task. Furthermore, the material must be light (< 20 popunds) and compact enough (18x18x18 inches) to be handled safely and efficiently. If the amount of material cannot be reduced sufficiently, equipment should be used to move the load mechanically.
- -Assess whether the workers have modified tools to determine if they are well suited to a particular job. Customized grips, makeshift padding, and tool workstations wear are signs of potential problems.
- -Purchase toosl well suited to the job, especially those designed to minimize such wrist movements as rotating or bending. Many tools come with padded grips and other design improvemetns. For example, upgrade to battery-powered screwdrivers for jobs requiring frequent screwdriver use.
- -Train workers to "work smart"; verify that tools are used correctly and that workers know how to avoid or prevent injury.
Explain workstation design and layout. (pages 6-15 and 6-16)
Ergonomics assesses worker needs to reduce the distraction of discomfort. When designing a comfortable and ergonomically sound workstation, four important evaluative steps should be taken.
- 1. Review job descriptions to determine the competencies (knowledge, psychology, biomechanics, and sensory, quality, safety) required to work risks and demands.
- 2. Inventory the tasks that personnel perform in the work environment.
- 3. Categorize each task into a risk cateogry that indicates the potential for injury while performing that task.
- 4. Identify all high-intensity, repetitive tasks and all tasks that may be infrequent but could c ause ergonomic stress.
The degree of worker safety and the lack of stress caused by workplace equipment directly depend on the extent to which adjustability and flexibility have been incorporated into the design.
What is the key factor to consider when determining the type of lighting to use? (page 6-20)
The type of lighting best suited to an office depends on the task being performed. Employees who work on reqports laid out on a desktop need lighting that provides adequate contrast from the work surface without creating glare or excess brightness. On the other hand, a person working with an illuminated computer monitor that is essentially perpendicular to the table or desktop needs minimal bright lighting.
The impact of interior finishing on lighting is equally important. Bright, glossy interior surfaces, such as white walls, reflect light, whereas dark, matte finishes tend to create more shadows and may diminsh the available lighting. Flooring material sshould be selected to reflect 15-20% of the light; walls with a matte finish should reflect about 50% of the light.
Windows can also cause problems, especially if th esun shines directly in and creates glare on computer monitors. Glare in any form will increase employee stress and eyestrain. Facing workers directly toward or away from windows, without providng blinds or shades, is likely to cause problems. For these reasons, computer users should be oriented toward a wall.
What are the benefits of using an ergonomics program? (pages 6-21 and 6-22)
- The direct benefits of an ergonomics program are:
- -reduced occupational illness and injury
- -reduced number of lost workdays
- -reduced number of workers' compensation claims
- -reduced premium payments for workers' compensation insurance
- -reduced number of complaints of discomfort
- -reduced instances of eyestrain
- -reduced incidents of localized pain
- The indirect benefits of an ergonomics program include
- Effects on produtivity:
- -projects are completed
- -client deadlines do not lapse
- -client relations stay positive
- -workers are more productive
- Effects on cost:
- -The cost of prodcing a piece of work does not increase because there isn't a need to replace the previous worker and train a new one.
- -Insurance costs do not go up.
- -Regulatory liability is reduced.
What should a written ergonomics program include? (page 6-24)
Mission Statement: Defines resources, policies, and procedures for meeting your objectives.
Lines of Responsibility: Identifies the functions and responsibilities of managers, administrators, and other employees.
Program Implementation: Involves creating timelines, assigning tasks, and budgeting for anticipated expenses.
Why are work/rest cycles important? (page 6-28)
One proven method of hazard engineering is the establishment of work/rest cycles. Work/rest cycles should be presented as an interval during which an employee stops a repetitive or stressful activity to stretch or perform other work-related activiteies. The important thing is to recognize that taking a break from a potentially stressful activity is a key part of avoiding injury.
What is ASHRAE's definition of IAQ? (page 7-3)
ASHRAE (the American Society of Heating, Refrigerating, and Air-Conditioning Engineers) defines IAQ as "a function of the outside air quality, the design of the inside spaces and the ventilation air system, the way in which the HVAC system is operated and maintained, the presence of indoor sources of contaminants, and the strength of such sources."
What is ASHRAE's definition of acceptable IAQ? (page 7-4)
In Standard 62-2001, Ventilation for Acceptable Indoor Air Quality, ASHRAE defines acceptable IAQ. ASHRAE's definition has two parts.
1. "The air can be considered acceptably free of annoying contaminnts if 80% of a panel of at least twenty untrained observers deems the air to be objectionable under representative conditions of use and occupancy."
This part of the definition covers annoying conaminants such as odors, temperature extremes, uncomfortable relative humidity, and substances that irritate the senses. It does not apply to other harmful contaminants that occupants cannot readily detect (for example, carbon monoxide, volatile organics, and radon.)
2. "No known contaminants at harmful concentrations as determined by cognizant authorities."
This part of the definition deals with other contaminants such as carbon monoxide or radon that could harm building occupants. These contaminants may not be identified unless complaints generate an overall air-quality study or the building is classified as producing SBS or BRI.
Why is IAQ important to business? (page 7-5)
It is estimated that businesses lose billions of dollars every year as a result of poor IAQ, although much of this loss is never identified as stemming from IAQ problems. This loss is attributed to poor productivity, performance, and attitude, as well as associated lost work time.
How is air contamination usually detected? (page 7-10)
The nose, sinuses, and olfactory organs can detect small concentrations of odors that could indicate problems. In facdt, our olfactory senses are typically the first indicator that "something isn't right." Odors can be simply unpleasant or can indicate a toxic exposure. The sensitive membranes of the olfactory organs are also physically affected by lower humidity levels or increased quantities of dust.
Closely associated with the sense of smell is taste. People exposed to some materials in the air can actually taste them. This strongly suggests the presence of airborne contaminants and generally indicates a fairly high airborne concentration.
The skin is one major area in which we interact with our environment. Irritants, allergens, and temperature and humidity extremes can all cause undesirable conditions. Our skin can react to contaminants by generating rashes, itching, redness, or soreness. In low humidity environments, skin can become dry and develop cracks and fissures.
Excessive amounts of dust, allergens, and dry air can all lead to eye irritation. In addition, the ears and eustachian tubes are affected in many of the same ways as the sinuses, although they are usually affected by higher concentrations of a substance.
What are systemic effects? (page 7-12)
Systemic effects are those that cannot be isolated to a single organ or group of organs. A good example of a systemic poison is a pesticide, which can damage the lung tissue, central nervous system, and liver. Systemic effects can also be manifested at a site other than the exposure site.
What is sensitization? (page 7-12)
The development of an adverse, allergic-type response to a contaminant at even low exposures is known as sensitization.
What are allergens? (page 7-12)
Allergens are biological materials that contain proteins and other substances that elicit a response from the body, usually on the sensitive membranes where the body contacts the environment (for example, the eyes, nose, sinuses, throat, and lungs). People who are allergic to a contaminant in their building usually experience relief from their symptoms when they leave the structure.
What is penicillium? (page 7-12)
A common cause of an allergic response associated with HVAC systems is penicillium. This mold grows in the cool, dark, moist environment found in interior-lined air-conditioning ductwork. the mold releases spores and spreads throughout the strcture. Penicillium spores are spread throughout the HVAC system and building every time the HVAC cycles.
What are hypersensitivity diseases? (page 7-12)
Hypersensitivity diseases are characterized by allergic responses to antigens (substances such as toxins that can trigger an immune response). Those diseases most clearly associated with sensitization are asthma, rhinitis, and hypersensitivity pneumonitis.
How do you define a sick building? (page 7-14)
Although there are many definitions of SBS (sick building syndrome), a consensus of IAQ professionals and NIOSH (National Institute for Occupational Safety and Health) and EPA guidance indicates that a building can be considered "sick" when all of the following three statements are true:
1. A significant number (some investigators use a figure of at least 20%) of building occupants report or experience health effects such as, but certainly not limited to, fatigue, muscle pain, headache, eye irritation, sore throat, cough, or general sensory irritation.
2. There is no obvious contaminant source or an easily recognizable contaminant pathway.
3. The onset of the health symptoms is associated with the time spent inside the building, and relief of those symptoms is associated with the time spent outside the building.
How does the HVAC system affect IAQ? (pages 7-16 and 7-17)
The HVAC system is central to IAQ. It brings outdoor air into a building; filters and distributes outdoor and recirculated air into a building; controls temperature and humidity levels; provides ventilation; and handles such other factors as noise and vibration. The HVAC system controls the building environment; therefore, it can be both a cause of and a solution to IAQ problems.
How much outdoor air does ASHRAE recommend per person? (page 7-17)
The current ASHRAE standard recommends 20 cfm (cubic feet per minute) of outdoor air per person versus the previously recommended 5 cfm per person for office spaces.
What conditions lead to contamination in the HVAC system? (page 7-17)
The HVAC system can harbor damp or wet areas because unit pans drain poorly or malfunctioning humidifiers introduce too much momisture into the ductwork. As a result, spore, fungal, viral, or bacterial contaminants can enter the ventilation air. Dirty heating or cooling coils and dirty filters are other sources of contaminants. Chemcials used for coil cleaning or pest control may also contain contaminants. HVAC systems destroy and remove negative ions from indoor air, which can affect workers' feeling of well-being and thus adversely affect their productivity and morale. In addition, asbestos and fiberglass on ductwork or piping can enter the supply air distribution system and be a source of contamination.
The system can also take in contaminated air from outside sources.
How do office materials and furnishings affect IAQ? (page 7-18)
Building materials include such office materials and furnishings as desks, shelves, chairs, partitions, carpeting, flooring, and drapes. The release of formaldehyde gases (or off-gassing) from these materials has long been recognized, but the effects of other VOCs (volatile organic compounds) are now being evaluated. Besides VOCs, office furnishings absorb biological toxic contaminants, tobacco smoke, and vapors from other sources such as paints or maintenance and cleaning chemicals. This plays a major role in levels of odors, dust, and bacteria and in evaluating contaminant levels and in mitigation strategies.
How do wood products affect IAQ? (pages 7-18 and 7-19)
Many wood products are held together with formaldehyde-containing resins, glues, and adhesives. Particl;eboard has been found to contain 1-6% free formaldehyde by weight. It also emits other significant VOCs such as acetone and benzene. Another example is urea formaldehyde resins, which have 10-20 times the off-gassing potential of phenol-formaldehyde resins.
Why are stains, coatings, and cleaners IAQ concerns? (page 7-19)
Over 65,000 chemicals are in commercial use today, and 80% of them have unknown health effects. Stains, coatings, and cleaners that contain these chemicals are applied to furniture, cabinets, woodwork, and tile. These products contain a myriad of VOCs. Other furnishings can absorb the airborne VOCs, which can later be off-gassed throughout the building air.
What is the predominate VOC in draperies and wall coverings? (page 7-19)
Formaldehyde is the predominant VOC released from draperies and wall coverings.
Why is upholstered furniture an IAQ concern? (page 7-19)
Open-celled foam (for exammple, polyurethane foam), found predominantly in upholstered furniture, often emits enough TDI (toluene disocyanate) to cause respiratory difficulties. Formaldehyde and phenol can also be significant off-gassed products.
Why are modular partitions an IAQ concern? (page 7-19)
Office partitions, which often surround occupants, can emit multiple VOCs; formaldehyde is the most recognized, but TDI may also be present if the partitions contain open-celled foram. Thse factors, coupled with a large surface area and high off-gassing rates, make partitions a potential cause of employee complaints and IAQ problems. Another problem arises because methylene chloride solvents are often used to clean the panels before they are shipped. The indoor air is then contaminated with this VOC as the panels are installed. Furthermore, modular partitions often obstruct the distribution of air to occupants, allowing off-gassed materials to accumulate in individual work areas.
Why are flooring materials an IAQ concern? (page 7-20)
Carpeting releases VOCs as a result of both its chemical treatment for stain resistance and its glue-based backer material. These adhesives used to install carpets or floor tiles or coverings - and the required sealers and polish - also introduce VOCs into the building air.
Why is office equipment an IAQ concern? (page 7-20)
Office equipment includes laser printers and typewriters, as well as facsimile, copying, and blueprint machines. Thes types of equipment may emit VOCs, hydrocarbons, and ozone. Dry-process photocopying also emits respirable suspended particulates; wet-process photocopying machines rely on VOC-based solvents for toners, dispersants, and developers. Thsee VOCs are also released into the building air. Furthermore, heavy copying use in low ventilation-rate spaces increases the VOC concentrations that occupants are expoed to during the workday. Office equipment also generates heat, and colling fans (such as those found in computers) contribute to the recirculation of airborne contaminants.
What outdoor sources contribute to poor IAQ? (pages 7-20 and 7-21)
Often overlooked, outdoor sources can be significant contributors to IAQ. This includes outdoor air, soil gases, moisture, and standing water. Air drawn from outdoors can contain odors, pollen, dust, fungal spores, asbestos, industrial pollutants, vehicle exhaust, ozone, and other contaminants.
What building activities are sources of poor IAQ? (pages 7-22 through 7-24)
Building occupants, maintenance staff, and contractors can also contaminate the indoor environment. Their actions produce odors and introduce additional sources of chemicals into the building air. Included are activities such as cleaning, printing, food preparation, smoking, appolying cosmetics and colognes, human waste functions, general maintenance and repair, renovation, and pest control. This is especially a concern if the occupied space has not been carefully planned to effectively ventilate any potential contaminants based on the anticipated use of the area. Many tenants perform functions that generate airborne contaminants.
What federal agency controls IAQ regulations and guidelines? (page 7-41)
OSHA will investigate building IAQ complaints from workers and has established guidelines for IAQ investigations.
What are the most common and most extensively regulated air pollutants? (page 8-4)
Criteria air pollutants are those substances for which a NAAQS has been established as provided for in the 1970 CAA Amendments and subsequent standards. In general, the criteria pollutants are the most common, and the most extensively regulated air pollutants. The criteria air pollutants include the following:
- 1. ozone
- 2. nitrogen dioxide (essentially synonymous with nitrogen oxides or oxides of nitrogen)
- 3. sulfur dioxide
- 4. PM10 (particulate matter < 10 micrometers)
- 5. PM2.5 (particulate matter < 2.5 micrometers)
- 6. carbon monoxide
- 7. lead
What is ozone? (page 8-4)
Ozone is formed in the atmosphere under certain conditions, and is created by the emissions of hydrocarbons (also referred to as VOCs) and oxides of nitrogetn, which together are referred to as ozone precursers. Its principal sources are from the manufacture of solvents, automobiles, and boilers. Commercial building sources include paints and coatings for buildings and heating plant boilers. Impacts on commercial buildings include the degradation of paints and textiles, deterioration of rubber, and general oxidization of materials.
What dictates nitrogen dioxide emission rules for boilers? (page 8-6)
Whether a boiler is subject to rules on nitrogen dioxide emissions usually depends on either its rated fuel capacity or its annual emissions, or both. Rules applicable to specific boilers ore other equipment in commercial buildings can be determined as part of an emissions inventory.
What is sulfur dioxide? (page 8-6)
Nitrogen dioxide and sulfur dioxide develop from fuel combustion in boilers. Sulfur dioxide is not a major concern for gas burning; it is generated almost exclusively by coal-fired or oil-fired boilers. Sulfur dioxide is also considered to accelerate corrosion of ferrous and nonferrous metals.
Why are PM10 and PM2.5 important? (page 8-7)
Both PM10 and PM2.5 are a concern for human health. Regulation of PM2.5 is intended to focus more precisely on human effects, as these fine particles can penetrate more deeply into the human respiratory system. However, great uncertainty exists as tot he magnitude and root causes of health effects observed to be associted with particulates. The primary impact of particulates for building management is in the form of soiling of buildings and decorative materials, as well as clothing.
What is the CAA? (page 8-11)
The Clean Air Act (CAA) is the primary basis for federal regulation of air pollutants. CAA programs vary widely, from attainment of ambient air quality standards to introducing market-based controls for sulfur dioxide as a precurser to acid rain to promoting research on air quality impacts on the Great Lakes.
Originally, the central goal of the CAA was to identify criteria pollution levels and to ensure that they were achieved nationwide. The act required a mixture of federal and state programs. The EPA was directed to set emission standards and require certain permits. The EPA is also responsible for identifying criteria pollutants and setting the concentrations that are the "criteria" of clean air. But the states, or sometimes countries or other regions, were responsible for regulating local industries to meet the EPA's ambient standards. As such, each state's regulations are different.
Who regulates local industries? (page 8-11)
States, or sometimes the counties or other regions, are responsible for regulating local industries to meet the EPA's ambient standards. As such, each state's regulations are different.
Who is covered under air pollution emission standards? (page 8-13)
Most emissions standards are targeted at industry. However, in some cases tenants of commercial buildings can be affected. For example, dry cleaners are subject to a MACT (maximum achievable control technology) standard. Commercial establishments such as gas stations, small printers, automobile repair shops, and others could be affected.
What constitutes a major source (requiring an air permit)? (page 8-13)
The emission level that defines a major source varies by the permit and pollutant. Depending on the industry, criteria pollutant emissions of 250 (attainment area)would qualify a facility as a major source for PSD. A facility is major for Title V with criteria pollutant emissions of 100 ton/year, or lower emissions of VOCs or nitrogen dioxide in ozone non-attainment areas. A source of hazardous air pollutants is major if it emits 25 tons/year of total hazardous air pollutants or 10 tons/year of any one hazardous air pollutant.
What is the RMP? (page 8-14)
Risk Management Program. Federal accidntal release prevention regulations, including the preparation of risk management plans, apply to those facilities that store toxic of flammable chemicals that are listed in the RMP (risk management program) - in quantities greater than specified in the list (40 CFR, Part 68.130)
What is the general intent of CFC regulations? (pages 8-16 and 8-17)
Under Title VI of the CAA Amendments of 1990, massive changes are required for refrigeration and air-conditioning equipment that uses CFCs. Production and importation of CFCs were banned as of January 1, 1996. CFCs are still available for maintenance and refrigerant replacement, however, because those manufactured or imported before January 1, 1996 can continue to be recycled or reclaimed for future use.
- Other EPA regulations affect the procedures and personnel for maintenance of CFC-based systems. Specific requirements apply regarding:
- -the amount of refrigerant that must be recovered during maintenance
- -procuedures for recycling (on site) and reclaiming CFCs to industry standards of purity
- -leak repair in commercial equipment
- -certifications of both technicians performing specific maintenance and equipment used to recycle or recover CFCs
- -record keeping for refrigerant added to commercial appliances, service records, technician certifications, CFC and HCFC purchase records, and CFC reclamation
Other regulations have established phaseout dates for some HCFC replacement refrigerants, including the current most popular replacements for the CFCs subject to the 1996 production ban. CRC regulations continue to evolve as refrigerants are being analyzed for global warming (greenhouse gas) effects as well as ozone depletion.
What are the requirements for air, construction, and operating permits? (pages 8-20 and 8-21)
The air permit is the central regulatory enforcement tool for air quality management. A variety of emission sources, including boilers, paint spray booths, industrial processes, and sometimes minor activities such as metal parts washers in maintenance shops, require a regulatory agency to approve the designs and specifications for the equipment and issue a construction permit before "construction" begins.
In many areas, equipment that requires a construction permit before it is installed also requires an operating permit before, or shortly after, the equipment begins normal operation. A facility that is a major source under federal regulations may require a Federal Operating Permit, sometimes referred to as a "Title V" permit because it is required under Title V of the CAA Amendments of 1990. If required, a Title V permit covers all air emission activities at the facility.
Why would a facility manager be required to keep records and/or to report important emissions or other activities? (page 8-21)
Many facilities that have air permits and/or equipment subject to air regulations must conduct specific record keeping and/or reporting of their emissions or other activities. For a boiler, you may need to document fuel burned and calculate emissions based on emission factors. For a paint spray booth, you may need to record the total quantity of paint and thinner used throughout the year and the quantity of VOCs contained in each paint. Record-keeping and reporting requirements may be specified in a permit, if you have one, or may be in a separate regulation. It is your responsibility to know whether your air emissions and/or equipement require you to keep records and/or to file reports.
What are the penalties for failure to comply with permit and record-keeping requirements? (pages 8-21 and 8-22)
A building owner or manager who does not obtain permits, conduct testing, keep records, and/or file reports under one or more air regulations can be subject to fines. Federally enforceable requirements, which often include requirements imposed by states based on federal requirements, carry maximum fines of up to $25,000 per day, per violation. While actual fines may be much lower or waived entirely for minor violations, any violation can result in an expensive fine.
In addition to fines, the EPA uses other types of penalties and deterrents. Under the 1990 CAA Amendments, if you knowningly violate one or more regulations, you can be subject to criminal penalties, including fines and/or imprisonment.
Fully explain an air emission inventory. (pages 8-23 through 8-25)
The air emission inventory identifies a facility's processes that emit pollutants into the ambient air. It also establishes some basis for estimating amounts of those emissions. The regulatory review compares your specific equipment with the wide range of regulations that could be applicable. These two tasks are related, because the requirements will dictate how much detail is needed in the inventory.
If no emissions inventory exists from a past analysis, the most efficient approach is usually to divide the emissions inventory into a source inventory and an emissions estimate. Conducting the regulatory review after the source emissions inventory and before the emissions estimate can save time by identifying what information is and is not needed about your equipment before you collect the data and calculate the emissions.
- For the source inventory, survey the entire facility to identify all activities taht could produce air pollution. If you have a heating plant, boilers will be the largest and most obvious source. Identify other sources of criteria pollutants (including VOCs) and hazardous air pollutants. Sources might include:
- -boilers and other heaters
- -generators, including emergency generators
- -parking garages
- -paint spray booths and other surface coating operations (except painting the building or its architectural features)
- -storage tanks for fuel, solvents, or chemicals
- -parts washing
- -woodworking equipment, with or without dust collectors
- -laboratory hoods
- -commercial machines, such as printing presses
- -any equipment for whichyou already have an air permit
Include activities vented directly to the outdoor air and those that may not be
What are the water treatment/distribution municipalities and authorities responsible for? (page 9-3)
Municipalities and authorities construct, operate, and maintain the treatment/distribution systems that supply customers in their service area. These agencies are resonsible for providing water that is safe to drink at appropriate flow rates and pressures for their customers within the service area.
What is a common groundwater concern? (page 9-3)
Groundwater supplied from wells typically contains significant amounts of dissolved minerals. An abundance of the dissolved minerals calcium and magnesium makes the water "hard water." Hard water can cause scaling in boilers.
Name some typical surface water sources. (page 9-3)
Lakes or rivers are common surface water sources.
What are some common surface water issues? (page 9-3)
Surface water supplies, such as those from lakes or rivers, normally have less hardness than groundwater but are generally more susceptible to seasonal changes that may affect water quality. Seasonal changes typically do not affect boilers or other building systems, but they may cause taste, odor, and/or high turbidity (being thick or opaque with, or as if with, roiled sediment) problems.
What are the components of a plumbing distribution system? (page 9-4)
Exterior wall distribution systems generally consist of buried piping, which branches out to smaller pipes that provide the water to buildings. The larger pipes are referred to as mains, and the smaller branch pipes are called laterals. This distribution system has valves located at strategic points that can be accessed from the surface. These valves are typically located so that the wtaer can be shut off during maintenance activities. Additionally, fire hydrants may be connected to the water mains.
An interior water distribution system is referred to as plubming. Plumbing lines typically run through floor and wall cavities to their points of use, such as sinks, toilets, manufacturing processes, fire system, boilers, et cetera. Again, the pipes branch to smaller pipies, and valves are placed to isolate certain segments of piing for maintenance purposes.
Fixtures are faucets, toilets, hose connections, and other devices used to control the flow and use of water. Interior plumbing may also supply water for irrigation such as lawn sprinkling. These systms typically have automted controls that open and close water valves at preset times.
For water supply from municipal sources, meters are installed and maintained by the water purveyor. Water meters are typically located inside buidings where the water supply enters the building. These meters are periodically read to determine the basis for billing.
Where the possibility exists of potable water becoming contaminated by non-potable water, backflow preventers are used. These are safety devices that contain two check valves and an atmospheric vent. They can be applied to boiler feed lines, domestic city water connections, and other appliances required by local plumbing codes to prevent backflow when the pressure of a supply line falls below the system pressure.
When water is treated, what is removed? (pages 9-4 and 9-5)
Treatment of raw ater may be required to remove any of a variety of compounds that cause objectionable taste and odors, or minerals that may affect boiler operation (scaling). In addition, some manufacturing processes require ultrapure water, which necessitates removing trace amounjts of certain compounds.
The groundwater in some areas contains sulfur compounds that cause objectionable odors but have little or no health impact. Groundwater that is high in iron may cause staining of fixtures and laundered clothes. Water supplies with low pH (a measure of acidity or alkalinity) can cause corrosion of the plumbing and fixtures. These water quality issues also require treatment, even though they have little health impact.
In what areas or processes can water be conserved and reused? (pages 9-5 and 9-6)
To determine how water may be conserved, each use must be examined separately. Then, a plan to optimize and/or minimize water use can be developed for each use.
It should be noted that fixtures that suffer leaks, such as sink faucets and toilets, are often a primary cause of wasted water. In addition, external water lines and valves may also leak. This can be determined by pressure testing lines and measuring the leakage.
In certain areas, irrigation is a major water use. The type of landscaping employed around a building or facility can be altered to minimize such irrigation water consumption.
In some areas it is economical to reuse wastewater. The methods for water reuse are beyond the scope of this chapter; however, wastewater can be rused for water supplied to toilets, cooling towers, non-potable systems, and irrigation uses (if not softened).
What is process wastewater? (page 9-6)
Process wastewater is the water that comes in contact with and is part of the production process used to convert raw materials into manufactured goods (the manufactring process). It is typically generated in pulp and paper mills, electronic parts manufactruting, metal forging, mining, electroplating, leather tanning and finishing, textile mills, and petroleum refining before being discharged to a municipal sewer system. Small processes in office buildings or commercial facilities can also generate process wastewater.
What is a direct point source discharge? (page 9-6)
A process wastewater discharge to a lake or river, or to the groundwater (subsurface), is considered a direct point source dischargeand requires a permit from the EPA or state or other regulatory agency. Typically, wastewater being directly discharged will require treatement.
What is an indirect point source discharge? (Page 9-7)
Process wastewater discharged to a municipal sewer system is considered an indirect point source discharge and does not require an NPDES (National Pollutant Discharge Elimination System) permit, but such discharges are regulated by state and local pretreatment standards. This type of wastewater must be pretreated if the contaminant levels are higher than those capable of being handled at the municipal facility.
What is sanitary wastewater? (page 9-7)
Sanitary wastewater includes all flows generated from a building or facility that result from the use of water, excluding process wastewater. Gray water is associated with kitchens, baths, and showers, whereas black water is associated with toilet wastewater only. In most buidings, gray water and black water are collected together.
What is stormwater management? (page 9-10)
Stormwater management refers to collecting precipitation and routing it to areas that will not create a nuisance for an owner's or manager's facility, neighboring properties, or the environment.
How is a stormwater system designed? (page 9-11)
The design of a stormwater system starts with a determination of an appropriate design storm, that is, the severest storm likely to occur within a given time period for the area. Storms are rated according to expected intervals of occurrence; for example, a "10-year" storm is expected to occur once in a decated.
In designing the stormwater system, the engineer bases his or her calculations on the maximum amount of water (peak flow) that would result from the given design storm. For small drainage areas, known as drainage basins or watersheds, water flow is commonly found by a numerical equation (the so-called natural method), based on the design storms' rainfall-duration-intensity relationships. These relationships have been established for each region of the country and are available through state agencies.
The storm drainage systems for most developed properties are based on a 10-year system; therefore, they should adequately remove water from storms of this frequency. If a more intense storm does occur, ponds may be created in open areas and parking lots. However, because of the low rate of occurrence of this type of situation, presence of such ponds may be considered acceptable. If more intenste storms would result in flooding and property damage, the engineer would design the system to handle these types of flows.
What are detention ponds? (page 9-12)
Many properties developed within the last 15 years incorporate detention ponds as part of their stormwater design. When heavily vegetated property is developed to include a large number of parking areas and b uildings, for instance, the volume and velocity of stormwater runoff are greatly increased. Areas where stormwater could normally pond and leach into the soil are eliminated and replaced with buildings or paved surfaces. In addition, the impervious surfaces transport the water more quickly than the undeveloped land does. The increased flow and volume can damage stream channels.
During a storm, the runoff from a developed property is discharged to a detention pond, which allows an increased volume of water or runoff to enter the pond, while limiting the amount of water leaving the pond to a constant rate. The pondcollects excess water because the volume flowing in is greater than the volume flowing out. The pond and the outlet structure are sized so the flow out of the pond approximates but does not exceed the flows from the drainage area before it was developed.
What are sedimentation ponds? (page 9-12)
Sedimentation ponds are similar to detention ponds. In many cases, the detention pond functions as a sedimentation pond, providing an area for silt and sediment picked up and carried in turbulent stormwater flows to settle out in a controlled area. Thes econtaminants may consist of sand, silt, and sediments that have been swept up off paved and unpaved surfaces during a storm. Silts and sediments are the smallest soil particles.
When are oil/water separators used? (page 9-15)
Environmental regulations now require the use of oil/water separators at certain locations. In general, these structures are found in areas where there is a risk of petroleum product leakage, such as at gas stations, facilities such as oil refineries, tank farms, and fuel-oil delivery services. They may also be located where stormwater discharges into environmentally sensitive areas such as fish or waterfowl breeding grounds. Separators, located below ground level, are usually constructed of concrete and steel and are approximately 5 feet deep, 5 feet wide, and 10 feet long. A 2" vent pipe is connected to the separator and extends approximately 6-8 feet above grade. An access manhole is located in the top of the tank. Please note that there are many types of oil/water separators.
What are the three types of wastewater that require an NPDES permit? (page 9-18)
An owner or manager must be familiar with the three types of wastewater that require an NPDES permit:
- 1. process or inustrial wastewater
- 2. stormwater that comes in contact with industrial activities
- 3. sanitary wstewater
When is a stormwater permit required? (page 9-20)
A NPDES stormwater permit is required if the stormwater drain is connected to a navigable waterway. There are three types of NPDES stormwater permits: general permits, individual permits, and group permits.
What is a group permit? (page 9-20)
A group permit is used for certain categories of facilities that have similar plant operatoins and discharges. In many cases, a number of sewage treatment plants that discharge treated wastewater operate under a group permit if the discharge limits are the same and the facilities are similar. At least 11 facilities must participate, but there is no maximum limit. The advantage of submitting a group application is that the paperwork associated with individual permits for periodicaly monitoring and analyzing discharge effluents is reduced.
When is an individual permit needed? (page 9-20)
An individual permit is used for facilities that do not qualify for a general permit and whose stormwater flows may come in contact with contaminants. In these cases, only those stormwater discharges linked to industrual activities are required to be covered by a permit. Other storm water discharges at the facility, such as those from parking areas associated with business activities, are not required to have or be included in an NPDES individual permit.
What are the general goals of the EPA's RCRA regulatory programs? (page 10-2)
Under Subtitle I of RCRA (the Resource Conservation and Recovery Act), Congress directed the EPA (Environmental Protection Agency) to establish regulatory programs that would prevent, detect, and clean up releases from UST systems ontaining petroleum or hazardous substances. The UST regulations that the EPA issued in 1988 established a number of corrective action requirements for UST owners and operators, including the requirement to clean up soil and groundwater as needed to protect human health and the environment.
What are the minimum requirements for underground storage tank (UST) construction? (page 10-3)
- Federal and state rules mandated that existing tanks were to meet the following upgrade requirements by December 22, 1998
- -corrosion protection
- -overfill protection
- -spill protection
What types of corrosion protection may be used on these tanks? (page 10-4)
- Corrosion protection for the tank must be provided in one of the following ways:
- -Steel tanks have corrosion-resistant coating and cathodic protection
- -Uncoated steel tanks have cathodic protection
- -Tank is made of noncorrodible material (such as fiberglass)
- -Steel tanks are clad with (or enclosed in) noncorrodible material
- -Steel tanks have internal lining without cathodic protection (which some states allow)
What are the requirements for UST leak and release detection? (page 10-5)
The UST system must be designed and constructed using a leak detection method that will monitor releases monthly, with a .95 probability of detection and a .05 probability of a false alarm. It must be possible to detect a leak in any part of the UST system that routinely contains product, including piping.
What must UST owners and operators report to the implementing agency? (page 10-6)
As specified in Federal law 40 CFR 280, owners and operators of UST systems must submit the following information to the implementing agency:
- -When installing or upgrading a UST, fill out a notification form and submit it to your state or local agency. This form provides informatino about your UST, including a certification of correct installation.
- -Report suspected releases, spills, and/or overfills that endanger human health or the environment to the regulatory authority. If a release is confirmed, you must also report follow-up actions you plan to take or have taken to correct the damage caused by your UST.
- -When corrective actions are planned or taken, including initial abatement measures, intitial site characterization, free product removal, investigation of of soil or groundwater cleanup, report the corrective action plan to the proper authorities.
- -Notify the regulatory authority 30 days before you permanently close your UST.
What types of records must be kept? (page 10-7)
Owners and operators of tanks have to provide an inspector with records during an on-site visit that prove your facility meets certain requirements. These records must be kept long enough to show your facility's recent compliance status in four major areas.
- 1. Keep the following records of leak detection performance and maintenance:
- -the last year's monitoring results, and the most recent tightness test
- -copies of performance claims provided by leak detection manufacturers
- -records of recent maintenance, repair, and calibration of on-site leak detection equipment
2. Keep records that show the required inspections and tests of your corrosion protection system. According to 40 CFR 280.20(a)(4) and 40 CFR 280.20(b)(3), if corrosion protection equipment is not used, a corrosion expert (qualified by the National Association of Corrosion Engineers and recommended by installation contractors) must analyze the site corrosion potential.
3. Keep records that show a repaired or upgraded UST system was properly repaired or upgraded.
4. Keep records of the site assessment results required for permanent closure for at leat three years after closing a UST. (These results show what impact your UST has had on the surrounding area.) It is advisable though, that these records be kept permanently.
What are the requirements for all new and retrofitted tanks? (pages 10-11 and 10-12)
New tank standards stipulate that all new tanks and retrofitted tanks must be installed properly, tanks must be adequately designed for corrosion protection, and they must include spill and overill protection and leak detection. Owners and managers are required to meet these minimal design standards on all new tanks.
How can USTs be upgraded for corrosion protection? (page 10-13)
- Depending on your local regulatory requirements, you might have three options for upgrading existing steel USTs:
- 1. interior lining
- 2. cathodic protection
- 3. internal lining combined with cathodic protection
Note that some states do not allow interior lining alone to meet corrosion protection requirements.
How often must cathodic protection systems be tested? (page 10-14)
Regulations require a qualified cathodic protection expert to design cathodic protection systems, supervise their installation, and inspect them after they are installed at the UST site. The system must be tested by a qualified cathodic protection tester within six months of installation. Impressed current systems must be tested yearly, whereas sacrificial anode systems must be tested every three years.
What are the overfill protection requirements of USTs? (page 10-18)
- The new tank standards mandate that overfill protection equipment either shut off the filling operator when the tank is 95% full or alert the filling operator when the tank is 90% full. Every UST must have overfill protection. When a new UST is installed, overfill protection devices must likewise be installed. The three main types of overfill protection devices are:
- 1. automatic shutoff devices
- 2. overfill alarms
- 3. ball float valves
What are the three main types of overill protection devices? (page 10-18)
- 1. automatic shutoff devices
- 2. overfill alarms
- 3. ball float valves
How often must UST system monitoring occur? (page 10-20)
Several types of monitoring can help owners and managers detect leaks from a UST system. Monitoring devices can be used inside the tank; in the interstitial space (that is, the space between the primary and secondary layers of the containment) of a double-wall tank; in the secondary barrier surrounding a tank; in soil; or in groundwater wells. The regulations require that owners or managers provide one or a combination of these types of monitoring at least once a month.
What are the leak detection requirements for pressurized piping and for suction piping? (pages 10-21 and 10-22)
- Pressurized piping must meet the following requirements:
- -The piping must have devices that automatically shut off or restrict flow or have an alarm that indicates a leak.
- -Your must either conduct an annual tightness test of the piping or use one of the following monthly methods noted above for tanks: intertitial monitoring, vapor monitoring, groundwater monitoring, statistical inventory reconciliation, or other approved monthly methods.
- If your UST has suction piping, your leak detection requiremetns will depend on which type of suction piping you have.
- -Suction piping that does not require leak detection because it has the following readily determinable characteristics:
- -- Below-grade piping operating at less than atmospheric pressure is sloped so that the piping's contents will drain back into the storage tank if the suction is released.
- --Only one check valve is included in each suction line and is located directly below the suction pump.
-Suction piping that does not exactly match the characteristics noted above must have leak detection, eithe rmonthly monitoring *using one of the monthly methods noted above for use on pressurized piping) or tightness testing of the piping every two years.
What are the first two steps in tank closure? (page 10-26)
To comply with the closure regulations, owners and managers have two basic options: removal or abandonment. Completely removign a UST system is likely to be the most effective way in which an owner or manager can reduce risk. Once a tank is removed and properly disposed of, and any present contamination is cleaned up an owner's or manager's risk is virtually eliminated. Abandoning a system in place is also a risk-reducing strategy. However, because of the restrictions placed on this option, the risk is not reduced as much as it would be by permanently removing the tank system.
Begin your permanent closure procedure by notifying the authorities of your plans. Next, make a site assessment and, depending on the conditions of contamination at the location, work up a corrective action plan. It is recommended that you use a qualified consultant.
What are the requirements for temporary closure (up to 12 months) of a UST? (pages 10-27 and 10-28)
- You may temporarily close your UST for up to 12 months by following these requirements for a temporary closure:
- -Continue to monitor for leaks by maintaining the UST's leak detection. (If your UST is empty, you do not need to maintain leak detection.) Also, continue to monitor to monitor and maintain any corrosion protection systems. If a release is discovered, quickly stop the release, notify your regulatory authority, and take appropriate action to clean up the site.
- -If the UST remains temporarily closed for more than 3 months, leave vent lines open but cap and secure all other lines, pumps, manways, and ancillary equipment.
What are the requirements for permanent closure? (page 10-28)
- If you decide to close your UST permanently, you must follow these requirements for permanent closure:
- -Notify the regulatory authority at least 30 days before you close your UST.
- -Either remove the UST from the ground or leave it in the ground. In both cases, the tank must be emptied and cleaned by removing all liquids, dangerous vapor levels, and accumulated sludge. These potentially very hazardous actions need to be carried out carefully by trained professionals who follow standard safety practicies. If you leave the UST in the ground, have it filled with a harmless, inert soid, like sand.
- -Using subsurface investigation, determine if contamination from your UST is present in the surrounding environment. If there is contamination, you may have to take corrective action. For at least 3 years, keep a record of the actions you take to determine if contamination is present at the site (or you can mail this record to your regulatory authority).
Who enforces the RCRA, the Solid Waste Disposal Act, the Solid Waste Disposal Act Amendments, and the HSWA? (page 11-3)
The EPA administers RCRA nationally, although implementation is frequently under state authority. The EPA has the authority to develop RCRA rules and regulations and to define the penalties for noncompliance.
What are the primary goals of the RCRA, the Solid Waste Disposal Act, the Solid Waste Disposal Act Amendments, and the HSWA? (page 11-3)
- The primary goals of RCRA are to:
- -Protect human health and the environment from the potential hazards of waste.
- -Conserve energy and natural resources.
- -Reduce the amount of waste generated.
- -Ensure that waste management is environmentally sound.
What do RCRA hazardous waste regulations focus on? (page 11-4)
RCRA hazardous waste regulations focus on generator responsibilities. These standards also regulate those who store, treat, or dispose of hazardous waste, whether or not they generated the waste. For generators, teh person or business that creates or generates hazardous waste must manage and treat or dispose of it properly. These regulations will affect building owners, managers, and maintenance staff if either the owner or the tenants create hazardous wastes.
What are the owner's and manager's responsibilities regarding hazardous wastes generated by tenants and contractors? (page 11-4)
From both the owner and the manager's perspectives, it is important to consider each tenant's busines stype, the types of chemicals it uses, the wastes produced, and the established policies of hazardous waste management. RCRA does not center on legal liability issues. Owners will be required to clean up any hazardous waste on their properties that threatens human health and the environment, no matter who is responsible for producing it. Therefore, a building owner and/or manager will want to insist that the clauses in a lease pertaining to hazardous waste use explicit language concerning the tenant(s) responsibility for proper disposalof such materials, as well as for other related environmental health and safety issues.
Define a Large-Quantity Generator. (page 11-5)
Any generator producing more than 1,000 kilograms (approximately five 55-gallon drums) per month is a large-quantity generator. Any generator storing a total of more than 6,000 kilograms (13,200) is considered a large-quantity generator, regardless of the rate of waste generation.
Define a Small-Quantity Generator. (page 11-5)
Any generator that produces more than 100 kilograms (220 lb) but less than or equal to 1,000 kilograms (approximately 2,200 lb) of hazardous waste per month is a small-quantity generator.
Define a Conditionally Exempt Small-Quantity Generator. (page 11-5)
- Any small-quantity generator producing less than or equal to 100 kilograms of hazardous waste, or less than 1 kilogram of acutely toxic waste, per month is called a conditionally exempt small-quantity generator. The only requirement for this type of business or facility is that the waste be disposed of properly in one of the following ways:
- -at a permitted facility
- -at a facility with "interim status" (that is, an authorized facility awaiting a formal permit)
- -at an authorized state hazarous waste management program
- -at any facility that can beneficially use, reuse, recycle, or reclaim the waste
What are P-list wastes? (page 11-6)
Hihgly toxic chemical wastes, such as those from cyanite and arsenic compounds and those from certain pesticides and herbicides.
How does the EPA define hazardous waste? (page 11-7)
The EPA defines hazardous waste in 40 CFR 261.3. Hazardous wastes are a subset of solid wastes, which means that in order for a material to be a hazardous waste, it must first meet the definition of a solid waste. Solid wastes, as defined by the EPA, include many waste streams that are acutally liquids. Hazardous waste of a certain quantity, form, or type (infectious, for example) may cause or contribute to a higher mortality rate or an increased incidence of serious illness.
The EPA's definition of hazardous waste is reasonably broad. The EPA has two categories of hazardous waste: "listed" and "characteristic."
In order for a material to be a hazardous material, it must first meet the definition of solid waste. A solid waste is any discarded material (garbage, refuse, sludge, liquid, or other waste). This EPA definition focuses not on the physical state of the material but on the physical act of discarding it, whether the intent is to abandon, recycle, reclaim, treat, store, or dispose of the material. By this definition, a solid waste can take the physical form of a solid, a semisolid, a liquid, or even a contained gas. Note that not all solid wastes are hazardous.
What are listed hazardous wastes? (page 11-10)
The EPA has identified many wastes that are "listed" as hazardous and must be managed and discarded properly. They are divided into three categories to help business and industry recognize their potential responsibilities. Knowing the specific waste, waste process, and waste chemicals makes it possible to profile the waste from the lists that follow.
- Generic Waste (F-List)
- Source-Specific Wastes (K-List)
- Commercial Chemical Products (U-List)
What are the characteristics of hazardous waste? (page 11-11)
- Four types of "characteristics" are associated with hazardous waste:
- 1. Ignitable Waste (Flammable)
- 2. Corrosive Waste
- 3. Reactive Waste (Explosives)
- 4. Toxic Waste (Poisons)
Do all questionable wastes meet the RCRA definition? (page 11-13)
Does dilution work to minimize detrimental effects? (page 11-13)
Remember that the solution to pollution is not dilution. That is, a hazardous waste cannot be legally rendered nonhazardous simply by diluting the hazard. If a nonhazardous waste is mixed with a hazardous waste, the resulting mixture is treated as a hazardous waste.
What are PCBs? (page 11-14)
PCBs (polychlorinated biphenyls) are chlorinated organic compounds - typically oil-like liquids - that are excellent electrical insulators that will not support combustion. Because of this property, they were used as insulation and heat-transfer fluids in electrical equipment such as transformers and capacitors.
Are PCBs still in use? (page 11-14)
PCBs have not been manufactured or used in industrial equipment since about 1979, but equipemt that dates from before 1979 is likely to contain PCBs and is therefore subject to TSCA regulation. In typical office buildings, PCBs might be contained in the small ballasts in fluorescent lighting, in large electrical transformers and switch gear, and in hydraulic equipment for elevators and escalators.
Where are PCBs found in typical office buildings? (page 11-14)
In typical office buildings, PCBs might be contained in the small ballasts in fluorescent lighting, in large electrical transformers and swtich gear, and in hydraulic equipment for elevators and escalators.
How does the EPA track hazardous wastes during transport? (page 11-16)
An EPA identification number is required for any business transporting, treating, storing, or disposing of waste, or otherwise involved int he management of such waste (while conditionally exempt small-quantity generators do not require an identification number under RCRA, many state and local agencies will require an identification number). The generator identification number must appear on labels attached to hazardous waste whenever it is transported.
Under what cirucmstances are storage permits required? (page 11-16)
Permits for storage are required only if the facility stores hazardous wastes for more than 90 days. The permitting requirement for storage is less stringent for some small-quantity generators.
What are the rules for storage areas? (page 11-17)
- First, all ares should be kept clean by following good housekeeping practices, and all containers must bevisible and clearly marked. To be in control of the areas - according to the RCRA - the following are required:
- -Containers must be clearly labeled with the words "Hazardous Waste," the identity of the chemical (proper EPA/DOT, chemical name) and the accumulation start date.
- -Containers must be closed when not being actively filled. Lids must be securely fastened, with bungs (stoppers) in place. It is not acceptable to leave funnels in the lid for ease of storage.
- -Emergency response equipment should be ready and available. This equipment (fire extinguisher, spill-control and fire-control, decontamination, emergency notification, including names/numbers of contact person, and water supply) should be inspected periodically to ensure that it is in good working condition.
- -Adequate aisle space must be maintained to allow the containers to be inspected.
- -A contingency plan must be maintained for the area.
Who is required to have a writen contingency plan? (page 11-18)
Generators and TSD facilities are required to develop an emergency response plan to handle on-site emergencies. Large-quantity generators must have a written plan available for all employees. Small-quantity generators are not required to have teh plan in writing as long as employees understand their responsibilities and actions in emergency situations. TSD facilities must have a written plan and work with local emergency response teams to train them in carrying out their contingency plan.
Who must receive training? (pages 11-18 and 11-19)
All employees must receive annual training in the basics of hazardous waste management. Initially, all employees must be trained within the first six months of their job assignment. Although RCRA regulations do not require a specific employee training program for a small-quantity generator, employees must be thoroghly familiar with proper waste-handling procedures relevant to their responsibilities.
How long must paperwork be maintained? (page 11-20)
All RCRA paperwork must be maintained for a minumum of 3 years. Included are all employee training records, hazardous waste manifests, biennial reports (small-quantity generators are exempt from this requirement), and any other documentation about hazardous waste. Although RCRA requires that all records be kept for 3 years, the responsibility for managing the waste properly does not end. Note that the management responsibility actually ends after the post-closure period, but the post-closure period for a disposal site is at least 30 years after site closure).
What are the general RCRA requirements for containers? (page 11-23)
- RCRA requires the following management practices regarding containers:
- -Drums and pallets should be in good condition. Visibily distressed drums with rust, dents, creases, or bulges should never be used. Damaged pallets can cause drums to spill.
- -Incompatible chemicals should always be stored separately or as far away from each other as possible to prevent accidental mixing or potential reactions.
- -Containers with ignitable wastes should be grounded to prevent potential explosions from sparks.
- -Containers should have enough room to allow for expansion.
- -Containers should be protected frome xtreme temperature and weather conditions.
- -Containers should be handled using special drum attachments to prevent spills.
- -Containers should be DOT approved for transportation to the off-site disposal facility.
Empty hazardous waste containers require special attention, as empty containers are not necessarily clean. Unless specific conditions are met before empty containers are reused or discarded, containers must be treated and handled as hazardous waste.
Define an accumulation storage area. (page 11-24)
An accumulation storage area is the area where hazardous waste can be stored while arrangements are being made for its treatment and disposal.
In an accumulation storage area, each container must be dated as soon as it has begun to be filled. This date, known as the accumulation start date, starts the clock for waste transfer, treatment, and/or disposal. The large-quantity generator then has 90 days from the accumulation start date to transfer the waste to a TSD facility. A small quantity generator has 180 days (or 270 days if the TSD facility is more than 200 miles away) to ship the waste off site for treatment.
Define a satellite storage area. (page 11-24)
A satellite storage area is the area near the point of waste generation (for convenience) where no more than 55 gallons of hazardous waste or 1 quart of acute hazardous waste can be stored. Waste in satellite storage is usually moved to the accumulation storage area prior to disposal.
Therei s no limitation on the storage time for a satellite storage area. However, as soon as the satellite storage volume limitation is exceeded, the excess waste must be moved to the accumulation storage area within three days. If it is not moved within three days, the satellite storage area must comply with accumulation storage area requirements.
What are the RCRA inspection requirements? (page 11-26)
RCRA requires that all storage areas and drums be inspected weekly. Storage tanks (as opposed to containers) must be inspected daily. It is important to document any error so that corrective action can be taken to bring the area into regulatory compliance.
When must Large-Quantity Generators report to the EPA? (page 11-27)
Large-quantity generators are required to submit Biennial Reports to the EPA. Teh Biennial Report must5 be submitted on EPA Form 8700-13A, available from EPA offices. These reports, due no later than March 1 of every even-numbered year, detail the company's waste generation and management processes.
What is the Uniform Hazrdous Waste Manifest? (page 11-28)
When ahzardous waste is transported off site for treatment, storage, or disposal, it must be carefully tracked by a legal document known as the Uniform Hazardous Waste Manfiest. The manifest, usually prepared by the generator, identifies the type and quantity of the waste, as well as the transporters and facility to which it will be shipped. The manifest must accompany the waste. Each person involved in the process must sign the manifest and keep one copy. When the waste reaches its final destination, the facility taht accepts shiopment returns a copy of the manifest to the genertor to confirm that the waste was received.
What are the labeling requirements for hazarous waste storage and transportation? (page 11-31)
For waste stored in accumulation storage areas, each container must be labeled as "Hazardous Waste," alon gwith the date upon which each accumulation period begins. For satellite storage areas, the words "Hazardous Waste," or similar words clearly identifying the waste, must appear on each container.
- For transportation of hazardous waste, each container must e labeled with the appropriate DOT required markings, as found in 49 CFR 172. This icludes the requirement that all containers of 110 gallons or less be marked with the following:
- "HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authortiy or the Environmental Protection Agency.
What are the keys to a compliant emergency response program? (See Figure 12-1, page 12-3)
- Keys to a Compliant Emergency Response Program:
- -Method to assess potential emergency conditions
- -Compliance with regulations
- -Consolidated data
- -Readily available information
- -Employee/responders training program
- -Monitored and updated program components
What must an emergency action plan include? (pages 12-8 and 12-9)
- The emergency action plan must include the following:
- -emergency escape procedures and escape route assignments
- -procedures for employees who remain to implement critical plant operations before they evacuate the building
- -procedures to account for all employees after emergency evacuation has been completed
- -assignments of rescue and medical duties for designed employees
- -preferred methods of reporting fires and other emergencies
- -lists of people or departments responsible for implementing the plan
What are the major elements of a fire prevention plan? (See Figure 12-2, page 12-9)
The two major elements of a Fire Prevention Plan:
- -Identification and Control of Major Workplace Fire Hazards
- -Indentification of Persons Responsible for Preventing or Controlling Fire Hazards
What is an incidental release? (page 12-15)
An incidental release is the release of a hazardouse substance that can be absorbed, neutralized, or otherwise controlled by employees in the immediate vicinity. Understanding the distinction between an incidental release of a hazardous substance and a release that requires an emergency response is fundamental to proper compliance with the HAZWOPER standard. The standard covers a wide array of facilities and situations relating to emergency response operations, regardless of where the hazard is located.
What is a circumstantial release? (page 12-16)
The properties of the hazardous substance, the circumstances of the release, and the mitigation factors in the work area combine to define the distinction between incidental releases and releases that require an emergency response. The distinction is facility specific and is a function of the emergency response plan.
The properties of hazardous substances, such as toxicity, volatility, flammability, explosivenes,s and corrosiveness, as well as the particular circumstances of the release itself (quantity, confined space considerations, and ventilation) determine what employees can handle safely and what procedures should be followed. Additional factors that may mitigate the hazards associated with a release and its remediation include the knowledge of the employee in the immediate work area, the response and personal protective equipment at hand, and the pre-established standard operating procedures for responding to release of hazardous substances. Some engineering control measures will also mitigate a release when employees activate them to help control and stop the release.
What is a true emergency release? (page 12-16)
By their very nature, some releases of hazardous substances pose a signifcant enough threat to health and safety to require an emergency response tregardless of the circumstances surrounding the release or the mitigating factors. An employer must determine the potential for an emergency in a reasonably predictable worst-case scenario, referred to as an anticipated emergency, and plan procedures accordingly.
What are some of the elements of an effective written plan? (page 12-18 and 12-19)
The written emergency response plan must be available for inspection by employees and must address, at a minimum, the following elements:
- -Pre-emergency planning and coordination with outside agencies
- -Personnel roles, lines of authority, training, and communication
- -Emergency recognition and prevention
- -Safe distances and places of refuge
- -Site security and control
- -Evacuation routes and procedures
- -Decontamination procedures
- -Emergency medical treatment and first aid
- -Emergency alerting and response procedures
- -PPE (personal protective equipment) and emergency equipment
- -Medical surveillance
- -Site topography, layout, and prevailing weather conditions
- -Procedures for reporting incidents to government agencies
- -Critique of response and follow up
When defining personnel roles for site control, what should you specify? (page 12-18)
The people who will participate in an emergency response must be identified, and their roles and procedures for communication must be established. In addition, the limitations of the various roles during an emergency msut be defined and personnel must know when not to intervene, such as when a fire is too large to handle. The appropriate level and method of training must also be designated.
What should emergency alerting and response procedures include? (page 12-19)
Installing equipment and developing procedures for alerting people to an emergency are important aspects of emergency planning. The location of all emergency alarms must be noted on the evacuation plans. Personnel must be trained in the types and meaning of various internal alarms. The employer must also establish an employee alarm system that complies with OSHA standards. The plan must specify a system to alert all affected employees of an emergency situation. However, OSHA exempts workplaces with fewer than 10 employees when the agencdy determines that a direct verbal alert is sufficient. The type of system chosen will depend on the size of the facility. For multistory buildings subdivided by interior walls, traditional alarm systems are recommended. OSHA prefers supervised telephone or manual fire alarm, pull-box stations with paging systems to transmit messages throughout the building. The alarm boxes must be located so that employees do not have to travel more than 200' to reach one.
What are the procedures for reporting? (page 12-20)
Several regulations require reporting of releases of hazardous substances to designated government agencies on the federal, state, and local levels. Emergency plans should include the identification of reportable incidents and the appropriate agencies to be notified, as well as the senior person responsible for reporting such incidents.
Explain the responsibilities of an employee at the First Responder-Awareness Level. (pages 12-24 and 12-25)
- Hazmat awareness is important for those people who are likely to witness or to first discover a hazardous substance release and who should be able to initiate an emergency response by notifying the proper authorities. These people take no further action beyond notification. First responders at the awareness level must have adequate training (perhaps just a few hours) or experience to recognize an emergency situation and demonstrate competency in understanding the following areas:
- -hazardous substances and the risks associated with them
- -the potential outcomes of an emergency when hazardous substances are present
- -identification of the hazardous materials, if possible
- -the role of the first responder in the employer's emergency response plan
- -the DOT Emergency Response Guidebook
- -recognition of the need for additional resources and appropriate notifications
- -respiratory protection, its uses, and its limitations
Explain the responsibilities at the First Responder-Operations Level. (page 12-25)
- First responders at the operations level are part of the inital response to the site of the releases or potential releases of hazardous substances to protect nearby people, property, and the environment from the effects of the release. They are trained to respond defensively without actually trying to stop the release. Their functions are to contain the release from as afe distance, to keep it from spreading, and to prevent exposure. First responders at the operations level receive at lest eight hours of training, unless they have sufficient experience to demonstrate competenece, certified by the employer, at the awareness level and in the follwing areas:
- -selection and use of proper personal protective equipment
- -basic hazardous material terms
- -basic control, containment, and confinement operations
- -basic decontamination procedures
- -established procedures for responding to and abating an emergency and the follow-up measures to eterminate the response
Explain the responsibilities of a hazmat technician. (pages 12-25 and 12-26)
- Hazmat technicians are trained to respond to releases or potential releases of a hazardous substance in order to stop the release. They assume a more aggressive role than people at the first responder operations level, in that they may approach the point of release of a hazardous suybstance to plug, patch, or otherwise stop it. Hazmat technicians receive at least 24 hours of training, including the equivalent of the first responder operations level, and must be certified as competent in the following areas:
- -ability to implement the employer's emergency response plan
- -use of field survey instruments and equipment to classify, identify, and verify known and unknown materials
- -selection and use of the proper PPE for specialized chemicals
- -ability to function within an assigned role in the incident command system
- -hazard and risk assessment techniques
- -advanced control, containment, and/or confinement operations
- -decontamination procedures
- -termination procedures
- -basic chemical and toxicological terminology and behavior
Explain the responsibilities of an on-scene incident commander. (page 12-27)
- On scene incident commanders, sometimes called facility emergency coordinators, are the senior emergency response officials at the response site. They assume control of the incident scene beyond the first responder awareness level and take charge of the ICS during an emergency. All the other levels of emergency responders are coordinated and controleld through the on-scene incident commander. Incident commanders receive 24 hours of training and must demonstrate competency and be certified by the employer in the following areas:
- -understanding an implementing the employer's ICS
- -implementing the employer's emergency response plan
- -the hazards and risks associated with employees working with chemicals, including the hazards of working in chemical protective suits
- -implementing the local emergency response plan
- -the state of emergency response plan and the federal regional response team
- -the importance of decontamination procedures
What is the PSM standard? (page 12-29)
OSHA's PSM (Process Safety Management) standard found in 29 CFR 1910.119 was developed to prevent or minimize the consequences of catastrophic releases of toxic, reactive, flammable, or explosive chemicals. However, the standard applies to a specific list of chemicals in certain manufacturing industries.
What emergency response records must be maintained by owners/manager? (page 12-35)
- The record-keeping requirements for emergency response are:
- 1. Training
- 2. Notification
- 3. Documentation
- 4. Contingency Plans
What is environmental due diligence? (page 13-3)
As part of the normal due diligence requirements for financing, refinancing, or foreclosure, parties associted with a property transaction typically contract for an ESA to satisfy themselves about the value or condition of the property, including the potential for any on-site environmental contamination. Virtually all real estate investments, whether they are commerical, industrial, or residential in nature, have the potential for environmental liabilities or concerns.
What is an environmental audit? (page 13-3)
An environmental audit is aprocess often used during leagl proceedings to evaluate a facility's operational compliance with environmental regulations.
What is CERCLA? (pages 13-6 and 13-7)
- Enacted in 1980, CERCLA established requirements for identifying and cleaning up contaminated sites and containing unauthorized releases of hazardous substances. CERCLA has four basic objectives:
- -to provide the enforcement agency with the authority to responde to releases of hazardous wastes from inactive hazardous waste sites that endanger public health and the environment
- -to establish a fund (known as "Superfund") to provide for cleanup of inactive or abandoned hazardous waste sites
- -to establish regulations controlling inactive hazardous waste sites
- -to assign liability for releases of hazardous wastes from such inactive sites
What is SARA? (pages 13-6 and 13-7)
In 1986, SARA (the Superfund Amendments and Reauthorization Act), amended CERCLA. The basid objectives of CERCLA were left in place, but SARA added tougher cleanup requirements and increased the amount of money available in the Superfund.
Why are CERCLA and SARA important? (pages 13-7 and 13-8)
CERCLA and SARA, both now collectively known as Superfund, have had a profound effect on the transfer of property ownership. Slthough these two acts principally deal with inactive or abandoned hazardous waste sites, active proerties are also within the jurisdiction of the acts. Take note, however, that superfund regulations do not cover petroleum. This substance is included in many state laws, though, such as ASTM and Phase I ESA.
What is an environmental compliance audit? (page 13-13)
An environmental compliance audit is a systematic, documented evaluation of a facility, focusing on current operating and administrative procedures and processes. Environmental health and safety compliance issues and internal policies, practices, and procedures are evaluated. Chemical and hazardous material usage and handling, compliance with environmental permits, and a review of discharges to air, land, or water are some of the audited items.
What are non-routine compliance audits? (page 13-13)
An audit performed on a non-routine basis represents only a snapshot in tiem of the facility's operations. During a property transfer, a buyer might contract for an audit if the transaction involves acquiring and continuing operations similar to those of the previous owner.
What is the purpose of a Phase I ESA? (page 13-20)
A Phase I ESA is likely to be the most cmomon form of site assessment that an owner or manager encounters during financing, refinancing, and foreclosure. To evaluate the environmental concerns associated with the subject property, most lenders normally require a Phase I ESA before a transaction closes.
What does Phase I involve? (page 13-20)
- The ESA investigatin can be broken down into the following four major parts:
- -Investigation of past property activities or operatiosn involving the use, storage, treatment, or disposal of hazardous or other regulated materials.
- -Review of current property activities or operatiosn involving the use, storage, treatment, or disposal of hazardous or other regulated materials
- -Review of the environmental compliance statutes concerning permits, discharges, and other regulatory issues.
- -Investigation of adjacent and surrounding proeprties that may adversely affect the subject property.
What is the purpose of a Phase II ESA? (pages 13-30 and 13-31)
Comprehensive Phase I research helps the investigator in designing the Phase II investigation. The Phase II investigation is typically used to characterize the levels and extent of any soil or water contamination on the property, and to identify the sources of that contamination. A Phase II assesssment may also provide an estimate of costs to fully investigate and remediate (or clean up) the site.
What does Phase II include? (page 13-31 and 13-32)
- 1. Field Sampling Plan
- 2. Health & Safety Plan
- 3. Utility Clearance
What does Phase III cover? (pages 13-41 and 13-42)
The Phase II site assessment considered to be the final phase of the site assessment process. Phase II typically covers those site investigation tasks designed to establish the vertical and lateral extent, or magnitude, of the contamination identified during Phase II.
What is a RAP? (page 13-44)
RAP (remedial action plan). A plan created by a property owner or responsible party that specifies the selected remedial actions that will protect the public from a threatened or actual release of hazardous substances and the timetable for implementing those remedial actions.
After the property owner or other responsible party has defined the remedial action objectives, in cooperation with the lead regulatory agency, the remedial action process may proceed with the development of a RAP (remedial action plan). The objectives of the RAP are to design the selected RAs (remedial actions) that will protect public health and welfare and the environment from a threatened or an actual release of hazardous substances and to schedule implementation of the RAs.
The RAP outlines, in detail, the approach that has been selecgted to remediate the contamination to acceptable levels, based on the results of the Phase II investigation, site-specific conditions, any risk assessments that were performed, and the evaluation of remedial alternatives. The evaluation process for remedial alternatives is often refered to as a "feasibility study." The RAP also includes a dicussion of the rationale used in the selection of any risk-based soil and/or groundwater cleanup standards adopted for the project.
How long should monitoring or RA systems remain in place? (page 13-44)
Any monitoring or response action systems employed in the implementation of the RAP must typically be left in place and operated until the cleanup objectives set forth in the RAP are achieved, or upon ation of a revised cleanup objective. This stage of the Phase III process typically is termed "final closure" or "no further action."
Why aren't Phase III time and costs uniform? (page 13-48)
Phase III costs are not uniform because the extend of contamination is not known until after this phase has been completed. PHase II assessments are sometimes handled as time-and-materials contracts, with laboratory analysis and drilling costs identified with a unit-pricing structure.
What are the record-retention requirements concerning site assessments? (page 13-52)
There is no regulatory requirement for retention of environmental assessment documents. However, because such assessments document the environmental history of a property, environmental assessment reports should be retained for as long as possible. These reports should be retained for as long as possible. These reports can be used to validate loan qualification requirements of banks and various state agencies.
Having reports available to show that environmental concerns have already been identified and addressed will prevent lost time and money for unnecessary reinvestigation when property changes hands. Environmental assessment reports tend to live on with the proeprty, being passed from one owner to the next, and they an invaluable source of information on prior operatiosn at the site.