1. Advanced Chemical Safety DO YOU NEED A HAZMAT TEAM? NEAL LANGERMAN Advanced Chemical Safety, Inc. San Diego Presentation is posted on both the DivCHAS website and www.chemical- safety.comwww.chemical- safety.com For more information – neal@chemical-safety.com neal@chemical-safety.com

2. Advanced Chemical Safety DO YOU NEED A HAZMAT TEAM? Regulatory Constraints Financial Considerations Practical Implementation – –Full Hazmat Team –Small Spill Control

3. Advanced Chemical Safety DO YOU NEED A HAZMAT TEAM? Regulatory Constraints Is this an emergency? Emergency response or responding to emergencies means a response effort by employees from outside the immediate release area or by other designated responders (i.e., mutual-aid groups, local fire departments, etc.) to an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous substance.

4. Advanced Chemical Safety DO YOU NEED A HAZMAT TEAM? Regulatory Constraints Alternatives … Employers who will evacuate their employees from the danger area when an emergency occurs, and who do not permit any of their employees to assist in handling the emergency, are exempt from the requirements of this subsection if they provide an emergency action plan in accordance with 29 CFR, 1910.138(a).

5. Advanced Chemical Safety DO YOU NEED A HAZMAT TEAM? Regulatory Constraints Alternatives … Implement aggressive spill prevention and control measures ( Slide borrowed from Justrite Manufacturing )

6. Advanced Chemical Safety DO YOU NEED A HAZMAT TEAM? Regulatory Constraints Alternatives … “Big Spills” cannot occur at your facility.

7. Advanced Chemical Safety DO YOU NEED A HAZMAT TEAM? Regulatory Constraints Alternatives … Responses to incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel are not considered to be emergency responses within the scope of this standard. Responses to releases of hazardous substances where there is no potential safety or health hazard (i.e., fire, explosion, or chemical exposure) are not considered to be emergency responses.

8. Advanced Chemical Safety DO YOU NEED A HAZMAT TEAM? Regulatory Constraints –Not Emergencies < 20 L solvents < 5 L acids Most solids Most “Lab Scale” –Lab engineering and time can control risks

9. Advanced Chemical Safety DO YOU NEED A HAZMAT TEAM? Regulatory Constraints All employees who might clean up non-emergency spills must be trained under 29 CFR 1910.1200 or 1450.

10. Advanced Chemical Safety DO YOU NEED A HAZMAT TEAM? Financial Considerations –Full HazMat Team Initial Cost: >$100,000 Maintenance: (ca) $20,000 per year –Cost of a lab spill clean-up: $1,000 - $20,000

11. Advanced Chemical Safety DO YOU NEED A HAZMAT TEAM? Financial Considerations –Small Spil Initial Cost: (ca) $100 per employee Maintenance: (ca) < $50 per employee per year –Cost of a lab spill clean-up: $100 - $400 per spill

12. Advanced Chemical Safety DO YOU NEED A HAZMAT TEAM? Practical Considerations –Full HazMat Team Initial Training: 1910.120 requirements Annual Refresher

13. Advanced Chemical Safety DO YOU NEED A HAZMAT TEAM? Practical Considerations –Lab Spill Initial Training: 1910.1200 requirements (training is part of “Hazard Communication” training or ½ day stand alone

14. Advanced Chemical Safety DO YOU NEED A HAZMAT TEAM? Conclusions: Full Spill Teams are not for everyone. Most teaching and R&D labs do not need a full team. Define an “emergency” carefully and prevent spills.