| About This Archive | | DCHAS-L 2007 Index | | DCHAS-L Yearly Index | |
Check out Safety Emporium for your N95, N99, and face shield needs.
|
Previous by Date: Subject: Re: Tier 2 Reporting Date: Wed, 14 Feb 2007 10:42:44 -0600 Author: Diane Amell |
Next by Date: Subject: Job opening: Director of Environment, Health, and Safety, Date: Fri, 16 Feb 2007 09:18:10 -0500 Author: List Moderator |
I wanted to briefly "second" Diane's post. The previous post implying that it's silly to have to include baby shampoo, rock salt, sand etc on the annual Tier II to EPA and local emergency responders seems to kind of be missing the point of what these reports are for. No insult intended...however it is important to keep the purpose of Tier IIs in mind when deciding what to include. Why report things that seem relatively innocuous (assuming you have a large quantity)? Because the purpose of EPA is to protect the environment (as opposed to OSHA, which focuses on worker safety... what most of us safety folks usually are focused on) and to protect the safety & health of the community. A release of 5,000 gallons of baby shampoo may sound innocuous, but imagine firefighters trying to rescue someone or keep a building full of flammables cooled down in a parking lot full of liquid soap (the shampoo would probably impact the nearby streams and maybe the soil too.) A river overflowing its banks into a 10,000 lb pile of road salt will probably impact the pH and cause a fish kill. The rupture of 150 lb cylinder of chlorine gas from malfunction or fire could kill everyone within a certain radius. These are examples of things the local emergency responders need to know are there -- BEFORE they go roaring in w/lights and sirens. [I personally might not report sand on a Tier II unless it's required (we don't have enough for me to have looked into it), but that doesn't mean it's not a significant hazard to people who work around airborne silica. Sand at the beach isn't typically airborne to a significant extent, and that which is is heavily diluted.] Too keep the reporting process from being too cumbersome, you only have to report very large quantities, or items that are extremely hazardous in smaller quantities (e.g. chlorine gas, for example). EPA provides a list of items they consider to be extremely hazardous. So if you have 5 cases of baby shampoo, no reporting; but if you have a 5,000 tank of it, then probably yes. Hmmm....it's unusual for me to be in the position of defending EPA regulations since they are typically ridiculously complicated in my opinion! But much as I dread this annual exercise, this one actually has some basis in sanity. -m2c Mary M. Cavanaugh, CIH phone 828.262.6838 email cavanaughmm**At_Symbol_Here**appstate.edu -----Original Message----- From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of Diane Amell Sent: Wednesday, February 14, 2007 11:43 AM To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU Subject: Re: [DCHAS-L] Tier 2 Reporting I was going to stay out of this, as I don't deal with SARA Title III (although a good friend of mine coordinates all the Tier I/Tier II/TRI/pollution prevention reporting in the state), but I'm afraid the previous comment upset me a bit. If you don't think silica sand is hazardous, please read NIOSH's Silicosis in Sandblasting: A Case Study Adapted for Use in U.S. High Schools at http://www.cdc.gov/niosh/docs/2002-105/2002-105.html (also available in Spanish and as a pdf file). You may want to pay special attention to the box on the Hawk's Nest incident.
Previous post | Top of Page | Next post