Spill Response

Description

All spills should be cleaned up immediately, since they may pose a hazard. Even small drips equate to product loss, and an impact on the bottom line. Drips from valves, drum pumps, and other dispensing devices should be controlled, and preferably eliminated. This can be done by providing drip pans, routinely repairing or replacing worn or defective components such as valves, and proper material-handling techniques. Elimination of all spills should be the goal.

You should establish the definition of a "small spill" in your facility based on the products and average volume of materials routinely handled. Employees should be informed of these guidelines and instructed on how to activate your emergency response team to clean up a spill that is too large or a spill that may meet the U.S. EPA reportable quantity guidelines. This contact and procedural information should be made readily available in the work area.

Best Management Practices & Pollution Prevention

Dry methods of spill clean-up help control the spread of hazardous materials through encapsulation. Additionally, when cleaning up hazardous materials, all of the wastewater used to clean up the spill will also be considered hazardous waste. It is good practice, both financially and environmentally, to generate as little additional waste as possible.

If employees are given an incentive for reporting even small spills, they will be less likely to attempt to cover up these incidents. An ideal incentive program will provide for establishing a baseline and an incentive for reducing the number and size of future spills.

Even small spills cost the company money as a result of labor costs to clean up the spill and the lost material. In order to help increase awareness of the cost of spills, it is helpful to establish a small minimum reporting requirement and begin documenting the cost of each and the cumulative cost of these spills. This information is not recommended for disciplinary action, but to help all employees understand the financial impact that these small spills can cost. Ultimately, increased awareness will help reduce spills, promoting cleanliness while increasing shop safety.

For access to vendors who may supply alternative materials and equipment, see the PNEAC Vendor Directory.

Environmental Regulations

If hazardous waste is stored at a facility, emergency response equipment is required to be provided.

Depending on the type and volume of material, the incident may be required to be reported to EPA at the National Response Center, the local fire department, the local emergency planning committee, the state environmental agency, and/or the state fire marshal.

OSHA HAZWOPER training must be provided to all personnel who are to respond to a spill that is large enough that it requires more people than those in the immediate area of the spill. OSHA deems these spills “large” and the amount of training for each employee is dictated by their role in the response. For those involved in cleanups, first responder training of eight hours is required as a minimum, with 40 hours as a maximum. If a spill can be cleaned up with the personnel in the immediate area, then formal training is not required, as OSHA has stated that the training performed under the Hazard Communication Standard is sufficient. Likewise, a contingency plan calling for the containment of the spill and evacuation will also negate the formal training requirements. Training is to be conducted every three years.

For those employees involved in handling DOT defined hazardous materials in the shipping/receiving or loading dock area, formal training on DOT requirements, including spill response, is required. This training is also to be conducted every three years.

Release Reporting - DOT Notification of a Release of Hazardous Materials/Waste

The transporter is required to notify DOT if a release of hazardous materials/waste occurs and as a direct result of the hazardous materials any of the following occur:

  1. A person is killed
  2. A person receives injuries requiring hospitalization
  3. Property or carrier damage exceeds $50,000
  4. The general public must be evacuated for one hour or longer
  5. One or more major transportation arteries is closed or shut down for one hour or longer
  6. The material released is radioactive
  7. Greater than 119 gallons or 882 pounds of solids of any marine pollutant (hazardous waste, ink, etc.) is released
  8. At the judgment of the carrier the incident is reported to the National Response Center even though it does not meet other DOT reporting criteria

For complete details see 49 CFR 171.15 and 49 CFR 171.16.

CERCLA - Section 103

There are three types of reporting requirements under CERCLA: CERCLA 103(a) for actual releases, including spills, of hazardous substances; CERCLA 103(c) for facilities where hazardous wastes have been disposed of and where such releases might occur; and CERCLA 103(f)(2) for releases that are continuous and stable in quantity and rate, and may also include petroleum products as well as non-hazardous reported releases.

More information on CERCLA Section 103 can be found on the EPA Web site and the United States Code Web site.

EPCRA - Section 304

This section includes reportable items that are commonly found in pressroom chemicals and materials (inks). Some of these have a very low reporting threshold and the combined amount (which can be a small, but significant percentage in products like inks) from the various sources in a printing facility can trigger reporting requirements, without it being readily apparent to the printer.

Following is an incomplete list of chemicals and compounds that might be found in a flexographic printing facility. This is just a sample and should not replace reviewing the relevant chemical lists, along with your facility chemical list and volumes stored and used at your facility. If there are multiple sources of the same chemical released, they must be totaled, and can quickly add up to a quantity that must be reported. See the EPCRA entry in the EPA List of Lists Database.

Ammonia: EPCRA Section 304: Release into the environment - 100 lb. threshold
CERCLA 103: Release into the environment - 100 lb. threshold
Benzene: EPCRA Section 304: Release into the environment - N/A
CERCLA 103: Release into the environment - 10 lb. threshold
Ethylene Glycol: EPCRA Section 304: Release into the environment - N/A
CERCLA 103: Release into the environment - 50,000 lb. threshold
Lead: EPCRA Section 304: Release into the environment - N/A
CERCLA 103: Release into the environment - 10 lb. threshold
Mercury: EPCRA Section 304: Release into the environment - N/A
CERCLA 103: Release into the environment - 1 lb. threshold
Sulfuric Acid: EPCRA Section 304: Release into the environment - 1,000 lb. threshold
CERCLA 103: Release into the environment - 1,000 lb. threshold
Styrene: EPCRA Section 304: Release into the environment - N/A
CERCLA 103: Release into the environment - 1,000 lb. threshold
EPCRA Section 312: Storage of Chemicals - 10,000 lb. Threshold
EPCRA Section 313: Usage of Chemicals - 25,000 lb. Threshold - Otherwise Used, 10,000 lb. Threshold – Manufactured
Section 112R CAA RMP: Storage and Potential Release Written Plan - N/A

Ammonia and styrene are very common ingredients in water-based inks and coatings. Ammonia is also a common ingredient in adhesives. It is also used in many refrigeration (chilling) systems. Use or storage of these products could trigger TRI reporting and CAA RMP requirements. Benzene is a common additive in blanket wash and other cleaning solvent blends. Ethylene glycol is used in radiators of forklifts, company vehicles, sprinkler systems, etc.

Lead may be found in ink pigments, grinding wheels, brazing rods, etc. Lead may also be found in the electrodes of forklifts battery cables and forklift batteries. Sulfuric acid is most commonly used in lead acid batteries. Mercury is most commonly found in light bulbs used in light fixtures and UV curing systems. It is also found in film processors, thermostats, thermometers, many gauges, ABS brakes on vehicles, etc. Light bulbs and lead acid batteries are considered universal waste. Unless the bulbs are crushed or broken as a common practice, or the battery is dismantled, then the lead, mercury and sulfuric acid are not required to be reported as a release under EPCRA Section 304 and CERCLA Section 103 regulations.

EPCRA Regulatory Hierarchy:

  • EPCRA section 302: List of chemicals and their reporting threshold. Presence of Extremely Hazardous Substances (EHS) at or above Threshold Planning Quantity (TPQ).
  • EPCRA List of Extremely Hazardous Substances (EHS) – Alpha and CAS
  • EPCRA section 304: Release of an EHS or Hazardous Substance at or above a reportable quantity must be reported to the Local Emergency Planning Committee (LEPC) and the National Response Center at 800.424.8802.

Health & Safety

According to U.S. EPA if a hazardous waste is stored at the facility, emergency response equipment is required to be provided.

Depending on the type of material spilled and the volume will depend on whether the incident must be reported to EPA at the National Response Center (800) 424-8802, local fire department, local emergency planning committee, and the state environmental or state fire marshal.

OSHA HAZWOPER training must be provided to all personnel who will respond to a spill that is large enough that it requires more people than those in the immediate area of the spill. OSHA deems these spills "large" and the amount of training for each employee is dictated by their role in the response. At a minimum an 8-hour first responder training is required and a maximum of 40 hours is required for those involved in cleanups. If a spill can be cleaned up with the personnel in the immediate area, then formal training is not required, as OSHA has stated that the training performed under the Hazard Communication Standard is sufficient. Likewise, a contingency plan calling for the containment of the spill and evacuation will also negate the formal training requirements. Training is to be conducted every three years.

At with any exposure to chemicals, proper precautions need to be taken in responding to a spill in a safe manner. As a minimum, the appropriate personnel protective equipment (e.g., gloves, goggles, splash apron, etc.) should be used during the spill clean up. Additional measures such as localized ventilation or respirators may also be necessary. All appropriate health and safety measures need to be identified in the spill response plan.

For those employees involved in handling DOT defined hazardous materials in the shipping/receiving or loading dock area, formal training on DOT requirements including spill response is required. Training is to be conducted every three years.