By Jacob Keating Two of the most common issues I find when performing onsite environmental compliance assessments are the lack of available Safety Data Sheets (SDS) and unsafe storage practices for water treatment chemicals. Many facilities use outside contractors to handle the maintenance of process water quality.  The service provider brings in the chemicals to create the precise balance needed to protect equipment and keep the facility running smoothly. Many times, site personnel do not know the type or quantity of water quality chemicals brought on-site, when the materials arrived, or even where they are stored.  I have found drums of caustic chemicals tipped sideways and held up by wood pieces in an effort to get the last drop out of the drum and into the system.  Frequently, these chemicals, which are classified as hazardous by OSHA, are located in compressor rooms and may be stored near drains that lead to the sanitary sewer and local water treatment facility.

Who is Responsible?

Even though those chemicals are brought on-site and managed by a contractor, these are the responsibility of the company not the contractor.  Every chemical in use at an industrial facility must have an up-to-date SDS on file and be available to the employees at a moment’s notice. This includes chemicals that were not ordered or brought on-site by the business’ team members.  It is vital to the workers’ safety that these chemicals are stored safely, with necessary secondary containment and proper placement.

The Chemical Approval Process

Many facilities require an approval form to be submitted to their EHS manager prior to a new chemical being ordered, with one exception – chemicals managed by outside contractors.  Extending the approval process to include contractors is one way to ensure that chemicals brought to the facility are accounted for and compatible with those already on site.  The EHS Manager can then ensure those chemicals are stored properly and that SDSs are available. The Manager can start by talking with outside contractors and informing them of the new requirements for chemical approval.  The contractor must inform the Manager when any new product is brought on site.  This includes any formulation change or name change.  Water quality management companies often tweak and adjust proprietary chemical formulations.  It is imperative that outside contractors understand that EHS personnel must be informed when chemicals change and that they must provide an updated SDS as soon as the chemical is on site.

Safety First

The EHS Manager must have a process to inform all contractors of safety expectations.

• • • Does your facility require all open hazardous materials to be stored on secondary containment pallets? If so, then contractor chemicals must also be stored in accordance with facility operating procedures.
    • Show contractors where drains are located and provide explicit instructions regarding your facility’s notification process for any/all spills.
    • Make sure contractors fully understand the expectations for safety and that deviations are unacceptable.
    • For construction materials brought on site temporarily, inform contractors that they are responsible for the removal of all unused materials once the project is complete.
    • If the contractor is using spray paint or other products in aerosol cans, make sure they know the proper disposal procedures for those “empty” cans and ensure that those containers don’t end up in the general trash. Aerosol cans in the general trash can lead to hazardous waste violations and/or fires.  Don’t let an outside contractor be the reason your general trash waste hauler raises your prices because they found hazardous materials in your waste stream.

Overall, it is crucial to all team members’ safety for the company to know exactly what materials are in the facility.  It is vital for the EHS manager to teach outside contractors the business’ expectations and to periodically check that they are following the requirements. Jacob Keating is an Environmental Specialist at Cornerstone working primarily with clients in the area of air emissions inventories, contingency plans, spill prevention control and countermeasure (SPCC) plans, stormwater plans and full facility environmental compliance assessments.