As you move through your career, you may find yourself responsible for managing hazardous materials (hazmat) and controlling associated risks. That’s why it is important to understand the basics even if you aren’t working with hazmat today, including the meaning of the diamond-shaped symbols you could encounter on the job.
Our Fire Protection and Public Sector Practice Specialty communities presented a webinar by Christopher Butts, P.E., CFPS, ARM, a senior property risk specialist with Sompo International, who shared his insights on how to build and implement an effective hazmat safety program.
Identifying and Classifying Hazardous Materials
Multiple sources define hazardous materials, including the International Building Code, the International Fire Code and the National Fire Protection Association, but the theme among these definitions is that these materials pose physical or health hazards.
While there are multiple categories for those that pose physical hazards, they are largely classified as flammable and combustible by their flash point and/or boiling point. For example, a flammable material may be classified as Class 1A (e.g., acetaldehyde), Class 1B (e.g., isopropyl alcohol, gasoline, acetone and methanol) or Class 1C (e.g., turpentine). A combustible material is classified as Class II (e.g., formaldehyde, mineral spirits and primer thinner), Class IIIA (e.g., diesel fuel and kerosene) or Class IIIB (e.g., motor oil and hydraulic oil).
Materials that pose health hazards are defined by the point at which they constitute a lethal dose by weight or volume. These materials are classified as toxic (e.g., chlorine and ammonia), highly toxic (e.g., formaldehyde and nicotine) and corrosive (e.g., hydrogen peroxide and sulfuric acid).
Taking all this into account, the red, yellow, white and blue diamond-shaped FISH diagram is a visual way of classifying hazardous materials:
- F: The red diamond indicates the fire hazard flash point temperatures.
- I: The yellow diamond indicates instability points.
- S: The white diamond is the specific hazard type (e.g., oxidizer, acidic, alkali, corrosive).
- H: The blue diamond indicates the level of health hazard the material poses on a numeric scale.
It is essential to have safety data sheets (SDS) on all hazardous materials present in a facility. An SDS uses 16 categories to provide information on each material, including the Chemical Abstracts Service (CAS) number, composition information, firefighting measures, handling and storage information, and physical and chemical properties such as boiling and flash point and toxicological information.
Butts also advocates using electronic programs such as the Hazardous Materials Expert Assistant (HMEX) program for example. It provides information similar to what you will find on an SDS, but it includes more information and classifications tied to international fire codes to help you consider maximum allowable quantities.
Locating Hazardous Materials in Acceptable Quantities
While hazardous materials can be found everywhere, including in our homes, safety professionals must know their quantity and location in a facility so they can be managed appropriately. To do this, safety professionals must consider the maximum allowable quantity (MAQ) and control areas.
To determine the MAQ, you can consult IBC Table 307.1(1). For example, a company may have 30 gallons of a Class IA flammable liquid. But an organization can increase its storage capacity by 100% if the building is fully sprinklered and by another 100% if approved storage cabinets are used. These actions would bring the total MAQ to 120 gallons.
What happens if MAQ is exceeded? The building will change to a high-hazard occupancy, which includes H1 through H5. This designation carries additional safety requirements, such as:
- Spill control
- Secondary containment
- Mechanical or natural exhaust ventilation
- Mandatory, often robust sprinkler protection
- Explosion control
- Standby or emergency power
- Limit controls
- Emergency alarms
“An organization wants to avoid becoming an H occupancy as much as possible,” Butts says, mostly due to cost implications.
To do so, an organization can use multiple control areas, which each carry individual MAQs, because they are separated by a fire-resistant barrier. These barriers include a fire wall or fire barrier — the requirements of which can be found in IBC sections 706 and 707. For more information on the design and number of control areas, consult IBC Table 414.2.2.
Developing a Comprehensive Hazmat Program
“The owner needs to know what they have and where it is, what those hazards are and what the protection strategies are,” Butts says. “This is where hazmat safety programs come into play.”
When hazardous materials are located on premises and are subject to permits or the requirements of a fire code official, the following rules apply and can be compiled into a hazmat safety program.
Safety Data Sheets
Not only are SDS required by OSHA, but they also must be made readily available for each hazardous material on site and may be required for permit submission.
Individual containers, cartons or packages of hazardous materials must be marked or labeled so you can look at them and understand what they are. Buildings, rooms and spaces containing hazardous materials must be identified with warning signs.
The individual responsible for the operation of areas in which hazardous materials are used should lead the hazmat training program.
- This person must be familiar with the chemical nature of the materials and the appropriate mitigating action necessary in the event of a fire, leak or spill.
- Responsible persons must also be designated and trained as liaisons to the fire department. “This is really critical,” Butts says.
- The liaison must be able to aid the fire department in preplanning emergency responses and identifying the locations of hazardous materials.
- The liaison must have access to safety data sheets and be knowledgeable in emergency response procedures.
Hazardous Materials Inventory Statement
The hazardous materials inventory statement has two parts: A summary and inventory report.
- Summary report: Addresses control areas or high-hazard occupancy areas, amounts in storage, hazard classes, inventory amounts and the MAQ per control area.
- Inventory report: Includes hazard class, chemical name, common name, CAS number, location and similar details.
Hazardous Materials Management Plan
The hazardous materials management plan includes three elements:
- Facility Site Plan: Shows the building and grounds, access to each storage area, emergency equipment, meeting location for emergency responders, purpose of other areas in the building, location of all above-ground and underground tanks, hazard classes in each area, location of all control areas, and group H occupancies and emergency exits.
- Emergency Action Plan: Includes the assessment, treatment and actions. The plan must be constantly monitored for changes in quantities and types of materials.
Facility Closure Plans
Facility closure plans include contingencies for several scenarios, such as:
- Facilities that are temporarily out of service but must continue to maintain a permit and be monitored and inspected.
- Facilities for which a permit is not kept current or is not monitored and inspected on a regular basis are deemed permanently out of service and closed in an approved manner. The authority having jurisdiction may require a closure applicant to provide a facility closure plan.
The plans must demonstrate that hazardous materials used in the facility will be transported, discarded or reused in a manner that eliminates the need for further maintenance and any threat to public health and safety.
Written Hazard Communication Program
There must also be a written hazard communication program that complies with OSHA 1910.1200(e) and includes:
- Labels and other forms of warning
- Employee information and how training requirements will be met
Finally, Butts recommends that safety professionals seek out professional certifications and training programs because the more knowledge, the better the risk control for the organization and the safer everyone will be.
“By implementing and applying and maintaining these foundational building blocks, EH&S staff will be better positioned to protect their properties and people,” Butts says.
Understanding Risk Management and Assessment
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