2
Environmental and Health
raw materials, etc.), storage and handling, disposal and shipping, and
recordkeeping. An industrial facility that does not have programs
addressing all four of these issues should essentially not be handling
hazardous materials.
The environmental and health-safety manager, referred to in this
textbook as an Occupational Safety Professional (OSP), must know what
his or her facility is purchasing, generating, storing, treating and
disposing of in order to effectively satisfy the "cradle to grave"
provisions of RCRA (Resource Conservation and Recovery Act). Good
recordkeeping and communication are essential to several key elements
of any pollution control and prevention program: emergency procedures,
contingency planning, and employee training. For example, if a caustic
line from a plating operation building breaks, how is the waste material
kept out of the storm sewer in order to prevent a NPDES (National
Pollutant Discharge Elimination System) violation and how large can the
spill be before it constitutes a reportable quantity (RQ) under CERCLA
(Comprehensive Environmental Response Compensation and Liability
Act)? Contingency plans must describe actions the facility will take to
minimize hazards in the event of a release and employees must be trained
to respond appropriately.
Well run organizations are those which have established formal
Safety and Hazardous Materials Management Programs. These programs
establish corporate policy, which addresses pertinent aspects of OSHA
(Occupational Safety and Health Act), TSCA (Toxic Substances Control
Act), CERCLA, SARA (Superfund Amendments and Reauthorization
Act), RCRA, the Hazardous Materials Transportation Act (HMTA), and
other applicable regulations. The need for an integrated program and
policy uniting everything from purchasing through use and disposal can
be demonstrated by considering what happens if a hazardous material is
purchased or generated without knowledge of the regulations. OSHA
regulations could be violated because precautions for employee exposure
are not taken, SARA could be violated because the requirement for
notification of the presence of listed material has not been met, and
RCRA regulations could be violated if waste
from the material is not
stored or disposed of properly. There are also potential violations of
other acts such as the Clean Air Act and Clean Water Act.
The OSP must become integrated into all aspects of a facility's
operations. A properly informed OSP helps limit the amount of a
hazardous material stored onsite, monitors the use of the material so that
 |  |  |