 Figure 1 Author: Richard DiNitto
Within any commercial, industrial, warehouse, or other business operation, regardless of size, paint storage is regulated by the Occupational Health and Safety Administration (OSHA), National Fire Protection Association (NFPA), and often your municipality. Not all paints are the same and we often come to think of them as relatively safe and not related to our typical chemical management approaches, such as with solvents or oils. However, many paints are considered flammable, and as a result, come under OSHA Rules 1910.106 and 1926.152 Flammable liquids. Paint storage requirements are based on flammability and flash points. Oil-based paints are considered flammable, while latex-based paints are not considered flammable. NFPA considers paints to be a Category 3 Flammable Substance, the latter classification having a flash point that ranges from 73°F to 140°F (see Figure 1). Storage of paint containers follows some simple rules, though complexities exist. Storage requirements include:
The Isosceles Group is retained to develop, implement and maintain Occupational Health & Safety (OHS) and Environmental Management Systems (EMS) at industrial and commercial facilities. It also manages various EHS issues that affect the operation and expansion of such facilities. If you would like The Isosceles Group to assist with EHS management at your facility, please contact Richard DiNitto at [email protected] or (617) 330-2800.  Authors: Richard DiNitto and Amanda Adams Bacterial growth in water-based systems and environments in common commercial and industrial buildings can often lead to an outbreak of Legionnaires' disease, a severe and often lethal form of pneumonia. The disease is caused by the presence of Legionella pneumophila bacterium. The bacterium in water-based systems results in up to 18,000 people each year becoming infected, with as many as 1,800, or 10%, proving fatal. Flu-like symptoms such as coughing, fever, headache and shortness of breath are common. While a substantial number of people may die from the disease, it is highly treatable with antibiotics if caught in the early stages. Facilities with water-based systems or environments should implement a periodic testing program to ensure that the bacterium are either not present, or at levels that are below published guidelines. When detected at elevated levels, prompt action on the part of the property owner or building manager is warranted. Easy and cost-effective solutions are available to eliminate the bacteria. Common locations that Legionella will grow include:
The CDC has published a handy Fact Sheet on the disease, which is available for free at: https://www.cdc.gov/legionella/downloads/fs-legionnaires.pdf. Regular testing of these features can help control and eliminate any bacteria growth. Depending on your operation’s features, recommended testing frequencies may vary. Many facilities will test between one to two times per year, typically in the spring and early fall. When testing for the first time, it is highly recommended that all sources be tested and not just a representative portion. Once the results from the initial testing are obtained, a reduced testing frequency on all sources can be made. Unfortunately, in reviewing water testing results, there are no federal or state-level regulatory standards for comparison, only guidelines for remedial action. A handy guide for comparison by some example water sources is shown below:  Since growth of Legionella is controlled largely by temperature and water free of compounds not toxic to them, treatment is easy and effective. While the bacterium will die above 122 degrees F, they will become dormant at colder temperatures (< 68 degrees F).
Cleaning and disinfecting your water systems, and using a biocide application, is the most effective remedy in controlling and eliminating Legionella. While there are no enforceable regulatory levels, some states and municipalities have established mandatory inspection, testing, cleaning, and disinfection requirements, as well as requirements for registration of possible sources. Our staff can assist you in identifying any local agency registration and inspection requirements, as well as providing further information on a testing regime and disinfecting program. The Isosceles Group is retained to develop, implement and maintain Occupational Health & Safety (OHS) and Environmental Management Systems (EMS) at industrial and commercial facilities. It also manages various EHS issues that affect the operation and expansion of such facilities. If you would like The Isosceles Group to assist with EHS management at your facility, please contact Richard DiNitto at [email protected] or (617) 330-2800.  Author: Richard DiNitto
Working on a roof can be a dangerous activity and is often considered part of an overall Fall Protection Program. Fall protection is one of the most commonly cited violations by the Occupational Health and Safety Administration (OSHA). Nearly 900 people die annually in the US from falls from a roof. Care in how you perform roof work is critical to your overall safety programs. Within the US, OSHA establishes requirements for roof work under Rule 1910.28 Duty to have fall protection and falling object protection. Rule 1910.28 establishes that an employer must ensure that each employee on a walking-working surface (such as a roof in this case) with an unprotected side or edge that is 4 feet (1.2 m) or more (for general industry or 6 feet or more for construction work) above a lower level is protected from falling by one or more of several specified control measures:
Under the Rule, the distance from the edges of the roof dictates which systems must be in place and what allowances may be acceptable:
A Designated Area is defined by OSHA as "A distinct portion of a walking-working surface delineated by a warning line in which employees may perform work without additional fall protection."
These exceptions for using a designated area or not having to enforce a fall protection plan requires that the work is both temporary and infrequent. These terms are defined as:
As with any work activity that has inherit risks and safety concerns, a proper hazard evaluation or risk assessment to determine the best and safest approach is warranted. While the information provided above is a good overview and guidance for safe work on a roof, the regulatory rules cover additional parameters and issues that you need to consider in your roof work evaluations and program. Consultation with roof safety experts is strongly recommended. The Isosceles Group is retained to develop, implement and maintain Occupational Health & Safety (OHS) and Environmental Management Systems (EMS) at industrial and commercial facilities. It also manages various EHS issues that affect the operation and expansion of such facilities. If you would like The Isosceles Group to assist with EHS management at your facility, please contact Richard DiNitto at [email protected] or (617) 330-2800.  Author: Richard DiNitto Onsite oil, diesel, and related liquids may require that you implement a government-mandated spill management plan in the United States when certain conditions are met. Many people are not aware that if you have 1,320 gallons or more of oil and related liquids “combined” in above-ground storage containers (or greater than 42,000 gallons “combined” in underground storage tanks), you may have to develop and put into place a Spill Prevention & Countermeasures Control (SPCC) Plan under the Oil Pollution Prevention Regulations (40 CFR 112). The second criteria for establishing an SPCC Plan is that a release from the above storage could impact “navigable waters” and “adjoining shorelines”. This is a more difficult one to address and requires greater knowledge of your facility’s location in relation to surrounding surface water bodies and channels. Even onsite drainage ditches that channel runoff to nearby streams, etc., could place your operation within this requirement. While many facilities may not routinely store any oils or related liquids, such as diesel, onsite for general use, they often forget to take into account emergency back-up generators. Just two of these generators can have a combined storage capacity of greater than 1,320 gallons. It is important to note that it is the “combined quantity” of all storage onsite that counts, and not the size of just the largest tank. Two tanks of 750 gallons will exceed the threshold for application of this regulation. If you meet the applicability requirements of these regulations, then a SPCC Plan must be prepared and certified by a professional engineer unless:
The contents of the SPCC Plan are detailed within the regulations, but broadly must contain the topics in the table below. The SPCC Plan must be maintained at the facility if manned 4 hours/per day or more, or at the nearest field office if manned less than 4 hours/per day. It is also required to be reviewed and updated every 5 years, or within 6 months of any material changes.  The Isosceles Group is retained to develop, implement and maintain Occupational Health & Safety (OHS) and Environmental Management Systems (EMS) at industrial and commercial facilities. It also manages various EHS issues that affect the operation and expansion of such facilities.
If you would like The Isosceles Group to assist with EHS management at your facility, please contact Richard DiNitto at [email protected] or (617) 330-2800. |
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November 2019
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