Frequently Asked Questions
- What training is required if I use or handle chemicals at SLAC?
Chemical workers at SLAC are required to take Course 105 Hazardous Materials. If you handle, store or generate hazardous waste you must take Course 105R Hazardous Waste as an annual refresher.
- What are my responsibilities as a supervisor or manager of chemical workers?
Managers and supervisors will:
- Select, implement, and maintain appropriate measures for controlling work area hazards associated with hazardous materials
- Provide applicable PPE at no cost to employees
- Ensure hazardous materials are properly labeled
- Designate chemical asset custodians for their area of responsibility
- Provide any necessary inventory information to the hazardous materials program manager to support maintaining an accurate hazardous materials inventory for regulatory and compliance purposes
- Providing accurate and complete hazardous material inventory in each work area where hazardous materials are store or used. This can be accomplished through local inventories and/or SLAC inventory.
- Ensure personnel complete both ESH training and site-specific on-the-job training (OJT), including providing training to lab workers on non-routine tasks involving chemicals
- Ensure personnel comply with all safety controls
- Ensure that all personnel on all shifts have access to relevant MSDSs (either online or a hard copy)
- If required, ensure that appropriate emergency eyewash and shower equipment is available in the work area and that local exhaust ventilation is properly operating
- Know the location of hazard control and emergency equipment, inspect the equipment, provide for equipment maintenance, and notify appropriate personnel to repair or replace the equipment if it is missing, defective, or inoperative
Chemical laboratory supervisors, supervisory personnel responsible for the operations in laboratories designated under the CHP, will:
- Develop laboratory-specific procedures for their laboratories
- Sponsor safety meetings, including review of training as well as provide training to lab workers on non-routine tasks involving chemicals
- Monitor work practices on a daily basis
- Answer questions regarding safety procedures
- What types of chemical inventories are there and why are they needed?
There are different types of chemical inventories that meet different regulatory and management goals. The two that are currently being used at SLAC are the Hazardous Materials Inventory Statement (HMIS) and the HazCom inventory. The table below compares the similarities and differences:
|Area Of Concern||Fire Control Area or whole building||Work Group storage under control of one supervisor/manager|
|Threshold levels that must be considered||
- 55 gallons or 275 gallons aggregate- lubricating oils|
- 55 gallons or more - all other liquid hazardous materials including waste oil
- 500 pounds or more - solid
- 300 gallons - Propane used for heating
- 200 cubic feet or more- all other hazardous material gases
- Any amount of radioactive material that requires an emergency plan under Parts 30, 40, or 70 of Title 10 CFR or applicable quantities specified above, whichever amount is smaller.
|No lower threshold limit -
Includes any hazardous material except:|
- Materials whose hazardous components are inextricably bound in a product and cannot be released,
- Consumer products used for the purpose intended by the manufacturer in quantities not greater than those purchased by the average consumer must be inventoried.
|Does it include hazardous waste?||Yes||No|
|Is there a quantitative element?||Yes - Maximum and average amount for each separate chemical or product stored or used||No - it consists of a list of chemicals used/stored and MSDSs |
|Driver||Emergency Management and Community-Right-to-Know||Worker protection and Right-to-know|
|Driver||HazMat Program manager for site; Building manager||Work Group supervisor|
|CMS/Haas support||Partial - for chemical purchases, does not include process tanks, hazardous waste, or oil filled equipment||Partial - for chemicals purchased since August 2005. Does not include legacy chemicals purchased prior to that date. Does not include chemicals that came from another work area and moved.|
|Documentation||Submitted to the Santa Clara County CUPA and Palo Alto Fire Department at least annually.||Must be able to demonstrate compliance when asked. |
- Do I still need to keep a MSDS binder in my work area?
The HazCom requirement for MSDS availability is met by the on-line MSDS platforms. However, in the event of a power outage this resource will not be available and a back-up is needed. Keeping binders of MSDSs in your work area meets this need, though it isn't the only way. Alternatives can include battery powered lab tops or a hard copy filing system. Whatever way you choose to back-up your area MSDSs it is critical that your employees know how to access and use it.
- How do I generate a HazCom inventory using the CMS?
- What is the Chemical Storage Asset Custodian Program?
The Chemical Storage Asset Custodian program is designed to support the safe storage and handling of chemicals at SLAC. The program has three elements:
Identified custodians for each storage asset (tank, flammable or chemical cabinets, fume hood, gas racks...). The custodian's contact information should be on each asset or in a prominent location for a storage area.
Monthly documented inspections of chemical storage assets. Custodians will inspect their assets to document status, observe and resolve potential problems, and to verify the location is captured on the CMS map.
Mapping of each storage area. All storage assets should be on the CMS map. If, on review, the custodian notes the area or asset isn't accurately captured on the map they should contact Stafford McCaskill to make any corrections.
- What are my responsibilities as a Chemical Storage Asset Custodian?
The responsibilities of a custodian include:
- Ensuring compliance with the chemical storage requirements of Chapter 40
- Maintaining documentation about the location, inspection, and testing of chemical assets under their control
Training Requirements: Custodians must take Course 105 Hazardous Materials. If hazardous waste is stored in their asset/area, they must also take Course 105R Hazardous Waste annual refresher
Management Requirements: Custodians are responsible for the management of the asset. This may include securing the asset and limiting use to specified employees, or creating a gate keeper role that would require employees using the asset to get approval from the custodian.
Proficiency Requirements: Custodians must know what is stored in their asset and who uses it. They need to be able to determine if a material is abandoned, expired, or damaged and take steps for its removal. Custodians need to understand how to determine chemical compatibilities and any special storage and handling requirements for the materials in their charge. They need to know what resources are available to them to meet these responsibilities.
Monthly Inspections: Using this knowledge they inspect and assess their asset and document their finding monthly.