Q&A: Over-the-Counter Medications
Recently, one of our subscribers asked the following question:
Category: Q&A
Biennial Report
Q. We store Lead Metal Scrap on our property and sell it to recyclers. Would I mark Item 12 “Notification of Hazardous Secondary Material Activity” on the 2015 biennial report as “Yes” or as “No”?
SPCC Secondary Containment
Q. Is secondary containment necessary for storage containers under 55 gallons (i.e. 5 gallon buckets)?
Q&A: Pedestrian Travel Paths
Recently, one of our subscribers asked the following question: For pedestrian safety, how wide does a designated protected employee travel path need to be? What type of stationary protective guards are acceptable to prevent forklifts from hitting pedestrians?
SDS Requirements
Q. Can you provide some guidance on how to satisfy the requirements of the Safety Data Sheet (SDS) information without revealing the names or Chemical Abstracts Service (CAS) numbers of the chemicals we use in our mixtures?
Q&A: First responders
Are all companies required to have first responders? If so, how many, and what training is required for them?
Spill Reporting
Q. Would flavorings that contain small amounts of oil (for example, almond and hazelnut oil) count towards an inventory to determine Spill Prevention, Control, and Countermeasure (SPCC) applicability if they are stored in 55 gallon drums or greater?
Q&A: Rigid Splints Recordable?
Recently, one of our subscribers asked the following question:
TRI Reporting
Q. An EHS chemical, Sulfuric Acid, exceeds 500 pounds. Therefore aggregation of Sulfuric Acid containing compounds is required in TRI reporting. In that aggregation, are lab chemicals included or exempted?
Flammable Substance Threshold
Q. Would the risk management plan (RMP) flammable substance exemption include warehouses? We will store cans of foam containing isobutane. Will the RMP regulations apply?