Question: Our employees are sometimes required to clean spill tanks or overflow tanks at gas stations. Are employees supposed to have special training for this activity?
Answer: Any situation involving the cleanup of hazardous materials can spurn the need for specialized trainings. Given the scenario above, here are a few things that you may need to consider.
Hazard Communication
It is the employer’s responsibility to teach their employees about any hazards that they may encounter on the job, as well as the procedures to follow to work safely. This includes being exposed to flammable liquids. In addition to training, employees need to have access to Safety Data Sheets at all times.
Emergency Spill Response
Employees who will clean up incidental spills need to be aware of the hazards the spilled liquids present, know how to properly protect themselves and know how to use response tools and equipment. The Occupational Safety and Health Administration (OSHA) allows employers to cover incidental spill response training with hazard communication or other safety trainings.
However, if the employees will be responding to emergency spills (those that pose a significant threat to the safety and health of employees and others in the immediate vicinity), they need to be trained by a qualified individual to meet the requirements of OSHA’s Hazardous Waste Operations and Emergency Response (HAZWOPER) Regulations.
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It is important for all employees to understand the difference between an incidental and an emergency spill and know how to get help if they are not comfortable or properly trained to clean up a spill themselves.
Confined Space
Tanks that are large enough to enter typically meet OSHA’s definition of “confined space.” If the employees will physically enter these tanks to clean, repair or otherwise service them, they will need to be trained on confined space hazards and entry. Additionally, because the residual fuel can present a fire or explosion hazard in the tank, the tank may be considered a “permit entry confined space.” In addition to training for the personnel who will enter, a rescue team must also be trained, able and ready to assist with rescue functions any time an employee is in the tank.
Managing Spill-Related Wastes
Any time a waste is generated, it is the employer’s responsibility to determine if the waste is hazardous. Wastes can be hazardous if they are on any of the Environmental Protection Agency’s (EPA) lists or if they have a hazardous waste characteristic.
Chances are good that an absorbent that has been used to clean up a fuel spill will exhibit the ignitability characteristic. If this is indeed the case, it means that these wastes will need to be handled, shipped and disposed of properly. The Department of Transportation (DOT) requires anyone who handles, packages, marks or offers hazardous materials for shipment to receive training that describes how their activities affect hazardous materials shipments.
Other Considerations
Additionally, you may also need to train workers on other specific safety or environmental conditions that they may face while cleaning up the fuel spill. For example, if they will work outdoors in the summer or winter months, they will need to be aware of the signs and symptoms of heat– or cold-related injuries.
Taking the time to provide specialized trainings will give them the knowledge that they need to do their jobs safely so that they can prevent injuries and death.
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