OSHA HAZCOM Standard - What You Need To Know
OSHA HAZCOM Standard (Hazard Communication Standard)
During vacuum truck service operations, a safe work procedure must include the potential for chemical reactions and release of toxic gas or fumes. Workers must be aware of the variety of material that their vacuum trucks typically carry.
The key points of the OSHA HAZCOM Standard are:
1 Hazard Evaluation - There must be a list of all hazardous materials in the workplace.
2Labeling - Everything hazardous in the workplace must be labeled and indicated with the proper warnings.
3MSDS - Material Safety Data Sheets must be readily available for all hazardous materials.
4Worker Training - All employees that will be handling the material need training to be able to identify and handle all hazardous materials in the workplace.
5Written HAZCOM Program - There must be a written plan developed to clearly indicate to workers how the standard is implemented in their particular workplace. the plan needs to be completely implemented to be in compliance
OSHA has defined several communication standards to help vacuum truck owners ensure that their operators are aware of the hazards of what they are transporting. The following OSHA HAZCOM Standard list will help determine which OSHA training online courses will provide the required training:
- Hazard Communication OSHA 29 CFR 1910.1200;
- Flammable and Combustible Liquids, OSHA 29 CFR 1910.106;
- Hazardous Waste Operations and Emergency Response, OSHA 29 CFR 1910.120;
- Hazardous (classified) Locations, OSHA 29 CFR 1910.307;
- Air Contaminants, OSHA 29 CFR 1910.1000 and;
- U.S. DOT "Motor Carrier Safety requirements for proper hazard classification and manifesting of flammable liquids, approved container design, and periodic testing”, 49 CFR, Parts 171, 172, 173, 178, 179, 382, 383 and 390-397.
Before starting vacuum operations, worker’s must be aware of:
- The hazards that may be associated with the chemical and physical characteristics of the liquids being vacuumed and transported - they may be combustible, toxic or corrosive;
- The evacuation and rescue safe work procedure in the event of a toxic gas leak, that may also result in a fire or explosion hazard.
The OSHA HAZCOM Standard specifies that air quality monitoring must be continuous, specifically at the discharge area of the vacuum truck venting hose, to ensure there is no toxic vapor build up. Test equipment can include combustible gas indicators, suitable toxic gas testers, or hydrocarbon analyzers.
Before taking the truck on the road, operators must review the safe working condition of the tank and pumping equipment. They need to check that water tanks are full and the jetter hose doesn’t have any cracks or punctures. Cyclone separators, filter bag house, and tank interior must be clean and free of any materials that may react with new materials to be vacuumed or transferred.
Operators need to make sure that the materials being loaded into the tank are compatible with any materials that were previously loaded and that the mixing of these substances will not create toxic gas/vapor, heat, explosion or fire hazards.
- All department of transportation certified vacuum trucks and vacuum excavators are equipped with two emergency shutdown devices (ESD):
- A pushbutton ESD switch on the driver side of the unit, upon activation, will close all valves to the vacuum tank releasing vacuum pressure from hoses, fittings connected to the vacuum tank. For vacuum excavators, it closes the boom hose valve thereby eliminating vacuum from the suction tube.
- Diesel industrial vacuum trucks and hydro excavation trucks come with a manual shut off switch located in the cab plus an RPM limiting shut off.
Additional OSHA HAZCOM Standard Safety Guidelines
- Grounding the vacuum truck is essential when vacuuming contaminated muds or hydrocarbons whereby static electricity may trigger an explosion. Air movers should never be used on anything being removed with a temperature flashpoint of 140 Fahrenheit or less.
- Also, to ensure a continuous conductive path (eliminating static) from the vacuum truck through the jetter hose and suction nozzle all the way to the tank or source container, the entire vacuum transfer system should be bonded.
- Vacuum trucks handle hazardous materials therefore if the operator decides to make a repair inside the tank, caution should be exercised by wearing appropriate protective gear and following safe procedures.
- Driving safely with hazardous materials is very important. A fully loaded vacuum truck has reduced braking power and acceleration. Back up your truck with extreme caution or with a spotter.
Transfer Operations Safety
- Do not transfer fluids between trucks unless there is confirmation that no chemical reaction will occur;
- Position the vacuum truck to minimize exposure to any plumes of gases or fumes;
- Make sure discharge lines are large and long enough for safe operation;
- Position the lines away from workstations and workers; including shutoffs, valve handles, gauges, control panels, and suction hose attachment points. If at all possible, use a vertical exhaust bag to diverge exhaust gases from workers and ignition sources;
- Verify that air monitoring systems are operational to confirm that venting is safely monitored.
Things to Monitor
- Tank temperature gauges to identify potential chemical reactions.
- Tank pressure gauges to avoid over pressurizing tanks or creating excessive vacuum in supply tanks.
Tank level indicators to avoid overfilling:
- Reduce the introduction of air when pressure loading or unloading. Submerge the vacuum hose in liquid or reduce the speed of the vacuum pump when skimming or nearing the end of a load.
- Maintain a log of loaded fluids and any potential residue. This will help to avoid any chemical reactions from occurring by knowing what materials were previously transported. This log has to be readily accessible to amy truck operator.
- When possible, use gravity loading and unloading.
- When available, use a vapor recovery system to avoid venting tanks directly to the atmosphere.
OSHA HAZCOM Standard Provides for Worker Safety
- Workers need to be properly trained, alert and extra cautious when working with or in the area of the following hazards; pinch points, hotspots, rotating machines, automated machinery, loose clothing.
- MSDSs (Material Safety Data Sheets) need to be readily available for all materials being transported.
Always wear PPE (Personal Protective Equipment)
- Industrial vacuum trucks are hazardous; operators must realize vacuums can be very hazardous to life and limb.
During off loading, workers must stay out of the cab and shut off the engine if there are any flammable vapors.
- Prevent static and always ground the truck - for instance sucking grain dust may trigger a dust explosion.
- Drawing and vent material should never be mixed, unless the operator knows that there is no chance of a chemical reaction.
- Workers need to be given a site-specific orientation. All materials to be handled during the job need to be explained along with any risks involved. Safe handling procedures need to be explained. A summary of emergency handling procedures also needs to be provided.
- Workers need to be trained in emergency procedures that conform to OSHA 29 CFR 1910.120(q) and OSHA 29 CFR 1910.38(a). OSHA HAZWOPER training will provide this.
For further information on the OSHA HAZCOM Standard please refer to OSHA Training Online courses given by authorized trainers. The OSHA HAZCOM Standard is also taught through community colleges and employers.
Related article: OSHA Training Online
Related article: OSHA HAZWOPER Training
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