We are trying to prepare for an OSHA inspection, and would like to develop a chemical spill preparedness plan. What advice can you give us?
The Safety Exchange Says: Spill management falls mostly under EPA guidance and rules, although an OSHA inspector would be pleased to see that you have developed a spill management plan. OSHA is mostly concerned with worker safety, while the EPA is focused on environmental impacts.
The first thing to do when planning for a chemical spill is to know what chemicals you are dealing with, what their hazardous behaviors are, and what strategies best mitigate those hazards.
The recommended starting place for hazardous behavior is the Safety Data Sheet (SDS, formerly, MSDS). Read through carefully and you will find mention of primary ingredients, incompatible chemicals, and spill management recommendations. Some SDSs are better than others. Some will give sweeping general advice, and others will provide detailed recommendations. If you find the SDS information lacking, contact your chemical manufacturers and ask them for specific advice on spill management.
You will typically need to know if the material can be washed down into floor drains with ample water (“dilution” or “dispersion”), if it should be mixed with another chemical (“neutralization” or “deactivation”), or whether you should try to stop the movement of the product (“isolation”, “absorption”, or “adsorption”). Be sure to understand what personal protective equipment (PPE) is appropriate and be sure to have those supplies on hand and accessible. There may be other recommended pieces of equipment, such as secondary containment pallets, spill absorbers, etc.
A critical, and often overlooked, part of spill management is documented training. Once you have developed your procedure(s) and have the necessary supplies, conduct a mock spill cleanup using water as the spill. Make sure your staff are able to follow the procedures. Modify the written procedure if you discover a step that doesn’t work or is to difficult to implement. Another important part of training is to learn when to try to tackle the cleanup with your own staff, and when to call the local fire department hazmat team.