HAZARDOUS MATERIAL MANAGEMENT PROGRAM

STANDARD OPERATING PROCEDURES

Hazardous Waste Management Plan: This document is not intended to be a

comprehensive discussion on Hazardous Materials/Waste, but will focus on practical
considerations and requirements for the handling, packaging, marking, storage, spill
prevention/remediation, and disposal of hazardous materials within ABCD’s
operational area of environment. Hazardous material handling procedures include the
collection, segregation, storage, and disposal of hazardous waste and materials. This
is not an all source compilation of regulatory guidance. It is intended to provide simple
straight forward procedures that will meet federal and international standards for the
protection of individuals and the safeguarding of the environment.

A. Duties and Responsibilities

1. Program Manager: Ensures the Hazardous Material handling procedures are

followed in accordance with ABCD policies and Standard Operating Procedures.

2. HAZMAT Handler: Reports directly to the Program Manager and is responsible

for complete oversight of the hazardous materials handling process. Conducts
inspections of storage and handling activities, performs regular hazardous waste
inventories, provides initial and continuing training on material handling procedures,
and advises management on changes to hazardous materials policies. The individual
will be a certified hazard material handler IAW U.S. standards or through an
international certification recognized by the U.S. Government as being equal to or
better than the U.S. standard for certification.

3. Operations Supervisor: Works with the HAZMAT Handler to implement

hazardous materials handling procedures within the entire operational environment.
Ensures that hazardous materials are stored only in designated areas and in as few
places as possible in order to facilitate oversight.

4. Team Leaders: Responsible for the direct oversight of their team

activities. Ensure that all team members are trained in the handling of
hazardous materials, that they comply with all ABCD directives and
procedures, and they use all appropriate safety equipment.

B. Hazard Determination: Hazard determination is the process of evaluating

available evidence in order to determine if a material is hazardous pursuant to the
Occupational Health and Safety Administration’s (OSHA) Hazard Communication
Standard (HCS). This evaluation identifies both physical hazards (e.g., flammability
or reactivity) and health hazards (e.g., carcinogenicity or sensitization). The hazard
determination provides the basis for the hazard information that is provided on
hazardous material tags, signs, and employee training. Hazard determination does not
involve an estimation of risk. Hazard refers to an inherent property of a substance that
is capable of causing an adverse effect. Risk, on the other hand, refers to the
probability that an adverse effect will occur with specific exposure conditions. A
substance will present the same hazard in all situations due to its innate chemical or
physical properties and its actions on cells and tissues. However, considerable
differences may exist in the risk posed by a substance, depending on how the
substance is contained or handled, personal protective measures used, and other
conditions that result in or limit exposure.

C. Hazardous Wastes Characteristics: The four common characteristics of

hazardous wastes are listed below:

1. Ignitability - wastes that could catch fire during normal handling.

Dangers from such fires not only include heat and smoke but also the spread of
particulate detrimental to health.

2. Corrosivity - wastes that attack standard materials, thereby

requiring special types of containers. These wastes must be
segregated because they could dissolve toxic contaminants from
other wastes.

3. Reactivity (explosiveness) - wastes that may react

spontaneously and vigorously with water and air during normal
handling. These wastes are unstable to shock or heat, and may explode and generate
toxic gases.

4. Toxicity - wastes containing toxins which, if released in sufficient quantities,

pose substantial hazard to human health or the environment.

D. Hazardous Material Minimization: Hazardous waste minimization is the most

effective strategy for reducing hazardous waste generation. This is done by
substitution of less hazardous materials, process changes, and reuse or other recovery
procedures as applicable. In order to protect the environment and reduce the levels of
hazardous wastes, ABCD has developed its own Hazardous Waste Minimization
policy. The objective of the A-HAZMIN policy is to reduce or eliminate excess
volumes, or the toxicity of hazardous materials within its operations. This task will be
accomplished through proactive management and oversight. Whenever possible,
materials will be recycled, but otherwise all waste products will be disposed of in
accordance with applicable U.S. and local laws and regulations.

1. ABCD will procure Hazardous Materials in the smallest practical size and
quantity. Although larger containers may cost less, these costs are mitigated through
the reduction in hazardous waste disposal costs and the added safety issues revolving
around long term storage.

2. ABCD will maintain a sensible stockage level. Hazardous Materials will be

ordered using the equipment TM and in the minimum amounts necessary, based on
equipment usage.
 3. Open containers will be used first.

4. No hazardous materials will be stored in the work area. Once the task requiring
the hazardous Material is completed any left over material will be returned to the
designated storage area.

5. ABCD will substitute non-toxic materials for toxic materials when ever possible.

E. Hazardous Waste Handling, Storage, and Disposal: Segregation is one of the most
important factors required to ensure a successful hazardous waste management program.
To minimize contamination, operational personnel will use the original empty product
can or container (provided it is in good condition) to collect the hazardous wastes
whenever possible. Containers used will be small enough to easily be handled and filled-
up in less than 90 days. Longer term collection and storage increases the risk of
accidents exponentially.

1. Flammable hazardous wastes are to be stored in Department of

Transportation (DOT)-approved containers. Metal to metal contact
and the use of electrical devices while working with stored wastes may
cause sparking. Storage cans will be properly grounded when
transferring flammable wastes, and while being used to store flammable solvent
wastes.

2. Hazardous wastes may be stored onsite up to 90 days after the date of generation.
The storage date will start when a waste is first placed into a container or unused
material is declared as waste. An exception to this policy is if wastes are collected at
or near the point of generation. In this case, the storage date begins the date the
container is full or the quantity of hazardous waste exceeds 55 gal, or the quantity of
acutely toxic waste exceeds 1 qt.

3. Hazardous wastes must be packaged correctly so that they can be transported and
stored safely pending disposal. Wastes will be packaged in tightly closed containers,
either in the original container or one approved by the DOT. Most wastes should be
collected in the original container. The containers must show no signs of
deterioration or damage. The container’s construction material must be chemically
compatible with the contents.

4. A good segregation program requires proper identification of hazardous waste for

both collection and subsequent handling. Containers will be tagged with the name of
the substance, and the beginning date of initial storage. Hazardous waste containers
will be segregated from other materials and signs will be placed along the limits of
the storage areas warning of the potential danger. All hazardous waste containers will
be color coded to reflect one of the following categories of materials:
 a. Flammable – Red
b. Toxic – Green
c. Corrosive – Yellow
d. Reactive – Blue

5. ABCD will arrange with local contractors for the disposal of hazardous waste in
accordance with U.S. and local laws, Contracting Officer guidance, and applicable
ABCD hazardous waste and environmental policies.

F. Collection Procedures: The procedure for collecting and handling the incoming
hazardous waste consists of four major steps:

1. Make sure the container is not leaking and the contents are
identified;

2. Identify the hazard category for the waste;

3. Document the type, amount, and destination of the waste; and

4. Properly pack the waste into a drum of similar materials.

Guidelines for packing drums are summarized below:

1. The waste must be contained in sealed, sound, and leakproof containers; the
composition of the containers must not react with the stored waste.

2. The drum must meet DOT specifications and not have a volume greater than 110
gallons.

3. All of the wastes contained in the drum must be compatible. Reactive wastes,
other than cyanide or sulfide-bearing wastes, must be rendered non-reactive before
being packaged in the drum.

G. Transportation: Before drums containing the hazardous waste can be transported,

they must be labeled in accordance with the DOT regulations and be recorded on a
Uniform Hazardous Waste manifest. All shipments must be made in compliance with
U.S. and local laws and the Contracting Officer’s guidance.

H. Spill Mitigation: To lessen the safety risk to personnel and limit the damage to the
environment, definitive steps must be taken as soon as a hazardous waste spill is
identified.

1. Treat a chemical/POL spill as an emergency.

 2. If possible, shut off the source of the spill by righting containers, plugging holes
and shutting valves.

3. Immediately report any spill to:

a. The shift Team Leader

b. The HAZMAT Handler

And give the following information:

• Location
• Type and size of spill
• Any spill response procedures initiated
• Point of Contact
4. Isolate the area; prohibit vehicles and personnel from entering.

5. Contain the spill using sand bags, dirt, dry sweep, rags, etc.

6. Prevent the spill from entering drains or any water source.

7. Clean up the spill and dispose of contaminated materials IAW Hazardous Waste
Handling procedures.

I. Education and Training: Handling of hazardous waste requires specialized

knowledge and training. Proper training is essential for maintaining both a safe working
environment and a work force capable of dealing with emergencies related to hazardous
substances. Failure to follow appropriate procedures may lead to fire, explosion, or spill,
and the situation may be worsened by the absence of correct and timely response to the
situation. Training can help prevent emergencies and the corresponding losses caused by
property damage and personnel injury.

1. HAZMAT Handler – The HAZMAT Handler serves as the primary trainer for all
other ABCD personnel in safe handling procedures. The HAZMAT Handler will
receive training in general Hazmat handling, spill or contamination remediation and
prevention, and applicable U.S. laws and regulations. He will be a certified hazard
material handler IAW U.S. standards or through an international certification
recognized by the U.S. Government as being equal to or better than the U.S. standard
for certification.

2. Operational Personnel: All personnel assigned to ABCD Operations will receive

initial and refresher training in the handling, storage, marking, and spill remediation
of hazardous materials. Training will be annotated in the individual’s personal
employee file maintained by the administrative staff.

J. References:
1. Occupational Safety and Health Act (OSHA), 29 CFR 1910.1450.
2. Clean Water Act, 40 CFR 110-120.
3. Toxic Substances Control Act (TSCA), 40 CFR 760.
4. Occupational Health and Safety Standard 28 CFR 1910.1200, Hazard
Communication.
5. Occupational Safety and Health Act (OSHA), 40 CFR 265.316, Storage of Hazardous
Waste
6. Joint Service Storage and Handling of Hazardous Materials, TM 38-410