Oil, lubricants, solvents and other hazardous substances are regulated by OSHA (Occupational Safety and Health Administration) under the Hazard Communication standard - more commonly called HazCom or the “Right to Know Law,” the Hazardous Waste Operations and Emergency Response standard (HazWoper) and more specific standards such as Flammable and Combustible Liquids, as applicable. The U.S. EPA regulates used oil, hazardous waste and hazardous substances under a variety of regulatory programs.
If you have hazardous substances in your shop, OSHA requires that you have a written program addressing how the shop complies with the HazCom standard 29 CFR 1910.1200. The program must explain how you meet the requirements for labeling, material safety data sheets (MSDS) and employee training.
Year in and year out, OSHA cites violations of the HazCom Standard more than any other requirement.
The HazCom written plan must include a chemical inventory – a list of all chemicals that are produced, imported or used by your shop – using the identity on the chemical label, whether a chemical name or trade name. It should also include the chemical’s Chemical Abstracts Service (CAS) number.
When chemical orders arrive, check for MSDS and compare them to the containers to make sure everything is properly labeled. The name on the container label and MSDS should match. Do not allow technicians to use any chemicals that don’t have an MSDS at your shop.
OSHA requires every container of hazardous chemicals in your facility to have a label. This label may already appear on the incoming container, or the shop can use an in-house labeling system such as the National Fire Protection Association’s or the Hazardous Material Identification System.
This requirement also applies to portable containers, if the contents are not immediately used by the employee who transferred the chemical.
One other label to be aware of is the U.S. Department of Transportation (DOT) label, if there is one. This label must remain on the container in accordance with the retention provisions of HazCom standard 29 CFR 1910.1201.
Improper storage of chemicals, or storing incompatible chemicals together, can cause unwanted reactions, fires or even explosions. Read the MSDS and the container label for information on proper storage.
The Flammable and Combustible Liquids standard 29 CFR 1910.106 generally requires that all flammable or combustible liquids and aerosols be kept in a flammable storage cabinet, inside a storage room or flammable storage warehouse.
There is an exemption for incidental storage, which allows employers to store up to 25 gallons of Class IA and 120 gallons of Class IB, IC, II or III in any one “fire area” of the facility outside of a flammable storage cabinet or storage room. This would apply to substances technicians are using or store around their toolboxes or workbenches.
Your local or state fire code may dictate other storage requirements, and may cover how you store such items as aerosols, so check with your local fire authorities.
Container types – Under OSHA regulations, drums or containers used to store hazardous chemicals must be in good repair and compatible with the chemical placed inside. Containers for flammables and combustibles must be approved, which means that they have been tested by a nationally-recognized laboratory or approved for use in transport by the DOT.
For used oil storage, EPA is clear that storage must be in tanks or other containers subject to regulation under 40 CFR 279. Above-ground tanks and containers must be:
- In good condition (no severe rusting, apparent structural defects or deterioration).
- Free from leaks (no visible leaks).
- Labeled or marked clearly with the words “Used Oil.”
Underground storage tanks for used oil must:
- Have fill pipes labeled or marked clearly with the words “Used Oil.”
- Meet the Underground Storage Tank standard (40 CFR 280) whether or not the used oil exhibits any characteristics of hazardous waste.