Waste Reduction Guide Photo Finishing Business

Waste Reduction Assistance Program Alaska Health Project April 1991

0199 1, Alaska Health Project

The Alaska Health Project The Alaska Health Project is a private, non-profit organization

established to provide information about occupational and environmental health. The Alaska Health Project has been assisting Alaskan businesses with hazardous material concerns since 1986. We can assist you in the proper management and reduction of toxics use. We can provide you with basic information on how to educate yourself and specific information on products and wastes. Our services are free and confidential. We are not a regulatory agency, and are not affiliated with any government agency. Call the Alaska Health Project at 800-478-2864 (or 276-2864 in Anchorage) to reach our hazardous materials hotline or Waste Reduction Assistance Pr0grZl.m.

Alaska Health Project 1818 West Northern Lights Blvd., Suite 103 Anchorage, Alaska 99517 1-800-478-2864 or (907)276-2864 in Anchorage or out of state

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Contents A. Wclste Reduction Why and how to reduce waste in any business

B. Photo Finishing Tips Tips for reducing waste in your business

C. Chemical Safety The basics of chemical safety and how to set up a hazardous materials management program

D. Environmental Regulations A basic introduction to waste regulations and regulatory agencies

E. Worker Right-to-Know Law What the right-to-know law is about, and what it requires

F. How to Read a Material Safety Data Sheet (MSDS)

G. For More Information Partial directory of emergency numbers, resource organizations, vendors and services

Appendices Profiting from Waste Reduction in Your Small Business A guide to help you identifjr, implement and evaluate an industrial waste reduction program

Understanding the Small Quantity Generator Hazardous Waste Rules: a Handbook for Small Business

Acknowledgements This manual is funded as part of the Response/Ability program. This

manual is designed to assist you in identifying and implementing waste reduction in your business. The Alaska Health Project, through a grant with the Charles Stewart Mott Foundation, designed the Response/Ability pro- gram to help your business manage toxic materials effectively. The purpose of the Response/Ability program is to respond to your business from the Alaska Health Project's Waste Reduction Assistance Program, helping your business improve the work and local environment to the best of its ability.

Researched and written by Kristine Benson, M.S., Margaret Drumm and David Kidd, M.S., P.E. Thanks to Kristine Benson for use of the cover photograph. Design by Margie Ann Gibson, Shooting Star Artworks. Printing by Color Art Printing Company, Inc. Special thanks to our local business and government reviewers.

A. Waste Reduction

Reasons Waste reduction makes sense for

any business. By reducing waste, you can increase your profit margin and enhance your community’s quality of life. Reasons to reduce waste include:

1. High disposal costs -- Waste disposal is becoming more and more expen- sive as landfill and incineration costs rise, and landfills run out of space with the increasing flux ofgarbage. Strict hazardous waste regulations and liability are driving disposal costs even higher.

2. Financial liability -- Generators of hazardous wastes are liable for their waste even after it is transported some- where else for disposal. This liability in- cludes potential mishandling by the trans- porter or disposal facility, and any future release of disposed wastes, such as a leak from a failed landfill containment system .

3. Public relations -- Waste reduction is perceived favorably by the community and can enhance a business’s public image. Potential pollution

h c k of precautions create unnecessa y health risks. These leaking drums contained led-based paint. Ingestion or inhalation of lead can cause nerve damage. Children are particularly susceptible (Gus tauus). 0

-- Abandoned barrels with unknown contents pose a health threat. This is common throughout Alaska.

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from hazardous waste, as well as waste of nonrenewable re- sources, are wide- spread public con- cerns.

4. Safetyand health --Waste reduc- tion improves commu- nity quality of life. Re- duction or elimination of hazardous materi- als use and genera- tion improves worker and community safety and health conditions.

Hazardous waste cleanup is prohibitively expensive. This site, Alaska Husky Battery, was contaminated with lead acid and PCBs (Anchorage).

How Identi& wastes

Inventory all raw materials usage, including water and energy. Also inventory all outputs, including products and waste. Look at what is being hauled off as trash and what is released to the environment. Wastes include air emissions, wastewater, solids, and waste heat.

Encourage employees to assist you in identifylng wastes. This is an ongoing process. Inventory wastes as part of your regular business inventory.

Identifi your options to reduce waste: 1.Source reduction -- Reduce the creation of wastes.

Substitute. Substitute a raw material that is less toxic or nontoxic, or creates less waste, or a less toxic or more reusable or treatable waste. For example, use water-based paint rather than oil-based. Change the product. Change the product composition, conserve the product, or substitute a product which yields less waste. For example, use reusable coffee cups inplace of Styrofoam cups. Change the process. Look for production processes which create less waste, or which allow you to recover and reuse “wastes”. For example, add an oil ultra_filter to an engine to extend oil @e. Improve housekeeping

Improve resource and waste handling and storage to reduce and contain spills

schedule production to reduce waste of resources periodically inspect business facility and grounds for

existing or potential leaks, waste and spills train employees in materials handling and efficiency. For

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example, keep materials covered and protectedfrom tempera- ture extremes, have shelvesfirmly anchored in a safe location to prevent spillage during earthquakes or if the shelf is bumped, and train employees to watch for and clean up spills. Separate wastes. A small amount of hazardous waste can contaminate a large volume of previously non-hazardous waste, making it all hazardous waste. Mixed wastes are more difficult to treat and/or dispose of, and may render an otherwise reusable waste useless.

2. Reuse waste. Once a waste has been created, waste reduction can still be achieved by recycling or reusing the waste. Recovered “wastes” are a resource.

Reclaim. It may be necessary to reclaim waste before it can be reused. This might require varying levels of treatment. For example, filter air to recover chlorinated solvents; usefilters, centrifuges, and distilling units to reclaim liquid solvents; use oil/water separators to reclaim oil; or use drainboards to collect solventfrom cleaned parts. Recycle. Reduce the raw material used by recycling waste from within the production process or following consumer usage. For example, recycle metal shavings, recirculate wash water, or recycle paper. Reuse. Find another use for wastes. For example, bum used lubrication oil for space heating, compost waste organic mat- ter, or make note pads from used paper.

Choose and implement options

Choose simple, easily implemented options. You can build on them. Use a simple cost analysis to determine how cost effective your options are. Be sure to consider the cost of waste disposal to determine the best choice. Counter-cun-ent washing is one

way to reduce the amount of waste generated. Water from previous rinses is used for the first rime. Fresh water is used only in thefinal rinse. The same method can be used for washing with solvent.

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Last Resort Waste which cannot be eliminated or reclaimed and reused must be

properly disposed. It should be treated to reduce pollution. If treatment is not possible, as a last resort, waste should be contained in a way which minimizes its potential to pollute the environment.

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3 B. Photo Finishing Tips

Bleach Regeneration Renew photo-processing chemicals by use of replenishers and

regenerators. Most bleach and bleach/fix can be regenerated for reuse. Check with the manufacturer of your brand and type of chemicals for the most effective way to do this.

Chemical Management Use floating lids on bleach and developer containers to reduce the

oxidation and evaporation of chemicals, prolonging chemical life and saving on chemical costs.

Squeegee film between baths. This removes most of the residual solutions and prevents cross-contamination of rinses and baths. Again, chemical life is extended and chemical costs are reduced.

Counter- current washing uses water from previous rinses to first contact the film being developed. Fresh water contacts the film at the final rinse stage and then is used again for the first film rinse.

Use non-absorbent “twin-checks”. The use of non-absorbent labels to identify negatives helps decrease the amount of chemicals carried from one bath to another, extending bath life.

Keep updated on chemical products. Vendors are responding to customer economic and environmental concerns by developing new prod- ucts that are less toxic and create less waste.

Use counter-current washing to reduce wastewater.

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Silver Recovery Silver recovery is not just for

big photo-processors these days. In- expensive and simple units are avail- able that allow small businesses to comply with sewer discharge regula- tions and save dollars that are cur- rently washed down the drain. A simple test paper is available from manufacturers to test the effluent wa- ter for silver content.

Electrolytic recovery units pass a controlled direct electrical current between two electrodes. The electrodes are suspended in used fur solution, and silver collects on the cathode in a highly pure plate. Small units with

(’ minimal power requirements make electrolytic silver recovery feasible for low-volume users.

This unit recovers silver from solution using metallic replacement. The reclaimed silver can be sold for cost recovery.

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Metallic replacement canisters provide a simpler though less effi- cient option. They usually consist of a 5 gallon bucket packed with steel wool. The spent fm bath is poured into the bucket, and over time, the silver in the fix bath replaces the iron in the steel wool. The silver then forms a sludge on the bottom of the canister while the effluent water contains iron. When the steel wool is depleted, the entire canister is sealed and shipped to a refining company. These types of units are available for approximately $50, but have high shipping and refining costs. Small Quantity Generators would be required to manifest silver shipped for recovery (see Understanding the Small Quantity Generator Hazardous Waste Rules, enclosed).

Film scraps can be sent to processors for additional recovery of silver, or you can handle it in-house by fixing the film scraps, then de-silvering the f d n g bath.

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Office Recycling Reducing trash pays off. Recycling can save your business money.

Redemption prices will vary. There are recycling centers around the state for:

White office and computer paper Colored office paper Glass Green and white computer paper Corrugated cardboard Newspaper Shopping bags Nonferrous metals

Aluminum

Plastic bottles

Laser printer toner cartridges can be regenerated and reused at approximately half the cost of purchasing new cartridges. Copier toner cartridges can be regenerated. Several companies in the state provide this service: some provide mail service for rural customers.

To find the real cost savings in recycling, look at your empty dumpster that no longer needs to be picked up and taken to the dump. A simple collection system in your business or office can keep the materials listed above from filling up your dumpster and will save you money. A recent EPA survey estimated that 80% or more of office trash is recyclable paper and cardboard. With trash collection and disposal costs already high and bound to increase, recycling can make a big difference to

Many recyclers will pick up paper at your office, saving you the problem of taking it to the recycling center. The "Flying Can" program is in place to return aluminum cans from rural areas to the Anchorage Recycling Center. Arrangements can be made with truckers to return your recyclables from rural areas to recycling centers (contact the Anchorage Recycling Center).

The market for recycled materials depends on the demand. To support recycling, purchase recycled products. Many different grades of recycled paper are available. Recycled plastic products, metals, and glass are all on the market. Find new uses for recycled materials.

Recycling can improve your public image and employee morale. Consumers and employees want to see recycling; waste reduction and recycling are good for public relations. Encourage employee participation. Have employees develop their own system. Consider providing incentives for employee participation.

, ] abusiness.

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3 C. Chemical Safety1

“State Officials Tracking Benzene Contamination in Wells”, “Work- ers Exposed to Toxic Gases”, “Corporation Fined for Illegal Dumping”; these types of headlines are becoming common and can make a businessperson lose sleep. Businesses find themselves dealing more and more with environmental regulations. This is expensive for a large company which must hire consultants and technical staff to deal with regulatory concerns. Small businesses often feel overwhelmed by the maze of requirements.

People may debate the effectiveness of regulations and enforcement, but the threat of toxic chemicals is very real. Chronic exposure to even minute levels of benzene can cause cancer. A small amount of fuel leaking from an underground tank could contaminate an aquifer with enough benzene to put people at risk who drank water from that well.

Hazardous materials create a variety of problems for businesses, including regulatory compliance headaches, worker exposures, and in- creased liability and expense. To deal with hazardous materials, businesses should focus on becoming informed, drawing up an inventory, planning for proper handling, storage, and disposal, and training workers. The plan should focus on reducing the use and creation of hazardous materials and hazardous wastes to avoid creating problems.

There are many separate regulations dealing with hazardous mate- rials, but the best approach is to deal with the entire issue as one concern, and to address all aspects in one plan. What follows is a basic approach to develop and implement a hazardous material management plan.

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Sumps should not be used for waste disposal. Storage and work areas should provide complete containment of spills of hazardous or toxic chemicals. Spills should be kept out of sewers, drainjklds, or stormdrains.

1. Become informed

First, gather basic informa- tion about hazardous and toxic mate- rials in your business. Keep current by reading trade journals and news- paper articles about these issues. The regulatory agencies (the federal Envi- ronmental Protection Agency and Occupational Safety and Health Agency, and the state Department of Environmental Conservation and Department of Labor) often have lit- erature and give seminars on these subjects. The Alaska Health Project can also provide information on haz- ardous materials and waste reduc- tion.

lThis section is adapted from an article that flrst appeared in Alaska Business Monthly. November 1990.

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Hazardous materials are substances that are flammable, reactive, corrosive, radioactive, or toxic. Examples include paint thinner, muriatic acid, lubrication oil, gasoline, and typing correction fluid.

2. Inventory your facility To effectively manage hazardous materials, you first need an accu-

rate idea of what hazardous materials you use and what hazardous wastes you generate. A review of records and a walk-through of your shop will help to determine what materials and processes are actually used. A walk- through will often turn up materials in the shop that you had no idea were there.

Use labels, material safety data sheets (MSDS), and lab tests to determine if materials are hazardous. Once you have determined what materials are used in your shop, you can research their ingredients by different means:

A. Look for any of the following on product labels:

B. Read the material safety data sheet (MSDS) for each material. Alaska Right-to-Know legislation requires that manufac- turers and distributors provide MSDS sheets for materials that may be dangerous. Material Safety Data Sheets give you information on the make-up of the chemical, the dangers it presents to workers, and proper handling procedures. Information on how to read an MSDS is provided in a separate section of this manual.

C . Have a lab test the material for hazardous characteristics.

Many of the hazardous materials that you use will become hazardous wastes when discarded. A hazardous waste is a material that is no longer fit for its intended use and is listed in the regulations or has the hazardous characteristics defined in the regulations (flammability, reactivity, corro- siveness or toxicity). EPAs publication, Understanding the Small Quantity Generator Hazardous Waste Rules: A Handbook for Small Businesses is also included in this manual and can be very helpful in describing the different types of hazardous waste and how they must be handled. 1

3. Handling and storage

The materials that you identified in your inventory must be handled carefully to avoid accidents. Hazardous materials should be carefully stored to avoid spills and fires. Spillable materials should be stored in a bermed, lined, and covered area. Flammable materials should be kept in a fire locker. Underground storage tanks should be monitored for leakage and should meet the regulations or should be moved aboveground in a lined and bermed area. Non-compatible materials (acids and bases, corrosives and flammables) should be stored separately.

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4. Emergency plan Formulate an emergency plan for

dealing with spills or emissions. This plan should include a designated emergency coordinator, a layout of your shop with ('7

Chemicals should be clearly labeled with appropriate precautions. Workers should be instructed in proper handling and storage and provided with appropriate protective gear.

\9 hazardous materials storage areas shown, and posted emergency telephone numbers. Identify possible emergency situations, and have emergency containment and cleanup materials ready, such as personal protective clothing, absorbent materials, booms, pumps, or neutralizing solutions. Information on the hazardous materials kept in your facility should be provided to the local emergency planning and response personnel.

5. Worker safety Hazardous materials can affect workers with immediate and

long term effects. The hazardous materials you have identified in your shop can cause a variety of health problems in workers. These include skin irritations, internal organ effects, central nervous system effects and cancer. Hazardous materials must be handled and used properly to avoid exposures to workers. Over the lifetime of a worker, exposures can accumulate and cause a great deal of harm.

Exposures to hazardous materials occur through skin contact, inhalation, or through the mouth. Hazardous materials enter the body in three ways: absorption through the skin, inhalation through the lungs, and ingestion through the digestive system. These three routes of exposure must be cut off to protect workers. The basic methods of protecting workers in order of preference are:

The hierarchy of worker safety A. Substitute a less toxic chemical or process for the hazardous one. B. Isolate the worker from the hazard. Create a barrier to keep the

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At the Alaska Husky Battery site in Anchorage, lead, acid, and PCB contamination required extensive cleanup. Here, a worker is going through the decontamination line before leaving the site.

hazard away from the worker. For example, adequate ventilation should be provided for employees working around harmful vapors.

C. Use personal protective gear. This is the least preferred alternative, because it is the least effective. If the process cannot be modified or iso- lated, the worker must be protected with gloves, protective clothing, face shields, and respirators.

Workers should be careful to wash after using hazardous materials and to avoid smoking, eating, drinking, or touching sensi- tive body parts (eyes, mouth, penis, rectum, vagina) when around hazardous materials.

60 Train workers Your workers need to know their role

in your hazards management plan. Training can be incorporated into existing worker right-to-know or safety training.

Employers are required to provide a worker training program under the worker right-to-know laws. The program should have Material Safety Data Sheets available for all hazardous materials on the job site, labelling of all containers, worker training on proper usage of hazardous materials, and a worker right-to-know poster displayed in the work site. For more information on worker right-to-know laws, refer to Section “ E in this manual.

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70 Minimize wastes generated Minimize the wastes that you produce. This will decrease the amount

of waste you need to deal with. There are many ways to reduce toxics and waste. Alternatives are listed in order of preference:

A. Source reduction Substitute less hazardous materials or modify processes.

For example: Substitute water or citrus based degreasers for petroleum

solvents. The degreasers ofen work just as well as the petroleum solvents but are less toxic and more readily biodegradable.

Use a bypass oiljllter on equipment. An add-on bypassjllter can greatly extend the lijie of lubrication oil in an engine: extended oil lijie means less waste oil generated.

Separate hazardous wastescfi-om non-hazardous wastes. Be careful to avoid mixing wastes to prevent a large contamination problem and to allow recove ry and reuse of pure wastes.

Soy oil based inks aregrowing inpopularity in the newspaper industry. They are less hazardous than petroleum based inks, give better “mileage”, and are less likely to rub off.

Use high efliciency spray paint guns to minimize overspray.

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B. Recycling Wastes can often be recycled within an operation to recover

resources: Solvent stills are used to recover a clean and usable product

from a contaminated batch of solvent. They can tum 10 gallons of hazardous waste solvent into 9gallons of usable product and 1 gallon of waste sZudge.

C. Treatment Wastes can be treated to make them less hazardous: Waste jker bath from photo processing units can be run

through a silver recovery unit to recover valuable silver and avoid heavy metal contamination in the sewer.

Oil-contaminated waterfi-om vehicle wash racks can be run through an oil/water separator. The wash water can then be reused.

For more information on waste reduction, refer to Section A in this manual.

8. Manage the wastes that are generated properly

H a z a r d o u s wastes should be prop- erly contained and mani- fested for shipment to an authorized disposal fa- cility. Small businesses in Anchorage can use the municipal hazardous waste collection station to cheaply and easily dis- pose of their hazardous wastes .

Special precautions are necessary when transporting hazardous substances. Loads must be manijiested, packaged, and secured following strict requirements. This open bed load is poorly contained. Covered beds provide better protection.

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til

D. Environmental Regulations

Public awareness and concern over safety, health, and the environ- ment has grown steadily in this country, resulting in a growing array of regulations. New legislation and policies are constantly under considera- tion. This section reviews the current regulatory framework for environ- mental concerns in Alaska: however, it is by no means comprehensive, but only a basic overview. Worker safety, public health, and environmental health are related, but regulations fall under the jurisdiction of a variety of agencies and programs which often overlap or leave gaps.

The Players The Federal EPA

The U S . Environmental Protection Agency (EPA) oversees environ- mental regulations at a national level. The EPA is responsible for ensuring that federal environmental regulations are complied with in each state. States can administer some of the federal programs under the oversight of the EPA. To administer federal programs, the state program must meet or exceed the EPA's standards.

The State ADEC 1

The Alaska Department of Environmental Conservation (ADEC) administers environmental regulations in Alaska. The ADEC administers some federal (EPA) programs such as the Clean Air Act and parts of the Resource Conservation and Recovery Act (RCFW) as well as non-federal state programs. The ADEC also provides technical assistance for environmental compliance.

Local Government In general, local government has the option of adopting and enforcing

environmental regulations which are more stringent than state and federal regulations. Local boroughs and cities may have their own regulations. For example, Anchorage has a more extensive community right-to-know pro- #am than the rest of the state, and the Kenai Peninsula Borough recently required more stringent remedial action for oil-contaminated soil than the state.

Others Depending on the nature and location of your business, other

agencies may also have jurisdiction and environmental regulations you should be aware of. These include:

The federal OSHA (Occupational Safety and Health Admini- stration) regulates worker safety and health. In Alaska, the federal regulations are enforced by the state OSHS under federal oversight, except on federal land and offshore, which is regulated directly by the federal OSHA.

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The state OSHS (Occupational Safety and Health Section of the Department of Labor) administers worker safety and right-to- know programs. Section E of this manual describes Alaska’s worker right-to-know law in more detail.

The State and Local Fire Marshal - The Uniform Fire Code regulates the placement and installation of fuel storage tanks, such as for oil and gas.

The Department of Transportation - Federal, state, and sometimes local regulations govern transport and handling of haz- ardous substances.

The U.S. Coast Guard enforces pollution control within their jurisdiction, including MarPol, the Marine Pollution Control Act, which prohibits dumping of waste in U.S. waters.

Local Publicly Owned Treatment Works (POTW) and land- fill owners/operators may restrict what they can accept through the sewage system or as solid waste, respectively.

The Programs This is not a comprehensive list of environmental regulations, but an

introduction.

RCRA, Resource Conservation and Recovery Act Federal hazardous waste regulations: standards for generators and

transporters of hazardous waste and for owners and operators of hazardous waste treatment, storage, and disposal facilities, and for owners and operators of underground storage tanks. 40 CFR 260-28 1 (Title 40 of the Code of Federal Regulations, Parts 260-28 1).

What is a hazardous waste? For regulatory purposes, a waste is considered hazardous when it is

specifically listed in the regulations or it has one or more of the following characteristics:

Ignitability: Does the waste catch fire easily or would it contribute to a fire by providing oxygen or other gases?

Reactivity: Can the waste react violently, either by itself or when it is mixed with water or exposed to heat or pressure? Is it explosive?

Corrosivity: I s the waste corrosive? Will it burn skin or erode metals? Is it caustic?

Toxicity: Would the waste cause health problems to humans, animals, or plants if they are exposed to it, such as by inhalation or ingestion?

Generator status - Requirements for hazardous waste generators depends on the

volume and type of hazardous waste produced. To determine your generator status, refer to the EPA publication enclosed in this binder: Understanding

Businesses. the Small Quantity Generator Hazardous Waste Rules: A Handbook for Small ‘b

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CERCLA, Comprehensive Environmental Response, Compensation, and Liability Act

Federal “Superfund” contaminated site cleanup and liability provi- sions. Authorizes EPA cleanup involvement in the event of an actual or threatened release of a hazardous substance or pollutant that may present an imminent or substantial danger to public health and welfare. 40 CFR

A “hazardous substance” is defined to include RCRA waste, TSCA chemicals (see paragraph on TSCA below), pollutants as defined in the Clean AirAct, toxic or hazardous pollutants as defined in the Clean Water Act, and additional hazardous substances designated by the EPA.

Those who spill a hazardous substance or pollutant are liable for cleanup costs. Potentially responsible parties include facility owners and operators, ex-owners and ex-operators, generators, transporters and lend- ing institutions (“Cradle-to-grave” responsibility). Liability includes all cleanup costs, damages to natural resources, cost of certain health assess- ment or health effects studies, and up to three times the cost of a government cleanup, if the responsible party refuses to do the cleanup or takes too long.

300-304.

SARA, Superfind Amendments and Reauthorization Act, Title III

Federal community “right-to-know” legislation. Storage and re- leases of toxic and hazardous chemicals must be reported. Provides for the establishment of local emergency planning committees. 40 CFR 350-372.

Toxic Substance Control Act (TSCA) Requires premanufacture testing of new chemicals and identifica-

tion and possible testing of all existing chemicals. The EPA can place restrictions on chemicals which pose “unreasonable risk,” as for PCBs (polychlorinated biphenyls, Part 76 1) and asbestos (Part 763). 40 CFR 700- 799.

Safe Drinking Water Act Establishes national MCLs (maximum contaminant levels) and

secondary standards (guidelines) for drinking water. In conjunction with RCRA, establishes the Underground Injection Control (UIC) program to protect ground water from contamination. 40 CFR 14 1 - 143 (drinking water) and 144-149 (UIC).

Clean Water Act Establishes the NPDES (National Pollution Discharge Elimination

System) permit program to prevent pollution of waterways. EPA is required to set effluent standards for toxic pollutants and to include limits for toxic pollutants in NPDES permits. Spills of “reportable quantities” of oil and hazardous substances into waterways are prohibited. 40 CFR 104- 140 and 400-47 1.

Hazardous Materials Transportation Act Regulates interstate transportation of hazardous materials through

the U.S. Department of Transportation, including packaging, labeling, and shipping of approximately 16,000 hazardous materials. 49 CFR 106- 107, 171- 179.

Clean Air Act ) Specifies National Ambient Air Quality Standards (NAAQS). Primary

standards protect human health, while secondary standards protect plants, animals, and property. States are required to have State Implementation Plants (SIPS) to ensure compliance with NAAQS.

In 1990, this act was extensively amended. Title I11 Hazardous Air Pollutants establishes a program to control 189 pollutant chemicals. The EPA must identify major sources of these pollutants by industry, and then develop technology standards based on priority. “Major sources” are industries which emit 10 tons/year of a listed pollutant, or 25 tons/year of a combination of listed pollutants. Targeted industries will include degreas- ing, printing, publishing, dry cleaning, and paint removers.

Title VI Stratospheric Ozone Protection requires production phase- out of CFCs, 1, 1, l-trichloroethane, and HCFCs. Non-essential products which release CFCs or 1 , 1 , 1 -trichloroethane during use or manufacture will be prohibited 2 years after enactment.

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Title 18, Alaska Administrative Code, Environmental Conservation

Title 18 of the Alaska Administrative Code, Chapters 15 through 95 (18 AAC 15-95) implements Title 46 of the Alaska Statutes on Water, Air, Energy, and Environmental Conservation. Title 18 regulations range in scope from food service quality control to litter, wastewater, and mining provisions.

The array of environmental regulations is complex and confusing, but ignorance is not bliss. Even small businesses need to be familiar with the relevant regulations. Compliance with these regulations is crucial to ensure a safe working and living environment and to protect against potentially enormous liability.

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E. Worker Right-to-Know Law

The Alaska Right-to-Know Law (AS.60.068) requires all employers, as of July 1, 1984, to collect and provide employees with information about health effects for hazardous exposures at their job sites. Employers are required to provide training on proper handling procedures and precautions for hazardous exposures. In June 1987, the Governor approved a change to expand the statute to include hazardous physical agents, such as noise, radiation, and vibration, as well as hazardous chemical substances.

These are the employer’s major responsibilities under the law:

Collect and maintain a file of Material Safety Data Sheets (MSDSs) and Physical Agent Data Sheets (PADSs) for any hazardous chemicals and physical agents present in the workplace. Post, or post notice of the workplace location of MSDSs and PADS and provide them to employees upon request. MSDSs must be provided by manufacturers. PADS are available from the Alaska Department of Labor.

1. A Chemical and Physical Agents Inventory

2. Label all Hazardous Materials Containers This includes bags, barrels, boxes, cans, cylinders, drums, reaction

vessels, etc. Portable containers need not be labeled if the chemicals are

immediate use (within the shift) of the employee who makes the transfer. The label must identify the product, give appropriate hazard warnings, and give the name and address of the manufacturer or a responsible party.

-) . taken from a labeled container, and the portable container is for the

3. Safety Training for Employees Conduct a safety training program for each new work assignment

informing employees of: A) the location and properties of the hazardous substance or physical agent, B) the known or suspected health ef- fects, C) the nature of any operation that could result in exposure to hazardous substances or physical agents, D) any necessary handling or hygi- enic practices or precautions, and E) the location, proper use, and limi- tation of personal protective equip- ment used in the workplace. Worker safety training is required.

Here, workers are being trained in hazardous waste sampling by the Alaska hborers Training School.

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4. Plant Hazard Communication Plan

tains: You must have a written hazard communication plan which con-

A) A list of hazardous substances and physical agents in the workplace. B) Methods to inform employees of the hazards of non-routine tasks. C) Methods to inform employees of the hazards of chemicals in unlabeled pipes. D) Methods to inform on-site contractors and their employees of potential hazards. This plan must be made available to workers and/or unions.

5. Right-to-Know Poster Display a poster with information about worker rights under the law

(available from the Department of Labor Occupation Health and Safety Section [OSHS]).

Employees may request safety and health information about a product or exposure. Employers must supply an MSDS or equivalent information or a PADS for a hazardous physical agent. Chemical information should include:

the product name and chemical name the name and address of the manufacturer principal hazardous components fire and explosion hazard data health hazard information precautions to follow during spills and leaks proper disposal methods handling and storage practices

All employers should have this information available, so employees can get it during the same shift they request it. If this information is not available, the employer must contact either OSHS or the product's manu- facturer within three days of the employee's request. OSHS has an information retrieval system to assist employers. Workers also may use this system to obtain health and safety information about hazardous workplace exposure.

If the employer does not provide information within 15 days of an employee's request, the hazardous exposure in the workplace must be eliminated.

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'3 F. HOW toRead a Material Safety Data Sheet (MSDS)

Most information presented to workers under the Alaskan right-to- know legislation will be in the form of a material safety data sheet (MSDS). This same document often is referred to as the OSHA Form 20. Alaskan workers should have a basic understanding of this document in order to effectively utilize their right to know about hazardous materials in the workplace. The following section briefly outlines the important sections of an MSDS.

Section I Identifies the manufacturer and the product. Note in particular the

"emergency telephone number."

Section I1 Hazardous Ingredients

Lists most product ingredients for which there is an OSHA Alaskan) standard. Also lists the percentage of the ingredient, and

\I (or its

threshold limit value (TLV). A TLV measurement is the amount of the hazardous substance in the air which is thought to be harmless to most workers exposed repeatedly to it. A trained worker or industrial hygienist with proper equipment usually can make the appropriate measurement.

Section I11 Physical Data

Lists selected chemical data which can be useful in deciding how dangerous a product is. For example, if the vapor density is considerably greater than air (air = l), the substance may collect in low places and be a particular hazard to workers in low-lying, confined spaces.

Section IV Fire and Explosion Data

A flash point near or below 100°F indicates a particularly unstable substance which might catch fire or explode as the result of static electricity or a cigarette. The flammable limits refer to the range of vapor concentra- tions in air which will explode if heat is added. The lower the percentage of the LEL (lower explosive limit), the less of the substance has to be in the air before it is likely to explode. '+-)

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Section V Health Hazard Data

This section often provides insufficient quality data. Long term health hazards such as cancer or reproduction problems usually are not mentioned. The health hazards associated with the ingredients should be established with additional research beyond the information provided in the MSDS.

Section VI Reactivity Data

Gives information on conditions that could cause the product to react dangerously or to decompose and release dangerous materials.

Section VI1 Spill or Leak Procedures

Gives instructions for handling spills.

Section VI11 Special Protection Information

Gives information on the minimal protective equipment and ventila- tion to be used with the product.

Section IX Special Precautions

Lists unique hazards for those working with the product and protective measures.

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G. For More Information

Emergency Hotlines Alaska Division of Emergency Services call 91 1 or 800-478-2337

Alaska Department of Environmental Conservation, Oil and Hazardous Spill Substance Reporting 800-478-9300

Chemtrec - Chemical Transporters Emergency Center 800-424-9300 If you are transporting a chemical and have an emergency, they can give immediate advice for handling the problem and can contact the product shipper.

Poison Control Center 800-478-3 193 Recommend treatment and emergency care for accidental and acute poisonings.

National Response Center (Coast Guard) 800-424-8802 To report a major spill of hazardous substance to a navigable waterway. They will contact local agencies.

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Agencies Alaska Department of Environmental Conservation

Oil and Hazardous Substance Spill Reporting 800-478-9300

Pollution Prevention Program Hatline 907-478-2864 Pollution Prevention Program Office 907-465-267 1 A free non-regulatory assistance program to help Alaska’s busi- nesses and communities prevent pollution through waste reduction and recycling.

Reeional Offices Northern Regional Office (Fairbanks) 907-452-1714 Southcentral Regional Office (Anchorage) 907-563-6529 Southeast Regional Office (Juneau) 907-789-3 15 1

Alaska Department of Labor, Occupational Safety and Health Section (OSHS)

Consultation 907-264-2599 Compliance 907-264-2594

Alaska Health Project 276-2864 (Anchorage)

A non-profit public service organization which provides free and confidential consultation on waste reduction, occupational, and en- vironmental health.

800-478-2864 (statewide) )

Chemical Referral Center 800-262-8200 When you give them a product brand or chemical name, they can tell you how to contact the manufacturer to request health and safety in formation. Operated by the Chemical Manufacturer’s Association.

Environmental Protection Agency Anchorage Office 907-27 1-5038 Juneau Qffice 907-586-76 19 Pollution Prevention Office 202-245-3557 RCRA/Superfund Hotline 800-424-9346 If you use, store, or are disposing of a hazardous waste, this is an information service to assist in understanding the EPA regulations under the Resource Conservation and Recovery Act (RCRA) and the Superfund law.

SARA Title I11 Hotline 800-535-0202 Small Ombudsman (SBO) Hotline 800-368-5888 For assistance on how to meet any of the EPA requirements, or for assistance to small businesses on environmental matters.

National Institute for Occupational Safety and Health (NIOSH) Anchorage office 907-561-8209 National office 800-356-4674 Provides information and help regarding hazardous conditions on the job, such as poor ventilation and chemical exposure.

Trade Organizations Halogenated Solvents Industry Alliance 800-332-4742

Industry Cooperative for Ozone Layer Protection

A non-profit industry cooperative to share information in response to concern over use of solvents.

(ICOLP) 202-737-1419

National Association of Solvent Recyclers 1333 New Hampshire Avenue SW, Suite 1100 Washington, DC 20036

202-463-6956

Vendors and Services DISCLAIMER - This list is provided for informational purposes only. It is not complete and does not constitute endorsement of any kind.

: .I AntiJreeze Recycling BG Distributors of Alaska - Purify used antifreeze 907-276-8002 3380 C Street, Suite 105 Anchorage, Alaska 99502

(or in Alaska) 800-478-8005

Oil Bypass Filters and Testing Amsoil Synthetic Lubricants - Oil bypass filters and testing Attn: Marc Staten 5773 Old Seward Highway Anchorage, AK 99507

Analysts, Inc. - Oil testing P. 0. Box 2955 Torrance, CA 90509

Cash's Filtration - Gulf Coast oil bypass filters and testing 340 E. 76th Avenue Anchorage, AK 995 18

907-563-3277

213-212-7001 800-336-3637

907-349-7649

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DSR Companies - B.O.S.S. oil bypass filters and testing 225 W. 92nd Avenue Anchorage, AK 995 15

Professional Services Industry 2271 1 La Palma Ave. Yorba Linda, CA 92687

Oily Water Treatment Cascade Machinery and Electric Inc. - Oily water treatment 4600 E. Marginal Way South P.O. Box 3575 Seattle, WA 98 124-3575

Marvin Company Inc. - Oily water treatment P.O. Box 509 Redmond, WA 98073

Northwest Power - Oily water treatment 2366 Eastlake E., Suite 234 P.O. Box 12128 Seattle, WA 98 102-0 128

Wetco Inc. - Citrus-based degreasers; oily water treatment 1614 Post Rd. Anchorage, AK 99501

Parts Cleaning and Solvent Recovery CDS Group - Sodium bicarbonate abrasive cleaning system 503 McKeever, # 15 10 Areola. TX 77583-9805

Environmental Technology Port of Sanford Manufacturing Facility Sanford, FL 32771

Gleason Research, Inc. Solvent sills and used oil space heaters P.O. Box 771 171 Eagle River, AK 99577

907-522-3234

7 14-692-9603

206-762-0500 or

800-289-0500

206-88 1-3944

206-324-6880 or

800-395-6880

907-276-41 15

800-332-5424

407-321-7910

907-694-2299

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Inland Technology, Inc. 2612 Pacific Highway East, Suite C Tacoma, WA 98424

Orange - Sol, Inc. 4802 Loretta Land Anchorage, AK 99507

RGF Environmental Systems - Water recycling pressure cleaner 2600 N W 55th Ct. Suite 230 Fort Lauderdale, FL 33309

206-922-8932

907-563-5070

800-842-777 1

Van Waters and Rogers Inc. - Citrikleen degreaser

Anchorage, AK 9951 1-2589 800-478-7444

907-344-7444 P.O. Box 112589 or

Wetco, Inc. - see “Oily Water Treatment”

Rec y ding Anchorage Recycling Center - Recycling, balers, and compactors

Anchorage, AK 99518 _> 6161 Rosewood St.

907-562-2267 or

800-478-2267

Battery Specialists of Alaska - Battery recycling

Anchorage, AK 99501 800-478-553 1

907-276-525 1 1939 E. 5th Avenue or

GK Equipment - Baler and compactors 22023 70th Ave. Kent, WA 98032

Industrial Materials Exchange - Information on markets for industrial products 172 20th Avenue Seattle, WA 98122

206-575-3050

206-296-4633

Also check with your local borough and/or city for recycling options.

Silver Recovery AgCo Metalex Corp 3701 South Road Lynwood, WA 98037

4 Eastman Kodak, Inc.

206-743-7886

800-242-2424, ext. 60

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Konica Imaging Charles Street Glen Cove, NY 11542

Oxford Asseying and Refining, Inc. 3406 Arctic Blvd. Anchorage, AK 99503

Soy Oil Ink Alaska Printers Supply (will special order) 9 15 W. Northern Lights Blvd. Anchorage, AK 99503

J.M. Huber Corporation 333 Thornall St. Edison, N J 08818

General Printing Ink 63 1 Central Avenue Carlstadt, N J 07072

516-674-2500 or

800-645-6252

907-561-5237

907-277-7543

201-906-1760

20 1-933-4500

Used Oil Burners Gleason Research, Inc. - see “Parts Cleaning”

NuEra Technologies - Black Gold space Heaters P.O. Box 112332 Anchorage, AK 995 1 1-2332

907-345-64 1 1

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