Canadian Federal Government Proposing New Regulations on Cross-border movement of Hazardous Waste

Environment Canada and Climate Change (ECCC), which is the Canadian equivalent of the U.S. Environmental Protection Agency, recently released draft regulations to control the cross-border movement of hazardous waste and hazardous recyclable material. The regulations, if eventually promulgated, would repeal and replace the Export and Import Regulations, the Interprovincial Movement Regulations, and the PCB Waste Export Regulations. Although the proposed Regulations would maintain the core permitting and movement tracking requirements of the former regulations, the regulatory provisions would be amended to ensure greater clarity and consistency of the regulatory requirements.

Electronic Tracking System

The proposed Regulations would provide flexibility for the electronic movement tracking system by no longer prescribing the specific form required for tracking shipments of hazardous waste and hazardous recyclable material. Instead, the proposed Regulations would require specific information to be included in a movement document (that can be generated electronically) and would allow movement document information to be passed on to different parties in parallel to facilitate the tracking rather than prescribing the handover of copies from one party to another.

Furthermore, given that movement documents would be able to be managed electronically, the proposed Regulations would no longer require that the movement document and permit physically accompany the shipment. The proposed Regulations would instead require parties to immediately produce the movement document and the permit upon request. Similar simplifications would be included in the provisions related to the movement document for interprovincial movements of hazardous waste and hazardous recyclable material.

The proposed Regulations would clarify the responsibility of a receiving (importing) facility to pass on information regarding the origin of the hazardous waste and hazardous recyclable material being transferred to a subsequent authorized facility for final disposal or recycling. Clarifications would also be made to the provisions for the return and rerouting of shipments to better align those requirements with current practice and ensure that confirmation of disposal from the alternative facility is also required in order to properly complete the tracking of those shipments.

Definitions of hazardous waste and hazardous recyclable material

With respect to interprovincial movements, under the proposed regulations, the definitions of hazardous waste and hazardous recyclable material would be aligned with those of international movements. In addition, proposed changes to those definitions would ensure a more consistent application of regulatory provisions for all types of transboundary movements and would better align definitions with other jurisdictions and international agreements. Some of these proposed changes are listed below.

Toxicity characteristic leaching procedure

The proposed Regulations would reference the toxicity characteristic leaching procedure (TCLP), in its entirety. This procedure is a standard test method used to evaluate the mobility of a number of contaminants that may be found in waste and recyclable material and, therefore, their potential for release. While making reference to the TCLP, the Export and Import Regulations exclude a step requiring that the size of particles in a sample be reduced to fit into the testing apparatus. In order to ensure that the method is used consistently, hazardous waste and hazardous recyclable material undergoing testing would need to be shredded to meet the TCLP’s specific particle size requirement.

Electrical and electronic equipment

Electrical and electronic equipment (EEE) is not currently listed as hazardous under the Export and Import Regulations and must meet other criteria to fall under the definitions of hazardous waste or hazardous recyclable material, which can be difficult to ascertain. The proposed Regulations would clearly designate “circuit boards and display devices and any equipment that contains them” as hazardous waste or hazardous recyclable material to be controlled when destined for specific disposal or recycling operations. The proposed Regulations would maintain the exclusion currently under the Export and Import Regulations for this type of hazardous waste and hazardous recyclable material moving within OECD countries (including moving between provinces and territories in Canada).

Mercury

The proposed Regulations would remove the small quantity exclusion for hazardous waste and hazardous recyclable material containing mercury. Any waste or material containing any amount of mercury that meets the definitions of hazardous waste or hazardous recyclable material would be subject to the regulatory provisions for both international and interprovincial movements.

Batteries

Batteries are not currently listed as hazardous under the Export and Import Regulations and must meet other criteria to fall under the definitions of hazardous waste or hazardous recyclable material. Some types of batteries are clearly covered by the definitions; however, for some other types it is not clear. The proposed Regulations would clarify that all types of batteries (i.e. rechargeable and non-rechargeable) being shipped internationally or interprovincially for disposal or recycling are included in the definitions of hazardous waste and hazardous recyclable material.

Terrapure Battery Recycling Facility

Waste and recyclable material generated on ships

The proposed Regulations would add a new exclusion to clarify that waste or recyclable material generated from the normal operations of a ship is not captured by the definitions of hazardous waste and hazardous recyclable material. This exclusion would further harmonize the proposed Regulations with the Basel Convention (which excludes this waste) and the Canada Shipping Act, 2001 where this waste is already covered.

Residual quantities

The proposed Regulations would add a new exclusion for waste or recyclable material that is to be transported in a container after the contents of that container have been removed to the maximum extent feasible and before the container is either refilled or cleaned of its residual content. This exclusion would clarify that such waste or recyclable material is not captured by the definitions of hazardous waste and hazardous recyclable material.

Recycling operation R14

Over the years, ECCC has received numerous questions regarding recycling operation R14 found in Schedule 2 of the Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations. Section 2 R14 reads as follows : “Recovery or regeneration of a substance or use or re-use of a recyclable material, other than by any of operations R1 to R10”. This recycling operation is not included in the Basel Convention or the OECD Decision.  ECCC is proposing to delete this part of operation R14 to remove uncertainty about its application.  This change may result in some recyclable material no longer being captured and defined as hazardous.  For example, a used material that is to be used directly in another process that is not listed as a recycling operation would no longer be captured. 
This change would further align regulatory provisions with international guidelines under the Basel Convention.


Exports, Imports and Transits of Hazardous Waste and Hazardous Recyclable Material 2003-2012

Proposed changes regarding waste containing PCBs

The regulatory provisions for the export of waste containing PCBs would be streamlined and integrated into those for hazardous waste and hazardous recyclable material. This would include removing the partial prohibition on exports of waste containing PCBs in a concentration equal to or greater than 50 mg/kg to allow controlled exports beyond the United States. Therefore, waste and recyclable material containing PCBs in a concentration equal to or greater than 50 mg/kg would be able to be exported provided a permit is obtained and all of the conditions of the proposed Regulations are met.

Proposed changes to improve the permitting process

The proposed Regulations would no longer require the name of the insurance company and the policy number for the exporter, the importer and carriers with the notification (i.e. permit application). In addition, copies of the contracts would no longer need to be provided with the notification. In both cases, the applicant would be required to provide a statement to the effect that valid insurance policies and contracts are in place and to keep proof of insurance coverage and copies of contracts at their place of business in Canada for five years.

The proposed Regulations would require a new notification for any changes in information, other than correcting clerical errors, on a permit.

The proposed Regulations would increase the maximum duration of a permit from 12 months to 3 years, consistent with international agreements, for the movement of hazardous recyclable material directed to pre-consented facilities within OECD countries.

The proposed Regulations would set out conditions under which a permit may be refused, suspended or revoked.

Impacts on Business – Costs and Operations

According to the consultation documents prepared by ECCC, the proposed Regulations, if promulgated, would affect 295 companies, 281 of which would be considered small businesses. For these small businesses, the proposed Regulations are expected to result in incremental compliance and administrative costs of $296,000 in average annualized costs, that is, $1,070 per small business.

If the proposed Regulations are implemented, it would result in an clarifications to the definitions of hazardous waste and would ensure a more consistent application of regulatory provisions. In addition, the proposed Regulations would help minimize environmental impacts outside Canada by ensuring that exported hazardous waste and hazardous recyclable material reach the intended disposal or recycling facilities. The present value of compliance and administrative costs of the proposed Regulations would be $2.5 million in 2017 Canadian dollars, discounted at 3% to 2018 over a 10-year period between 2021 and 2030.

The proposed Regulations would impose incremental administrative costs on industry attributable to the completion of additional movement documents for interprovincial movements of hazardous waste and hazardous recyclable material. Provincial and territorial authorities that are using a tracking system would achieve small savings if they decided not to request movement document information. The present value of administrative costs of the proposed Regulations are expected to be $460,000 in 2017 Canadian dollars, discounted at 3% to 2018, over a 10-year period between 2021 and 2030.

Public Consultation

Public comments to the proposed Regulations are being accepted by ECCC until up to mid-February. Any person may file with the Minister of the Environment comments with respect to the proposed Regulations or a notice of objection requesting that a board of review be established under section 333 of the Canadian Environmental Protection Act, 1999 and stating the reasons for the objection. All comments and notices must cite the Canada Gazette, Part I, and the date of publication of this notice, and be sent by mail to Nathalie Perron, Director, Waste Reduction and Management Division, Environmental Protection Branch, Department of the Environment, 351 Saint-Joseph Blvd., Gatineau, Quebec K1A 0H3 (fax: 819-938-4553; email: ec.mt-tm.ec@canada.ca).

Forecast for U.S. Federal and International Chemical Regulatory Policy 2019: Hazardous Materials

The ACTA Group of Bergeson & Campbell PC recently wrote an article in the National Law Review (NLR) forecasting the U.S. federal and international chemical regulatory policy related to hazardous materials for the coming year. The two major areas covered are hazardous materials transportation and trade.

Under hazardous materials transportation, the NLR article predicts that the
The U.S. Department of Transportation’s (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) will face the challenge of a growing burden on it as the scope and complexity of its mission grows. The article predicts this pressure will require the PHMSA to fundamentally rethink how it will use data, information, and technology to achieve its safety goals.

The article states that new information and research will drive much of what PHMSA undertakes in 2019. Advances in technology, enhanced commerce, and a rapidly evolving global trade in hazardous materials must be matched by PHMSA if it is to satisfy its mandates. At this point, PHMSA appears to recognize these new challenges and is poised to maintain its highly honed edge on hazardous materials transportation.

Specific actions that PHMSA will undertake in 2019 include the following:

  • Legislative requirements in the Fixing America’s Surface Transportation (FAST) Act, especially as it applies to high hazard flammable trains – PHMSA is slated to promulgate a final rule pursuant to the FAST Act that will expand the applicability of comprehensive oil spill response plans based on thresholds of liquid petroleum that apply to an entire train ;
  • Transportation of lithium batteries by air;
  • Conversion of special permits;
  • International standards harmonization; and
  • Identifying research gaps and determining priorities.

The NLR article states that PHMSA can be expected to continue to promulgate rules in compliance with its statutory mandates but it also recognizes the need to shore up gaps and to keep pace with an accelerating array of products that are transported in commerce. New information and research will drive much of what PHMSA undertakes in 2019. Advances in technology, enhanced commerce, and a rapidly evolving global trade in hazardous materials must be matched by PHMSA if it is to satisfy its mandates.

With respect to U.S. trade with other countries, the NRL article discusses the five pillars of U.S. trade policy:

  1. Trade Policy that Supports National Security Policy;
  2. Strengthening the American Economy;
  3. Negotiating Trade Deals that Work for All Americans;
  4. Enforcing and Defending U.S. Trade Laws; and
  5. Strengthening the Multilateral Trading System.

Specific trade actions are discussed in the NRL article that apply hazardous materials including the new agreement that replaces the North American Free Trade Agreement and the new focus of the U.S. on bi-lateral trade agreements.

What are the most common HazMat threats for first responders?

by Steven Pike, Argon Electronics

The unintentional release of toxic chemicals can pose a wide range of physical, health and environmental hazards. And when it comes to the storage, handling or transport of hazardous materials (HazMat), safety is paramount.

The US Environmental Protection Agency (U.S. EPA) defines HazMat as any substance that is potentially harmful to human health or the environment. 

While there are a multitude of precautions that industries will take to stay safe, in the event of accidental spillage due to a road traffic accident or as the result of an industrial incident, highly trained HazMat crews will be called on to mitigate the threat.

In this article, we explore eight of the most common hazardous materials that first responders are likely to encounter in the event of an industrial accident or road transport incident.

1) Carbon Dioxide

Refrigerated carbon dioxide is a colorless, odorless, non-flammable gas used to chill or freeze food products as part of the process of transport to market.

Although non-toxic, when carbon dioxide displaces oxygen in confined spaces the carbon dioxide vapors can cause headache, nausea, dizziness or asphyxiation. And when carbon dioxide comes into contact with skin it can also cause severe burns.

When responding to incidents where C02 is stored, firefighters need to be alert to the possibility of leakages. A low oxygen meter should be used to determine that an area is safe for occupancy.

2) Chlorine

Chlorine is a key component in the production of key industrial and consumer products including the vast majority of pharmaceutical production and virtually all crop protection chemicals.

It is a highly reactive and volatile substance, particularly when in the presence of heat, and is considered to be among the most dangerous of hazardous materials.

Chlorine is classified as both a Toxic Inhalation Hazard (TIH) and a Poison Inhalation Hazard (PIH).

3) Fireworks

Both the transport and storage of consumer fireworks pose a high fire risk. In the United Kingdom (UK), the physical movement (transfer) of explosives from one place to another (excluding those moved within a site) requires a Recipient Competent Authority (RCA) document. 

According to the UK’s Health and Safety Executive (HSE) a license is required from an appropriate licensing authority in order to be able to store explosives, however depending on their hazard type certain quantities of explosives can be kept for a short time without the need for a license. 

In the US, the Consumer Product Safety Commission (CPSC) has issued mandatory safety regulations for fireworks devices that are regulated under the Federal Hazardous Substances Act.

4) Gasoline

Typical gasoline contains approximately 150 different chemicals including benzene, toluene, ethylbenzene and xylene.

The highly flammable nature of gasoline, the ease with which it evaporates and its explosive potential in air, makes it a high exposure risk. Gasoline exposure can occur through the breathing of gasoline vapours, via the drinking of contaminated water or by coming into contact with contaminated soil.

Gasoline should only be stored in approved containers and must not be handled near any ignition source.

5) Argon

A refrigerated liquid, Argon is most commonly used in the production of fluorescent light bulbs and in welding.

Argon is classed as neither flammable nor toxic, however it can cause significant tissue damage if it comes into contact with skin and it can be extremely harmful if inhaled. To avoid sudden releases Argon is transported in upright cylinders.

6) Sulfuric Acid

Sulfuric acid (also known as “battery acid”, “hydrgen sulfate” and “oil of vitriol”) is one of the most important compounds in the chemical industry. The annual production of sulfuric acid worldwide has been predicted to hit 260 million tonnes by the end of 2018. 

Sulfuric acid is used widely in the production of phosphate fertilizers, metal processing, lead-based batteries, fiber production and chemical manufacturing (including paints, pigments, dyes and synthetic detergents.)

It is a highly corrosive substance which is destructive to skin, eyes, teeth and lungs. Severe exposure can be fatal.

7) Propylene

Propylene is a volatile, flammable gas used as a crucial product in the petrochemical, packaging and plastics industries.

It is often used in the place of propane in high-velocity oxygen fuel (HVOF) processes. Propylene gas poses a fire hazard when it is handled in the vicinity of any equipment capable of causing ignition.

8) Liquefied Petroleum Gas (LPG)

Comprising a combination of propane and butane, LPG is commonly used as both a fuel (to heat vehicles and appliances) and as a refrigerant. Its mixture of hydrocarbon gases poses a major fire risk which means it must be stored in pressured vessels.

Toxic chemicals can pose a wide range of potential health and physical hazards to those employees operating within industrial plants and to the personnel charged with handling or transporting these substances. And as such they are heavily regulated.

In the rare case of accidental release, the knowledge of HazMat crews can provide life-saving assistance in identifying the threat, containing the area and mitigating the effects of the incident. 

This article was first published on the Argon Electronics website.

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About the Author

Steven Pike is the Founder and Managing Director of Argon Electronics, a leader in the development and manufacture of Chemical, Biological, Radiological and Nuclear (CBRN) and hazardous material (HazMat) detector simulators.
He is interested in liaising with CBRN professionals and detector manufacturers to develop training simulators as well as CBRN trainers and exercise planners to enhance their capability and improve the quality of CBRN and Hazmat training.

What is the best HazMat training method to keep first responders safe

by Steven Pike, Argon Electronics

While regulations exist to guide HazMat training requirements for first  responders, the reality is that many personnel still don’t consider themselves to be adequately skilled in the use of their equipment.

Sometimes it’s because there simply isn’t enough time to carry out regular and structured training programmes. Sometimes this lack of preparedness comes as the result of budget cuts where training is one of the first things to go.

So says, independent CBRN consultant and subject matter expert, Debra Robinson in a white paper she has written which explores the subject of keeping first responders safe.

As Debra explains, it’s not enough for a department to simply purchase a full array of safety and monitoring equipment.

“Responders need to be thoroughly knowledgeable about the capabilities, limitations and applications and be proficient in the use of each piece of equipment, and that takes a great deal of training,” she says.

It would seem too that smaller fire departments are often the ones losing out, with many volunteers not always being crystal clear on what their training requirements even entail. 

“Large city or larger communities with paid fire departments are far better off than the smaller departments. Some 70-80% of fire departments across the United States are manned by volunteers and many struggle to find volunteers to provide the services, let alone complete the requisite training,” she says.

For those departments that do have training coordinators and solid programs in place,there is still the challenge of trying to deliver equipment training that provides the most realistic learning experience possible whilst also guaranteeing personnel safety.

As Debra points out,the equipment that is used to detect, identify and measure hazardous materials can often involve significant risk, even in the presumed safety of a training environment.

Some trainers may still defer to more traditional HazMat training methods – such as the use of powerful simulants that closely mimic the properties of chemical materials. But many of these simulants can be hazardous in their own right,even in the smallest and most controlled of quantities.

In recent years, Debra explains, there’s been more of a move towards the use of training simulators which rely on specific frequencies and technologies to replicate the effects of actual, chemical, radiological and biological materials.

Says Debra: “The obvious benefit is the simulators greatly reduce the risks associated with the use of live agents. Used properly, they can be a valuable training tool and can provide for a much more realistic training environment.”

Simulators have developed a strong reputation for their abilities to facilitate hands-on training that can simply not be achieved with live agent training methods. Live agents by their nature carry an extreme level of inherent risk – something that is eliminated through the use of simulator equipment.

As Debra highlights, having the opportunity for some “serious hands-on time with the equipment” is another major plus for trainees, where repetition is the key to successful learning.

And there are also tangible benefits to be gained for a department’s bottom-line, she says, with the return on investment (ROI) being clearly evident in fewer operator errors,as well as “reduced damage to detectors, avoidance of simulant and source related administration etc. and perhaps even lower insurance premiums.”

As Debra argues, it can be easy for political or government leaders to dismiss the need for investment in CBRNe and HazMat training – and particularly when budgets are tight. Bu the risk to communities from chemical, biological or radiological threat is very real. While this may come in the form of terrorist threats, there is also the much greater risk of hazardous materials that exist in our communities’industrial plants, hospitals and businesses.

As Debra concludes:”Ultimately, the decision-point and justification is quite simple. Are you willing to accept the risks associated with under-qualified personnel and insufficient training and capabilities, or should you consider moving toward ensuring you have sufficiently trained, equipped and qualified personnel to respond to the hazards that exist in the community?”

Debra Robinson is founder of 2o8 Consulting & Solutions, based in Lincoln, Nebraska. She provides consulting and SME services in chemical, biological, radiological, and nuclear (CBRN) and Emergency Management preparedness across a diverse range of platforms and industries.

This article was first published in Argon Electronics website.

About the Author

Steven Pike is the Founder and Managing Director of Argon Electronics, a world leader in the development and manufacture of Chemical, Biological, Radiological and Nuclear (CBRN) and hazardous material (HazMat) detector simulators.

Market Report on VOC Detectors

VOC Detector Market

QY Research recently published the Global Market Study VOC Detector Market Provide Forecast Report 2018 – 2025.  The report presents a detailed analysis of the VOC Detector market which researched industry situations, market Size, growth and demands, VOC Detector market outlook, business strategies utilized, competitive analysis by VOC Detector Market Players, Deployment Models, Opportunities, Future Roadmap, Value Chain, and Major Player Profiles. The report also presents forecasts for VOC Detector investments from 2018 till 2025.

United States is the largest Manufaturer of VOC Detector Market and consumption region in the world, Europe also play important roles in global VOC Detector market while China is fastest growing region. The 126 page VOC Detector report provides tables and figures and analysis the VOC Detector market. The report gives a visual, one-stop breakdown of the leading products, submarkets and market leader’s market revenue forecast as well as analysis and prediction of the VOC Detector market to 2025.

Geographically, this report splits the global market into several key Regions, with sales (K Units), revenue (Million USD), market share and growth rate of VOC Detector for these regions, from 2013 to 2025 (forecast), covering United States, China, Europe, Japan, Southeast Asia, and India.

The report provides an analysis of the global VOC Detector market competition by top manufacturers/players, with VOC Detector sales volume, Price (USD/Unit), revenue (Million USD) and market share for each manufacturer/player.  The top players include the following: REA Systems; Ion Science; Thermo Fisher; Skyeaglee; Omega; and E Instruments.

The report provides an overview of the global market on the basis of product.  This report displays the production, revenue, price, market share and growth rate of each type, primarily split into the following types of detectors:
PID and Metal-oxide Semiconductor.   The report also breaks down the global market based on application as follows:  Environmental Site Surveying; Industrial Hygiene; and HazMat/Homeland Security.

RAE Systems Gas Detector

Chemical hazard training using Simulator Detectors

by Steven Pike, Argon Electronics

The ability to deliver consistent, engaging and true-to-life chemical hazard detection training scenarios relies on regular access to realistic, hands-on equipment.

What’s vital is that these training tools replicate not only the readings and the responsiveness of real detectors, but that they also provide trainees with an authentic experience that recreates the potential challenges that they will face in actual incidents.

Training for CBRNe and HazMat threats

Planning exercises for modern-day CBRNe and HazMat threats has never been more complex, with the need to respond to anything from clandestine laboratory searches to major industrial incidents, chemical improvised explosive devices or terrorist threats.

And key to the success of any training scenario is the capacity for instructors to be able to create compelling training experiences that are straight-forward to set up and easy to repeat.

While training with Live Agents (LAT) can still have a role to play, it introduces a substantial degree of risk to instructors, students, their equipment and the environment – not to mention incurring greater cost, increased administrative effort and a heavier regulatory burden.

Simulant training is often viewed as presenting a safer “middle ground” for CBRNe and HazMat exercises, bringing with it the advantages of a more credible, real-life experience but at the same time reducing risk through the use of smaller, controlled quantities of substances.

But even in the most carefully managed of exercises, the use of simulants brings with it certain disadvantages. It can often restrict the breadth and variety of scenarios – for example, when they are required to be used in confined spaces, or where wind, temperature or training location can impact negatively on the learning experience.

It is also increasingly common for modern detectors to provide limited response to simulant sources, due to their highly developed interference rejection (IR) capabilities.

The good news though is that safe, high-quality and easily repeatable CBRNe/HazMat training needn’t be so complicated.

Simulator detectors for CBRNe and HazMat training

One solution that has revolutionized modern approaches to chemical detection training is the adoption of innovative and safe detector training aids that replicate the functionality of real devices.

These intelligent, electronic training tools place instructors in control, they are environmentally friendly, they can be set up in an unlimited variety of indoor and outdoor locations and they offer powerful after action review features.

Let’s now take a closer look at one specific example of a chemical hazard detector – the Smiths Detection LCD3.3 – and its simulator equivalent – the LCD3.3-SIM, also known in the USA as the M4A1 JCAD and M4A1 JCAD-SIM respectively.

The Smiths Detection LCD3.3

The Smiths Detection LCD3.3 is a person-worn device which is reported to be the most widely deployed chemical detector in use today.

It is used for the detection of Chemical Warfare Agents (CWAs) – including nerve, blood, blister and choking agents – as well as for the identification of a selected library of Toxic Industrial Chemicals(TICs). The detector also incorporates different operating modes ensuring optimal detection capability.

The detector is simple to operate, requires no calibration or routine maintenance and can log up to 72 hours of mission data for further analysis while user replaceable sieve packs reduce the need for factory based overhaul. A key benefit of this detector is its ability to specifically identify CWAs, however this advanced selectivity and makes simulant based training challenging.

The Argon LCD3.3-SIM

The LCD3.3-SIM is a training device that has been designed replicate the features and functionality of the actual LCD3.3.

The simulation detector responds to electronic sources that imitate the effects of chemical vapors, toxic substances and false positives and that realistically replicate the effects of wind direction and temperature, the depletion of sieve packs and batteries, confidence testing and the use of a survey nozzle.

With no requirement for simulants as part of training, there is zero possibility of environmental contamination or health and safety risk to instructors or students.

The device is compatible with a wide variety of other simulators (including simulators for the AP2C, AP4C, CAM, LCD3.2 and the RAID-M100) which means that multi-detector and multi-substance training can take place within the same scenario.

The inclusion of a remote control feature provides CBRNe and HazMat instructors with complete management of the exercise – from deciding on the effectiveness of decontamination drills, to simulating the effects of wind, temperature and persistency and the ability to instantly reset a scenario in readiness for a new exercise.

After Action Review (AAR) enables instructors to confirm that their students have set up and used the detector in accordance with the procedures for the real-life device. In the event of student error, the student performance reporting feature provides a detailed breakdown of their actions to assist with learning.

The use of innovative simulator detector training systems significantly increases personnel safety, as well as enhancing learning and easing regulatory pressures.

Such devices also place the instructor firmly in control of the exercise to ensure you’re delivering consistent, verifiable and measurable CBRNe/HazMat training outcomes.

This article was first published as a blog on the Argon Electronics website.

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About the Author

Steven Pike is the Founder and Managing Director of Argon Electronics, a world leader in the development and manufacture of Chemical, Biological, Radiological and Nuclear (CBRN) and hazardous material (HazMat) detector simulators.

When Oil and Water Mix: Understanding the Environmental Impacts of Fracking

Dan Soeder, director of the Energy Resources Initiative  at the South Dakota School of Mines & Technology, has co-authored the cover article titled “When oil and water mix: Understanding the environmental impacts of shale development,” in the recent issue of GSA Today, a magazine published by the Geological Society of America.

The article explores what is known and not known about the environmental risks of fracking with the intent of fostering informed discussions within the geoscience community on the topic of hydraulic fracturing, says Soeder. Soeder’s co-author is Douglas B. Kent of the United States Geological Survey.

In this paper, Soeder and Kent bridge the gap in consensus regarding fracking, providing current information about the environmental impacts of shale development. The article is open access and adheres to science and policy, presenting a complicated and controversial topic in a manner more easily understood by the lay person.

“Geoscientists from dinosaur experts to the people studying the surface of Mars are often asked by the public to weigh-in with their opinions on fracking. We wanted the broader geoscience community to be aware of what is known and not known about the impacts of this technology on air, water, ecosystems and human health.  A great deal has been learned in the past decade, but there are still critical unknowns where we don’t yet have answers,” Soeder says.

Development of shale gas and tight oil, or unconventional oil and gas (UOG), has dramatically increased domestic energy production in the United States and Canada.  UOG resources are typically developed through the use of hydraulic fracturing, which creates high-permeability flow paths into large volumes of tight rocks to provide a means for hydrocarbons to move to a wellbore. This process uses significant volumes of water, sand, and chemicals, raising concerns about risks to the environment and to human health.

In the article, Soeder and Kent address the various potential impacts of fracking and how those impacts are being addressed.  Risks to air include releases of methane, carbon dioxide, volatile organic compounds, and particulate matter. Water-resource risks include excessive withdrawals, stray gas in drinking-water aquifers, and surface spills of fluids or chemicals. Landscapes can be significantly altered by the infrastructure installed to support large drilling platforms and associated equipment. Exposure routes, fate and transport, and toxicology of chemicals used in the hydraulic fracturing process are poorly understood, as are the potential effects on terrestrial and aquatic ecosystems and human health.

Schematic diagram illustrating unconventional oil and gas (UOG) development activities relevant to research on human-health and environmental impacts (not to scale): well-pad construction (1); drilling (2); completion/stimulation (3, 4); production of natural gas (5) and oil (6) with well casings designed to protect drinking-water aquifers; ultimate closure (plug and abandon), illustrating legacy well with leaking casing (7); wastewater disposal (8); induced seismicity (9); landscape disturbance (10); and potential for transport pathways from deep to shallow formations (11). Also represented are water supply wells in shallow and deep aquifers (12). Photographs by Dan Soeder.

 

Canadian ban on asbestos and asbestos containing products

In the same week the cannabis became legal in Canada, the federal government announced the prohibition of asbestos and asbestos-containing products, according to a recent study published at DailyCBD.com.  The government action is considered the final step in the prohibition of asbestos and asbestos-containing products in Canada.

These new regulations are part of the government-wide strategy announced in 2016 to protect Canadians from exposure to asbestos. The new regulations prohibit the import, sale, and use of asbestos as well as the manufacture, import, sale, and use of asbestos-containing products, with a limited number of exclusions.

In addition, exports of asbestos and asbestos-containing products are now prohibited, with a limited number of exceptions, and the existing Export of Substances on the Export Control List Regulations and schedule 3 of the Canadian Environmental Protection Act, 1999 were amended to reflect that.

The new regulations and related amendments will come into force on December 30, 2018.  They will protect the health of Canadians by preventing new asbestos and asbestos-containing products from entering the Canadian market.

“This is the final step to ban asbestos in Canada.  We have followed through on our promise to deliver new, tougher rules to stop the import, use, sale, and export of asbestos in Canada. These measures will protect our communities and the health and safety of all Canadians,” stated Catherine McKenna in a news release.

Quick facts

Asbestos was declared a human carcinogen by the World Health Organization’s International Agency for Research on Cancer, in 1987.  At the height of its use, asbestos was found in more than 3,000 applications worldwide.

The regulations do not apply to residues left from mining asbestos.  However, these asbestos-mining residues cannot be sold for use in construction or landscaping without provincial authorization, and they cannot be used to make a product that contains asbestos. The mining of asbestos in Canada ceased in 2011.

Risks related to asbestos-containing products that are already in use or installed—such as in existing buildings, equipment, and vehicles—will continue to be managed by existing federal, provincial, and municipal rules and regulations. There are no significant health risks if asbestos fibres are enclosed or tightly bound, in good condition, and left undisturbed.

The use, sale, and export of any asbestos-containing products that exist in inventories but that have not yet been installed are prohibited under the new regulations and related amendments.

The current Asbestos Products Regulations under the Canada Consumer Product Safety Act will be repealed as these new regulations are more comprehensive.

What You Need to Know about Your Written Hazard Communication Plan

by Michael Collins, CIH, CSP, CIEC, GLE Associates

The United States Occupational Safety and Health Act (OSHA) requires employers to maintain a written hazard communication plan that effectively protects workers from potentially harmful chemical exposure in the workplace. On the surface, the requirement sounds simple, yet failure to meet this requirement is the second most commonly cited OSHA violation.

Here’s what you need to know to ensure you comply with this simple, critical OSHA requirement.

Who Needs a Written Hazard Communication Plan?

OSHA regulation 1910.1200 requires all employers with hazardous chemicals in their workplaces to prepare and implement a written hazard communication plan. This applies, according to the regulation, “to any chemical which is known to be present in the workplace in such a manner that employees may be exposed under normal conditions of use or in a foreseeable emergency.”

There are some exclusions to the requirement, including ingredients in food, certain pesticides, and distilled spirits. In most cases, the excluded chemicals are covered by other regulations. For full information, visit OSHA’s hazard communications page.

What are the Key Requirements of the Written Hazard Communication Plan?

Employers are responsible for developing and maintaining a written hazard communication program for the workplace that includes:

  • Safety Data Sheets (SDSs) for each chemical present
  • Lists of hazardous chemicals present, referenced in each case to the appropriate SDS
  • Appropriate labeling of containers of chemicals in the workplace
  • Labeling of containers of chemicals being shipped to other workplaces
  • Preparation and distribution of SDSs to employees and downstream employers
  • Development and implementation of employee training programs regarding hazards of chemicals and protective measures, which must be provided at the time of the employee’s initial assignment, as well as whenever a new chemical hazard is introduced to the work area
  • The methods the employer will use to inform employees of the hazards of non-routine tasks, and the hazards associated with chemicals contained in unlabeled pipes in their work areas

Employers are further responsible for making the written hazard communication program available, upon request, to employees and their designated representatives.

What Hazards Does the Standard Protect From?

Chemicals can pose a wide range of health hazards, including but not limited to:

  • Irritation
  • Sensitization
  • Carcinogenicity
  • Flammability
  • Corrosion
  • Reactivity

The written hazard communication plan helps protect workers from these and other risks associated with exposure in the workplace.

How to Prepare Your Written Hazard Communication Plan

Writing a hazard communication plan is not overly complicated, but it’s critical that you get it right. Start by collecting data on all potentially hazardous chemicals in use at your work site. Make a list of them. Gather SDSs for each chemical, and reference the SDS for each one inside the master list.

Identify which workers experience exposure risk during the course of their workday, as well as in foreseeable emergency circumstances. Develop an information and training program to ensure workers understand the hazards present in their workplace, as well as appropriate protective measures for those hazards. And, conduct personal air sampling for these chemicals to establish OSHA-required Negative Exposure Assessments (NEAs).

Many employers prefer the confidence and ease of hiring an experienced firm like GLE to prepare an OSHA-compliant written hazard communication plan on their behalf and conduct NEAs.

 

This article was first published on the GLE Associates website.  GLE is an integrated architecture, engineering, and environmental consulting firm, headquartered in Tampa, Florida, with offices throughout Florida and the Southeastern United States.

 

HAZMAT Training – Precautions to Consider

By Ryan Henry, HazSim

Training is an essential priority for any subject that we wish to become proficient in. The HAZMAT training field is no exception to this. However, due to the serious and strenuous nature of HAZMAT response, it is important to safely execute training in a way that doesn’t damage our gear or our health.

Often times one of the most costly things we can do to our response gear is ruining it while in training, rendering it useless during an actual event. Ripping and tearing your issued PPE during a training that, let’s face it could have been planned better, hurts no one but our own members. From bunker gear scraping across a concrete truck bay to a plastic CPC being torn from an ultra-impossible scenario that our training officer threw together can become costly and wasteful.

I may strike a nerve with this one, so prepare yourself now. I feel that most chemicals we commonly deal with as HAZMAT responders can be mimicked with much safer alternatives – rather than using the real things. Many times training facilities or classes boast the fact that live agents are used, and this peaks much interest for the student.

Degrading our PPE for the sake of real meter readings and visual cues is a costly degradation to bestow upon gear that you will decon and possibly re-don in the near future and assume it will protect you adequately. Visual cues are able to be exaggerated, and meter readings manipulated without exposing your gear, and potentially yourself, to harmful materials that every day becomes part of a long list of carcinogens.

Another consideration during training is that of your gas detection equipment. It is no secret that gas detection equipment can be very costly, and sometimes hard to replace. While learning how to use and interpret your detectors efficiently is imperative; a mistake while training could render some out of service for quite some time. We are always looking for ways to make detection more realistic, whether through cross sensitivity or simulation. Sometimes, however, an overzealous approach to making meter equipment respond to atmospheric stimuli – can end up costing us in burned sensors, and possible damage to our front line equipment. Simulation is the future of training, and gas detection is no exception to this.

Time and time again, especially in this glorious age of the internet we are in, we are bombarded with self-proclaimed subject matter experts, who claim their tactics are the only way, or that their way of approaching specific problems is pretty much be all end all. Sifting through these mirages and other facades can prevent us from potentially wasting time, or not being open to other ways of thought about particular subjects.

These statements are true not only for HAZMAT, but fire, and pretty much any other subject if you look hard enough only. It’s great to try new tactics, and store them in your toolbox for the next time the alarm goes off, however, keep an open mind. While I love my leather helmet, I am very open to the possibility that technology may be to the point where I need to hang it on a wall and choose safety over looks.

In closing, training in a necessity for all of us no matter what industry we are in. From oil and gas to emergency response, staying up to date on our skills and tactics is a must if we are to remain successful. Keep an open mind, and protect your equipment. These are the biggest keys to remember while training. Or you may find yourself with an expensive bill, and a rookie who really didn’t learn anything.

This article was first published on the Hazsim website.