Chemicals: safe mixing and loading
If you decide to pre-treat the wash water and dispose of it
on-site instead of recycling it, you should call your local EPA
office to determine whether they will require you to obtain a
permit to do so.
If you decide to pre-treat the wash water and dispose of it on-site instead of recycling it, you should call your local EPA office to determine whether they will require you to obtain a permit to do so.
If you manage employees, you're expected to develop and maintain standard management practices that will protect them and, at the same time, reduce costs and potential liabilities. If your employees handle chemicals, it's vital to put in place safe chemical mixing and loading practices — not only for the benefit of the employees, but for the environment as well.
Before planning out your worker-protection practices, consider that there are some guidelines already established by regulatory bodies, and you must be in compliance with their standards. These groups include the Environmental Protection Agency (EPA), Occupational Safety and Health Administration (OSHA) and local regulatory agencies. While you are planning, also take note of each element that your plan must address. These include designing and constructing a proper mix-and-load area and storage facility to ensure you have safe storage for pesticides, fungicides, insecticides and herbicides; making necessary preparations for handling and mixing of pesticides, as well as loading them into spray equipment for application; setting up a disposal system for left-over pesticides; knowing where you'll be cleaning pesticide containers and pressure-washing application and other equipment that has been touched by chemicals.
Designing the mix-and-load area
Your first step towards compliance with established safety standards is designing a proper maintenance site, mix-and-load area and storage facility. Select an area that is spacious, away from any body of water or stream, and where you can restrict entry of unauthorized persons. Next, design and build a non-pervious, permanent concrete pad adjacent to the chemical storage shed for mixing and loading and a separate, sealed concrete pad on which to wash equipment. This is necessary because, according to university and EPA studies, even small amounts of chemicals repeatedly dropped on the ground in the same location can build up over time and contaminate the soil, ground and surface water. Ideally, you should construct a shelter over both pads to protect your employees from inclement weather and minimize the rainfall-based runoff from the pads. Install a chemical-resistant sump basin and pump to facilitate the collection of any spills, and design them to pump into a chemical holding unit.
You may decide to construct your own chemical-storage shed. However, keep in mind that several manufacturers offer pre-fabricated buildings — with all of the necessary features included — that can be delivered straight to your door. Either way, make sure your shed includes these options:
Secondary leak-proof flooring below chemical-resistant grating to collect spills and prevent run-off and contamination (it is usually required that this be able to hold 130 percent of the largest vessel's content)
Hands-free mix-and-load enclosed chamber
Automatic ventilation system
Hand and eye wash basin with a hookup to a potable water source
Sump system in the flooring
Special chemical-resistant interior lighting
Employee safety posters such as Pesticide Safety Information Series A-8 (you can find these by visiting the EPA's web site at www.epa.gov/pesticides)
Leaflets and Material Safety Data Sheets (MSDS) written in English and Spanish readily available at a centralized location (these are available from the EPA or chemical manufacturers)
Temperature control or insulation, depending on the climatic conditions
Visible signage written in English and Spanish on the exterior of the building (such as “NO SMOKING,” and “WARNING PESTICIDE STORAGE”).
Employee training and handling procedures
As a manager, it is your responsibility to make sure that all employees who handle pesticides are properly trained to do so. Put your training program in writing and hand it out to each employee working in the facility. Also make a copy available at a central location at the workplace. Include information such as study guides; pesticide product labeling; Safety Information Series (SIS) leaflets and MSDS (in English and Spanish, as well as other languages if necessary); slides and videos if applicable; and any other information that you provide in the training course, including the name of the person or firm providing the training.
Employee training should cover pertinent information for each pesticide or chemically similar group of pesticides, and should include:
Learning to read and understand the product labels and directions (remember that labels are considered a legal document)
Chemical hazards including signs and symptoms of acute exposure
Common ways that pesticides can enter or be absorbed into the body
Emergency aid procedures
Safety procedures including proper handling techniques.
Following these guidelines and maintaining accurate records can help reduce the number of accidents and resulting injuries. Have each employee involved in the initial and any subsequent training courses sign an acknowledgement that they went through the training course and received and understood the packet of materials.
Proper storage of pesticides
Once you have installed your storage facility, you are ready to stock it. Some simple, common-sense rules pertain to the safe storage of these pesticides. Keep similar pesticides together. For example, if you keep herbicides with herbicides and fungicides with fungicides, an employee who is conducting the application will be less likely to make a mistake in mixing the wrong ones together. Also, you should store flammable chemicals in a separate area. Once these containers are empty, triple rinse and crush them so that they may be transported to an approved landfill or waste facility. If you are not sure where to take them, simply call your local waste-management facility or regional EPA office for a list of locations near you.
In the event an accidental spill or large leak occurs, you must be prepared to locate and control the source. Re-direct large spills away from water sources, ditches or storm drains. Instruct employees, as part of their training, to report the spill as soon as possible.
Keep them separated
The trend for many golf courses today is to combine the mix-and-load facility with a wash-down area for application and mowing equipment. The non-pervious concrete pads for the mix-and-load area should be completely separate from the equipment-washing area so that accidental spills cannot run over onto the mix-and-load area and rainwater cannot carry pesticides over to the washing pad. Typically, your wash-down area should contain wash-water recycle or discharge equipment, which is designed to handle trace amounts or “small spikes” of the chemicals that could show up on a daily basis. These include hydrocarbons, oils and metals from equipment as well as grass cuttings that are washed off onto the pad. A recycle or discharge system, which contains enhanced biological media and oxidation/aeration as part of its technology, will break down the small amounts of pesticides typically found in minor spills and “small spikes,” allowing you to safely re-use the water or discharge.
Spills or leaks (“large spikes”) in concentrated form will quickly saturate the filtration materials or biomedia of the recycle or discharge system, and allow chemical compounds to flow through to the pressure washer user. Not only is this unsafe for employees, it's not economical for you because you'll constantly be changing the filter cartridges and wash water.
If you decide to pre-treat the wash water and dispose of it on- site instead of recycling it, you should call your local EPA office to determine whether they will require you to obtain a permit to do so. Local environmental offices are more than happy to work with facilities on these projects and prefer to do so in lieu of enforcement actions after the fact.
For your own protection
Putting together a complete safety program for mix-and-load operations will make it easier for you and your employees to adhere to workplace safety regulations. It will also boost the efficiency of your mix-and-load operations and give you the peace of mind that comes from knowing that you are complying with required practices for pre-treating and disposing or recycling of wash water.
Sharon Rinehimer is corporate counsel for RGF Environmental Group, Inc. (West Palm Beach, Fla.), which designs and manufactures technology for industrial pollution control, as well as for waste-water pre-treatment and recycling systems. RGF also offers turn-key services that include mix-and-load pad designs, chemical sheds and discharge and wash-water recycling systems. You can reach her by phone at 800-842-7771 or though the company's web site at www.rgf.com.
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