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2004 National Environmental Assistance Summit Incorporating P2 and Toxics Education into Compliance Inspections : 

2004 National Environmental Assistance Summit Incorporating P2 and Toxics Education into Compliance Inspections Virginia St. Jean, CIH Hazardous Materials Unified Program Agency (HMUPA) San Francisco Department of Public Health

Some Important Questions To Ask: 

Some Important Questions To Ask Why are we still seeing so many hazardous materials and hazardous waste violations? Why are we still seeing so many hazardous materials used? Are the new products really better for us and the environment? How do you know? Why is there still pollution with all of our efforts to protect the environment? How can we be more effective conducting inspections and still meet our inspection quotas?

The Business Perspective: 

Most businesses don’t want to be out of compliance- it’s embarrassing, expensive and can increase liability. Most businesses don’t want to pollute their employees or the environment. Most businesses want compliance assistance, but tend to learn about regulations from their inspectors. Most businesses complain that there are too many agencies regulating them with a narrow focus. The Business Perspective

More Business Concerns: 

More Business Concerns Most businesses complain that there are too many regulations! Most businesses are learning about chemical hazards from their vendors. Most businesses want unbiased help choosing “green” products- difficult to judge relative hazards using MSDSs. Economic burden- can’t afford to hire a environmental or industrial hygiene consultant.

More Business Concerns: 

More Business Concerns Easier and more comfortable not to change anything- don’t have to change training and inventory reporting. Risk of trying a new system or product and having customer not like substitute’s performance; potential of losing customer. No one agency looks at the whole operation- most agencies focus on one media only.

Vendor/Manufacturer Concerns: 

Vendor/Manufacturer Concerns Vendors/Mfrs have to keep their products compliant to sell their products legally, so are forced to make/sell new reformulated products as regulations change. Vendors/Mfrs need to keep customer satisfied to keep customers. Vendors may be hesitant to recommend new “green” products in case customer is not satisfied or customer may be resistant to change.

Vendor/Manufacturer Concerns, cont.: 

Vendor/Manufacturer Concerns, cont. Vendors are not always safety, health or environmental experts, but want to help customers and are often put into the position of giving relative health or environmental advice about products. Vendors/Mfrs may be selling “green” products with new formulations with uncompleted long term toxicity studies. As long term studies are completed, formulations may change again. Hard to stay experts in their products when formulations change quickly.

Inspector Challenges: 

Inspector Challenges Most regulatory agencies are have full plates. Hard to educate businesses while inspecting when inspectors are pressed for time. Most agencies and agency auditors judge inspector performance by how many inspections they conduct and if they conduct their routine inspections within required frequency (annually or triennially).

Inspector Challenges, cont.: 

Inspector Challenges, cont. Some inspectors are more comfortable as educators than others. Some inspectors are not comfortable training on subject matter outside their primary purview. How do agencies make this education transition when in crisis mode- who has time to figure it out?

Inspector Challenges, cont.: 

Inspector Challenges, cont. SFDPH already regulates hazardous materials, hazardous waste, underground and aboveground storage tanks (active tanks and oversee removals), hazardous waste treatment sites, medical waste generators, regulated substances (EHS), CFC recycling and back up diesel generators- full plate! Inspectors already feel they are “jack of all trades” and may not welcome pollution prevention and toxics reduction educating into their already full plates. How to do more with less?

A Simple Idea But Not So Simple To Implement: 

A Simple Idea But Not So Simple To Implement Toxics Education Benefits Educate businesses on all applicable compliance issues and which chemicals to avoid Better compliance, less hazardous materials, less hazardous waste generated, less pollution

How to Bridge the Gap in Theory: 

How to Bridge the Gap in Theory If we start to look at business compliance improvements as a result of extra time spent on site educating, we should be able to justify that extra time, especially since compliance is our primary job function. If we measure compliance progress from inspection cycle to inspection cycle, we can quantify improvements (much easier if inspections are electronically tracked).

How to Bridge the Gap in Theory, cont.: 

How to Bridge the Gap in Theory, cont. If we assist businesses with all applicable regulations (air, fire, water, hazmat and hazwaste), they begin to understand how all tie together- need industry specific compliance training guidelines. NEED TO CHANGE THE QUOTA SYSTEM! Judge employee performance by how much businesses improve compliance and sustainability. Need to add health and safety educating to the equation. Need to learn what products are used in each industry type (all ingredients) and help businesses understand associated hazards.

How to Bridge the Gap in Theory, cont.: 

How to Bridge the Gap in Theory, cont. Need to work with businesses to find safer or “greener” product substitutes, if available. Get their input. Use precautionary principles, especially with new product formulations. Look at pollution prevention education opportunities during each inspection. Many businesses want assistance determining best management practices.

Tools Available to Rate Relative Hazards of Products: 

Tools Available to Rate Relative Hazards of Products MSDSs and ingredients from label. Environmental Preferable Purchasing lists and criteria (have to rate each new formulation as products change). OSHA, NIOSH and State Health Service Departments. Other regulatory agency networking- ensure one product does harm one media, while harming another (MTBE and n-hexane examples). Business experiences with new products- they are the best experts in effectiveness of products. Get them involved in the process of toxics reduction.

San Francisco’s Efforts: 

San Francisco’s Efforts We are partnering with other regulatory agencies who also oversee businesses in our purview to develop business friendly compliance assistance tools. We are getting business input on what is most effective for them and their industry type (surveys, interviews, and peer leader input). We are using existing resources within SF to assist- many agencies have similar missions such as solid waste management agencies, conservation agencies, power companies, water bureaus, and labor unions, for example.

San Francisco’s Efforts, cont.: 

San Francisco’s Efforts, cont. Find a tool that will work for your city, county or state. In the SF area we have the Bay Area Green Business Program which has a compliance component as well as sustainability components. ( Green Business Checklists are available for auto repair, hotels, printers, restaurants, office/retail, garment cleaning (soon), landscapers and general standards for other types of industries.

San Francisco’s Efforts, cont.: 

San Francisco’s Efforts, cont. Appoint a city or county coordinator to work with other area counties and state agencies for consistency and efficiency. Don’t reinvent the wheel unless necessarily. Work with one industry type at a time and get all “partners” to participate. Some partners have staff to share, while other partners have expertise. Some may even have funding or translation services to contribute.

Bay Area Green Business Program: 

Bay Area Green Business Program Voluntary Certification Program. Business pledges to comply with all applicable environmental regulations and strive to exceed compliance. Business demonstrates P2, toxics reduction, energy and water conservation, and solid waste reduction. Business receives free conservation and P2 audits. Certification good for 3 years. Revocation policy for non-compliance or not maintaining minimum checklist measures to maintain certification.

Auto Repair Industry Model: 

Auto Repair Industry Model Determine all applicable environmental regulatory agencies that regulate the auto industry. In SF that includes air district (regional as well as state air board), water district, fire department, health department, CalOSHA and SF Port authorities. Try to get their support with your education efforts. May need to market this (what’s in it for them) as they may be understaffed as well. Remember: they want better compliance, also. Determine Best Management Practices for the industry- many resources available on internet. Include P2, toxics reduction, water and energy conservation and solid waste reduction. Meet with partners regularly and work together.

Auto Repair Industry Model, cont.: 

Auto Repair Industry Model, cont. Work with auto repair shops to determine what chemicals they are using. Look at ingredients and educate business on the toxicities of the ingredients. Inform business of possible safer substitutes or have them work with their vendors to find best and safest product for the job. They want to know what chemicals to avoid so they can inform their vendors of their desire to avoid those chemicals. Remember-it has to be effective or no one will use the product. Use staff industrial hygienists to assist in the toxics education if available.

Chemical Usage Table for Auto Repair Shops: 

Chemical Usage Table for Auto Repair Shops

Parts Washing: 

Parts Washing Old Methods of Degreasing: Parts washers that use ketones, various acetates, petroleum blends with or without chlorinated hydrocarbons The Problem with old method: Solvents are CNS depressants and some cause cancer. High VOC’s which make them greenhouse gases. Lose a lot of product to atmosphere while exposing employees to health hazards.

Parts Washing, cont.: 

Parts Washing, cont. New Methods: Aqueous solutions- basically surfactants in water. Warm water is more effective than cold, but uses more energy to heat tank. Types available: Dishwasher style Sink top style Ultrasonic Enzymes Be cautious of new types of organic solvents such as volatile methyl siloxanes and brominated hydrocarbons. Long term toxicities still being evaluated. Use precautionary principles.

Brake Cleaning: 

Brake Cleaning Old Methods: Solvent Dip Tanks Aerosol Cleaners New Methods: Water Dip Tanks Drying with Compressed Air No Aerosols Needed

Aerosol Cleaning: 

Aerosol Cleaning Positives Popular with Employees Easy to Use Product “Hits” it’s Target Specific Cleaners Negatives Toxic Ingredients - “Toxic Soup” Propellant – Not an Active Ingredient More of an Inhalation Hazard due to Aerosol Form

ARB Aerosol Regulations: 

ARB Aerosol Regulations In CA Air Resources Board has banned the manufacturing and use of chlorinated solvents in aerosols. In California, aerosols are regulated by CARB (regulate less than 2 gallon container sizes). Regional air districts regulate the stationary sources such as parts washer tanks. Check with your air boards to see how aerosols are regulated in your areas.

Aerosol Trends in CA: 

Aerosol Trends in CA Aerosols: More Toxic Solvents (OSHA PELs from 1997, CalOSHA and NIOSH may be significantly lower ppms) Chlorinated hydrocarbons- CNS, liver, carcinogen Methylene chloride (25 ppm) Perchloroethylene (100 ppm) Trichloroethylene (100 ppm) Trichloroethane (350 ppm) Brominated hydrocarbons- CNS, liver, reproductive toxin N-bromopropane (TLV not yet established) N-hexane- Peripheral neuropathy (500 ppm)

Aerosol Trends in CA: 

Aerosol Trends in CA Aerosols: More Toxic Solvents (Cont.) Aromatic hydrocarbons-CNS, liver Xylenes (100 ppm) Toluene (200 ppm) Ethylbenzene (100 ppm) Aromatic blends Methyl ethyl ketone- CNS (200 ppm) Cyclohexanone (50 ppm) Butanol (n-butanol 100 ppm, tert-butanol 100ppm, sec-butanol 150 ppm) Naphtha (coal tar 100 ppm) Volatile methyl siloxanes- uterine cancer (MSDS from 11/02 10ppm)

Aerosol Trends: 

Aerosol Trends Aerosols: Less Toxic Solvents Heptane (500 ppm) Acetone (100 ppm) Isopropyl alcohol (400 ppm) Methanol (200 ppm) Ethanol (1000 ppm) Ethyl Ether (400 ppm) Aerosols: Less Toxic Aliphatic vs. Aromatic Hydrocarbons Aqueous

Common Floor Cleaning Chemicals: 

Common Floor Cleaning Chemicals Acids (usually hydrochloric or sometimes a weaker acid) Sodium metasilicates in combination with a caustic or glycol ether Phosphate cleaners (TSP) Glycol ethers Various detergent and water solutions Alkyl Phenols (endocrine disruption)

Floor Cleaning Best Practices: 

Floor Cleaning Best Practices Seal the floor Use dry floor clean-up methods Rags Hydrophobic Systems Eliminate the use of loose absorbent

Education is the KEY: 

Education is the KEY Education is the key for inspectors in the millennium. We are the most knowledgeable about compliance issues, chemical hazards and looking at the whole picture. If we educate our regulated businesses a bit more, we will be seeing increased compliance as well as a good understanding of specific pollution prevention practices for that business. Simple and site specific toxics education is welcomed by businesses and makes us more effective in implementing P2 change.

Contact Info: 

Contact Info If you have any questions or comments, please feel free to contact me: Virginia St. Jean, CIH 415-252-3907 HMUPA 1390 Market Street, Ste. 210 San Francisco, CA 94102

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