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Definitions
ANSI
Z400.1
Material Safety Data Sheet (MSDS)
Review, Development, and Generation
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ANSI
Z400.1 is the American National
Standard for Hazardous
Industrial Chemicals - Material Safety Data Sheet - Preparation,
published by the American National Standards Institute, Inc. (ANSI).
and
sponsored by the Chemical Manufacturers Association (CMA). The standard
was developed in recognition of the need for guidance to help Material
Safety Data Sheet (MSDS) preparers develop consistent, understandable
MSDSs that pertain to a wide variety of MSDS users. It identifies
information that must be included in a Material Safety Data Sheet to
comply with the OSHA Hazard
Communication Standard (HCS), as well as state and Federal
environmental and
safety laws and regulations. Material Safety Data Sheets are useful on
a variety of levels. MSDSs provide much needed information in the event
of an emergency, and MSDSs also assist warehousemen and consumers in
proper storage and handling, disposal, and health and safety risks, in
addition to other details. RCS, Inc.'s regulatory experts can
evaluate a product and create a Material Safety Data Sheet that
effectively communicates any hazards associated with the substance and
exceeds regulatory standards. In addition, our associates can evaluate
a current MSDS, determine areas of deficiency, and revise the MSDS as
necessary. At RCS, Material Safety Data Sheets are always created and /
or evaluated by a highly educated technician according to the ANSI
standard, never a computer program,
and we are capable of reviewing / creating one single product MSDS or
thousands of different MSDSs.
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Compliance
Audit
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A
Compliance Audit
is performed at a facility by RCS, Inc.'s highly qualified regulatory
professionals to identify potential hazards
that may be regulated by the following agencies: DOT, EPA, NFPA, OSHA,
as well as other local, state, and Federal regulatory bodies.
Compliance Audits cover paperwork requirements, including training,
written plans,
and miscellaneous items such as mandatory postings, record keeping, and
permitting as required by the Department of Transportation, the
Occupational Safety and Health Administration, and the Environmental
Protection Agency, both at the state level and the Federal level.
Compliance Audits also include a physical walk-through of the facility
to
investigate interior and exterior facility elements that are regulated
by the DOT, EPA, and / or OSHA. General Warehouse elements are also
reviewed thoroughly as they pertain to OSHA, DOT, EPA, and NFPA
requirements. A complete Audit Report is provided to the facility upon
completion of the audit which identifies deficiencies and recommends
areas for improvement.
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Contingency
Plan
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RCS
technical
associate can assist companies in the development and implementation of
a Contingency Plan. Contingency Plans follow guidelines issued by the
Resource Conservation and Recovery Act (RCRA) under the United States
Environmental Protection Agency (EPA) for the management and disposal
of
hazardous waste at a facility. Although the facility is responsible for
the compliance with environmental regulations put forth by the
Environmental Protection Agency (EPA), RCS Inc. is able to
provide expert guidance to the company in regard to waste management
activities and decisions. An EPA Contingency Plan describes the
hazardous waste management program at a
facility by providing detailed written procedures for the handling,
storage,
labeling, and disposal of hazardous waste.
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Discharge
Prevention, Containment and Countermeasure / Discharge
Cleanup and Removal Plan (DPCC/DCR)
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Discharge
Prevention, Containment and Countermeasure / Discharge
Cleanup and Removal (DPCC / DCR) plans are required for facilities that
use, store, transfer, or process hazardous substances in the state of
New Jersey. These plans are regulated by the New Jersey Department of
Environmental Protection (NJDEP) Bureau of Discharge Prevention and
describe the storage,
facility complex, maintenance procedures, training procedures, SOPs,
and contact information in the event of an accident.
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Department
of Transportation (DOT) HM-126F Training
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Warehouseman and / or Management
Level
HM-126F – This DOT General Awareness training program is
intended for any associates involved in any way with the transportation
of hazardous materials. This training is required for all workers
involved with hazmat. The warehouseman level DOT HM-126F training
program was created to provide general awareness for hazardous
materials workers to meet the requirements set forth by the Department
of Transportation. The DOT requires that all workers involved with
hazmat must be trained within 90 days of hire, and yearly thereafter,
except when the worker's responsibilities change, and then DOT training
is required within 90 days of the change. Additional DOT and safety
training may be required, depending on the worker's specific job
function.
In addition to General Awareness training, the Department of
Transportation (DOT) requires Function-Specific training for employees
to teach the necessary knowledge, skills, and abilities for an
individual's specific job function. Function specific DOT training
needs will
vary depending on the individual's involvement in the hazardous
materials transportation cycle. Department of Transportation HM-126F
training programs that are required by the Department of Transportation
are available at the Warehouseman Level, as well as more extensive
Management Level training.
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Department of Transportation (DOT)
Security Plan
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The
Department of Transportation (DOT) requires that certain facilities
that ship hazardous materials must implement a facility Security Plan
and applicable training. The Security Plan addresses the realization
that hazardous materials in transit are vulnerable to sabotage and
misuse, and if in the wrong hands, pose a significant threat to
national security. To combat this realization and raise awareness on
all levels, the DOT Research and Special Programs Administration (RSPA)
issued new regulations that are intended to enhance the security of
hazardous materials in transit. The new DOT regulations impose Security
Plan and Security Training requirements on certain hazardous materials
shippers and carriers.
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Emergency
Planning and Community Right to Know (EPCRA)
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The Emergency
Planning and Community Right-to-Know (EPCRA) Act was passed in 1986 in
response to concerns about the storage and handling of toxic chemicals
and their associated environmental and safety hazards. To reduce the
likelihood of a major disaster in the United States, the EPCRA
establishes requirements for Federal, state, and local governments, as
well as Indian Tribes and industry regarding Emergency Planning and
Community Right-to-Know reporting for hazardous and toxic chemicals.
The EPCRA requirements include:
- Emergency planning
(Section 301-303)
- Emergency release
notification (Section 304)
- Hazardous chemical
storage reporting requirements (Sections 311-312)
- Toxic chemical
release inventory (Section 313)
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Responsible
Care
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The
Responsible Care program was implemented by the American Chemistry
Council in 1988. Responsible Care is a voluntary program intended to
achieve improvements in environmental, health, and safety performance
beyond that which is required by the US government. Participants in
the Responsible Care program are committed to working toward the
vision of "no accidents, injuries, or harm to the environment" and
agree to "publicly report global health, safety, and environmental
performance". Responsible Care members also agree to lead their
companies in "ethical ways that increasingly benefit society, the
economy, and the environment".
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Risk
Management Plan (RMP)
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The
US Environmental Protection Agency (EPA), under the Clean Air Act (CAA)
Amendments
of 1990, provides regulations and guidelines for chemical accident
prevention at facilities that use extremely hazardous substances.
Regardless of size, companies that use certain flammable and toxic
substances are required to develop a Risk Management Program (RMP) to
meet EPA requirements. The
Risk Management Program is intended to reduce chemical risk at the
local level, in an effort to assist fire, police, and emergency
response personnel and provide for a better understanding of chemical
hazards to the surrounding community. Companies may refer to the List
of Regulated Substances, found in 40 CFR Part 68, Section 112 (r), to
determine if a particular operation is subject to the EPA RMP
requirements. Risk
Management Plans must be revised and resubmitted to the US EPA every
five years.
EPA Risk Management Programs (RMPs) must include:
Hazard
Assessment:
details potential effects of an accidental release, accident history,
and evaluation of worst case and alternative accidental releases.
Prevention
Program: includes safety precautions, as well as employee
training, maintenance, and monitoring.
Emergency
Response Program:
details employee training, emergency health care, and procedures for
informing emergency response agencies and the public in the event of an
accident.
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Standard
Operating
Procedure (SOP)
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Standard
Operating Procedures are necessary in a Quality environment to ensure
that all processes are documented and performed according to a
standardized, approved process. Standard Operating Procedures are
written, controlled documents that explain the step-by-step procedure
for task completion. SOPs should be ever-changing, as a company strives
to continually improve processes and procedures to eliminate waste and
streamline processes. Standard Operating Procedures clearly state
details of a task, such as the Scope / Purpose, Responsibility and
Authority, Process, Related Procedures, Records, and Revisions.
Standard Operating Procedures are an integral part of the ISO
certification process.
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Stormwater Pollution
Prevention Plan (SWPPP)
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The
Stormwater Pollution Prevention Plan (SWPPP) is required by the US EPA
(Environmental Protection Agency). The Clean Water Act (CWA) Amendments
of 1987 required the EPA to regulate storm water discharge under the
National Pollution Discharge Elimination System (NPDES). Regulations
published by the EPA as a result of the CWA Amendments in 1990 require
certain facilities that discharge to the waters of the United Sates to
apply for NPDES permits. The EPA has identified 11 categories of
industrial activity as facilities with "storm water discharge
associated with industrial activity" that must apply for a NJDEP SPCC
permit. Part of the permitting requirement of the US EPA NPDES permit
includes preparation of the Stormwater Pollution Prevention Plan
(SWPPP).
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Underground
Storage Tanks - RCRA Subtitle I
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The
Resource Conservation and Recovery Act (RCRA), Subtitle I, regulates
underground storage tanks (USTs). The EPA announced four initiatives
for
the Underground Storage Tank Program in 2000, including improvement of
compliance, clean-up of known petroleum leaks, ensuring new tanks are
better designed and operated, and recycling America's abandoned gas
stations. The Underground Storage Tank Program was enacted by President
Reagan in November 1984, making this year the 20th anniversary of the
Underground Storage Tank Program. The EPA requires underground storage
tanks to have preventive measures for spill, overfill, and corrosion
protection, as well as release detection, corrective action, and proof
of financial responsibility. In 1988, RCRA Subtitle I was amended to
create LUST (Leaking Underground Storage Tank) Trust Fund to oversee,
enforce, and pay for clean up at contaminated Underground Storage Tank
sites.
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For pricing
information or quotes, please contact our
Client Assurance
Department toll-free at:
877-377-4243
Our Client Assurance Representatives are
available between the hours of 9 AM and 5 PM EST.
P.O. Box 2028
Heath, Ohio 43056-0028
FAX (740) 344-9501
Email
RCS
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