February 2015 Slips and Falls Winter conditions make it almost impossible to avoid walking/driving on ice or snow at some point. This is a major safety issue in the workplace. The United States Occupation Safety and Health Administration (OSHA) recently conducted a study on slips and falls in the workplace and made the following discoveries: Injuries from slip and fall are the most common work related injury. 25,000 slip and fall injuries happen every day. 35% of all work related injuries are from slips and falls. 65% of all work days lost are from slips and falls. The total annual cost of slip and fall injuries in the United States in over $60 billion annually 66% of falls happen on the same level resulting from trips. It's worth the extra time and expense to shovel, plow and salt. Walkways and parking areas require multiple visits to insure they are clear and safe at all times. A written plan and specific people or groups should be assigned to maintain clear safe walkways and parking areas. With some planning the amount of slips and falls this winter can be drastically reduced. It's ultimately up to each individual to plan, stay alert and pay attention. Remember to stay aware of slippery conditions. Bulging Drums Bulging drums are a major concern this time of year. Temperature can effect the internal PSI of drums. The NFL has educated us in that fact recently. The truth is temperature is only one reason drums might build up unsafe levels of pressure. Temperature change from 30 degrees F to 90 degrees F in a 55 gallon steel drum has been tested to increase the inside pressure by 2 PSI. Other common causes for unsafe bulging 55 gallon drums are:

Chemical reaction inside the drum. Materials mixed together and sealed inside a tightly closed drum will often result in a bulging drum issue. Biodegrading of organic materials. Chemical breakdown of organic compounds produce gas that can increase pressure inside a sealed drum. Overfilling drums Drums filled with more then 50 gallons does not allow room for expansion with temperature changes. This can cause buildup of pressure inside drums. Chemicals with high vapor pressure. When temperatures increase these can cause issues. The amount of pressure inside a drum can cause a violent, explosive reaction causing the lid to release the built up pressure. This violent shooting up of the lid can be deadly. Self venting drums vent at approximately 14 PSI. This level might seem low but at that PSI the force on the lid is in excess of over 5300 LBF. At 14 PSI the lid could fly as high as 20 feet in the air. Louis Sferrazza and Michael William, PHD studied and tested bulging drums back in 2000. The information I have gathered has come directly from this study. The information is something that should be shared with anyone opening drums. Using the standard 55 gallon H steel open top drum they discovered the following to be true: 1 PSI the lid flew 2 feet with 380 LBF 6 PSI the lid flew 10 feet with 2280 LBF 10 PSI the lid flew 15 feet with 3801 LBF 14 PSI the lid flew 20 feet with 5322 LBF The self venting drums did not vent until the internal PSI reached above 14 PSI. The drums contained deadly force long before reaching the 14 PSI level. How to determine if there is a dangerous level of pressure? Bulging drums require a safe, remote opening. Detecting that a drum may contain dangerous pressures before someone attempts to open it can be done with some education. Three things everyone dealing with drums should be aware of: 1. Bulging top or bottom should be a red flag. 2. The lid of a normal 55 steel drum will have a minimum of 1/2 inch movement when pushed down on with your hand. If this movement is not there, pressure could be the reason. 3. Tapping on the lid of a steel drum will have a higher tone with increased pressure. Being aware and using a combination of these techniques could prevent some of the accidents and near misses associated with pressurized drums. What to do when a pressurized drum is suspected? Do not overpack it!

The pressure must be released safely. Every situation is different but a safe method of releasing the pressure is needed. Remote opening practices will differ depending on the situation and location. Devices are available for helping with bulging drums. Cycle Chem can also respond to bulging drums if needed. TRIR Update Great News! Due to our employees concerns for company safety, our TRIR (Total Recordable Incident Rate) is the lowest in the company's history. We want to thank ALL our employees for their dedication and focus on our safety programs. Company: TRIR: CVI 1.28 CCI/DG 1.88 EnviroTech 0.00 e-manifest As many of you are aware the Hazardous Waste Electronic Manifest Establishment Act (e Manifest Act, October 2012) calls on the agency to establish this Board by October 2015, to provide recommendations on the e Manifest system and associated User Fees. The 9 member Board will have as its Chair the EPA Administrator (or designee), and the agency is now recruiting for the other 8 members of the Board: at least 3 state representatives. at least 3 industry/user representatives. at least 2 Information Technology (IT) experienced/professionals. Nominations are due March 20th. All the other information you should need to consider and submit nominees is included in the Federal Register Notice (see link): https://www.federalregister.gov/articles/2015/02/18/2015 03300/the hazardouswaste electronic manifest system advisory board request for nominations Elemental Mercury

The US Congress passed legislation called the Mercury Export Ban of 2008, which went into effect in 2013. To summarize, this law prohibits the export of elemental mercury outside of the U.S. Elemental mercury is used in developing countries to efficiently extract gold, with severe human and environmental impacts. The USEPA has tasked the USDOE to establish secure repositories for all waste mercury in the US on a fee basis. The location of the facilities and the costs associated have not been established. The domestic market for elemental mercury is saturated, so we are forced to send elemental mercury for sulfide stabilization. This change does not include mercury impacted debris, or universal waste mercury devices. If you have any questions or are unsure how something will be handled please call or email your Cycle Chem Representative. What does that stand for? AL - Action Level AOC - Area of Concern ASTM - American Society for Testing Materials CA - Corrective Action CAA - Clean Air Act CDC - Center for Disease Control CEI - Compliance Evaluation Inspection CEMS - Continuous Emissions Monitoring Systems CERCLA - Comprehensive Environmental Response Compensation and Liability Act CESQG - Conditionally Exempt Small Quantity Generator CFC - Chlorofluorocarbon CFR - Code of Federal Regulations COC - Contaminants of Concern or Constituents of Concern CMA - Corrective Measures Assessment CWA - Clean Water Act DNAPL - Dense Non-Aqueous Phase Liquids DOT - Department of Transportation EO - Executive Order EPCRA - Emergency Planning and Community Right-to-Know Act System FOIA - Freedom of Information Act HAZWOPER - Hazardous Waste Operations and Emergency Response Worker Protection Standard HCFC - Hydrochloroflourocarbon HHE - Human Health and the Environment HOC - Halogenated Organic Compounds LDF - Land Disposal Facility LDR - Land Disposal Restrictions LNAPL - Light Non-Aqueous Phase Liquids LQG - Large Quantity Generator LQHUW - Large Quantity Handler of Universal Waste LUST - Leaking Underground Storage Tank

MGP - Manufactured Gas Plant MSDS - Material Safety Data Sheet MSW - Municipal Solid Waste MTBE - Methyl Tertiary-butyl Ether NARM - Naturally Occurring and/or Accelerator-produced Radioactive Material NCP - National Oil and Hazardous Substances Pollution Contingency Plan NEPA - National Environmental Policy Act NESHAP - National Emission Standards for Hazardous Air Pollutants NIC - Notice of Intent to Comply NIMBY - Not-In-My Backyard NIOSH - National Institute for Occupational Safety and Health NOD - Notice of Deficiency NOV - Notice of Violation NPDES - National Pollutant Discharge Elimination System NPL - National Priorities List NRC - National Response Center OPA - Oil Pollution Act OSHA - Occupational Safety and Heath Act PA - Preliminary Assessment PBT - Persistent, Bioaccumulative and Toxic PCB - Polychlorinated Biphenyl PHC - Principal Hazardous Constituent POG - Point of Generation POHC - Principal Organic Hazardous Constituent POTW - Publicly-Owned Treatment Works PVC - Polyvinyl Chloride RCRA - Resource, Conservation, and Recovery Act RI/FS - Remedial Investigation/Feasibility Study SAA - Satellite Accumulation Areas SARA - Superfund Amendments and Reauthorization Act SDWA - Safe Drinking Water Act SPCC - Spill Prevention, Control, and Countermeasures SQG - Small Quantity Generator SW-846 - Test Methods Manual for the Evaluation of Solid Waste SWDA - Solid Waste Disposal Act of 1965 TCLP - Toxicity Characteristic Leaching Procedure TSCA - Toxic Substance Control Act TSDF - Treatment, Storage, and Disposal Facility UST - Underground Storage Tank UTS - Universal Treatment Standards VOC - Volatile Organic Compound WWTU - Wastewater Treatment Unit Todd Meyer Cycle Chem, Inc. Your Environmental Services Source Give us a call today! 908-355-5800 www.cyclechem.com

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