From: "Ryan, Patrick" <patrick.ryan6**At_Symbol_Here**EXCHANGE.MONTANA.EDU>
Subject: Re: [DCHAS-L] solvent drums
Date: Wed, 24 Apr 2019 13:22:14 +0000
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: BYAPR02MB56869952A4C668C68AA10CE8893C0**At_Symbol_Here**BYAPR02MB5686.namprd02.prod.outlook.com
In-Reply-To <003501d4fa08$006ad230$01407690$**At_Symbol_Here**bellsouth.net>


Zack,

 

1.      I think you are exactly correct and have provided a truly excellent summary of the core issues here. 

2.      The overarching issue goes well beyond code compliance; it’s about facility safety, risk management and BMPs.

 

Patrick

 

Patrick Ryan – CIH, CSP, CHMM

Hazardous Materials Manager

Montana State University

Patrick..ryan6**At_Symbol_Here**montana.edu

Tel: (406) 994-7803

Cell: (406) 570-9140

 

From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Zack Mansdorf
Sent: Tuesday, April 23, 2019 1:09 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] solvent drums

 

Yaritza:

 

This is actually much more complicated than a simple rule.  It is multifactorial and highly dependent on a risk assessment..

Is this a lot of drums or just a few?

Do you have floor drains?

Do you have floor containment (sloped to contain any spill with raised sills and no drains)?

Are the solvents compatible with wood or should you be using plastic pallets?

Are the solvents compatible with the flooring?

Are the solvents highly volatile and with low OELs?

Are the solvents highly flammable?

Do you have adequate sprinklers (and the right type) for the storage in case of fire?

Do you have ventilation in the storage area?

Do you have spill response equipment?

 

I could go on for a long time but will stop here.  Get the advice of a good IH or safety person that you respect.

 

In most locations, the local zoning board or the local fire marshal will approve this type of storage and use.  Was that done?

 

Good luck

Zack

S.Z. Mansdorf, PhD, CIH, CSP, QEP

Consultant in EHS and Sustainability

7184 Via Palomar

Boca Raton, FL  33433

561-212-7288

 

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> On Behalf Of Yaritza Brinker
Sent: Tuesday, April 23, 2019 2:15 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: [DCHAS-L] solvent drums

 

Hello,

 

Our new unopened drums are stored on a wood palette until they are needed. A colleague recently suggested that new unopened drums should be stored on a spill containment platform instead of the palette. However, I have visited plenty of facilities where new unopened drums are stored directly on the concrete floor. Is there a rule on this? Where can I find it?

 

Also, there’s some debate as to whether or not new unopened drums need to be grounded while in storage?

 

Thanks,

Yaritza Brinker


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