Posted by: Green Knight | August 29, 2010

A Note on Terminology

Most people, when it comes to environmental hazards, are concerned but not informed, which can result in skewed priorities.  Some of the more obvious things can look a lot worse than they are, while others can be all but invisible to the untrained person but be much more dangerous.  My big word when conducting safety training is COMMUNICATION.  If we use the same term to mean different things, or get our terms mixed up, we have built-in problems.

Let’s say you’re investigating a 55-gallon drum in an alley.  It’s leaking some glowing, foaming green stuff.  There’s a partial label, and you radio the information to your support team, which is a safe distance away, and upwind.  Chemical names can be long and complex, and can sound kind of like twenty others.  You’re wearing respiratory protection, so that information has to be heard through the mask, over background noise, and come out intelligibly on the other end of the walkie-talkie circuit.  Say the support person hears it wrong, and tells you to use an inappropriate neutralizing agent, absorbent material, or extinguisher, and you go BOOM.  Hard to make that look like an achievement, eh?

It’s a similar problem when people use the terms “hazardous waste” and “toxic waste” interchangeably.  Wrong!  Toxicity is just one of four ways a waste can be a hazardous waste per EPA definitions.  It can be ignitable (basically flammable, but with a different temperature cutoff than is used for the latter term).  It can be corrosive (a strong acid or base).  It can be reactive (unstable in one of several ways).  Or it can be toxic (poisonous)…basically everything can be toxic depending on the dose; some things are just a lot more so than others.  Radioactive waste is NOT “hazardous waste,” because it isn’t regulated by that EPA program, but instead by the Department of Energy.  Infectious medical waste is also NOT “hazardous waste;” it’s generally regulated by State health and/or environmental departments, and by the US Dept. of Transportation (DOT) for shipping requirements.

Confused yet?  That’s why there are consultants, my children, that’s why there are consultants.

Then there are the terms hazardous materials, hazardous chemicals, hazardous wastes, hazardous substances (plus highly hazardous chemicals and extremely hazardous substances).  Different terms defined by various laws and regulations, and not always meaning the same depending on the agency using the term.

“Hazardous materials” (hazmat) is used by DOT and NFPA (the National Fire Protection Association), and applies to spills, chills, and thrills.

“Hazardous chemicals” is used by OSHA and applies to chemical products used in the workplace.

“Hazardous waste” is used by EPA for stuff that’s spent, or too dirty to reuse without treatment; basically anything headed for disposal from active facilities.

“Hazardous substance” is used by a different EPA program nicknamed “Superfund,” for cleaning up abandoned mystery sites, and for reporting new spills.

To further enliven things, some State programs have additional materials regulated as State hazardous wastes, e.g. waste oil, infectious waste, certain types of incinerator ash (even if in compliance with EPA analytical requirements), etc.  The easiest way for a facility to get in trouble is to just follow Federal regulations and not bother to find out what State and local stuff applies…those programs must be at least as stringent as Federal, and are usually more so.  Good luck!

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