Wastewater-Treatment Facility Safety Guidelines
The wastewater-treatment industry has three major safety categories: confined-space entry; lockout/tagout; and personal protective equipment (PPE). All three safety concerns cover specific issues, and all are equally important. Methods of defense against some of these life-threatening conditions include air monitoring, proper ventilation, respiratory protection and fall protection.
Confined-space entry issues are closely monitored to ensure that employees are properly trained and follow the strict, OSHA-regulated wastewater-treatments facility guidelines.
In the wastewater-treatment industry, confined-space hazard awareness can mean the difference between life and death. Depending on individual sites, the following locations have the potential to be considered confined spaces in a wastewater-treatment facility:
- aeration basins
- applicator machines
- primary tanks
- vaulted sampling pits
Several of these locations are below ground level and have stair entry for access to routine maintenance, inspection, testing, sampling and repairs. The level of fall protection necessary depends on the facility, its required activities, and the job tasks being performed. Full-body harnesses, ladder-safety systems, tripods and hoists are among the more important fall-protection products. Although some of the above locations might not be deemed a confined space according to regulations, many facilities lean toward the side of safety and do treat them as confined spaces.
OSHA defines a confined space as an area that:
- is large enough and so configured that an employee's body can enter and perform assigned work;
- has limited or restricted means for entry or exit; and
- is not designed for continuous employee occupancy.
A permit-required confined space is defined as a confined space that:
- contains or has a potential to contain a hazardous atmosphere;
- contains a material that potentially could engulf an entrant;
- has an internal configuration that could trap or asphyxiate an entrant through inwardly converging walls or a floor that slopes downward and tapers to a smaller cross-section; or
- contains any serious safety or health hazard.
Identifying and properly marking a confined space is a major step toward providing safety for wastewater-treatment facility employees. Please refer to Quick Tips #115: Confined Spaces, 29 CFR 1910.146, which summarizes confined spaces and has a permit-required, confined-space decision flow reference chart. Employers in the wastewater-treatment industry should also obtain a copy of 29 CFR 1910.146, permit required confined spaces, to ensure that they are in full compliance with this standard.
Routine maintenance, inspections, repairs and testing take on another important area of safety known as lockout/tagout. Lockout/tagout plays an important role in system testing, inspections, servicing and repairs, and routine maintenance by ensuring that energized equipment is de-energized or shut down, locked out and tagged. Nearly 90 percent of the activities that require lockout/tagout are applications that require de-energizing an electrical source that provides power to a system or equipment components within the system. These might include pumps, electrical motors, valves and mixing systems. The remaining activities include lockout/tagout of pipelines and systems, and valves in which the energized source of potential danger could be water entry, high water pressure, air pressure and/or steam.
Personal Protective Equipment (PPE)
A wastewater-treatment facility presents employees with a variety of personal hazards. Employees depend on personal protective equipment to protect themselves from hazards and perform daily duties. PPE includes but is not limited to safety glasses, face shields, hard hats, gloves, foot protection, and durable and disposable chemical-protective clothing. Respirators and fall protection might also be required. However, respirators and fall protection fall under separate OSHA standards.
To properly determine what types of PPE employees need to help follow wastewater-treatment facility guidelines, the employer is required under the revised personal protective standard, 29 CFR 1910.132, to perform a hazard assessment or a walk-through survey of each work area and certify that it has been done. The survey should consider impact, penetration, compression (roll-over), chemicals, heat, harmful dust and light (optical) radiation. After the survey, the employer should select the proper PPE to suit the hazard.
PPE is only one aspect of a comprehensive program for ensuring the safety and health of workers. Careful planning, work practices and engineering controls (isolation) and administrative (avoidance) controls should be considered as well. If circumstances prohibit engineering controls or work practices, or these measures do not sufficiently reduce worker exposures, OSHA mandates that personal protective equipment be used.
Once the need for PPE is established, a careful evaluation of the hazards is necessary so that a selection can be made that minimizes user risk. For chemical situations, knowing the hazard includes being aware of the type of chemical; its physical state, whether it be liquid, solid or gas; and physiological effects, whether they be caused by toxins, carcinogens, asphyxiation or corrosives. Knowing the level of exposure is also important. The requirements for each type of personal protective equipment as well as additional selection criteria follow.
Eye and Face Protection
Protective safety glasses, goggles and face shields are required where machines or operations create flying objects, glare, liquids, injurious radiation or a combination of these hazards. Goggles offer the most complete impact protection because they form a seal around eye areas, keeping out dangerous objects. They also prevent tiny dust particles, chemical splashes and vapors from getting in eyes. Eye and face devices bought after July 5,1994, must comply with ANSI Z87.1-1989. In 2003, the ANSI Z87 standard was updated to reflect current additions.
29 CFR 1910.135 (a)(1) states that each employee must wear a protective helmet when working where falling objects could cause head injuries. The standard also covers electrical-hazard conditions. Although the OSHA standard does not identify specific occupations or applications where head protection is required, it does address the topic under a nonmandatory appendix, Appendix B to Subpart I: non-mandatory compliance guidelines for hazard assessment and personal protective equipment selection. It also provides examples of general applications during which head protection should be worn. Helmets bought after July 5, 1994, must comply with the performance guidelines in ANSI Z89.1-1986, American National Standards Institute for personal protection-protective headwear for industrial workers' requirements. In 2003, the ANSI Z89 standard was updated.
According to 1910.136(a), each affected employee should wear protective footwear in areas where falling objects, rolling objects or objects that might pierce a sole might cause foot injuries, and where feet are exposed to electrical hazards.
Employers must select appropriate hand protection for employees exposed to hazards such as those from skin absorption of harmful substances, severe cuts or lacerations, severe abrasions, punctures, chemical burns, thermal burns and temperature extremes. When choosing the proper glove, it is necessary to match material with each application or task. This includes assessing the job for chemical exposures, and then selecting the appropriate glove based on material, thickness, length and other traits.
Chemical resistance and suit design need to be considered when selecting appropriate protective clothing. Chemical-resistance data is frequently published and available from many manufacturers and distributors. A manufacturer might also have unpublished data available. Suit design addresses how the garment is assembled, designed and fits. Suits also might be selected for durability or their disposable materials depending on the chemical and its permeation and breakthrough data.
The revised personal protective equipment standard does not apply to respirators. Respirators are governed by the respiratory protection standard, 29 CFR 1910.134. A system of local and/or general exhaust is recommended to keep exposure below the airborne exposure limits. If the exposure limit is exceeded, a half-face or full-face air-purifying respirator with a cartridge may be worn up to 10 times the exposure limit, or to the maximum-use concentration specified by the appropriate regulatory agency or respirator supplier, whichever is lowest.
For emergencies or instances where exposure levels are unknown, use a full-face piece, pressure-demand supplied-air respirator with an egress bottle. A self-contained breathing apparatus also is appropriate.
As with any personal protective equipment, employees must be trained in several aspects of PPE. These include when PPE must be worn; what type of PPE is necessary; how to properly don, adjust, wear and remove the PPE; limitations of PPE; PPE care and maintenance; and useful life and disposal of PPE. In addition, hazardous areas must undergo a hazard assessment any time there is a process change, when new equipment is used or when accident statistics point to a problem area.
Chemical Storage and Handling
Chemicals play an important role in many aspects of wastewater treatment. Minimizing the quantity of stored chemicals such as chlorine can reduce the inherent hazards of chemicals. However, when chemicals must be retained, in-house proper storage and handling can reduce or eliminate risks. Chemicals should be properly labeled and stored according to information specified on the MSDS. Emergency equipment should also be considered when storing or handling chemicals. The equipment includes first aid supplies, emergency phone numbers, eye wash and shower facilities, fire extinguishers, spill-cleanup supplies and personal protective equipment, all of which should be readily available.
Practicing safety in the laboratory involves more than just keeping your lab area clean and wearing your proper protective equipment. It requires the cooperation and involvement of everyone associated with laboratory work. Occupational exposures to hazardous chemicals in laboratories, 29 CFR 1910.1450, provides strict guidelines for laboratory safety. Key components of the standard include having a chemical hygiene plan and providing employees with training and information.
Wastewater treatment includes testing for pH, turbidity, dissolved chemicals, hardness, color, alkalinity, chlorine, ammonia and fluoride. This testing involves following EPA-designated test procedures. Maintaining and controlling levels is essential to the wastewater-treatment in order to produce safe drinking water. The first step in controlling these levels is measuring it. For example, pH can be measured by various methods including pH paper, digital-readout pocket testers, and portable and benchtop meters. In wastewater-treatment facilities, portable meters are a better choice because most portable meters are larger than pocket testers, are more durable, and are better suited for accurate pH readings in the field.
Wastewater-treatment operations fall under many specific regulations that apply to all site personnel. Developing written wastewater-treatment facility safety guidelines that are specific to the worksite is critical for compliance. Regardless of the many safety issues that pertain to wastewater-treatment workplaces, training and enforcing the safety procedures and processes are critical to employee safety.
Confined Spaces, 29 CFR 1910.146.
Fall Protection and Walking/Working Surfaces, 29 CFR 1926.500 (Subpart M)
Guarding Floor and Wall Openings and Holes, 29 CFR 1910.23
Hazard Communication, 29 CFR 1910.1200
Ladder-Safety Devices; 29 CFR 1910.27(d)(5)
Laboratory Standard, 29 CFR 1910.1450
Lockout/Tagout, 29 CFR 1910.147
Personal Protective Equipment, 29 CFR 1910.132-138
Find even more information you can use to help make informed decisions about the regulatory issues you face in your workplace every day. View all Quick Tips Technical Resources at www.grainger.com/quicktips.
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The content in this newsletter is intended for general information purposes only. This publication is not a substitute for review of the applicable government regulations and standards, and should not be construed as legal advice or opinion. Readers with specific compliance questions should refer to the cited regulation or consult with an attorney.
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