Requirement for Secondary Containment of Stored Chemicals

B

Benjamin28

#1
Good morning all,

I wanted to see if anyone could educate me on requirements for secondary containment of stored chemicals. In particular we maintain storage of acids utilized for etching purposes, whether these be 2 gallon jugs, or 50 gallon drums...I was wondering if there is a requirement for secondary containment of these chemicals and if it is triggered by the volume of chemical stored...i.e. anything above 50 gallons requires secondary containment, or something along those lines.

Further, what type and amount of spill containment equipment is required (speedy dry, pads, booms)? In the aviation fuel industry we had these requirements flowed down from ATA103, NFPA, FAA, customer, etc. But at an ISO 17025 test lab I'm thinking OSHA would be the most practicle source for these requirements. Anyone enlighten me or direct me to where I can find info on this?

:thanx:
 
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Scott Catron

True Artisan
Super Moderator
#2
Re: Requirement for Secondary Containment..

This is sort of an environmental issue, so it's probably the responsibility of the US and State EPAs.
 

Scott Catron

True Artisan
Super Moderator
#3
Re: Requirement for Secondary Containment..

Did some Googling:

Lab Safety states: "Facilities dealing with the storage of hazardous materials may also be required to have containment if they are required to meet the Uniform Fire Code (UFC) standards."

I didn't find anything about secondary containment at the Connecticut Council on Environmental Quality site.

EDIT: The city of Santa Rosa has the UFC standards posted as part of their city code. There's some details there.
 
Last edited:

SteelMaiden

Super Moderator
Super Moderator
#5
I believe that a lot of these requirements will depend on your state's regulatory requirements and your permits.

An example of what we have for ourtdoor storage tanks is that we have sencondary containment with enough volume to hold the tank(s) contents plus the maximum amount of rain recorded in a 24 hour period. Previously, the regs only stated big enough to contain the contents of the containers.
 

Randy

Super Moderator
#6
Hazardous materials storage in the workplace is primarily covered by OSHA under the Hazard Communication Standard under 29CFR 1910.1200.... http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099

Additionally depending upon the material and quantity there my be some Fire Code & EPA requirments that must be fulfilled. Your hazardous materials that are kept in your receiving area after shipment may also be subject to DOT requirements under 49 CFR, Parts 170-179 most likely 172.

If you are unsure at this time about materials then in all probability you are in violation of multiple federal and state regulatory requirements.

Under clause 4.3.2 Regulatory and Other Requirements it is your responsibility to link your aspects to the applicable requirements. You need to maximize your Corrective Action process (4.5.3).
 
D

DsqrdDGD909

#7
Good morning all,

I wanted to see if anyone could educate me on requirements for secondary containment of stored chemicals. In particular we maintain storage of acids utilized for etching purposes, whether these be 2 gallon jugs, or 50 gallon drums...I was wondering if there is a requirement for secondary containment of these chemicals and if it is triggered by the volume of chemical stored...i.e. anything above 50 gallons requires secondary containment, or something along those lines.

Further, what type and amount of spill containment equipment is required (speedy dry, pads, booms)? In the aviation fuel industry we had these requirements flowed down from ATA103, NFPA, FAA, customer, etc. But at an ISO 17025 test lab I'm thinking OSHA would be the most practicle source for these requirements. Anyone enlighten me or direct me to where I can find info on this?

:thanx:
Lawrence Livermore Lab has a good document on chemical management.

For Storage Considerations See Section 3.4.4 of

http://www.llnl.gov/es_and_h/hsm/doc_14.01/doc14-01.html.

Randy had a good summary of the governing regulatory bodies.

Here is the specific reference from OSHA on Occupational exposure to hazardous chemicals in laboratories. - 1910.1450:
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10106


Some municipalities have their own secondary containment regs.
 
Last edited by a moderator:
#8
Hi,

It is always necessary to ahere to the local regulations on this subject. But in most of the developing nations, there is no legislative information available as to the requirements of storage of chemical substances. In the absence of a legislation, a thumb-rule indication is to have a secondary containment that will hold 1.5 times the volume of the liquid stored. For example, if you store 1000 litres of a liquid chemical in a container, it has to be placed in a secondary container that will hold 1500 litres of the chemical (please bear in mind that the chemical container will occupy some space and hence allowance has to be given for this volume too while designing the secondary containment - I have seen many instances where this had not been taken into consideration as a result, in case of a leak, the liquid was overflowing the secondary containment.).

In my opinion, this applies to laboratories too, where relatively small quantities of liquid chemicals are stored and handled...providing a secondary containment helps us to reduce the spread of spill and to control the spill effectively.

With best regards,

Ramakrishnan
 

Kimmy

Involved In Discussions
#9
Hi,

Just wanted to share a couple of things I learned over the years regarding secondary containment.

While there are very specific regulations that must be followed, there is more than one correct way to accomplish compliance to the regulations. The goal is to prevent chemicals (the amount does not matter) from leaving your facility and contaminating the environment whether it is by flowing out the door to the ground or to a sewer/storm drain or, in some cases, to the air.

Secondary containment does not always mean that you must place containers of hazardous chemicals inside of larger containers. Sometimes, the room layout can provide the secondary containment you need. For instance, we modified our chemical storage room to include various dykes, which will prevent the liquids from leaving the room. In another (recently built) area of our facility where we perform parts cleaning, the room was designed and built with gently sloping floors that will force all free liquids to flow to the center of the room. In both cases, the inspector said it fully meets the definition of secondary containment.

In other cases, the size of the container and where located in the facility can determine if secondary containment is needed. For instance, a two gallon can of mineral spirits stored next to a floor drain which leads out to the sewer will need secondary containment. However, the same container sitting in the middle of a 12000 square foot room (with no drains) will not because it wouldn’t be possible for the liquid to escape to the outside if it did tip over.

Hopes this helps.
 
H

HSSE Auditor

#10
Good morning all,

Further, what type and amount of spill containment equipment is required (speedy dry, pads, booms)? In the aviation fuel industry we had these requirements flowed down from ATA103, NFPA, FAA, customer, etc. But at an ISO 17025 test lab I'm thinking OSHA would be the most practicle source for these requirements. Anyone enlighten me or direct me to where I can find info on this?

:thanx:
I addition to what Kimmy said. Here is a link to 1910.1450 - Occupational exposure to hazardous chemicals in laboratories. http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10106

This is required for labs. It addresses most of your concerns, I believe. If you are only receiving chemicals DOT is not a concern.
 
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