Hazardous Materials Handling Checklist
Personal Protective Equipment
EHS pulls Section 8 (exposure controls / PPE) from the SDS for every chemical in use at the work center. Confirm glove material against the chemical — nitrile is not universal; many solvents require Viton or butyl. Splash goggles vs. safety glasses is driven by splash potential, not operator preference.
HazCom (29 CFR 1910.1200) is required at hire and on new chemical introduction. Respirator users need annual fit testing and medical clearance per 1910.134. Pull the training matrix from the LMS and flag anyone past due before the shift.
Reassign affected operators and schedule the missing training (HazCom refresher, fit test, or chemical-specific module) before they return to the work center. OSHA citations on this point are common and avoidable.
Operator-level inspection: gloves checked for pinholes via inflation test, face shields free of cracks, respirator straps intact, chemical aprons free of degradation. Damaged PPE is red-tagged and removed from service immediately.
Eyewash and emergency shower within 10 seconds of the hazard per ANSI Z358.1, weekly activation logged. Clean PPE in lockers near point of use; contaminated PPE in marked disposal bins, not mixed with general waste.
Storage and Labeling
Workplace-labeled secondary containers (squirt bottles, totes, dispensers) need product identifier and hazard pictograms per HazCom 2012. Unlabeled secondaries are the most-cited HazCom violation. NFPA 704 diamond on bulk storage where applicable.
Acids away from bases, oxidizers away from flammables and organics, water-reactives away from any aqueous source. Use the facility's compatibility matrix; physical separation, not just shelf-level distance, is required for many pairs.
SPCC requires containment sized to the largest container plus freeboard. Flammable storage cabinets per NFPA 30 — verify self-closing doors, bonding, and quantity limits (60 gal Class I/II, 120 gal total). Check for staining or pooling that signals a slow leak.
Every chemical on site must have a current SDS accessible to employees on-shift. New chemicals introduced since the last reconciliation trigger HazCom training. Inventory feeds Tier II (EPCRA, due March 1) and TRI (due July 1) reporting.
RCRA satellite accumulation: marked "Hazardous Waste," container closed except when adding waste, max 55 gal per waste stream at point of generation. Once full, dated and moved to 90/180/270-day storage based on generator status (LQG/SQG/VSQG).
Spill Response and Cleanup
Universal absorbent for general areas, oil-only at machining centers, acid/base neutralizers near plating or battery areas. Inventory the kit against its packing list — gloves, goggles, overpack drum, disposal bags. Restock before logging the kit as ready.
Cover the incidental vs. emergency release threshold from your written plan. Incidental releases the trained operator can clean up; emergency releases require evacuation and HazWoper-trained responders (1910.120(q)). Confirm reporting numbers — internal first, then the National Response Center at 1-800-424-8802 for reportable quantity releases under CERCLA.
Document substance, quantity, root cause, response actions, and waste disposition. If volume hit the CERCLA RQ or any state threshold, attach the agency notification confirmation and the EPA e-Manifest for offsite disposal of contaminated absorbent.
Run 5-why on the release. Update the spill response plan, PFMEA, or storage layout as warranted. CAR closure requires effectiveness verification — a clean follow-up audit at the same point of use, not just a retraining sign-off.
Transportation of Hazardous Materials
The shipping clerk pulls UN number, proper shipping name, hazard class, and packing group from the Hazardous Materials Table. Misclassification is the most common DOT roadside violation and a frequent reason carriers refuse loads. Verify against the SDS Section 14.
Air shipments need IATA-trained shippers and a Shipper's Declaration for Dangerous Goods; many carriers require electronic submission. Ocean shipments follow IMDG with stowage and segregation codes. Lithium battery shipments have their own special provisions — check the current IATA edition.
Drum or combination packaging must carry a current UN spec mark matching the hazard class and packing group. Closure per the manufacturer's instructions — torque values matter for screw-cap drums. Damaged or expired packaging is rejected before fill.
Proper shipping name and UN number on packaging, hazard class labels on each side, orientation arrows for liquids. Placards required at 1,001 lbs aggregate (Table 2) or any quantity for Table 1 materials. Double-check the placards match the actual contents loaded.
49 CFR 172.700 requires hazmat employee training every three years. The person signing the shipping paper must be currently certified. Pull the training record before the BOL is released to the driver.
24-hour emergency response phone number (CHEMTREC 1-800-424-9300 or equivalent) listed on the BOL with the contract number when applicable. Driver receives the shipping paper before the truck leaves the dock; copy retained per 172.201(e).
