Managing solvent-contaminated rags: a potential liability that you cannot ignore

Dirty Rags: Don’t Leave Them Lying Around by Clare Condon Topic: Hazardous Materials

Over 2.2 billion solvent-contaminated rags are used in workplaces in the United States on an annual basis. It is no surprise then that environment, health, and safety (EHS) managers must contend with requirements from both the U.S. Occupational Safety and Health Administration (OSHA) and the U.S. Environmental Protection Agency (EPA) for managing these rags. Today we will review how OSHA wants you to deal with rags, and tomorrow we will take a look at options under the EPA for managing solvent-contaminated rags.

Solvents are used on rags in workplaces for a variety of reasons, including applying finishes and degreasing or otherwise cleaning equipment. Solvents are also highly flammable. Although OSHA and the EPA are both advocating the use of safer materials, it is a safe bet that rags contaminated with solvents will be around American workplaces for a long time. Rags Lying Around—Again A sign manufacturing company in Lima, Ohio was recently fined $46,970 in part for leaving solvent-contaminated rags lying around. Let’s look at the exact violation and how the company could have avoided it. The requirements under the OSHA standard for spray finishing that uses flammable materials include: Residue scrapings and any debris contaminated with the residue must be immediately removed and properly disposed of. Metal waste cans must be provided for rags or waste that are saturated with finishing material. The rags and waste must be put in the can immediately after use. The contents of the waste cans must be properly disposed of at least once daily or at the end of each shift. Sign Source USA, Inc. was cited by OSHA in part for not ensuring that the metal cans that contained flammable finishing materials were emptied properly and in a timely manner (i.e., once daily or at the end of each shift). This was the second time in 3 years that Sign Source USA was cited for the same violation. Sign Source USA was also cited for not training employees in the use of hazardous chemicals and for not properly labeling hazardous chemical containers. All employers that use or store flammable liquids must comply with OSHA’s standard for flammable liquids, which includes details on constructing and locating storage areas, procedures to control and extinguish fires, and steps to prevent contact between flammable liquids and ignition sources. Employers whose employees work with flammable liquids must also comply with OSHA’s Hazard Communication Standard, which includes container labeling requirements and provides information and training concerning hazardous chemicals.  Spray finishing operations have additional requirements for using flammable materials. Train Your Workers A way Sign Source USA could have avoided some of the recent citations was to properly training its workers about flammable materials and, in particular, the requirements for spray finishing operations. The employees responsible for the proper disposal of the rags in the metal cans must know the basic safety rules for working with flammable liquids, including: Know the flash point of the liquid. The flash point is the lowest temperature at which the vapors from a liquid are concentrated enough to be ignited. Flammable liquids have a flash point below 199.4 degrees Fahrenheit. The lower the flash point, the more hazardous the liquid. The vapors from the liquid can catch fire, even at low temperatures. Safety data sheets (SDSs) will tell you what the flash point is. Keep all sources of ignition away (e.g., open flames, cigarettes, sparks). Use only approved fireproof containers for storage or transfer. Keep containers closed when not in use. Follow all warning for working with flammable liquids, including: Signs Instructions on labels and SDSs Company rules Solvent-contaminated rags—you use them, you need them, but what’s the best way to get rid of them? Check tomorrow’s Advisor for options under the EPA for managing your rags.