**The Manager's Tool Kit**

**for Environmental Compliance & Pollution Prevention**

**Module 6 of 6**

**A Telecast Originating from the BLM National Training Center in
Phoenix, Arizona**

**March 21, 2002**

This transcript is from the closed-captioning file produced during the
telecast.

It may contain errors and omissions in transcription.

Announcer: The Bureau of Land Management Satellite Network and the USDA
Forest Service present live from the BLM National Training Center in
Phoenix, Arizona the Manager\'s Tool Kit for Environmental Compliance
and Pollution Prevention. And now, the host of your program, Tony
Garrett.

T. Garrett: Good morning and welcome to the sixth and final module of
our interagency course on Environmental Compliance and Pollution
Prevention. In today\'s training we focus on HazMat management systems,
including procedures, audits, record keeping and training. Here is our
objective for today\'s session. Upon completion of this telecast you
will be able to, 1, initiate the process to develop an environmental
management system. And, 2, describe the environmental audit process.
Here\'s our schedule for today. In our first segment we\'ll be covering
management systems, including policies and procedures, audit systems and
training. Then we\'ll have a virtual field tour where we\'ll look at a
number of the on the ground examples of audits from around the country.
All of that should take about an hour. Then we will take a 15‑minute
break. After the break we\'ll finish our virtual field tour. Then we\'ll
go live to a Federal facility being audited where you\'ll be able to
participate and interact with the auditor to identify violations. Then
we\'ll review the entire course on the Manager\'s Tool Kit, including
Martin Thrasher\'s top 10 list of the most important things for you to
remember from this course. Again, we have a top notch team of
instructors led by Martin Thrasher, an attorney with broad experience in
hazardous materials issues in the public sector. Welcome back, Martin.

M. Thrasher: Good morning, Tony.

T. Garrett: And to give us the USDA Forest Service perspective back with
us again is Frank Mills, the national coordinator for environmental
enforcement. Hello again, Frank.

F. Mills: Hi, Tony. It\'s great to be here. Looking forward to this last
broadcast.

T. Garrett: And back earlier from modules in this series from BLM\'s
Washington Office is Ken Morin, who is the national lead for the
Bureau\'s CASHE audit program. Welcome back, Ken.

K. Morin: It\'s good to be here. I\'m looking forward to doing the
virtual audit. Should be fun.

T. Garrett: All right. We would like to again welcome our viewers from
the BLM, the Forest Service, U.S. Fish

&

Wildlife Service, park service, Bureau of Reclamation and anyone else
who may be watching. We want you to know you are participation is very
important, and again to help you communicate in real time with our
instructors, we\'re going to use the push‑to‑talk technology so you can
interact with us directly. We encourage you to use those push‑to‑talk
microphones whenever you have a question. Or when you have something to
share with our instructors and our other viewers. And we have some fun
things lines up for you in today\'s module where you\'ll get to use the
push‑to‑talk system to interact in a whole new way. So stay tuned for
that. And remember, when you do push to talk with us, we ask that you
begin by stating your name and location. We will acknowledge your call
and then you can proceed with a question or comment. That helps us avoid
confusion with more than one person is calling in. To help manage all
this, we will let you know when it\'s ok to push‑to‑talk by putting a
green light in the upper right corner of your screen, like the green
light appearing there. During periods when we would prefer you hold your
questions for the moment we will put a red light in the corner like this
one. And we\'ll keep the green light on as much as possible because we
do want to hear from you and we want to answer any questions that may
come up. Now, if you did not get the phone number and the numeric pass
code for the push‑to‑talk telephone bridge for your agency. Please call
our operator at this number to get that information. If you don\'t have
a push‑to‑talk system at your viewing site, that\'s ok. We still want to
hear from you. We encourage you to get in touch with us by telephone or
fax. Call us toll‑free at\.... Sites in the greater Phoenix area should
call\.... And you can send us a fax any old time at\.... By now we hope
everyone has registered for this satellite course and received the
course training materials, the Manager\'s Tool Kit. If you haven\'t done
so, please see your agency\'s website to download the tool kit. The
websites contain a study guide and other useful resources. And now to
get round 6 of the Manager\'s Tool Kit under way here once again is.

M. Thrasher:.

M. Thrasher: Thank you, Tony. I want to reit rate what Tony and then
Frank said during the warm‑up. Ken and Frank and I are all used to doing
stand‑up instruction in front of live students, and so at any time that
you have questions, make sure to interrupt. Ken\'s going to be out in
front of a green screen and out on a virtual audit, and any time you
want to interrupt him and ask questions or make comments, I know he
welcomes that. In today\'s module we\'re going to be covering what we
call environmental management systems, and that terminology tends to be
rather daunting and formidable when we talk about it. And yet I want you
to realize that you deal with management systems all the time in other
contexts. Certainly if you want to hire an employee, you have a
management system or a process that you go through to hire employees. If
you want to buy a major end item like a computer for your office, you
have a process that you go through in order to do that. And the same is
true for environmental management systems. When I talk about
environmental management systems, I\'m really talking about three
different things. One are policies and procedures that relate to your
compliance requirements. The second component is an audit system that\'s
an evaluation or assessment tool for managers to use.

Caller: Stephanie, Arlington square, checking in.

M. Thrasher: I ‑‑

Caller: Stephanie Nash. Fish & Wildlife, Arlington square.

M. Thrasher: Thank you very much for joining us. So the three components
of an environmental management system are written policies and
procedures and then some type of audit system, and the forest system and
BLM have those in place. The third very important component is the
training component. Let me just spend a few minutes here discussing each
one of these components of an environmental management system so that we
can get it down where you can really understand what we\'re talking
about. In order to make all of the environmental management requirements
that you have work, you\'ve got to have written policies and procedures,
and after you put all those procedures together, along with your audit
system and your training, then you\'re going to have a complete
environmental management system. You can\'t accidentally be in
compliance with all of these rules that we\'ve discussed in the last
five modules. And word of mouth, and doing it orally, simply doesn\'t
work. Today what we\'re going to be doing is walking through an audit
system which is part of the environmental management system and look at
the individual items that raise issues. Now, obviously as a result of
those audits you must fix the items that are ‑‑ that are found to be
deficient during the audit. Let me suggest to you if that you just fix
those items and you don\'t look behind that to determine why you had
those issues in the workplace, then two years from now you\'re going to
have the same issues or maybe other issues brought up during the audit.
What you really need to be looking at is what kind of system do you need
to put into place, what kind of protocols, what kind of policies do you
need to put into place to make sure that you don\'t have a recurrence of
all of these problems. Let me give you a couple of examples. If you go
through an odd and it you find that ‑‑ an audit and you find that there
were five different material safety data sheets that were not in the
book, certainly you have to find those MSDSs and put them in your book,
but if you don\'t do anything more, two years from now you will go back
and look in the book and you will have ten MSDSs missing. What you
really need to do is look at your management of your safety program and
how you keep that book and keep the training up to date in order to make
it work. Another example, if during an audit you find you have ten
different drums that weren\'t properly labeled, certainly you are going
to go label those drums but, again, if you don\'t have a management
system in place to make sure the drums are properly labeled when
they\'re received and then while they\'re in your warehouse or wareyard,
then you are going to have the same issues arise again and again. And
this is sort of the thing we don\'t want to have happen. The key to all
this is to put a written procedure or policy into place and I know that
that sounds rather daunting, but industry and other government agencies
do it. It\'s a quite doable thing. It certainly takes commitment of
resources in order to do it. Now, you can go out in the marketplace,
these days, and buy commercially prepared environmental management
systems. There are several of them that you can find on the Internet or
through other contacts, but quite frankly, these are not the best
systems. They may provide a good model or beginning for some of the
systems, but the very best systems that I\'ve found in my career and
then going around working with industry and other public agencies is the
home ‑‑ is to home grow your systems so they match exactly what you\'re
doing in the workplace. Let me show you a couple of models here that we
developed when I was working for another company. One of the things we
had happen in the late \'70sand early \'80s is we had two of our
managers indicted for violation of the hazardous waste rules under the
Resource Conservation Recovery Act. And then I\'ve dealt with several
administrative and civil complaints by the EPA and the state of Colorado
for hazardous waste violations. We found that hazardous wastes was one
of the primary problem areas, and so what we did, let me see if I can
get this on this camera here zoomed down, we put together what we called
a hazardous waste control procedure, and it was a fill in the blank type
thing where it fit exactly all the rules, Federal and state and local
rules for our jurisdiction that we had to comply with dealing with
hazardous wastes. Then after we put this model together, the various
facilities and departments filled in the blanks, made it customize to do
their particular operation and then they\'ve got an established
procedure in place and then they trained to that procedure. Let me show
you one other one here. Another area that that particular client was
really in trouble with was over containers. Continually we had
containers that were not marked, they were mismarked, they had mixtures
of different things in them with the ‑‑ that resulted in them being
hazardous waste. Couldn\'t do anything with them except dispose of them
as HAZ waste. So we put together a container control procedure to train
people on how they had to mark containers, put things in containers,
take them out, how they had to dispose of the containers. So when I talk
about environmental management procedures, this is the type of thing
that I\'m talking about. And the best way to do this, again, is to grow
them yourself. Again, it takes some resource commitments. Now, let me
mention just a few minutes, I want to get some dialogue with you if I
can, about what types of written procedures or policies that you need in
the Federal land management agencies. Certainly first and foremost, you
need to have a hazard communication plan. That has to be in writing.
Now, you\'re not directly under OSHA, but the president has issued an
Executive Order that you will comply with OSHA requirements, and one of
the hallmarks is a written HazCom plan. So all of your field facilities
should have a written HazCom plan so when somebody walks in and they say
may I see your HazCom plan, you can take it off the shelf and hand it to
them. I think another one that you probably need particularly at the
field level is what you have typically called a contingency plan or a
spill or a release plan. I do want to caution you like I did in the
preparatory remarks that the term \"contingency\" plan is used as a
specific kind of plan dealing with large quantity generators of
hazardous waste. But whatever you call it, you need to have some type of
plan. Frank said something interesting during the warm‑up that I think
needs to be reiterated. There are so many different kinds of plans that
are required. Some of the agencies that are on the front end of this are
starting to consolidate all of these things into one master plan or
master procedure and then they\'re training that from, and that seems to
be a real good, workable tool as well. So even though I\'m kind of
delineating these separately, you can certainly consolidate those into
one document. Now, what questions do we have from here? Because we\'ve
got some other plans that I can suggest or procedures that you\'d need.
I already alluded to the containers. But what I\'ve said so far, has
that brought up any questions from anyone about your written procedures?
All righty. Let me go through and suggest a couple more. During the
virtual tour that Ken\'s going to give, he\'s going to talk some about
safety and confined space entry and use of respirators. If you\'re
having your staff, your employees going into confined spaces, or if
they\'re using respirators, both of those require a written plans to
cover those activities. I know another major area for the Federal land
managers is pesticides. A lot of you contract out that work, which is
great. It kind of gets you on the sideline of the business. But if
you\'re you a ming pesticides, it\'s a real good idea to have a written
procedure for that. And quite frankly n my experience in the field, even
though people contract out pesticide usage, they forget about the cans
of RAID and other pesticides they use around the office and wareyards.
So, in fact, they are using pesticides anyway. Could mention a couple of
others here. If you\'re dealing with underground storage tanks,
disposing of solid waste on your Federal lands, doing water discharges
from wastewater treatment plants, or you have irrigation ‑‑ air emission
discharges from various sources, then you should have a written
procedure about that. To we have any comments or things that I\'ve said
that kind of raise questions in your minds about the written procedures?
The idea here is to develop your written systems to address the
environmental and the HazMat areas that you\'re involved with. Now,
where do you get help with this? Yeah, you can buy this stuff off the
shelf commercially, but, again, it\'s not a really good source. What I
would suggest is if you have a hazardous materials coordinator, you can
start there. And, then, of course, you have resources at a more central
location like Ken and Frank and others that can help you do that. Now,
if we don\'t have any questions about that, what I\'d like to do is turn
to the audit systems really briefly. An audit system is simply a tool, a
management tool, to evaluate or assess your programs. It should be
nonthreatening. I have talked to Ken and Frank about their programs and
they\'re built the way most are for industry, and that is, they\'re not
supposed to be punitive or threatening. You certainly need to do
something with the issues that are raised there. It\'s simply an
evaluation tool and it\'s one of the hallmarks of an effective EMS
system. It should be used to give you as managers an idea of the areas
that you need, you have weaknesses, and you need to develop some systems
to make sure that you don\'t have recurrence of the problems. But,
again, the main focus of the audit should be development of systems. You
certainly have to go back and fix the individual problems. You need to
look behind those. Now, the third element or ‑‑ of the environmental
management system in my mind is training, and it\'s absolutely
essential. Environmental management responsibilities are not intuitive.
They\'re not something we just figure out by sitting down and thinking
about it, and they\'re not things that our parents normally teach us
about or we learn in school. You have to have specific training. Many of
the statutes like EPCRA, Hazwoper, have specific training requirements
but others don\'t. In any event, whether training is required or not,
you need to have those training programs in place to train your people
up to your procedure. I think with that, that\'s kind of an overview of
environmental management systems, and just to summarize, what you really
need are written procedures in place. You need to have an audit program,
which most of you have already. And then you have to have your training
component along with it. So I think with that, Tony, I\'ll turn it over
to you and see if there are any questions.

T. Garrett: Let\'s pause briefly and see if there are any questions and
then we\'ll get right to the virtual field tour. We\'ll take a moment
now and field any questions that you may have. Any of our field offices,
please feel free to check in with us now.

Caller: Stephanie Nash, Fish & Wildlife, Arlington. I was wondering, was
there a handout for this module?

M. Thrasher: There was material that was put out on the web page that
could be downloaded for all of the modules, to my knowledge, and I\'m a
little weak on my knowledge of Module 6, though, and what was available.

F. Mills: Stephanie, this is Frank Mills. One of the things that you can
do is there is what\'s known as a generic protocol for environmental
compliance programs from EPA, and the EPA office of Federal facilities
assistance and enforcement actually has a very good website which has a
number of things that you can get off of that website to help you
develop programs and processes for environmental management systems,
auditing and training. So I would encourage each of you to go to the
website at EPA, look up the Federal facilities compliance office
section, and devil into that amount of material they have there.

M. Thrasher: Of course, your other resources s as I said, to go to your
hazardous ‑‑ help me out ‑‑ the coordinators and then go to your central
offices. Because, see, what I find is that people get so afraid of all
the numbers of things ‑‑ I mean, it\'s really daunting, it\'s
intimidating, all these programs you need to have in place and through
the audit system, through your own knowledge of your operations, you
need to figure out the priority areas and start working on those first.
Hazardous waste, container control, sometimes pesticide. It all depends
on what\'s going on in your facility. You can\'t attack it all at once.
Take the top priority items and work on those first.

T. Garrett: All right. Thank you, Stephanie, for checking in with us.
Any other viewers who would like to offer a question or comment at this
time before we move to the virtual field tour? We\'ll, of course, give
you an opportunity later in the program and keep that green light on as
long as we can, even during the virtual field tour, and during the
actual audit exercise later in the program. So when the green light is
on, please feel free to go ahead and push to talk. Martin, right now I
think we will give it back to you and have you get us into the virtual
field tour and Ken Morin.

M. Thrasher: What we\'re going to do now is turn to Ken. He\'s going to
takous a tour that illustrates a lot of the environmental hazardous
materials areas that we\'ve been covering. I want to make sure that you
interrupt him whenever you want to to ask questions. He\'s able to hear
you out there. But the challenge I have for you is you look through this
tour is to be thinking about, ok, what kind of management systems do you
need to put into place to take care of the issues that he\'s
illustrating in the field. So with that, Ken, I\'ll turn it over to you.

K. Morin: Thanks, Martin. What I want to go through today is not a bunch
of slides on what are the regulations because in general you know that.
What I want to emphasize today is some real world situationss, and
we\'re going to do that by me standing in front of some pictures and
pointing out some stuff. In the 20 years I\'ve been doing the audits,
I\'ve been to a lot of beautiful places, like this place in Southern
Utah, but more importantly, I\'ve had an opportunity to work with a lot
of great people and I have never met anybody that told me they didn\'t
want to be in compliance. Had a lot of people say, ah, this regulation
is stupid or that I don\'t understand it. Most of it is really common
sense and one of the benefits of doing the audits is explaining why
they\'re appropriate. That\'s what I\'ll do with these slides. Another
benefit of doing these audits is that it rein forces what you are
existing field safety and hazardous materials coordinators are already
saying. Unfortunately there\'s too many time out there in the field that
you can\'t be a prophet in your own land. You may have been talking to
somebody throughout in a different program and, yeah, they hear you, but
they\'re not really willing to do it for some reason, and you bring in a
separate audit team and it reinforces what you\'re saying and brings a
new perspective and that\'s what this is all about. Bringing a new
perspective to it, because beyond the obvious signage problems here,
where we\'ve got the Winnemucca Field Office and the nut house here,
what we\'re doing when we\'re doing an audit is we\'re looking at things
differ reny. If you are a Field Manager, walking out to a vehicle and
you see drums on a pallet, no big deal. But you come take a look at it,
little closer and you notice they\'re not properly labeled. Does UN mean
United Nations or does it mean unknown? Take a closer look at the drums.
They\'re completely bulged on the bottom down here. They are they
bulging because they froze with water or are they bulging because we
have some unknown hazardous chemical, some very volatile product. Look
closer at the staining on the pallet here. So if I\'m a regulatory
inspector, I see drums that we don\'t know what\'s in them and I see an
obvious release to the environment. It\'s some sort of petroleum product
beading up, because it had rained the day before. Another thing, look at
flammable storage cabinets and you figure, if it\'s in there, it must be
a hazardous material and it belongs in there. But a different
perspective we bring, sit really supposed noon there or or how often are
you using this stuff? Here\'s some Al examples. This first product in
the green container is a flammable liquid. It\'s supposed to be in here.
Second product, though, is drain cleaner. Contains sulfuric acid. Can\'t
be in there. If this happens to leak, gets knocked over, it ‑‑ cup ‑‑
some of it leaks out, it eats the flammable liquid container. When an
acid and flammable liquid mix, at a minimum they\'re going to form some
form of a toxic gas. Potentially spontaneously ignite. The last product
here, we have dangerous if not kept dry. This product is calcium carbide
used in soil test kits. It will release acetylene gas when it gets wet.
You obviously don\'t want to have this in a flammable storage cabinet.
If there is a fire you will be adding to the fire because you will be
generating acetylene. Flammable storage sheds are also a good source for
‑‑ take a closer look what\'s in it. You will come into one and
everything\'s nice and neat on shelves. I have antifreeze in here. No
big deal. But what\'s up in here. What\'s up on this top shelf here?
Anybody want to tell me on the push‑to‑talk? What does this yellow
diamond mean? It\'s a D.O.T. sticker.

Caller: Looks like an oxidizer.

K. Morin: Exactly. Thanks, Olivia. We definitely don\'t want that in
well flammable liquids. See the box on the shelf. It says do not ship or
store with antifreeze, which is why we stored it next to antifreeze in
the flammable storage cabinet. That oxidizer is those ping‑pong balls
weep use to start prescribed fires. I found these quite a bit in
flammable storage cabinets and flammable storage sheds out in the field.
Everybody realizes it\'s a hazardous material and we have HazMat shed
but unfortunately, not all hazardous materials can be stored together.
Probably the biggest issue we have is the storage and transportation of
fuel. Throwing a 55‑gallon drum in the back of a pickup truck is not
really a big deal, but it depends how you mount it in there. Using plain
rope to do that is that probably not a good idea. What happens when you
tie into it the bar here, it is this ‑‑ this bar that\'s keeping the
tool box in the shed ‑‑ in the back of pickup truck is literally driving
into this drum and you can see the dent in here. It\'s only a matter of
time until we start leaking either diesel fuel or gasoline in the bed of
this truck. There was a fire recently with fuel leaking out of a pickup
truck getting ignited from a muffler on the truck. So to get around
that, because drums tend to be a pain to actually load into a truck and
they\'re hard to secure, some people have resorted to using trailers
that they scrounge from D.O.T. The problem with the trailers is,
particularly if you\'re transporting drip torches, we are driving on
bumpy roads and this brown staining here that you see in the back,
that\'s from leaking fuel. Look at the back of this trailer, and
there\'s a tipped over drip torch there. You can see the sheen down here
from the leaking fuel. This is what we are driving out to the field to
go fight a fire. As a result of this, because we\'ve seen so many cases
of them in BLM, we\'ve actually put out an I.M. prohibiting the use of
trailer mounted tanks because they are not compliant with D.O.T.
regulations. If we were trying to haul diesel fuel, it would be ok but
drip torch fuel is a flammable liquid. Another example is this pipe
coming down. You can see the ball valve here. This is how the drip torch
fuel somebodying dispensed. The problem with this is if you\'re in
traffic, trying to get to the fire, somebody doesn\'t judge their
stopping distance appropriately, they could potentially hit the back of
this trailer, snap off this pipe and they we just released 100 gallons
of flammable liquid onto a public highway. What happened recently in a
department of interior fire vehicle in Colorado, something similar
happened. They had drip torches mounted on the bumper, the driver in the
fire engine behind didn\'t judge the stopping distance, hit the drip
torches and started a small fire. The best wad to it is mount a tank by
the cab of the truck. But it depends what kind of fuel you are hauling.
It also depends on the piping. The concern I have here is if this truck
is involved in a rollover accident, this pipe that you see is going to
snap off and again, we have the potential for releasing large quantities
of fuel onto a public highway. Now, for hauling drip ‑‑ for hauling
diesel fuel this tank is fine. There\'s a sticker where it\'s real dirty
here, I am going to show you the next picture, it\'s been wiped off, but
it says right on the bottom the tank ‑‑ this tank is not designed to
meet Title 49 of the U.S. Federal register regulations. Title 49 of the
D.O.T. regulations. In other words, this tank does not comply with
D.O.T. regs. It\'s true we are not in interstate commerce and
technically we don\'t have to comply with the D.O.T. regs, as long as we
are using government trucks, technically the D.O.T. regs don\'t apply
but if this truck gets involved in an accident and we Release 120
gallons of fuel on an interstate or main street in Rollins, Wyoming,
that\'s going to be difficult to get the state police or any emergency
response agency to buy off on it. Never mind the fact if that there is
an accident and there\'s a fire involved and we hurt somebody, the tort
claim is not going to care that we don\'t use a compliant tank. As a
result of this, I\'m working with NFSCE right now, and within the next
six months we will be putting out guidance on the type of tanks we want
you to buy to handle drip torch fuel. Any questions on this type of
tankage? It\'s fine for diesel fuel. There is a huge exemption for
diesel fuel, it\'s actually in 49 CFR. But are there any questions on
this type of tank? I think it makes sense you can haul diesel fuel in
these because the flash point is so much higher, 100 degrees Fahrenheit.
Gas is minus 38 degrees. Drip torch fuel is 65 degrees. It\'s much more
flammable than diesel. Let\'s go on. The tank also has to have the
proper type of pump on it and this one is. This is what you should ‑‑ if
you are looking at it, this is an explosion proof motor. It\'s designed
specifically for flammable liquids. What we see a lot of times is a
motor that\'s ‑‑ that\'s a farm pump, and they don\'t comply at all.
Last but not least associated with the tank is how sit mounted? How is
it secured to the truck bed? And the closer examination of this corner
right here, you can see the bolt. There\'s a crack in this truck bed. So
if this is in a rollover accident, even though we tried to secure it,
there is the potential for this thing to rip out of the truck. So
something you need to be looking for if you\'re doing this. Because this
is a Forest Service vehicle that was involved in an accident, it wasn\'t
the driver\'s fault. Got T boned in an intersection. This blue container
here is retardant which isn\'t a big issue. But we are carrying
flammable liquids out there. We are carrying hazardous materials. We
want to make sure we can transport them in a safe manner out there.
We\'ve gone from transportation of fuel to storage of fuel in field
directed tanks. Anybody want to comment on whether this tank is
compliant at all? It\'s in secondary containment. Is this type of tank
compliant? You have a 50‑50 chance out there.

Caller: No.

K. Morin: It\'s not even close.

Caller: I wouldn\'t say so just from common sense.

K. Morin: There\'s a couple things wrong with it, but hopefully this
picture looks familiar to several of you. What you ever\' got here is ‑‑
you see this ‑‑ we have bottom dispensing of fuel, which you can\'t
have. The uniform fire code requires you can only dispense liquids from
the top. For a couple reasons. Primarily, if there is a leak somehow,
the fuel can easily drip out. If there is vandalism, someone knocks this
pipe off, again we just released a whole bunch of fuel. The tank, most
importantly, it has to be constructed in accordance with U.L. standards
or American petroleum institute standards. The OSHA regulations,
national fire code, NFFPA all refer to tanks being constructed in
accordance with industry standards. This one is not in that is, though.
This type of tank is one example. There\'s plenty of vendors that make
secondary container tanks. This is called a convault. It\'s protected
from vehicle traffic. I have the right U.L. listed pumps. I have vents
12 feet in the air with flame arrestors. We have this mushroom thing in
the background. It\'s an emergency release vent. If this tank is in a
fire, instead of the tank blowing up, the fumes in the tank will vent.
The other tan headquarter a regular normal vent and it\'s not a big
enough diameter to relieve all the pressure that occurs when a tank is
involved in a fire. It also has spill containment at the fill. But most
importantly is, it\'s got this U.L. pedigree on it. This is what you
should be looking for on your tanks. It says that this tank is
constructed, it\'s designed with a two‑hour fire rating and lots of
bells and whistles like that. That\'s what you should be looking for.
Air tanker bases, what\'s the primary issue ‑‑ actually there\'s two
issues associated with air tanker bases that are relatively unique to
air tanker bases within interior and the Forest Service. What are the
two issues that we\'ve talked about? Anybody want to take a hazard at at
least one of them?

Caller: We\'ve got a Clean Water Act issue and we also have an EPCRA
issue at air tanker bases. When it rains, what happens at these tanker
bases? Also, what are we storing in large, very, very large quantities
at these tanker bases? This tank has 20 thousand gallons of fire
retardant. One of the things we talked about was EPCRA. If you store
more than 10,000 pounds of a hazardous material, what do you have to do
out there? Under the EPCRA regulations, 40 CFR 373, you store more than
10,000 pounds, we have to notify both the state and the local emergency
planning committee that we\'re storing above threshold quantities of a
hazardous material. And fire retardant is a hazardous material.
Definition of a hazardous material is anything that has an MSDS and fire
retardant obviously does. The other issue, though, is the drainage. This
ditch right here writ goes off upscreen here, what happens to this
runoff from an air tanker base? In this particular case, it\'s running
through this pipe and it\'s going up and discharging into navigable
waters of the U.S., I.E., this wetland. This has been corrected. I
wouldn\'t ‑‑ we\'ve solved this problem at this site over a year ago,
but this blue stain is coming from the cyanide that\'s in fire
retardant. It\'s actually ferrocyanide. It\'s a corrosion inhibitor
because the retardant is very corrosive to the air tankers, but when it
gets out to the environment, the cyanide comes back out and it\'s that
blue stain. There\'s also some black in here. That\'s from oil and
grease from washing down the air tankers. Now, this is what everybody\'s
transitioning to. And if you have an air tanker base and you\'re not
managing your runoff, you need to be talking to your state or your
regional fire manager and see where you\'re QUEUEing up, because your
runoff nays to be retained in some sort of lagoon like this one, needs
to be lined, and some issues that we found building these things,
because the fire retardant has so much phosphorous in it, the tends to
grow algae blooms and so you are getting some odor problems. Also
because you are washing off the planes, you are creating a lot of oil
and grease, and that forms a sheen on the surface of this lagoon, and it
turns the entire lagoon into a rain gauge. We can\'t evaporate it. So
what we have done, particularly at this site s we are bubbling air into
it. It keeps the odors down and it allows everything to evaporate. This
10 by 10 here is to allow the prairie dogs that go swimming to be able
to get out of the lagoon easy. As I said, when we\'re washing these
things, and that\'s what thankth guy is doing right here, we\'re
generating runoff and when a raw sip raw indicating engine on an air
tanker starts up, it loses from 5 to 20 gallons of oil that gets all
over the surface of the apron. And sometimes a tanker will occasionally
discharge a load of retardant, and that stuff is very, very slick. The
combination of the retardant and the oil makes for a very hazardous
working environment around aircraft. So these ramps have to be washed
down. What happens to the runoff, though, is why we have to have these
evaporation lagoons. Now, the solvent I am seeing people use is
typically is ZEP product and I have seen it in at least half a dozen
tanker bases, and it sounds ‑‑ hi‑foam, that sounds pretty innocuous,
but the next word is degreaser. It has this warning statement on it that
it contains aromatic hydrocarbons, which are benzene rings. This is a
full‑blown regulated substance. We need to look for pollution prevention
opportunities. The picture I showed you before of the person watching,
he was actually using this product, this alpha 3, product, and it says
right on it\'s biodegradable. It\'s not a benzene base. It\'s not BUTYL.
It\'s not a petroleum based product. I asked the guy, I said, why are
you using this? He said, I would really rather use the ZEP product. I
said, why are you using thing? He said, because I also land at D.O.D.
facilities and they won\'t let me use the ZEP. Why? Because of pollution
prevention. We need to look at greener detergents when cleaning the air
tankers. Another pollution prevention opportunity, this is the engine
and here\'s a soda can and there is a primary drip point off this
engine, particularly after you wash them and you get a lot of oil and
greasy water. So they put a Coke can up here to collect it. Below here
is just an absorbent pad in a wooden frame. And this keeps the amount of
oil and grease to a minimum on the apron. So there\'s less being
discharged into the environment. Field stations. Whether it be just a
remote field station where we\'re doing research or it\'s a remote fire
station, one of the primary things wrong we find out there is drinking
water. Most common thing is that it\'s not being even sampled. This one
is. We\'re taking a sample now at this site. But what we frequently find
is signs like this, that says, do not drink the water. And if you do,
they don\'t even want you spitting it out, it\'s so bad. What I commonly
find is that the answer to that issue is, well, we provide bottled water
for drinking. But that\'s not good enough. What OSHA says is you have to
have drinking water or potable water to be able to wash your dishes, to
wash your food. You also have to have it to shower in. So if the water
is not potable, it\'s not safe to drink, it\'s also not safe to be
bathing in. The OSHA reg says you have to have potable water again not
only for drinking but for washing, washing utensils, washing food and
for bathing in. Now, why am I putting up a sink? What could be the
possible issue at a remote site with just a sink? If you see a slop sink
like this, then you see a flammable storage cabinet and you\'re in a
remote area, you should be asking yourself, what kind of hazardous
materials they have. This is a gallon of paint thinner. There\'s a
variety of paint products here. What do they do with that thinner?
Because at remote sites they\'re probably connected to a septic system.
And at two of our facilities, both of them in Montana when they were
inspected by EPA, they got cited for violations of the underground
injection control regulations and those are actually safe drinking water
regulations under the Safe Drinking Water Act. Under ground injection
control regulations prohibit the discharge of any industrial waste from
entering a septic system. Actually what the reg refers to as a
subsurface disposal system. What that means is the tile field for the
septic system. Or it could just be a dry well. And the concern is,
particularly in region 8 because they\'re taking a lot of initiative in
this area, hazardous ‑‑ primarily awful EPA because they reissued the
control regs in December \'99, the concern is there\'s over 130
superfund sites in the United States that are a direct result of
contaminants going into a septic system. So as a result of that, when
you see a sink like this, look what they\'re doing, because down below
here is all those paint brushes and, yeah, they were soaking in thinner
and if you look inside the sink, there\'s a bunch of staining and this
type of discharge is illegal. Any questions on the underground storage
tank regulations ‑‑ not underground storage tank, but the UIC regs. Do
you understand what I\'m talking about? We\'ll move on. Related to
drinking water, this sign is not probably posted more than it should be.
We should probably be removing the yard hydrant completely. If it\'s not
safe to drink, why should we be providing it? But there\'s a big ‑‑
we\'re trying to meet competing interests. We wanted to provide water
not only to drink, but hunters want use to it, fisher men want to use it
and we also need it for fire protection. So what are we going to do? We
need to look at how we develop the drinking water systems, particularly
springs. This is a spring box. You open up the hatch in the spring box
and I am trying to find what are the sources of contamination. Look
inside. This is a dead rodent. This gray thing here. It\'s either a
mouse or squirrel. That\'s obviously a source of COLIform contamination.
Look at the other part of the spring box and I\'ve got right here, he\'s
hard to see, so we circled him, there\'s a TOAD. How are they getting
into the spring? Well, primarily because it\'s not properly developed.
All springs are supposed to have an impervious geotextile fabric ‑‑ not
geotextile but high density polyethylene and three feet of cover if that
you don\'t want to use the impervious like high density polyethylene,
then it needs to be 10 feet of impervious soil. This has a metal lid.
You can see the big crack in here where the grout has all fallen out.
We\'ve got critters going into the spring development. This is a very,
very common problem, not only in BLM, but in the Forest Service as well.
Other issues related to drinking water, and this site ‑‑ it has a well.
What happens this is right here, thanks well. Groundwater should be
easier. But what I\'m finding when I\'m going out to sites, when I go
into the pump house or ‑‑ where they have all the valves to control the
distribution system, I look in the back corner and I\'m seeing this more
and more, here\'s some bleach. We installed a chlorinator. The question
‑‑ there\'s a couple questions you should be asking your field people
when you go throughout and all of a sudden there\'s a new chlorination
system. Anybody wants to take a hazard what we should be asking? Two
primary questions. If you have a hot tub in your backyard or swimming
pool in your backyard, what do you routinely do? Periodically test,
right? Want to make sure the bromine or chlorine you\'re using is still
in that swimming pool. What I\'m finding, and the bark service doesn\'t
really have a big wish this so much as I know the Forest Service does
and BLM does because\' teach drinking water for both of the agencies, is
that we\'re using volunteers or staff that\'s not fully trained on
drinking water. And we install a chlorination system like it\'s a magic
fix but we\'re not solving ‑‑ we\'re not curing the disease. We\'re just
treating the symptoms. So the first question you should really ask is,
why did you install it? And the answer typically is because it was
testing positive for coliform and they didn\'t like doing all the extra
sampling you have to do when it does. But when they tell you that, the
next question should be, did you ever find the source of contamination?
The next question after that is, when they tell you no, is how often are
you testing chlorine residual and where are you testing it? What I
routinely find it when you have a campground host, they\'re testing at
their site. That\'s what I would do. I want to make sure I have chlorine
at my spigot. You\'re going to have dead ends. You are going to get zero
chlorine residual throughout. If you are not testing daily, you won\'t
know when to flush the system to increase the chlorine dosage. You need
to walk the system. When you to that, you are going to see things like
underground ‑‑ like tanks that you\'re storing your drinking water in.
This looks pretty good. This rusty thing here is just the pressure
switch that turns the pump on and off. My hatch opening for the tank is
well above grade. It\'s protected by this wooden structure. Not a
problem. But I have a second hatch right over here. And it\'s got some
ponded water on top of and it it\'s completely flush with grade. When I
inspected this site, there is a little bead of caulk right here but the
rest of it I could just pop one my hand. And the source of contamination
is obvious. It\'s water sheet flowing across here and running into the
tank. It doesn\'t take much to contaminate your drinking water. And the
storage tanks are typically the opening in your system that is going to
cause you the problem. The problem that I\'m finding out in the field
is, it took us a mile‑and‑a‑half to hike to this thing and find it and
no one had actually looked at it in over a year. We\'re also acquiring a
lot of old ranches, primarily in urban interface zones for environmental
Ed centers. I don\'t know if any of the other agencies are acquiring
other properties, but what is the one thing you should be doing before
you acquire some property? Anybody want to hazard a guess on that?
Actually there is an ASTM standard on it on what you should be doing?
This is one of the management things that Martin was talking about. What
sort of processes and procedures do you have in place that will prevent
you from causing yourself problems? Before you acquire a site like this,
you should be doing what\'s called an environmental site assessment. And
following it in accordance with ASTM standards. What that site
assessment will identify is what\'s called recognized environmental
hazards. That could be underground storage tanks. It could be a dump. A
variety of things. At this particular site, one of the issues that we
discovered when we were doing the audit is their drinking water system
which is in this vault. Here\'s the well. It\'s in a vault. It\'s in a
confined space. That brings up a whole bunch of other issues I will I\'m
not going to get into. But we can\'t even enter this thing maintain it
without complying with the confined space entry regs. But we can move
this above ground and solve that problem. The concern I have is this
well is not sealed. There\'s some openings in it right there where the
wiring ‑‑ the electrical line to the pull is that going through is not
sealed. Now, there is a sanitary seal in here, but it\'s ‑‑ but that\'s
a rubber mechanical seal and those things do tend to dry rot and I
don\'t want to re rye on just this rubber doughnut to keep contaminants
from coming in, particularly at the electrical connection. These black
things right here, there\'s some straw here, some more black things,
right up in here there is a whole bunch of and it where Martin circled
is a bunch. Those are mouse droppings. I could show you several other
pictures similar to this where we have the same thing occurring. So you
have to make sure your openings in a well are properly sealed. Another
obvious source of contamination. The other thing associated with this
ranch is that vault is right behind this tree for that drinking water
system. And what I\'m standing in right now, and, yes, I do walk on
water, is the irrigation ditch for this ranch. If this well is shallow,
it\'s less than 50 feet from the irrigation ditch. We might not be
providing protected groundwater. We might be providing groundwater under
the direct influence of surface water which means there\'s mandatory
disinfection, mandatory certification and a host of operation and
maintenance issues. So instead of having a nice environmental Ed center,
we have a \$50,000 water treatment plant we have to operate if it is
groundwater direct influence. Any questions on drinking water? The other
thing you should do, then, when you\'re requiring ‑‑ acquiring an old
ranch like this is clearly define to the property owner that you are
exchanging with what you are willing to accept in regards to what is a
good material and what\'s a hazardous material you don\'t want. Because
inside this barn was all of this stuff. We\'ve got used oil in this
bucket rights here ‑‑ or this half of a drum. We\'ve got a variety of
petroleum products. None of which the field people wanted. More
importantly, though, and the back end here, is this item right here. The
chlordane dust. Which I\'m not even sure we can legally apply anymore
and it\'s going to be hazardous waste. It\'s going to cost us a thousand
dollars to get rid of stuff that the rancher looked at as maybe being
good product and we wanted, when, in fact, we had no use for it. So when
you are doing that environmental site assessment, establish up front
with that person you may be doing the exchange with what materials you
want. Because all ranches have a bone yard, or they have an old dump,
particularly if it\'s an historic ranch. They had to do something with
it and Browning‑Ferris Industries didn\'t exist 50 years ago and they
weren\'t picking up trash in the north 40. So the trash was going into
the north 40. You want to make sure those dumps are cleaned up. I\'ve
been to a bunch of them. There have been school buses, cars, half a
dozen refrigerators, all of which are going to pose a risk to the people
that are going to be visiting this site. On top of that, you might have
a bunch of pressure treated lumber, creosote railroad ties which again
were usable materials to this rancher but they may not be to you. Last
but not least, the 55‑gallon drum. This one has ‑‑ it\'s got a flammable
sticker on it, had some unknown product. We had to pay to characterize
it before we could even get rid of it. Enough about acquiring property.
Let\'s talk about our own facilities. This is a pretty typical shop.
Should look like some that you have. If you\'ve got heavy equipment, a
lot of our shops, we\'re not contracting out that type of maintenance,
we\'re doing it in house and we\'re doing oil changes. This oil filter
here could be thrown into the trash if we had managed it a little
differently. What do we need to do differently with the oil filters when
we are draining them so they are exempt from hazardous waste
regulations.

Caller: You poke a hole in them and hot drain them.

K. Morin: Exactly. They have to be gravity hot drained and punctured on
the dome end. That\'s right out of the regs. In some states, California,
New Jersey, and Texas come to mind, it\'s mandatory recycling on these
for the Steele. But for well over two‑thirds of the country f you
gravity hot drain these and puncture them ‑‑ when you puncture them it
breaks a vaccuum and you get another half a quart of oil. Then they can
just be thrown in the trash. Parts washers. Typically it\'s not a big
issue. The concern here, though, what\'s below the parts washer. Because
I\'ve got another five gallon bucket of some sort of solvent. Actually
it\'s a carburetor cleaner and it had a as corrosive label right on it.
That immediately tells me this is methylene chloride, which is very,
very corrosive to the skin. It\'s a big‑time skin irritant. It\'s also a
suspected skin carcinogen. With this underneath the parts washer, which
was supposedly safety clean green, now we have cross contamination.
Maybe I took a chainsaw motor to clean it and then I took that chainsaw
motor and put it in the safety clean solvent to do something else to it.
So I have cross contaminated everything. It\'s a management practice,
one of the hazardous waste things, management tools that Martin was
talking about earlier. Think about your waste streams and how they could
be affecting your generator status. The shop also has on the other side
a variety of other ‑‑ we have welding, drill presses, et cetera. Anybody
want to take a hazard of what\'s the problem in this compressed gas
storage? The green cylinder is oxygen. The red one down here is
acetylene. The green one is nicely contained in here. This red acetylene
one, it could easily be knocked over. So that\'s one problem. But
what\'s the primary issue with oxygen and acetylene when they\'re in
storage, assuming these were both secured ‑‑

Caller: Lamar, big thicket.

K. Morin: What\'s proper storage for oxygen and acetylene?

Caller: Separate 20 foot apart.

K. Morin: Exactly. They have to be 20 foot apart. Unless they are hooked
up ready for use, and then they can be right next to each other. This is
a free standing cylinder that also needs to be stored properly. Behind
this is the overhead crane. The issue I am finding cranes is no one has
been trained on how to do the frequent and the periodic inspections that
are required. Also, there\'s been no weight test conducted. There is
supposed to be a load limit marked on this I beam, actually on both
sides of the I beam. Sit rated for 5 tons, 2 tons, 500 pounds? What
I\'ve seen out in the field is we\'ve scrounged this thing from
someplace and installed it without doing engineering work to determine
what is a safe limit for this I beam. I talked about the periodic and
frequent inspections that are required. OSHA requires that once a month
someone has to actually sign off and say that this crane is safe to
group their signature is required. And if you\'re going to make me do
that, I want to be trained in what to look for that were the links
deformed? Is this hook, sit cracking? Is the throat in here, this
distance between the top of the hook and the bottom, is that distance
expanding? That would be indicating that the steal is starting to yield.
You\'re supposed to be checking to see if the brakes work on the crane.
A whole bunch of stuff. As I said before, it has to be certified monthly
it\'s safe to use. This routinely isn\'t being done. Paint rooms are
always a Kodak moment or target‑rich environment for me. One of the
primary things we\'ve been identifying inside these paint rooms is
excess hazardous materials. And the biggest excess HazMat for us has
been these automotive paints, whether they be be by Pittsburgh paint and
glass, or Dupont. But they say clearly on it, industrial use only by
trained professional, not intended for sale to the general public. And
BLM doesn\'t have any professional painters. We don\'t have any auto
body people. Maybe they did it in a previous job and say, yeah, I can do
that for you, I can touch up the fire engine that got damaged in an
accident. But when we do that, it brings in more management programs
that with we\'re probably not ready for, particularly respiratory
protection. What happens when we do don\'t have those programs in place
is he we get improper ‑‑ we ‑‑ our employees aren\'t properly protected.
Here is another industrial product and it states right on it that you
have to have wear a respirator. It says wear an appropriate properly
fitted and that\'s the key term right there, properly fitted, vapor
particulate respirator. So I see the paint, I ask the person that\'s
with me, so do you have a respirator? And this guy ‑‑ it was very easy
for him to say, yeah, he does. Because it\'s stored ‑‑ let me go over on
this side. It\'s stored right next to the paint. With the organic vapor
cartridges still on it. So the next time this person wants to use it,
these cartridges are fully contaminated. In other words, they\'re not
protecting anybody. It\'s another evidence of we don\'t have the
management policies and procedures in place to properly protect our
employees. Inside these paint rooms is also a ‑‑ particularly in the
back corners, lots of excess hazardous materials. The stuff up front is
stuff you\'re using all the time, gets turned around. But routinely we
see paint that\'s approaching 20 or 30 years old. This was made in 1984.
We did this odd it in 2000. If the paint is 16 years old, I begin to
question whether it\'s ever going to be used. It has a shelf life of two
years. Now, it\'s been properly stored. Yeah, you could probably use it.
But are you going to spend three days out in the field painting
something with paint that\'s 16 years old that a year from now may be
peeing away? That wastes a lot of labor. You are probably not going use
paint this old, it\'s nah going to mix properly, the pigment and solvent
have stratified. It\'s not going to mix. That\'s why it\'s been using
here. Old tree marking paint is another source of hazard that we find
quite a bit and there ‑‑ Forest Service and BLM have switched to a new
type of tree marking paint. What are we going to do with the old stuff?
This was one office\'s solution, to pour it into a swimming pool they
created. And they\'re just letting the paint dry up here. Is this
appropriate treatment ‑‑ is this appropriate way to deal with a
flammable paint product? Anybody want to hazard a guess? This isn\'t
Latex now. This is got a flash point of under 140 degrees.

Caller: No.

K. Morin: No, it\'s not.

Caller: Lamar, big thicket.

K. Morin: Hi, Lamar. What would you do if you had this type of tree
marking paint you wanted to get rid of it?

Caller: I don\'t know about that. Probably you have an air quality
problem there.

K. Morin: Yeah, if ‑‑ even if I was an attainment area, I still have a
problem. Because even a conditionally exempt small quantity generator of
hazardous waste, and that\'s what we have decided this is, because this
isn\'t being beneficially used, we\'re just a evaporating it, so we\'re
defer nutly managing it like a waste, even if they want to treat it and
evaporation is considered treatment, they have to get some sort of
permit from their regulatory agency on how to proper hey manage this
liquid. The bigger issue is, let\'s say we got that treatment permit.
The state said you\'re in the middle November where, you don\'t have any
air quality issues, you are going to do this where there is no ignition
sources. We don\'t have to worry about a fire hazard. Go ahead and
evaporate it. Underneath in blue point is orange and yellow. And these
cans say orange and yellow contain lead. So what I\'ve done by
evaporating this paint is I\'ve concentrated the lead and this will fail
TCLP, or the toxicity characterization leach 8 procedure test and it
will fail it for lead. So I\'ve taken three or 400 quarts of tree
marking paint which have a high BTU content, 55‑gallon drum of paint can
be disposed of for about \$180, but now I\'ve just got concentrated lead
sludge and it\'s going to be much more expensive to get rid of.
Herbicide. We\'ve got loft trucks out there applying stuff and if
you\'re hauling out a big tank like this, if it\'s just water for
mixing, that\'s great. But you\'ve got to label it that way. Needs to
say, nonpotable water, herbicide use only. So we don\'t have any chance
of cross contamination. On top of that, more importantly is, if this
vehicle is cut off and we have an accident and it rolls over, when we
see containers of herbicide com coming out of the truck, your emergency
response people are going to be freaking out and activate the HazMat
team because this isn\'t labeled. Does this have mixed herbicide in it?
We need to be placarding. Even if it\'s mixed herbicide and diluted,
it\'s going to be at a minimum a class 9 hazardous material. The other
issue is how are the herbicides that you\'re carrying in the truck, how
are they secured in here? Because I\'ve looked at a bunch of these
trucks and the bottom of the bed has got the blue stain from mixed
herbicide over it because these things will tend to abrade and start to
leak or get knocked over and spilled. So you want to make sure when
they\'re stored in the truck here that they\'re not sliding around and
tipping over and spilling. Now, the storage of herbicides in general,
though, we\'re doing a great job. Primarily because we have trained
applicators out there. They are segregating by product type. We don\'t
have the incompatible problems that we have with regular hazardous
materials storage. The issue, though, is again, it\'s an emergency
response issue. When we put it in a building like this one and there\'s
a fire, let\'s say your office is on fire, the fire department needs to
know that behind them in this building you\'ve got a couple hundred
gallons of herbicide that they need to know, they need to protect this,
remove the product, or if it does catch on fire, they need to be able to
put on the right protection, probably supplied air. Or just let it burn
to the ground and evacuate the site. That\'s probably the best way to
treat a herbicide fire. When you start putting water on it, you
contaminate the water and that concentrated pesticide and herbicide and
the runoff use from the water used for firefighting, you have probably
created hazardous waste on the ground. You probably should let it burn.
What you want to do to protect yourself and those emergency response
people is on that this building, it needs to be properly signed, danger,
pesticides stored inside and there also needs to be an inventory of
what\'s in there by chemical and quantity. Just wrapping up here because
we\'re totally expanded the scope of what we do in BLM with our odd and
its this woman here is ‑‑ we brought out now electrical testing
equipment and we\'re out in the field and randomly testing circuits.
This one actually has a false ground on it. What happens the FG means.
The number two finding that we have in BLM now are electrical issues.
We\'re looking at junction boxes. What we\'re seeing is extremely bad
tape jobs, and this is high voltage electricity now that unfortunately
we\'ve got people messing around with, and you can see what happens when
these tape jobs aren\'t done right. Look at the chunk that came out of
this metal when it went to be closed. It actually arced and ate a piece
of this. If somebody had been working nearby, it could be a potential
electrocution hazard. We are always looking at woodworking material but
we we\'ve gone a step beyond and we\'re making sure it\'s guarded. This
one is missing it. And it has a manual reset switch. When you are Urich
Wing on a table saw or radial arm saw, when the power goes off, and when
it comes back on, you don\'t want to it start. Or the piece of work if
it\'s left there could kick back. A manual reset switch means you have
to push the butt tune get the saw to reengage. Those are typically
buying. If you are buying Delta products a lot of the manual reset
switches are built in. But if you are buying Sears and Roebuck saws or
table saws, they\'re not there. Those are for household use. You can buy
an \$80 retrofit to provide that feature. That\'s it for the virtual
tour here. I\'m going to turn it back to Martin, unless you have any
questions for me. When we come back, I\'m going to talk about 11
management things that you should take to maintain your compliance. Any
questions at all? Martin, back to you.

M. Thrasher: All right, thanks, Ken. Ken\'s going to stay live with us
here, so if you have any questions for him, that would be great.
Obviously Ken has raised a lot of issues here and the challenge for us
as managers is to recognize some of those issues and then to start
thinking about well, what kind of management techniques can you put into
place to address some these issues? I was wondering if ‑‑ as you
listened to Ken there, if you had thought of any management policies or
procedures or techniques that might help address some of those issues?
Let me give you an idea what I\'m thinking about here. Remember when Ken
was talking about the acquisition of farmhouses by some of the agencies
and the problem is that when you acquire those, either by buying them or
trading for them, sometimes they leave a lot of junk around there,
chemicals and so forth some of which may be hazardous waste. You may
have water quality issues at the sites. And one of the management
techniques to take care of that is to use ‑‑ Ken referred to it, was to
use the ASTM audit standards. They\'re actually called phase I and phase
II audits under the ASTM standards. You can ‑‑ you could develop a
management policy that says whenever we\'re going to acquire a new
property that we\'re going to assess the property used in the ASTM phase
I and phase II audit standards prior to that acquisition. That would be
a management policy and you\'d have your procedure in place, because the
ASTM standards are already written. But would that safeguard you from a
lot of these hazards and expenses later on down the road. At least you
know what you\'re buying. What has somebody else thought of? Remember
Ken referred to the use of respirators. Hopefully that will bring to
mind if that you\'re using respirators that you need to have a
respirator protection program. That\'s a written program that includes
how you\'re going ‑‑ what type of equipment, what type of training
should all be in righting. Frank, I wonder if you had any thoughts as
you listened to some of those?

F. Mills: Well, hopefully I hope that the managers out there who are
watching the program are beginning to realize the complexity of all of
these issues. You know, it\'s kind of like a large family. You know, you
have a whole bunch of people and different things have that to interact
and someone has to be in charge and actually say, it\'s time to eat
dinner once in a while. So I think oftentimes as managers we\'ve got to
look at this whole broad issue of environmental, safety, OSHA, D.O.T.
and that\'s why these environmental management programs are so
important, is they allow us to take all of this, put into it a pot, mix
it up, and actually come one something that I as a manager can work with
on a daily basis to ensure that I\'m meeting all these requirements. Any
one thing can be affected by a number of laws at any one time and I need
to know when to be able to speak out and make sure that a correction is
made in my program. So as you\'re working with this, keep in mind, and
hopefully you\'ve seen throughout these six sessions the complexity of
all of these issues and how they\'re interwoven into a big mass
organizational type issue.

K. Morin: Frank f I could add something to that. These issues are
complex, but at least in our experience, and I think you\'ll validate
this, 85 to 90% of the environmental issues you find out there, they
don\'t cost a nickel to fix. A little preplanning, some policies to
prevent you from creating waste streams or to tell you what to do when
you do have a problem, will prevent large costs down the road if that we
buy the right tank for fuel storage as an example with secondary
containment, if it does leak, we don\'t have to clean up the ground as
an example.

F. Mills: Ken, you\'re really right about that. We found in our audits
in the Forest Service that fully 85% of those audits can be fixed for
actually under a \$300 problem. So when we find these things, it\'s not
money, and we hear appear lot from managers. We have a money issue. I
can\'t afford it. It\'s really having it on paper up front that would
have prevented that, and a lot of these things are very minor to fix. If
you don\'t, though, they\'re going to cause you problems down the road
that\'s going to cost you big dollars.

M. Thrasher: One of the other things that came to mind while Ken was
talking, he talked about using what key called greener products, which
essentially when they become a waste, they do not become a hazardous
waste. They\'re either totally consumed in process which is good, or
when you have to dispose of them, they can be disposed of either in a
landfill or possibly down a publicly owned treatment works, whatever,
but at least they\'re not a hazardous waste. At first glance some of
these products may be a little more expensive, I don\'t know, depends on
the product, but even if they\'re a little bit more expensive than
another product, if you look at the total Lifecycle cost of that
product, it may end up being cheaper than disposing of stuff as waste.

F. Mills: That\'s very true, Martin. Ken, you can jump in here also. We
notice in our tree marking paint issue that when we went from a
solvent‑based tree marking to a water based tree marking paint the cost
of just disposing of the ‑‑ you know, the materials that we clean up our
brushes with and our sprayers is so much less, so much more
environmentally friendly, that we\'ve actually made a great stride on
the whole nation as a whole because where we went with treat marking
paint, private corporations are following suit also.

K. Morin: The other benefit is not only waste disposal costs are
reduced, but the exposure to the employees. That\'s more important.
They\'re not being exposed to those hazardous chemicals, whether they be
corrosive or inhalation hazards you go to the greener products.

M. Thrasher: And I have to add another \"and\" also under superfund. If
you are disposing of hazardous substances and it has to be cleaned up,
talk to the local school districts who took out minor amounts of
asbestos and there\'s been thousands and tens of thousands of dollars
cleaning up places. I think with that we would invite some other
questions or comments from the folks out there, if you have any comments
about what you\'ve seen here this morning. All right. I think what
we\'ll do now is turn to Tony and I think we\'re about ready for a
break, aren\'t we? That\'s right. At this point we are going to take
15‑minute break. When we come back, Ken Morin will continue his virtual
field tour and then we\'ll be going live to a Federal facility being
audited, and you\'ll be able to participate and interact with the
auditor using that push‑to‑talk system. Then after that, we\'ll have our
course review and Martin\'s top 10 list. Lots more to come in our second
half. We\'ll see you 15 minutes from now.

T. Garrett: Welcome back to Module 6. Our last broadcast in the
Manager\'s Tool Kit series. In a moment. We will be going back to Ken
Morin and more of his virtual field tour but before that we would like
to mention some upcoming telecasts. On April 3rd and 4th we will be
broadcasting a two‑day interagency satellite course. Contracting
refresher\'s training. If you are a COR and need to keep your
certificate current, contact right away to register. . On May 2nd we\'ll
be taking a look ahead at the 2002 fire season. This interagency
telecast will examine whether fuels and moisture predictions, the
National Fire Plan, fire rehab, fuels safety. Please mark your calendars
for those important training events and we hope you\'ll plan to be with
us. We would also like to mention we would like all of you who have been
participating in this course to complete our online course evaluation.
That can be found at the Manager\'s Tool Kit website on the BLM National
Training Center\'s homepage at www.blm.gov/education. So please take a
few minutes after our show today and complete that evaluation for us.
Now let\'s again go back to Ken and his virtual field tour. Ken?

K. Morin: Thanks, Tony. I went over a variety of common sense compliance
issues in the previous hour. Hopefully most of them were you recognized
them, they were relatively easy to correct, you could do them for little
to no money. What I want to go through now is 11 management type issues
that if you implement you can maintain compliance. The first one is, you
need to provide your staff with an easy way to get rid of their
hazardous wastes. Because if you don\'t do that, when they\'re preparing
for Frank and I to come out and do a audit, you will see five gallon
buckets like this one being dumped in the trash or the yellow one behind
it that has solvent in it. This came from a chainsaw cleaning operation
that we saw on the site. They didn\'t know what else to do witness. They
knew they couldn\'t pour it on the ground, so like maybe the trash could
absorb it. You can\'t put any liquid waste into a dumpster at all. If
you provide the staff with an easy way to get rid of stuff, it won\'t
wind up in the trash like this did. Here are some aerosol cans. Both
these are at least two‑thirds full because I tested them. Aerosol can is
going to be an ignitable hazard waste and also a reactive hazardous
waste. There are 23 states in the country that require conditionally
small quantity generators to dispose of their hazardous wastes at a
hazardous waste treatment storage or disposal facility. In other words,
you can\'t throw it in the trash at all. By state law. Those states
include Colorado, New Jersey, Illinois, a variety of states. Like I
said, there\'s 23. It list came out in July 1994 study that EPA did. So
this type of action could easily get you into trouble. Now, what also is
commonly created is plastic containers full of mystery fuel. In other
words, what\'s the ratio of the fuel to saw oil? Is it 40‑1, 6‑1. ? No
one is going to use it. Maybe it will be used for drip torch fuel but
it\'s been my experience these things tend to pile up until you finally
run out of containers to put them in and so we start filling 55‑gallon
drums full of mystery fuel, and those are the things we find in the back
north 40 in your wareyard or your bone yard with weeds overgrowing and
they\'re starting to leak. You need to develop some policies procedures
that allow your staff to easily get rid of this stuff. This is what one
office did. They bought some flammable storage cabinets and they\'ve got
a hazardous ‑‑ waste accumulation site. They\'re locked up, but
everybody in this Field Office knows, because a memo went out via
e‑mail, if you\'ve got something you don\'t want, turn into it Fred or
Sally or Sue, and they\'ll either find someone who can use it, maybe we
can recycle it, maybe another agency wants it, and if not, then that
individual is responsible for disposing of it properly. Second point is
don\'t purchase stuff in bulk. It\'s just going to lead you into
problems. What traditionally happens with that 55‑gallon drum of solvent
is it does get stuck in the north 40, it\'s hard to dispense out, people
only want two or three ounces. It doesn\'t work. Don\'t buy in bulk.
Third issue is avoid picking up anything from DOD or DOE. There is a
reason why they\'re surplussing it. Could be shelf like expiration or
could be just the chemical is really hazardous and here\'s an example in
this flammable storage cabinet. This is airfield marking paint. With few
exceptions, we don\'t need this stuff. Someone thought, ok, it\'s free,
I can scrounge it, can I use it. It\'s also traffic marking paint. We
could use it for our parking lots. But it\'s got a flash point of ‑‑
it\'s almost zero. So it\'s extremely volatile. The Field Office staff
when I was talking to them about it, they refused to use it because it
was giving headaches. So they bought this Latex traffic marking paint
here outside the cabinet. So because we scrounged this DOD runway
product, now we have to dispose of five gallons of hazardous waste. Your
flammable storage buildings, they need ‑‑ they should be in detached
facility, a detached structure, with explosion heating, lighting,
ventilation. This is a good example of the type of structure I\'m
referring to. But what you have to be concerned of here is this is built
right on the property line. You can see the fence behind it. See the
fence back in here? So I\'ve got two walls. I\'ve got that wall and back
over here on the other side I\'ve got two walls of the structure that\'s
right on the property line. NFPA and OSHA both require that your
flammable storage buildings have to be 50 feet from a property line, or
if they\'re property line, all the walls that are exposed to the
property line, have to have a two‑hour fire rating and these concrete
masonry unit structures only have a two‑hour fire rating if you fill in
the voids and more often than not when we are doing lease‑purchase
contracts on these buildings, we don\'t specify that and these voids are
hollow and don\'t have the right fire rating. The other issue is, if we
do build something like this, and you can see the snow on the ground
here, these things become ice boxes in the wintertime because we don\'t
have heating. We don\'t have ventilation. In the summertime they become
furnaces. This says keep from freezing. This five gallon bucket of stain
cost around \$100. But if it freezes, it might be potentially useless
and now in addition to the \$100 we spent to by the product, we have to
spend money to get rid of it. You want explosion proof heating in there.
This container right shear an example of what happens to paint or stain
when it freezes. You can seat ice crystals. Even if this defrosts in
April, the pigment and solvent stratify so much that it\'s going to be
nearly impossible to mix this enough so it\'s usable. Next issue, we\'re
merging ‑‑ we\'re merging offices, trying to keep down overhead costs.
When we do that, or the fire programs are growing and we are moving
dispatch for fire in the warehouse and that warehouse used to have lots
of hazardous materials in it. But now we\'ve changed its occupancy from
a warehouse to office occupancy. And the OSHA regs are very, very clear,
office occupancy can only have the hazardous materials that are
necessary to operate the office. As far as I know, there\'s no office
that we have that needs gasoline or tree marking paint to make the
general office run. You may need a flammable toner for a copy machine.
But you certainly don\'t need a 5 gallon Jerry can for it. So none of
that stuff can be stored in office occupancy. What happens when you
change that occupancy and start building offices in your warehouse, now
you have to find a place to store all the flammable materials. If you
are going to proceed due that, you need to provide for hazardous
materials storage because things like Silvex has a flash point of 105
degrees. If you have buckets or drums, this cannot be stored in office
occupancy. It\'s considered a combustible liquid. Has the same flash
point as diesel fuel. Silvex is 8% alcohol. Next issue, don\'t buy
products that need PPE. PPE is ‑‑ means Personal Protective Equipment,
IE., respirators. Because what happens when you do that, is the
employees, they can read as well as anybody else can, they read the back
of the container, and it says they need a respirator. So they go buy
one. I find this all the time. This one right here, you see the yellow
staining all over it? Right up in here? Right there. This was done. They
were painting cattle guards. They wanted a paint that would stand up to
the abuse of traffic running over it. So they bought some really
high‑tech paint, extremely volatile, flash point very low and they
needed respirators. So they bought them. What they didn\'t do, though,
was get any training. There was no management plans put into place. And
most importantly, there was no medical clearance or fit test provide to
do these employees. So they bought respirators that didn\'t feet them
properly. What happens when you do that is you start to suck the air or
the vapors around the sides of your mouth and directly into your
breathing space. See where this is stained over here? See where it\'s
stained here? That\'s the yellow paint that they were suing in right
into their breathing zone. If we had had an effective respiratory
protection program, they would have been properly fit tested and they
would have had a respirator that prevented that from happening. Because
the big thing that happens when somebody gets a respirator, they think
they are protected and so they are working closer than they would
normally. The next issue is go green. Particularly you want flash points
less than 140 degrees on any solvent that you are using. The reason why
is anything product with a flash point less than 140, when it becomes a
waste, is an ignitable hazardous waste. So you go to green solvents and
you all have, or a lot of you have, safety clean parts washers and
that\'s what happens this one is. They should have a label like this one
does. It says safety‑KLEEN105 solvent. The 105 is referring to the flash
point. This is under 140. It\'s a hazardous waste. When we were out
there, safety KLEEN was out there changing the solvent. I said, hey, do
you have your green blend, higher than 140? Please switch it out. No
problem. He did so. And restickered it. This premium gold does not have
‑‑ the one that had the 105 on it, it had a listed solvent it in.
That\'s what makes it so flammable. The other thing that you can do to
maintain compliance is if possible go to Latex paints and if you need
oil based, and you might for those cattle guards as an example, and
instead of spraying it you decide to brush it, use disposable brushes
and then you don\'t generate the turpentine waste and the paint thinner
waste. I have turpentine here. I have brushes soaking in this bottom
half of an old antifreeze container. What happens, though, is ‑‑ how
many times do you really use this high strength paint? The stuff that
you need to turpentine to clean the brushes with? You don\'t do it that
often. The brushes tend to be left to be soaked in this stuff, and out
of sight, out of mind, you all have too much to do. Maybe you\'re
applying herbicides, fighting fire, whatever it happens to be opinion
what happens is everything just evaporates out of here anyway and the
brushes are literally stuck to this container. They may have been \$10
brushes but now they\'re trash because they are completely bent and
they\'re all gummed up from the turpentine that evaporated. So you wind
up throwing them out anyway. So you might as well start with disposable
brushes to begin with. Your remote fire stations, remote field stations,
I showed you pictures of fuel storage and vehicle wash racks, and those
field erected tanks you\'re putting up or the wash rack connected to a
dry well or a septic system are going to wind up biting you because they
don\'t comply with either OSHA, EPA or uniform fire code regulations.
These type of tanks, I went through them, you can\'t dispense from the
bottom, they don\'t have pressure relief on them. You need to be
switching to a convault such as this one. Something like this. You also
on your vehicle wash racks want to make sure this drain is going into
hopefully ‑‑ you can go into a publicly owned treatment work. That\'s
probably not likely at most of our fire stations. So if this drain is
going into a septic system or it\'s going into a dry well as this one
was, you are in violation of the under ground injection control
regulations and you are going to have to discontinue this practice. The
easiest way to provide a wash rack at a remote site is to put in a
gravel pad and wash on the surface, provided runoff is not running into
a local irrigation ditch or storm sewer or arroyo. If it\'s maintained
at the pad and not going anyplace, you are fine and fully compliant. The
theory being is if you are getting a lot of oil and grease or other
contaminants, you will see it staining the surface. When you go into a
dry well, you don\'t know what\'s happening underneath and it\'s a
direct path to groundwater. There is over 130 superfund sites in the
United States created from dry wells. Our 10th point, one more to go
after this, you need to assign someone with responsibility for operating
your water systems and for sampling them properly. You can\'t be relying
on a campground host that\'s never been trained. You need to set up some
management practices like COLIform sample siting plans. The ones we are
righting now, they are describe what do you do when you test positive?
Where are the public notices going to be posted? If it tests positive
for fecal or e‑coli, are we going to post a boil order or shut the
system down in the preplanning will prevent from running around with
your head cut off. When it does test positive right before the 4th of
July weekend, your management team will be meeting in Washington D.C. or
doing something else and you\'re the poor recreation person that you
don\'t the authority to shut down the water system. You want to set up
the management systems in advance so you can take the right actions.
What I\'m seeing more often be not when I\'m going out in the field with
the rec. person, they are walking around with bottled water because they
won\'t drink the water out of the sites. They said, hey, I found frogs
in that before or, yeah, we do get dead rodents in their periodically.
Then last but not least o these audits, you want to have your program
staff participate in them. I don\'t mean your safety and your
environmental, your hazardous material coordinators. They\'re
participating already. I\'m talking about your fire people, your weeds
people, your wild horse and burro people, range CONS, et cetera. When we
visit their site, the biggest thing we can do for you is provide them
real world site specific training. When we open up that cabinets and
there\'s incompatibles in there, we can explain why it\'s a problem. To
just hand that person a report and tell them you need to take the
oxidizer out of that cabinet, they haven\'t learned inning. So they take
that one out and put anis identify in there. If they are available at
the site when we are doing the audit, the training opportunities are
tremendous. On top of it, it makes environmental everybody\'s
responsibilities. You can\'t just rely on your safety and your
environmental coordinators to be in compliance. Everybody\'s
responsibility is for compliance. Any questions on those issues? if
there aren\'t any, Martin, I\'ll turn it back to you.

M. Thrasher: Thanks, Ken. That was a great tour. Raise as lot of issues
for managers to think about. What I\'d like to do now is to get a
dialogue going with those of you that are watching the program to talk
about some of the issues that Ken raised, some of the management issues,
how you would address some of those, some of those that you saw that
maybe you\'re confused about how to address. I think it\'s pretty
apparent that one of the major programs that you need to have in place,
and again the Forest Service, BLM, have them, I would be interested to
know if the National Park Service, BIA and some of the other agencies
have audit programs in place, because that\'s a really important
management tool as a part of your total environmental management system,
because without that, without these experts to go out and help the
managers out to identify the issues that you\'re faced with, a lot of
them you wouldn\'t even know about. So what kind of questions or
reactions do we have from the folks that are watching? How about the
National Park Service, do you have an audit program?

Caller: This is Kate in Virginia. We just recently completed an
environmental audit, the EPA, through a contract out of regional office.

M. Thrasher: Great. Is that going to be a continuing process or is it a
one‑time deal?

Caller: I believe the odd sit just a one‑time deal and we\'re now
implementing all of the recommendations out of that audit and have our
own management audit system set up to reinforce the things we learned
out of the audit.

M. Thrasher: Good. When you say implementing the audit, do you mean
you\'re just fixing the things or are you looking behind to that see why
they occurred and try to make some long‑term solutions to those?

Caller: I think the latter. We really are fixing the deficiencies, but
we\'re also providing training, putting contracts in place, like with
safety‑KLEEN ‑‑

M. Thrasher: That\'s excellent. That\'s exactly what you need to be
doing. Frank, did you have any other thoughts or any of you out there
have any other thoughts about what we\'ve seen?

F. Mills: Well, Martin, one of the things I would encourage the managers
to consider is that auditors, and especially environmental auditors, are
specially trained to do a certain type of audit. A lot of the times the
field staff believe that we\'re there inspecting them, and that\'s
further from the truth. An audit ‑‑ an environmental audit is not an
inspection. I\'ll give you kind of an example of why we don\'t call it
an inspection. If a state inspector came out and he was looking at, say,
your hose connections to see if you had back flow prevention, the
inspector would actually look at every single hose bib and say, you
don\'t have one here, you don\'t have one here and we would write each
one up. An auditor, on the other hand, goes and looks at those hose bibs
but, instead of saying you have 50 missing, the auditor says, you don\'t
have a program in place for backflow prevention. So the fix to this is
let\'s get a program in place for backflow prevention, instead of just
writing up each every little audit finding we have. I think what I see
in our audits is about Wednesday of every week the field staff start
looking at us like, instead of being an alien from space, they actually
start looking at us as someone there to help them complete their program
and do a better job. We\'re not there looking for problems to get them
in trouble. We\'re looking for problems to fix so they can provide the
public a better service.

M. Thrasher: That\'s when we developed our audit program in the
mid‑\'80s. What happens we did. We had a tough time at first selling
managers that we weren\'t there in some kind of punitive fashion. We are
there to help them. If they don\'t implement programs, they don\'t do
the right things, then it can become a punitive thing, but that\'s not
the intent of the program. The other thing that I think our program that
we developed is similar to yours, is, sure, we look to examples of
problems like containers not being labeled, backflow prevention, but
those were indicators of a lack of a management system that you need to
go back and work on. Yeah, I have to correct the little individual
things, but the big picture was to put up ‑‑ a procedure in place so it
didn\'t occur again. What other thoughts did we have from folks? I know
we\'ve got Forest Service folks there and some BLM folks. What are your
thoughts about the virtual tour?

Caller: One of the things that I noticed during the virtual tour was
when Ken was showing a bulk tank in one of the yards, I thought that
maybe some reference was going to be made to the requirements or what
triggers an SPCC plan, and I was wondering if you could make discuss the
SPCC and what triggers it and if there is any program or canned product
that would assist a person or an agency to do not SPCC plan.

M. Thrasher: Right. I sure can. We tried not to get into that kind of
detail, but let me give you the triggers for an SPCC plan. If you store
under ground more than 42,000 gallons of petroleum, you need an SPCC
plan, or if you store more than 1320 gallons total above ground, then
you have to have an SPCC plan. Or the third one, if you have a container
of 660 gallons or more above ground, then you need an SPCC plan. Now,
remember on the above ground storage, when you\'re calculating the
quantities, you have to calculate the quantities of all the petroleum
that you\'re storing, no matter what size of container. It could be a
big 500, thousand‑gallon above ground storage tank, or it could be a
quart tank ‑‑ a quart jar or gallon jar. You compute all of those to add
up your totals. So those are the triggers. You got your 660 in a single
container, 1320 total above ground or 42,000 below ground storage are
the trigger marks. Now, as far as a model for SPCC plans, I know that
Ken has sent out a model kind of fill in the blank SPCC plan and I\'m
not sure if the Forest Service has one.

F. Mills: We actually did have one, but we also utilize the one that the
EPA has put out.

M. Thrasher: That was the other thing I was going to mention. EPA has
actually put out a model SPCC plan. Now, you remember you have to have a
professional engineer prepare that plan and sign off on it. So they\'d
have to take that model, whatever model from the Forest Service or BLM
or from the EPA, and Taylor that to your ‑‑ tailor that to your
facility.

F. Mills: Another thing I might mention is that the U.S. Coast Guard has
special teams that will come ‑‑ they don\'t have to be near the
coastline. They\'ll actually come to a facility and help you develop
SPCC plans and a management system for above ground storage.

M. Thrasher: I didn\'t know that.

F. Mills: They\'re very active and they like to get called to places
they don\'t come to very often.

M. Thrasher: Colorado.

F. Mills: They love that.

M. Thrasher: I didn\'t know that. Hopefully we answered your question
there. Any other questions or comments? How about the D.O.T. issues, any
comments or questions about that? All right. One of the issues that Ken
brought up was ways ‑‑ waste minimization and he talked about using
products rather than throwing them away, certainly storing them in a
fashion so they don\'t become waste to start with, and maybe an option
of finding others that could use products that you don\'t want to use
rather than throwing them away. What he\'s actually done is outlined
what we typically called a waste minimization program where you look at
all of the legitimate alternatives to not have hazardous materials enter
the waste stream. Do any of you have any programs like that or\... ok.
Nobody has any comments about that? Well, that\'s a very important
attribute of most of these hazardous materials programs s to go green
and then minimize the amount of materials and I think one of the other
methods that Ken mentioned was to reduce the amount that you purchase so
you don\'t have excess on site.

F. Mills: Right. We had a great plan in the state of Texas where the ‑‑
all the forest in pooled their resources into a hazardous materials
purchasing ‑‑ actually an FTP. So this person sits at one location, and
each forest, when they need a hazardous material, contact this person to
actually make the purchase, but the person\'s responsibility to the
forest is to check all the alternatives and suggest some things that
they could use instead. And we\'ve got really good results from that
kind of a pooling effort, and having one person who is very familiar
with the GSA purchasing requirements and things like that.

K. Morin: I know when ‑‑

M. Thrasher: I know when I had a staff, I told them I wanted them
spending out 90% of their time trying to figure out how to use material
or somehow keep it out of the waste stream, because it got too
expensive. I think with that what we\'re going to do is turn to another
segment of this module, and that\'s a ‑‑ an actual audit of a Federal
maintenance facility and Ken\'s going to spearhead this for us. The way
this is going to work is Ken\'s going to actually go in with Bob to a
maintenance facility, conduct an audit, and point out some of the
issues, both positive and negative, in that particular facility. Now,
during this part of the program, it\'s all live. They can hear you. So
make sure to use your push‑to‑talk if you have questions and they would
be glad to stop and talk to you about that. So with that, Ken, we\'ll
turn to you.

K. Morin: Thanks, Martin. What we\'re going to do now is actually do an
audit at a shop here at the Training Center, and Bob Sykes will be the
shop foreman and we\'re going to run through and I want the push‑to‑talk
people, we\'re going to freeze frame periodically and I would really
encourage you to ask us to turn stuff around or ask Bob questions
related to what may be in a cabinet or how does he handle or manage
different materials. So with that, we\'ll kick off the audit. Bob, you
have a nice looking shop here, pretty clean. You haven\'t been here very
long.

B. Sykes: Not too long.

K. Morin: Let\'s start with the drill press in the middle of the room.
Want to positively note it is mounted properly so it can\'t walk or move
while you are using it, but I notice you\'ve got the guard missing up
here. So we have belts and pulleys fully exposed. Sit always like this
or did you replace a belt?

B. Sykes: It\'s always been like that and we haven\'t had any problem ‑‑

K. Morin: You can see how it might be a problem. What the OSHA regs
require is that all belts and pulleys within seven feet of floor have to
be fully enclosed.

B. Sykes: Ok.

K. Morin: You have a grinder right here. What are you using the grinder
for?

B. Sykes: We use it to Shar pen some tools and to do some metal work on
some equipment that we have here.

K. Morin: You\'ve got the tool rests which are required, but I notice
this one is way out of adjustment. What OSHA requires sit has to be
within an 8th of an inch of the wheel so that it can\'t get caught in
here. You have supposed to have a tongue guard that stops the sparks
from flying back at you. On this side it is properly adjusted, and the
tongue guard is in place and you\'ve got ‑‑ you have hearing protection,
eye protection. So you are three quarters of the way there, we just need
to find the tongue guard and readjust this.

K. Morin: On your welding equipment here, you have the leathers to
protect your upper body, you also have leathers for your legs, you have
gloves, you\'ve got a shield, your leads are all fine. I suggest to you
when you\'re storing this and it doesn\'t appear it\'s an issue here,
you don\'t want to be storing this outside or leaving it on the back of
your pickup because it dry rots the leads and these will crack and then
become an arcing hazard, a potential shock hazard. But otherwise you\'re
in great shape. On your oxygen and acetylene, they can be hooked up like
this, as long as they\'re hooked up ready for you, you\'re fine, but in
storage we\'ve got some issues and I\'ll ask you to show me if you have
spare cylinders in a little bit. On your torch itself, though, this is
an old, old torch, because it does not have flashback protection built
in it. If it did, it would have an FC in here and it would have a flow
direction. What that means is the flame cannot travel back up these
rubber hoses where the gas is coming through. I need you to buy ‑‑ it\'s
a \$30 retrofit that will go on both acetylene and oxygen and it\'s like
a flame checker, and a little check valve to provide you further safety.
I\'ve actually had people tell me they\'ve seen these go up in flames
and it\'s not a pretty sight. Do you have spare cylinders?

B. Sykes: Yes, we do. We have several of them right here.

K. Morin: Ok. As I said before, your oxygen and acetylene need to be
separated if they\'re not hooked up ready for use. They have to be
separated by 20 feet. The other thing is we don\'t want them to be free
standing, because if they get knocked over, there\'s 150 pounds of
pressure in here and if this breaks off, this can be a torpedo, and it
can hurt somebody pretty bad. Even if it doesn\'t hurt anybody, just
cause a lot of damage in the shop. The other thing with acetylene is,
there\'s acetone in the cylinder and if you allow it to be stored
horizontally, the acetone can leak out and then the acetylene can leak
out and then we have an ignition source.

B. Sykes: I\'ll make sure those get properly stored.

K. Morin: They will need to be chained 20 feet apart, below the
shoulder, right below the shoulder.

B. Sykes: We\'ll do.

K. Morin: Let\'s look at the cabinet. This is typically a Kodak moment
for us. But you look like ‑‑ it\'s not overflowing with stuff. I just
want to point out you don\'t need to be storing motor oil and stuff in
cabinets. If you are running out of space shall ‑‑ this is a flammable
and combustible liquid storage cabinet. Motor oil, lubricating oils,
flash points well over 300. They don\'t need to be in here. Fine if they
are, it\'s not a problem, though. Some of the things that are jumping
out at me, though, I want the ‑‑ like the viewers to take a look at. So
if we could get a good shot of this shelf right here, and if we could
freeze right on that.

Caller: You have a closive with a flammable.

K. Morin: Exactly. That corrosive, Martin f you could circle it for me.
That\'s battery acid. You can seep the box, it\'s got some brown stain
on it. It\'s actually ‑‑ because these things tend to leak a little, or
when you dispense out of them, it\'s actually eating itself. Because you
get dripage. It\'s a plastic cube container with sulfuric in it. This
that leaks out, it could cause ‑‑ it could actually eat the nearby
combustible liquid or flammable liquid and cause maybe spontaneous
combustion. Let\'s go back live for a second, mark. Some other things in
here that you should be looking at, whenever you see typing on a label,
it\'s probably telling you you\'ve got a really old GSA or mil spec
product. This is a mill spec cement for grinding disk, actually made in
April of 1996. Are you doing any fancy woodworking operations or metal
grinding that you need to be gluing disks ‑‑

B. Sykes: As long as I have been here, we have never used this. Probably
needs to ‑‑ we probably need to get rid of it.

K. Morin: What we will give you is a finding for excess hazard material
and this will be one of the items on it. Another item that\'s an issue
‑‑ this one is actually stuck to the cabinet s I notice you have just ‑‑
you have a two‑part paint here, two‑part epoxy and all I see is the part
A, so you couldn\'t use it if you wanted to. So put this on your excess
HazMat list. Down below here, whenever I\'m doing an odd and it I see a
five gallon container like this one, it keys a whole bunch of questions.
Because ‑‑ anything above a gal sun something that we typically don\'t
use. Or we don\'t use very often and don\'t need. This particular
product is one of those Dupont automotive paint products I was talking
about before. It\'s clearly labeled that it\'s for industrial use only
by trained professionals and that you need to wear a respirator. Do you
have a respirator?

B. Sykes: Not that I know of.

K. Morin: Even if you wanted to use this product, because of the beard,
the OSHA regs prohibit you from wearing one. You have to be clean Shea
convenient to wear a respirator. So, with your ok, I will put in theth
on the excess HazMat list as well.

B. Sykes: Good.

K. Morin: Now, let\'s look at your fuel storage. We\'ve got this plastic
container, and this yellow container. Let\'s freeze on this, mark, on
these two containers when you get them in here. Push‑to‑talk viewers, is
a plastic container acceptable for storage of flammable combustible
liquids?

Caller: No.

K. Morin: No, it\'s not. Thank you. You had a 50‑50 chance. You know why
it\'s not? You\'re correct.

Caller: Because they can crack and the liquid would leak out?

K. Morin: Yeah. OSHA specifically ‑‑ OSHA does allow you to use plastic
under certain circumstances, but they will only allow it if you have
automatic fire detection and suppression and you have secondary
containment for all the liquid that\'s stored in plastic. That secondary
containment has to be large enough to contain all the firefightering
watt irthat would be used. The reason they don\'t like plastic is
because the containers don\'t vent and when it\'s involved in a fire, it
will melt, it will spread the fire and the melting plastic also gives
off toxic fumes. Let\'s go back live. You can\'t use plastic. It has to
be a metal container. And this is the container that we recommend. This
is ‑‑ it\'s a D.O.T. safety can and it\'s also fully compliant with
D.O.T. regs. This U.N. number means it made in accordance with the
D.O.T. performance oriented packaging regulations, means it\'s legal for
transport on public highways. It\'s painted yellow because this has
diesel fuel in it. The rest one down bee slow for gasoline. OSHA wants
you to distinguish between a combustible and flammable liquid. This is
the type of container you need to be buying. They cost around \$95. Much
more expensive than the plastic one, but unfortunately I got to tell you
to get rid of that one.

B. Sykes: We\'ll do.

K. Morin: Let\'s close this cabinet.

Caller: Ken, before you close that cabinet, I have a further question
for you.

K. Morin: Shoot, Ron.

Caller: Let\'s look at the top shelf, right‑hand side. Are those propane
containers and could you discuss that?

K. Morin: Actually, ideally and that\'s a good question, Ron, ideally
you want to be storing propane outside, because if the cylinder leaks
you don\'t want to contain it in the cabinet, but there isn\'t a reg
that prohibits you from storing these small containers inside. The
larger container, the 20‑pound containers, anything from ‑‑ like for a
barbecue grill, up to 40 pounds, those propane containers are subject to
D.O.T. regs and they have to be hydrostatically tested 12 years from the
original date of manufacture and they also have to have what\'s called
an O.P.D., or an overfill protection device and you can tell whether
your cylinder has that because it will have a triangular valve on it. If
it has the traditional valve, next time you go to refill it, assuming
you\'re not at a self‑filling station, the owner of the propane company
will make you do a retrofit or buy a new tank. Did I answer your
question, Ron?

Caller: Yep.

K. Morin: Yep.

Caller: This is mark. Can you hear me?

K. Morin: Go ahead.

Caller: Up on the top on the right‑hand side there is that two‑inch bone
plug. When do those need to be vented outside.

K. Morin: Excellent question. If you are going to vent it, you have to
do it in accordance with NFPA, and it needs to be vented outside and has
to have a fire damper it in, in other words, a fusible link. So if there
is a fire outside, the fire damper will close and the fire can\'t get
into your cabinet. They do not have to be vented at all and what I
routinely find in the field is that the bung is missing and it\'s not
missing from it\'s, it\'s actually on the other side. But if you have a
cabinet and you haven\'t properly vented it, then those bungs have to be
in place. But there\'s no requirement that it has to be vented. Benting
is only required when you\'re dispensing inside a building. If you\'re
just storing stuff in a cabinet, venting isn\'t required. Did that
answer your question, mark?

Caller: Yes, it did. Now let me ask you another one, on transporting
D.O.T., propane and oxygen bottles together, what\'s regs on that?

K. Morin: There\'s a three‑day course that will address that. You know,
I can\'t give you a simple answer on that, Mark. I would actually have
to look it up to make sure I was correct and I don\'t want to give you
the answer off the top of my head. I apologize for not knowing the
answer.

Caller: That\'s fine. Tell me, can you transport the bottles laying
down?

K. Morin: There\'s no reason that I can think of that you can\'t.
What\'s your concern associated with it?

Caller: Just to do things proper. I know they want the caps ‑‑
regulators off the caps, whatever you call that, protective cap on, and
chained down if they are standing up. I didn\'t know if you could
transport them down or not. Just ‑‑ what\'s right. That\'s all I\'m
asking.

K. Morin: Ok. One other thing I want to point out cabinet is that this
cabinet has a self‑closing doors. I\'ll just let them go opinion whoops.
It worked right in the rehearsal. But self‑closing. Those are required
not by OSHA but by the uniform fire code. If you\'re in a state west of
the Mississippi, most western states are uniform fire code states and
this is a feature you have to have on your flammable storage cabinet. It
increases the price your cabinet about \$250. But it is a feature
required by the code. So let\'s see what you\'ve got ‑‑ let\'s see what
you have over your work bench here. I\'m not worried about glass cleaner
or superglue or this all‑purpose ‑‑ hey, you have a green cleaner.
That\'s great. I\'m curious, though, what ‑‑ this is obviously not
purified water. So ‑‑

B. Sykes: I\'m not sure what\'s in that. The workers that were in here
before, I don\'t remember seeing that, so I\'m not really sure what\'s
in that container.

K. Morin: Ok. Now, under the hazardous waste regulations, you\'re
required to do a waste determination on all of your products that you
potentially want to get rid of. This is actually a ‑‑ if this is a
usable product, then you are in violation of the HazCom regulations
because this isn\'t labeled properly. Is this antifreeze? Is it some
sort of lubricating oil? You don\'t know. If you were ‑‑ maybe it\'s a
mild acid. But if you were to get this into your eyes or something, Bob,
you wouldn\'t know what to do. That\'s why it\'s important to clearly
label stuff so if that you are exposed to it somehow, we can go to the
MSDS and get you the right treatment.

B. Sykes: I agree. Let me take a look at your tools here for a second. I
see this grinder you have. This looks like something that\'s gotten an
awful lot of use.

B. Sykes: It has. We\'ve had it for as far as I know quite a long time.

K. Morin: Let\'s do a quick freeze on this thing and see if we can get
the push‑to‑talk people. What\'s the primary hazard I\'m showing in
this?

Caller: No blade guard.

K. Morin: Exactly. This is supposed to have a half moon guard. The
Bureau safety program manager was a former OSHA compliance officer. He
investigated a fatality ‑‑ let\'s go live. Any investigated a fatality
where the grinder got kicked back at the operator and literally slit the
person in half. It needs to have a half moon guard that will cover from
here to here so it can\'t kick back and hurt you. Some other electrical
issues. At this strain relief, it\'s actually separated and as a result
we are now exposing the conductor. Which is a real problem because you
are operating it down here. If you have a bigger hand than mine, you
could potentially short yourself. Also I can tell you\'ve have to use
this ‑‑ it is ‑‑ you had to use it in a place where you didn\'t have a
three‑prong outlet or receptacle.

B. Sykes: Right.

K. Morin: Looks like you pulled out the grounding pin.

B. Sykes: We did.

K. Morin: So now this isn\'t fully grounded and isn\'t safe to use that
pit it needs to be thrown in the trash. Any questions on this tool?
Anybody on push‑to‑talk? Let\'s look at what you have on your shelves.
All right. These dewalt cordless drill and you have look likes another
cordless screwdriver, et cetera, could we freeze on this? Viewers,
what\'s issue ‑‑ what potential environmental issue do I have with this
drill? Or with cell phone batteries or laptop batteries. Do I have ‑‑

Caller: You have the nicad battery disposal problem.

K. Morin: Exactly. Very good. Nicad batteries are a hazardous waste.
There\'s actually a free recycling program in the country. Let\'s go
live again. There\'s a free recycling program that is run by the
recyclable bat ‑‑ I don\'t remember. Call 1‑800‑battery. You get a
recording and push in your zip code. It will tell you where they will
accept nicad batteries, cell phone batteries, the lithium batteries,
small sealed lead acid batteries so that way you don\'t have to pay for
the disposal costs.

B. Sykes: Good. Let me just show everybody real quick. Here you do have
a grinder with the guard on it, so everybody can see what one should
look like. This is obviously a much smaller one, but this is what was
missing off the other piece of equipment. Let\'s see what we\'ve got on
the other side of these shelves. Looks like you\'ve had a spill here,
Bob. What is your ‑‑ you haven\'t been in here in a while, have you?

B. Sykes: No, I haven\'t.

K. Morin: Because it\'s dried up. What would be your procedures if you
have a spill like this? Do you have a spill plan at all?

B. Sykes: Yes, we do, and we have a spill kit that\'s in the warehouse
that we could use to at least contain the spill.

K. Morin: Now, one of the issues that I routinely bring up to people
when they have herbicides and you\'ve got actually ‑‑ you\'ve got
arsenal, roundup, some spike. The only one you don\'t have that I see a
lot is Tordon. You should have as a best management practice the spill
kit here. Out in the warehouse doesn\'t do us any good. And what I\'m
concerned about is that if ‑‑ if there is a leak, I don\'t want it
running into other equipment or people walking through it, et cetera.
You want to be able to respond to it immediately. The other thing is
you\'ve got enough herbicide here that it could potentially be an issue.
If I see one two‑and‑a‑half gallon container of herbicide, I\'m not
really worried bit. But you\'ve got now at least 10 gallons, and there
‑‑ looks like there maybe some stored more behind it. You have come to a
threshold where you want to do some consulting with your emergency
response people, whether it be fire or police, because they would want
‑‑ they may want to know at this volume if they go to fight a fire here
that this stuff is in here so they\'re wearing the right protective
equipment. Let\'s freeze on this for a second. Push‑to‑talk viewers,
what would ‑‑ what would you have to do ‑‑ let\'s say I have 10 or 20
cases of this stuff in this shop? What would things should you be doing
to this building to alert emergency response personnel?

Caller: Label it from the outside.

K. Morin: Right, it\'s got to be labeled \"danger pesticides.\" Anything
else?

Caller: Flammable if it is flammable.

K. Morin: Ok. Let\'s go live again, please. The other thing that the
emergency response personnel are going to want is an inventory with what
the chemical is and how many gallons of it, because like Tordon, it\'s
very corrosive, and they\'re more concerned about that. It\'s a
restricted use herbicide than they are, say, roundup, as an example. And
it will alert them to what protective measures they may want to take. So
you want to post an inventory and also that sign out there. Let\'s see
what else we have back here. All right. You\'ve got some concrete mix.
We\'ve got ‑‑ super rust deoxidizer ‑‑ when is the last time this thing
even saw the light of day?

B. Sykes: I really have no idea.

K. Morin: We\'ll add that to the excess HazMat list. This is actually
Foss Furyk acid and it is used for concrete etch, and we routinely find
this, but we typically find that no one is using it. This will be
relatively expensive to get rid of. Corrosives are much more expensive
to dispose of an a flammable liquid, but it brings to mind a question
that do you have an MSDS for the concrete mix?

B. Sykes: I believe we do. It should be hanging on the board over here.

K. Morin: Let\'s see what you\'ve got. All right. Well, I\'m pleased to
know that you even know what an MSDS is, but have you received ‑‑ when I
was talking about the unknown, here\'s the MSDS you have for a pipe
sealant, and hopefully the concrete mix is in here. But if you were to
spill the pipe sealant on you, what would you do?

B. Sykes: I\'d look at the MSDS and look at what kind of measures I
would need to take to\...

K. Morin: What if you got it in your eyes?

B. Sykes: There should be some directions on the MSDS on what to do.

K. Morin: It\'s going to be tough to read when nights your eyes. The
point I\'m making is there are several things you have to have in your
HazCom program. Not only do you have to have MSDSs, but the employeers
supposed to be trained with what\'s the hazard associated with their
use. That doesn\'t mean if you have 15 different kind of flammable
paints, you ever to go through 15 different MSDSs, but you have to do it
by hazard type, by flammable, corrosives, skin irritants, by inhalation
hazards. Your employees are supposed to know what happens if they become
exposed to it and what are the symptoms of overexposure. In other words,
are you getting a headache because this pipe sealant is causing it? Or
is it because you, you know, were out partying with me too long the
night before. Ok? I think that wraps it up.

B. Sykes: I do have a question, though. On the transporting of a
compressed cylinders in a vehicle, can you tell me what needs to be done
with that?

K. Morin: Well, we did have another caller who talked about that. They
do need to be stored with the valve caps on them if the tank or the
cylinder is fabricated to accept a valve cap that the. The two smaller
ones you had are not. They also need to be secured. Whether they have to
be secured upright or not, I honestly can\'t answer that question. Other
than acetone, which I know has to be. I haven\'t seen anything else in
the D.O.T. regs that says they have to be upright. But I don\'t know for
certain. I do have one more question for you, though. I noticed in your
cabinet, let\'s look at your cabinet, because that bucket reminded me of
something. I saw a bucket over there, and it looked like it had some
liquid in it. What I want to know from you, Bob, is ‑‑ this is a
question you should be asking when you are doing your audits and when
I\'m doing an environmental audit, I refer to myself as Colombo a lot,
because I walk past something and then something else will key another
question. What I\'m interested in, what do you do with your spent
lacquer thinner?

What we do and even some used oil is that we do pour it in the bucket,
and then certain times we\'ll go out, when weather permits, and put it
on a slash fight and ignite the slash pile.

K. Morin: Let\'s do a little pushed on that. ‑‑ push‑to‑talk \'that.
Does anybody out there have suggestions on what\'s a good management
technique for used oil and paint thinner? How should we be managing that
properly? In other words, is it acceptable to mix the two and use it
kind of like drip torch fuel? I know I\'m challenging a little bit here.
Let\'s say we don\'t even mix it. We just have used oil. Can we dump
that on a slash pile?

Caller: No, doesn\'t it have to be recycled?

K. Morin: You\'re right. If used oil is recycled, if you burn it, you
need a variety of permits. The only reason you threw on it a slash pile
is to dispose of it. Do you use the lacquer thin, one thing I suggest
you do is, you can use it 50 or 60 times. Put it back in the container
and reuse it. But with that, I\'m going to throw it back to Martin.

M. Thrasher: All right, thanks, Ken and Bob. As you can see these audits
tend to be really thorough, and the auditors need to do that so they get
a pretty good picture of what you\'re doing at your various facilities.
I don\'t know, Ken, how do you think Bob did there? I think Ken gotten
plugged. Anyway, what I would like to do is see if you had any questions
or comments about what you saw in this audit process. Was it what you
expected, more thorough than you expected, not as thorough? What were
your thoughts about it?

Caller: Stephanie Nash, Fish & Wildlife, I thought it was very thorough,
and it was a good piece for us to see how an actual audit is done, and
he was very, very thorough.

M. Thrasher: Yeah. Quite frankly, I have been involved in audits in a
lot of different places, hadn\'t particularly seen this type thing here,
but they\'re all pretty much the same, fairly thorough. They tend to be
a little intimidating, but the nice thing is they come back later with a
written finding and recommendations and then you can actually see in
print. So it\'s not all just so intimidating. Good deal. Any other
thoughts about the scene you saw there? Frank, did you have any thoughts
as you observed what was going on? Is that typical of when we\'re seeing
in the Forest Service?

F. Mills: It\'s very typical of an audit we conduct. One thing I would
like to mention is we often bring out subject matter experts to assist
in audits. For instance, let\'s say that we\'re auditing a forest that
has a large CERCLA program where they are doing a lot of abandoned mine
cleanup. Then we will include on our audit team a CERCLA specialist to
look at that program and see if they are meeting the requirements of the
environmental regulations. Another area that we typically involve a
subject matter expert is in the water area, where, f let\'s say that our
forest has a large municipal type water treatment plant, then we will
bring someone in who is familiar with those kind of operations to audit
that facility specifically and help them see if there\'s problems in
that area. The auditors tend to be generalists and they tend to know a
lot of things, but it\'s not uncommon for a team to include certain
specialists type people with the audit team to help out safety ‑‑ safety
is another area where we often include a specialist to look at certain
things.

M. Thrasher: I think that\'s a good point. I know we struggled with how
many people to take on an audit, because when we brought an entourage of
people it was very intimidating. Yet we wanted to have the right people
there because, as you say, a lot of us are kind of generalists, we can
discuss a lot of things, but when you have particular highlighted areas,
you need to get that specialist in there.

F. Mills: Right. And I would encourage the managers out in the field,
when the audit team is there, usually a typical Todd it takes about a
week to do. So the team is in about your facilities throughout that
week, you should have routine meetings with the audit team leader
throughout the week, at least three or four times, to see ‑‑ get a one
on one perspective about the team is seeing, and ask them every day, did
you see anything that I need to know about? Are there issues that really
are very, very important to me as the manager of this facility? I think
that\'s important for the people to have a dialogue with the audit team
leader so that there\'s really a one on one relationship between the
manager and audit team leader about what\'s happening out there.

K. Morin: One of the things we have done at BLM because there is a lot
of fear that this is a witch hunt. I have suggested to Field Managers to
send their staff, their safety or HazMat person, send them to an audit
we are doing in the area and you can see what we\'re doing is very well
received out in the field. Most of the time when you\'re out in that
remote fire station, the person out there has got an inkling that maybe
things aren\'t just right and they are looking for the help and that\'s
been very, very successful in letting the audit program grow.

F. Mills: Martin, we\'ve actually timed our auditors and follow them and
see how much time they spend doing certain things? We found out the
auditors actually spend half of their time with the personnel training
the personnel in the field, not even auditing, but just teaching them
about different things as they go along. It\'s not uncommon for us to
sit down with a group of personnel, for instance, in a fire station, and
spend an hour‑and‑a‑half just talking about containers and
transportation and things like that. And the field really liked that one
on one contact.

M. Thrasher: Good opportunity for that. I think with that we pretty well
summarized the audit that we\'ve gone through here and Tony, I\'ll giver
it to you to see if we have any more questions.

T. Garrett: We will pause and remind our viewers that the green light is
on and we\'re coming up on the final minutes of Module 6. So we
certainly want to take time to answer any questions that you have about
any of the material covered in any of the six modules, particularly the
material we\'ve just covered with this audit exercise. Please go ahead
and pushed if you have a question or a comment for us from any of our
downlink sites.

Caller: Tony, is it proper to leave a WD40 can on the bench day and
night?

K. Morin: I can address that. The answer is as it is with most
compliance questions is it depends. If it\'s an office occupancy, no.
What OSHA says is that all containers of flammable combustible liquids
have to be kept in flammable storage cabinets. I saw 10 or 12 cans of
WD40 scattered through it. The chairs were squeaky. They didn\'t have
individual offices or dividers. So they had the WD40 to keep chairs from
squeaking, but if it\'s like in a shop area completely detached, you can
up to 120 gallons of flammable combustible liquids out on a shelf not in
a flammable storage cabinet. What we recommend, though, is you still put
it in a flammable storage cabinet. When something goes bad in your
refrigerator, you can tell. It turns into a science project and you
handle it properly. If you have your hazardous materials in your shop,
scattered all over the north 40, they wind up getting covered one tarps,
plastic, tools, whatever, and they\'re out sight, out of mind and you
forget about them. So having the cabinet is not a good idea. If you are
over 120 gallons, you do have to have a flammable storage cabinet. The
120 only refers to 1B through class 3 liquids. A 1A liquid is ether and
the volume for is that only 25 gallons. Hopefully I answered your
question. Did I?

Caller: Yes. How about that welding machine, did it have any
ventilation?

K. Morin: Good question. You only have to have ventilation if you are
welding galvanized and stainless inside if that you\'re welding
galvanized outside, you don\'t have to have it at all. You also have to
have ventilation if the cubic footage in that shop is less than, I
think, 16,000 cubic feet. I could look it up and tell you later, but
ventilation is not always required. If you\'re just doing plain Steele,
in general it\'s not required.

T. Garrett: Thanks for that question. Any other questions from any of
our viewers at any of the downlink sites? Steele. If not, we want to
thank you for that interaction with our instructors and at this point we
will return to Martin has a wrap‑up of the entire Manager\'s Tool Kit
series.

M. Thrasher: I was asked to give a summary of all of these six modules
that we\'ve gone through, and obviously we\'ve covered a great deal of
material and it\'s tempting to go back and just do a summary of all the
details and so forth. But I thought it might be more fun and instructive
from a management point of view to put together kind of a top 10 list of
things that we think that you ought to get out of this program. So here
is Martin\'s top 10 HazMat list from this course. We\'re going to go in
reverse order here starting with number 10. And number 10 is managers
are subject to personal liability for failure to comply with
environmental laws. We don\'t like ‑‑ want people to feel threatened,
but we want you to know there is personal and civil and organization
liability if you fail to comply. Number 9 item was, compliance with air
quality regulations requires more than just \"smoke management.\"
Remember that Federal agencies are required to do compliance reviews
with state implementation plans and that there are National Ambient Air
Quality Standards that far exceed just smoke issues, although those are
important. And the next 8 item is minimizing the use and disposal of
hazardous materials is fundamental to reducing liability. The less you
have, the less you use, the less toxic you use, the better off you\'re
going to be. And the number 7 of the top 10, Federal land management
agencies are required to comply with OSHA, including development of a
written hazard communications plan. So even though you\'re not
mandatorily under OSHA according to Congress, there\'s a presidential
Executive Order that says you\'re going to comply and you need that
written plan. And the number 6 of the top 10, liability for superfund
cleanup costs is without fault, but implementation of proper management
techniques reduces exposure. Remember, every time that you have to
dispose of a hazardous waste or a hazardous substance, it doesn\'t die
there. It lives on and fit has to be cleaned up, you may be part of the
cleanup process and pay for part of the cost. Number 5 on the top 10
list, Federal land managers must collaborate with other Federal, state
and local officials in environmental planning. You can no longer sit
back as Federal officials and just do your own planning without
consideration and collaboration with other government agencies. Number 4
on the top 10 list, a hazardous material may be exempt or not regulated
under one law and may be regulated under other laws. It\'s a common
misconception that if something\'s exempt that it\'s exempt from
everything. Nothing could be farther from the truth. Now we get up to
the top three and number three is employee training is fundamental to
compliance. Remember, you cannot accidentally be in compliance with all
of these rules. They\'re not intuitive. You have to have training in
place. And number 2 in the top 10 list, effective management of
hazardous materials and compliance with environmental laws requires
development of written systems such as plans, procedures and policies.
You cannot do this by word of mouth. You have to have a concerted
management system in place. And the number 1 thing that I think that you
need to get out of this course is Federal land management agencies, and
managers, are required to comply with environmental laws, including in
many cases, state and environmental laws. It\'s been a common
misconception appear lot of these environmental hazardous materials laws
were built for industry and didn\'t apply to the Federal government
agencies, and, of course, that is not the case. Another common
misconception is that Federal agencies don\'t have to comply with the
state laws and in many cases sovereign immunity has been given up by the
Federal government. So you must comply with the state and local laws.
So, Tony, with that, that\'s kind of ‑‑ kind of summarizes the course
from high point of ‑‑ my point of view.

T. Garrett: Excellent summary of the top 10, and 10 of many of the
important elements of this instruction we presented over the past few
weeks. Now, nearing the end of our Brad cast we want to give our
instructors an opportunity to share any final thoughts they would like
to present to the audience and, Ken, let\'s begin with you.

K. Morin: What I would like to tell the audience is that the reason why
I have a job is to support you. If you have a question, give us a call.
That\'s what Frank and I do. Our staffs, we talk to each other all the
time and we\'re also talking to other people out in the field. If
you\'ve got a problem, we\'ve probably already done that, been there,
solved it someplace else. So get ahold of us.

T. Garrett: Frank Mills from the Forest Service?

F. Mills: I would just like to say that any of you out there who would
like to go with us on an audit, you\'re welcome to come along. The
invitation is open. We conduct about 10 to 15 audits a year, and we
always have room for somebody to come and learn. If you need to get in
touch with us, you have Tony\'s e‑mail. Just e‑mail him and we\'ll send
you an audit schedule and we encourage managers at any level, if you
want to get out and participate and see it from someone else\'s
perspective, please call us and make yourself available and we\'ll
certainly put you to work out there helping the team.

T. Garrett: Thanks very much. Martin any final thoughts for our viewers.

M. Thrasher: I just want to make sure to leave you with the thought that
environmental management is doable. Make sure to access your experts,
your HazMat coordinators and Ken and Frank and others that are involved
with this business, and then I want to thank you for your participation
and the opportunity to participate in this program. Thank you, Tony.

T. Garrett: That will complete Module 6 in the Manager\'s Tool Kit on
Environmental Compliance and Pollution Prevention. We hope this series
has been beneficial in giving you some ideas about how to better manage
the HazMat program in your agencies and at your facility. Please
remember to complete the online course evaluation, which can be found at
the Manager\'s Tool Kit website on the BLM National Training Center\'s
homepage at www.ntc.blm.goV. That would be helpful us to. Let us know
how many of you were with us today. Please sign the roster in your
viewing room and fax that to us. And remember the primary source of
information about this course, study materials and resources will be
found on your agency\'s websites. once again, we would like to thank
Martin Thrasher, Frank Mills, Ken Morin and all the other instructors
and staff from the USDA Forest Service and the Bureau of Land Management
who made this series possible. On behalf of the Forest Service and BLM,
thanks for watching, and so long from Phoenix.

Announcer: This broadcast has been a presentation of the USDA Forest
Service office of corporate training and the BLM National Training
Center.