Working with Hazardous Materials
Forklift operators transport hazardous materials daily. Forklifts are used in chemical manufacturing plants as well as other hazardous locations. Accidents and spills occur. Workers need to be aware of these hazards and how to avoid exposures. All employers with hazardous chemicals in their workplaces must prepare and implement a written hazard communication program, and ensure that all containers are labeled, employees are provided access to Material Safety Data Sheets (MSDSs), and an effective training program is conducted for all potentially exposed employees. They must also ensure that only properly authorized powered industrial trucks enter hazardous locations and that these locations are posted.
Department of Transportation (DOT)
DOT Hazardous materials regulations are subdivided by function into four basic areas:
- Procedures and/or Policies (49 CFR Parts 101, 106, and 107)
- Material Designations (49 CFR Part 172)
- Packaging Requirements (49 CFR Parts 173, 178, 179, and 180)
- Operational Rules (49 CFR Parts 171, 173, 174, 175, 176, and 177)
OSHA's HAZWOPER Standard
OSHA's HAZWOPER standard, 29 CFR 1910.120, covers emergency response personnel who respond to the incident. If the operator of the vehicle becomes actively involved in an emergency response, then he/she is considered an emergency responder and is covered by 29 CFR 1910.120(q).
Several agencies have overlapping authorities for regulating shipments of radioactive materials. DOT regulates the shipment of hazardous materials, including radioactive materials. The Nuclear Regulatory Commission (NRC) regulates commercial activities at nuclear power plants. The Department of Energy (DOE) ships commercial radioactive waste for storage and defense nuclear waste and weapons for storage or use. DOE and the Environmental Protection Agency (EPA) share responsibility for transportation of hazardous waste or radioactive and hazardous-waste mixtures generated at facilities operated by DOE under the authority of the Atomic Energy Agency (AEA).
The following is an overview of the major laws enacted, regulations, training requirements, and other resources:
General Industry (29 CFR 1910)
- 1910.120, Hazardous waste operations and emergency response [related topic page]
- 1910.134, Respiratory protection [related topic page]
- 1910.178, Powered industrial trucks. Incorporates by reference a number of other OSHA and industry Standards:
- 1910.1000, Air contaminants
- 1910.1201, Retention of DOT markings, placards and labels
Shipyard Employment (29 CFR 1915)
- 1915 Subpart Z, Toxic and hazardous substances
Construction Industry (29 CFR 1926)
- 1926 Subpart Z, Toxic and hazardous substances
- Disparity Between 29 CFR 1910.178(c)(2)(vii) and Table N-1, 29 CFR 1910.178(c)(2). STD 01-11-006 (STD 1-11.6A), (February 19, 1979).
Letters of Interpretation
- What type of powered industrial truck can be used in an aluminum powder production building where dust levels may be in an explosive concentration. (June 16, 1995). Provides guidance on OSHA's acceptance of the type of trucks listed and approved in later versions of NFPA No. 505, Summary Tables on Use of Powered Industrial Trucks.
- Clarification of the use of powered industrial trucks in Class I, Division 2, Group C locations. (May 24, 1995). Clarifies the use of powered industrial trucks in hazardous locations.
- Use of a powered industrial truck to dump hexamine into a hopper of a bucket elevator. (June 3, 1993). Provides guidance on the use of a powered industrial truck, not approved for use in atmospheres that can contain combustible dusts, in an operation where a cloud of combustible dust could be created.
- Definition of the phrase "Adequate ventilation" as used in 1910.178. (January 26, 1976). Indicates a "typical exhaust fan" could meet this requirement if the concentrations of the hydrogen gas in the fan's ambient air never exceeded the lower explosive limit.
EPA, OSHA, and DOT each have separate training rules, but there is often overlap among the various requirements. OSHA's goal is to reduce worker injury and illness. DOT requires all employees who handle or transport hazardous materials to receive general awareness, function-specific, and safety training. EPA training focuses on eliminating the release of pollutants and wastes, both on and off site.
The following are OSHA's major training statutes related to the shipping of hazardous materials:
- 1910.38, Emergency action plans. OSHA Standard. The training requirements of 1910.38(e) cover the designation and training of employees to assist in a safe and orderly evacuation of other employees.
- 1910.178, Powered industrial trucks. OSHA Standard. Includes specific training requirements for the use of forklifts in hazardous locations.
- 1910.120, Hazardous waste operations and emergency response. OSHA Standard. The training requirements of 1910.120(e) covers the requirements for different worker populations, and determining if a release is covered by the standard.
- 1910.134, Respiratory protection. OSHA Standard. The training requirements of 1910.134(k) cover respiratory hazards, type of respirators, respirator selection, fitting and maintenance, medical surveillance, and respirator training and administration.
- 1910.145, Specifications for accident prevention signs and tags. OSHA Standard. Includes specific training requirements for the identification of signs and tags, hazard determination, and precautions to take for personal protection as indicated by signs.
- 1910.157, Portable fire extinguishers. OSHA Standard.
- 1910.165, Employee alarm systems. OSHA Standard. The training requirements of 1910.165(b)(4) covers how to explain to employees the preferred means of reporting emergencies.
- 1910.1200, Hazard communication. OSHA Standard.
- 1910.1201, Retention of DOT markings, placards and labels. OSHA Standard.
General Hazard References
- Evacuation Plans and Procedures. OSHA eTool. Assists small, low-hazard service or retail businesses to implement an emergency action plan and to comply with OSHA's emergency standards.
- For additional information, see OSHA's Safety and Health Topics Pages on: