Environmental, Health and Safety Compliance Programs

Program

Description

Asbestos Management

Asbestos containing materials have been located and mapped. Whenever a task that might disturb asbestos is planned, the extent of the asbestos material is verified by inspection from a New York State Department of Labor certified inspector. The asbestos is then removed and disposed of properly, as per all pertinent rules and regulations by certified asbestos removal companies.

Blood Borne Pathogens

For Security and janitorial personnel. Annual refresher training in what blood borne pathogens are and Sabin’s Exposure Control Program are provided.

Cadmium Health and Hygiene

Exposures to cadmium are measured. Employees who are exposed to measureable amounts of cadmium are provided annual training in the health effects of cadmium and ways to protect themselves from cadmium. Physicals are provided annually for Pollution Control – Maintenance employees.

Carbon Monoxide Monitoring and Alarm Response

New York State requires that spaces that are heated with fuel to be continuously monitored for carbon monoxide. If a monitor alarm sounds, Sabin plans to respond by evacuating the area, measuring the carbon monoxide levels, locating sources, shutting them off and ventilating.

Confined Space Entry

Program for safety in entering confined spaces. Permits are written and used for every permit required confined space. Air is monitored prior to confined space entry, as part of the permit generation process. Safety equipment is obtained and used that make confined space entry safe.

Contractor Training

All contractors that are to work on-site are provided training in hazard communication, emergency response, Site Security Plan and any other training needed for their particular work.

Emergency Response

Training regarding evacuation procedures is provided. Sabin performed impact analyses to predict the outcome of foreseeable chemical accident scenarios so that plans for dealing with emergencies could be developed.

Emission Monitoring

Sabin collects information and estimates its monthly emissions on an ongoing basis in order to demonstrate and document that it is a minor source relative to air emission regulations.

Fall Protection and Ladder Safety

Training is provided in the proper inspection and use of ladders and fall arrest systems.

Fire Extinguisher

Annual refresher training in fire extinguisher used is required for those working in the Hot Work Safety program.

Forklift Safety

A training and certification program cycled every three years to see that employees are aware of proper forklift operating procedures. They are also evaluated for being able to operate forklifts safely.

Hazard Communication

Given before an employee works in a department where there are potential exposures to chemical hazards. Material specific hazard communication training is given when customer material of unusual hazards are received or new process chemicals are introduced.

Hazardous Material Management

New chemicals are reviewed for hazards, classified as per Fire Code and a management program is developed for them to ensure compliance with Fire Code and other environmental, health and safety requirements.

Hazardous Waste

Anyone who has duties that have to do with hazardous waste management needs to have annual training in their tasks dealing with hazardous waste to ensure compliance with existing Federal and state hazardous waste rules.

Hearing Conservation

Noise levels are monitored. Employees are classified according to noise levels to which they are exposed. Those exposed to noise over 85 dB eight hour time weighted average get annual training and hearing tests. Hearing protection is provided, where required or requested.

Hexavalent Chromium

Exposures to hexavalent chromium are measured. Welders who cut up stainless steel equipment used to make nitric acid or who make stainless steel pans used in our thermal reduction processes are included in this program. This entails yearly refresher training and physicals performed at Strong Memorial Occupational Medicine.

Hot Work Safety

Anyone who welds, torch cuts or otherwise uses a flame generating device must have training in this. Permits are required to use flame or spark generating devices.

Lead Health and Hygiene

Exposures to lead are measured. Employees who are exposed to lead over the Action Level are provided annual training in lead health and hygiene. Strong Occupational Medicine technicians are brought on-site for blood-lead sampling.

Lock Out/Tag Out

Employees are trained in recognizing hazardous energy and procedures for controlling and locking out hazardous energy. Methods of controlling energy sources for equipment installed and used by Sabin are documented when more than one energy source is evident.

National Emission Standard for Hazardous Pollutants – Non-ferrous Metal

This is an environmental law meant to ensure that the pollution control devices used to control emissions from smelting secondary copper are maintained. Weekly ductwork inspections are performed to see that there are no uncontrolled leaks of air contaminants from them and yearly comprehensive baghouse inspections are done. A certification process was required where the emission from the affected devices was measured to determine that they emit less pollution than the Federal standard allows. Both of the pollution control devices subject to this rule were found to operate well below the Federal standards.

Odor Prevention and Response

Sabin has a Best Management Practice Plan for dealing with odor generating processes. Every year, employees are trained in how to prevent odor incidents and how to respond to and document odor complaints.

Operational Flexibility Review

Sabin is allowed to install processes that do not cause it to exceed regulatory limits that would make it become a major source of pollutants or cause it to contravene air regulations. Whenever a process is proposed for installation, the Environmental Engineer reviews the process and, when found to be allowed under Operational Flexibility rules, the findings are documented and the process is installed. This frequently requires air emission studies and impact analyses.

Personal Protective Equipment

Sabin determines the appropriate protective equipment for all work activities taking place on-site and provides them, free of charge, to its employees. These include, but are not limited to, safety boots, safety glasses, hardhats, gloves and chemical protective suits.

Regulatory Management

Federal Registers are reviewed for regulations that may pertain to Sabin. When such regulations are found, compliance plans are developed.

Respiratory Protection

Employees who need to use respirators are given medical evaluations to determine that they are healthy enough to wear respirators. They are then fit tested to determine the size and style that best fits them. Annual training is provided in the proper use of respirators.

Site Security Plan

Sabin is a Department of Homeland Security Tier III facility. It has to maintain a Site Security Plan, update it annually and see that employees get required annual training in the procedures outlined in that plan.

Spill Prevention (CBS)

Sabin uses what have been determined as hazardous chemicals under Section 304 of Emergency Planning and Community Right-to-Know Act rules. It also operates a Chemical Bulk Storage tank as part of its Process Water Recovery system. This program requires training in how to handle spills of the listed hazardous substances for employees working in the Process Water Recovery operation.

Spill Prevention, Control and Countermeasures (SPCC)

This is a program for facilities that have bulk petroleum storage tanks. Although Sabin closed its fuel oil storage tank system in October of 2015, it maintains an SPCC plan for its 500 gallon tanks of diesel fuel and gasoline. This plan outlines how employees will prevent spills of petroleum products and what they will do in the event of a spill. It requires notifications of spills and proper clean-up.

Storm Water Pollution Prevention

Employees receive training in methods to prevent storm water pollution and response to outdoor spills. Inspections and storm water sampling is done quarterly to ensure that the storm water being discharged is meeting State requirements and to see that the Storm Water Pollution Prevention Plan is being properly implemented. A comprehensive storm water inspection is done yearly to certify that the program is achieving its goals.

Universal Waste Management

Sabin recycles its Universal Wastes such as spent fluorescent bulbs, mercury switches, batteries and used oil. Training is provided on the specific rules attending Universal Waste storage, labeling and packaging, as well as mercury spill clean-up.