Paying attention to storage areas is vital to the effective management of your facility when it comes to environmental, health and safety. The fact is that these areas are typically ground zero for EH&S issues…including those that, left unattended, can result in material releases requiring lengthy and costly remediation.
This goes for both interior and exterior storage areas. And in the case of an accidental release, it’s not only your property/facility you have to worry about. Because without proper storage and containment, a release can spread quickly… even onto neighboring properties.
In the past, I’ve written about the best practices for storing materials inside your facility. Now, I’d like to focus on everything you store on the outside.
The great news is that many of the guidelines for proper and safe storage that minimizes EH&S issues are the same for interior and exterior storage and encompass all stored materials, whether they be raw materials, finished goods, intermediate products, or waste products.
When storing materials, whether inside or outside your facility, keeping these areas neat, clean, and well-organized makes them much easier to manage and keep under control. It’s all too easy to let storage areas get overwhelmed and out of order - something to put off dealing with until another day. But that is a recipe for disaster.
There are a few must-dos when it comes to keeping your house in order:
· Don’t let storage areas become overstocked. Control the quantities of material as much as possible. And only place materials in their designated areas. Storage areas should not be a catch-all for any material that doesn’t have anywhere else to go.
· Store compatibles with compatibles. When storing material make sure you separate materials that will have a dangerous reaction if mixed. Have two chemicals that will produce a toxic gas if combined? Even if they are cleaning products in a janitor’s closet… they should be nowhere near each other!
· Label your containers. This is an issue we see all too often in facilities: “mystery containers” sitting on shelves for who knows how long…
In some cases, there is no clear label, so nobody really knows what material is inside. There is also an issue with incorrect or old labels on containers. In these cases, often a container was emptied of its previous contents and reused for a different material… but the old label remains.
That can be quite a serious issue if mislabeling leads to incompatible ingredients coming into contact. But it’s an easy fix. Whenever you reuse a container, remove the old label, and put on a new one that reflects the current contents.
One last thing on this point. It goes without saying… but I’ll say it anyway because it’s so important. Any container with hazardous materials should be prominently labeled as such.
· Use the right containers. You should only store materials in containers that are intended for that material. Always keep in mind that some materials could corrode or otherwise damage certain types of containers.
For example, some wastes are corrosive and could react with steel drums… even causing them to fail and result in a release. Use plastic drums when storing corrosives.
For flammable materials, make sure your containers are properly grounded to prevent fire or explosion – and have the ground confirmed by a licensed electrician.
· Monitor the condition of your containers. Before you place any material in any container, make sure that container is in good condition and its integrity is solid to prevent accidental releases.
You don’t want to use a drum with a large dent in the side or one that is rusting, for example. And always make sure that containers are tightly closed. And I mean closed enough so that if the container tips over by accident, no material is released.
· Maintain the storage area. You should regularly inspect your storage areas for potential pathways to the environment and promptly address any issues you come across.
These pathways could include floor cracks and open floor seams. For exterior storage, you should also make sure the area is paved, so that if there is a spill, it does not directly impact the soil.
And when it comes to shelving, it must also be undamaged and in good working order…and never overloaded beyond its weight limit.
· Determine if containment is needed. If you haven’t already, I recommend that you determine whether or not secondary containment is needed in your storage area. To help make this determination, you should look for potential pathways if a spill occurs.
Containment pallets or berms are often needed to prevent spills from spreading.
· Determine if shelter is needed. When storing materials outside, it’s important to have a roof or cover that provides protection from the elements. You don’t want rain, snow, or other weather events to damage containers or carry waste materials into stormwater runoff systems where they eventually impact the environment.
· Make storage areas part of routine preventative maintenance. It’s all too easy for storage areas to become out of sight, out of mind… with any or all the issues I’ve mentioned so far getting out of control. That’s why I suggest you make inspections of your storage areas, interior and exterior, an important part of your calendar. Schedule regular inspections and walk-throughs and pay close attention to the issues I’ve listed in this article.
This alone will catch many issues before they become major headaches.
Examples of Improper Storage
Properly storing materials seems like it would be straightforward, which is why it doesn’t get much attention in many facilities. But this ignorance doesn’t get them off the hook when it comes to fines from regulators for improper storage or costly remediation efforts due to releases that impact the environment.
For instance, many retail stores are getting in hot water these days for their exterior storage practices. Take big box hardware stores with gardening centers that store bags of fertilizer on pallets outdoors. A bag rips, it rains, and that fertilizer flows with the stormwater into surface water bodies. That’s a potential violation for contributing to stormwater pollution.
Other retail stores have compactors and dumpsters out back that aren’t properly covered and secured or are frequently overloaded. As a result, you get a lot of windblown debris and even stormwater pollution when those solids fall into a stormwater basin and then into whatever body of water that basin drains into.
When it comes to restaurants, the most frequent violation is improper management and disposal of used cooking fats and grease, as well as food wastes. Often, these containers leak, and this material gets into stormwater or sewer lines.
Where to Go from Here
As you can see, it’s not just manufacturing facilities that must worry about proper storage. Retailers, residential communities, restaurants, office complexes… nobody is immune from having to pay attention to these best practices to prevent issues and stay in the good graces of regulators.
And one last thing to keep in mind is that exterior storage areas create regulatory interest. They’re easy to spot just by driving by. And for a regulator, any violations, like improperly stacked drums or materials exposed to the elements, will be glaring.
The thing is, once a regulator’s eye is caught by issues like that… they’ll likely give your whole facility a once over.
In addition, based on our environmental due diligence experience, we often find that if a property has a contamination issue, the source areas for the contamination are usually storage areas. When we review historical aerial photographs of a property and we see poor exterior storage practices in those photos, you can be sure that we will be conducting some sampling on that property in these historical storage areas to determine if there are any environmental issues resulting from these past practices.
That’s just one more reason to make effectively managing your facility’s storage areas a top priority.
At Envision Environmental, Inc. we can help you get in step with your storage areas. We offer compliance evaluations, for example, and are happy to answer questions you may have about best practices for a particular material or type of facility.
Just reach out to me, Mark Roman, at 609-208-1885 or get in touch via email at email@example.com.