ISHN - As the Country Goes Green

Process Modifications Reduce Environmental Contaminants

EPA awareness is high, their budget even higher. The administration in Washington is doing all it can to turn the country green. Businesses from coast to coast are cooperating, establishing multiple objectives relating to the enviromnent. In addition to enhanced enforcement, state and federal regulations greatly incentivize these green efforts.

Energy saving, recycling, and VOC conservation programs are in full bloom this spring.

This article touches upon air and ground-water protection and how some industries have modified their processes using equipment specifically designed to reduce environmental contaminants.


The control of volatile organic compounds (VOCs) has been a concern in this country for decades and has been mandated for the past 20 years. The Clean Air Act of 1990 created standards to protect public health by requiring sources to control emissions from hazardous air pollutants. EPA regulates these standards as charged in CFR 40 pan 63.

The release of VOCs must be controlled, even in small quantities. Following are examples of how organizations in the aerospace and furniture industries are complying with these regulations.

Aerospace Industry

A major airline received multiple EPA citations for violations of the following sections of Subpart GG: National Emission Standards for Aerospace Manufacturing and Rework Facilities (NESAM).

Section 63.741- Designation of Affected Sources: (1)(i) All hand wipe cleaning operations constitute an affected source.

Section 63.742 - Definitions: Cleaning operation means collectively hand wipe, spray gun, and flush-cleaning operations. Hand wipe cleaning operation means the removal of contaminants such as dirt, grease, oil, and coatings from an aerospace vehicle or component by physically rubbing it with a material such as a rag, paper, or cotton swab that has been moistened with a cleaning solvent. Cleaning solvent means a liquid material used for hand wipe, spray gun, or flush-cleaning. Aerospace facility means any facility that produces, reworks, or repairs in any amount any commercial, civil, or military aerospace vehicle or component.

Section 63.744 - Cleaning Operations Standards: (a) Housekeeping measures.
(1) Place solvent-laden cloth, paper, or any other absorbent applicators used for cleaning aerospace vehicles or components in bags or other closed containers immediately after use. Ensure that these bags and containers are kept closed at all times except when depositing or removing these materials from the container. Use bags and containers of such design so as to contain the vapors of the cleaning solvent.
(2) Store fresh and spent cleaning solvents used in aerospace cleaning operations in closed containers.

In order to meet these requirements, a portable, bench top solvent can was modified to include a spring-loaded, gasketed, self-closing lid. Existing equipment was also modified to achieve protection against vapor emissions from drums containing solvent-soaked swabs or cloths. Standard drum covers were redesigned, eliminating the fusible link mechanism. New covers are gasketed and equipped with a latch, and come in either manual or self-latching styles.

Furniture Industry

Furniture industry regulations include: 40 CFR Parts 9 and 63 - Final Standards for Hazardous Air Pollutant Emissions from Wood Furniture Manufacturing Operations; Final Rule, Section 63.803 Work practice standards, (g) Storage requirements. Each owner or operator of an affected source shall use normally closed containers for storing finishing, gluing, cleaning, and washoff materials.

A special mixing can was developed to help the furniture industry meet the EPA 40 CFR 63.803 (g) and EPA requirements for limiting VHAP (Volatile Hazardous Air Pollutants) emissions, while providing the same safe-guards of the Safety Can for the Storage of Flammable and Combustible Liquids per OSHA 29 CPR 1910.106 to safely relieve internal pressure in the event of a fire.

Disposing of spent aerosol cans can be hazardous in any industry. Residual gas or product creates a pressure that must be relieved without VOC emission to the atmosphere. Designation for aerosols requires businesses to recycle or properly dispose of them as hazardous waste. A system is available to change spent aerosols from solid hazardous waste to a non-hazardous waste state.

Spill Prevention, Control and Countermeasures

The SPCC rule requires owners or operators of onshore and offshore facilities to prepare and implement a plan for the prevention of oil spills. A spill of only one gallon of oil can contaminate one million gallons of water. Oil spills include both petroleum oils and non-petroleum oils.

Under the authority of the Federal Water Pollution Control Act and the Clean Water Act, the rule requires the demonstration of consideration for secondary containment solutions for containers 55 gallons and larger. Each secondary containment unit must:

  1. Hold the entire capacity of the largest container.
  2. Have sufficient freeboard to hold precipitation.


  1. Freeboard: the vertical distance to the lowest point of overflow.
  2. Adequate freeboard needs to be determined by the owner, or the operator or their engineer as outlined in their plan.
  3. Pallets that are sheltered do not require freeboard to hold precipitation. This would be implied under "good engineering practices".

In February, EPA fined an Oklahoma oil company for violating this SPCC regulation. Among the irregularities cited was inadequate secondary containment of storage areas. Mobile or portable storage containers were not positioned to prevent discharged oil from reaching waterways. Equipment is available to help industry meet these environmental objectives, including spill pallets and accumulation platforms that comply with secondary containment requirements.

Buy Green

Another way many companies are reducing their environmental footprint is by purchasing eco-friendly products. Manufacturers are stepping up their green efforts by offering products made of recycled materials or eliminating from products materials that are harmful to the environment. Consider this: one ton of this recycled material saves 163 barrels of oil (that's 685 gallons), 5,774 KWH of electricity and 30 cubic yards of landfill space.

Organizations such as UL Environment are available to validate green claims covering a variety of products. An independent validation provides confidence to customers as opposed to a self-declared manufacturer's claim.

Do Your Part

Whether your primary exposure is VOC emissions or SPCC compliance, there are steps you can take toward a greener path. Audit your existing exposures. Record where exposures exist and analyze each problem situation. Search for solutions - check the Internet, libraries, and vendors' literature. Then apply the best solution to each problem.


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From Industrial Safety & Hygiene News
May 2010