Internal communication or alarm system

One of the most frequently cited violations under RCRA is the lack of an internal communication system at places where hazardous wastes are being handled.

40CFR264.34 (a) states that “whenever hazardous waste is being poured, mixed, spread, or otherwise handled, all personnel involved in the operation must have immediate access to an internal alarm or emergency communication device, either directly or through visual or voice contact with another employee”.

40CFR 264.32(b) goes on to state that “if there is ever just one employee on the premises while the facility is operating, he must have immediate access to a device, such as a telephone (immediately available at the scene of operation) or a hand-held two-way radio, capable of summoning external emergency assistance.”

The requirements are pretty clear. Yet many facilities do not have them and end up being cited by the inspector.

We have scheduled several online live webinars to discuss the most frequently cited RCRA violations and how to avoid them.

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2 responses to “Internal communication or alarm system

  1. Thanks, Norman. Does a cell phone qualify as a means of emergency communications?

  2. Yes…I would think so. However if you were storing some highly ignitable wastes, the agency would probably want to see some spark proof communication device.

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