Health and Safety Training for Underground Storage Tank Removal

Abstract

The 1984 Hazardous and Solid Waste Amendments have launched a national effort to remove underground storage tanks (USTs) and to upgrade existing sites. The objective of this research was to determine the extent of the hazards in UST removal and to develop a 40-hour training course for employees involved in UST removal. Reports from the Occupational Safety and Health Administration (OSHA) database of fatalities and injuries caused by explosions, confined space entry, electrocution, and cave-ins during UST removal operations and similar activities underscore the hazardous nature of UST removal. Leak detection, prevention, tank cleaning, and closure may fall under the scope of 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response, and thus be subject to employee training requirements. Topics typically covered in 40-hour hazardous waste training are not sufficient for UST removal employees, who require additional emphasis on cave-ins, tank pressure testing, tank entry, toxicity of petroleum products, flammable liquids, tank purging and inerting, drilling rigs, compressed air lines, overhead electrical lines, and buried utility cables.

A 40-hour training course for UST removal supervisors was developed, using as a foundation a 16-hour U.S. Environmental Protection Agency training course for state UST inspectors and materials adapted for use in UST training. Respirator training, basic training in handling hazardous wastes, field exercises, and first aid/CPR training comprised the additional hours required to meet the 40-hour training requirement of 29 CFR 1910.120. OSHA has published proposed rules amending 29 CFR 1910.120(e), Training, and adding 29 CFR 1910.121, Accreditation of Training Programs for Hazardous Waste Operations. These proposed rules require that workers receive training in an accredited program and describe the accreditation procedures. The specific course content required in 1910.120(e) contains many topics of direct concern to UST operations; however, the requirement that topics such as laboratory waste pack and drum handling procedures must be included reduces the time available in a 40-hour format to cover UST-related topics. The author recommends 1) that specialized training which recognizes the specific hazards of UST removal should be made available for UST removal workers and 2) that this training should be eligible for accreditation under 29 CFR 1910.121.