Comments on Revisions to Hazardous Materials (EC3)
Note: ASHE comments are highlighted in yellow.
Current Standard: EC.3.10 Current EP 2:
The organization creates and maintains an inventory that identifies hazardous materials and waste used, stored, or generated using criteria consistent with applicable law and regulation (for example, the Environmental Protection Agency [EPA] and the Occupational Safety and Health Administration [OSHA]).
Revised Standard: EC.3.01.0: Revised EP 1
The [organization] maintains a written, current inventory of hazardous materials and wastes that are used, stored or generated.
(see also IC.2.10 EP 6 and MM.1.02.0 EP 4)
Footnote: Law and regulation define the categories of hazardous materials and wastes that must be tracked on the inventory.
State which law and/or regulation is to be followed.
Current Standard: EC.3.10 Current EP 3:
The organization establishes and implements processes for selecting, handling, storing, transporting, using, and disposing of hazardous materials and waste from receipt or generation through use and/or final disposal, including managing the following: Chemicals
Revised Standard: EC.3.01.0: Revised EP 3
The [organization] minimizes risks associated with selecting, handling, storing, transporting, using, and disposing of hazardous chemicals.
AND
Revised Standard: EC.3.01.0: Revised EP 5
The [organization] minimizes risks associated with selecting and using hazardous energy sources.
Note: Hazardous energy sources include but are not limited to energy sources generated while using ionizing or nonionizing radiation equipment, lasers, microwaves, and ultrasound equipment.
This has moved from being a foot note in EP3.10 to being an EP, in effect making it a new requirement. Is there evidence to support microwaves and ultrasound equipment as being a hazardous energy sources?
What type of microwaves is this referring to… microwave communications, microwave ovens? The safe use of medical equipment should be covered in the medical equipment management standard
Revised Standard: EC.3.01.0: Revised EP 6
The [organization] minimizes risks associated with selecting, handling, storing, transporting, using, and disposing of hazardous gases and vapors.
Note: Hazardous vapors and gases include but are not limited to glutaraldehyde, ethylene oxide, vapors generated while using cauterizing equipment and lasers, and gases such as nitrous oxide.
This has moved from being a foot note in EP3.10 to being an EP, in effect making it a new requirement. This is covered by EC.3.01.0 EP 7
Current Standard: EC.3.10 Current EP 8:
The organization monitors and disposes of hazardous gases and vapors.
Revised Standard: EC.3.01.0: Revised EP 7
The [organization] monitors levels of hazardous gases and vapors to determine that they are in safe range.
Note: Law and regulation determine the frequency of monitoring hazardous gases and vapors as well as acceptable ranges.
Define a safe range or specifically cite the “laws and regulations” that will be enforced.
Current Standard: EC.3.10 Current EP 10:
The organization maintains documentation, including required permits, licenses, and adherence to other regulations.
AND
Current Standard: EC.3.10 Current EP 11:
The organization maintains required manifests for handling hazardous materials and waste
TO
Revised Standard: EC.3.01.0: Revised EP 8:
The [organization] has the permits, licenses, manifests, and material safety data sheets based on law and regulation.
The current EPs do not include a requirement for material safety data sheets. This is an addition to the standard.
Specify which “law and regulation” will be enforced.