An OSHA inspector visited a steel service center and cited them for three hazardous material violations in the first hour. Unlabeled containers of used cutting oil stored next to the loading dock. No Safety Data Sheets (SDS) available for the seven chemicals used in the shop. And an employee grinding without respiratory protection in an area where hexavalent chromium exposure exceeded the permissible exposure limit. Total penalties: $48,000. The cost of compliance would have been under $3,000.
What Counts as Hazardous
The most common hazardous materials at a steel service center include used cutting oils and coolants (classified as used oil under EPA regulations), hydraulic fluid from forklifts, cranes, and processing equipment, solvents used for degreasing or cleaning (acetone, mineral spirits, brake cleaner), welding gases (argon, CO2, acetylene, oxygen) which are compressed gas hazards, dust collector fines from plasma cutting, grinding, or blasting which may contain hexavalent chromium or other metal particulates, and aerosol paint cans which are hazardous waste when discarded.
Not everything is hazardous. Steel scrap, rust, and general warehouse debris are not regulated as hazardous waste. Lubricating grease and most water-based coolants are typically non-hazardous. But the determination must be based on SDS information and sometimes lab testing, not assumptions.
OSHA Requirements
The Hazard Communication Standard (HazCom, 29 CFR 1910.1200) requires that you maintain a Safety Data Sheet for every chemical product used in your facility, label all chemical containers with the product name, hazard warnings, and GHS pictograms, train employees on the hazards of chemicals they work with and how to protect themselves, and maintain a written Hazard Communication program that lists all chemicals on site.
This is one of OSHA's most frequently cited standards across all industries, and the violations are usually simple to fix: get SDS sheets from your suppliers (they are required to provide them), put them in a binder or digital system accessible to all employees, label every container, and train your team annually.
EPA Waste Management Requirements
If your facility generates hazardous waste (and most service centers with processing equipment do), you need a generator identification number from the EPA. The requirements depend on how much waste you generate per month. Small Quantity Generators (between 220 and 2,200 pounds per month) can store hazardous waste for up to 270 days and have less stringent requirements. Large Quantity Generators (above 2,200 pounds per month) face stricter storage limits (90 days), more extensive record keeping, and annual reporting requirements.
Most service centers fall into the Small Quantity Generator category. The key requirements include storing hazardous waste in labeled, closed containers in a designated storage area, arranging pickup by a licensed hazardous waste transporter, maintaining records of all waste shipments (manifests) for at least three years, and training employees who handle hazardous waste.
Practical Steps
Designate one person as your hazardous materials coordinator. This does not have to be a full-time role. It can be your maintenance manager or your safety coordinator. Their responsibilities include maintaining the SDS library, ensuring proper labeling, scheduling waste pickups, and keeping records current.
Conduct a walk-through of your facility quarterly to verify that all containers are labeled, waste is stored properly, SDS sheets are accessible, and no materials are being disposed of improperly (dumping oil down a drain, throwing aerosol cans in the dumpster, or burning waste materials).
The cost of a compliant hazardous materials management program is minimal: $500 to $1,500 per year for waste pickup, $200 to $500 for labels and signage, and 4 to 8 hours per year of employee training time. The cost of non-compliance, as our opening example shows, is 10 to 100 times higher.