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Emergency Equipment Testing Schedules?

by Dan Sowry

When required, all facility communications or alarm systems, fire protection equipment, spill control equipment and decontamination equipment must be tested and maintained “as neces- sary” to ensure proper operation during an emergency (Ohio Administrative Code (OAC) rule 3745-65-33). Small and large quantity generators of hazardous waste must comply with this rule. The term “as necessary” often causes some confusion.

“As necessary” simply means that emergency equipment must be tested and maintained to ensure it will work correctly during an emergency. When determining compliance with this rule, Ohio EPA refers you to the manufacturer’s suggested testing and maintenance schedule. For example, if the manufacturer of a fire extinguisher requires it be tested once every six months to determine whether it is operating correctly, then testing once every six months would meet the rule’s requirement. Though not required by the OAC rule, it may be helpful to have a copy of the manufacturer’s suggested maintenance schedule ready for your hazardous waste inspection.

The OAC rule also requires that you keep a record of all emergency equipment testing and maintenance activities in a log or summary. Ohio EPA has developed an emergency equipment inspection log that you can use to comply with this rule.

Emergencies at Your Facility: SQGs and LQGs

Across 1. You must have an internal commu- nications or ___ system. 5. ___ are required to prepare and maintain a written contingency plan. 6. If required, there should be one employee who has ___ access to a device that can summon external emergency assistance. 8. When a facility uses its contingency plan, it must submit a written ___ report to the director of Ohio EPA. 9. You must have a device such as a ___ or two-way radio capable of summoning emergency assistance. 10. Equipment inspections must be recorded in this. 12. Emergency equipment must be ___ and maintained as necessary to ensure its proper operation during an emergency. 13. Unless none of the hazards posed by the waste that you handle require it, you must have

portable fire control, spill control and equipment. ___ must be maintained on-site by SQGs and LQGs. 14. Emergency ___


2. Contingency plans must contain ___ procedures whenever there is a fire, explosion or release of hazardous waste or hazardous waste constituents which could threaten human health and the environment. 3. Contingency plans may include information stating that the ___ nature of hazardous waste you are managing would not pose a threat to human health or the environment in certain emergency

situations. 4. Your emergency equipment must be with the waste. ___ to allow unobstructed movement of personnel and 7. You must maintain adequate ___ ___ emergency equipment to any area of your facility in the event of an emergency.(two words) 11. You must maintain and ___ your facility to minimize the possibility of emergencies.

Notifier-Winter 2006



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