Hazard-based approach

Deactivation and D D actions can range from stabilization of multiple hazards at a single site or facilities containing chemical or radioactive contamination, or both, to routine asbestos and lead abatement in a nonindustrial structure. Strategies include programs that meet compliance objectives, protect workers, and make certain that productivity and cost-effectiveness are maintained. The content and extent of health and safety-related programs should be proportionate to the types and degrees of hazards and risks associated with specific operations. 

The hazard-based approach allows key operational hazardous waste activities to proceed in a safe and cost-effective manner. These activities may include  

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The amount and type of hazards will determine the performance standard specified in site-specific control plans. This includes the content, detail, and formality of review. The approval of the plans is based on risk and hazard potential. Using the hazard-based approach, levels of risk or methods to rank risk (degree) are standardized. 

Training for other activities such as deactivation and D D may not fall under the hazardous waste definition. As previously mentioned, the authors believe that, in many cases, applying hazardous waste principles based on a hazard-based approach will help to provide a safe worksite and add value to these activities. These activities may involve hazard abatement processes, such as chemical lab packing, asbestos, lead, mercury, or... 

A suspicion-based approach implies that evidence of a chemical hazard or exposure can immediately lead to regulatory action. Hazard-based approaches focus on the sources of a potential risk, attempting risk reduction by limiting the quantities of hazardous material produced and used. A hazard-based approach therefore requires only the hazard of a chemical to be identified. 

SME. In this area, France and the UK may have a lot to learn from Sweden s use of policy objectives with respect to promoting a culture of chemical safety in industry and through supply chains. For France, adopting a more hazard-based approach to risk management could limit the occurrence of victim associations . 

Should the prioritisation of chemicals of concern and their subsequent assessment and control take a more precautionary hazard-based approach or should a risk assessment always be undertaken ... 

One of the key concerns facing regulators is that any toxicity discharged will be recalcitrant ( hard ) and, even if initial toxicity is diluted below any PNEC, effects may occur as toxic material builds up in the environment. Consequently, some regulators are interested in reducing the potential of effluents to cause a problem by reducing the amount of toxicity discharged (a hazard based approach) irrespective of the risks posed. 

In the search for solutions to chemical risks a hazard-based approach looks upstream for inherently safer chemicals rather than downstream for methods for reducing exposure. The properties of inherently safer chemicals include reduced human and environmental toxicity, reduced physical hazards, such as explodability and corrosivity, and reduced concern for the environmental fate of a chemical (which equals rapid degradation into benign chemicals and low bioaccumulation potential). 

Catino, C. A., and Ungar, L. H., Model-based approach to automated hazard identification of chemical plants, AIChE J. 41(1), 97-109 (1995). 

There has been a gradual move in environmental policy and regulation from hazard-based to risk-based approaches. This is partly due to the recognition that for many environmental issues a level of zero risk is unobtainable or simply not necessary for human and environmental protection and that a certain level of risk in a given scenario is deemed acceptable after considering the benefits. 

API RP 752, Management of Hazards Associated With Location of Process Plant Buildings, 2d ed. (American Petroleum Institute, Washington, 2003), which gives a risk-based approach to evaluating protection afforded by occupied structures... 

The approach should be risk-based, not hazard-based... 

The process hazard analysis required by OSHA PSM is an example of a performance-based approach it allows for a variety of hazard analysis methodologies. A performance-based system requires experts to identify and evaluate all relevant reactive hazards of a process and to determine the complexity of the hazards analysis. If the hazard evaluation demonstrates the possibility of a catastrophic consequence, the process has regulatory coverage. This approach to hazard evaluation allows for both a comprehensive analysis and flexibility in implementation however, if applied to reactive hazards, it requires expertise for implementation and regulatory evaluation. 

Two states have successfully implemented or are considering a list-based approach to address coverage of reactive hazards that affect the public. Delaware uses the same overpressurization criterion as OSHA for determining the quantity of a listed substance that is covered New Jersey is expected to include the criterion in its revision of the Toxic Catastrophe Prevention Act (TCPA). 

This approach is based on concepts developed by the U.S. Air Force to define the extent of possible safety hazards. The approach applies qualitative ratings to a series of questions about the chemical environment. 

Chemical analyses which determine the types of substances present, are incorporated to provide information for predicting control approaches, atmospheric dispersion/-transformation, and potential toxicity of the stream. Finally, because prediction of hazard based on physical and chemical analyses alone is subject to many uncertainties, biological assay techniques are incorporated as a measure of the potential toxicity. The basic Level 1 analytical procedures are given in Table II. 

An example of another approach is DEREK, a pnblicly available expert system designed to assist chemists and toxicologists in predicting toxicological hazards based on analysis of chemical strnctnre (see table 9.1). DEREK differs from other compnter methods for toxicity prediction in that it makes qnalitative rather than qnantitative predictions and does not rely on algebraic or statistical relationships. 

There are two possible alternatives to using risk directly as the basis for waste classification non-risk-based systems and surrogate systems. Non-risk-based systems could use any conceivable attribute of hazardous waste as a basis for classification, including its source (see Sections 4.1 and 4.2 for examples) or the date it was produced. These bases are at best somewhat related to risk and at worst are totally unrelated. Because of this variable relationship, the use of non-risk-based approaches to waste classification could result in an unacceptable risk if the waste is managed in a way that does not provide adequate long-term protection, or an inappropriate allocation of resources if relatively innocuous wastes are managed in the same way as much more hazardous wastes. 

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