The distribution system for water treatment has several hazards especially asbestos cement piping. The operator is exposed to this hazard during line repair and replacement, because they must disturb the asbestos in order to complete their job. Each time this work is done the operator must protect themselves through various hazard control methods. This article will highlight the asbestos pipe safety awareness, techniques, and compliance concerns including trenching and excavation.

In older communities, cement piping was regularly used for the water distribution system. It was common to have asbestos used in this cement piping to strengthen the pipe. In addition, asbestos cement pipe was often used because, it is less expensive than cast iron piping. It is also lighter than iron pipe and easier to install and to tap. However, asbestos cement pipe is a carcinogen if released in air when making repairs.

Asbestos Containing Material (ACM) or Presumed Asbestos Containing Material (PACM) when disturbed is known to cause asbestosis, mesothelioma, or lung cancer. Generally speaking the symptoms of asbestos caused diseases, do not appear until 10 to 35 years after the exposure from the material. Friable asbestos, the dry power-like form, is a significant risk to the workers and anyone in the immediate area.

In addition to asbestos exposure, the operator that is responding to a line break has to cut through concrete which is known to contain silica sand. This silica exposure can create silicosis in the lungs if inhaled during the process of getting to the water main break for repair. Therefore, it is important that the distribution operator protects their respiratory system from any asbestos and silica. Selecting the proper PPE for respiratory protection is necessary and required in some states.

The Occupational Safety and Health Administration (OSHA) requires in subpart I 29 CFR 1910 that a written PPE hazard assessment must be conducted by the employer for each task or job description. Hazards associated with asbestos cement pipe repair in the distribution system includes, but is not limited to:

  • trenching & excavation hazards
  • cave-ins
  • caught in between
  • asbestos exposure
  • silica exposure
  • lacerations
  • overexertion
  • head injury
  • etc.

Some state have required protection for municipal workers from occupational hazards, through a state OSHA plan. However, other states do not have a state OSHA plan, therefore it is up to the individual municipalities to protect their own workers. For instance, some states require that a trench permit be acquired prior to any trench work being done including for municipal workers. So in order to repair the ACM pipe, the municipality would have to request the trench permit and then complete the permit after the emergency repair has been completed.

An important step, prior to digging, is to call the national 811 number to locate underground utility lines. This will avoid any additional hazards such as electrical burns or electrocution if the trench work exposes live electrical lines. A competent person must be responsible for checking the excavation prior to entry. The check would include a soil analysis and monitoring for any hazardous condition present.

When it’s time for the workers to begin cutting through concrete or asbestos cement, is important that the workers have the proper respiratory protection. A N95 particulate mask, which is a two strap filtering facepiece, is not sufficient enough to protect against friable asbestos. A half face respirator with a 100 percent particulate filter would be proper minimum respiratory protection.

State OSHA programs require that in order for a worker to wear a respirator they must first have a medical clearance and fit testing. The medical questionnaire and fit testing is performed on an annual basis or if there’s a change in the person’s facial features, the worker has experienced a heart attack, or has been diagnosed with a respiratory ailment within that year.

At the job site, the workers are suggested to adhere to the following procedures at a minimum:

  • post trench permit if required
  • verify that minimum PPE has been provided
    • HEPA filter cartridges for respirator
    • disposable coveralls with a hood and booties
    • safety glasses with side shields
    • hardhat
    • hearing protection
  • perform a job safety briefing
  • set up a decontamination area or have plenty of water available for flushing work uniforms
  • create a work zone traffic control area
  • have a minimum of 6 mL poly bags for disposal of ACM pipe
  • durable tape to tape ACM pipe in plastic bags
  • stickers labeled: “Danger: Contains Asbestos Fiber, Avoid Creating Dust. Cancer and Lung Disease Hazard” or any identifying sticker to warn of asbestos danger

When cutting the ACM or PACM and material it is best to use a wet method of cutting and avoid using cement saws that will generate dust. The use of the snap cutter would be better than a chop saw or pipe saw, because the snap cutter does not generate excessive dust.

Proper disposal of ACM and PACM material is a critical step to compliance. The operator must check with local regulatory agencies and landfills to find their procedure for disposal of ACM and PACM material. Each piece of pipe must be wrap at a minimum two times and taped up at the ends and in the middle securely to avoid airborne ACM or leaching of liquid from the wet cutting that contains asbestos.

Some states require training for workers that do asbestos abatement and supervisors of workers that do asbestos abatement. Therefore, you must check your state or local regulatory agencies to make sure that you’re complete compliance with these rules. Most of these trainings involves a 40 hr. course for each level of certification or a 16 hr. course for a maintenance worker involved in asbestos abatement. In addition to the required initial courses, an approved annual four hr. refresher course for maintenance worker and an eight hr. refresher course for asbestos abatement supervisor and abatement worker is required.

Asbestos safety awareness is paramount to protecting the workers and to reduce the risk of cancer-causing exposure. Each municipality should take the safety of the worker and the general public in consideration when doing tasks with ACM or PACM. For information please refer to the asbestos safety guidance on the EPA website:

5 Tips for Acing the Wastewater Licensing Exam Math Questions

The words “wastewater math” often carries an undercurrent of fear for the operator that has to take a state exam. Most of the students that I have taught throughout the years have a mental block when it comes to process control math. I even had a student that vowed to not do any math and just plan to ace the other portions of the 100-question wastewater exam. For the record, avoiding the math questions is not a good strategy for passing your operator exam. In addition, if you do get your license using this tactic, you will be limited in your professional career. This article will give you 5 tips to ace your math questions and help you pass your operator exam.

Read the question all the way through, before you look at the provided data

Each math question will give you a data set to help you answer the question. Do not look any of the data until you have completely read the question. The human mind likes to solve problems in the quickest most efficient way. If you are caught in the trap of looking at the data set first then you have a chance of not reading the question fully and answer what you “think” is the question being asked. Then analyze the data set to make sure your understanding what is given and what is needed.


Solve the following question:

What is the volume in million gallons per day (MGD) of the Aerbay? (Volume= Length x Width x Depth x 7.48)

Plant Data

Parameter Data
Raw Flow 13.5 MGD
Influent BOD 230 mg/l
Influent TSS 240 mg/l
Aerbay Dimensions 220 x 25 x 15
Aerbay Operating Capacity 523,345 gallons
Aerbay MLSS 2878 mg/l
Aerbay MLVSS 2278 mg/l
Effluent BOD 10 mg/l
Effluent TSS 4.5 mg/l
WAS Flow .897 MGD
WAS TSS 7565 mg/l


Looking at the question “What is the volume in MGD of the Aerbay “and the data chart, you would see the answer without any calculations. The plant data already give the capacity as 523,345 gallons, so all that is needed is to convert gallons to MGD. 523,345/1,000,000= .523345 MGD.

Make the Davidson Pie diagrams for the question that you are trying to answer

What happens if the known information was lbs. and flow, but not concentration or lbs. and concentration, but not flow? Well according to the principles of algebra, you can determine any missing element of a formula if you have two known elements. Operators frequently use a visual tool called Davidson Pie Chart (Figure 1.0) to show the relations between all the parts of the pounds formula.

(Photo Credit: Sheldon Primus upcoming Wastewater Math book)

The pie chart can be used for other application including, but not limited to:

  • Electromotive Force
  • Power Equation
  • Pump Rates
  • Chemical dosage

Don’t mix units for detention time formulas

A common mistake that is made on the operator exam is when MGD is used for detention time (DT) questions that want the answer in gallons. The basic formula for detention time is Volume/flow, but the operator exam would have the formula similar to DT, Hr= (Tank Volume, gal x 24 hr/day)/ Flow, gal/day

Remember to keep apple with apples, so the formula will be compatible.

Using the Plant Data provided, what is the detention time of the aeration basin in hours?

Attempt 1 using MGD and Gallons:

DT, hrs.= (523,345 x 24)/13.5

DT, hrs.=12,560,280/13.5

930,391 Hours

Attempt 2 using gallons in both places:

DT, hrs.= (523,345 x 24)/13,500,000

DT, hrs=12,560,280/13,500,000

DT, hrs=0.93

Attempt 3 using MGD in both places:

DT, hrs.= (.523345 x 24)/13.5

DT, hrs.=12.56/13.5

DT, hrs.= 0.93

Use the units in the formula as a clue to the answer

Often the actual formula for the answer give the operator the blueprint to solving the question. The detention time formula in the previous section was DT, Hr.= (Tank Volume, gal x 24 hr/day)/Flow, gal/day. In the formula the gallons are in both the numerator and denominator. Therefore, the astute operator can ascertain the units right from the formula.

Another example is the calculation for finding the backwash rate required to backwash a filter.

Formula: Backwash rate, gpm/sq. ft.= Backwash Flow, gpm/surface area, sq ft

When you dissect the formula it gives that you’re looking for gallons and square feet. If the operator calculates length x width x depth of the filter, then the answer is already wrong. Also, test writers like to give MGD for flow in this scenario to confuse the test taker to not convert the MGD back to gallons. If this happens, then the operator will have an incorrect answer.


One of my greatest tips to students is to “breathe”! It sounds simple, but during a stressful event, like taking an important test, shallow breathing comes naturally. Each deep, belly filling, breath will give more oxygen to your brain and help the body regulate the stress. Harvard Medical notes that deep diaphragmatic breathing slows the heartbeat and lower or stabilizes a person’s blood pressure. It is a valuable tool for the operator to help prevent mistakes due to elevated stress levels.

In conclusion, the operator exam is a daunting task, but don’t let the math be intimidating. Test writers design exams to help verify that the operator knowledge and comprehension of the classroom training. Using these 5 tips the math portion will be manageable for the operator. Good luck!

Four OSHA Changes to be aware of in 2015

The utility sector mirrors what happens with the general industry and construction sectors throughout America. The field personnel conduct trenching, excavations, even erecting structures on a regular basis. Plant personnel are exposed to chemical, biological hazards, and many other hazards that can cause injury or illnesses. OSHA, the Occupational Safety and Health Administration, is the regulatory body that has jurisdiction to guide the employers in ways to protect the employees.

However, only states that have their own approved OSHA program can regulate public water and wastewater utilities. Each state plan must be as strict as or more stringent than the federal OSHA as a term of their program approval. In addition, the state programs must adopt the federal OSHA regulations within 6 months for the final ruling in the Federal Register. This article will highlight four key regulatory changes or pending changes in 2015.

According to OSHA’s Unified Agenda, there are three stages for rules to become law:

  • Pre-Rule
    • Emergency Response and Preparedness
    • Communication Towers
  • Proposed Rule
    • Cranes and Derricks in Construction: Operator Certification
    • Occupational Exposure to Crystalline Silica
  • Final Rule
    • Improve Tracking of Workplace Injuries and Illnesses
    • Confined Spaces in Construction


Recordkeeping requires the employer to denote workplace injuries, illnesses, catastrophes, or fatalities within a certain timeframe. After January 1, 2015, a catastrophe will be one hospitalization instead of three, which has been modified. Once the worker is admitted to the hospital, OSHA has to be notified within 24 hours of the hospitalization. In addition, any amputation or loss of an eye must be reported to the OSHA office within 24 hours. A workplace fatality must be reported no later than 8 hours of notification.

The utility can report to OSHA by:

  • 1-800-321-OSHA (6742)
  • Calling the closest OSHA Area Office
  • Use the upcoming online form

Process Safety Management (PSM)

OSHA has been making a push to get companies to switch from highly hazardous chemicals to safer alternatives. This switch will help reduce the exposure to chemical hazards to the workers and the community. Liquid utilities have to disinfect with chemicals in a large quantity, therefore, several are under the Process Safety Management program or the EPA Risk Management Program. There is a guidance electronic tool (e-tool) provided by OSHA that gives 7 steps transition to safer chemicals. These steps are:

    1. Develop a team to outline a plan with achievable goal and milestones to the transition.
    2. Include engineering, service workers, maintenance, operators, laboratory personnel, and any applicable stakeholder.
    3. Develop a work plan (OSHA sample work plan model used below).


Reduction Goal

Achievement to Date

Action Steps



Alternative Assessment Tool Used



Conducted initial research

Identify alternatives to Chlorine Disinfection

January 2015




    1. Evaluate your current chemical use.
    2. Prioritize what chemical is the greatest concern for the utility.
    3. Do an inventory to date to ascertain how much product must be replaced and in what timeframe.
    1. Look for all possible chemical alternative that will be as effective as or more effective than the target chemical.
      1. Make sure to check with NPDES permit issuers for regulatory guidance on alternatives.
    1. Be aware of the hazards associated with the alternative chemical.
    2. Know how to protect the workers from the new hazards, if any, in accordance to regulatory requirements.
    1. Continue to assess the pros and cons of each alternative, but select one after the analysis.
    2. The EPA has a design for alternative assessments for chemicals to help the utility in this quest.
    1. Do a small and large-scale test to make sure the anticipated result matches the actual performance.
    2. Consider a job hazard analysis for the handling and use of the new chemical to identify and select protection for each stage of the tasks.
    1. Did the alternative chemical work as well as you wanted?
    2. Keep tracking performance to verify effectiveness.
    3. Share your results with fellow utilities.

Fall Protection for General Industry

Falls in constructions is a known hazard that is addressed in OSHA’s Focus 4 (the four leading causes of death) initiative. The construction standard, 29 CFR 1926, even has Subpart M, which is expressly for Fall Protection. However, the General Industry standard 29 CFR 1910, there are sporadic mentions of fall protection. Falls to lower levels can end tragically, but there are not standards to cite when a general industry worker is maintaining a building at an elevated height. A simple task of changing a windsock on a steep pitched roof would not violate a specific standard except the General Duty Clause in 5A1 of the OSH Act of 1970 that states in part that an employer must furnish a place of employment free from any known or suspected hazards.

In the Unified Agenda, OSHA has a final rule on the revision of the Walking Working Surfaces and Personal Fall Protection System (Slips, Trips, and Fall Prevention). However, this final rule for this 29 CFR 1910 revision to Subpart D (Walking Working Surface) and Subpart I (Personal Protective Equipment) has been pending since May 2010. If 2015 were the year that the fall protection for general industry passes, then the utilities would have an additional regulation to be aware of and comply. Training on compliance requirements and additional PPE will be needed by the utility.

Confined Space Entry for Construction

Confined Space is defined:

  • as any space that a worker can get into and perform assigned work; and
  • it is not meant for continuous human occupation; and
  • has limited access and egress

When a confined space has a hazard present such as electrical, atmospheric, configuration, etc., then it becomes a permit-required confined space. The permitting process is in-house, but it takes account of the situation, entrants responsibilities, attendee responsibility, and how to protect the worker from the hazard that is present.

In construction, excavations meet the definition of a confined space; therefore, the workers must be protected in the same manner as general industry. OSHA has made the final rule for this change, so now the utility must adjust and train workers as to how to protect themselves.


Although, this article only highlighted four occupational safety concerns and future and/or current regulations, the utility must remain vigilant to protect the workers from injury and illnesses. As always, protecting the workers is a high priority with each public sector throughout the US.

The Top 5 Performance Tips for a Healthy Secondary Clarifier

The secondary clarifier is a vital part of every wastewater treatment plant. Its health is determined by upstream variables and the mechanical integrity of the clarifier components. Some wastewater facilities do not have a filtration system to capture total suspended solids that are discharged from the unit. This can cause the treatment system to be in a violation state or inhibit the operations of a disinfection system such as Ultraviolet treatment units. This article will focus on the top 5 performance tips to achieve or maintain a healthy secondary clarifier.


  1. Monitor the Upstream Biological System Very Closely

No matter if the process is a trickling filter, rotating biological contactor (RBC), pure oxygen aeration, or extended aeration the clarifier performance is married to the upstream biological system. Poor settling solids is a condition of the biological process. Here are some process control check for the operator:

  • Maintain an optimal dissolved oxygen level for you treatment train. If possible automate the blower control to appropriately react to the changing conditions of the hydraulic or organic loadings.
  • Check plant operations and maintenance (O&M) manual to compare design criteria with current operations. The O & M provides guidance as to the engineering capabilities of the biological system, therefore deviations can be detrimental to the system.
  • Extended Aeration Plants: Monitor key parameters such as alkalinity, temperature, and nitrification. As the plant nitrifies the potential for rising sludge will increase, because of the denitrification that happens in the clarifier. Alkalinity and nitrifying bacteria must be present, in the right ratio, to achieve complete nitrification.
  • Do microscopic examinations of the aeration basin daily to monitor filamentous growth and take prompt corrective action if any abnormal condition is observed.

Photo Credit: Loxahatchee River District taken by Sheldon Primus


  1. Uniform the Sampling Locations

Choosing the right sampling location for sludge sampling and clarifier core testing (commonly called sludge judge testing) is important for assessing the health of the clarifier. If operators do not have a uniformed location and speed in which to conduct the “sludge judge” test, then it becomes difficult to trust the data that is collected from shift to shift. A review of sampling procedures, location labeling, and operator techniques should be made semi-annually. Also a written sampling standard operating procedure (SOP) will erase arbitrary actions by individual operators.

  1. Use Trending Data to Predict Conditions

Trending data on Supervisory Control and Data Acquisition (SCADA) terminals is a wonderful way to help identify positive and negative plant trends on a given intervals. Here are some tips to maximize the use of the plant’s SCADA data (every plant does not monitor the same parameters, but one listed below are common):

  • Check the available flow data (Raw flow, recycled flows, return activated sludge (RAS) flow, etc.) in conjunction with the D.O. concentration. This will give you a correlation to the impact of hydraulic loading to the D.O. usage
  • Monitor the mixed liquor suspended solids (MLSS) concentration in the aeration basin and plant effluent total suspended solids (TSS) to the temperature in the aeration basin. This will give a connection to see how higher or lower temperatures affect settling. (Note: Settling can also be effected by concentration alone. Lighter flock settles slower)
  • Trend the plant pounds of solids in the aerbay, waste activated sludge (WAS), and effluent TSS to give you the necessary information to determine the plant Sludge Retention Time (SRT). Targeting flow may give you an incomplete picture of the process characteristics.
  1. Take Quick Action to Correct Poor Trends or Conditions

Gathering data is only a small portion of what is required for top performance. Once you analyze the data, then you must make prompt corrective action to avoid catastrophes. Corrective actions should be made strategically and incrementally to the process. Each major change (i.e. lower concentration of MLSS through wasting more, the addition or subtraction of a process train, or switching the aeration pattern of the aerbay) should be given 1 full SRT cycle. Then verify the expected changes has meet the expectations of the actual plant performance.

  1. Be Prepared for Seasonal Weather Conditions or Process Conditions

Seasonal weather or process changes can throw the proverbial monkey wrench in any well working treatment system. Being aware of the latest weather trends will help the plant superintendent to decide if a preemptive strike such as raising the plant solids loading will be necessary. Remember, the secondary clarifier will react to concentration changes, filamentous bacteria, and organic or hydraulic loadings. The more predictable the seasonal condition the better prepared the operator should be to protect the clarifier and aeration operations.

The secondary clarifier is dependent on the upstream process, but the clarifier performance can be optimized through following these simple tips. An important tip that didn’t make the top five is to have a quality preventative maintenance program that monitors the mechanical integrity of the system. Through a concerted effort of the plant maintenance and operations staff the secondary clarifier can reach peak performance.

The Top 5 Fall Protection Hazards Overlooked by Utilities

Fall hazards are the number one killers in the construction field according to the Occupational Safety & Health Administration (OSHA). In 2010, fatalities from falls to lower levels was 255 out of 264 recorded fall deaths ( However, other industries and sectors are also affected by fall hazard in day to day task. Utilities have several exposure points for fall hazards. This article will only highlight the top 5 fall protection hazards overlooked by utilities and way to mitigate this hazard.

  1. Ladder Safety

Photo Credit: Utility Compliance Inc.

The man seen here is on the top rung of a metal ladder operating a chainsaw without adequate fall protection. In the Occupational Safety and Health Administration (OSHA) general industry standard of 1910, there is no specific wording on fall protection for working on a metal ladder (29 CFR 1910.26) which becomes the working surface. Utilities have varies needs for using a ladder throughout the plant and in the field. 20 feet step ladders are sometime times used to change light bulbs or gain access to other areas of the plant.

Ladder use and care are very important to prevent fall hazards from occurring at the utility. It is common for the utility staff routinely do limp cutting, put up shutters on upper levels, and travel up and down ladders for tank entries and roof access. These tips will keep the workers safe and help with state OSHA compliance:

  • Read the manufacturers recommendations on the ladder care and use
  • Remove broken ladders from service
  • Instruct workers on the proper use of ladders
  • Be aware of the ladder duty and weight guidelines.


2. Scaffolding and Articulated Boom Truck

Photo Credit:


Falls from scaffolding and articulated booms can be fatal, due to the heights related to the nature of the work. Many operators have to use scaffolding for accessing elevated work surfaces of the plant for maintenance work and some construction. As a point of clarification, there must be an understanding of what is classified as construction and what is classified as maintenance. OSHA, in a 2003 letter of interpretation, explains construction under these considerations:

  • The physical condition of the equipment/structure being worked on by the worker (does this item need to be removed completely)
  • Was the replacement material for prevention of a state of failure or to supplant deteriorated sections
  • What are the physical characteristics (height, weight, width, and material) of the equipment or structure
  • Is work being performed by a contractor other than employees
  • Is this work done during an annual scheduling

Maintenance is described in a 1999 letter of interpretation as:

  • Efforts to keep equipment or structures in proper condition through “routine, scheduled or anticipated measure without having to significantly alter the structure or equipment in the process (OSHA, 1999)”

If the nature of the job is construction, then the utility should follow the 29 CFR 1926. 450 (Subpart L) rules and guidance on Scaffolding and 1926.500 (Subpart M) Fall Protection. If the task is deemed to be maintenance, then follow the 29 CFR 1910.28-.29 requirements for scaffolding.

Tips for compliance and hazard mitigation are:

  • Have the scaffolding constructed and broken down by a competent person
  • Inspect the elements of the scaffold and articulated boom for any damage
  • Instruct workers to stay within the rails of the protective system
  • Use fall arrest systems when appropriate and “tie off” on the approved anchor points per the manufacturers recommendation


3.   Floor Holes

Photo Credit: Utility Compliance Inc.

A floor openings are all over treatment plants and collections/distribution systems. Anything that is 12″ or more is considered a floor opening under 29 CFR 1910.21 and works must be protected from falling to a lower level. Many places in the treatment plant has Hydrogen Sulfide and other gases that are corrosive in nature. Workers must walk on grates, covers, and lids often in their day to day duties. If any of the brackets or track that hold the covers are compromised, then the worker can sustain injuries. Here are some steps to protect from floor opening hazards.

  • Put checks of the floor opening on the checklists used in daily operations. The worker should be checking the integrity of the cover, tracks, and any hardware.
  • Replace corroding hardware with stainless steel or other hard to corrode hardware
  • Use agents that will reduce sulfides in lift stations where at all possible
  • Use engineering controls to protect workers from exposures during entries or maintenance to the covered structure.

4.  Tank Maintenance

Photo Credit:


Clarifier, digester, holding tank cleanings are always a challenge for the operator, due to the heights and being over water. In some cases, the work area has not been engineered for proper cleaning at every location of the tank. Therefore, the worker has to adapt to the work environment in order to get the work accomplished. In the above picture, the worker is prepared for the event that he may fall into the tank, by wearing a life preserver. However, if he loses his balance and were to fall backwards he would suffer injury from the fall. Employers have a duty to protect their workers from known hazards and to provide a safe work condition under the Occupational Safety and Health Act General Duty Clause 5(a)(1). The workers can be protected by the following steps:

  • Perform a Job Hazard Analysis prior to performing the work.
    • List the step of the task one by one
    • Identify the hazards related to each step
    • Identify a control (Engineering, Administrative, and/or PPE) for each step listed.
  • Engineer a walkway with a railing system as a capital budget item issue when possible.
  • Provide a fall protection system
    • Safety Net
    • Fall Arrest System
    • Fall restraint system


5.   Vehicles

Photo Credit:


Falls from vehicles and heavy equipment is also a concern for the utility sector. In order to maintain or check critical components on an elevated vehicle, the workers are exposed to a fall hazard. Even short checks on the top of a tanker, truck, or trailer can prove to be a major hazard with debilitating consequences. Again, it’s up to the employer to provide a workplace free of known or suspected hazards in the work environment. Here are some tips to keeping the workers safe from falls off of vehicles:

  • Use a portable anchoring system with a retractable lifeline (as pictured above)
  • Use a platform to access the truck top
  • Wear the proper foot PPE to protect from slippery walking surfaces

In conclusion, each treatment plant has several fall hazards present, but though the hazard exist the worker can be protected by reduced exposure, engineering, administrative, or PPE controls. It is up to the utility to provide a work environment free from any known or suspected hazard.





Utility Safety Workshop | OSHA Regulatory Compliance : Compliance Training Webinar (Online Seminar) –

Utility Safety Workshop | OSHA Regulatory Compliance : Compliance Training Webinar (Online Seminar) –

Why Should You Attend:

Utilities have a myriad of hazards that must be mitigated on a continuous basis. There are physical, chemical, biological, and in some instance terrorist hazards and threats. Several utilities have dedicated safety personnel who take a leadership role in the organization’s safety and health program, but that is not always the case.

The liquid utility sector is a specialized group with a high level of exposure to hazardous environments and life threatening tasks. Wastewater and drinking water personnel have not been given the occupational safety training to the same degree as their private sector counterparts. However, the municipalities with state OSHA regulations must meet the same standards of 29 CFR 1910 and 29 CFR 1926 as the privately own companies.

This webinar will explain hazards related to each treatment process including water, wastewater and stormwater treatment. It will also provide attendees’ tools that they need to protect themselves on a day to day basis.

Areas Covered in the Webinar:

  1. Basics of water treatment, wastewater treatment, and stormwater treatment
  2. Hazards related to each process of a water treatment facility
    1. PPE for drinking water and wastewater sector
    2. Screening facilities
    3. Physical processes
    4. Chemical process
    5. Disinfection
      1. Gas chlorine
      2. Bleach
      3. UV
      4. Ozone
      5. Fluoridation
    6. Maintenance/Electrical (Both water and wastewater)
      1. Lockout/Tagout
      2. Welding
      3. Materials handling
      4. Machine guarding
    7. Process safety management (both water and wastewater)
    8. Walking and working surfaces (both water and wastewater)
  3. Hazards related to each process of a wastewater treatment facility
    1. Biological waste
    2. Nuclear waste
    3. Industrial waste
    4. Screenings
    5. Ergonomics
  4. Hazards related to collections and distribution systems
    1. Working in hot environments
    2. Emergency action plan
    3. Distracted driver
    4. Defensive driver
  5. Hazards related to construction in utilities
    1. Fall
    2. Caught-in between
    3. Electrocution
    4. Struck-by
    5. Silica dust
    6. Asbestos
    7. Trenching
  6. Hazards related to water and wastewater laboratories
    1. Hazard communication
    2. Bloodborne pathogens
    3. SDS Transition
  7. Basic understanding of homeland security concerns related to utilities
    1. Terrorism
      1. Domestic
      2. International
  8. Basic understanding of EPA risk management programs for utilities
    1. Risk management program compliance for handling highly hazardous chemicals

Who Will Benefit:

  • Utility Directors
  • Public Sector Underwriters and Insures
  • Public Works Personnel
  • Construction Foremen
  • Laboratory Personnel
  • Compliance and Safety Officers
  • Regulatory Affair Personnel

Instructor Profile:

Sheldon Primus, is a Certified Occupational Safety Specialist with a Masters of Public Administration with a concentration in Environmental Policy. He has been in the environmental field since 1994 as an “A” licensed Wastewater Operator, Plant Superintendent of Operations and Maintenance, Industrial Pretreatment Coordinator, Compliance and Safety Officer for a Special District of the State of Florida, and is an adjunct instructor for Florida Gateway College in the Environmental Science department. Additionally, he is a trainer for the Certified Occupational Safety Specialist program of the Alliance Safety Council-Baton Rouge, LA.

Additionally, Sheldon is an authorized OSHA General Industry and Construction trainer for the 10 and 30 hour Outreach program. He has created Spill Control Plans, Risk Management Plans for Chlorine gas, and has conducted numerous training for water, wastewater, industrial pretreatment, and distribution system operators and engineers.

Currently, Sheldon is the owner/CEO of Utility Compliance Inc. and its subsidiary OSHA Compliance Help a safety consulting, operator training, and a regulatory agency compliance assistance company based in Port St. Lucie, Florida. In this capacity, he creates Hazard Communication Plans, OSHA Compliance Mock Audits, Water and Wastewater Plant Operations and Maintenance training courses, and many other safety and training services. Sheldon is also part of the Water Environmental Federation (WEF) Water Sector Safety Committee and the US Department of Environmental Protection Agency (USEPA) taskforce on All Hazards Communication training for the Water and Wastewater Sector. Sheldon is currently under contract with Elsevier Publishing to write a wastewater math resource book, set for a Fall 2015 release.

Topic Background:

Workers in the liquid utility field have been plagued with amputations, struck-by, and caught-in between injuries. State OSHA programs has recorded 367 inspections of drinking water plant (SIC code 4941) through planned, follow-up, referral, and complaint inspections in a one year period. While wastewater plants (SIC code 4952) had 233 inspections in the same time period. Drinking Water Plants have been cited a total sum of $94,478 from the period of October 2012 to September 2013 ( Wastewater Plant has been cited a total sum of $29,728 in the same period(

However, the citations are only a small portion of the “cost” of an accident. Utilizing OSHA’s Safety Pays online calculator just one amputation at a 3% profit margin would cost the utility $133,074 in direct and indirect costs. The utility would have to generate $4,435,800 million to offset that total cost ( Those funds come from the local community in the form of their utility rate.



National Certification: What Would it Mean for Wastewater Treatment Operators? | TPO – Treatment Plant Operator Magazine

In North America, water, wastewater, and distribution and collections systems do not have a national certification program. In some industries — including teaching, nursing, therapy disciplines and interpreting — a national certification has been the norm for years. 



National Certification: What Would it Mean for Wastewater Treatment Operators? | TPO – Treatment Plant Operator Magazine.

Let’s Talk About National Certifications

A national certification program for water, wastewater, distribution and collections systems is not currently available in North America. There are some industries where a national certification is the “norm” and has been for years. Industries such as teaching, nursing, therapy disciplines, and interpreting. There should be a way for the liquid utilities to standardize and formalize, under a federal requirement, treatments for drinking water, wastewater, and the related services. This article will explore how it may be possible to have a national certification program and why it may serve the greater good of the field in the future.

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The Current Certification System


In the current system for certification, all states are responsible for creating their own criteria to maintain compliance with FRL-6230-8 found in the Federal Register Volume 64 No. 24 February 5, 1999. The federal register is a publication that give the general public notification of all final rules for the federal government. The ruling is specific to drinking water operator certification, but wastewater certification has been adopted under this ruling. States were given control over items such as:

  • The type of exam that should be given, oral or written
  • The type of operator training
    • EPA is responsible for evaluating the state program on an annual basis
  • They must have a fixed cycle of renewal not to exceed 3 years
  • They must establish training requirements for certification renewal
  • They must follow the operator certification guidelines as outlined by Section II Operator Certification Guideline.

Reciprocation is another issue that goes hand in hand with a national certification program. Reciprocation is where a state will allow an operator that holds a valid license from another state to get credit for that established license. Therefore, the operator will only have to apply for reciprocity with the new state. States like Indiana and Kentucky currently reciprocate with other states. However, some states like Florida do not reciprocate with any other state. An operator that wants to move to Florida and operate a facility must meet all of the state’s requirements as a new operator. Though the experience will still be credited to the operator, he/she must meet the training and testing requirements before they can receive a valid Florida license.

Why Do We Need a National Certification Program?


A national certification program would give the liquid utility a much needed image boost and add professional credentialing to a highly technical industry. In an August, 2013 article in the Opflow
magazine, the authors declared “operators also enjoyed comparatively less earning power than other professions, largely due to the fact that the cost of their services are priced much lower then they’re worth”(Copeland, A. & Moore, G., 2013). The article on went on further to introduce a Professional Operator (PO) designation much like an engineer has a Professional Engineering (PE) designation behind their name (Copeland, A. & Moore, G., 2013).

In addition to a PO designation, the liquid utility field can shed the system of reciprocity of one state to the next with a national certification. This certification should not be mandated, but only an option for the operator that may want to keep their options open. In this day and age there are many reasons for a family to have to move states in order to keep two incomes. Operators that must move can have assurance that they will be able to apply for a job in any state without having to take a drastic pay cut while they get a new license.

Lastly, a national certification program will have a uniformed training criteria as developed by the Environmental Protection Agency (EPA), a national operator association, or other entities such as the Association Boards of Certification (ABC). ABC, has an established voluntary, international, operator certification program and has developed a model standards of operator certification that provides a framework and benchmarks for operator evaluation (ABC, 2014). There may be another entity that is developing a national or international certification model, but I’m unaware of any other besides ABC.

How Can We Create a National Certification Program?


The creation of a national certification program will have to come from the inside out. Meaning the driver must come from the operators, municipalities that are struggling to hire qualified operators, and the States that are willing to divide the piece of the certification fee, “pie”. The industry has widely established the Sacramento State Course as a standard for drinking water and wastewater certification. Therefore, the course training for the utility sector doesn’t have to change from the established curriculum. However, in addition to these courses, a criteria should be set to determine the perspective operator’s knowledge on specialized systems. Imagine having a national certification with a concentration or endorsement for UV Disinfection, Advance Waste Treatment, or Biological Nutrient Removal. With the endorsement addition to a national certification, then the hiring municipality can be assured that the candidate is qualified to operate “their” system.

States can administer the test or use an online program as most states have currently. CEU requirements will be consistent of the law, not more than 3 years, but that training will be as its current framework within the states. A PO would have to meet the requirements of the ABC program, but each state would have to formally recognize the Professional Operator designation. The future of operations in the States would change forever with a national certification program. Who know, it may lead to an international program where the global Water and Wastewater communities can share talent.

7 Tips For Risk Management Program Compliance

Program Overview

The Risk Management Program (RMP) is an Environmental Protection Agency (EPA) initiative that tracks, audits, and regulates facilities with extremely hazardous substances (EHSs), Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), and toxic chemicals over a certain quantity. Congress enacted the Emergency Planning and Community Right-to-Know Act (EPCRA) in 1986 as a reaction from the 1984 Bhopal, India accident where Union Carbide chemical plant had a release of methyl isocyanate.

This incident cause thousands to die and many injuries in India, but 6 months later a chemical release in West Virginia (EPA, 2012). Therefore, Congress moved under the Code of Federal Regulations (CFR), the protection of environment is Title 40 to create ways of protecting the American public. The RMP can be found 40 CFR Part 68 in the Clean Air Programs section. You can find specific chemicals on “The List of List” for regulated chemicals.

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Each owner/operator has a duty to be responsible for the safe handling, storage, and use of regulated hazardous substances under The General Duty Clause (GDC) Section 112 (r)(1). This GDC covers “any stationary source producing, processing, handling, or storing regulated substances or other extremely hazardous substances” (EPA, 2009). The RMP sets a framework for an accident prevention program, reporting system for releases, establishing program levels, and compliance structuring (EPA, 2009).

Having an all-inclusive policy for all facilities is not a practical way of having a RMP on a national level. Therefore, the EPA has divided systems in to programs levels to better “match their size and the risks they pose” (EPA, 2009). The Program Level are as follows:

Program Level 1:

A facility that on its very worst day would not affect the public (as noted in a worst-case scenario modeling) and did not have an accident within the past 5 years

Program Level 2:

A facility not eligible for Program 1 or Program 2 is put into program level 2 status. These facilities have additional hazard assessment, emergency response, and management requirements (EPA, 2009).

Program Level 3:

Program that does not meet level 1 requirements, has to comply with the Occupational Safety and Health Administration (OSHA) Process Safety Management Standard (PSM), or is one of ten specified industry codes from the North American Industrial Classification System (NAICS). Level 3 programs must follow OSHA PSM standards because the RMP incorporates the PSM into its standard.

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  1. Know Your Deadlines

Drinking Water and Wastewater Facilities have potential to have several substances regulated by the RMP and even OSHA PSM programs. Drinking water facilities (NAICS 22131) have 2,289 total facilities under the RMP, 108 accidents, 90 injuries, and $3,653,153 in property damage in the past 5 years (RTKNET, 2014). Wastewater facilities have 1,514 RMP facilities, 92 accidents, 70 injuries, and $5,179,500 in property damages in the past five years (RTKNET, 2014).

In 2009, the RMP system was updated by EPA in which all current facilities under the program had to resubmit their programs for approval. This program revision and resubmittal must be done every 5 years or if changes in the quantity stored, processes, handling, or any aspect of the program have been made within six (6) months of that change to maintain compliance of 40 CFR 68.36.

Compliance Audits must be conducted and be certified every three (3) years to evaluate the program, procedures, and practices are adequate to comply with the rule. In order for an audit to comply with the 40 CFR 68.58 rule the auditor must be knowledgeable of the process, give a written report of the findings, a compliance schedule for deficiencies must be established, the owner has to retain the two most recent audits.

Here’s a chart to help know your compliance dates:































Note: x=If there is a program change in audit or revision years, then training is required.

Chart Credit: Utility Compliance Inc.

  1. Hazard Reviews

Conducting an accurate Offsite Consequence Analysis (OCA) will product two scenarios, a worst-case and an alternate case scenario. Think of the worst-case scenario as who in the general public will be affected if there is a release of chemicals from the facility. By the quantity of the produce, wind direction, and other variables the scenario should be carried out to its end point. A circle is drawn around the facility to the endpoint distance in all directions to ascertain what public receptors or environmental receptors are in the “circle of death”. Worst-case scenarios are highly unlikely, but must be accounted for in your hazard determination.

Conversely, the alternate scenario is the most likely occurrence with treatment facility. In the case of chlorine gas, when the operators change from an empty bank of cylinders to a full bank some gas may escape the regulator or chlorine distribution system. The gas will be released into the room and in most cases not reach the operations control room before dissipation.

  1. Operating Procedures

There are six phases to the operating procedures that must be effectively addressed. Detail each step and write a narrative as to what is involved in each step of the process. In addition, add the number of personnel needed, Personal Protective Equipment (PPE) that must be worn, and any other considerations for each of the following phases:

  • Normal Start-up
  • Normal Operations
  • Normal Shutdown
  • Emergency Shutdown and Operations
  • Initial Start-up
  • Temporary Operations
  1. Training

Training is an important criteria for this program, because the utility staff are the first line of defense. 40 CFR 68.54, states that the owner or operator “MAY” certify in writing that the employee “has the required knowledge, skills, and abilities to safely carry out the duties and responsibilities as provided in the operating procedures” (EPA, 2014). This is not a requirement, but it’s a good practice to record refresher training, initial training, and annual training events.

With regulators, it didn’t happen unless it is documented in writing (with signatures from attendees). Refresher training SHALL be every three years or if there are changes in the program or process. It’s a good practice to document training with an exam to prove operator mastery of the program and process phases.

  1. Maintenance

Maintaining mechanical integrity of the process systems is a must in 40 CFR 68.56. Training on the safety of working on the maintenance of the components is a requirement for this section. Even the contractor must be trained as to the hazards surrounding the maintenance to the equipment. In addition, the equipment must be tested and inspected to ensure that they are within the recommendation of the manufacturer, industry standards and codes, and good engineering practices.

  1. Compliance Audits


After an internal or external audit is complete, then the process for abatement of deficiencies must be clear and specific. Each action item must be given to an accountable party for correction. It is not enough for the audit review team to tell the operator to fix the problem with no timeline for abatement. Here is a sample form for Action Item assignment with risk assessment and follow-up:



B-Within 7 days

C- Within 30 Days


60 Days

E-After 60 Days

Action Item








1-Not Likely



4-Very Likely

Risk Total

(Severity x Probability)=


Code, System, or Regulation

Action to be Completed

Assigned to

Target Date

Completion Date


A.I. #1




Chlorine Regulators

Fix slow leak in manifold system


June 1, 2014

June 1, 2014

Chart Credit: Utility Compliance Inc.

  1. Incident Management

40 CFR 68.60 has a summary of how incident investigations should be conducted and recorded. However, prior to the investigation make sure that in the event stage that all notifications are made to the National Response Center (NRC) and/or State Emergency Response Commissions (SERCs). When making the initial notification have these items ready for the incident notification center:

  • The chemical name
  • An indication of whether the substance is extremely hazardous
  • An estimate of the quantity released into the environment
  • The time and duration of the release
  • Whether the release occurred into air, water, and/or land
  • Any known or anticipated acute or chronic health risks associated with the emergency, and where necessary, advice regarding medical attention for exposed individuals
  • Proper precautions, such as evacuation or sheltering in place
  • Name and telephone number of contact person (As quoted from EPA, 2014).

Written notification is required to local emergency response and the state emergency response entities as soon as practicable after the event. Other notification rules can be found in 40 CFR 355.40 to avoid penalties (40 CFR 355.50) that can be up to $25,000 for each violation, civil penalties up to $25,000 per day, and criminal penalties for up to two years imprisonment.

The RMP system is necessary to protect the surrounding community from extremely hazardous chemical, but the regulations are very strict and daunting. There has been a movement for utilities to replace the use of these chemicals where practical and appropriate. If you have an active RMP, then these 7 tips will help you meet or to stay in compliance.