Fact Sheet: Jewelry Manufacturers' Regulatory Requirements Information

Board of Public Works
HTM Office
City of Los Angeles

Translation Services Provided by Officer Tevork Shamlyan
Los Angeles Police Department
Valley Traffic Division

Hazardous & Toxic Materials Office Board of Public Works
City Hall 200 N. Spring Street
Room 353
Los Angeles, California 90012
(213) 237-1209

Rev. 2-95

Hazardous Waste Generation

Do I Generate Hazardous Waste And If So, What Is it?

Hazardous waste is defined as any solid, liquid, or contained gaseous by-product of manufacturing that may pose a threat to human health or the environment. Hazardous wastes are currently regulated by federal, state, and local public health and environmental protection agencies. There are two ways a waste may be brought into the hazardous waste regulatory system:

• By listing or
  
• Characteristics.

Characteristic Wastes - Even if your waste does not appear on one of these lists, it is considered hazardous if it exhibits any of the following characteristics:

• Ignitable
  
• Reactive
  
• Corrosive
  
• Toxic.

Hazardous Waste Generator Responsibilities

Hazardous waste generators must comply with the following requirements:

• Obtain a Generator Public Health License (contact Los Angeles County Fire Department, Health and Hazardous Materials Division).
  
• Obtain an EPA I.D. number (contact California Environmental Protection Agency, Department of Toxic Substances Control).
  
• Properly manage hazardous waste storage, transportation, treatment, recycling, and disposal.
  
• Prepare a contingency plan.
  
• Train personnel (also see worker safety section).
  
• Maintain proper emergency equipment.
  
• Prepare and submit biennial reports.
  
• Pay generator fees and taxes.

Hazardous Waste Management Requirements

You must handle your hazardous waste properly on-site while accumulating adequate volumes to ship to a permitted hazardous waste facility. Treatment of hazardous waste on-site, such as reclaiming gold from bombing solutions, requires authorization from the Department of Toxic Substances Control. In addition, all generators dispose of hazardous waste must use permitted Treatment Storage and Disposal Facility (TSDF) authorized to accept the waste. Some of the requirements for hazardous waste handling are listed below:

• Place hazardous waste in properly labeled, closed containers compatible with the waste. If the waste is to be shipped offsite it must be in containers that meet Department of Transportation requirements.
  
• Date each container when waste accumulation begins
  
• Store no more than 90 days on-site
  
• Use registered haulers with certified vehicles to transport waste a registered transporter.
  
• Select permitted Treatment Storage and Disposal Facilities
  
• Complete a Uniform Hazardous Waste Manifest for shipment

Hazardous Material Use

Hazardous Materials Business Plan

California law requires business handling hazardous materials at any one time in quantities of 55 gallons, 500 lbs., or 200 cubic feet for Hazardous Materials and any quantity of Acutely Hazardous Materials to implement a Hazardous Materials Business Plan. In the City of Los Angeles, Hazardous Material Business Plans are reviewed by the Los Angeles City Fire Department. Examples of hazardous materials used in jewelry manufacturing include: Compressed Oxygen, Hydrogen Peroxide, Sulfuric Acid, Potassium Cyanide, Ammonium Hydroxide, and Sodium Bisulfate. Among the information required are an inventory of the hazardous material handled on-site, a site map, emergency contact, emergency procedure and employee training records. For more information, see the contact list below.

Inventory & Certificate of Disclosure

Inventory disclosure of all hazardous substances is required by the City of Los Angeles. Division 8 of the Los Angeles City Fire Code requires that all businesses that store, handle, or process any hazardous substances must file an application for a "Certificate of Disclosure of Hazardous Substances". To obtain a form contact the Hazardous Materials Section of the Los Angeles City Fire Department. You must mail your completed application to the City Clerk within 30 days.

The disclosure and plan will help the City Fire Department and your employees respond appropriately should and incident occur at your facility.

Zoning - Occupancy

Generators of hazardous waste may be required under City of Los Angeles regulations to follow specific guidelines for occupancy. For detailed information consult Chapter 9 of the City of Los Angeles Uniform Building Code or contact the City of Los Angeles Department of Building and Safety.

Worker Safety and Health

Jewelry manufacturing poses a number of health and safety risks for the works in such environments. The California Occupational Safety and Health Administration (CAL/OSHA) is responsible for insuring compliance with the applicable labor code and specifically Title 8 of the General Industry Safety Orders including the new requirements of Section 3203 (SB 198, Effective July 1991). This requires employers to establish, implement, and maintain an effective safety plan, and injury and illness prevention program In Writing.

SB 198 requires:

1. A written safety plan
   
2. A System for identifying and evaluating work plan hazards
   
3. Methods and procedures for correcting hazards at the workplace, reporting of hazards by employees, and actions to correct it
   
4. Occupational training covering hazards
   
5. Communication system
   
6. System to ensure employee compliance with safety
   
7. A record keeping system

Right To Know

All employees have a legal Right to Know what hazardous substances and materials they are near or in contact while at the work place. Employees are entitled to ask employers for a Materials Safety Data Sheet (MSDS) for all hazardous substances on the premises. It is the employers responsibility to help the employees understand them. The employees should also know how to recognize the hazardous substances, safety precautions that should be taken when using any hazardous substances, and what the emergency and first aid procedures are for the particular substance the employees may come in contact with.

The following is a brief description of the hazards that may be encountered in the various steps of jewelry manufacturing that can impact worker health and safety, and what you can do to protect your workers.

Soldering

Solders commonly contain cadmium. Cadmium can cause permanent kidney damage and may cause cancer. Cadmium free solders are now available for soldering jobs.

Casting

Silica dust is created when cured investment is broken up to free the cast trees. Investment dust contains silica that can cause silicosis, a disabling lung disease, and cancer. Keep flasks under water while breaking up the investment.

To clean the investment from the casting, hydrofluoric acid is used. Hydrofluoric acid can cause serious, painful burns when it contacts skin. Safer techniques, such as dilute hydrochloric acid, are now available.

Polishing

Polishing wheels can cause tripoli dust, which is composed mainly of silica-like investment plaster. Make sure the dust collectors on all polishing wheels are strong enough to pull most dust away from workers

Bombing/Striping

Cyanide, a deadly poison, is commonly used to strip jewelry. Non-cyanide alternatives are now available, and some companies produce jewelry without any stripping at all.

Other areas where worker safety should be maintained are in the tooling and metal stamping area, press operations, assembly and finishing, degreasing, and electroplating.

Health and Safety Summary

What all manufacturers should be reminded of:

• Know what to wear (goggles, rubber gloves, boots, repirators, and dust masks), when to wear it, and how to use it.
  
• Know how to respond in case of accidents.
  
• Know the location of all eyewashers and showers, who to call for help, and the location of emergency switches to stop operations.
  
• Know how to handle materials safely.
  
• Learn how to mix chemicals properly, and how to store, transport, and prevent contamination and spills of chemicals.
  
• Know how to operate machinery properly.
  
• When shielding devices are necessary, pay proper attention to even the simplest of tasks.

Hazardous Waste Minimization

The Department of Toxic Substances Control, Office of Pollution Prevention and Technology Development, Technology Clearinghouse produces a Hazardous Waste Minimization Checklist and Assessment Manual for the Jewelry Industry which is available at no charge.

Where to Turn to for Help

For additional information on the regulations that impact your operations, contact the following:

Business Plans and Certificate of Disclosure	Los Angeles City Fire Dept. 200 N. Main Street Los Angeles, CA. 90012 Tel. (213) 485-8080
Certificate of Disclosure Fees	Elias Martinez, City Clerk 200 N. Spring Street Los Angeles, CA. 90012 Tel. (213) 485-3960
Generator Public Health License	Los Angeles County Fire Dept. Health Hazardous Materials Division 5825 Rickenbacker Road Commerce, CA. 90040 Tel: (213) 890-4045
Industrial Wastewater Discharge Permit	City of Los Angeles Bureau of Sanitation Industrial Waste Operations Tel. (213) 485-5886
State Fees/Taxes on Waste Generation	(If a business Generates > 5 tons of waste per year or land dispose > 500 pounds of waste per year) State Board of Equalization Tel. (916) 739-2582
EPA ID Number	Cal-EPA Department of Toxic Substances Control P.O. Box 806 Sacramento, CA. 94234-7320 Tel: (800) 618-6942 - ID number (916) 323-5871- tiered permitting (916) 322-3670 pollution prevention
U.S. EPA	Region IX Public Inquiries (415) 744-1500
RCRA Program - PRC	135 Main Street, Suite 1800 San Francisco, CA. 94105 Tel. (415) 495-8895
Generator/Waste Reduction Assistance	City of Los Angeles Hazardous and Toxic Materials Office (HTM) 200 N. Spring Street, Room 353 Los Angeles, CA. 90012 Tel. (213) 237-1209
Air Quality Permits/Small Business Air Quality Permits Assistance	South Coast Air Quality Management District Public Advisors Office 21865 Copley Drive Diamond Bar, CA. 91765 Tel. (909) 396-3218 (213) 847-4622 (L.A. City Hall)
Worker Safety and Health California Occupational Health and Safety (Cal-OSHA)	455 Golden Gate Ave., Room 5246 San Francisco, CA. 94102 Tel. (415) 703-4050
California Occupational Health Program (COHP)	2151 Berkeley Way, Annex 11 Berkeley, CA. 94704 Tel. (510) 540-2115
Cal-OSHA Consultation Service	10350 Heritage Park Drive Santa Fe Springs, CA. 90670 Tel. (310) 944-9366

The original brochure prepared by: Pollution Prevention International under contract by the City of Los Angeles