Oilfield Waste Profile Sheets

2.1 Classification of the substance or mixture

Products intended for use in the workplace are classified based on their hazardous properties.  Labels - Provide basic information that a worker needs to know to safely use a hazardous product.  Safety data sheets (SDSs) - Supplement the label with more detailed information about a product’s physical and chemical characteristics, its hazardous properties and necessary handling precautions.  Worker education - Ensures workers understand the information on labels and safety data sheets and can apply this knowledge on the job. The hazard information on the waste profile sheets follows the guidance of federal WHMIS 2015 requirements. 8.1 Worker Safety The primary purpose of provincial Occupational Health and Safety Regulations is to protect workers against health and safety hazards on the job. The provincial regulations set rules for health & safety in workplaces and enable WHMIS. Wastes must be properly characterized to determine the hazards and control measures needed for worker safety. If a workplace chemical is a hazardous waste generated at the worksite, the employer (waste generator) must ensure that it is stored and handled safely using a combination of:  Proper means of identification, and  Instruction of workers on the safe handling of the hazardous waste. The waste profile sheets provide hazard information to workers on how to safely handle, store and dispose of different types of oilfield waste. Workers should be able to identify the oilfield waste, understand the information on the waste profile sheets, and can apply this knowledge on the job to protect themselves (i.e. what personal protective equipment to wear) and others. 9 Management Methods Once wastes are classified, storage, disposal and tracking can be determined based upon regulatory requirements. In the event of a spill, releases must be reported. 9.1

Storage

Oilfield wastes, whether Dangerous Oilfield/Hazardous Waste or Non-dangerous/Non- hazardous Waste, are generally stored:  At a waste storage facility (stand-alone) operated by a waste generator for collection of their own wastes, or  At a waste transfer station operated by an independent company as a third-party waste receiver. Specific site-storage requirements for oilfield waste are identified on the waste profile sheets for reference. 9.2 Treatment & Disposal Waste treatment (or waste processing) means to apply any method, technique or process that is designed to change the physical, chemical or biological character or composition of a substance. Waste treatment methods reduce the hazard of the waste and alter the waste into a material which may not require further disposal. Waste disposal means that the handling of the waste is complete and that the intentional placement of waste on or in land is in its final location. Waste generators are responsible to ensure appropriate treatment and disposal practices are utilized. Specific oilfield waste disposal options are identified on the waste profile sheet for reference. Waste receivers are responsible for knowing the capabilities and limitations of their treatment technologies and as such, must only accept wastes exhibiting the properties their facility is approved to handle. Generally this will require waste characterization, unless the stream is sufficiently well-known through prior testing or an in-depth knowledge of the origin of the waste. A waste profile sheet may assist in this determination. 9.3 Tracking Waste generators are responsible to track their wastes from the time of initial generation through to final disposition (cradle to grave). The effective tracking of oilfield waste is essential to aid the waste generator in ensuring the proper handling, treatment and disposal of oilfield wastes. All waste generators must implement and maintain a waste tracking system. The waste tracking system must enable the waste generator to demonstrate compliance and provide the appropriate information required for reporting. 9.4 Spills In the event of a spill, report any release of a substance into the environment that may cause, is causing, or has caused an adverse effect. An adverse effect is impairment of, or damage to, the environment, human health or safety, or property. Releases must be reported to the appropriate regulator(s) – refer to federal and provincial release reporting regulations. 10 Transportation There are numerous requirements that apply to the transportation of wastes whether DOW/HAZ or non-DOW/non-HAZ Waste. These requirements include identification of dangerous goods, handling, communication of hazards, shipping documentation and training. 10.1 Wastes Classified as a Dangerous Good Wastes which meet the characteristics of a dangerous good must comply with the TDG Regulations. The waste generator (consignor) is responsible for determining if the waste meets the classification of a dangerous good, in accordance with Part 2 of the TDG Regulations. In addition, the consignor must also have a proof of classification. A proof of classification can be:  A test report;  A lab report; or  A document that explains how the dangerous goods were classified. A typical TDG classification is provided in the waste profile sheet as a guide to classify the wastes as per the TDG Regulations. The waste profile sheet is an acceptable proof of classification if it is accompanied by an explanation that describes how the dangerous goods were classified. Periodic testing of all wastes to confirm classification is recommended. 10.2 Handling All wastes must be transported in an appropriate means of containment, which is a container or packaging, or any part of a means of transport that is or can be used to contain wastes. For the packaging of wastes which are dangerous goods, the means of containment are prescribed based on the hazards associated with the material. 10.3 Communication of Hazards and Identification of Dangerous Goods Communication of hazards related to waste shipments is required for the purposes of protecting the health and safety of workers and emergency responders, and public safety. Hazards are communicated on container labels and the documents that must accompany all waste shipments and be made readily accessible during transportation. Safety Marks are the labels and placards that are used to identify dangerous goods. Placards are a clear indication that a transport unit contains dangerous goods that otherwise might not immediately be identified as such. 10.4 Shipping Documents All waste shipments must be accompanied by a shipping document which contains specific information as prescribed by the regulatory authority where the waste is generated. When a waste is a dangerous good the shipping document must comply with the Transportation of Dangerous Goods requirements. Non-hazardous waste shipments must be accompanied by a either a Company Waste Shipping Document (if in use) or a truck ticket. Hazardous waste shipments must be accompanied by a federal Movement Document/Manifest. In Alberta, Dangerous Oilfield Wastes must be accompanied by an AER Alberta Oilfield Waste Form (or equivalent). Hazardous recyclables that are shipped within Alberta to a recycling facility use a Recycle Docket. Hazardous waste shipments across all provincial and international borders must use the federal Movement Document/Manifest. 10.5 Training Every person engaged in the handling, offering for transport, or transporting of wastes, including waste classified as dangerous goods, must be trained in the aspects applicable to their assigned duties. This is important in managing the shipments of these waste materials, because without adequate training, workers may not be able to select the proper packaging, labels or shipping documents. 11 Waste Profile Sheets The Oilfield Waste Profile Sheets contained in this guide have been prepared to assist upstream petroleum industry operators with the classification and handling of common industry wastes. Each Waste Profile Sheet has been divided into four sections: General Information, Hazard Information, Management Methods, and Transportation. The waste profile sheet information is provided as general industry guidance. The waste profile sheets do not substitute for specific analysis, the approval of waste specific disposal methods and any other work required for the proper determination of health and safety protocols, transportation requirements, and suitable waste disposal methods. 11.1 General Information Original Use A description of the general use or the process from which the waste is generated in upstream operations. Physical Description Waste material is most often described as solid, liquid, sludge, or gas, with a description, if applicable, such as colour and odour. To satisfy regulatory requirements, a waste must be identified as a solid, liquid, or gas to determine proper characterization, appropriate management, and means of containment selection. The “Paint Filter Test” is commonly used to classify a waste as a solid or liquid (compared to a sludge). Contaminants Contaminant information may be useful to determine proper laboratory analysis for waste classification and manifesting. However, as the information is very general, it may not apply to all wastes of the same type. Further waste analysis may be required to determine the classification of the waste as per the jurisdictional regulation. Other Codes Identifies specific provincial or federal waste codes, primarily the AER Codes as per Directive 047 & 058 and AER supplied announcements on updates to the Directive. The word “reportable” indicates that the waste type is reportable to the AER, upon request, through an annual digital data submission (DDS). Wastes that are “reportable” are either DOWs or other Reportable Oilfield Wastes as per Table 9.1 of AER Directive 058. 11.2 Hazard Information The hazard information section on the Waste Profile Sheets uses the WHMIS format for the communication of hazards. This section follows the Federal WHMIS 2015, which is expected to be fully implemented in all jurisdictions by December 2018. Refer to the relevant WHMIS regulations for specific details. WHMIS Class The hazard information applies to two major groups of hazards: physical, and health.

Physical hazards

based on the physical or chemical properties of the waste – such as flammability, reactivity, or corrosivity to metals.

Health hazards

based on the ability of the waste to cause a health effect – such as eye irritation, respiratory sensitization (may cause allergy or asthma symptoms or breathing difficulties if inhaled), or carcinogenicity (may cause cancer). Safety Data Sheets (SDS) Indicates a particular SDS(s) which may identify safety information for the waste more accurately. In most cases, the SDS is reflective of the contaminant information in the first section of the waste profile sheet. WHMIS Labels & Personal Protective Equipment This section identifies, via WHMIS symbols, the hazard type and the personal protective equipment and precautions which workers must employ to protect themselves during the handling and storage of the waste (i.e. gloves, respiratory equipment, eye protection, footwear, and clothing). Environmental The impacts that the specific waste could have on the environment. The major pathways of possible environmental concern are provided. Pathways may include surface water contamination, groundwater contamination, vegetation damage, air pollution, and fire / explosion.