The production is committed to minimizing impacts on the environment and maintaining compliance with Federal, state, and local environmental regulations. It is the responsibility of Production’s individual departmental coordinators and supervisors in conjunction with the Safety Program Director to ensure compliance with all applicable environmental regulations. Please contact the Production Safety Consultant with any questions, concerns or if you require assistance with any environmental compliance, hazardous waste or other regulations at any time.
- All surface coating (i.e., painting) operations that involve spray-applied coatings of non-architectural set pieces should take place in a properly constructed and permitted spray booth. All coating operations should comply with all applicable environmental regulations. If the use of a spray booth is not possible, please contact the Production Safety Consultant prior to the initiation of coating operations to ensure regulatory compliance.
- Generally, spray-applied coatings should be applied with a high volume, low pressure (HVLP) spray gun, electrostatic application, airless or air-assisted airless spray gun, or an equivalent technology. Spray gun cleaning should prevent atomizing cleaning solvents. All solvents used to clean spray guns should be properly contained.
- Lacquer thinner should not be used to clean spray guns or for any other purpose than thinning lacquer-based coatings. Alternative solvents are available for spray gun cleaning and wipe-cleaning. The use of fluid-recycling parts washers is recommended.
- The production encourages the use of water-based and no-and-low-Volatile Organic Compound (VOC) products.
- All air quality permit regulations, including record-keeping requirements such as VOC logbooks, should be strictly adhered to. Air quality permits are generally required for spray booths, coating operations, portable generators, etc. Copies of permits and log books should be kept with Production files.
- In California, ensure that Production complies with the local Air Quality Management District (AQMD) or Air Pollution Control District (APCD) VOC and other regulations.
- Only water-based coatings should be sprayed on set unless approved in advance by the Production Safety Consultant and the local fire authority. Do not spray lacquer or other flammable materials without pre-approval.
- Use all materials in accordance with manufacturer recommendations for application and thinning.
- All containers must have tight-fitting lids. Keep lids on containers when not in use.
- Products should be kept in their original, labeled containers. If materials must be transferred into secondary containers (i.e., can or bottle), ensure that the secondary container is properly labeled with, at a minimum, the identity of the material (i.e., chemical name) and the proper hazard warnings (eg., flammable, corrosive, etc.).
- Ensure that routine and non-routine activities including vehicle washing, vehicle/equipment maintenance, pressure washing, and other industrial activities do not impact or discharge to storm drain systems. Utilize best management practices to ensure pollutants are not discharged to the storm drain system, rivers and ocean.
- Vendors are available that can assist with capturing wastewater before it enters the storm drain.
- Identify all equipment and systems used outdoors that may spill or leak pollutants. Regularly inspect these areas to detect potential leaks, or identify conditions that may result in the development of leaks.
- Cover waste disposal and material storage containers when not in use.
- Do not dispose of chemicals in the garbage, storm drain or the sewer.
Hazardous Materials Abatement
Special precautions must be taken when dealing with asbestos , lead-based paint, and other potentially hazardous building materials. The Production Safety Consultant provides project management services for contractors during the survey, assessment and stabilization or removal of hazardous materials from production facilities and locations. The Production Safety Consultant should be notified well in advance of the beginning of work on all construction projects in order to identify potential hazardous materials and safety issues.
Hazardous Waste / Materials Spill Response and Management
- Hazardous waste and regulated materials must be handled, stored and disposed of in accordance with local, state and Federal requirements.
- Measures should be taken to protect employees in the workplace from hazardous chemicals to which they may be exposed to during normal work operations or in any reasonable foreseeable emergencies.
- Use all chemicals in accordance with manufacturer recommendations.
- Always read and comply with the manufacturer’s labels and Safety Data Sheets (SDS) and maintain a current chemical inventory.
- Productions should obtain safety data sheets (SDSs) for all chemicals used or stored. SDSs are available from the chemical supplier or manufacturer. SDSs must also be made available to all employees working with or near the hazardous chemical. SDSs can also be obtained by calling the SDS Hotline at (888) 3627416.
- Hazardous waste (corrosive and flammable materials, asbestos contaminated debris, lead contaminated debris, etc.) is regulated waste and must not be mixed with other waste. Acute Hazardous Wastes are those that can be fatal to humans or animals in low doses.
- Typical hazardous wastes generated by production include but are not limited to paints and solvents.
- In the case of an incident or emergency, call 911 as necessary. Contact your local hazardous waste vendor for assistance and the Production Safety Consultant for additional assistance and to report the issue.
Hazardous Materials Spill Response
- Measures should be taken to protect individuals from exposure, isolate the spill and prevent the material from entering a storm drain. The production should have a spill kit or other spill supplies in advance for small spills.
- Larger spills must be cleaned up by trained professionals. Contact ESIS On Call at (855) 913-2784 for assistance with emergency spill response and to coordinate any necessary regulatory notification(s). Always, keep the Production Safety Consultant updated on the status of any hazardous materials spills / cleanups.
Hazardous Waste Management
- Production, typically care of the Construction Coordinator and / or Lead Scenic is responsible for proper hazardous and regulated waste management in accordance with local, state and Federal requirements. Other Department heads of departments generating hazardous waste are also responsible for proper hazardous waste management of those waste streams. Production is responsible to understand and adhere to Federal, state, local, as well as additional or overriding requirements based on location.
- Productions should:
- Determine their generator status and proceed accordingly, per the guidelines in the Hazardous Waste Generator Chart.
- Obtain an EPA or State ID number as required
- Report ID number to the Production Safety Consultant
- Arrange for necessary training
- Manage waste onsite in accordance with regulations Proper accumulation, storage, labeling, signage, inspection, etc.
- Coordinate with hazardous waste vendor for offsite shipment
- Complete a Weekly HW Inspection Form
- Sign and retain transportation documents (aka Manifests)
- Manifests must be kept with production files and a copy forwarded to the Production Safety Consultant
- Comply with Federal, state and local regulations regarding other manifest submission requirements
- Never dispose of chemicals in the trash, storm drains, or the sewer
Transportation of Dangerous Goods
It is prohibited to ship or transport dangerous goods without specific training and certification. Specific regulations are set by the Federal Aviation Administration (FAA) and Department of Transportation (DOT) and apply to both production and personal goods. Common examples of dangerous goods which are prohibited to ship or transport without proper authorization and documentation include, but are not limited to:
- Pyrotechnic materials such as explosives,
- Blank ammunition,
- Lithium ion batteries (cameras, drones, power tools, etc.),
- Other specific battery types,
- Aerosol canisters (hair spray, canned air, lubricants, adhesives, etc.),
- Compressed gas cylinders (propane, CO 2†, nitrogen, etc.),
- Flammables or combustibles (solvents, lacquers, rubber cement, etc.),
- Paint, sludge and chemical waste,
- Other hazardous wastes.
A trained and certified shipping firm should be utilized utilized to ensure that dangerous goods are properly packaged and labeled. Prior to shipping any dangerous or potentially dangerous goods.
Sustainability & Recycling
The Production is encouraged to implement sustainable production practices and to recycle and reuse materials when possible. The PGA Green Production Guide is a valuable resource for sustainable production best practices, tips, green vendors, etc. The Green Production Guide can be accessed at www.greenproductionguide.com .
In addition, the PGA Green Production Guide offers a carbon calculator for productions to assess their environmental impact. Please forward a copy of the completed carbon calculator to the Production Safety Consultant when the production wraps. Contact the Production Safety Consultant for additional information on sustainable production practices.