Whenever I am doing a Chlorine project this always comes up, as I almost always try and get anyone who is using elemental chlorine to make the switch to “bleach”, or sodium hypochlorite (NaOCl). Too many facilities are not capable of safely storing and handling elemental chlorine – that is just a hard fact. These businesses who are using “short-filled” cylinders, a 1-ton cylinder filled only with 1,500 pounds, in order to avoid PSM application think that since PSM (or RMP) is not applicable that there are no OSHA standards that cover their use of the chlorine. Thus the environment and management system around the handling and storage of this Highly Hazardous Chemical (HHC)/Extremely Hazardous Substance (EHS) fall WAY SHORT of what is needed. So for these businesses we can use an INHERENTLY SAFER alternative that if they were doing all they needed to do to safely manage their Cl2, it would also be cheaper for them.
But wouldn’t we have to count the amount of Cl2 in the bleach and maintain those amounts less than 1,500 pounds of chlorine?
No, and here’s why…