Hazardous Waste Training

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					          Providence VAMC
Hazardous Waste Management Program

         Research Lab
 Hazardous Waste Training 2008

                               1 RCRA
           Hazardous Waste Management

Why do we have a HW Program?

  It is mandated by EPA, RI Dept.
   Environmental Management (RIDEM), and VHA

  Safety of Patients, Staff, and Students

  “Cradle to Grave” responsibility for our waste

                                             2 RCRA
          Hazardous Waste Management
 HW Program Elements

  1) Employee Hazardous Waste Training

  2) Hazardous Waste Identification

  3) Hazardous Waste Storage
     Accumulation Point (AP) Management
     Satellite Accumulation Point (SAP)

  4) Spill Response Procedures

                                           3 RCRA
Hazardous Waste Management


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                Employee Training

HW training is required for personnel
 managing accumulation (AP) & initial
 accumulation points (IAP)

Initial HW training should occur within 6
 months of a person assigned to a AP/IAP,
 then annual refresher.

It is NOT Health and Safety Training

 HAZCOM training

                                         5 RCRA
                Employee Training

HW training will be done by a person trained
 in hazardous waste management (e.g. VAMC GEMS

Training must include Integrated Contingency
 Plan Procedures (e.g. Spill Response Procedures)

Training must include hazardous waste
 procedures relevant to the position they are

                                          6 RCRA
  Hazardous Waste Management


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                Hazardous Waste Identification
Definition of a Hazardous Waste:
  Contaminated or spent chemicals that can no longer be used for
   their intended purpose, outdated or expired chemicals, and
   chemicals in poor containers (e.g. broken containers, missing labels,

  Acutely toxic chemical listed by name in 40 CFR 261
    (e.g. Sodium Azide; U and P Listed)

  A chemical listed by name in 40 CFR 261 from a non-specific
   source (e.g. Methanol Solvent; F Listed)

  Determined to exhibit a characteristic that the EPA has
   identified as making it a hazardous waste (e.g. isopropyl alcohol;
    D Listed)
      Ignitable (<140oF)
      Corrosive (pH <2, >12)
      Reactive (water, oxidizer, friction, etc..)

                                                              8 RCRA
           Hazardous Waste Identification

Examples of RESEARCH Hazardous Waste
  Mixed Isopropyl Alcohol: (Ignitable, D001)
  Trans Buffer (Toxic, F003 / Ignitable, D001)
  X-Ray Fixer & Rinse-water (Toxic, D011)
  X-Ray Developer (State Listed R006)
  Hydrochloric Acid w/ Methanol (Corrosive, D002
   / Ignitable, D001 / Toxic, F003)

                                           9 RCRA
            Hazardous Waste Identification

Some wastes may not be “hazardous waste”
 but must be handled following hazardous
 waste procedures
  Chemicals prohibited by the RI Narragansett
   Bay Commission for disposal to sanitary sewer

  Universal Waste
    Fluorescent Light Bulbs
    Rechargeable Batteries

  Used Oil

                                             10 RCRA
          Hazardous Waste Identification
Universal Waste: A special class of
 hazardous waste

  Batteries: Lead Acid, NiCad, Lithium, Silver

  Used lamps (FLB’s, Sodium Lamps, etc.)

  Mercury containing items, such as
   thermostats, thermometers, BP cuffs, some
   pressure gauges, some flow meters, etc

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                    Universal Waste
Universal Waste must be properly labeled
  “Universal Waste Batteries”
  “Universal Waste Lamps”
Universal waste may not be accumulated
 for more than one year
     (Note: Hazardous Waste may not
 accumulate for more than 89 days)

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  Hazardous Waste Management


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           Storage of Hazardous Waste
Initial Accumulation Points (IAP)
  A storage location at or near the point of
   generation where hazardous waste is initially

  Limits on the amount of waste that can be
   accumulated at the IAP.
    One container, up to 55 gallons per waste

  No time limit on accumulation

  Almost every Service has a SAP manager.

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             Storage of Hazardous Waste

Initial Accumulation Point Managers
  Have control over the waste stored in their area
  Responsible for weekly storage area inspections
  Responsible for contacting the GEMS Coordinator if
   storage areas requires a waste pick-up
  Responsible for training employees who place waste in
   their storage area.

RESEARCH IAP Managers are…
  Julie Newton
  Kerry LaPlante
  C. McGeary

                                                     15 RCRA
               Initial Accumulation Points

   IAP-03, RM 123 Hoods                 IAP-14, RM 125
                    Waste Streams
650-047 & 650-103              650-018, 650-019, 650-056

Methanol & DMSO               Developer, Fixer , Rinse water
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             Storage of Hazardous Waste
IAP Requirements
1. Compatible Containers (e.g. Acids in plastic/glass,
   Oils in metal containers)

2. Containers must remain closed when not adding

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          Storage of Hazardous Waste
IAP Requirements
3. Labeling: All waste containers must be
   labeled appropriately with the words
   “Hazardous Waste”
    & “Contents of Container”

      GEMS Coordinator can provide labels and containers

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         Storage of Hazardous Waste
IAP Requirements
4. Secondary Containment for containers
   (protect floor drains)

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          Storage of Hazardous Waste
IAP Requirements
5. Emergency Contact Information Posted
6. Have Spill Control Materials Available

                                       20 RCRA
             Storage of Hazardous Waste

IAP Requirements
7.Weekly Inspections
  No leaks
  No deterioration of containers
  Containers closed
  Everything properly labeled
  Labels face forward
  No incompatibles stored together
  Date and time of inspection
  Corrective actions taken
  Full name of inspector
     (Initials or nicknames not acceptable)

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Example of weekly inspection log

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           Accumulation Point Management
Room 135 & 227 – Flammable Storage
  SAP containers are brought here when full

  ASD placed on container

  90 Day Accumulation

  More than one container

  Proper Segregation

  Weekly Inspections

  HW labeled completely filled out

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          Hazardous Waste Management
What happens to your waste after
 it is picked up?
  We take it to our
    Central Accumulation Area
  We conduct field tests
   for disposal characterization
  We assign waste codes
  We keep a weekly inventory
   and running inventory of the waste.
  Waste must be off-site within 90 days.

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Hazardous Waste Management

Spill Response

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            Spill Response Procedures

Workers must be familiar will VAMC
 Integrated Contingency Plan (ICP)

Incidental spill
Non-incidental spill

   Report ALL spills to your supervisor,
        No matter what size it is

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                   Incidental Spills
Small quantity (e.g. Amount you would use on
 a lab bench or slight spillage when transferring
 from one container to another in a shop

Can be cleaned without outside assistance

Always use the appropriate PPE when
 cleaning up spills

Spill clean-up material is hazardous waste

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              Non-Incidental spill
Amount greater than normal use

Outside resources needed due either to
 quantity or PPE limitations

Notify VA Police (x4999)

Process is identified in EOC Manual and
 Integrated Contingency Plan

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         Spill Response Procedures

  Incidental         Non-Incidental
No Env. Exposure     Env. exposure

                                      29 RCRA
Spill Response Procedures

  Major spill
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          Hazardous Waste Management

                  THE END

 Contact GEMS Coordinator @ x2637

                                    31 RCRA
                                         Training Certificate
                                      RESEARCH SERVICE
                                      VA MEDICAL CENTER
                                                   Providence, RI

                                  PROOF OF TRAINING FOR VA EMPLOYEE

I affirm that I have reviewed the mandatory VA Research Hazardous Waste Training:

PRINTED NAME                                                    DATE


                                                                                    32 RCRA

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