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)
       Management

  4) Spill Response Procedures

                                           3 RCRA
Hazardous Waste Management




EMPLOYEE
TRAINING



                      4 RCRA
                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

It is NOT HAZMAT, HAZWOPER, or
 HAZCOM training

                                         5 RCRA
                Employee Training


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


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

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

                                          6 RCRA
  Hazardous Waste Management




HAZARDOUS WASTE
 IDENTIFICATION




                        7 RCRA
                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   their intended purpose, outdated or expired chemicals, and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,
    etc.).

  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..)
      Toxic

                                                              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
   Button.

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

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


                                            11 RCRA
                    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)




                                      12 RCRA
  Hazardous Waste Management



HAZARDOUS WASTE
    STORAGE




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

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

  No time limit on accumulation

  Almost every Service has a SAP manager.

                                             14 RCRA
             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
                                                    16 RCRA
             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
   waste

                                                   17 RCRA
          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


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




                                      19 RCRA
          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
  Observations
  Corrective actions taken
  Full name of inspector
     (Initials or nicknames not acceptable)

                                              21 RCRA
Example of weekly inspection log




                            22 RCRA
           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


                                               23 RCRA
          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.



                                            24 RCRA
Hazardous Waste Management



Spill Response
 Procedures




                     25 RCRA
            Spill Response Procedures

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

Incidental spill
      V.S.
Non-incidental spill

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


                                       26 RCRA
                   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

                                              27 RCRA
              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


                                      28 RCRA
         Spill Response Procedures




  Incidental         Non-Incidental
No Env. Exposure     Env. exposure


                                      29 RCRA
Spill Response Procedures




  Major spill
                       30 RCRA
          Hazardous Waste Management

                  THE END


Questions??
 Contact GEMS Coordinator @ x2637




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



           VA-SPONSORED HAZARDOUS WASTE TRAINING
                                  PROOF OF TRAINING FOR VA EMPLOYEE




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


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                                                                                    32 RCRA

				
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