Document Sample
SOP 4 Powered By Docstoc
					Household Hazardous Waste

SOP 4.6: Aerosol Can Puncturing Procedures: Hand-fed and Mechanical

1. 2. 3. 4. 5. 6. 7. Introduction......................................................................................1 Regulatory and contractual requirements ...........................................1 Staff qualifications.............................................................................1 Safety precautions ............................................................................2 Health precautions ............................................................................3 Spill response ...................................................................................3 Processing aerosol containers ............................................................4

1. Introduction
Aerosol-can-puncturing devices rupture and empty the cans to classify as them as “empty.” These processed cans no longer contain HW and can be sold as scrap metal for recycling. The contents of aerosol cans are liquid or gas propellants. Propellants are hazardous materials and pose a safety hazard during the puncturing process because the containers are pressurized and flammable. Staff shall use extreme caution if aerosol-can-puncturing devices are used at this Facility.

2. Regulatory and contractual requirements
The management of waste aerosols is governed by the requirements established in the HHW program and state agency contract (Exhibit A); Occupational Safety and Heath Administration (OSHA) 29 CFR 1910.1000 and 1910.106(e)(3)(v); Code of Federal Regulation (CFR) 40, 261.7; Minn. Rules pt. 7510, 7045.0626, subp. 7; Minn. Stat. § 299F.011, subd. 4; Minnesota Uniform Fire Code; Minn. Rules; and local building and fire codes.

3. Staff qualifications
3.1 Training
3.1.1 The designated Program staff responsible for ensuring safety procedures are followed during

the aerosol puncturing process is the Facility Manager. This person shall enforce standards, rules, or policies as they relate to staff actions and conduct.
3.1.2 This Facility shall have a written training program that describes the management and

processing of aerosol containers relevant to job duties and shall include function-specific training, safety, regulatory, and emergency procedures.

4.6 Aerosol Can Puncturing Procedures


3.1.3 Staff shall be trained within six months of hire or starting a new position at this Facility, or be

supervised by trained staff until that time. Refresher training shall be conducted annually and properly documented.
3.1.4 Staff shall have thorough knowledge and training prior to the use of Facility aerosol puncture

equipment. Staff shall review all manufacturer operation manuals prior to processing cans to become familiar with equipment design, operation, and maintenance; see SOP 5.1 Equipment Maintenance.

4. Safety precautions
4.1 Training
4.1.1 Prior to sorting, managing, or preparing HW for highway transport, staff shall complete

Hazardous Categorization, Occupational Safety and Health Administration (OSHA), and DOT (or equivalent) trainings. Refresher training shall be conducted annually.
4.1.2 Staff shall be trained within six months of hire or starting a new position or shall be

supervised by trained and experienced staff; see SOP 2.3 Employee Right-To-Know.
4.1.3 Staff responsible for any aspect of hazardous waste management shall be trained relevant to

job duties, including contingency plan implementation; see SOPs 2.1 AWAIR and 2.10 HW Contingency Plan.
4.1.4 Only trained Facility staff shall manage abandoned or unknown waste. Staff shall be trained

on personal protective equipment (PPE) use and requirements. Staff shall also be trained to respond to spills in accordance with the HHW program and state agency contract. See Section 4.2 of this SOP and SOP 2.6 Spill Response.

4.2 Personal protective equipment (PPE) requirements
This Program may choose to implement a more restrictive PPE policy, as engineered solutions to environmental conditions and experienced staff judgment shall be used for unique conditions and situations. PPE shall be utilized if the potential for exposure remains after the institution of work practice controls; see SOP 2.4 Personal Protective Equipment. At a minimum, the following PPE shall be used while processing aerosols:       Safety glasses with side shields, goggles, or equivalent eye protection Face shield Footwear with reinforced toe or toe caps or equivalent foot protection Nitrile gloves or equivalent hand protection Chemical splash apron, Tyvek coveralls, or equivalent Respirator use (If Facility has respirator program, see SOP 2.5 Respirator Program.)

4.6 Aerosol Can Puncturing Procedures


5. Health precautions
5.1 Ventilation
 Select an open, well-ventilated area outside the Facility to perform the aerosol-puncturing process. Stay away from low-lying areas, buildings, and confined spaces. If puncturing aerosols inside Facility, ensure the process area is near exhaust fans or open doors and windows.   No smoking is allowed near the aerosol-puncturing area. Precautions shall be taken to avoid inhaling aerosol vapors during the puncturing/crushing procedure, as aerosol vapor particles are small and easily pass through skin and lung tissue to enter blood stream.  Some aerosol contents are classified as Class I liquids (liquids with a flashpoint from 0° to 100° F). When Class 1 liquids are bulked or punctured indoors, the area shall have a minimum ventilation of one cubic foot per minute per square foot of floor space.  The major propellants of aerosol cans (propane and butane) are extremely flammable. The aerosol-puncturing device filter DOES NOT capture propane and butane vapors. These gases are heavier than air and will vaporize into the surrounding air very quickly during the puncturing process, producing a flammable hazard.

5.2 Medical monitoring
Staff exposed to HW substances for 30 or more days per year shall receive an annual medical monitoring examination per OSHA regulations. It is this Program’s responsibility to maintain a medical surveillance program; see SOP 2.6 Medical Surveillance.

6. Spill response
6.1 Facility staff shall be responsible for cleaning up incidental spills that could happen in the course of
packing HW that may pose potential safety or health hazards. Only trained emergency response staff or an emergency contractor shall respond to control and clean up of spills requiring assistance beyond the capabilities of Facility staff. Facility staff shall be trained and be able to respond to small spills only. This Facility shall make prior agreements with emergency response teams or HW contractors who could be used in case of an emergency. See SOP 2.6 Spill Response and SOP 2.10 HW Contingency Plan.

6.2 Precautions shall also be taken to prevent environmental impacts. The Facility safety plan shall
include the use of aerosol-puncturing device. Facility staff shall request the local fire marshal to ensure aerosol-puncturing practice complies with local fire codes.

4.6 Aerosol Can Puncturing Procedures


7. Processing aerosol containers
7.1 Tools for processing aerosol cans
The following tools shall be used when processing aerosol cans:      55-gallon, UN-approved metal container or drum Filter for aerosol drum Two grounding straps (for aerosol drum and puncturing device) Screw driver Hand-fed or mechanical can puncture equipment

7.2 Selecting drum for aerosol wastes to be bulked into
Selecting containers for bulking aerosol depends on the waste type being processed. Paints and aerosol can contents can be bulked into a 55-gallon UN-approved metal drum or similar container.

7.3 Sorting aerosol containers
Sort aerosol cans into two categories (empty, not-empty) and place in separate containers.
7.3.1 Empty containers

 

Staff shall ensure aerosol cans are completely empty prior to disposal (trash or recycling) as residues remaining in the cans may be subject to federal and state regulations. Aerosol cans with plastic lids may be disposed of in the trash. If the can is going to be recycled, remove can lid prior to puncturing and recycle the metal. Spray nozzles do not need to be removed.

7.3.2 Cans containing product


Do not process cylinders or fire extinguishers with other waste aerosol cans. See SOP 4.8 Cylinder Evacuation and Valve Removal.


Place the unrestricted waste aerosol cans that have functioning spray nozzles onto Facility product exchange or reuse shelf.


Segregate cans into the applicable waste streams for processing. Aerosol cans requiring a separate waste stream shall be lab packed separately. Aerosol cans containing pressurized product may be shipped for HW disposal without draining contents. Five- through 55gallon (UN1A2 metal or UN1H2 poly) containers or DOT cubic yard boxes are acceptable for storage and transportation of non-punctured aerosol containers. See SOP 4.4 Waste Packaging.

4.6 Aerosol Can Puncturing Procedures



The following waste types shall be lab packed. DO NOT puncture aerosol cans with the following ingredients:          Ethyl ether Chlorinated compounds Oven cleaners Pesticides Freons and foamers Cylinders Fire extinguishers Dioxins*
*Dioxin waste types include unknown herbicides, pentachlorophenol, silvex, 2,4,5-TP, Woodlife, hexachlorophene, Ronnel, 2,4,5-T, trichlorophenol, and fenchlorophos.

7.3.3 Waste aerosol container markings

Mark aerosol waste lab pack container with the words:    Inside packages comply with prescribed specifications. DOT E-11396 All other markings as specified with the state-contracted hazardous waste disposal company.

7.4 Puncturing aerosol containers
Facility staff shall always ground steel drums prior to starting the aerosol-puncturing process. To ground steel drums, attach one end of a bonding wire to the drum and attach the other end to an electrical ground. For more information on grounding, see Attachment A of SOP 4.5 Waste Bulking. To puncture aerosol cans:     Presort cans into similar sizes to avoid adjusting the puncturing unit more than necessary. Remove lid from the aerosol container (spray nozzles do not need to be removed). Regulate the pressure release by slowly lowering and raising the puncturing unit’s handle. This minimizes pressure build-up and leakage around the puncturing unit’s gasket. Watch for “fume rings” around the escape valve of the aerosol-puncturing device, as the collection filter of the aerosol-puncturing device will not be able to collect all of the propellant gas as it is released.   It is recommended that cans that contain solvents, degreasers, and lubricants be punctured last to help clean out puncturing unit. Use pressure-release valves to avoid over and under pressure problems due to temperature fluctuations. Valves with micropore membranes fit containers with ¾-inch bungs and can be used while storing and transporting containers.  Aerosol can devices puncture and capture the can contents during the aerosol bulking process. There are two types of can puncturing equipment: manual and mechanical.

4.6 Aerosol Can Puncturing Procedures


7.5 Manual aerosol can puncturing device procedure
Manual can puncturing units do not require power and are manually operated.
Unit operation

      

Secure puncturing device to the top of a rust-free 55-gallon, closed-top drum to collect the aerosol liquids. Facility staff shall use extreme caution while loading aerosol cans into puncturing cylinder or appropriate puncturing compartment. Push the lever to activate the puncturing device. Allow a few seconds of contact time before releasing the lever to raise the puncturing pin. Completely empty can by allowing contents to drain into the 55-gallon containment drum. Remove punctured can from unit and air dry in a well-ventilated area prior to recycling. Full 55-gallon drums may be disposed of using the state-contracted HW disposal company.

7.6 Mechanical aerosol-can-puncturing device procedure
More sophisticated aerosol-puncturing units have a pre-loader which moves the aerosol can into a sealed cylinder. This cylinder is ruptured and crushed into a thick wafer by a piston. The propellant and concentrate then pass through a check valve in the piston and are collected in a pressure tank. A scavenger system accepts the remaining propellant and reduces internal pressure to atmospheric before the opening the cylinder. Capacities of mechanical puncturing devices range from 120 to 2,000 cans per hour. Available features include explosion proofing and electric, hot oil, and steam heaters to vaporize residual propellant.
Unit operation

      

Clear all obstructions from hoses, motor, and hydraulic pump. Check the hydraulic oil level and ensure the guides are greased. Secure puncturing device to the top of a rust-free 55-gallon drum to collect the aerosol liquids. Check unit by performing a practice or dry run prior to placing cans in crushing compartment. Place can in crushing compartment and engage equipment. Cans are discharged from unit. Air-dry empty cans in a well-ventilated area prior to recycling. Full 55-gallon drums may be disposed of using the state contracted HW disposal company.

7.7 Managing empty and drained aerosol cans
Empty, steel aerosol cans are accepted by the steel industry; verify with local recycling programs. Prior to recycling cans, completely empty and remove the plastic lid. Spray nozzles do not need to be removed. Residues remaining in aerosol can may be subject to federal and state regulations so complete product drainage is recommended.

4.6 Aerosol Can Puncturing Procedures


7.8 Clean-up and maintenance of aerosol-can-puncturing devices
Proper operation and maintenance of puncturing equipment is required for its safe use. Maintain a strict clean-up schedule to keep the aerosol-can-puncturing device in good working order, including:   Use a putty knife to clean accumulated materials from the crushing platform, walls, and container funnel. Ensure proper cleaning of the puncturing unit to prevent its plastic sleeve from “freezing” in place. If plastic sleeve is frozen, it becomes very difficult to remove or replace the gasket. See owner’s manual for all scheduled maintenance, repair, and adjustments. Clean aerosol-puncturing device after each day’s use. After each use, remove and clean the following parts of the puncturing device: 1. Plastic sleeve 2. Puncturing unit throat 3. Gasket


4.6 Aerosol Can Puncturing Procedures