Hazardous Waste Training - Envir by fjwuxn


									Hazardous Waste Training
     Environmental Health & Safety
              May 2008
        EH&S Contact Information
   Linda Vishino
       Environmental Compliance Officer
       vishinol@wustl.edu
       935-7864

   Donna Hall
       Environmental Compliance Manager (Danforth Campus)
       dhall22@wustl.edu
       935-4650

   Livi Isringhausen
       Environmental Compliance Manager (Medical School Campus)
       isringhausenm@wusm.wustl.edu
       362-6735

   Regulatory Reviews
   Review of Hazardous Waste
   Virtual Tour
                Hot Topics – Regulatory Inspections
Unprecedented number of surprise federal and state regulatory inspections since 4/1/08
Environmental Protection Agency (EPA)           Twice – hazardous waste inspections
Centers for Disease Control & Prevention        Select Agent inspection
United States Department of Agriculture         Inspection of researchers and animal facilities
(USDA)                                          involved in research with animal pathogens
Occupational Health & Safety Administration     Workplace safety – focus on construction
(OSHA)                                          activities
Fire Marshal                                    Three times – fire safety
Petroleum Insurance Fund                        Fuel storage tank leak detection systems

National Institutes of Health (NIH) Office of   Assess WU’s institutional oversight of
Biotechnology Activities (OBA)                  recombinant DNA research activities, including
                                                human gene therapy, plant and animal
Nuclear Regulatory Commission                   Review loss of two small, short half-life, very
                                                low activity implant seeds
           Hot Topics – Regulatory Inspections
Other Regulatory Directives
Drug Enforcement Agency (DEA)     Notice to WU that researchers must
                                  have a separate DEA research license
                                  for use of controlled substances in
                                  research and not use their DEA medical
                                  license (for prescribing medications) for
                                  research purposes

                                  Reminder – follow all DEA requirements,
                                  including fully securing and tracking all
                                  use of controlled substances, and use
                                  controlled substances only for approved
                                  medical or research purposes
Department of Homeland Security   Requesting information about specific
                                  chemicals of concern – location, access
                                  control – told WU will fall into a security
                                  risk category, but not which level
         Other Potential Inspections

   Department of Transportation (DOT) and Federal
    Aviation Administration (FAA)
       Last year, issued two Letters of Investigation and one Notice of
        Violation to WU for WUSM labs
            Letters sent to the Chancellor
            Considered serious compliance concerns by DOT/FAA
       Unannounced laboratory inspections
            Visiting WU approximately every two to five months
       Require personnel who ship samples (“dangerous goods”) to
            Package for shipment
            Paperwork
            Provide shipping papers for past two years
            Provide documentation of training
             Other Potential Inspections

   Additional Nuclear Regulatory Commission (NRC)
       Now regulating cyclotron produced materials
       Increased Controls – security requirements (e.g. fingerprinting)
       New decommissioning requirements
   Alcohol Tobacco Firearms (ATF) – alcohol usage in
    research laboratories
   EPA return visits
       Check progress on areas where there were issues
       Will return for surprise visits every year for next few years
   Missouri Department of Natural Resouces (MDNR)
    hazardous waste inspections
   Other?
          Hot Topics –
          Decommissioning Laboratories or Lab Areas
          When Faculty, Staff and Students Leave

   Give EH&S a minimum of two weeks
    advance notice before initiating any large
    scale cleanout of chemical containers
       Greater than 50 containers
   When faculty, graduate students, post docs
    or staff leave:
       Follow EH&S “Closing Laboratories”
          http://ehs.wustl.edu/new/safetycommittee.htm
    Review of Hazardous
(Chemical) Waste Regulations
 EPA’s Emphasis During Recent Inspections
            Main issues raised by EPA
   People saying “That’s not my responsibility” or “I don’t know” (how to
    manage hazardous waste)
   Containers missing labels or labels not filled out properly
   Full waste containers in labs longer than three (3) days
   Waste containers in labs longer than one (1) year
   Moving waste containers from one room to another
   Open containers
   Multiple full waste containers of the same waste stream
   Not dating containers with earliest date waste was collected
   High Performance Liquid Chromatography (HPLC) waste collection
    container lids with open holes
   Not having written documentation from EH&S that chemicals are
    permitted to be sewered
Guidance on EH&S Web Site

                          Compliance checklists available on-line
           Hazardous Waste Storage

   Segregate waste and materials by hazard class
       Flammables: segregate and store in flammables cabinet
       Acids: segregate & store in corrosives cabinet
          Segregate organic from inorganic acids
       Bases: segregate & store in corrosives cabinet
       Oxidizers
       Toxics
       Peroxide-forming chemicals
          Date when opened, date when declared waste
       Segregate anything that is incompatible or will react
       Can use tubs or trays in cabinets or on shelves to segregate
       Store all below eye level
         Hazardous Waste Management

   Chemical waste containers must be in good
    condition and appropriate for the contents
   Containers must be kept closed when not actively
    being used
   Submit request for pickup (RFP) within one (1)
    year of start date or when container is near full
   No more than one (1) waste container of a
    chemical waste stream per area/laboratory
   Waste containers must be kept in area/lab where
    waste is generated and not moved to other rooms
           Hazardous Waste Management

   Never evaporate hazardous chemical waste (in the
    fume hood or otherwise) or dispose of in the trash,
    on the ground, or down a drain
   Hazardous waste label must be applied upon
    beginning of waste collection (not before or after)
       Date must indicate when waste was first added to the
   Segregate by hazard class
   Store using secondary containment
       Cabinet
       Tray
        Hazardous Waste Management

   Hazardous waste label
    applied to container
   Include:                                                        HAZARDOUS WASTE
                                              Federal law prohibits improper disposal. If found, contact the nearest police,

       Description (no acronyms                 public safety authority or the U.S. Environmental Protection Agency.
                                               GENERATOR INFO: WASHINGTON UNIV. SCHOOL OF MEDICINE

        or abbreviations)                                       660 S. EUCLID, CAMPUS BOX 8229
                                                                         ST. LOUIS, MO 63110
                                                                     EPA ID NO.: MOT3000010857
       Principal Investigator (PI)                Contents:____________________________________________
        name and location                           ___________________________________________________
                                                    P.I. Name: _____________ Dept. Name: _________________
       Start date: MO/DAY/YR                   Bldg: __________ Room #: ______ Start Date: _________
                                                Environmental Health Collection Date: ___________________

   Send Request For                  HANDLE WITH CARE!

    Pickup to EH&S when
    filled or <1 year
             Hazardous Waste Management

   If smaller waste containers are combined or
    poured into a larger collection container:
       Small containers must meet all labeling and container storage
       Larger container must meet all labeling and storage requirements
        and be dated with the earliest date of the waste collected in any of
        the various containers
       List all compounds in mixture (do not use generic “halogenated
        solvents” or “solvent” designations, or trade names; keep compound
        list on or near waste container)
       All containers must be in room/lab where waste was generated
           Do not take containers to another room
      Hazardous Waste Labeling

   Containers without
    labels will not be
    picked up!
           Bad Label Examples

Missing Label

                Stored longer than one year;
                spell out names
Chemical Disposal
Request for Pickup (RFP)
              Chemical RFP
                  Form required by
                  Must be filled out
                  Submit electronically:
Use on-line RFP to request
disposal of chemicals
          Solid Hazardous Waste
   Tubes, tips, pipettes, microplates containing trace or
    residual hazardous chemicals
      Cannot be placed in regular trash
      Collect in sealable plastic bags or plastic-lined
       cardboard boxes
   Apply hazardous waste label to bag or container
    and treat as normal hazardous waste
   Bag or container must be kept sealed at all times
   Add waste to container inside fume hood to avoid
    occupational exposure
       Waste container can be placed in a chemical storage
        cabinet within the same lab
             Problem Hazardous Waste
   Shock or temperature sensitive
       Old ethers, organic peroxides, dry
        picric acid or picrates, etc.
   Air or water reactive compounds
   Gas cylinders/lecture bottles
   Poison by inhalation compounds
   Extremely toxic (LD50<5mg/kg)
   Mixed waste
      Chemical & radioactive
            Must meet both NRC and hazardous
             waste requirements
      Biohazard & chemical
   Contact EH&S immediately
           Hazardous Waste

   Make sure written Standard Operating
    Procedures (SOPs) are available for your
    research processes
       e.g. drying silica gel columns which are used to
        separate compounds in solvents – issue of
        blowing air through column versus pulling air
        through with aspirator and using solvent trap
          Use   trap and aspirator
   Keep chemical inventories up-to-date (at
    least once a year)
               Hazardous Waste Requirements for
               HPLC / Other Wastes

   Collection container must be
    properly labeled as hazardous
    waste and dated
   Collection container cap should
    have hole(s) sized to fit the effluent
    tube(s) (no open holes in cap) from:
        High Performance Liquid
         Chromatography (HPLC),
        Gas Chromatograph (GC),
        Mass Spectrometer (MS), or
        Other automated processor which
         produces hazardous waste

                                             Extra hole in stopper is a violation
            Other Hazardous Waste

   Rags, paper towels, absorbent pads, etc., contaminated with
    solvents or other hazardous chemicals
   Certain chemicals from x-ray and photographic film and
    photographic paper processors
   Metal filings from soldering, cutting, welding, grinding, filing or
    wiping lead metal, brass, etc., and sponges from soldering
   Cleaners or degreasers with hazardous constituents
   Aerosol cans containing hazardous materials
   Certain paints and adhesives – oil, enamel, acrylic, epoxy, etc.
       Latex paints must be totally dry before disposal in trash (absorb with
        kitty liter and dry)
           Hazardous Waste

   Unless you have in writing from WU EH&S
    that a waste stream is nonhazardous,
    assume that it is hazardous and needs to be
    sent through the EH&S hazardous waste
    collection program
       http://ehs.wustl.edu/hazmats/hazwaste.htm
             Equipment Disposal
   Hazardous material disposal
    required for:
       Refrigerated equipment
       Computers, monitors, and
        other circuitry
       Lamps
            HID
            Germicidal
            Fluorescent
            Metal halide
       X-ray or photo film containing
       Non-alkaline batteries
       Follow labeling, container closure
        and storage requirements found
        on EH&S web page
         Hazardous Waste Management

   Everyone in a laboratory, shop, art studio, or
    location where chemical waste is generated
    needs to know:
     How to properly manage the chemical waste
     What are the hazards of the chemical waste and
      how to protect themselves from the hazards
     What to do in the event of spill, release to the
      environment or exposure
   EPA will ask lab occupants at random to
    explain the process
              Hazardous Waste
   Penalties for:
        Hazardous waste label not filled out properly
        Start date is not on the label
        Lid is not secure
        Container is stored longer than one (1) year
             Notify EH&S through the on-line system to collect the container before the one year deadline
              passes, even if the container is not full
        Container is stored longer than three (3) days after the container is filled
             EH&S must be notified through the on-line system to collect the material the day the container
              is full
             To avoid this problem, contact EH&S before the container is full
       Waste is moved to another area/room
      Container and/or lid is leaking or damaged
      Container is stored next to incompatible materials
      Improper disposal
   Reminder – departments are responsible for any fines or penalties that are the
    result of violations in their areas
            Hazardous Waste Management

   EH&S needs a minimum of two weeks
    notice prior to cleaning out a laboratory or
       Dependent on size and timing of cleanout,
        outside vendors may be called in to assist at the
        expense of the department
         Chemical Inventories Required

   Contact EH&S to learn about inventory
     Environmental Database Specialist
     935-9845
End of Hazardous Waste
 Management Section
            Virtual Tour
Both Good and Bad Examples – You Decide
           Virtual Tour

Bad – label not filled out
Virtual Tour

               Good – segregation and labels
             Virtual Tour

                                            Good – containment & wrap for vacuum implosion hazard), but
                                            could use better label
Bad – no labels and secondary containment
                  Virtual Tour

Bad, bad, bad – open container, no label, no date, potential   Labeling issues
for overflow into sewer drain
                 Virtual Tour

Need for secondary containment   Hard to see in photo – filled over a “full” line and stored
                                 longer than three days in lab after full
                 Virtual Tour

                                Open container
Stored longer than one year
Virtual Tour

               materials –
               send in
               Request for
               Pickup to
Virtual Tour

               Convert to non-flammable
               scintillation cocktails
               whenever possible
Virtual Tour

Virtual Tour

               even if non-
Virtual Tour

                  Virtual Tour

Do not store chemical containers, particularly glass
containers, on the floor – potential to be kicked over and

                                                             Do not store anything within 18 inches of the ceiling or
                                                             fire protection sprinkler heads to allow sprinkler heads to
                                                             function properly in case of fire
Do not overfill glass and sharps collection
        Environmental Health &
   Phone:     362-6816
   Website:   www.ehs.wustl.edu
   Email:     esafety@msnotes.edu
   Fax:       362-1995

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