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VIEWS: 304 PAGES: 215


                      For the




                  Casey Stephens, Director
      Citrus County Division of Solid Waste Management
                Citrus County Central Landfill
               230 West Gulf to Lake Highway
                   Lecanto, Florida 34461
                             TABLE OF CONTENTS

CHAPTER 5    MEDICAL MONITORING PROGRAM                          32
CHAPTER 9    MOBILE HW COLLECTION                               71
CHAPTER 16   BULKING HAZARDOUS WASTE                            116
CHAPTER 19   UNIVERSAL WASTE (UW) MANAGEMENT                    136
CHAPTER 22   DOT SECURITY PLAN                                  152
CHAPTER 25   MANAGING MERCURY WASTE                             168
CHAPTER 26   MANAGING ASBESTOS WASTE                            174
CHAPTER 27   MANAGING PCB WASTE                                 178
CHAPTER 28   MANAGING METH LAB WASTE                            183
CHAPTER 29   MANAGING RADIOACTIVE WASTE                         186
CHAPTER 31   LOCK OUT / TAG OUT (LOTO) PROGRAM                  194
CHAPTER 32   ERGONOMIC SAFETY                                   202
CHAPTER 33   OSHA: HEALTH AND SAFETY                            206


The Citrus County Division of Solid Waste Management developed these best management
practices guidelines to comply with O.S.H.A.’s Hazard Communications Standard, Title 29 of the
Federal Regulations 1910.1200. These guidelines are not hard and fast rules, but are meant to
provide information and guidance to staff members for the operation of the Citrus County
Hazardous Waste Collection Center (HWCC). A copy of this manual will be available for
inspection at the Citrus County Division of Solid Waste Management, 230 West Gulf-To-Lake
Highway, Lecanto, FL, 34461. Many of the guidelines and procedures found in this manual have
been incorporated, with permission, from those suggested procedures written by the Minnesota
Pollution Control Agency, 520 Lafayette Road, St. Paul, MN.

In 1976, Congress passed the Resource Conservation and Recovery Act (RCRA) to protect the
public’s health and the environment from the improper management of hazardous waste, which
have been incorporated into these best management guidelines; see Chapter 23 on RCRA.

On February 12, 1985, Florida received final authorization from the U.S. Environmental
Protection Agency to administer its own hazardous waste management and regulatory program
under the Resource Conservation and Recover Act (RCRA). The most important feature of that
authorization is Florida’s agreement to issue permits that conform to the regulatory
requirements of the law, to inspect and monitor activities subject to regulation, to take
appropriate enforcement action against violators and to do so in a manner no less stringent
than the Federal program.

Citrus County hazardous waste regulations are referenced through the Florida Administrative
Code (FAC), section 62-730.        Regulations controlling hazardous waste through the
Environmental Protection Agency (EPA) are contained within 40 CFR (Code of Federal
Regulations) Parts 260 – 370. Because of EPA rule, 40 CFR Part 311, Citrus County
employees who work with hazardous wastes are also covered under Occupational Safety and
Health Administration (OSHA) regulations which are listed in 29 CFR 1910.120. In addition, the
packaging, handling and transportation of hazardous wastes are referenced through the
Department of Transportation (DOT), 49 CFR Parts 106 – 178.


The Citrus County Hazardous Waste Collection Program handles the collection of Household
Hazardous Waste (HHW) and Conditionally Exempt Small Quantity Generator (CESQG) wastes.

To this end, the Director of the Division of Solid Waste Management, within the Citrus County
Department of Public Works, oversees the proper compliance and direction of this Program.

The Customer Service Supervisor is charged with coordinating the operations of the Household
Hazardous Waste (HHW) Collection Program, Small Quantity Generator (SQG) Inspection
Program, hazardous waste staff members, and Solid Waste Technicians.

The Hazardous Waste Coordinator will provide daily management of the HW Collection Program
and will supervise the operations of the Hazardous Waste Specialist, Technician, Assistant, or
other staff members who may be called to work at the Hazardous Waste Collection Center.

The Hazardous Waste Specialist assists the Household Hazardous Waste Coordinator, inspects
Citrus County businesses which may dispose of hazardous wastes and may be called on to
supervise hazardous waste operations, in the absence of the HW Coordinator.
The Hazardous Waste Technician and Assistant assists the HW Coordinator and HW Specialist
with the acceptance, storage, packaging, handling and shipping of hazardous waste materials.

All assigned, HW staff members are responsible for the proper housekeeping and maintenance of
their collection site, equipment, and supplies. HW staff consists of personnel who are trained and
familiar with this facility’s operating guidelines, rules, requirements and expectations.


The Citrus County Hazardous Waste Collection Center currently accepts household paints and
tars, flammable liquids, oxidizers, flammable solids, corrosives, pesticides, hazardous wastes, a
limited amount of Division 1.4 materials from Citrus County households and other materials
normally found within a county residence. The HW staff will also refer or assist CESQG
businesses with safe, convenient and acceptable methods of disposal for their hazardous wastes.

The Citrus County HW collection program is funded, in large part, by an annual assessment, paid
by each homeowner, for the collection and proper disposal of household hazardous waste.
Currently, renters and homeowners within Citrus County are allowed to dispose of sixty pounds of
properly labeled household hazardous waste to this facility, per visit, for no additional charge to
the customer. The expense for appropriate and legal disposal of hazardous waste is very high. In
many instances, the disposal cost for a hazardous waste product will be more than its’ original
purchase price. High expenses are caused by several factors which include strict regulations
governing the handling, storage, packaging, transportation and disposal of hazardous waste and
the very large costs of liability associated with the handling and disposal of hazardous waste.

The Board of County Commissioners contract with several, licensed, hazardous waste
transportation and disposal companies to handle the packaging, transportation and disposal of the
waste collected at the Citrus County HW Collection Center. Universal wastes are also accepted,
stored and properly disposed of through licensed and approved contract carriers.

Citrus County residents are permitted to drop off household wastes, including paint, pool
chemicals, lawn and garden products and automotive products during the collection center’s
normal operating hours, on Tuesday, Thursday and Friday, between 9:00 a.m. and 1:00 p.m.
Also, to provide convenient disposal for those residents who cannot bring their household wastes
to the center during weekdays, the HWCC will hold quarterly, Saturday HW collection events.

HW participants and their vehicles are permitted access to the front of the HW Collection Center.
This facility is located at the southwest corner of the Citrus County Solid Waste Management
complex. At the scale house, participants will be directed to drive to the HW Collection Center,
park in front of the Center and shut off their vehicle. Smoking is prohibited at the Collection
Center facility.

                               WHAT IS HAZARDOUS WASTE

Household hazardous waste is exempt from federal regulations under Subtitle C of the Federal
Resource Conservation and Recovery Act (RCRA). The U. S. Environmental Protection Agency
defines which solid wastes are hazardous, within the Code of Federal Regulations (CFR), Chapter
40, Part 261.4.

Household Hazardous Waste (HHW) is defined as any material derived from households (single
and multiple family residences, condominiums, hotels and motels) that contain hazardous
chemicals or exhibit any characteristic (ignitability, corrosivity, toxicity, reactivity) of hazardous
waste. Examples of HHW include residential paints, tars, solvents, lead-acid batteries, pesticides,
herbicides, insecticides, oven cleaners, aerosols, pool chemicals, and automotive products.
These wastes can pose a serious health threat to the user as well as the environment, when
disposed of improperly.

Household products which are delivered by county residents are considered waste products when
delivered to and stored at this Hazardous Waste (HW) Collection Facility. Such products must
comply with EPA storage regulations found in 40 CFR. When household waste is shipped from
this facility for proper disposal, it is then governed as hazardous waste under DOT regulations
found in 49 CFR. It is estimated that each U. S. household throws away as much as 21 pounds of
HW per year. Many of these items contain the same chemicals found in business waste that
must be managed in accordance with EPA regulations. Although federal regulations exempt
Household HW from being classified as a hazardous waste, many household hazardous wastes
are improperly deposited with regular household garbage into landfills, burn barrels, municipal
sewers or septic tanks.

Disposal by these methods can pose serious health and safety risks to those who come in contact
with these materials. Although it is estimated that HW constitutes only about .05% to 1.0% of the
municipal sold waste stream, improper HW disposal can cause significant environmental damage.
Managing HW to be separate from the municipal solid waste stream becomes essential for
reducing the harmful impact to the environment and to those individuals who may come in contact
with such waste.


This facility should be maintained and operated to minimize the possibility of a fire, explosion, or
any unplanned sudden or non-sudden release of hazardous waste or hazardous waste
constituents to air, soil, or surface water that could threaten human health or the environment.

All facility communications or alarm system, fire protection equipment, spill control equipment, and
decontamination equipment, where required, should be tested and maintained in accordance with
manufacturer's recommendations and as necessary to assure its proper operation in time of

Facility personnel should maintain adequate aisle space to allow the unobstructed movement of
personnel, fire protection equipment, spill control equipment, and decontamination equipment to
any area of facility operation in an emergency.

Whenever hazardous waste is being poured, mixed, or otherwise handled, all personnel involved
in the operation should have immediate access to a walkie-talkie or other emergency
communication device.

Normal operating procedures requires that there be two personnel on site at all times. If there is
ever just one employee on the premises while the facility is in operation, he/she should have
immediate access to a device, such as a telephone (immediately available at the scene of
operation) or a hand-held two-way radio, capable of summoning external emergency assistance.
Telephones and radios should not be used or placed in areas where the atmosphere may become
explosive due to the presence of flammable vapors, dusts, or gases. For further information,
refer to the Emergency Incidents and Contingency Plans for the Citrus County Central Landfill.
                                      CHAPTER ONE
                                 HAZARD COMMUNICATION
                                  STANDARD (HAZ-COMM)
                 Waste                             (Revised December 2009)
                             In years past, there were no assurances that workers would be
made aware of chemicals with which they might come into contact at the workplace. Labels on
containers and warning sheets did not always provide adequate information of potential hazards
or emergency spill/leak provisions. That is why the federal government decided to establish a
uniform set of regulations that mandates employers provide information to workers about
workplace safety. OSHA's Hazard Communication Standard 29 CFR 1910.120 requires
employers to develop a written hazard communication program for their employees, and to
inform and train employees regarding the correct way to use cleaning products. This chapter is
designed to explain the basic Standard as it applies to our hazardous waste staff members.

Employers are required to fully evaluate all chemicals in the workplace for possible physical and
health hazards. The information relating to these hazards should be made applicable to all
employees during normal working hours or emergency occurrences. It should also include
information on how employees will be trained on hazardous chemicals, including how to
recognize, understand and use labels and Material Safety Data Sheets (MSDS), as well as using
safe procedures when dealing with emergency incidents. The information contained in this section
can be used to help satisfy our HW facility’s requirement for a written Hazard Communication.

In turn, the employee should be responsible for their own safety and the safety of their co-
workers. They should pay attention to warning signs, read labels and Material Safety Data Sheets
and follow instructions. If any doubt exists, they may obtain additional information by asking a
supervisor or, in some cases, by contacting the product manufacturer. Although an employer is
required to follow government mandates for workplace safety, the employee should take
responsibility to know all they can about potential hazards at the workplace and how to work with

This Hazard Communication Standard does not apply to tobacco products, wood or wood
products, food, drugs or cosmetics intended for personal consumption. A copy of this Hazard
Communication Standard has been made a part of the Household Hazardous Waste Operating
Procedures and will be presented to each employee who handles or comes in contact with
hazardous waste and will also be posted at the HW Collection Center and the front office of this
Solid Waste Management facility, for reference.

Operation of the Hazardous Waste Collection Center presents a challenge to meeting the Hazard
Communication Standard, since the potential exists for workers to come in contact with numerous
hazardous wastes and materials. Therefore, it is important for workers to exercise the general
safety standards/procedures presented in this manual at all times while working in the Customer
Service Area or in the HW Collection Center.


The Federal Government mandates that all containers of hazardous chemicals be properly
labeled by the manufacturer. Each manufacturer will use a different format, but all are required to
include similar types of information. All labels for hazardous materials must include words and/or
symbols to tell the consumer the:

      Common name of the product
      Name/address/emergency phone number of the manufacturer
      Physical or health hazard (toxic, flammable, reactive, corrosive)
      Signal words (Danger, Warning, Caution)
      Precautionary measures
      First-Aid instructions
      Special instructions (e.g. for children)

The above information will provide guidance to an employee about possible hazards and basic
steps which can be taken to protect against risks associated with a material. A label may contain
valuable information but does not always contain specific data needed for workplace safety.

The Hazard Communication Standard also requires all employees to maintain Material Safety
Data Sheets (MSDS) for every hazardous chemical in use. The MSDS is the key to workplace
safety. It will provide vital information about the hazardous materials in use at the workplace.

As is common to labels, an MSDS will generally contain the same information; however, the
format may be different for each manufacturer. All MSDS will cover the following information:

       1. Identity – the name of the chemical; the manufacturer’s name, address, phone number
           and the date the MSDS was prepared;

       2. Hazardous ingredients – the components that make up this particular hazardous
          material, the chemical components and their common names;

       3. Physical and chemical characteristics – appearance, odor, color, boiling point, vapor
          pressure, vapor density, solubility in water, melting and evaporation rating;

       4. Fire and explosion hazard – indicates whether a material might catch fire or explode
          and how to handle these hazards;

       5. Reactivity – indicates whether a material is stable, tells conditions under which a
          material may explode or catch on fire and how to avoid these situations;

       6. Health hazard – indicates routes of entry / exposure (inhalation, ingestion, injection or
          contact) signs and symptoms of exposure (eye irritation, dizziness, rash, headache),
          plus emergency first-aid procedures;

       7. Precautions for Safe Handling and Use – handling and storage procedures, spill or
          leak procedures and disposal procedures;

       8. Control measures – indicates the personal protection (eye wear, gloves, aprons,
          coveralls, etc.) necessary when handling the material, personnel hygiene practices.

Because household hazardous waste is exempt from federal regulations, providing an MSDS to
staff is not a requirement of the HW Collection Center. In addition, it would be extremely difficult
to provide an MSDS for every consumer product that could potentially be brought into the center.
And, due to the nature of the program, many materials come in as unknown, which makes it
difficult to obtain the specific MSDS for materials.

Providing MSDS to members of staff can be a valuable information tool. Therefore, a book of
MSDS will be kept within the Hazardous Waste Collection Facility at all times. This book will
include both generic MSDS as well as specific MSDS for any chemicals purchased for use at the
collection facility. This MSDS book will be available to employees at all times during normal
working conditions or emergency incidents. In addition, the book entitled Household Chemicals
and Emergency First Aid will be kept at the HWCC facility at all times. This book contains
information on common brand name household products including their hazardous ingredients
and disposal procedures and is a very good source of information.

                           HAZARD COMMUNICATION TRAINING

Hazard Communication requires that employers train their workers about hazardous chemicals in
the workplace. This guarantees the employee the ―right to know‖ about potential hazards in the
facility operation or whenever a new hazard is introduced into the workplace. Specifically, training
must include methods of determining the presence or absence or release of hazardous
chemicals, the physical and health hazards associated with chemicals in the workplace, measures
to protect the employee and details of the employer’s written Hazard Communication program.
Training is the key to worker awareness and safety. Take it seriously and get as much
information as possible from it. Hazard training for HW Collection Center workers will include
monthly Guidelines manual refresher training, along with the need for the following certifications:

Front Gate NFPA 704 Sign

NFPA 704 is a standard maintained by the U.S.-based National Fire Protection Association. It
defines the "fire diamond" used by emergency personnel to quickly and easily identify the risks
posed by nearby hazardous materials. The four divisions of a NFPA 704 sign are typically color-
coded, with blue indicating level of health hazard, red indicating flammability, yellow (chemical)
stability/reactivity, and white containing special codes for unique hazards. Each of health,
flammability and reactivity is rated on a scale from 0 (no hazard; normal substance) to 4 (severe
risk). A 704 display sign is mounted on the front of the hazardous waste collection facility
displaying a value of 4 for red, 3 for blue, 3 for reactivity, and OXY for oxidizers.

HW Coordinator
           40 Hour OSHA HazWoper Training (29 CFR 1910.1200 and 29 CFR 1910.134)
           8 Hour HazWoper Refresher Training (29 CFR 1910.1200 and 29 CFR 1910.134)
           SWM/HW Employee Right-To-Know Training by RTK Coordinator or Supervisor
           FEMA, NIMS, Incident Command 100, 200, 700 and 800B.
           DOT Regulations for Hazardous Materials Transportation (49 CFR 172.704)
           DOT Regulations for Haz-Mat Transportation Refresher (49 CFR 172.704)
           Chemical Compatibility and Storage (TREEO) (40 CFR 262, 49 CFR 172, 177)
           Haz-Mat Chemistry for the Non-Chemist (TREEO) (40 CFR 262, 49 CFR 172, 177)
           Orientation to In-house, DOT Security Plan (49 CFR, Part 172.800)
           RCRA Hazardous Material Regulations for Generators
           40 Hour Fire/Rescue first responder First Aid and CPR
           8 Hour Florida first responder First Aid and CPR Refresher
           OSHA Hazard Communications Right to Know – RTK (TREEO)
           EPA Facility Spill Prevention and Control (TREEO)
           Florida DEP SQG Student Orientation Guide for SQG Inspectors
           Florida DEP, Class 1, 2 and 3 Landfill Operations Spotter Training (TREEO)
           Florida DEP, Class 1, 2 and 3 Landfill Spotter Training Refresher (TREEO)
           OSHA Forklift Safety Certification (29 CFR, 1910.178)
           Monthly, ongoing Safety and Procedure Manual Refresher Training

Hazardous Waste Specialist

            40 Hour OSHA HazWoper Training (29 CFR 1910.1200 and 29 CFR 1910.134)
            8 Hour HazWoper Refresher Training (29 CFR 1910.1200 and 29 CFR 1910.134)
            SWM/HW Employee Right-To-Know Training by RTK Coordinator or Supervisor
            FEMA, NIMS, Incident Command 100, 700 and 800B.
            DOT Regulations for Hazardous Materials Transportation (49 CFR 172.704)
            DOT Regulations for Haz-Mat Transportation Refresher (49 CFR 172.704)
            Chemical Compatibility and Storage (TREEO) (40 CFR 262, 49 CFR 172, 177)
            Haz-Mat Chemistry for the Non-Chemist (TREEO) (40 CFR 262, 49 CFR 172, 177)
            Orientation to In-house, DOT Security Plan (49 CFR, Part 172.800)
            40 Hour Fire/Rescue first responder First Aid and CPR
            8 Hour Florida first responder First Aid and CPR Refresher
            Florida DEP SQG Student Orientation Guide for SQG Inspectors
            Florida DEP, Class 1, 2 and 3 Landfill Operations Spotter Training (TREEO)
            Florida DEP, Class 1, 2 and 3 Landfill Spotter Training Refresher (TREEO)
            OSHA Forklift Safety Certification (29 CFR, 1910.178)
            Monthly, in-house Safety and Procedure Manual Refresher Training

Hazardous Waste Technician

            40 Hour OSHA HazWoper Training (29 CFR 1910.1200 and 29 CFR 1910.134)
            8 Hour HazWoper Refresher Training (29 CFR 1910.1200 and 29 CFR 1910.134)
            SWM/HW Employee Right-To-Know Training by RTK Coordinator or Supervisor
            FEMA, NIMS, Incident Command 100, 700 and 800B.
            DOT Regulations for Hazardous Materials Transportation (49 CFR 172.704)
            DOT Regulations for Haz-Mat Transportation Refresher (49 CFR 172.704)
            Chemical Compatibility and Storage (TREEO) (40 CFR 262, 49 CFR 172, 177)
            Haz-Mat Chemistry for the Non-Chemist (TREEO) (40 CFR 262, 49 CFR 172, 177)
            Orientation to In-house, DOT Security Plan (49 CFR, Part 172.800)
            40 Hour Fire/Rescue first responder First Aid and CPR
            8 Hour Florida first responder First Aid and CPR Refresher
            Florida DEP, Class 1, 2 and 3 Landfill Operations Spotter Training (TREEO)
            Florida DEP, Class 1, 2 and 3 Landfill Spotter Training Refresher (TREEO)
            OSHA Forklift Safety Certification (29 CFR, 1910.178)
            Monthly, in-house Safety and Procedure Manual Refresher Training

Hazardous Waste Assistant

            SWM/HW Employee Right-To-Know Training by RTK Coordinator or Supervisor
            Florida DEP, Class 1, 2 and 3 Landfill Operations Spotter Training (TREEO)
            Florida DEP, Class 1, 2 and 3 Landfill Spotter Training Refresher (TREEO) )
            Orientation to In-house, DOT Security Plan (49 CFR, Part 172.800)
            FEMA Incident Command Training, NIMS, Sections 100, 700 and 800B
            OSHA Forklift Safety Certification (29 CFR, 1910.178)
            Monthly, in-house Safety and Procedure Manual Refresher Training

                                   CHAPTER TWO
                              EMPLOYEE RIGHT TO KNOW
                                  (RTK) PROGRAM
                Waste                          (Revised December 2009)
                            Because the facility staff have a ―reasonable‖ potential for
exposure to chemicals, this Facility has implemented the following Right-to-Know (RTK)
Program. This RTK Program does not pertain to the chemicals collected as waste, but rather to
chemicals used within the Facility.

                       Regulatory and contractual requirements

Right-to-know requirements are established as part of the HW Hazard Communication
program, under direction of EPA’s 40 CFR Part 311, Hazard Communication and 29 CFR, Part
1910.120, Hazardous Waste Operations.

                              Implementing a RTK Program

Designate a Right to Know (RTK) Coordinator

Within this program, the Hazardous Waste Coordinator will act as the RTK Coordinator, who
will be responsible for implementing the Hazardous Waste Right to Know Program.

Obtain information on chemical and physical hazards

The employer will maintain, at the HW Collection Center, copies of the required MSDS sheets
for each hazardous chemical which are being used by staff and should ensure that they are
readily accessible to staff when they are in their work area(s).

Right-to-know Manual

This facility will alphabetically compile RTK/Material Safety Data Sheets (RTK/MSDS) and fact
sheets into a notebook/manual and place such information within the yellow, ―HAZARD
INFORMATION CENTER‖ cabinet located at the HW Collection Center. The RTK coordinator
will first locate and determine a list of chemicals currently being used (trade or product name)
and obtain their corresponding MSDS sheets and any physical hazards fact sheets (such as
noise or heat). He/she will update this list as new hazards occur, new products are being
utilized or when new MSDS sheets are obtained.

      Chemicals/MSDS. Compile and maintain a list (in alphabetical order) of the
       chemicals/products purchased for facility use. MSDS are not mandatory on hazardous
       materials processed at the facility. This list will be updated as new chemicals are added.

      Physical hazard fact sheets. Heat stress is a common hazard, listed in the Chemical
       and Physical Hazards List. If facility staff noise exposures exceed the limits of the OSHA
       noise standard, add noise to the list under physical hazards fact sheets. If noise limits
       are exceeded (90 dB or greater), a hearing conservation program will be required;

                             Guidelines for MSDS fact sheets
If an MSDS is not received with this facility’s purchased chemicals, an MSDS can and should
be obtained by contacting the manufacturer.
     MSDS are not required for household hazardous waste products collected by the
     MSDS are not required for chemicals for the reuse or product exchange program. If
       these products are used by a HW staff in a consumer-capacity, the product should be
       returned to the exchange room immediately after use.

Further information about household hazardous waste products can be obtained by:
    Contacting the manufacturer by phone or on its web site.
    Searching the Internet (example:

All incoming MSDS sheets should be reviewed with staff. New information should be
communicated to affected staff. After which, the data sheet will be placed in the RTK notebook.

When viewing an MSDS data sheet, the provided information should always include:
  1. Product identity and ingredients by chemical or common name.
  2. Physical and chemical characteristics.
  3. Physical hazards, such as fire and explosion.
  4. Health hazards, including symptoms.
  5. Primary routes of entry of the chemical into the body.
  6. Legal exposure limits (OSHA and other recommended limits).
  7. Whether the chemical can cause cancer.
  8. Precautions for safe handling and use.
  9. Control measures, including ventilation, personal protective equipment, etc.
  10. Emergency and first aid procedures.
  11. The date the MSDS was prepared.
  12. Name, address, and phone number of the manufacturer.
  13. Whether the chemical is listed as a hazardous material by United States Environmental
       Protection Agency, EPA SARA Title III rules, or EPCRA (Community Right to Know).

The Chemical and Physical Hazards List, MSDS, and any associated fact sheets should be
made a part of the RTK/MSDS notebook/manual. The alphabetical listing of materials and
hazards should be kept up-to-date. Staff will use this same list as a table of contents for filing
fact sheets and MSDS sheets.
                                 Products of Use Labeling

The RTK coordinator should verify that all containers of chemicals purchased for use at the
facility are clearly labeled in English with the following information:
     chemical’s identity (trade name)
     appropriate hazard warnings (including any target organ)
     manufacturer’s name and address

When staff members transfer a product into a secondary container (e.g. spray bottle) the
container should be labeled to identity the product and any hazardous properties. Labels are
not required on the original, immediate-use containers, bottles, or cans.

                                     Facility staff training

The HW RTK coordinator should ensure that all Facility staff are trained and kept up-to-date on
MSDS and other information covered under the RTK Program.

Initial training

All new facility staff, prior to starting work with chemicals or physical agents should receive
basic RTK training as well as facility-specific RTK training, which should include:

       an overview of the RTK Standard and the HW RTK Program.
       location and availability of the facility’s written RTK Program, MSDS, postings, and other
        written information.
       physical and health effects of the chemicals (HW chemical categories) and physical
        agents, as applicable.
       Instructions for how to read and interpret information on labels and MSDS.
       methods and observation techniques used to determine the presence of chemicals in
        the work area.
       techniques for reducing or preventing exposure to hazardous chemicals or physical
        agents by using good work practices, personal protective equipment, etc.
       information on steps the facility has taken to reduce or prevent exposure to chemicals or
        physical agents.
       emergency procedures.

Additional training should be provided:

       during the January, Hazardous Waste Operating Guidelines, refresher training program
       during the in-house, monthly, safety and in-service training sessions
       when a new chemical is introduced into a work area
       when a new hazard category is introduced into a work area
       for volunteers and return-to-work Facility staff, if they will possibly be exposed to new or
        hazardous chemicals

The HW RTK coordinator will document, review annually, and update training as needed.

Training for hazardous, non-routine tasks

Facility staff may be asked to work in the presence of various hazardous waste chemicals or
non-routine tasks. Prior to starting work on such projects, the RTK coordinator should provide
training on potential hazardous chemical or physical exposures. This information should

       specific chemical hazards
       protective/safety measures
       precautions to take to reduce or avoid exposure

                                       Record Keeping
Training records

The RTK coordinator is responsible to see that training and attendance records are being
maintained for at least the past three years, to include the:

      staff name
      staff identification and/or job title
      date of training
      trainer
      summary, outline, or agenda of contents of the training session
      training handouts, reference materials, handouts, etc.

MSDS records

The HW RTK coordinator is responsible for maintaining current, MSDS sheets for chemicals
that were purchased by this Facility, which may or may not still be used, including to:
     write the initial month and year on the MSDS, indicating when it was first used
     pull non-current MSDS and keep them separate from the current sheets
     keep non-used MSDS sheets on file for 30 years after the last date of use

Hazard Exposure Records

The Hazard Communication standard requires that chemical information must be transmitted to
employees who work with hazardous materials or processes. Employee exposure records can
tell if a worker is actually being exposed to a chemical or physical hazard and how much
exposure he or she is receiving. OSHA regulations that establish access rights to hazard
exposure records are found in 29 CFR 1910.1020: Access to Medical and Exposure Records.
Such information involves the right of access to product monitoring or measurement for:
      Dusts, fumes, or gases in the air.

      Absorption of a chemical into the body, e.g. blood lead levels.

      Noise exposure.

      Radiation exposure.

      Spores, fungi, or other biological contaminants.
Employees and their designated representatives have the right, under this OSHA regulation, to
examine or copy exposure records that are in the possession of the employer. This right applies
not only to records of an employee’s own exposure to chemical, physical, or biological agents
but also to exposure records of other employees whose working conditions are similar to the
employee’s. Union representatives, if applicable, have the right to see records for any work
areas in which the union represents employees.

In addition to seeing the results, employees and their representatives also have the right to
observe the actual measurement of hazardous chemical or noise exposure. Exposure records
that are part of an OSHA inspection file are also accessible to employees and union
representatives. In fact, these files, with the exception of certain confidential information, are
open to the public after the inspection has been legally closed out.

             Attachment A - Employee Right to Know
               Chemical and Physical Hazards List
                    HW Chemical Category Information Sheet

     Carbon Monoxide

     Corrosives and Irritants + Caustic Exposure



     Pesticides (Signs and Symptoms of Pesticide Poisoning)

     Solvents and Solvent-based Products

                      Physical Hazards Information Sheet

     Heat Stress

Material Safety Data Sheets (MSDS) – Products used at the Facility

1.      GOJO Orange Pumice Hand Cleaner

2.      Oil – Dri Floor Absorbent

3.      Simple Green Germicidal Cleaner and Deodorant

4.      Sodium Bicarbonate Absorbent and Neutralizer

                                       Carbon Monoxide
What is carbon monoxide?                                   Warning: Ensure rescue attempts do not create
Carbon monoxide (CO) is a poisonous,                       additional victims by exposure to fatal CO levels.
colorless, odorless, and tasteless gas. Although
it has no detectable odor, CO is often mixed with          How to prevent CO poisoning
other gases that do have an odor.                          To reduce the chances of CO poisoning in the
                                                           workplace, employers should take the following
CO is a common industrial hazard resulting from
the incomplete combustion of natural gas and
any other material containing carbon such as                      Install an effective ventilation system to
gasoline, kerosene, oil, propane, coal, or wood.                   remove CO from work areas.
The most common source of exposure in the                         Maintain equipment and appliances which
workplace is the internal combustion engine.                       may produce CO (e.g., water heaters,
                                                                   space heaters) to assure safe operation
How CO can cause harm                                              and reduce CO formation.
CO is harmful when inhaled because it deprives                    Consider switching from gasoline-powered
the heart, brain, and other vital organs of                        equipment to equipment powered by
oxygen. Large amounts of CO can quickly                            electricity, batteries, or compressed air (if
overcome a victim without warning, causing loss                    it can be used safely).
of consciousness and death.                                       Prohibit the use of gasoline-powered
                                                                   engines or tools in poorly ventilated areas.
Besides tightness in the chest, initial symptoms                  Install CO monitors with audible alarms.
of CO poisoning may include: headache, fatigue,                   Test air regularly in areas where CO may
dizziness, drowsiness, or nausea. Sudden chest                     be present, including confined spaces.
pain may occur in people suffering from angina.                   Educate staff about CO poisoning,
During prolonged or high exposures, symptoms                       including likely sources and to report
may worsen and include: vomiting, confusion,                       suspected symptoms (e.g, dizziness,
muscle weakness, and finally loss of                               nausea, drowsiness).
consciousness. Symptoms vary widely from                          Report any situation that might cause CO
person to person. CO poisoning may occur                           to accumulate.
sooner in people most susceptible, including                      If CO poisoning is suspected, avoid
those who are: theyng, elderly, pregnant,                          overexertion and leave the contaminated
suffering from lung or heart disease, located at                   area.
high altitudes, or already exhibiting elevated CO
blood levels (smokers).                                    OSHA standards for CO exposure
                                                           The OSHA PEL is 50 parts per million (ppm).
CO poisoning can be reversed if caught in time.
                                                           OSHA standards prohibit worker exposure to
However, even following complete recovery,
                                                           more than 50 ppm averaged during an 8-hour
acute poisoning may still result in permanent
                                                           time period
damage to body parts requiring a lot of oxygen
(e.g., heart, brain). Significant reproductive risk        Carbon monoxide monitoring devices
has also been linked to CO poisoning.
                                                           There are three types of CO monitoring devices
What to do if CO poisoning is suspected                    that are suitable for determining worker
When CO poisoning is suspected, promptly take              exposure.    There    are   advantages     and
the following actions that may save lives:                 disadvantages to each device.
     Move the victim immediately to fresh air.
                                                           1) Electronic sensing instruments with digital
       Call 911 for medical attention or                  readout.
        assistance and inform them of suspected
        CO exposure.                                       2) Colorimetric detector tubes with a hand-held
       If the victim has stopped breathing, if              pump.
        trained,     perform   cardiopulmonary
        resuscitation (CPR).                               3) Passive colorimetric detector tube.

                              Corrosives and Irritants
Corrosives and irritants include acids and       Control measures may include:
bases (alkaline, caustic), as well as other
                                                         Storing acids separately from bases.
chemicals. Skin and eye contact are the
more common routes of exposure.                          Always adding acid to water, as doing it
Exposure to irritants and corrosives usually              in reverse may cause a reaction,
occurs when the chemical is spilled or                    resulting in splashes and potential
splashed. When corrosives are heated,                     injury.
vapors are produced. These vapors can be                 An emergency eyewash and shower
irritating to the nose and throat when                    should be readily accessible when
inhaled.                                                  handling corrosives.
Some corrosives and irritants are also in                Refer to the material safety data sheet
particulate or powder form. Exposure to a                 and the product label for additional
moist surface (e.g., skin, inhalation, eyes)              health and safety information.
may result in a painful reaction or burn. See
the following table for examples of
corrosives,    irritants,   and      products
containing these materials.
                                                      Corrosives          Products     containing
Corrosives can irritate, burn, or destroy             and irritants       these materials
living tissue (e.g., skin, eyes, respiratory         Acids, inorganic    Cleaners        Naval jelly
tract). Any corrosive material that comes in         Includes nitric,    Strippers       Battery acid
contact with moist tissue may cause serious          hydrofluoric,
or permanent damage if not rinsed                    muriatic,     and
immediately. Irritants may cause tissue              hydrochloric.
irritation or inflammation, as opposed to            Acids, organic      Rust            Cleaners
tissue destruction.                                                      removers
                                                     Includes oxalic,                    Etchants,
Hazard potential variables                           citric,    and      Photos          descalers
      specific chemical                             acetic.             chemicals
      concentration and pH                          Alkalines/bases     Cleaners        Liquid wood
      duration of exposure/contact                  Includes            Detergents
                                                     calcium,                            Surfactants
      location of the contact (eye or skin)         sodium       and
      how quickly first aid action is taken         potassium
       (flush with water)
                                                     carbonates, lye,
In case of accidental contact with the               soda        ash,
skin or eyes, IMMEDIATELY flush the                  caustic    soda,
area thoroughly with water. Continue to              ammonia, TSP,
flush for 15 minutes.                                and      sodium
Precautions and control measures                     Irritants           Cleaners          Bleach
Wear       appropriate    chemical-resistant                             Disinfectants     Latex
personal protective equipment (PPE); the                                                   paint
type of PPE (e.g., glove length, face shield,
goggles, apron, footwear) is dependent
upon the type of task being performed,
extent of exposure, or splash potential.

A material is described as a gas if its               Corrosive and irritant gases can damage,
physical state is gaseous at normal                   burn, or destroy the tissue of breathing
temperature and pressure. Some materials              passages or lungs. For example, chlorine
that are normally a solid or liquid at room           and ammonia can irritate the upper
temperature can change their physical state           respiratory tract, bronchial passages, skin,
to a gas (e.g., heating, burning, decreasing          eyes, and mucous membranes. Symptoms
pressure).                                            of overexposure may include coughing and
                                                      shortness of breath.
Most gases are colorless at low
concentrations and cannot be seen. Some
gases (e.g., ammonia and chlorine) can be
detected by their odor and irritating effects,        Compressed gas containers should be
at certain concentrations. However, other             handled with care. Cylinders should be
gases (e.g., carbon monoxide, acetylene)              stored in a well-protected and ventilated
have no odor or immediately irritating                area. Oxygen and acetylene cylinders
effects on the body.                                  should be stored separate from fuel
Gases can be inhaled directly into the
lungs, and are either absorbed into the
blood or exhaled. Some gases act as                   Rules for handling compressed gases
poisons to body systems, while other gases
(e.g., nitrogen, carbon monoxide) reduce                 Compressed gases are normally not
the amount of oxygen available to the body.               accepted by this facility unless approved
                                                          and accepted by the Customer Service
Gases are used directly in some work
processes, or they can occur as
by-products from work processes or                       Preferably, use a hand truck for
operations, such as carbon monoxide from                  transporting cylinders; do not drag.
fuel-operated forklift trucks. Gases may                  Secure or chain the cylinder and
also be contained in pressurized cylinders                transport in an upright position.
as compressed gases (e.g., acetylene,
                                                         Never lift a cylinder by the cap.
oxygen, propane).
                                                         Cylinders should be chained in place or
Asphyxiants are gases that interfere with                 otherwise secured at all times.
the body’s ability to utilize oxygen. Simple
asphyxiants (e.g., methane, argon, helium,               Use cylinders in an upright position only.
nitrogen) are materials that act by replacing            Protect cylinders from being struck.
the available oxygen in the air, making the
oxygen concentrations too low to support                 Do not drop cylinders or otherwise
life. Confined space entry is an example of               permit them to strike each other.
a situation where oxygen deficiency could                Leave valve cap on cylinder until
be     a    potential   problem.    Chemical              secured and ready for use.
asphyxiants interfere with the transportation
                                                         All valves should be closed when not in
and use of oxygen by the tissues in the
body.      Overexposure       to    chemical
asphyxiants (e.g., carbon monoxide,                      Cylinder storage area should be dry,
hydrogen,      cyanide)     can   result    in            well ventilated, and the temperature
suffocation. Initial symptoms may include                 kept below 100° F.
headache, dizziness, and nausea and will
                                                         Always consider cylinders to contain
usually subside upon ceasing exposure to
                                                          product and handle accordingly.
the asphyxiant gas. Refer to Carbon
Monoxide information sheet for more

                                         Heat Stress
                                                          mental confusion, delirium, loss of
Some Program situations (e.g., HW mobile
collection events) may require staff to work               consciousness, convulsions, or coma
in hot environments or in conditions that                 body temperature of 106ºF or higher
pose special hazards to safety and health.
                                                          hot, dry skin, which may be red, mottled,
     Body reactions to heat stress                         or bluish
Four environmental factors affect the
                                                       Victims of heat stroke will die unless treated
amount of body stress in a hot work area:
                                                       promptly. While awaiting medical help, the
ambient air temperature, humidity, radiant
                                                       victim should be moved to a cool area; their
heat and air velocity. Important personal
                                                       clothing soaked with cool water, and fanned
variables include: age, weight, fitness,
                                                       vigorously to increase cooling. Prompt first
medical condition, and/or acclimation to
                                                       aid can prevent permanent injury to the
                                                       brain and other vital organs.
The body reacts to high temperatures by
                                                       Heat exhaustion results from loss of fluid
circulating blood to the skin, allowing the
                                                       through sweating. This occurs when there is
release of excess heat. However, if muscles
                                                       failure to drink enough fluids, or take in
are being used for physical labor, less blood
                                                       enough salt, or both. The symptoms of heat
is available to flow to the skin to release the
                                                       exhaustion     include;    sweating  while
                                                       experiencing extreme weakness or fatigue,
Sweating is another mechanism the body                 giddiness, nausea, or headache. The skin is
uses to maintain a stable internal                     clammy and moist, the complexion pale or
temperature. However, sweating is most                 flushed, and the body temperature is
effective when the humidity levels are low             normal or slightly elevated.
enough to permit evaporation. To prevent
                                                       Treatment requires the victim to rest in a
dehydration, replace lost fluids and salts as
                                                       cool place and to drink an electrolyte
                                                       solution (a beverage containing potassium,
There are many ways to reduce the risk of              calcium, and magnesium salts). Severe
heat stress, such as moving to a cooler                cases involve victims who vomit or lose
place, reducing the work pace or load,                 consciousness,     which    may      require
and/or removing or loosening restrictive               treatment under medical supervision.
                                                       Heat cramps are painful muscle spasms
If the body’s core temperature rises more              caused by drinking large quantities of water,
rapidly than excess heat can be dissipated,            which fails to replace salt lost through
the heart rate increases and the body will             sweating. Muscles that are tired and used
continue to store heat. Then the individual            for performing work are usually the ones
begins to lose concentration, has difficulty           most susceptible to cramps. Cramps may
focusing on a task, may become irritable or            occur during or after working hours and
sick, and often loses the desire to consume            may be relieved by drinking liquids
liquids. If the heat stress is not alleviated,         containing electrolytes.
the person may faint and death is possible.
                                                       Heat rash may occur in hot and humid
              Heat disorders                           environments, where sweat is not easily
Heat stroke is the most serious health                 removed from the surface of the skin by
problem for workers in a hot environment.              evaporation. Heat rash can be prevented by
Sweating stops and the body can no longer              removing the victim to a cool place and
rid itself of excess heat. Symptoms may                allowing the skin to dry.

         Preventing heat stress
The likelihood of most heat-related health
problems can be prevented or reduced by
following these precautions:

1. Using Facility engineering controls which
   include adequate ventilation, evaporative
   cooling, air conditioning and cooling fans.
   Use power tools to reduce manual labor
   and wear personal cooling devices or
   protective clothing.

2. Providing plenty of drinking water (as
   much as a quart per worker per hour)
   can help reduce the risk of heat
   disorders.   Employers should also
   consider an individual worker’s physical
   condition when determining their fitness
   for working in hot environments.
   Individuals who are older, obese, or on
   some type of medication are at greater

3. Allowing longer rest periods in a cool
   area can help to avoid heat stress. If
   possible, heavy work should be
   scheduled during the cooler parts of the
   day and appropriate protective clothing
   provided. Staff should be trained to
   detect early signs of heat stress and
   should be permitted work interruption if
   they are extremely uncomfortable.

4. Acclimation to the heat through short
   exposures followed by longer periods of
   work in the hot environment can reduce
   heat stress. New workers and Facility
   staff returning from an absence of two
   weeks or more should have a five-day
   period of acclimation. This period should
   begin with 50 percent of the normal
   workload and time exposure the first day,
   and gradually build up to 100 percent on
   the fifth day.

5. Staff education should reinforce the
   importance of replacing fluids and salt
   lost through sweat, and how to recognize
   heat     disorders  (e.g., dehydration,
   exhaustion, fainting, heat cramps, salt
   deficiency, heat exhaustion, heat stroke).

Source: OSHA Fact Sheet No. OSHA 95-16

Chemicals may be present as particulates in the               Depending on the size, particles may get trapped
air, in containers, or on surfaces. Particulate               in the nose and if small enough, may reach the
agents include dust, fumes, smoke, mist, and                  lungs. Solid particles can settle out of the air
fog.                                                          where it may contaminate the floor and work
                                                              surfaces. Touching surfaces contaminated with
Dusts, fumes and smoke consist of solid                       toxic dust could transfer the particles to the
particles. Grinding, crushing, or working with                mouth.
powder or particulate materials produces dusts.
Fumes are produced when metals are heated                     Exposure to particles can result in a variety of
past the melting point. Smoke is typically the                symptoms (e.g., irritation, lung damage) and
result of heating or burning something.                       depends on the chemical concentration, length
                                                              of exposure, and the toxicity of the material.
Mists and fogs consist of liquid particles. Mists
are liquid droplets produced by breaking up a                 Wear appropriate protective clothing and
liquid, such as in spraying (e.g., oil, paint mist).          equipment. Use a filtering face piece respirator.
Fogs are formed when humid air cools and the                  (N, R, or P – 95 or 100). For additional safety
water vapor condenses. Particles are easily                   and health information, see the SOG Chapter on
released into the air and can settle onto exposed             Personal Protective Equipment.
work surfaces. If the particles remain in the air,
they are easily inhaled.

             Particulate                                                  Information
    Asbestos                  Asbestos fibers are naturally occurring minerals. Vermiculate may contain traces of asbestos.
                              Household remodeling debris may also contain asbestos. Do not open bags of household
                              demolition debris. Exposure through inhalation may cause long term health effects such as
                              asbestosis, lung cancer, or mesothelioma.
    Fertilizers               The formulation, the physical state, and the method of application influence the exposure
                              potential to fertilizers. The health effects depend on the fertilizer type, and have the potential
                              to cause respiratory, skin and eye irritation.
    Fiberglass                Direct contact with fiberglass materials or exposure to airborne dust may irritate the skin,
                              nose, and throat or may cause lung disorders.
    Lead                      Lead sources include paint, paint chips/debris, or solder wire. Lead exposure may occur
                              through inhalation or ingestion. The symptoms of chronic exposure include loss of appetite,
                              anemia, and muscle or joint pain. The liver, kidneys, or reproductive systems may also be
    Metal dust and fumes      Iron oxide is the main metal fume generated from welding on steel. Iron and aluminum oxides
                              may cause respiratory irritation. Exposure to toxic metals (e.g., beryllium or cadmium)
                              increases health hazard potentials. See also welding fumes below.
    Nuisance dust             At high concentrations, nuisance dust may cause respiratory irritation in some individuals. In
                              general they are not associated with permanent lung disorders.
    Silica                    Long-term exposure to silica (sand, quartz) may result in silicosis, a lung disorder which
                              results in decreased breathing capacity. Silica has been classified as a suspect carcinogen.
                              Diatomaceous earth also contains silica.
    Welding fumes             Welding fume hazards depend on the composition of the base metal, the use of local
                              exhaust, the type of area in which the welding is being done, base metal coating, etc. Iron
                              oxide and aluminum oxide are not associated with lung disorders. Welding on metals coated
                              with or containing alloys of lead, nickel, zinc, copper, etc. increase the hazard potential as
                              compared to welding aluminum or steel parts.
    Wood dust                 At high concentrations, wood dust can act as a respiratory and eye irritant. Certain woods,
                              including pine, beech and mahogany, can cause an allergic response (asthma and dermatitis)
                              in sensitized individuals. Chronic exposure to certain hardwood dusts is associated with the
                              potential to cause nasal cancer.

                                    Solvents and Solvent-based Products
                              Solvents are a class of liquids used to dissolve certain other solid materials (clean,
                Hazardous     degrease, thin). Many solvents are flammable or combustible; however, chlorinated
                Waste         solvents are not flammable. In general, solvents evaporate readily and become
                              airborne. With heating, solvents evaporate faster and more vapors are produced.

Most solvents can be detected by smell (odor threshold) at concentrations well below their allowable exposure
limits. Solvent vapors can be sampled using organic vapor badges or detector tubes.
Solvent hazard potential variables include:
     Use of product (bulking)
     Exposure route (inhalation or absorption)
     Toxicity
     Evaporation rate
     Exposure quantity
     Exposure time length
     Susceptibility of individual

                                                   Health effects
Skin disorders: Repeated skin contact may result in irritation and drying. Repeated contact may cause a rash or
inflammation (dermatitis) or may dry out the skin to the point of cracking and bleeding. Solvents should not be
used to wash or clean the skin. Some solvents can be absorbed through intact skin. Repeated contact with certain
compounds (e.g., epoxy) can cause allergic skin reactions or sensitization. Use extra precautions if contact with
these materials occurs. This information should be noted on the material safety data sheet.

Eye injury: Solvent vapors can irritate the eyes. Directly splashing the liquid into eyes may cause symptoms
ranging from irritation to serious burns and permanent damage.

Inhalation: Solvents act as a central nervous system depressant. General symptoms of acute (short-term)
exposure include headache, dizziness, and nausea. Generally, when the exposure is stopped, the reaction
disappears. Extreme exposure situations could lead to unconsciousness. Solvent vapors can also act as
respiratory irritants. Chronic (long-term) exposure to some solvents (trichloroethylene and carbon tetrachloride)
may cause permanent injury to the liver, kidneys, or other internal systems. Chloroform, carbon tetrachloride, and
formaldehyde are suspected to be carcinogens. Some products contain chemicals that can cause allergic
respiratory sensitization, including isocyanates (MDI, HDI, TDI) and urethanes.
Precautions and control measures
    Wear solvent-resistant gloves to prevent repeated or prolonged skin contact.
    In operations where the liquid could splash into the eyes, wear a face shield and/or goggles. In case of eye
       contact, flush the eyes with water for at least 15 minutes, while holding the eyelids open. Obtain medical
       assistance as needed.
    In operations where the liquid could splash onto the skin, wear appropriate protective clothing, such as a
       solvent-resistant apron
    If extensive skin contact should occur, flush the area thoroughly for at least 15 minutes.
    Personal hygiene is very important. Wash thoroughly. Do not wash up with solvents; use soap and water.
    In situations where a respirator is required, be sure the proper respirator is worn. It should protect organic
       vapors (OV) for solvents. If needed, a pre-filter can be used with the OV cartridge for paint particulates (N,
       R, or P – 95 or 100).
    In case of a solvent spill or leak, wear chemical protective clothing and gloves in order to avoid contact
       with the material. For larger spills, wear an organic vapor respirator to prevent overexposure, (if authorized
       to wear a respirator). Attempt to stop or control the spread of the material. Remove all ignition sources.

              CHAPTER THREE
                                         (Revised January 2010)
By order of choice, safety engineering, administrative directives and then personal protective equipment
are the preferred methods to protect staff from adverse exposure to chemicals or injuries. This PPE
program will ensure that staff is provided with the proper selection, procurement, and use of personal
protective equipment (PPE) and/or clothing.

Regulatory Requirements

Personal Protective Equipment requirements and directives are established in the HW program in
conjunction with EPA’s 40 CFR Part 311, OSHA’s 29 CFR; 1910.120 (g), 29 CFR 1910.132 – 138 and 29
CFR 1910, ATTACHMENT B, Subpart I.

Needs Assessment

A designated PPE person should conduct a needs assessment to determine and establish the required or
necessary PPE for specific operations. For this Program, the designated PPE staff person should be the
Hazardous Waste Coordinator. PPE requirements should be specific to this facility, for each individual,
and should be updated as job requirements change.

Required PPE should be provided by the SWM Division, at no cost to facility staff. A chart should be
posted for facility staff which lists job-specific tasks, identifying the necessary PPE; see Attachment A.

The above attachment, along with the existing environmental conditions, and the judgment of
experienced staff should be used to determine the level of PPE required for each unique situation.

PPE Training

The designated PPE person should be responsible for administering, implementing and enforcing the
PPE policy. If a hazardous waste or any other contractor is providing services to this Hazardous Waste
Collection program, each should comply with the PPE requirements specified in this SOG. The SWM
PPE Program should provide adequate and required training to all staff required to use PPE. The
designated PPE person should be responsible for requesting and coordinating training and providing
written documentation.

Each staff member should be trained on how to properly utilize the HW PPE, including:
    Choosing the type to be used and when
    How to don, doff, adjust, and wear
    The limitations and useful life of its components
    Care, maintenance, and disposal

PPE training should:
   Be conducted before any staff is required to use the PPE
   Be conducted when lack of compliance is observed
   Be conducted when workplace conditions change, rendering previous training obsolete
   Be designed to encourage staff to report and seek treatment for symptoms of health problems
       caused or aggravated while on the job
   Continue until staff can demonstrate an understanding of the training
                                            PPE Selection

PPE should be provided, used, and maintained wherever hazards exist (e.g., processing, environmental,
chemical, mechanical) or when hazards are encountered and are capable of causing injury or impairment
in the function of any part of the body. Injury can occur through absorption, inhalation, injection, or

  physical contact with these hazards. The designated PPE person should set a good example by donning
  PPE and following the PPE Program policy. The following guidelines are provided for hazard assessment
  and PPE selection:

  Eye and face protection. Appropriate eye and/or face protection should be worn if exposed to
  potentially injurious hazards (e.g., flying particles, liquid chemicals, corrosives, chemical gases, vapors,
  UV rays). All eyewear should provide:
       Eye and side protection;
       Protective devices to be worn over prescription eyewear, if needed;
       A proper and comfortable fit.

  Hearing protection. Facility staff should wear hearing protection when exposed to noise levels in excess
  of 85 dB for an eight-hour time-weighted average.

  Foot hazards. OSHA requires that staff wear protective footwear if the potential for foot injuries exist,
  including exposures to:
       Compression, squeezing, smashing, falling or rolling objects
       Electrical hazards
       Slipping
       Chemical exposure
       Repeated wetness which may result in fungal infections
       Puncturing from objects which may pierce the sole of footwear

  Engineering controls and work-practice solutions should be utilized, including wearing footwear correctly
  (fully laced, etc.) to receive maximum protection. The PPE Program should prohibit the use of sandals or
  open-toe shoes.

  Hand and body protection. Appropriate hand and body PPE should be worn when potential hazards
  exist, including an exposure to:
       Cuts and punctures – severe cuts and lacerations, abrasions or punctures from tools, machines or
           from handling sharp objects
       Thermal exposure – caused by extreme cold or heat or hot work
       Bloodborne pathogens (BBP) – caused by first-aid or the clean-up of blood, body fluids, or other
           potentially infectious materials (OPIM)
       Chemical exposure – skin contact from working with chemicals
       Repetitive motion disorders – caused by computer use or jobs requiring repetitive motion may
           cause carpal tunnel syndrome
       Entanglement – caused from wearing loose gloves, clothing or jewelry near moving equipment

  Head protection. Head protection (e.g., hard hat) should be worn if potential for injury from falling
  objects exist. Any head protection provided by Solid Waste Management should:
       Be used according to manufacturers instructions
       Not be altered in any way

  Respiratory protection. Site specific ventilation or exhaust systems are effective engineering control
  tools. Refer to Chapter 4, Respiratory Protection Program, for specific information.

                                             ATTACHMENT A

                                                        Bulking of
PERSONAL PROTECTIVE EQUIPMENT      Receive   Sorting    Aerosols,    Bulking of   Corrosives   Incidental   Identifying

                                     Wastes   Wastes     Flammables    Latex Paints   & Toxins   Spill      Unknown
                                                         or Solvents                  Packing    Clean-Up   Materials

Respiratory Protection               O        O          R*            O              R*         R*         R*

Tyvek Apron, Smock or Coveralls      R        R          O             R              R          R          O

Chemical Resistant Apron / Smock     O+       O+         R*            O+             O+         O+         R

Safety Glasses and/or Face Shield    R        R          O             R              O          R          R

Goggles                              O+       O+         R**           O+             R**        O+         O+

Nitrile Safety Gloves                R        R          O             R              O          R          R

Chemical Resistant Gloves            O+       O+         R             O+             R          O+         O+

Leather-Palm Work Gloves             O        O          O             O              O          O          O

Tyvek Sleeve Protection              O        O          R             O              R          O          R

Reinforced Safety Toe Shoes          R        R          R             R              R          R          R

Tyvek Shoe Cover Protection          O        O          O             O              O          O          O

Safety Helmet                        O        O          O             O              O          O          O

Hearing Protection                   O        O          O             O              O          O          O

Reflective Shirt, Vest or Jacket     R        R          R             R              R          R          R

                                                                                            Revised January, 2010

   O – Optional for HW Staff

   O+ - Use of these optional, PPE items is permitted to provide a higher standard of protection than the
   standard, minimum requirement (R).

   R – The minimum level of safety protection recommended for HW staff

   R* - Respiratory Protection and/or Chemical Resistant Smock are optional, only when dealing with small
   amounts of flammable, corrosive or toxic hazard classes, for a short amount of time, located in an open
   area, in conjunction with adequate ventilation.

   R** - In lieu of wearing goggles, staff has the option of wearing both safety glasses and a full face shield.

                                              CHAPTER FOUR
                                         RESPIRATORY PROTECTION
                        Waste                                 (Revised January 2010)

This Hazardous Waste Program is charged with determining the necessity, choice, use and
maintenance of respiratory protective equipment. Exposure to air contaminants should first be
eliminated or greatly reduced by using engineering barricades and/or administrative controls. In
addition to these primary protections, PPE respiratory protection should be provided.

Air filtering respirators used at this facility should be utilized within an environment where the physical,
chemical, and toxicological properties are known. The ambient air should contain enough oxygen to
sustain life (min. 19.5%), but should not be super-oxygenated (max. 21.5%).

Respirators should not be used in an environment which is Immediately Dangerous to Life or Health
(IDLH). The National Institute of Occupational Safety and Health (NIOSH) defines IDLH as a condition
―that poses a threat of exposure to airborne contaminants when that exposure is likely to cause death
or immediate or delayed permanent adverse health effects or prevent escape from such an

OSHA standard 1910.134(b) defines an IDLH environment as being ―an atmosphere that poses an
immediate threat to life, would cause irreversible adverse health effects, or would impair an individual’s
ability to escape from a dangerous atmosphere.‖

The exposure concentration limit of various chemicals can be found and are listed in the NIOSH Pocket
Guide to Hazardous Materials. Within this book’s ―Exposure Limit‖ category is a NIOSH, recommended
exposure limit (REL) concentration. REL is a permitted, time-weighted average (TWA) for an exposure
of 10 hours per day, 40 hours per week. This maximum, short term exposure limit (STEL)
concentration is based on a once-per-day, 15 minute, TWA exposure.

The same NIOSH guidebook lists a recommended maximum concentration by the Occupational Safety
and Health Administration (OSHA), Standard 29 CFR 1910.1000, referred to as the permissible
exposure limit (PEL), and is enforced by OSHA.

                            Regulatory and contractual requirements

Respirator program requirements are established based upon the procedures found in the HW
Program, 40 CFR Part 311, and OSHA respirator standard 29 CFR 1910.134 and 1910.134
ATTACHMENT D, 1910.1000, 1910.1020, and the Health Insurance Portability and Accountability Act
of 1996 (HIPAA) Privacy Rule.

                                          Medical evaluation

Staff who are required to wear any type of air filtration respirator in the performance of their job duties
should also be evaluated through a medical monitoring program. To assist a physician or other
licensed health care professional to determine if an individual is physically able to wear a respirator,
staff will first fill out Part A, Sections 1 and 2 of the OSHA medical questionnaire found in 29 CFR
1910.134. Staff will then take a physical examination specific to their respirator use. The medical
evaluation needs to be made prior to respirator fit testing and use. For more information, see Chapter
Five, Medical Monitoring Program guidelines.
                                    Voluntary use of respirators

This Program permits the voluntary use of air filtering respirators when:
    the use of a respirator is not required for their position
    there is no overexposure to airborne contaminants or oxygen levels and
    the only respirator being considered for use is an air filtering facepiece

If the only respirator voluntarily being used by staff members is an air filtering facepiece (e.g., a
disposable dust mask, dust mask with odor protection, a NIOSH-approved dust mask), then staff
should be trained in its use. There are no other requirements, if the use of a respirator is not

OSHA states those who are voluntarily using respirators are not required to undergo medical
monitoring examinations or annual fit testing, but should be provided with a copy of Appendix D to
Sec. 1910.134, (Mandatory) Information for Employees Using Respirators When Not Required
Under the Standard. A copy of this is found in Attachment A of this chapter.

                                   Respirator Selection and Use

The Respirator Protection Program Administrator (RPPA) is responsible for selecting the appropriate
type respirator for the intended task. Selection should be based on the hazard and/or the results of air
monitoring or industry experiences. For this HW program, the RPPA should be the Hazardous Waste

Attachment B of this chapter details the Respirator Selection and Use guidelines for staff members.
The Respirator Selection and Use guideline should be completed, updated, and maintained at the
hazardous waste collection site. The attachment should include those tasks requiring the use of
respirators, the type of respirator used, and the schedule for changing chemical cartridges.

                          Respirator inspection, storage and cleaning

Inspection. Respirators should be inspected prior to each use. Staff should report respirator defects to
the Respirator Protection Program Administrator and obtain replacement parts or a new respirator. The
use of known, defective respirators should not be permitted.

Storage. Clean respirators and cartridges should be stored in a clean, dry container, in a manner to
prevent deformation of the facepiece and exhalation valve. Protect from heat, direct sunlight, dust and
damaging chemicals. To preserve the shelf life of cartridges, store in re-sealable zip lock plastic bags
when not in use. If staff can taste or smell break though, immediately stop use as the cartridge may
need replacement. Filtering facepiece respirators (dust or odor-removing masks) should be discarded
after each use, when dealing with dusty, friable, or other hazardous waste materials.

Cleaning. Staff should clean their own canister respirator (not air filtering masks) following each use. A
cartridge-type respirator mask should be cleaned according to the manufacturer’s directions. A
respirator cleaning solution should be available for sanitizing and cleaning.

                                       Respirator Fit Testing

A respirator fit test should be used to determine the ability of the wearer to obtain a satisfactory seal
with the respirator facepiece. Respirator fit testing should be conducted following the procedures in the
OSHA respirator standard, Appendix A to 29 CFR 1910.134.
The RPPA should document and retain the testing results on a respirator fit test record form, similar to
the one found in Attachment D of this SOG.

According to OSHA 1910.134, fit testing should not be performed on staff with facial hair that passes
between the respirator seal and face. Any corrective glasses should be worn in a manner that will not
interfere with the seal of the facepiece to the face. If needed, an eyeglass holder should be provided
for the inside of a facepiece. The use of eye contacts is permissible.

Staff should conduct respirator seal checks prior to fit testing and prior to each use. Suggested seal
check procedures can be found in Appendix B-1 of 29 CFR 1910.134, as summarized in Attachment C
of this SOG.

                                        Respirator Training

Each person who uses an air filtration respirator for the collection and/or handling of hazardous waste
should first attend an OSHA 40 hour HazWoper training course. Trainees should be taught regarding
a respirator’s:

      Need for use
      proper selection
      operation, application and use
      limitations of use
      care and cleaning
      fit testing procedures
      proper positive and negative, user seal check
      emergency response procedures

The initial training and fit testing for respirators should be conducted and completed prior to the
actual use of respiratory protection. Certified, OSHA refresher training should be conducted on at
least an annual basis, or as needed

Any solid waste staff member who wishes to use an air filtering respirator on a voluntary basis
should first be trained on and given the information contained in Attachment A of this SOG.
Training should be documented and records maintained by the RPPA for such individuals.

                                        Record Keeping

The following records should be obtained by the HW Respirator Protection Program Administrator
(RPPA) and maintained in each person’s Human Resource personnel file for the period of time

      Respiratory protection training records (minimum of 3 years).
      Staff fit test records for the current year (until next test is conducted).
      Results of any individual’s medical monitoring records (for 30 years after employment)
      Results of any air monitoring conducted by this Facility or by the state (for 30 years).

                        Attachment A
       Voluntary Use of Filtering Facepiece Respirators
The following is required handout Information for Staff Who Opt to Use Respirators When Not
Required to, as found in Appendix D of Standard 29 CFR 1910.134.

Respirators are an effective method of protection against designated hazards when properly
selected and worn. Respirator use is encouraged, even when exposures are below the
exposure limit, to provide an additional level of comfort and protection for workers.
However, if a respirator is used improperly or not kept clean, the respirator itself can
become a hazard to the worker. Sometimes, workers may wear respirators to avoid
exposures to hazards, even if the amount of hazardous substance does not exceed the
limits set by OSHA standards. If their employer provides respirators for their voluntary use,
of if they provide their own respirator, they need to take certain precautions to be sure that
the respirator itself does not present a hazard.

They should do the following:

1. Read and heed all instructions provided by the manufacturer or employer on the use,
   maintenance, cleaning, care, and warnings regarding the respirator.

2. Choose respirators certified for use to protect against the contaminants of concern.
   NIOSH, the National Institute for Occupational Safety and Health is the agency which
   certifies respirators. A label or statement of certification should appear on the respirator
   or respirator packaging. Such label will tell they what the respirator is designed for and
   how much it should protect they.

3. Do not wear their respirator into atmospheres containing contaminants or oxygen levels
   for which their respirator is not designed to protect against. For example, a respirator
   designed to filter dust particles should not protect they against gases, vapors, or very
   small solid particles of fumes or smoke.

4. Keep track of and mark each individual respirator so someone else’s respirator is not
   mistakenly used.

                              Attachment B
                       Respirator Selection and Use

_ Paul Davis, Hazardous Waste Coordinator____ is the HW Respirator Program Administrator
              (Name and title)

                                                                    Revised January 2010

1. Tasks requiring the use of respirators & type of respirator (list):

* Bulking of either Acids or Bases into drums – Cartridge respirator with acid & multi-gas filters *

Bulking or combining Poisons / Organic Compounds – Cartridge respirator w/ multi-gas filter_ *

Cleanup or handling of Toxic / unknown materials – Cartridge respirator w/ multi-gas filter __ *

Bulking of Aerosol Paints into drums – Cartridge respirator with multi-gas / VOC filtration __ _ *

Bulking of Oil - Based Paints from containers into drums – NIOSH filter mask for VOC’s        __


2. Schedule for changing chemical cartridges and filters:

Examples:     Filters/pre-filters: When breathing becomes difficult.
              Filtering Facepiece respirators: When breathing becomes difficult or
              facepiece becomes dirty.
              Organic Vapor Cartridges: Every 24 hours of use or when chemical odor
              can be detected.

* Filters / Pre-Filters - Whenever the mask is soiled or when breathing becomes difficult______ *

Filtering Facepiece Respirators: When breathing becomes difficult or the facepiece is dirty__ *

Multi-Gas, Organic Vapor and Corrosive Cartridges: Every twenty – four (24) hours or______

_______           whenever a chemical odor can be detected___________________________ *

Volitile Organic Compound (VOC) Cartridges: Every twenty – four (24) hours of use or _____

             whenever a chemical odor can be detected.___________________________


                                       Attachment C

                         User Seal Check Procedures
OSHA, 29 CFR 1910.134, Appendix B-1 states that the individual who uses a tight-fitting respirator

is to perform a user seal check to ensure that an adequate seal is achieved each time the
respirator is put on. Either the positive or negative pressure checks listed in this attachment, or the
respirator manufacturer’s recommended user seal check method should be used.                 User seal
checks are not substitutes for qualitative or quantitative fit tests.

I. Facepiece Positive and/or Negative Pressure Checks

   A. Positive Pressure Check. Close off the exhalation valve and exhale gently into the
   facepiece. The face fit is considered satisfactory if a slight positive pressure can be built up
   inside the facepiece without any evidence of outward leakage of air at the seal. For most
   respirators this method of leak testing requires the wearer to first remove the exhalation valve
   cover before closing off the exhalation valve and then carefully replacing it after the test.

   B. Negative pressure check. Close off the inlet opening of the canister or cartridge(s) by
   covering with the palm of the hand(s) or by replacing the filter seal(s), inhale gently so that the
   facepiece collapses slightly, and hold the breath for ten seconds. The design of the inlet
   opening of some cartridges cannot be effectively covered with the palm of the hand. The test
   can be performed by covering the inlet opening of the cartridge with a thin latex or nitrile glove.
   If the facepiece remains in its slightly collapsed condition and no inward leakage of air is
   detected, the tightness of the respirator is considered satisfactory.

II. Manufacturer’s Recommended User Seal Check Procedures
The respirator manufacturer’s recommended procedures for performing a user seal check may be
used instead of the positive and/or negative pressure check procedures provided that the employer
demonstrates that the manufacturer’s procedures are equally effective.

                                         Attachment D
               Example of a Respirator Fit Test Record

Respirator Fit Test Record for: _______________________________________________(name)



                                     (manufacturer, model, size)

Date of fit test:____/_____/______             Fit test conducted by:_________________________

Fit test method:_____________________________________________________________

Results of fit test:     fits   does not fit

Respirator type:___________________________________________________________________
                                     (manufacturer, model, size)

Date of fit test:____/_____/______             Fit test conducted by:_______________________________

Fit test method:___________________________________________________________________

Results of fit test:     fits   does not fit

Respirator type:___________________________________________________________________
                                     (manufacturer, model, size)

Date of fit test:____/_____/______             Fit test conducted by:_______________________________

Fit test method:___________________________________________________________________

Results of fit test:     fits   does not fit


                                        CHAPTER FIVE
                                         (Revised January, 2010)

All staff members who are or may be exposed hazardous substances or health hazards at or above
the permissible exposure limits (PEL) for more than 30 days per year are required by OSHA to
undergo a medical monitoring program (29 CFR 1910.120(f)(2)(i)). The purpose of this medical
monitoring program is to document pre-existing conditions that may be aggravated by physical
demands of the job or by chemical exposures. Staff injury may be minimized by the early detection
and treatment of health problems caused or aggravated by workplace conditions and/or chemical

It is the responsibility of the employer, the Division of Solid Waste Management to tailor specific
medical monitoring guidelines. The employer is also responsible for paying for the employee’s
medical monitoring expense. The person responsible for implementing the medical monitoring
program will be the Director of the Division of Solid Waste Management.

                                REGULATORY REQUIREMENTS

Guidelines used to determine the medical monitoring program for this facility are taken from OSHA
standards found in 29 CFR 1910.134, 29 CFR 1910.120(b), 1910.120(f), 1910.1025 APP C, test
guidelines provided by the National Fire Protection Association (NFPA), Section 1582, and The
Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy Rule.

                                          MEDICAL EVALUATION

Staff who are required to wear air filtration respirators in the performance of their job for more than
30 days per year must also participate in a medical monitoring program (29 CFR
1910.120(f)(2)(ii)). To assist licensed health care professionals and to determine if an individual is
physically able to wear a respirator, staff will take a physical examination and will fill out the
(required) OSHA medical questionnaire found in 29 CFR 1910.134, App. C, Part A, Sections 1 and

A Citrus County Physician or other Licensed Health Care Professional (PLHCP) will provide their
written evaluation, as found in Attachment D, containing the following information:

       If they are medically qualified for employment without restrictions
       If there are medically acceptable for employment with listed restrictions
       Recommendations for a follow-up medical examination


This Facility’s medical monitoring program includes four examination phases or components:

   1.   Baseline examination
   2.   Annual (follow-up) examination
   3.   Incident Exposure examination
   4.   Exit examination

Baseline examination, per OSHA 29 CFR 1910.120(f)(3)(i)(A)

A baseline examination, also referred to as the initial exam, should be completed before a staff
member begins a regular assignment which involves working with any hazardous waste for more than
30 days per year. Staff should work under direct supervision and should not deal with chemicals
which may be above the permissible exposure limit until a baseline examination occurs. It is staff’s
responsibility to ensure that all previous records (e.g., physical results, laboratory results, spirometry,
chest X-ray reports, and forms) are retained by the County Human Resource Department and with
the county’s PLHCP, for comparison evaluation. The baseline examination will help to determine a
worker’s physical ability to wear a respirator and to perform the job. If any physical inabilities are
found, the Americans with Disabilities Act (ADA) also requires that:

   1. Pre-existing medical conditions or state of health may not be used to screen out applicants
      that are capable of performing job tasks with reasonable accommodations and
   2. The employer should make reasonable accommodations so staff can perform their job.

The primary function of the baseline examination is to:

   1. Determine if a staff member is healthy enough to physically perform the job duties (e.g., able
      to wear protective equipment while working). This exam also determines if accommodations
      for health limitations will be necessary.
   2. Document each staff member’s health condition before being exposed to on-job hazards.
   3. Establish baseline data for future comparison to later examinations (e.g., annual, incident
      exposure examinations or exit examination), and could hopefully provide an early detection of
      any adverse health trends. Comparing annual or incident exposure exam data to the baseline
      data may also help to determine if current protective measures have been effective.

The baseline examination should include, but not be limited to:

   1. The OSHA Questionnaire found in 29 CFR 1910.134, App. C, Part A, Sections 1 and 2
   2. A physical examination which includes the components of those items in Attachment B

Annual (follow-up) examination OSHA 29 CFR 1910.120(f)(3)(i)(B)

The results of the annual examination should be compared to the initial and to previous examinations
to detect early signs of adverse health changes and may indicate a need to adjust control measures
(e.g., engineering, administrative, PPE use). Individual staff health, the nature of the work, and
chemical exposures will determine if and when this examination is needed and what test parameters
should be included.

Incident Exposure Examination OSHA 29 CFR 1910.120(f)(3)(i)(D)

As soon as possible upon notification by an employee that the employee has developed signs or
symptoms indicating possible overexposure to hazardous substances or health hazards, or that the
employee has been injured or exposed above the permissible exposure limits or published
exposure levels in an emergency situation, such employee should receive a medical surveillance
examination. Except for an emergency, Access Health Care or Allen Ridge Medical Center are the
preliminary health care provider locations for workers compensation claims.

If the incident is reportable, completion of the First Report of Injury, form DWC-1, within 24 hours, is
mandatory for all job related injuries, along with a Worker’s Compensation Supervisor Statement. In
the case of the DWC-1, initial medical treatment for an on-the-job injury is always considered to be
authorized by the employer. All follow-up medical care must be pre-authorized.

A decision to provide emergency or non-emergency medical treatment should be made by the SWM
Emergency Response Coordinator on a case-by-case basis. Common signs (recordable by
instrument) and symptoms (outward signs or reactions) of chemical exposure may include:

 Behavior changes                  Drooling                          Light-headedness
 Breathing difficulties            Fatigue or weakness               Nausea
 Changes of complexion             Headache                          Redness of the eyes
 Coordination difficulties         Irritability                      Sneezing
 Coughing                          Irritation of eye, nose, throat   Sweating
 Diarrhea                          Irritation of skin                Tearing
 Dizziness                         Irritation to respiratory tract   Tightness of chest

An incident exposure exam is strongly suggested for staff that has signs or symptoms of
overexposure to chemicals or otherwise may exhibit occupational health problems. Staff should
document all reportable exposures and incidents, per County BOCC guidelines, on DWC-1.

Exit examination (OSHA 29 CFR 1910.120(f)(3)(i)(C))

An exit examination is the last exam in the series and should be performed if staff has had an
examination 6 months or more preceding any of the scenarios listed above. If there have not been
exposures to chemicals above the OSHA Permissible Exposure Limit (PEL) or the NIOSH
Recommended Exposure Limit (REL), this exam will not be required. The exit examination
instructions will follow the annual or exit examination process, found in Attachment B. If it is
determined to be necessary, staff should complete the exit examination within 30 days of:

      Leaving their HW job, or
      Changing their HW job duties (while remaining with the same employer) and duties which no
       longer include respirator use or further chemical exposure


The Medical Clearance Form, Attachment D, is a summary of the questionnaire and examination
results and is based on medical history, physical exam and test results. A physician or Licensed
Health Care Professional (PLHCP) should be knowledgeable in occupational medicine and is
preferably Board-certified in occupational medicine. The PLHCP will evaluate each individual’s
medical records, test results, OSHA questionnaire and job tasks to present their opinion on whether
that individual is medically able to perform their duties.

To participate in hazardous waste collection, each person’s medical clearance form should be
forwarded to the Hazardous Waste Coordinator, who will have a copy made for the Customer
Service Supervisor, one copy for the employee, and one copy forwarded to that member’s Human
Resource personnel file. The medical clearance form should be retained in that member’s HR
personnel file during the period of that person’s employment plus 30 years.

                             REQUIRED MEDICAL MONITORING

Staff who manage HW for greater than 30 days per year

Staff exposed to HW substances greater than OSHA’s Permissible Exposure Limit (PEL) or who
may be exposed to any open pesticide container contents for 30 or more days per year should
receive baseline, incident-specific, annual, and exit-based medical monitoring examinations, per
Attachment B of this SOG and per OSHA 29 CFR 1910.120(f)(2).

OSHA standards state that regardless of how many hours that staff spends working with HW, one
day of work equates to one calendar day of exposure. Therefore, all staff members who manage
HW more than 30 days per year through any combination of the activities listed below should be
enrolled in this Facility’s medical monitoring program:
           Accepting, sorting or screening for product exchange, packaging or other handling of
            HW containers and/or pesticides;
           HW spill containment and clean-up;
           Any activity that could require the wearing of a respirator; or
           Staff who may be exposed to any open pesticide containers and products.


Confidential Records

To maintain confidentiality, the Director of the Division of Solid Waste Management has determined
that the Citrus County Health Department and Human Resource Department should maintain and
retain all medical monitoring test results for SWM personnel who are required to wear a respirator.

Under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy Rule, only
the patient and, through a patient’s written ―authorization‖, their employer are permitted to view a
patient’s health status information. Employees should be aware that such authorization also
includes the Medical Clearance for Respirator Use form which determines that person’s medical
ability to wear a respirator.

An “authorization” is required by the Privacy Rule for uses and disclosures of protected health
information not otherwise allowed by the Rule. Where the Privacy Rule requires patient
authorization, voluntary consent is not sufficient to permit a use or disclosure of protected health
information unless it also satisfies the requirements of a valid authorization. An authorization is a
detailed document that gives covered entities permission to use protected health information for
specified purposes, which are generally other than treatment, payment, or health care operations,
or to disclose protected health information to a third party specified by the individual (U.S.
Department of Health and Human Services).

According to the Department of HHS, authorization must specify a number of elements, including a
description of the protected health information to be used and disclosed, the person authorized to
make the use or disclosure, the person to whom the covered entity may make the disclosure, an
expiration date, and, in some cases, the purpose for which the information may be used or
disclosed. With limited exceptions, covered entities may not condition treatment or the approval of
medical monitoring results on the individual providing an authorization.

                                   HIPAA Authorization Form
Federal Register/Vol 64, N. 212/Wednesday, November 3, 1999/Proposed Rules            (FR Doc. 99-28440)

                         Appendix to Subpart E of Part 164-Model Authorization Form
Section A: Must be completed for all authorizations

I hereby authorize the use of disclosure of my individually identifiable health information as described below. I understand
that this authorization is voluntary. I understand that if the organization authorized to receive the information is not a
health plan or health care provider, the released information may no longer be protected by federal privacy regulations.

Employee name: ___________________________________________________ County ID Number: _________

Employee’s address: ________________________________________________ Birth Date: _______________

Persons/organizations providing the information:                   Person/organizations receiving the information:
__________________________________________                         __________________________________________
__________________________________________                         __________________________________________
__________________________________________                         __________________________________________
__________________________________________                         __________________________________________

Specific description of information (including date(s)): ______________________________________________

Section B: Must be completed only if a health plan or a health care provider has requested the authorization

1.       The health plan or health care provider must complete the following:
         a. What is the purpose of the use or disclosure? _______________________________________________
         b. Will the health plan or health care provider requesting the authorization receive financial or in-kind
         compensation in exchange for using or disclosing the health information described above?
         Yes ____ No _____

2.       The patient or the patient's representative must read and initial the following statements:
         a. I understand that my health care and the payment for my health care will not be affected if I do not sign this
         form. Initials: ________
         b. I understand that I may see and copy the information described on this form if I ask for it, and that I get a copy
         of this form after I sign it. Initials: __________

Section C: Must be completed for all authorizations

The patient or the patient's representative must read and initial the following statements:

1. I understand that this authorization will expire on __ __/__ __/__ __ __ __ (DD/MM/YYYY) Initials: _________
2. I understand that I may revoke this authorization at any time by notifying the practice in writing, but if I do it won't have
   any affect on any actions they took before they received the revocation. Initials: ________

______________________________________________________                      __________________________
Signature of patient or patient's representative                            Date
(Form MUST be completed before signing)

Printed name of patient's representative: ___________________________________________________

Relationship to the patient: _______________________________________________________________
                               *THEY MAY REFUSE TO SIGN THIS AUTHORIZATION*

                                                   Attachment A

     Job Scenarios to Help Determine Medical Monitoring Needs
1.       Their job is to assist the main HW facility operator when the volume of waste
     becomes heavy. This includes tasks such as: labpack HW and bulk paint and
     flammable liquids; however, they will not be expected to wear a respirator for any
     reason. On average, this amounts to 1 day per month per year.
     Baseline examination — not recommended
     Surveillance examinations — not recommended
     Exit examination — not recommended
     Incident examinations for symptoms of overexposure — recommended
     Respirator certification — not recommended

2.      They are a back-up for the main HW facility operator. They expect to accept,
     sort and package HW for 15 to 20 days per year while the facility operator is on
     vacation. Based on their experience, they anticipate having a spill for which they
     will need to wear a respirator during clean-up.
     Baseline examination — not recommended
     Surveillance examinations — not recommended
     Exit examination — not recommended
     Incident examinations for symptoms of overexposure — recommended
     Respirator certification — recommended

3.      They are an assistant to the main HW facility operator. Their job is to accept,
     sort, labpack and bulk HW for an average of 1 day per week, per year. The bulking
     is done outdoors or inside of the facility which has adequate ventilation. They
     will not be expected to do any spill response, manage unsealed containers of
     pesticides, or to wear a respirator for any reason.
     Baseline examination — recommended
     Annual examinations — not recommended
     Exit examination — recommended
     Incident examinations for symptoms of overexposure — recommended
     Respirator certification — not recommended

4.    As a technician-assistant to an operator of a small HW facility, they manage HW an
     average of 1 day per week for the year. In the past 2 years, they have not worn a
     respirator and are not expected to do spill response within the facility. In the
     process of accepting household hazardous waste, they accept and manage unsealed
     containers of pesticides.
     Baseline examination — recommended
     Annual examinations — recommended
     Exit examination — recommended
     Incident examinations for symptoms of overexposure — recommended
     Respirator certification — not recommended

5.    They accept, sort and package all of the HHW and CESQG waste received at their
     facility. They manage HW approximately 100 days per year. Of those 100 days, they
     manage unsealed containers of household pesticides, 15 to 20 days.
     Baseline examination — recommended
     Annual examinations — not recommended
     Exit examination — recommended
     Incident examinations for symptoms of overexposure — recommended
     Respirator certification — recommended

6.    As the main HW facility operator, they have always worked full-time managing HW,
     including CESQG waste. Their facility also has an agreement with various CESQG
     businesses and farmers to accept and store pesticides, many of which are in
     unsealed containers when they come into the facility. They manage pesticides for
     more than 30 days per year.
     Baseline examination — recommended (includes cholinesterase testing)
     Annual examinations — recommended (biennially)
     Exit examination — recommended
     Incident examinations for symptoms of overexposure — recommended
     Respirator certification — recommended

                                                 Attachment B

                 Components of the Baseline, Annual, and Exit
                      Medical Monitoring Evaluations
                        (Citrus County Health Department)

Physical Examination

A brief physical examination involving the examination of targeted organ systems based upon
patient response to the medical examination questionnaire. It is recommended the physical
examination include, at a minimum:

   Vital Signs (blood pressure, pulse, etc.)
   Height
   Weight
   Hearing
   Vision
   Color Vision
   Brief neurological examination
   Abdominal examination
   Musculoskeletal examination

Tests or Vaccinations

   Pulmonary examination (12 lead EKG)
   Spirometry (lung capacity)
   CBC with Differential / Pitts (blood testing)
   Cholinesterase (for staff handling unsealed pesticides more than 30 days per year). Baseline
    tests require two samples one week apart. This test is recommended during the baseline
    screening or following an acute exposure.
   ChemStrip (urinalysis)
   Heavy metal screening (chromium, heavy metal, PCB)
   Tetanus (as needed)
   PPd 86580 (Tuberculosis)
   Radiology test to check for pulmonary disease

                                         Attachment C
Employee should print, fill out, and give to the designated Physician or other Licensed
Health Care Professional (PLHCP) the following, mandatory Appendix C to 1910.134:
OSHA Respirator Medical Evaluation Questionnaire, Part A, Sections 1 and 2, as specified
in 29 CFR 1910.120(f)(6)(v):

Appendix C to Sec. 1910.134: OSHA Respirator Medical Evaluation Questionnaire

To the employer: Answers to questions in Section 1, and to question 9 in Section 2 of Part A, do not
require a medical examination.

To the employee:

Can you read (circle one): Yes/No

Your employer must allow you to answer this questionnaire during normal working hours, or at a
time and place that is convenient to you. To maintain your confidentiality, your employer or
supervisor must not look at or review your answers, and your employer must tell you how to deliver
or send this questionnaire to the health care professional who will review it.

Part A. Section 1. (Mandatory) The following information must be provided by every employee who
has been selected to use any type of respirator (please print).

1. Today's date:_______________________________________________________

2. Your name:__________________________________________________________

3. Your age (to nearest year):_________________________________________

4. Sex (circle one): Male/Female

5. Your height: __________ ft. __________ in.

6. Your weight: ____________ lbs.

7. Your job title:_____________________________________________________

8. A phone number where you can be reached by the health care professional who reviews this
questionnaire (include the Area Code): ____________________

9. The best time to phone you at this number: ________________

10. Has your employer told you how to contact the health care professional who will review this
questionnaire (circle one): Yes/No

11. Check the type of respirator you will use (you can check more than one category):
a. ______ N, R, or P disposable respirator (filter-mask, non-cartridge type only).
b. ______ Other type (for example, half- or full-facepiece type, powered-air purifying, supplied-air,
self-contained breathing apparatus).

12. Have you worn a respirator (circle one): Yes/No

If "yes," what type(s):____________________________________________________________



Part A. Section 2. (Mandatory) Questions 1 through 9 below must be answered by every employee
who has been selected to use any type of respirator (please circle "yes" or "no").

1. Do you currently smoke tobacco, or have you smoked tobacco in the last month: Yes/No

2. Have you ever had any of the following conditions?

   a. Seizures (fits): Yes/No

   b. Diabetes (sugar disease): Yes/No

   c.   Allergic reactions that interfere with your breathing: Yes/No

   d. Claustrophobia (fear of closed-in places): Yes/No

   e. Trouble smelling odors: Yes/No

3. Have you ever had any of the following pulmonary or lung problems?
   a. Asbestosis: Yes/No

   b. Asthma: Yes/No

   c.   Chronic bronchitis: Yes/No

   d. Emphysema: Yes/No

   e. Pneumonia: Yes/No

   f.   Tuberculosis: Yes/No

   g. ilicosis: Yes/No

   h. Pneumothorax (collapsed lung): Yes/No

   i.   Lung cancer: Yes/No

   j.   Broken ribs: Yes/No

   k. Any chest injuries or surgeries: Yes/No

   l.   Any other lung problem that you've been told about: Yes/No

4. Do you currently have any of the following symptoms of pulmonary or lung illness?
   a. Shortness of breath: Yes/No

   b. Shortness of breath when walking fast on level ground or walking up a slight hill or incline:

   c.   Shortness of breath when walking with other people at an ordinary pace on level ground:

   d. Have to stop for breath when walking at your own pace on level ground: Yes/No

   e. Shortness of breath when washing or dressing yourself: Yes/No

   f.   Shortness of breath that interferes with your job: Yes/No

   g. Coughing that produces phlegm (thick sputum): Yes/No

   h. Coughing that wakes you early in the morning: Yes/No

   i.   Coughing that occurs mostly when you are lying down: Yes/No

   j.   Coughing up blood in the last month: Yes/No

   k. Wheezing: Yes/No

   l.   Wheezing that interferes with your job: Yes/No

   m. Chest pain when you breathe deeply: Yes/No
   n. Any other symptoms that you think may be related to lung problems: Yes/No

5. Have you ever had any of the following cardiovascular or heart problems?
   a. Heart attack: Yes/No

   b. Stroke: Yes/No

   c.   Angina: Yes/No

   d. Heart failure: Yes/No

   e. Swelling in your legs or feet (not caused by walking): Yes/No

   f.   Heart arrhythmia (heart beating irregularly): Yes/No

   g. High blood pressure: Yes/No

   h. Any other heart problem that you've been told about: Yes/No

6. Have you ever had any of the following cardiovascular or heart symptoms?
   a. Frequent pain or tightness in your chest: Yes/No

   b. Pain or tightness in your chest during physical activity: Yes/No

   c.   Pain or tightness in your chest that interferes with your job: Yes/No

   d. In the past two years, have you noticed your heart skipping or missing a beat: Yes/No

   e. Heartburn or indigestion that is not related to eating: Yes/No

   f.   Any other symptoms that you think may be related to heart or circulation problems: Yes/No

7. Do you currently take medication for any of the following problems?
   a. Breathing or lung problems: Yes/No

   b. Heart trouble: Yes/No

   c.   Blood pressure: Yes/No

   d. Seizures (fits): Yes/No

8. If you've used a respirator, have you ever had any of the following problems? (If you've never
used a respirator, check the following space and go to question 9:)
   a. Eye irritation: Yes/No

   b. Skin allergies or rashes: Yes/No

   c.   Anxiety: Yes/No

   d. General weakness or fatigue: Yes/No

   e. Any other problem that interferes with your use of a respirator: Yes/No

9. Would you like to talk to the health care professional who will review this questionnaire about your
answers to this questionnaire: Yes/No

Questions 10 to 15 below must be answered by every employee who has been selected to use either
a full-facepiece respirator or a self-contained breathing apparatus (SCBA). For employees who
have been selected to use other types of respirators, answering these questions is voluntary.
10. Have you ever lost vision in either eye (temporarily or permanently): Yes/No

11. Do you currently have any of the following vision problems?
   a. Wear contact lenses: Yes/No

   b. Wear glasses: Yes/No

   c.   Color blind: Yes/No

   d. Any other eye or vision problem: Yes/No

12. Have you ever had an injury to your ears, including a broken ear drum: Yes/No

13. Do you currently have any of the following hearing problems?
   a. Difficulty hearing: Yes/No

   b. Wear a hearing aid: Yes/No

   c.   Any other hearing or ear problem: Yes/No

14. Have you ever had a back injury: Yes/No

15. Do you currently have any of the following musculoskeletal problems?
   a. Weakness in any of your arms, hands, legs, or feet: Yes/No

   b. Back pain: Yes/No

   c.   Difficulty fully moving your arms and legs: Yes/No

   d. Pain or stiffness when you lean forward or backward at the waist: Yes/No

   e. Difficulty fully moving your head up or down: Yes/No

   f.   Difficulty fully moving your head side to side: Yes/No

   g. Difficulty bending at your knees: Yes/No

   h. Difficulty squatting to the ground: Yes/No

   i.   Climbing a flight of stairs or a ladder carrying more than 25 lbs: Yes/No

   j.   Any other muscle or skeletal problem that interferes with using a respirator: Yes/No

                                      ATTACHMENT D

                               Citrus County: A healthier future for the people of Florida!

TO:            SWM, Hazardous Waste Coordinator
               P.O. Box 340
               Lecanto, FL 34460

FROM:          Citrus County Health Department

SUBJECT: Clearance Form for Respirator Operation (Fit Testing)

Name: _____________________________________________ Date of birth: _________________

OSHA, 29 CFR regulation 1910.134 section (b), part (10) states, "Persons should not be assigned to
tasks requiring use of respirators unless it has been determined that they are physically able to use the

Based on test results obtained and from answers provided on the OSHA Respirator Medical Evaluation
Questionnaire, this individual:

____ is medically qualified for employment without restrictions;

____ is medically acceptable for employment with restrictions/accommodations as noted;





____ is recommended to have a follow-up medical examination from a physician or licensed health
care professional (PLHCP) as referenced under OSHA 29 CFR 1910.134(e)(3).

The above recommendation has been determined by:

___________________________________________________                                               _________________
      Authorized Personnel                                                                              Date

                                                                                                            ADHINT40            Revised 9/2009

                                                          CHAPTER SIX
                                                     BLOODBORNE PATHOGEN
                            Hazardous                  CONTROL PROGRAM
                                     (Revised March, 2010)

Citrus County Solid Waste Management is committed to providing a safe and healthful work
environment for our work force. In pursuit of this endeavor, the following exposure control plan
(ECP) is provided to minimize or eliminate occupational exposure to blood borne pathogens. This
Exposure Control Plan is written in accordance with the OSHA standard 29 CFR 1910.1030,
―Occupational Exposure to Blood borne Pathogens‖.

                         Regulatory and contractual requirements

This Bloodborne Pathogen Program is governed by the requirements of the HW Program and
OSHA Standard 29 CFR 1910.1020, 1910.1030, and Rule 38I-20.003 of the F.A.C., which adopts
federal Occupational Safety and Health standards and regulations.; Rule 10D-104, Florida
Administrative Code; and Florida DEP, Bureau of Personnel Services, Rule DEP 457.

                                 BBP Program Components

The OSHA Bloodborne Pathogen (BBP) control program includes the following components:
    Employee Exposure Determination - to be made without regard to the use of PPE;
    Program Administration;
    Methods of Exposure Control;
    Hepatitis B Vaccination;
    Post-Exposure Evaluation and Follow-up;
    Hazard Notification; and
    Training
    Accident Investigation

                             Employee Exposure Determination

During their normal course of employment, staff members:
    are exposed to broken glass and/or needles
    are exposed to materials or packages which may contain blood or OPIM
    may have to perform first aid for fellow HW staff members (OSHA 29 CFR 1910.120)
    clean up from or are exposed to products which may contain blood or OPIM

Therefore, it has been determined by the Director of SWM that employees who work directly
with either solid or hazardous wastes may likely have an exposure to blood or other
potentially infectious materials (OPIM) in the course of performing their job duties and
should be classified as having a high-risk-of-exposure.

Part-time, temporary, contract and per diem employees are covered under this standard.

                                   Program Administration

The Customer Service Supervisor will be the Administrator and will be responsible for the
implementation of the BBP Program. In this capacity, the Customer Service Supervisor will
maintain, review and update the BBP Program at least annually.

Those employees who have been identified to have a likely occupational exposure to blood or other
potentially infectious materials (OPIM) in the course of performing their job duties are advised to
adopt the best practice guidelines and work practices as outlined in this ECP.

The Customer Service Supervisor will be responsible to ensure the initial and annual training of
staff, and to ensure that the required recordkeeping is being maintained or passed on to the Citrus
County Risk Manager.

The Customer Service Supervisor should keep abreast of, maintain and provide adequate Personal
Protective Equipment (PPE), engineering controls (e.g. sharps containers) and Hazard Notification
as required by this standard. The Hazardous Waste Coordinator should ensure that adequate
safety supplies and equipment are available in appropriate selections and sizes.

                                Methods of Exposure Control

Engineering controls should be the primary method of exposure control. Engineering controls are
used to isolate or minimize the exposure of staff to blood or OPIM.


Sharps containers for storage of needles and sharps. These containers should be filled to no
more than ¾ the total capacity before being sealed and picked up by the Citrus County Health
Department. If available, sharps containers should be placed in areas where there is limited
exposure to the public or other employees who are not considered high/moderate risk.

Hand washing facilities with soap and tepid running water should be available to employees.
Alcohol based hand cleansers should be made available to employees whose job duties require
that those duties be performed in an area where hand washing facilities are not available.

Equipment should be available to pick up broken glass, needles or used sharp containers (e.g.
clamps, forceps, brooms, shovels and/or dustpans).

Thick Nitrile, Latex or Vinyl gloves should be made available to clean up spills of blood or OPIM.
 Employees with latex allergies should be provided approved, non-latex gloves when performing
duties where there is a likelihood of exposure to blood or OPIM.

Face shields or goggles and face mask should be worn when there is likely to be a splash or
exposure to the face/eyes. Aprons, coveralls, head and foot covering should be worn when it is
―reasonably‖ likely that there will be splashes of blood or OPIM on skin and clothing.

Approved disinfectants and cleaners should be available for equipment and /or surfaces that
have been contaminated with blood or OPIM.

Employees who are designated to provide first aid or CPR should be provided with first aid and
CPR supplies (face shield or bag mask) that would minimize contact with blood and OPIM, per 29
CFR 1910.120..

Engineering controls should be evaluated during all post exposure investigations. Engineering
controls should be instituted when an investigation conclusion supports that use of these controls
would eliminate or minimize exposure risk.


Work Practice Controls are safe work practices. These practices are part of the operating, best
practice guidelines of the Solid Waste Management Division. Listed below are general Work
Practice Controls that are universal to all SWM members and job descriptions:

Visually inspect all equipment and environment for contaminants prior to starting work duties.

Do not eat, drink, apply lip gloss, smoke, or handle contact lenses in work areas that may have
reasonable likelihood of contamination with blood or OPIM.

Never touch your face, eyes, nose or mouth without first washing your hands.

Solid Waste staff should wear protective gloves when:
     The skin of employee is cut abraded or chapped. Cover all open areas of skin prior to
       gloving or beginning work duties.
     There is a reasonable anticipation of hand contact with blood , OPIM or mucous
     When working with and/or cleaning contaminated surfaces or equipment.
     When dealing with any hazardous waste material
     Prior to administering first aid or CPR

Utility, non-permeable work gloves should be worn during housekeeping, cleaning or
decontamination per best practice guidelines.

Gloves and other PPE should be chosen based on the anticipated exposure to blood or OPIM.
Protective equipment should be considered appropriate only if it does not allow blood or OPIM to
pass through or reach clothing, skin, eyes, mouth, or mucous membranes under normal conditions
of use and for the duration of time for which the PPE is used.

Eye covering, face masks, and/or goggles should be worn when there is a reasonable anticipation
of splashing or misting of blood or OPIM.

Gowns, aprons, coveralls, or other protective coverings should be used when there is likely
exposure by splashes of blood or OPIM to head, torso, arms and legs.

Personal Protective Equipment (PPE) should be removed as soon as the procedure is completed
and safety permits. Contaminated reusable equipment should be cleaned with an appropriate
disinfectant, as per manufacturer’s instructions.

PPE should be evaluated by staff supervisors and coordinators. The Customer Service Supervisor
should review evaluations and have authorization to select the appropriate PPE. More than one
option should be available for evaluation. All PPE should meet minimum NIOSH or other national

Contaminated laundry should be removed and double bagged, as safety permits, for cleaning
services that are equipped to handle contaminated laundry.

Wash hands after removal of disposable gloves and any/all other PPE

When feasible, place absorbent padding on areas which may become contaminated (e.g.
hazardous waste carts, storage cabinets and work tables).

Never pick up sharps w/ bare hands. Use broom and shovel/dustpan or clamping device to pick up
sharps. Sharps should be disposed of in a ―sharps‖ container, obtained from the Citrus County
Health Department. If sharps needles are found in the Citizens Service Area, they may be
deposited into one of the metal roll-off containers, for disposal.

Contaminated, disposable, medical supplies should be placed in leak proof, color coded containers
or ―red biohazard bags‖ and disposed of accordingly.

Clean all drains or imbedded materials with broom, rake or other approved instruments that prevent
direct contact with your hands.

Never clean or touch drains w/ hands unless the drain has been decontaminated or removed from
the source of contamination. Lift all pumps out of contaminated drainage prior to repair or
maintenance, utilizing best practice guidelines.

Never use hands or feet to compact trash.

Never recap, bend or shear new or used needles. One handed recapping by the ―scooping‖
method is permitted if the disposable needle is not an option.

PPE should be donned prior to administering first aid. Always use a face shield, bag valve mask or
mouth shield prior to performing CPR, if performing mouth to mouth resuscitation.


Inspect normal work areas for contamination, worn or torn surfaces. Surface storage and work
areas should be cleaned on a routine schedule and after becoming contaminated.

Use appropriate PPE, Nitrile or Latex utility gloves when doing routine cleaning and
decontamination. Gloves should not be disinfected and reused. Inspect gloves before each use
for signs of wear, tears or cracks. Discard all torn or worn work gloves.

Leather work gloves absorb contamination and should be used only as an outer covering for Nitrile
or Latex utility gloves, when dealing with contaminated materials.

Contaminated material should be placed in a trash receptacle that is leak proof and puncture
resistant. .Clean or disinfect reusable equipment per manufacturer’s instructions.

When able, contain and post areas of contamination. Cover spills w/ absorbent material to assist
with cleanup and removal, per Attachment D.

Surfaces or equipment contaminated with blood or OPIM should be cleaned and decontaminated
as soon as possible, using household bleach which has been diluted between 1:10 to 1:100 with

Dispose of unused solution following the decontamination process. This sanitary solution is most
effective when mixed immediately prior to application. After application, let dry for approximately 10
minutes. Always clean or disinfect reusable equipment, per the manufacturer’s instructions.

                                   HEPATITIS B VACCINATION
Hepatitis B is a serious bloodborne infection caused by the Hepatitis B virus. Hepatitis B is one of
several types of hepatitis, including Hepatitis A, C, D and E. All types cause inflammation or injury
to the liver. In the United States, more than one million people are chronically infected with

hepatitis B, which means they will have this infection for a lifetime. More than 4,000 people die
every year in the U.S. from liver disease or liver cancer, caused by Hepatitis B.

Hepatitis B is 100 times easier from which to be infected than HIV, the virus that causes AIDS.
Hepatitis B is spread through contact with infected blood, body fluids or OPIM. The Hepatitis B
virus can survive and remain infectious in dried blood for up to seven days.
The U.S. Public Health Service, The American Academy of Pediatrics and the World Health
Organization all recommend that all children, and any adult who potentially may have exposure to
hepatitis B infection, be vaccinated.

The Hepatitis B vaccine series consists of an administration of three vaccine doses. The first dose
should be done within 10 days of initial assignment of high risk duties; the second one month later
and the last vaccine 6 months from the first dose. Determination as to the level of dosing should
be done according to the current Center for Disease Control’s (CDC) recommendations.

The Hepatitis B vaccine series will be offered free of charge to any employee whose job description
involves a high risk of exposure to blood or OPIM.

Training on Blood borne Pathogens, Hepatitis B vaccine efficacy, risks and benefits should be
offered within 10 days of initial assignment to high risk duties. This training should be provided
before the administration of a Hepatitis B vaccine series.

After receiving the initial training, those who elect to receive the protective vaccination should sign
the ―Election to Receive‖ form, as found in Attachment E. Employees who decline the vaccinations
should sign a Hepatitis B Declination Form, as provided in Attachment F.

The election or declination form should be maintained in that employee’s Human Resource medical
file. An employee has the right to decline these vaccines, but will be given the vaccine at no
charge, at a later date, if he/she should decide to, later, have the vaccination.

The available vaccine stimulates active immunity against HBV infection and can provide protection
against Hepatitis B for seven (7) years or more, following vaccination. 90% of persons develop
immunity following a properly administered vaccination series.

The HBV vaccine has been reported to be 70 – 80% effective when given within one (1) week after
HBV exposure to a non-immune person.

It is important that employees complete the vaccination series once started, according to
the three-series schedule in order for the vaccine to give effective protection against the
virus. If stopped before the series is completed, the three-shot series may have to be
initiated again, from the beginning.

The Hepatitis B vaccine will be offered to the employee after receiving the training required, within
10 days of initial assignment to high risk job duties. Vaccines will be administered by a licensed
healthcare professional (LHCP), as directed by the Citrus County Board of Commissioners and in
accordance with the guidelines of the U.S. Public Health Service (USPHS).

The vaccination for high risk, SWM employees is recommended and encouraged unless:
    Documentation exists that the employee has previously received the series and antibody
      testing reveals that the employee is already immune, or
    Medical evaluation shows the vaccination is contraindicated
The Citrus County Health Department can evaluate each high risk job employee, as above,
regarding their need for the vaccine. Employees that have already received the series may be
recommended to have a Hepatitis B Antibody Titer drawn to determine their level of immunity.


A Bloodborne Pathogen (BBP) exposure incident is defined as exposure to blood or OPIM:
    to mucous membranes (e.g. eyes, nose and mouth)
    to non-intact breaks in the skin or
    by parental contact (i.e. needle stick or a piercing of the skin)

Following an exposure, the injured person should immediately clean the exposed body area,
removing any contaminated clothing. Thoroughly wash the affected body area with antibacterial
soap and water. Mucous membranes should be flushed with clean water for up to 15 minutes.

Notify their supervisor and the BBP Program Administrator so that a Bloodborne Pathogen
Exposure Incident Report and a First Report of Injury or Illness can be completed. After the wound
is cleaned and dressed, the supervisor should contact Risk Management as soon as possible.

Exposure to communicable disease should be considered an occupational health hazard and any
communicable disease contracted as the result of a documented workplace exposure should be
considered to be occupationally related.

The First Report of Injury or Illness is to be typed, completed, and found via the intranet;
    A designated employee or supervisor should complete the First Report, not the employee.
    After completion, the supervisor & employee should then sign the First Report of Injury.
    Employee will be given a copy of each of the four pages of this formwork.
    Fax a copy of the First Report of Injury to Risk Management at 527-5300, within 24 hrs.
    Documentation of route and circumstance of exposure, source individual and medical
       treatment provided should be included on the First Report of Injury.
    The exposed staff member should also keep a copy of this form.

The employee should seek medical care as soon as they have cleaned the wound and completed
their paperwork. The employee should report to either Access Health Care or Allen Ridge Clinic,
for non-emergency care. If both of these facilities are closed, the employee should report to the
Citrus Memorial Hospital Emergency Department. Follow-up should be done at either Access
Health Care or Allen Ridge on the next business day. A copy of the completed First Report of
Injury or Illness should be sent with the employee for use by the clinic.

Confidentiality of the exposure information and of the persons tested must be maintained. A
person’s medical information is exempt from the Public Records Act. An employee’s medical
records must be maintained for at least the period of employment plus 30 years.

The Medical Provider should determine the need for medications, immunizations and source
testing. Baseline blood work should be drawn. Follow-up testing should be performed at either
Access Health Care or Allen Ridge, following the current CDC post exposure protocols. The
employee should be asked to read the protocols and sign a permission slip for HIV testing. A
schedule should then be given the employee for follow-up testing.

Pretest counseling will be done prior to baseline blood collection and must include:

      Purpose of the test - The test is for HIV antibodies, which will show up when someone has
       been infected with the disease. The time period to develop antibodies may vary from two
        weeks to six months. Most people develop antibodies within two to three months.
       Information about HIV and HBV should be provided to include the risk of infection and the
        need for early evaluation for HIV and HBV.

If the source of exposure is an individual who has tested positive to HIV or a person who refuses to
be tested, inform the exposed employee to report and seek a medical evaluation for any feverish
illness that occurs within 12 weeks of the exposure. During the follow-up period, especially during
the first six to twelve weeks after exposure, the exposed employee should follow recommendations
of the U.S. Public Health Service for preventing transmission.

Each exposure incident should be reviewed by the Infection Control Officer, Customer Service
Supervisor to evaluate the circumstances surrounding the exposure and SWM current policies
(Engineering, Work Practices, and PPE).

Post-exposure testing. The exposed employee should be tested as follows:

   a.   Initial, exposure test………………………..             HIV and HBV
   b.   Six weeks post-exposure……………….…               HIV and HBV
   c.   Three months post-exposure……………..             HIV
   d.   Six months post-exposure………………...             HIV
   e.   Nine months post-exposure……………….              HIV
   f.   Twelve months post-exposure…………….             HIV

The consenting employee will receive appropriate vaccination/treatment that conforms to CDC
recommendations for Hepatitis B prophylaxis following percutaneous or permuccosal exposure.

                                     HAZARD NOTIFICATION

Both the public and employees should receive sufficient warning of the presence of bio-hazardous
waste through labels, signs and tags.

The biohazard symbol warns of the actual or potential presence of a biological hazard.           This
international symbol should be displayed on:

       Equipment and containers which contain biohazard waste
       Refrigerators and freezers which are meant to contain blood or OPIM
       Containers used to store, transport or ship blood or OPIM
       Rooms that are used to store biological hazards or contaminated w/ biological agents

Sharps containers should be leak proof, puncture resistant, color coded red, and sealable. These
containers should be kept in a place out of reach of children.

Tags should contain the word ―Biohazard‖ as the signal word and may be followed by a descriptive
word (e.g. Biohazard Medical Waste). The signal word should be readable at the minimum
distance of five feet. Tags should be affixed as close as safely possible to the hazard with a string,
wire or adhesive to prevent its loss or unintentional removal.

Contaminated laundry may be collected in a bag that is leak proof and labeled with a biohazard
sign and/or the sign will be red in color.


All employees at this Facility who will have a likely occupational exposure to blood or OPIM should
receive training, through County Roscoe, in bloodborne virus infection prevention, prior to starting
job duties that are high risk. BBP training should be updated and provided to the employee
annually. The Customer Service Supervisor should oversee the training on the BBP Program,
individual job duties, and work practice controls that are specific to each person’s work site.

Training should be conducted by an individual who is knowledgeable about all the content elements
required by the OSHA standards and knowledgeable about the Hepatitis-B Vaccine.

All solid waste employees should attend one of these classes within six months of employment
and, as a refresher, annually thereafter. Training on Blood borne Pathogens, Hepatitis B vaccine
efficacy, risks and benefits should be provided within 10 days of an employee’s initial assignment of
high risk duties. HBV and/or BBP training should be provided before administration of the Hepatitis
B vaccine series.

Bloodborne Pathogen training should involve interactive questions and answers with the facilitator
conducting the session. At a minimum, the training program should include the following
      The OSHA Bloodborne Pathogen Standard; how to access a copy during working hours;
      epidemiology, modes of transmission, and symptoms of bloodborne diseases;
      how staff can access or obtain a copy of this Facility’s Bloodborne Pathogen Program;
      appropriate methods for recognizing tasks and other activities that may involve exposure to
       blood or other potentially infectious materials;
      proper Personal Protective Equipment (PPE) use (e.g., types, location, removal, handling,
       selection basis, decontamination, disposal);
      use and limitations of methods that prevent or reduce exposure (e.g., appropriate
       engineering controls, work practices, PPE);
      actions to take and contact information for an emergency involving blood or OPIM;
      Hepatitis B vaccine information (e.g., efficacy, safety, administration method, benefits,
       offered at no charge to the employee, declination process);
      procedures following an exposure incident (e.g., reporting methods, medical follow-up).
      follow-up evaluation process required after an exposure incident occurs.
      clean-up procedures for blood and other potentially infectious materials (OPIM);
      recognition of biohazard markings (e.g., signs, labels, color coding to denote biohazards)

All employees should be informed of the location of this Division’s written, BBP Exposure Control
Program. Each employee should also be offered an opportunity to receive a copy of our facility’s
Bloodborne Pathogen control Program.

Employees who have proof of testing positive for the antibody or have proof for receiving the
Hepatitis B vaccine and those who either accept or decline a vaccination should be provided annual
BBP information and training.


Training records should be completed for each high risk employee who attends the initial and/or
annual BBP training. Training should be documented on the Human Resources Safety Training
Sign-In Form. Training records should be kept for at least three years by the Citrus County
Training and Development Director.

Under the OSHA BBP program, the Human Resource Safety Training Sign-In Form should include:
    The dates of the training session
    The contents or a summary of the training session
    The name and qualifications of the person conducting the training
      The names and job titles of all persons attending the training session

A copy of the employee’s training records will be provided upon request to the employee or the
employee’s authorized representative within 15 working days of the request to Human Resources.
This request can be made as a public record request.

Medical records of immunizations and post exposure care should be copied for retention at the
Citrus County Human Resource Department, for the term of that person’s employment plus thirty
years. Medical records are exempt from Florida Sunshine public records disclosures. Therefore,
the release of medical records should only be done with written authorization of the employee
and/or by subpoena.

Post exposure medical recording may necessitate that the information is forwarded to the Risk
Management Department and its Workers Compensation Carrier. Medical records will be made
available to OSHA and NIOSH officials, as required by law. Medical records will be maintained for
at least the duration of employment plus 30 years.

                        Attachment A
           Bloodborne Pathogen Program Definitions
o   Blood: human blood, human components, and products made from human blood.
o   Bloodborne pathogens: pathogenic microorganisms present in human blood that can
    infect and cause disease in humans. These pathogens include, but are not limited to,
    Hepatitis B virus (HBV), Hepatitis C virus (HCV), and Human Immunodeficiency Virus
o   Contaminated: the presence or the reasonably anticipated presence of blood or other
    potentially infectious materials on items or surfaces.
o   Decontamination: the use of physical or chemical means to remove, inactivate, or
    destroy bloodborne pathogens on a surface or item to the point where they are no
    longer capable of transporting infectious particles and the surface or item is rendered
    safe for handling, use, or disposal.
o   Engineering controls: controls that isolate or remove the bloodborne pathogens
    hazard from the workplace: e.g., sharps disposal containers, or self-sheathing needles.
o   Exposure incident: a specific eye, mouth, other mucous membrane, non-intact skin, or
    parenteral contact with blood or other potentially infectious materials resulting from the
    performance of a staff member’s duties.
o   Hand-washing facilities: a facility providing an adequate supply of running potable
    water, soap, and single-use towels or hot-air drying machines.
o   Licensed healthcare professional: a person whose legally permitted scope of practice
    allows him or her to independently perform Hepatitis B vaccinations and post-exposure
    evaluation and follow-up.
o   Occupational exposure: reasonably anticipated skin, eye, mucous membrane, or
    parenteral contact with blood or other potentially infectious material that may result from
    the performance of a staff member’s duties.
o   Other potentially infectious materials (OPIM): includes human body fluids—semen,
    vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, peritoneal fluid,
    amniotic fluid, saliva in dental procedures, any body fluid visibly contaminated with
    blood, and all body fluids in situations where it is difficult or impossible to differentiate
    between body fluids. Unless visibly contaminated with blood, saliva (except in dental
    operations), feces, vomit, and urine are not considered to be OPIM.
o   Parenteral: piercing mucous membranes or the skin barrier through such events as
    needle sticks, human bites, cuts, and abrasions.
o   Post exposure prophylaxis: any medical precautionary treatment started immediately
    after exposure to a pathogen (such as a disease-carrying virus) in order to prevent
    infection by the pathogen and the development of disease.
o   Regulated waste: includes (1) liquid or semi-liquid blood or OPIM; (2) contaminated
    items that would release blood or OPIM in a liquid or semi-liquid state if compressed; (3)
    items caked with dried blood or OPIM that are capable of releasing these materials
    during handling; (4) contaminated sharps and used needles; and (5) pathological and
    microbiological waste containing blood or OPIM.
o   Sharps: any object that can penetrate or cut the skin and produce an opening in the
    skin or a puncture wound that would expose staff to blood or OPIM.
o   Source individual: any individual, living or dead, whose blood or other potentially
    infectious materials may be a source of occupational exposure to the staff.
o   Universal precautions: an approach to infection control. According to the concept of
    Universal Precautions, all human blood and certain human body fluids (OPIM) are
    treated as if known to be infectious for HIV, HBV, HCV, and other bloodborne

                             Attachment B
               Removal of contaminated disposable gloves
   Use two fingers to pinch the outside of one glove (near the inner wrist) with the other gloved
   Turn the glove inside out as it is pulled off.
   Use gloved hand to loosely hold the removed glove.
   Reach inside second glove with two fingers of the bare hand and pinch it.
   Turn the glove inside out as it is removed, enclosing the first glove.
   Properly discard the entire package in waste receptacle.
   Wash hands after removal of disposable gloves and any other PPE.

                                 Attachment C
                        Proper Hand-Washing Technique

   Remove rings and watches before washing.
   Hands should be positioned lower than arms to prevent back flow contamination.
   Running water is necessary to carry away dirt and debris.
   Wet hands with warm running water, apply antibacterial soap, and lather well.
   Rub hands together in a circular motion applying light friction. Include front and back of both
    hands, between fingers and knuckles, around and under fingernails, and the wrist area. (For
    proper timing, sing ―Happy Birthday to you‖ two times while washing hands)
   Rinse hands under running water.
   Dry hands with clean dry paper towel or air dryer.
   Avoid direct contact of washed hands with faucet. If foot, elbow or knee controls are
    unavailable, drape paper towel over faucet handle prior to turning off.
   Discard soiled paper towel in waste receptacle.

                                       Attachment D
                                      Blood clean–up
   Wear Nitrile, Latex or other impervious gloves for any blood cleanup.
   Eye covering, face masks, and/or goggles should be worn when there is a reasonable
    anticipation of splashing or misting of blood or OPIM.
   Gowns, hazardous waste aprons, coveralls, or other protective coverings should be used
    when there is likely exposure by splashes of blood or OPIM to head, torso, arms and legs.
   Use an absorbent material (rag, paper towel, etc.) or item covered with absorbent solidifier to
    wipe up blood.
   Place contaminated items in a plastic bag (not red) and dispose of in the garbage (as long as
    they do not meet the definition of a regulated waste).
   Wash the surface with detergent and water.
   Surfaces or equipment contaminated with blood or OPIM should be cleaned and
    decontaminated as soon as possible, using one of the following methods:
        o household bleach diluted between 1:10 to 1:100 with water. Dispose of unused
            solution following the decontamination process. This solution is most effective when
            mixed immediately prior to application.
        o EPA-registered tuberculocidal disinfectants or products registered against Hepatitis B
            virus (HBV), used according to label instructions.
   After a surface is disinfected using a bleach solution, let it air dry (approximately 10 minutes),
    or use an appropriate commercial disinfectant according to manufacturer directions.
                                       Attachment E

      Election to Receive the Engerix-B / Hepatitis-B Vaccine
            (Based on the Citrus County Fire/Rescue, BFST Model Safety Program)

I, _____________________________________ (please print) do hereby request to receive the
Engerix-B / Hepatitis B vaccine.

I understand that:

       1.      This vaccine is being offered by the Citrus County Division of Solid Waste
               Management, on a voluntary basis.

       2.      The Employer will pay for the cost of the vaccine series.

       3.      No blood or blood products are used to make Engerix-B. It is made from yeast
               cells that have been changed by genetic engineering.

       4.      You should not be vaccinated if you are allergic to YEAST.

       5.      The Engerix-B / Hepatitis-B vaccine consists of a series of three (3) injections,
               administered on Day one (1), on Day thirty (30) and on Day one Hundred and
               Eighty (180).

       6.      Any employee who is pregnant or suspects that she might be pregnant should
               first consult with her private physician before taking the series. Employees who
               become pregnant after starting the series should consult their private physician
               before continuing the series.

       7.      The Engerix-B / Hepatitis-B vaccine is stated to be 90% effective; that is, 90
               people out of 100 who receive the vaccine develop immunity to the Hepatitis-B

       8.      There are some side effects to the Hepatitis-B vaccine injections, but they are
               usually mild and last only a little while. The most common side effects are:

                      a)      Soreness, redness and swelling at the injection site

                      b)      A slight fever may develop or you may feel tired, dizzy or have a

Dated this ________ day of _________________, year ____________

By _____________________________________              SS ________ - ________ - ________

                                        Attachment F

                         Hepatitis B Declination Statement
          (Taken from the Citrus County Fire/Rescue, BFST Model Safety Program)

The following statement of declination of the Hepatitis B vaccination may be signed by a staff person,
if they choose not to accept the vaccine. The statement should be signed by staff only after following
appropriate training regarding Hepatitis B, Hepatitis B vaccination, the efficacy, safety, method of
administration, and benefits of vaccination, and that the vaccine and vaccination are provided to staff
free of charge. This statement is not a waiver; since staff will be able to request and receive the
Hepatitis B vaccination at a later date, if they remain occupationally at risk for Hepatitis B.

This Hepatitis B Declination Statement (Mandatory) is written for use and is copied as a document
from OSHA 29 CFR 1910.1030 Appendix A.


I understand that due to my occupational exposure to blood or other potentially infectious
materials I may be at risk of acquiring hepatitis B virus (HBV) infection. I have been given the
opportunity to be vaccinated with hepatitis B vaccine, at no charge to myself. However, I decline
hepatitis B vaccination at this time. I understand that by declining this vaccine, I continue to be at
risk of acquiring hepatitis B, a serious disease. If in the future I continue to have occupational
exposure to blood or other potentially infectious materials and I want to be vaccinated with
hepatitis B vaccine, I can receive the vaccination series at no charge to me.

I, (print name) __________________________________________ decline the Engerix-B/Hepatitis-B
vaccine series at this time.

Employee signature: ________________________ Date: ____________ SS#: _____ - ____ - _____

                              Attachment G
               Bloodborne Pathogen Exposure Incident Form
              (Present this form to the Physician, after reviewing it with the Supervisor)

                                                      Date of Incident: __________________________________

Employee name: ___________________________             Soc. Sec. #: _____________________________________

Job title:__________________________________           Date of birth: _____________________________________

Home phone: _____________________________              Work phone: _____________________________________

Exposure date: ____________________________            Exposure time: ____________________________________

Where did the incident occur?   ___________________________________________________________________

Nature of incident (contaminated needle stick; splash to exposed membrane or non-intact skin)
Describe what task(s) were being performed when the exposure occurred:
Were they wearing Personal Protective Equipment (PPE)?  Yes  No        If yes, list: ________________________


Did the PPE fail?  Yes  No    If yes, explain how: __________________________________________________

To what fluids were they exposed? _______________________________________________________________ _

What parts of their body became exposed? _________________________________________________________

Was this a puncture wound?  Yes  No       If yes, what was the object? __________________________________

Where did it penetrate their body? _________________________________________________________________

Was any fluid injected into their body?  Yes  No   If yes, what fluid? ___________________________________

How much? ___________________________________________________________________________________

Did they receive medical attention?  Yes  No    If yes, where? ________________________________________

When? __________________________________               By whom? _______________________________________

Identification / name of source, individual ___________________________________________________________

Name of Person Making Report (Can be the member involved or supervisor)

Signature ____________________________________            Title __________________________________________

Date _____________________________

                                    CHAPTER SEVEN
                              TRAINING AND CERTIFICATION
                                  FOR HW EMPLOYEES
                 Waste                                (Revised March, 2010)

To comply with federal, minimum training requirements and to retain a skilled staff, this facility will
conduct an educational program which is job specific and provides a worksite analysis to prevent
and control hazards. Hazardous waste training will include subjects involving County procedures,
HW program guidelines, hazard identification, categorization and mitigation, the Department of
Transportation (DOT), Environmental Protection Agency (EPA), and the Occupational Safety and
Health Administration (OSHA). Accidents and injuries cost money. Ongoing, operational health
and safety training programs pay for themselves.

                                   Regulatory Requirements

Hazardous Waste collection and training requirements are established for the Citrus County HW
collection program through various Code of Federal Regulations, including the (EPA) 40 CFR
265.16, (DOT) 49 CFR Parts 172.700 - 172.704 and (OSHA) 29 CFR 1910.38, 1910.95(k),
1910.120(e), 1910.134 (k), 1910.135, 1910.138, 1910.1000, 1910.1030 (g), 1910.1020, and
1910.1200 (h).
                              General HW training requirements

Program Administrator There should be a dedicated Program Administrator who will ensure
compliance with all HW training requirements. For this program, the Administrator will be the
Hazardous Waste Coordinator. This person should ensure that Hazardous Waste staff members
are provided and successfully complete all required and recommended training.

Six Months For the purpose of handling hazardous waste, staff members should receive their
necessary and required certification and training within six months of their date of appointment or
date of hire. This is referenced through the above listed EPA, DOT and OSHA regulations.
Therefore, new employees should not work in unsupervised positions until they have become
certified, qualified and adequately trained. .

Site-Specific Training Each job duty requires training specific to that task. This ensures that all
Facility staff receives standardized, required training to successfully and safely perform their job.

Temporary Staff and Volunteer Training Temporary staff or volunteers on site occasionally or for
a specific, limited task (e.g., assisting at a mobile collection event) and who are unlikely to be
exposed over permissible exposure limits (PEL) should receive preliminary Right-to-Know
training. These persons should work under the direct supervision of a trained and experienced
Program staff member.

Minimum Staffing This facility is designed and permitted to receive both Household and CESQG
hazardous waste. This Program sorts, packs, stores, bulks and otherwise handles hazardous
waste. Because of the nature of the job, there will be at least one on-site person who has no less
than 40 hours of training in the various aspects of hazardous waste/material management, including
the selection of appropriate protective equipment, clothing, procedures and emergency responses.
While collecting and sorting hazardous waste materials, there should be no fewer than two staff
members to assist each other with material acceptance and handling, hazard identification, medical
assistance and/or emergency response.
                                 Initial and Refresher Training

Facility personnel should successfully complete training programs which teach them to perform
duties in a way that ensures the facility is operated in a manner which protects them, their fellow
employees and the public from potential health and safety hazards, while safeguarding the

Initial instruction should be provided by a person who has been trained in regulated, hazardous
waste management. The person providing the initial training should have no less than 40 hours of
training in the various facets of hazardous waste management.

Personnel should take part in an annual review of the various operating procedures related to their
job, including the requirements set forth by the DOT, EPA, OSHA, FDEP and other regulating
agencies. Staff members should take refresher training for required certifications and aspects of
hazardous waste handling. Initial and refresher training should involve the following, federal areas:

                       Department of Transportation (DOT) Training

DOT Security Awareness Training- HW staff should receive annual security awareness training
and in-depth security training (49 CFR 172.704(a)); see SOG on DOT Security Plan, to include:

      Awareness of risks
      Methods to enhance transport security
      How to recognize security risks
      How to respond to security threats
      Facility security objectives
      Specific security procedures
      Staff responsibilities
      Security breach actions
      Organizational security structure

DOT Security, In-Depth Training for county HW Staff should be reviewed by the HW
Coordinator annually, conducted throughout the year, and should be specific to the Citrus
County HW Program; topics to include:

      Safety awareness;
      Function-specific hazards;
      DOT hazard classification;
      Loading segregation;
      Securing HM during transport;
      Communications;
      Incident reporting;
      Packaging standards; and
      Transportation Security Awareness Planning

DOT Hazardous Waste Transportation Training is required for any facility staff member who
has a direct affect on hazardous material (HM) or hazardous waste (HW) transportation safety.
Required DOT Transportation Training will apply to any staff employee who either:

      Prepares hazardous materials for transport (bulks or lab-packs)
      Has responsibility for HM safety;
      Loads, handles, or unloads HM materials;
      Operates HM transport vehicles; or
      Signs a DOT shipment manifest.

SWM, hazardous waste program staff and any staff members who are responsible for
preparing hazardous waste shipments for a licensed, hazardous waste transporter should
receive both the initial and refresher TREEO course - U.S. DOT Hazardous Materials/Waste
Transportation training. This training should include an awareness of:

      PPE use, testing and maintenance
      Routes of chemical entry
      Lab packing wastes
      Packaging, marking and labels
      Reactive or unknown wastes
      Waste packaging specifications
      Product Chemical/Category List
      Package inventory sheet usage
      Land Disposal Restrictions
      Invoice Tracking and manifesting
      Hazard Categorization Guide
      Bulking and grounding wastes
      Shipping day requirements

Refresher, DOT Hazardous Waste Transportation Training – The Department of
Transportation requires that, every three years, staff who are covered under this section take a
refresher course in DOT Hazardous Waste Transportation operations. Refresher training may
be accomplished by either attending those classes offered by TREEO, approved state
NAHMMA conferences or through equivalent training which utilize approved DVDs and/or DOT
web-based training.

                              OSHA Health and Safety Training

Staff who work in the HW facility area, who may be required to wear a face piece in the course
of their employment, must receive the initial, OSHA 40 hour and annual, OSHA 8 hour refresher
health and safety training. Health and Safety training includes the procedures within this
guideline manual, a critique of incidents that have occurred over the past year and should also

      Employee Right-to-Know (RTK) Training
      Staff First Aid/CPR
      OSHA recordkeeping
      Asbestos wastes
      Eye, face, and head protection
      Hand and foot protection
      Hazard communication
      Personal protective equipment
      Respiratory protection and fit testing
      Medical monitoring
      Bloodborne pathogens
      Noise and hearing conservation
      Contingency and emergency procedures plan (including spill response)
      Powered industrial trucks (forklifts)
      Lock out / tag out
      FAC, RCRA, EPA and OSHA regulations
      Occupational health and toxicology
      Fire or flammable materials
      Fire extinguishing methods
      Recognizing and controlling hazards
      Heat and cold stress
      Identifying and handling explosive and reactive materials
      Emergency eyewash and showers
      Hazardous Waste Operations (HazWoper)

OSHA HazWoper Training - OSHA outlines three different types of Hazardous Waste Operations and
Emergency Response (HazWoper) training: 40-hour, 24-hour, and an 8-hour refresher course.

Staff members who handle hazardous waste and who may be required to wear an air purifying
respirator should be certified at the 40 hour, OSHA HazWoper level. Facility staff should successfully
complete their initial 40 hour OSHA training during their first six months of employment. Until trained,
staff should work under the direct supervision of an experienced staff member who has completed the
40 hour certification.
OSHA HazWoper Training should contain subjects which include:
      Health and safety and/or potential hazards which are present on a work site
      PPE selection, maintenance and use
      Minimizing hazard risks through the application of proper work practices
      Medical surveillance (e.g., recognition of symptoms and signs of over exposure)
      Maximizing safety through the use of engineering controls and equipment

OSHA HazWoper, Annual Refresher Training - Staff engaged in HW processing, who have passed
their initial, HazWoper training, and who handle open packages of pesticides more than 30 days per
year, are identified by OSHA to receive annual medical monitoring and annual HazWoper refresher
training, per 29 CFR 1910.120(e)(8).

Medical Monitoring and Fit Testing – HW staff who may be assigned to handle hazardous wastes
should complete their baseline medical monitoring before coming into contact with toxic chemicals,
per OSHA 29 CFR 1910.120(f)(2). After a staff member completes the 40 hour HazWoper course,
completes their baseline medical monitoring examination and receives a physician’s approval to use a
respirator, he/she will be fit tested for an air-purifying respirator facepiece by the Citrus County
Fire/Rescue; see Chapter 5, Medical Monitoring.

Employee Haz-Comm, Right-to-Know Training - Prior to the initial handling of HW, staff should
receive the initial, Employee Right-to-Know (RTK) health and safety training, to include:

      an overview of the hazard communication (Haz-Comm), RTK Standard and Program
      location and availability of the facility’s written RTK program (MSDS sheets, postings)
      physical and health effects of on-site chemicals or processes
      instruction to read and interpret information on labels and MSDS
      methods, tests and observation techniques used to determine the presence of chemicals in the
       work area
      techniques for reducing or preventing exposure to hazardous chemicals or physical agents by
       using prudent work practices or personal protective equipment (PPE)
      how to reduce or prevent exposure to chemicals or physical agents
      emergency response procedures
      updates and reviews, if new chemicals or processes are introduced into work areas

First aid and CPR training - For the protection of on-site, HW personnel, this facility should have at
least one first aid and CPR-trained staff member on-site, during HW collection periods, per 29 CFR
1910.151(b). This is to protect fellow, HW staff workers and is due to the facility being located more
than 5 minutes (for life threatening injuries) away from the nearest medical hospital or EMS unit. As
soon as practical, the HW Coordinator, HW Specialist and HW Technician should become certified in
first aid and CPR application.

                          Hazardous Waste Staff Training Standards

Hazard awareness training for HW Collection Center workers should include a monthly refresher
covering each section of this SOG manual and SWM emergency and contingency guidelines. In
addition, each member should be made aware of and should be responsible for acquiring and retaining
the necessary certification, training and/or refresher courses for the following positions:
Hazardous Waste Coordinator
      40 Hour OSHA HazWoper Training (29 CFR 1910.1200 and 29 CFR 1910.134)
      8 Hour HazWoper Refresher Training (29 CFR 1910.1200 and 29 CFR 1910.134)
      SWM/HW Employee Right-To-Know Training by RTK Coordinator or Supervisor
      FEMA, NIMS, Incident Command 100, 200, 700 and 800B.
      DOT Regulations for Hazardous Materials Transportation (49 CFR 172.704)
      DOT Regulations for Haz-Mat Transportation Refresher (49 CFR 172.704)
      Chemical Compatibility and Storage (TREEO) (40 CFR 262, 49 CFR 172, 177)
      Haz-Mat Chemistry for the Non-Chemist (TREEO) (40 CFR 262, 49 CFR 172, 177)
      Orientation to In-house, DOT Security Plan (49 CFR, Part 172.800)
      RCRA Hazardous Material Regulations for Generators
      40 Hour Fire/Rescue first responder First Aid and CPR (29 CFR 1910.151(b))
      8 Hour Florida first responder First Aid and CPR Refresher (29 CFR 1910.151(b))
      OSHA Hazard Communications Right to Know – RTK (TREEO)
      EPA Facility Spill Prevention and Control (TREEO)
      Florida DEP SQG Student Orientation Guide for SQG Inspectors
      Florida DEP, Class 1, 2 and 3 Landfill Operations Spotter Training (TREEO)
      Florida DEP, Class 1, 2 and 3 Landfill Spotter Training Refresher (TREEO)
      OSHA Forklift Safety Certification (29 CFR, 1910.178)
      Monthly, in-house Safety and Procedure Manual Refresher Training

Hazardous Waste Specialist
    40 Hour OSHA HazWoper Training (29 CFR 1910.1200 and 29 CFR 1910.134)
      8 Hour HazWoper Refresher Training (29 CFR 1910.1200 and 29 CFR 1910.134)
      SWM/HW Employee Right-To-Know Training by RTK Coordinator or Supervisor
      FEMA, NIMS, Incident Command 100, 700 and 800B.
      DOT Regulations for Hazardous Materials Transportation (49 CFR 172.704)
      DOT Regulations for Haz-Mat Transportation Refresher (49 CFR 172.704)
      Chemical Compatibility and Storage (TREEO) (40 CFR 262, 49 CFR 172, 177)
      Haz-Mat Chemistry for the Non-Chemist (TREEO) (40 CFR 262, 49 CFR 172, 177)
      Orientation to In-house, DOT Security Plan (49 CFR, Part 172.800)
      40 Hour Fire/Rescue first responder First Aid and CPR (29 CFR 1910.151(b))
      8 Hour Florida first responder First Aid and CPR Refresher (29 CFR 1910.151(b))
      Florida DEP SQG Student Orientation Guide for SQG Inspectors
      Florida DEP, Class 1, 2 and 3 Landfill Spotter Training and Refresher classes (TREEO)
      OSHA Forklift Safety Certification (29 CFR, 1910.178)
      Monthly, in-house Safety and Procedure Manual Refresher Training
Hazardous Waste Technician
       40 Hour OSHA HazWoper Training (29 CFR 1910.1200 and 29 CFR 1910.134)
       8 Hour HazWoper Refresher Training (29 CFR 1910.1200 and 29 CFR 1910.134)
       SWM/HW Employee Right-To-Know Training by RTK Coordinator or Supervisor
       FEMA, NIMS, Incident Command 100, 700 and 800B.
       DOT Regulations for Hazardous Materials Transportation (49 CFR 172.704)
       DOT Regulations for Haz-Mat Transportation Refresher (49 CFR 172.704)
       Chemical Compatibility and Storage (TREEO) (40 CFR 262, 49 CFR 172, 177)
       Haz-Mat Chemistry for the Non-Chemist (TREEO) (40 CFR 262, 49 CFR 172, 177)
       Orientation to In-house, DOT Security Plan (49 CFR, Part 172.800)
       40 Hour Fire/Rescue first responder First Aid and CPR (29 CFR 1910.151(b))
       8 Hour Florida first responder First Aid and CPR Refresher (29 CFR 1910.151(b))
       Florida DEP, Class 1, 2 and 3 Landfill Spotter Training and Refresher classes (TREEO)
       OSHA Forklift Safety Certification (29 CFR, 1910.178)
       Monthly, in-house Safety and Procedure Manual Refresher Training

Hazardous Waste Assistant
    SWM/HW Employee Right-To-Know Training by RTK Coordinator or Supervisor
       Florida DEP, Class 1, 2 and 3 Landfill Spotter Training and Refresher classes
       Orientation to In-house, DOT Security Plan (49 CFR, Part 172.800)
       FEMA Incident Command Training, NIMS, Sections 100, 700 and 800B
       OSHA Forklift Safety Certification (29 CFR, 1910.178)
       Monthly, in-house Safety and Procedure Manual Refresher Training

                                          Training Records

The following personnel documents and training records should be maintained at the office of Human
Resources and/or the Division of SWM:

   The job title for each position at the facility related to hazardous waste management, and the name
    of the employee filling each job;
   A written job description for each position. This description should include the requisite skill,
    education, or other qualifications, and duties of facility personnel assigned to each position;
   A written description of the type and amount of initial and continuing education that will be required
    for each person filling a position; and
   Certificates and the accompanying class agenda documenting that the training or job experience
    required for each position has been completed by facility personnel.

A printed, training database has been developed and posted, listing position names along with required
and recommended coursework, training, certification courses, recertification courses and monthly SOG
Chapters which are scheduled for review.

                                     CHAPTER EIGHT
                              RECEIVING HAZARDOUS WASTE
                                  FROM PARTICIPANTS
                Waste                                  (Revised March, 2010)

The purpose of this procedure is to direct and encourage facility members to provide outstanding
customer service to participants and to ensure the safe receipt and proper management of both
Household and CESQG Hazardous Wastes.

Health and Safety Requirements

When possible, engineered solutions to environmental conditions and experienced staff judgment
should be utilized for each hazardous waste management situation. At a minimum, while accepting
household or CESQG waste, staff members should wear:
    safety glasses with side shields or goggles
    safety footwear protection
    latex or Nitrile protective gloves
    reflective or safety yellow shirts, sweat shirts or coats
    protective apron, smock or equivalent

Proper ergonomic techniques should be used while handling wastes. Such techniques include to:
    avoid bending and twisting while lifting materials from vehicles;
    be aware of weak hazardous waste containers. Cardboard boxes and paper bags may appear
       to be strong, but could tear when lifted;
    assist participants in unloading their paint containers (e.g., 5-gallon buckets, 1-gallon cans),
       but staff should discourage them from unloading or handling any other type of pesticide,
       corrosive or chemical waste;
    not provide any type of protective gear for use by household or CESQG participants;
    use a cart to move wastes from the vehicle unloading area to the waste sorting area.

Staff should prescreen waste for their potential hazards and be aware of suspicious activities or
behaviors, to ensure the security of the HW facility. It is important that precautions for the overall
health and safety of staff are addressed, (e.g., training, PPE, SOGs). Staff should be trained within six
months of hire or starting a new position or should be supervised by trained and experienced staff.
Staff should make every attempt, in the course of their normal duties, to prevent a negative impact to
the environment.

Equipment and Supplies

      Carts: made of non-porous materials, to provide secondary containment.
      Secondary containment: Place leak-proof containers (Tupperware, etc.) in pre-sort areas
       and label with the applicable waste type. Staff should ensure that incompatible waste types are
       not placed in close proximity; see SOG on Sorting and Screening.
      Presort tables: May be set up in areas utilizing good material process handling. Ensure that
       enough tables or carts are in place for incoming wastes.
      Spill kits: stocked and readily available; see SOG on Spill Response.
      Signage: to prohibit smoking and direct traffic flow.
      PPE: Proper PPE should be worn and available throughout the collection event. To reference
       the correct type of protective gear, see Chapter 3 of this SOG on Personal Protective
       Equipment - PPE.
                            PROCEDURES FOR RECEIVING WASTE
Customer Service

The acceptance of hazardous waste provides an opportunity to provide good customer service and
education. HW staff should be encouraged to enroll in courses involving dispute resolution and
customer service. Staff members should:
 encourage customers to be a wise consumer of chemicals, providing them with non-hazardous
 be courteous and provide efficient service; respond to participant complaints, suggestions, and
 be sensitive and informative to the needs of all who utilize the Program’s service
 present a neat and clean appearance
 avoid confrontation
 provide publications, program guides, HW product listing, or other printed materials
 offer a customer service response card to all participants who would like offer suggestions

Does this waste come from Citrus County?

Most of the funding for this Citrus County HW collection and recycling program is derived from the
collection of a solid waste assessment on each homeowner’s annual property tax bill. Because the
funding for hazardous waste collection and disposal is local, this Program may need to verify the
identity of an individual by requesting to see a driver’s license or other acceptable proof of residency.

Is the waste is from a residence or business?

Commonly accepted household hazardous waste streams include paints, flammables, corrosives,
aerosols, pesticides, and cleaners. Participants with questionable wastes may be required to sign an
assurance certifying the waste was not generated from a business. If a participant indicates the load
was generated from a business, the participant will be asked questions to determine their business
generator status, since only Conditionally Exempt Small Quantity Generator (CESQG) business waste
may be accepted by this facility. This Program is not permitted to accept waste from larger
businesses, since they must be licensed by the State and their waste must be delivered to a licensed
disposal facility; see Chapter 34 SOG on CESQG Haz-Waste Management. Business-generated
waste must be paid for, in full, and may not be passed as free HHW. When a suspicious waste is
brought in, pose questions to the participant and be alert for waste that:
 is transported in a commercial vehicle
 contains unusually large quantities of a single product (greater than 5 gallons)
 includes hazardous waste that is not normally purchased for residential homes
 is in containers displaying the markings ―for commercial use only‖

Protocols to help determine homeowner vs. business waste qualifications

  Homeowners may include those residents who live in apartment buildings, hotels and motels, and
   other multi-unit housing. If the hazardous waste is being delivered by a business or government
   entity, all of their waste deposits will be a chargeable expense. In addition, if the materials were
   used in the course of construction, demolition or renovation by a contractor, such waste is
   considered business-generated.
 Home-based businesses: If the incoming waste is from an ongoing, home-based business, it
   should not be accepted as being household-generated. However if the waste was abandoned at
   someone’s home and the people involved in the business are no longer living or their whereabouts
   are unknown, then the waste may be accepted as household hazardous waste (HHW).
Unacceptable waste types include, but are not limited to:

       Friable asbestos; see Chapter 26 of SOG on Managing Asbestos Waste. Only non-friable-
        asbestos containing asbestos fibers that are bound in tar-like or petroleum-based materials
       (such as roofing tar) should be accepted for disposal.
      Infectious or biohazard wastes are not accepted at this SWM Facility. County Health
       Department sharps disposal containers are accepted at the front, SWM office, during normal
       office hours.
      Non-hazardous waste, empty containers or regular household trash is not accepted as
       hazardous waste. Such waste can be placed with other trash.
      Explosives which are larger than residential, Division 1.4, should not be accepted by this
       program. Explosives from commercial businesses should not be accepted. In the event larger
       explosives are inadvertently accepted or found at this facility, the facility Emergency Response
       Coordinator (ERC) should notify the local sheriff’s department who may notify the Special
       Operations Bomb Squad.
      In general, radioactive material should not be accepted. Upon discovery of material known or
       suspected to be radioactive, the ERC should contact the current HW disposal contractor or
       local hazmat team for further directions. However, low-level, ionization-type smoke detectors
       may be disposed of in the trash, as solid waste.

Unidentified waste

Staff should attempt to learn as much as possible about unidentified wastes from the participant,

      where the material was stored or located
      is the waste generated within Citrus County and/or from a business
      if the participant had any hobbies, etc., that should provide clues as to the contents; see SOG
       on Managing and Identifying Unknown Hazardous Waste.

Condition of materials

Staff members should be mindful of the condition of incoming waste containment. Preferably, HW
should be received in its original, sturdy, non-leaking and properly labeled container. Any leaking
container should immediately be placed into secondary containment (e.g., over-pack drums, five-
gallon pails, heavy plastic bags, plastic buckets, etc.). If material has spilled into a participant’s
vehicle, the staff may assist with cleanup as much as practical.

Unloading Vehicles

Participants who transport wastes to this facility should do so in a manner that is generally safe for
staff to access and handle. This Program should not encourage, expect or allow staff to expose
themselves to unsafe hazards. If waste is delivered in a manner that is unsafe (i.e., leaking or covered
with other debris or very heavy items, such as refrigerators, broken glass, waste wood with nails etc.),
staff should inform the participant of the following options:

      staff may unload or remove the materials so that the HW load is safe to handle
      staff may offer assistance to the customer, to ensure the waste is accessible and manageable
       (e.g., move the items to be relocated to the rear of the vehicle)
      the customer can dispose of the waste at another time, when it is brought in a safe manner
      the customer should assume all risks and liability, in the event of an injury, if that customer
       unloads or moves the material without assistance from the Facility staff

Staff responsible for receiving waste from participants should perform the following steps:

   1. Direct the customer to the designated staging area for unloading
   2. Ensure that there is NO SMOKING in the receiving area
   3. Complete any applicable information forms or questions, as needed
   4. Inspect the waste load and be aware of containers that are:
          a) unlabeled
          b) leaking
          c) posing any immediate hazards
          d) possibly commercial wastes
          e) other unacceptable waste types
   5. Transfer acceptable waste onto a cart and bring the cart into the Facility sorting area.
   6. Primary containers are generally not returned to the participant. Secondary containers may be
      returned upon request of the participant if it does not appear to be significantly contaminated.
      Special arrangements may be necessary for a later return of containers (e.g., gasoline cans).
   7. This Facility may provide the participant with printed information regarding alternatives to
      hazardous household products, disposal options for unacceptable materials, and other
      information as requested.
   8. Segregate materials by their waste type or hazard class and place into a pre-sorted container
      or area for later lab-packing or bulking; see Chapter 12 of this SOG on Sorting and Screening
      Incoming Hazardous Waste.


If the material is brought into the collection center (or mobile collection) in an open or leaking container,
the site personnel should place the container and/or material into a larger, appropriate (e.g. plastic or
metal) receptacle (i.e. zip lock bag or 5 gallon bucket) and properly label the container. Any spilled
material should be soaked up with absorbent material (pads, vermiculite, abzorbit or oil-dry), which is
stored in the material locker. The contaminated, absorbent materials should also be handled as a
hazardous waste, packaged, labeled and sealed in an appropriate container and stored in chemical
storage lockers. Exception – if less than 25 gallons of waste motor oil or petroleum waste has been
absorbed into pads, socks or vermiculite, such absorbent material can be disposed of in the cell as a de
minimus quantity of solid waste.

                                    ACCEPTANCE PROCEDURES

Household Hazardous Waste (HHW)

This facility should only accept household waste if:

      it is material which is acceptable for disposal through our contracted, TSDF contractor;
      the material fits a hazard class which is accepted at this facility;
      there is no indication that the waste is being disposed of by an business;
      the HW should be in its original container and properly labeled;
      household Waste can be safely contained at the HW facility prior to transport and disposal

During scheduled collection days and times, the HW collection center will accept up to 10 gallons or 60
pounds of material from homeowners for no additional charge. If the volume of material brought in is so
large or if the nature of the material is such that it is suspected of being commercially generated, the
following procedures should be used:

   1. Request that the individual complete a Household Hazardous Waste Participant Certification
      form attesting that the material is residential, rather than being generated by a business.
   2. If the individual indicates that the waste is indeed commercially generated, HW staff should use
      their discretion to:
      a. weigh the materials and have them charged at the CESQG disposal rate; or
      b. follow the referral procedures for disposal of CESQG generated waste to State-licensed HW

Practice good judgment. If acceptable to our FDEP Permit, sometimes it is better to accept a small
amount of commercially–generated materials rather than take the risk that the individual will illegally
dump the material onto the ground or into our water aquifers.

CESQG Hazardous Waste

If possible, CESQG businesses owners should call before bringing their hazardous waste to this
collection facility. Facility personnel should enforce the following criteria with respect to CESQG
hazardous waste:

   a. Hazardous waste may be accepted only from CESQG businesses which have been inspected and
      are part of the DEP, SQG database.
   b. Do not accept unknown products from CESQG's. The generator is required to identify the process
      generating the waste and all materials that are used within that process. From that information,
      the generator or the facility supervisor must be able to determine which EPA waste codes are
      applicable to that waste;
   c. Only accept their hazardous waste if the CESQG can verify that it is what the generator says it is.
      (Note: a good way to do this is to find out what tests the contracted, HW hauler or disposal facility
      uses to verify the product description and waste code)
   d. When possible, schedule a convenient date and time at which they should bring their hazardous
      waste to this facility. Doing so will provide they enough time to verify the CESQG business
      information, waste classification, proper storage method, etc.
   e. Verify through county tax records that the waste source is being generated from Citrus County and
      that the business is a small, Conditionally Exempt Small Quantity Generator;

Household Hazardous Waste During Non-Program Days

Household hazardous waste may be accepted from Citrus County residents during times when the
resident is either unable to be in the County during scheduled collection days and/or when hazardous
wastes are present, along with other solid waste which is being disposed. These materials should be
screened for acceptance by the Hazardous Waste Coordinator, Hazardous Waste Specialist, HW
Technician, or by the Customer Service Supervisor.

All hazardous wastes which are accepted at times outside of the scheduled HW collection times should
be charged at a normal rate. In this case, the first 60 pounds are not provided for free.

Hazardous wastes should be relocated, each day, to the HW collection area. At the first opportunity,
such waste materials should be sorted by hazard class and placed on the provided roll-away carts or
containment receptacles which are located on the secondary containment slab, within the fenced area of
the site.

If a Solid Waste technician or employee discovers a questionable or unknown material or if HHW is
dropped-off during non-program periods, the Hazardous Waste Coordinator, Specialist, Technician,
Assistant or Customer Service Supervisor should be contacted for assistance.
             Hazardous Waste Collection Center Opening / Closing Procedures

The collection center staff should open / close the hazardous waste collection center using the following

   a. Unlock and open the entry gate into the Hazardous Waste Collection Center;
   b. Activate the HW storage building exhaust fans (10 minutes minimum run time);
   c. After fans have exhausted the inside air, unlock and open the HW storage locker doors;
   d. Turn lights on, as needed, inside HW storage room lockers and work areas;
   e. Set up carts, tools, labels, spill materials and absorbents for the day;
   f.   Open the satellite, receiving drums, as necessary.

The procedures for closing the HW Collection Center should be the reverse of those utilized to open the
Facility. All tools, carts and work areas should be cleaned and returned to their usual positions, when
finished. At the end of daily operations, the storage lockers, containers and gate will be secured against
entry, helping to ensure this Facility’s security.


                    Citrus County Hazardous Waste Program

Household Hazardous Waste (HHW) Participant Certification

Please print legibly. Complete this Participant Certification form to ensure the
acceptance of their waste. They must include some documentation of residency in Citrus
County, such as a copy of their driver’s license or a bill showing their mailing address.

Name.                                                           D.L. #
Address.                                                        City.
Telephone.                                                      Zip.


I certify that the wastes I am delivering to the Citrus County Hazardous Waste
Collection Center are wastes from my residence within Citrus County and that none
of these wastes result from a business, a commercial enterprise, or household
outside the limits of Citrus County.
Date:                                Signature:

                                                  CHAPTER NINE
                                Mobile Household Hazardous
                Hazardous             Waste Collection
                Waste                                  (Revised March, 2010)
                             The Household Hazardous Waste Program is able to provide mobile
collection service for residential hazardous waste materials, off-site. A ―mobile event‖ utilizes County
personnel and contractors to accept HHW from qualifying participants, within a city or community.
This Procedure provides guidance to ensure proper requirements are followed for safe and efficient
acceptance of hazardous materials at mobile HHW events. During a mobile event, CESQG, small
business hazardous wastes will not be accepted.

                           Regulatory and Contractual Requirements

Citrus County hazardous waste regulations are referenced through the Florida Administrative Code
(FAC), section 62-730. The acceptance of HW is also governed by the requirements established in
the rules of the Florida-licensed waste hauler and the TSD contractor, OSHA 29 CFR 1910.95,
1910.105(e)(3)(v), 1910.141(a-d and g), 1910.147, 1910.151 and 151(c), 1910.157, 1910.178,
1910.1000, 1910.1030, 1910.1120(q), DOT 49 CFR 172.502 A-C and 172.504 A-B.

                                 Staff Training and Qualifications

The designated, mobile event staff member responsible for ensuring that a mobile collection event is
properly coordinated and within compliance will be the Customer Service Supervisor, who shall also
serve as the Mobile Collection Supervisor. Planning and training will be an integral part of ensuring
that the mobile collection event is properly handled. Staff should follow a written training program and
guidelines that describe the collection and management of household hazardous wastes. Job
assignments and scheduling should be consistent with their normal Facility positions and such
assignments should spell-out each person’s responsibilities, procedures, regulations, and contingency

Adequate experience and training in waste sorting and processing is necessary. Staff should be
trained within six months of hire or starting a new position, or be supervised by trained staff until such
training is completed. Refresher training should be conducted annually and be documented.

                                  Health and safety precautions

During an event, staff should closely and quickly evaluate all incoming, unknown or abandoned
containers to determine if there is a threat to life, health, or the environment (i.e. temperature
sensitive, spontaneously combustible, bulging/leaking containers, explosives). Event staff should
ensure the proper management of materials and evaluate each situation on a case-by-case basis; see
SOG on Sorting and Screening of Hazardous Waste. For traffic control and community awareness,
the Mobile Collection Supervisor should notify the local emergency response community prior to the
collection event; see Attachment A of this SOG.

Staff should employ the proper ergonomic techniques when handling materials. Safe work practices
should be utilized, to minimize or eliminate risk of injury for event staff. To prevent injury, avoid
bending or twisting movements (especially while lifting materials from vehicle trunks). Use carts, dollys
or drum movers to transport large or heavy containers. See Chapter 32 on Ergonomic Safety.
A personal protective equipment (PPE) policy should be crafted, specific to each collection event,
depending on the weather, amount of outside assistance, and the type and volume of products
expected. The judgment of the site manager should determine the PPE level to be utilized, but
generally, during mobile events, those items found in Attachment B should be used at the collection

Allow ample time for work breaks, especially in hot weather conditions. Provide liquid refreshments in
a designated location away from waste processing areas. Instruct event staff and volunteers to
remove their PPE and wash their hands prior to partaking of any break-time food or removing drinks
from coolers.

Ensure that there will be an immediate availability of fire suppression supplies and equipment which
will provide a 15-minute, constant water supply. In addition, a portable eyewash station should be
provided within a 10-second travel distance from wherever injurious or corrosive chemicals are
handled. This eyewash station should be able to flush eyes for at least 15 minutes.

Take immediate action when danger threatens staff and/or property. Review the current, SWM
Emergency Incident and Contingency Guidelines. Be alert for suspicious activities or behaviors; per
Chapter 22, DOT Security Plan.

Emergency response
Staff should be trained in spill mitigation and able to respond to those situations when small chemical
spills may pose a potential safety or health hazard. Staff should be responsible for cleaning up
incidental spills that may happen in the course of managing HHW at a collection event. The Mobile
Collection Supervisor should be authorized to call 911, contact Haz-Mat, Fire/Rescue, Special
Operations Teams or an emergency contractor to respond to spills or emergencies which would
require assistance beyond the capabilities of on-site staff.

Staff should handle leaking containers, using caution to minimize spills, by immediately placing any
leaking containers into secondary containment. Prevent slipping hazards and potential impacts to the
environment by providing mitigation and clean up of small spills.

                                     Equipment and supplies

Equipment needed at mobile event collection site
For a full list of equipment and supplies needed for safe collection events, see Attachment B of this

Powered industrial forklift
If it is determined that a forklift will be necessary to maneuver pallets, cubes, or drums, only
authorized and certified staff members will be permitted to operate such forklifts at the mobile
collection site. Staff should comply with the safety requirements pertaining to equipment use and

Lockout / Tagout (LOTO)
At each mobile collection event, an energy control program should be put in place (and agreed to by
everyone involved) prior to using any electrically-energized machines or equipment at the mobile
collection site. Exposure to the hazards of unexpected energization or start up can be controlled by
unplugging the equipment from the energy source and by ensuring the plug is under the exclusive
control of the staff performing the equipment operation / maintenance, in accordance with Chapter 31,
Lock out Tag out (LOTO) Program.

Location of the mobile collection event site
Mobile event collection locations should:
    be located more than 150 feet from water supply wells
    meet local zoning, building, and fire codes
    have access to a water outlet and lavatories
    provide operational work areas that have controlled or restricted access to the public
    stage traffic-queuing areas away from a busy street or on a road that is heavily used by the
       general public or commercial vehicles

Pre-event preparations

Consult and schedule with the County Solid Waste Director and the hazardous waste disposal
contractor, a few months prior to the scheduling of the event’s date, time and location. Request from
the contractor the number of additional personnel needed. Promote the upcoming collection event via
local media and flyers at least two months prior to the collection.

Recruit and arrange for adequate assistance prior to collection event. Some communities have groups
or organizations that are willing to assist with the collection event (e.g., local fire department, hazmat,
Kiwanis, CERT teams, and LEPC members). Ensure all event staff and volunteers are at least 18
years of age. Determine staffing needs by considering the processing methods and anticipated
participation levels.     Customer participation levels may be estimated by reviewing historical
participation records in light of the event promotional efforts.

Advise all staff assisting with the site set-up to:
    arrive at the site at least two hours prior to the collection event start time (volunteer help should
       arrive at least one hour early)
    wear old clothes as they will likely get paint or stains on them
    wear long sleeves, long pants, and closed-toe footwear
    bring rain gear, hats or other clothing necessary for the weather
    park in a location away from the collection site, specific for event staff
    refreshments and/or lunch may be provided to volunteers

Prepare a participant tracking device or a survey event sheet; see Attachment C of this SOG.
Designate an experienced and trained HW Program member to be the event Safety Officer.

Schedule with entities, SWM staff or contractors to deliver:
    two roll-off, 20 yard dumpsters to be on site the day of the collection event for all trash and
      non-regulated (solid) material, maintained in separate locations
    ample tables to be available the day of the collection event to set incoming HW on for further
    adequate ventilation to be provided in work and storage areas
    extra ventilation fans to event collection as a precaution
    a portable generator to power electrical equipment, fans, etc.
    port-o-lets for those on the collection site, as needed
    HW Program and promotional information (i.e., cups, totes, rulers, printed publications, facility
      hours, lists of unacceptable materials, other educational tools) to be distributed at the event
    Event refreshments (e.g., cooler with ice and drinks)

Event day preparations

The Mobile Collection Supervisor should ensure that the mobile collection event is well organized and
begins at the scheduled time. Prepare for rain by creating covers over the sorting, bulking and lab
packing locations.
The designated receiving, sorting, packaging, and storage areas should have flooring that is
impermeable to hazardous materials by covering them with a 6 mil poly tarp, duct taping or pinning the
edges. This will prevent tripping hazards, environmental impacts, and keep the floor or ground area
clean from leaks or spills.

Block any floor drains or storm drains at the event location to prevent releases to the sanitary sewer or
to the environment. Place sorting tables, latex cubicles, drums and/or cubic yard boxes near the
waste processing locations, to minimize handling. Cover and protect all sorting tables with plastic and
duct tape.

Prepare the following items prior to the start of the collection event:
    Covered, triage sorting tables for HHW product categorizing and sorting;
    Storm coverings for personnel and materials, over sorting, bulking, and lab packing;
    Open, lined cubicle containers for oil-based paint containers and latex paint containers.
    Lab packing area and tables, one each for pesticides, oxidizers and corrosives;
      Solid waste dumpsters (at least two)
      A container for aerosols which contain paint products (empty aerosol containers may be
       placed in the solid waste dumpster);
      A container for aerosols which contain non-paint products, insecticides, cleaners, etc.
      55-gallon container for adhesives and lubricants containing petroleum distillates;
      55-gallon bulking drum for ignitable fuels, thinners, solvents; to be grounded when adding or
       removing waste and placed in a shady location during the collection event;
      55-gallon container for non-regulated, sewer-able, surfactant and polymerized liquids;
      55-gallon containers for recyclable motor oils and a separate barrel for oil filters;

Prepare the area for both participants and volunteers:
    To maximize traffic flow efficiency, create signs and clearly mark the vehicle entrance and exit
      points using multiple, orange traffic cones.
    Post ―No Smoking‖ signs in conspicuous places. Smoking should not be allowed during the
      collection event.
    Designate a separate, shaded area for eating and drinking, where event staff will not be
      exposed to toxic fumes or materials.
    Ensure adequate ventilation is provided for personnel who work in bulking areas.
    Ensure that one dumpster is located adjacent to the receiving area, yet readily available for the
      first line of staff pre-sorters. Dumpsters may be lined with poly, sand or mulch, to absorb spills
      from waste containers.

                         Accepting materials during a collection event
Customer service
Event staff who are assisting at a collection event should:
    provide courteous and efficient service
    avoid confrontation with unruly participants
    be sensitive and informative to the needs of all participants
    present a neat and clean appearance
    provide accurate information and potential solutions
    respond to participant complaints, suggestions, and questions;
    offer them a B.O.C.C. customer response card

Event job duties
Mobile collection events provide this Program with an opportunity to educate the public on alternative
household products with less hazardous properties. Volunteers should be directly supervised by
trained personnel. Only designated, trained event staff should remove materials from incoming
vehicles or lab pack materials. Staff will be needed for assigned, event duties, including the:
     Mobile Collection Supervisor
     Event Safety Officer;
     survey takers and/or traffic regulators (to include Sheriff’s officers);
     trained staff to unload hazardous waste materials from vehicles;
     trained sorters to segregate or relocate materials into their various waste streams;
     fuel/solvent bulker;
     oil based and/or latex-based paint packers; latex paint consolidators; and
     lab packing personnel, obtained from the assigned TSD contractor..

Event Safety Officer tasks: Designate an experienced and trained Program staff member to be the
Event Safety Officer. This person will be selected, based on their ability to:
    ensure adequate equipment and supplies are available for event workers; see Attachment B of
       this SOG
    provide instruction on adequate spill response
    communicate the importance of proper PPE use and monitor use to ensure compliance
    identify and report chemical and safety hazards
      address safety issues to prevent incidents and accidents
      ensure immediate access to communication device(s)

The designated Event Safety Officer should provide safety training to all event staff members and
volunteers, prior to the start of the collection. This training should include instruction or review of:
     collection day processes, individual job assignments, and appropriate PPE
     location of each designated area (e.g., eating, drinking, lab packing, fuel bulking)
     break schedules and names of people who will fill in for those taking breaks
     removal of PPE and washing hands prior to eating or drinking
     site-specific, emergency contingency plan
     spill or injury procedures
     location and use of event safety equipment
     ensure that the assigned staff understands the on-site waste stream procedures
     any known physical hazards or obstacles (e.g., swales, holes, water sources, slippery
       surfaces, ergonomics, sharp-edged containers, needles, broken glass, etc.)
     chemical hazards (to avoid unnecessary exposures)
     the importance of showering as soon as possible following the collection event
     the dangers of incoming vehicles and logistics of traffic flow

Controlling traffic and taking surveys: The Sheriff’s office should be used for traffic assistance.
Designate well-informed event staff, survey takers. Multiple, knowledgeable survey takers should be
assigned and each should wear reflective traffic vests. Their responsibilities should include to:
     explain the survey to the public utilizing the collection event; see Attachment C of this SOG
     question the participant about waste generation; be alert for business-generated waste
     ensure the participant’s residency in Citrus County and number of households represented are
       recorded correctly onto the survey
     provide participants with printed handouts, publications, facility hours, or other educational
       materials—use the collection event as an opportunity to educate the public about the fact that
       empty containers can be included with solid waste (a common question at mobile event
     direct traffic into open lanes and unloading area, but avoid sending too many vehicles to the
       unloading area at one time;
     allow enough time for participant’s household materials to be safely unloaded
     provide good customer service and provide an opportunity for participants to ask questions of
       the survey takers
Unloading materials from vehicles: Process incoming materials in a safe and efficient manner.
Designate experienced event staff/TSD personnel to unload materials from vehicles. When assessing
incoming materials, staff should:
     ascertain whether the materials being generated are from a household or a business; a mobile
       HHW Program is not designed to receive CESQG wastes
     determine whether the delivered waste is a waste stream that the program is allowed to
       accept. Notify staff or authorities when unacceptable waste types are discovered. Provide
       space for deposited waste types which are not expected to be received.

For unknown wastes at mobile collection events:
    attempt to learn as much as possible about the material from the participant
    ask questions that may provide clues as to the contents (e.g., where the material was stored,
       where the material was found, if the participant had any hobbies)
    test the unknown materials (e.g., container markings or labels); contractor chemists and
       experienced staff will provide the expertise for proper disposal or classification

Minimize the need for physically carrying waste materials by ensuring that ample carts are available
while removing materials from vehicles. When unloading materials, staff should:
     place incoming materials directly onto a cart using proper ergonomic techniques.
      be aware of weak container bottoms, leaking containers, loosened lids, and airborne powder
       wastes and place immediately into secondary containment, if necessary
      bring the cart directly to the presort, triage table (specifically set up for incoming materials) and
       move the containers from the cart onto this presort table.
      ensure materials are organized to prevent spills or the mixing of incompatible waste types,
       which could create unsafe work conditions.
      avoid over-stacking the incoming materials by providing adequate staff and tables.
      return containers if participant specifically requests and if practical.

Pre-sorting wastes: Avoid double handling incoming materials.
Sort materials from the pre-sort, triage tables and bring to these designated stream areas:
    latex paints
    oil base paints
    fuel/solvents
    aerosols
    lab pack materials (pesticides, oxidizers, corrosives, etc.)
    sewer-able, surfactant liquids

Segregate unknown materials into secondary containers until further evaluation can be
performed; identification should be performed by TSD chemists or experienced staff.

Bulking wastes: All fuels, solvents, latex-based paints, and sewer-able surfactants will be
bulked at the event location or placed into cubic yard boxes for later processing.

Lab packing wastes: Only TSD chemists should lab pack incoming, HHW products. HHW
should be presorted and placed into secondary containment before the end of the workday.
Materials should be sorted, packaged, and labeled according to DOT regulations.

Transporting materials from mobile collection events
Program staff may accept and transport (or contract with a licensed HW transporter) household
waste products from the mobile event collection site to the Citrus County HW Facility.
Household waste is considered to be household hazardous waste only at the point at which an
outside contractor accepts household or CESQG waste for DOT transport to a TSD facility. For
additional information on the use of Shipping Papers for household waste transport back to the
landfill, refer to Chapter 20 on DOT Shipping Papers and Waste Tracking.
Staff members who are transporting mobile event wastes back to the SWM Facility will be
responsible for immediately reporting spills to the Sheriff’s Department, Florida State Warning
Point and/or the Citrus County Special Operations, Haz Mat Team. The intended transport
vehicle should be packaged and designed to be able to safely contain all the waste loaded
therein.      Waste should be secured and segregated for transport according to DOT
requirements. If transporting waste in open vehicles (e.g., rolloffs, flatbed trailers), the Program
should not leave the loaded vehicle unattended, fulfilling the haz-waste, DOT security policy.

                              Attachment A
                     Emergency Contacts Telephone Posting

This information will be posted near a telephone in areas where hazardous waste is handled or
                           stored (including inside a HW Mobile Unit).

            Emergency Coordinator                       Work Phone #             Cell Phone #

_Casey Stephens____ , Division Director               (352) 527-7670          Cell – 302-6980
       Emergency Coordinator Alternates

_Carmen Bruno_ , Customer Service Supervisor               (352) 527-7670             Cell – 400-0674
_Prime DeVaughn__ , Field Crew Leader                      (352) 527-7670             Cell – 400-1646
                                        Emergency Phone Numbers
Fire Department                                            911
Citrus County Haz-Mat or Bomb Squad                        911
Citrus County Sheriff’s Department                         911
Citrus Memorial Hospital
502 Highland Blvd., Inverness, FL 34452
                                                           (352) 637-3337

Florida State Warning Point (24-hr spill reporting)        (877) 272-8335

National Response Center (24-spill reporting)              (800) 424-8802

                             Vendors for Emergency Response Equipment

Fire extinguishers         Eveready Fire & Security: (352) 628-3553
Fire alarm system          Eveready Fire & Security: (352) 628-3553
Spill control materials    Clean Harbors Florida: (Mobile) (863) 559-6136
Special equipment          Citrus County Public Works Director: (352) 527-5477

This list, when complete and posted, fulfills the emergency contacts telephone posting
requirements for Small Quantity Generators (Citrus County Solid Waste Management).

                            Attachment B
             Equipment needed at mobile event collection site

                   Administrative                                       Waste processing
   brochures/disposal option information                 canopy or tent shading
                                                          6 ml poly/dumpster liner
   shipping papers/DOT transport labels
                                                          identification of unknowns paper / kit
   participant documentations;       See    HHW
                                                          can crusher (if needed)
    Participant Certification forms
                                                          carts and/or drum mover
   toilet and washing facilities
                                                          sorting tables
   potable drinking water

                                                                      lab pack containers
                    Emergency response
    spill control equipment                                          packing materials
                                                                      duct tape
    access to water
                                                                      55-gallon steel drums
    over pack drum/secondary containment
                                                                      55- gallon poly drums
    decontamination equipment                                        cubic yard containers w/ liners and pallets
                                                                       for oil-based paint, latex paint, tars and
    fire control equipment                                            adhesives

    portable, emergency eyewash equipment                            5-gallon pails w/ lids for small HHW
    first aid kit                                                    ventilation fan

    cell phone or other communication device                         funnels
                                                                      paint stir sticks
                           Traffic control
                                                                      can openers
    traffic cones
                                                                      spark proof bung wrench
    ―No Smoking‖ signs
                                                                      wrenches for drum lids
    applicable signage                                               grates for bulking wastes (if bulking on site)

    high visibility traffic vests for staff                          crescent and ratchet wrenches
                                                                      marking pens
                                                                      screw drivers
    safety glasses with side shields or goggles
                                                                      drum-top spatula for bulking oil-base paint
    footwear with reinforced toe protection or toe
                                                                      hammers
                                                                      cardboard dumpsters for trash
    Nitrile / latex protective gloves
                                                                      grounding rod and grounding cables for
    long-sleeved shirts / Tyvek sleeves                               the bulking of ignitable materials
                                                                      20 yard roll-off for solid waste disposal
    protective apron, smock, or equivalent

    long pants, coveralls, or equivalent

    respirator (when this Program requires one)

    reflective vests for staff in traffic hazard

                                 Attachment C
               Survey to be taken at a mobile event collection site

                                      Do they know    Are they able        Including         How satisfied are        Was a
                     How did they     we collect HW   to bring their      today, how           they with our          BOCC
    Zip Code         hear about our    every Tues,    HW through        often have you          current HW          suggestion
                     HW program?       Thur, & Fri      the week,       used the HHW             Collection        card handed
                                       9:00 – 1:00?    Tue, Thr, or     program in the           Program?            out to the
                                                           Fri?            past year?        (scale of 1 – 10)      customer?

                                    CHAPTER TEN
                               SORTING AND SCREENING
                                 HAZARDOUS WASTE
                 Waste                          (Revised March, 2010)

The timely processing of HW depends on the proper initial screening of incoming materials.
The steps outlined in this Procedure should be used to help determine a material’s waste
hazard classification, ensure incompatible materials are safely segregated, and provide
guidance for proper waste transportation.

                         Regulatory and contractual requirements

The sorting of HW is governed by the requirements established in this Facility’s Program, EPA
40 CFR Part 262.11, DOT 49 CFR Part 172.101, and OSHA 29 CFR 1910.120 (a), & (q).

                                       Staff qualifications

The designated Program staff person responsible for ensuring the proper sorting of hazardous
waste is the Hazardous Waste Coordinator. Prior to managing or preparing hazardous materials for
highway transportation, staff should complete their training in Hazard Categorization, Occupational
Safety and Health (HazWoper), and Department of Transportation (DOT); see Chapter 7 on
Employee Training and Certification. Staff should be trained within six months of hire or from
starting their new position or should be supervised by a trained and experienced staff member.

                                Health and safety precautions
Some incoming materials may be potentially dangerous and require stringent safety precautions.
Facility staff should evaluate these waste types on a case-by-case basis. Staff should assess
incoming waste containers, first, to determine if a threat to life, health, or the environment exists.

Engineering controls, work practice procedures and PPE should all be utilized to eliminate or
minimize hazard exposure to HW staff. Proper ergonomic techniques should also be used whenever
handling wastes.

The following, minimum PPE should be used when examining and sorting hazardous wastes:
    Safety glasses with side shields, goggles or equivalent;
    footwear with reinforced toe protection or protective toe caps
    Protective gloves
    Long sleeved smock, protective apron or equivalent
    Air-filtering respirator, as necessary.

If dangers are present to nearby personnel and property, take immediate action. Keep alert for
suspicious activities or behaviors.

Spill response

Facility staff should be responsible for cleaning up incidental spills which may pose potential
safety or health hazards. Facility staff should be trained and be able to respond to small spills.
Only trained emergency response staff should respond to control and clean up of spills
requiring assistance beyond the capabilities of Facility staff.
This Facility should have agreements with response teams and/or contractors who could be
used in case of an emergency; see SOG on Spill Response for Hazardous Waste and the
Emergency Incident and Contingency Guidelines.

Use extreme caution and minimize handling when processing leaking or potentially reactive
materials (e.g. temperature sensitive, spontaneously combustible, bulging/leaking containers,
explosives). Staff should prevent any impact to the environment by recognizing faulty container
integrity and by immediately placing leaking containers into secondary containment.

                                   Equipment and supplies

Staff should ensure that adequate space, proper equipment and sufficient supplies are
available to process wastes. Staff should stage their sorting area away from public access.
Use carts to move wastes into and within the Facility to avoid injury and accidental spills. Sort
onto shelving and/or lab pack wastes as soon as possible to minimize the chances of
incompatible chemical interactions.

                                  Procedures for sorting wastes

Facility staff responsible for sorting materials should be able to identify bulging or leaking
containers and immediately place them into secondary containment. Other incoming waste
materials should be sorted into one or more of the following waste categories:

     Known, hazardous waste. Containers with known contents which have complete,
      legible labels and/or whose contents have been verified by the participant delivering the

     Unidentified wastes. Staff accepting waste should attempt to learn as much as
      possible about unidentified wastes from the participant. If Facility staff cannot identify a
      waste’s characteristics sufficiently to determine a hazard class, the waste should be
      considered an ―unknown‖ and set aside in a designated area for further analysis; see
      SOG on Managing and Identifying Unknown Haz-Waste.

     Explosive and incompatible wastes. A written Facility protocol for recognition and
      handling of explosives should be established: See Chapter 13 on Explosive and
      Reactive Chemical Waste and Attachment C of this chapter.

     CESQG waste. Follow the specific acceptance protocol for CESQG waste. Following its’
      acceptance and weighing, CESQG business wastes may be commingled with HHW, as
      found in Chapter 34, CESQG Hazardous Waste Management.

     Product reuse materials. At a future point of time when materials are able to be set
      aside and deemed suitable for reuse, they should be set out in a Facility product
      exchange area.

Waste classification of incoming household wastes should be completed by the end of each
work day. If HW staff is not able to inspect or categorize incoming waste, it should be
segregated from each other on portable carts. For more information on categorization, see
Attachment B: A Partial List of Incompatible Wastes.

If no specific name or category name is available, use generic hazard classes for the incoming
product. Hazardous Materials are divided into nine hazardous material categories:

Class 1: Explosives                     This facility accepted Division 1.4, consumer fireworks and flares.
Class 2: Gases                          Flammable gases are accepted, in the form of aerosol propellants.
Class 3: Flammable Liquids              e.g. oil-base paints, thinners, fuels, combustibles
Class 4: Flammable Solids, Spontaneously Combustibles, and Dangerous when wet materials
Class 5: Oxidizers and Organic Peroxides
Class 6: Poison (Toxic) and Poison Inhalation, e.g. herbicides, insecticides, rodenticides, pesticides
Class 7: Radioactive                    Not accepted, except in smoke detectors which can go in garbage
Class 8: Corrosive                      Includes both acids (<2 pH) and bases (alkali) (>12.5 pH)
Class 9: Miscellaneous                  Including PCB ballasts

                                       ATTACHMENT A

       Categories and Examples of Acceptable Household Hazardous Wastes

The following is a partial list of household hazardous wastes within their corresponding hazardous
characteristic categories. The following wastes will be accepted at the HW collection center,
weekly or during quarterly program days.

                       Flammable and Combustible Liquids (Class 3)

Alcohol                                                      Adhesives
Automotive fluids (recycle with motor oil)                   Aerosols (lab pack paints separately)
Acetone (finger polish remover)                              Enamel / oil-based paint
Benzene                                                      Diesel Fuel
Creosote                                                     Ethanol
Fiberglass Resin (unsolidified)                              Fingernail polish
Formaldehyde                                                 Glues
Floor / furniture polish                                     Gasoline
Kerosene                                                     Lacquer thinner
Lacquer paints (unsolidified)                                Liquid sandpaper
Lighter fluid                                                Linseed oil
Methanol                                                     Naptha
Neadsfoot oil                                                Paint thinner
Paraffin oil                                                 Paint solvent
Power steering fluid (recycle with motor oil)                Petroleum distillates
Transmission fluid (recycle with motor oil)                  Polyurethane (unsolidified)
Toluene                                                      Rug / upholstery cleaner
Shellacs                                                     Turpentine
Spot remover                                                 Tung Oil
Varnish                                                      Xylene

Corrosive Acids – Class 8                                    Corrosive Base (Alkali) –Class 8

Battery Acid                                                 Ammonia-based cleaners
Boric Acid                                                   Caustic Soda
Copper cleaner                                               Drain cleaners
Hydrochloric Acid                                            Ferric Chloride
Liquid Iron (Fe)                                             Lye
Muriatic Acid                                                Oven cleaners (non-aerosol)
                                       Oxidizers – Class 5

       Ammonium Nitrate                                             Chlorine Bleach
       Calcium Hypochlorite                                         Chlorine
       Chlorates                                                    Chlorites
       Fluorine                                                     Hair dye
       Hydrogen Peroxide                                            Hair coloring
       Nitrates and nitrites                                        Nitric Acid
       Sodium Peroxide                                              Sodium Hypochlorite

                                   Poisons / Toxins – Class 6

       Ant and Roach killer                                         Anti-Freeze (recycle in CSA)
          Atrazine                                                 Bug baits (non-aerosol)
          Chlordane                                                Diazinone
          DDT                                                      Dursban
          Ethylene Glycol                                          Flea Spray / Powder
          Malathion                                                Herbicides
          Pentachlorophenol                                        Pentachlorethylene
          Pesticides                                               Plant food (weed & feed)
          Pruning Paint                                            Parathion
          Pyrethrums                                               Rose dust
          Round Up                                                 Sevin
          Snail / Slug killer                                      Tree root / stump killer
          Weed and grass killer                                    Windshield wiper fluids

                                      Heavy Metal Poisons

          Arsenic                                                  Chromium
          Copper Sulfate                                           Lead Arsenate
          Lead compounds                                           Mercury

                                    Unacceptable Materials

          Ammunition (over 50 cal) *                               Asbestos
          Explosives (any Class 1 other than 1.4) *                Biomedical Waste **
          Radioactive materials or devices                         Dioxins
          Highly reactive materials                                55 gallon drums of material
          Ammunition and explosives from CESQG businesses

*         Division 1.4 fireworks, flares, ammo and shotgun shells are accepted from homeowners.
          No commercial fireworks will be accepted.
**        Sharps containers will be collected at the front, administrative office.

                                  ATTACHMENT B
                            CHEMICAL INCOMPATABILITIES
           KEEP THESE                  AWAY FROM THESE                  OR THEY MAY GET
    Acids (pH 0 – 3)              Bases (pH 12.5 – 14)             Violent Reaction
                                  Reactive metals (aluminum,       Fire
    Water or Alcohol              beryllium, calcium, lithium,     Explosion
                                  potassium, magnesium, sodium,    Hydrogen Gas (highly
                                  zinc powder) or metal hydrides   flammable)

Reactive organic                  Concentrated acids or bases,
compounds or solvents             reactive metals and metal          Fire
(alcohols, aldehydes,             hydrides                           Explosion
nitrated hydrocarbons)

Cyanide or sulfide solutions      Acids                              Toxic hydrogen cyanide gas
                                                                     Toxic hydrogen sulfide gas
Strong oxidizers such as          Organic acids, concentrated
chlorates, chlorine, chlorites,   mineral acids, reactive metals,    Fire
chromic acid, hypochlorites,      metal hydrides, reactive organic   Explosion
nitrates, perchlorates,           compounds or solvents,
permanganates, or                 flammable or combustible wastes
peroxides                         or liquids

                               ATTACHMENT C
              A Partial Reference List of Incompatible Chemicals
                              (Reactive Hazards)
Too often chemicals are stored by schools or companies, alphabetically. This can lead to
explosive or toxic alphabet soup. Substances in the left column should be stored and
handled so that they cannot accidentally contact corresponding substances in the right
column under uncontrolled conditions.

Source: Prudent Practices for Handling Hazardous Chemicals in Laboratories,
National Research Council, Washington, D.C., 1995.
           Chemical                                    Incompatible With
                                  chromic acid, nitric acid, hydroxyl compounds, ethylene glycol,
Acetic acid
                                  perchloric acid, peroxides, permanganates
acetone                           concentrated nitric and sulfuric acid mixtures
acetylene                         chlorine, bromine, copper, fluorine, silver, mercury
alkali & alkaline earth
metals                            water, carbon tetrachloride or other chlorinated hydrocarbons,
 (lithium, sodium,                carbon dioxide, halogens, powdered metals (e.g.,aluminum or
potassium)                        magnesium)
                                  mercury (e.g., in manometers), chlorine, calcium hypochlorite,
Ammonia (anhydrous)
                                  iodine, bromine, hydrofluoric acid (anhydrous)
                                  acids, powdered metals, flammable liquids,chlorates, nitrates,
ammonium nitrate
                                  sulfur, finely divided organic or combustible materials
aniline                           Nitric acid, hydrogen peroxide
arsenical materials               any reducing agent
azides                            Acids
bromine                           Same as incompatibilities to chlorine
calcium oxide                     Water
carbon (activated)                calcium hypochlorite, all oxidizing agents
                                  sodium, chlorates, ammonium salts, acids, powdered metals,
carbon tetrachloride
                                  sulfur, finely divided organic or combustible materials
                                  ammonia, acetylene, butadiene, butane, methane, propane
chlorine                          (or other petroleum gases), hydrogen, sodium carbide,
                                  benzene, finely divided metals, turpentine
chlorine dioxide                  ammonia, methane, phosphine, hydrogen sulfide

                              acetic acid, naphthalene, camphor, glycerol, alcohol,
chromic acid and chromium
                              flammable liquids in general
copper                        acetylene, hydrogen peroxide
cumene hydroperoxide          acids (organic or inorganic)
cyanides                      Acids
                              ammonium nitrate, chromatic acid, hydrogen peroxide, nitric
flammable liquids
                              acid, sodium peroxide, halogens
fluorine                      isolate from everything
hydrocarbons (e.g., butane,
propane, benzene)             fluorine, chlorine, bromine, chromic acid, sodium peroxide
hydrocyanic acid              nitric acid, alkali
hydrofluoric acid
(anhydrous)                   ammonia (aqueous or anhydrous)
                              copper, chromium, iron, most metals or their salts, alcohols,
hydrogen peroxide
                              acetone, organic material, aniline, nitromethane, combustibles
hydrogen sulfide              fuming nitric acid, oxidizing gases
hypochlorites                 acids, activated carbon
iodine                        acetylene, ammonia (aqueous or anhydrous), hydrogen
mercury                       acetylene, fulminic acid, ammonia
nitrates                      sulfuric acid
                              acetic acid, aniline, chromic acid, hydrocyanic acid, hydrogen
nitric acid (concentrated)    sulfide, flammable liquids, flammable gases, copper, brass,
                              phosphorus, and all heavy metals
nitrites                      potassium or sodium cyanide.
nitroparaffins                inorganic bases, amines
oxalic acid                   silver, mercury
oxygen                        oils, grease, hydrogen, flammable: liquids, solids, or gases
                              acetic anhydride, bismuth and its alloys, alcohol, paper, wood,
perchloric acid
                              grease, oils
peroxides, organic            acids (organic or mineral), avoid friction, store cold
phosphorus (white)            air, oxygen, alkalis, reducing agents
phosphorus pentoxide          Water
potassium                     carbon tetrachloride, carbon dioxide, water
potassium chlorate            sulfuric and other acids
potassium perchlorate         (see sulfuric and other acids also chlorates)
potassium permanganate        glycerol, ethylene glycol, benzaldehyde, sulfuric acid
selenides                     reducing agents
                              acetylene, oxalic acid, tartaric acid, ammonium compounds,
                              fulminic acid
sodium                        carbon tetrachloride, carbon dioxide, water
sodium chlorate               acids, ammonium salts, oxidizable materials, sulfur
sodium nitrite                ammonium nitrate and other ammonium salts
                              ethyl or methyl alcohol, glacial acetic acid, acetic anhydride,
sodium peroxide               benzaldehyde, carbon disulfide, glycerin, ethylene glycol, ethyl
                              acetate, methyl acetate, furfural
sulfides                      acids
                              potassium chlorate, potassium perchlorate, potassium
sulfuric acid                 permanganate (similar compounds of light metals, such as
                              sodium, lithium)
tellurides                    reducing agents


                                 acetyl chloride, alkaline and alkaline earth metals, their
                                 hydrides and oxides, barium peroxide, carbides, chromic acid,
water                            phosphorous oxychloride, phosphorous pentachloride,
                                 phosphorous pentoxide,sulfuric acid, sulfur trioxide

                              ATTACHMENT D
             A Partial Reference List of Incompatible Chemicals
                       And Possible Violent Reactions

Source: Prudent Practices for Handling Hazardous Chemicals in Laboratories, National Research Council,
Washington, D.C., 1995.

  Incompatible chemicals                                 Possible Reactions
                                     small amounts of acetic acid will cause the acetaldehyde to
acetic acid - acetaldehyde
                                     polymerize releasing great quantities of heat.
acetic anhydride - acetaldehyde
                                     reaction can be violently explosive.
aluminum metal - ammonium
nitrate                              a potential explosive
                                     unstable nitrogen tribromide is formed: explosion may
aluminum - bromine vapor
ammonium nitrate - acetic acid
                                     mixture may ignite, especially if acetic acid is concentrated.
cupric sulfide - cadmium
chlorate                             will explode on contact.
hydrogen peroxide - ferrous
sulfide                              a vigorous, highly exothermic reaction.
hydrogen peroxide - lead Ii or
IV oxide                             a violent, possibly explosive reaction.
lead sulfide - hydrogen
peroxide                             vigorous, potentially explosive reaction.
lead perchlorate - methyl
alcohol                              an explosive mixture when agitated.
mercury ii nitrate - methanol        may form hg fulminate- an explosive.
                                     phosphorous burns spontaneously in the presence of
nitric acid - phosphorous
                                     nitric acid.
potassium cyanide - potassium
peroxide                             a potentially explosive mixture if heated.
sodium nitrate - sodium
thiosulfate.                         a mixture of the dry materials may result in explosion.

                             CHAPTER ELEVEN
             HAZARDOUS WASTE
                                                         (Rev. March, 2010)
Abandoned waste is described as any unwanted hazardous material that is abandoned on
property without the owner’s permission. Unknown wastes include any material whose chemical
makeup or characteristic is unidentifiable. Certain abandoned and unknown wastes may be
accepted by this facility and after categorization, may be commingled with similar HW types.

Regulatory Requirements

The management and identification of unknown hazardous waste is governed by the
requirements established in this Facility’s Program, EPA 40 CFR Part 262.11, DOT 49 CFR
Part 172.101, and OSHA 29 CFR 1910.120 (a), & (q).

Staff Qualifications

      Only trained facility staff should manage and categorize abandoned or unknown waste,
      Staff should be trained within six months of hire or within starting the new position or they
       should be supervised by trained and experienced staff until adequate training is received;
      Staff responsible for any aspect of HW management should be trained relevant to job
       duties and position;
      Prior to sorting, managing or preparing abandoned or unknown Hazardous Waste for
       highway transport, staff should complete the DOT Regulations for Hazardous Waste
       Transport. Refresher training should be conducted annually.

Health and Safety Precautions

Unknown wastes are potentially dangerous and may require more stringent safety precautions.
Facility staff should assess and manage these waste types on a case-by-case basis. Staff should
assess each container to determine if a threat to life, health or environment exists.

Personal Protective Equipment (PPE) should be utilized when handling chemicals and hazardous
waste. The following PPE should be worn when managing abandoned or unknown wastes:

      Safety glasses with side shields, goggles or equivalent;
      Safety shoe protection
      Protective gloves
      Long sleeved smock, apron or equivalent
      Air-filtering respirator, as necessary

Screening and Identifying Wastes

Staff who discover abandoned waste should attempt to learn as much as possible about the party
responsible for improperly abandoning the waste. Attempt to determine if the waste was
generated from a household or business. Look for container markings which may provide clues.
If the identification of the improper generator is determined, they may refer the offending party’s
information to appropriate regulatory authorities (local sheriff’s office or code enforcement).
Abandoned materials should be examined at the time of discovery for any markings to determine
the waste type and hazard class. Segregate the suspect materials from other disposed wastes. If
the container markings indicate an explosive or reactive material, immediately notify the proper
authorities (sheriff’s office or Special Operations, bomb squad) and manage the waste as an
explosive/reactive product.

Each waste material presents its own hazard. Be alert for indications of chemical reactions from
the incoming waste containers (e.g. bulging, smoking, vapors escaping).

Unknown waste containers should be immediately examined at the time of discovery. Container
markings may provide additional information about contents. Staff should attempt to learn as
much as possible about unidentified wastes from the participant bringing in the waste. Questions
should be asked, such as:
    Was the material located or stored in an outside building or inside building? (Pesticides
       are generally stored outside while HHW cleaners are stored inside a home.)
    Was the material stored in the basement area or the garage? (Automotive wastes are
       generally stored in the garage, while HHW is generally stored in a home.)
    If the householder had hobbies that may provide clues as to the contents?

If contents are still unknown at this point, segregate the container from other stored HHW, place
into secondary containment, and test the product so it can be identified as to hazard class.

Every effort should be made to accurately identify the unknown waste. If necessary, perform a
preliminary test procedure (e.g., pH, flammability, water reactivity) to determine its hazard class.
Additional waste identification questions or further processing instructions may be addressed to
this facility’s HW disposal company. After the proper identification of unknown material is
determined, the waste may be commingled and packaged with compatible HHW.

Spill Response

Facility staff should be responsible for cleaning up incidental spills that occur in the course of
processing HW. Staff should be trained and able to respond to small or incidental HW spills.

Only trained emergency response staff or an emergency contractor should respond to chemical
spills requiring assistance beyond the capabilities of the facility staff. If trained emergency
response teams are required, the facility Emergency Response Coordinator should be notified.

Use extreme caution and minimize the handling of leaking or potentially reactive materials (e.g.,
temperature sensitive, spontaneously combustible, bulging/leaking containers, explosives). Staff
should immediately ascertain the waste container integrity and place leaking containers in
secondary containment, to prevent human or environmental repercussions.

To assist with the cleanup of spills, process all waste materials over a plastic tarp or impermeable

As staff members attempt to identify an unidentified waste product, personnel safety becomes the
most important issue. Staff must follow the proper PPE guidelines and precautions for sampling
and testing. Segregate all unknown wastes away from other stored waste, to decrease errors,
accidents, or events of incompatibility.

To help identify or classify unknown waste products, some of the processing steps may include:
Step 1: Determine the product’s physical characteristics
    Color
    State (solid, liquid)
    Particle size
    Layering
    Incidental odor (do not actively smell)

Step 2: Determine water solubility

    For liquids, place a few drops of the sample onto a strip of water-finding paper;
    Observe for any color changes.

 OBSERVATION                       RESULT
 Water-finding paper turns pink or Chemical is water-based or water soluble
 No color change                   Chemical is not water soluble and may be solvent-

Step 3: Determine water reactivity

    Place a pea-sized amount of the unknown material into a cup or weighted dish
    Add a few drops of water to the sample

 OBSERVATION                            RESULT
 Sample smokes, emits fumes, Sample is water reactive, potentially an inorganic metal
 sizzles, fizzes, or jumps in the water if solid, organic if a liquid, and would be RCRA
                                        Hazardous for reactivity - D003

Step 4: Determine flammability

      Place a nickel-sized amount of the unknown material into a cup or weight dish;
      Or, absorb the liquid into a small, pH paper strip, held at the end of metal forceps;
      Apply an ignition source (a match or butane lighter flame) to the unknown material;
      Depending on the following results, the material may be considered flammable:

OBSERVATION                              RESULT
Sample immediately ignites               Chemical is RCRA Hazardous for ignitability - D001
Sample combustion is delayed and/or      Chemical is combustible for DOT regulations but is not
gives off much smoke, but ignites        considered to be a flammable, RCRA Hazardous Waste
Sample melts but does not ignite         Non-combustible

Step 5: Determine if sample is an oxidizer
    For liquids, place a few drops of the sample onto a strip of potassium-iodide starch paper;
    For solids or semi-solids, slurry sample with some distilled water in a 1:1 mixture or ratio.
       Place the potassium-iodide starch paper onto the sample.
    Observe for any color changes.

 OBSERVATION                         RESULT
 Potassium-iodide starch paper turns Chemical is RCRA Hazardous for an oxidizer – D001
 blue or purple
 No color change                     Chemical is not an oxidizer by RCRA standards

Step 6: Determine corrosivity

    For solids, add a pea-sized portion of the material to a few drops of distilled water;
    For liquids, dip pH paper into the sample;

    For powders, add a very small amount of distilled water or saliva. Dip pH paper into

 OBSERVATION                             RESULT
 pH = 0 – 4                              Acidic – the lower the number, the stronger the acid.
                                         A pH of less than or equal to 2 (red) is RCRA
                                         Hazardous for corrosivity – D002
 pH = 5 – 9                              Neutral – Not RCRA Hazardous for corrosivity

 pH = 10 – 14                            Basic (or Alkaline) – the higher the number, the stronger
                                         the alkalinity. A result of greater than 12.5 (blue) is
                                         considered to be a RCRA hazard for corrosivity – D002

Step 7: Cyanide test (optional)

    Place 5 grams, a nickel-sized sample into a test tube
    If unknown material is solid or semi-solid, slurry it with some distilled water
    Wet a strip of the testing paper with some distilled water and place the paper well above
     the sample
    Add 5 ml of concentrated sulfuric acid to the sample and gently stir. Immediately cover the
     test tube.
    Observe for any test paper color changes

 OBSERVATION                             RESULT
 Pale green test paper turns blue        Cyanide is present. Chemical is RCRA hazardous for
                                         cyanides – D003

Step 8: Sulfide test (optional)

    Place 5 grams, a nickel-sized sample into a test tube
    If unknown material is solid or semi-solid, slurry it with some distilled water
    Wet a strip of lead-acetate paper with some distilled water and place the paper well above
     the sample
    Add 5 ml of hydrochloric acid to the sample and gently stir. Immediately cover test tube.
    Observe for any color changes to the test paper.

 OBSERVATION                             RESULT
 Lead-acetate test strip turns brown     Possible reactive sulfides – D003

Step 9: Determine if the material is Hazardous

If an unknown material is negative to all the above tests or if they are still uncertain as to what
hazard category in which to classify the material, they may place the unknown material to the side.
 A chemist with our TSD contracted disposal company can do additional testing upon their arrival,
during a quarterly collection program. In such a case, staff may fill out the following Unknown
Material Screening Report Form, to be reviewed by the contracted disposal company:




Contact person / phone number:

Date / time sampled:

                 Test performed                                   Result of testing:
pH of the material (write in the pH number)
Water soluble/based (yes or no)
Water reactivity
Air reactive (yes or no)
Oxidizer      (yes or no)
Cyanides      (yes or no)
Sulfides      (yes or no)

Comments: Include the color, size, and kind of container – glass, plastic, metal – color of the
material, physical state of the material, any label information or reports from the person who
brought the material to the facility, etc.

Staff member completing sampling:

If item is still unknown at this point, isolate and package the material; place this form with the
material and provide it to the contracted hazardous waste disposal company.

                                          CHAPTER TWELVE
                                        (Rev. April 2010)
During the initial phase of a natural disaster, Program staff should evaluate consequences,
confirm contacts and coordinate efforts with local, state, and federal agencies involved with
debris and hazardous waste (HW) collection and management. This SOG provides guidance
for the collection of Household Hazardous Waste (HHW) whenever disaster management
requires clean-up following a hurricane, tornado, flood, or other disaster.

                        Regulatory and contractual requirements

Guidelines used for this Program’s emergency contingency plan are established in the HW
Program, the Citrus County SWM Emergency and Contingency Plan, contracted HW disposal
companies, and rules under FDEP and Florida Administrative Code 62-731. Incident Command
and Unified Command procedures will be adhered to during a multi-jurisdictional operation.

                           Preparing for emergency incidents

Preparation and planning prior to an emergency incident will reduce stress and workload should
a disaster occur. Educate the public to take the following steps prior to disaster events:

1.   remove and properly dispose of unwanted hazardous waste chemicals long before an
     emergency requires the effort
2.   store HW in sealable plastic tubs or containers
3.   store HW on high shelves or on upper home floors to avoid flood waters
4.   keep bottled or other potable water containers in a place that’s unlikely to be flooded or
                                Disaster Response Staffing

The designated staff member responsible for implementing a hazardous waste collection event
following an emergency incident or disaster will be the SWM Emergency Response
Coordinator. This person should be trained and experienced, and should ensure information is
available to local emergency response teams, as needed. If this person is not available, this
task should be assigned to an Alternate Emergency Response Coordinator.

                                Post - Incident procedures

Communicate. Full communication should be maintained throughout the clean-up effort with the
designated Incident Commander and other assisting agencies (e.g., fire departments, hazmat
teams, Florida DEP, EPA, FEMA, city and county agencies, including health). Typically, the HW
clean-up response efforts will be directed by the County Haz-Mat team, SWM Emergency
Coordinator, or the County HW staff.

Determine type of collection event to offer. In severe disasters, ―solid waste‖ debris collection
sites will need to be established. Expect these sites to also receive significant quantities of
HHW. The most appropriate collection method will vary depending on the nature, severity, and
scope of the disaster, along with available resources. Alternative collection methods include:
             HW collection method                        Pros                      Cons

       A single-site, mobile collection event                                              A      greater          public
                                                              Less          labor   for
       where      the    public   brings    HHW to a                                       hardship and chance of
                                                              Program staff
       designated, mobile location.                                                        improper HW disposal

       A      single-site     mobile   collection    event
       where the public segregates the waste                                               More             collection
                                                              Less labor for the
       curbside, and Program staff picks up and                                            resources are required
                                                              general public
       consolidates at a mobile unit site set up in                                        (staff, trucks, etc.)
       the impacted county, area.

                                                                                           Greater resources are
                                                              Services the general         required for collection
       Perform weekly “milk runs” to pick up
                                                              public;        decreases     staff. NOTE: even after
       HHW        left   at    pre-designated       county
                                                              chance of improper           setting an end date for
                                                              HW disposal                  the public, HW will still
                                                                                           be left at the site

                                                                                           Greatest resources are
       All debris is picked up curbside and
                                                              Services the general         required for collection
       brought back to a temporary or fixed HW
                                                              public;        decreases     staff. NOTE: even after
       demolition site. From there, waste will
                                                              chance of improper           setting an end date for
       require further segregation into SW, HHW,
                                                              HW disposal                  the public, HW will still
                                                                                           be left at the site

                                                                                           Increased        expenses,
       Enlist a HW disposal contractor to assist              Less          labor   for
                                                                                           although costs may be
       with a HHW collection event                            Program staff
                                                                                           reimbursed by FEMA

Advertise. HHW mobile collections are commonly held one to two weeks following cessation of
the disaster event. Disaster victims require time to sort and segregate waste prior to disposal of
their personal belongings (e.g., SW, HHW, etc). Coordinate with local emergency responders to
determine the best date and time for a HHW collection event. Distribute flyers to affected
households; see examples at the end of this SOG. Also, place ads on local radio and television
station(s) promoting the event. For minor disasters, simply promoting the permanent HHW
Program and upcoming, Saturday collection events may be the best option.

Solicit help and equipment HHW collection events require trained staff, at the site, to minimize
risks such as releases, reactions or exposures. Coordinate efforts between the HW staff and
contracted disposal companies to ensure adequate assistance is available on the HHW
collection days. Request the use of other HHW Programs’ mobile unit(s), pickups or trailers.
Ensure adequate availability of staff that will be trained to lab pack and have plenty of supplies
and equipment, including:

          Plastic tubs/containment bins                                     Sorting tables
          Shipping containers and liners                                    Personal Protective Equipment

      Tent (protection from sun/rain)
      Poly lining for HW collection area
      Food and water for volunteers
      Solid waste dumpster(s) at site
      Secure location for mobile unit
      Nearby restrooms or portable toilets

Hazardous Waste volume estimate. To estimate the volume of HW that will require processing,
consider these factors:

      The scope of the disaster (determines the number of affected households).
      The type and severity of the disaster (affects the amount of waste generated in each
       home). Homes with modest damage typically generate an average of 50 pounds of
       HHW each, while destroyed homes typically generate an average 100 pounds of HHW
      The manner of waste collection (affects the volume of waste that will require
      The total expected HHW volume to be managed = # of homes experiencing damage X
       % of homes HHW is collected from X # of pounds/home collected on average)

       EXAMPLE: Actual Portland event (February 1996):

       Flood causing moderate damage to 8,500 different single-family homes with partial damage
       (averaging 50 pounds/home). Out of the 8,500 homes affected approximately 500 (6%) utilized
       the HHW collection event offered.

       (8,500 homes experienced moderate damage) X 6% of homes serviced in a door-to-door sweep)
       X (50 pounds/home) = 2,500 pounds of HHW collected

Event day collection. Following a disaster, it is possible that some generators may improperly
dispose of HHW into trash bins, even if separate HHW provisions are available. Ensure
adequate staff is available to check and remove Hazardous Waste from solid waste arriving at
the transfer station and/or landfill. Immediately place all leaking HW items into secondary

Separate collection events should be offered for CESQG HW generators. HW is not permitted
to be accepted at this landfill from SQG businesses which generate greater than 220 pounds
per month in the course of their normal operations. The FDEP/SQG database should be
consulted, to ensure that only household and CESQG businesses dispose of their wastes in
this manner and at this facility.

The following is an example of a flyer which can be distributed to citizens of Citrus County
which would advise consumers of how they can dispose of their solid and hazardous waste

                 Managing Citrus County Flood Debris

We are asking for your help in separating wastes from your property into 3 main types so that they can be picked up
and/or properly managed.

Floodwaters carry bacteria that can cause illness. Since you are cleaning up materials that have been flooded, wear
waterproof gloves, and wash up with soap and water when finished. County staff, waste haulers and volunteers will begin
collecting solid wastes from curbs; see date listed below.

       Large appliances           Refrigerators, ovens, dishwashers, stoves, freezers, washing machines, dryers
       Electronics                TVs, computers, monitors, and stereos
       Demolition debris          Carpet, sheetrock, wood, pipes, wiring, shingles, cement, any part of the building
 2.                               structure
       Solid waste                Garbage, lamps, furniture, bedding, clothes, dishes, books, small appliances, house

 3.    Household hazardous waste (HHW) collection from Citrus County residents

       Weekdays, on Tuesday, Thursday and Friday, from 9:00 a.m. until 1:00 p.m.

       HHW should be delivered to the Citrus
       County Central Landfill for proper
       segregation and disposal.

       The Citrus County HHW Facility located
       at: 230 W Gulf-to-Lake Highway, Lecanto,
       FL, phone 527-7670.

       Please put any leaking containers of HHW in a plastic bag or tub. Don’t mix wastes. Keep labels with
       products or write the name on the container so wastes can be identified and safely handled.
       Automotive                 Gas, oil, antifreeze, solvents, cleaners
       Cleaners                   Bleach; ammonia; oven, toilet bowl, and kitchen cleaners
       Mercury-containing         Cooking and fever thermometers, thermostats, fluorescent light bubs
       Flammables / Paints        Gasoline, oil based paint, liquid latex paint, stains, thinners, turpentine
       Pesticides                 Poisons, bug killers and weed killers
       Miscellaneous Other        Gas cylinders, aerosol cans, batteries, pool chemicals.
       items that should be
                                  Segregate and place each of these near other HHW
       segregated as HHW

    Questions? Citrus County residents can call their Hazardous Waste Staff at:
    (352) 527-7670 or email:

                                     CHAPTER THIRTEEN
                                   EXPLOSIVE OR REACTIVE
                                    HAZARDOUS WASTES
                    Waste                           (Revised April 2010)

This facility normally accepts only household fireworks, ammunition and flares. Although they
may be small, many explosive, reactive or incompatible materials can develop violent reactions.
For this SOG, all potentially explosive, reactive or incompatible chemicals or wastes will be
handled to as being ―unstable.‖ To reduce the potential for injury while managing these
unstable waste types, facility staff should follow established, safe work practices.

                                REGULATORY REQUIREMENTS

The management and handling of explosive and reactive chemical wastes is governed by the
requirements established in this Facility’s Program, EPA 40 CFR Part 262.11, DOT 49 CFR
Part 172.101, and OSHA 29 CFR 1910.120 (a), & (q).

                                     STAFF TRAINING

Hazardous Waste employees are responsible for ensuring that proper procedures are being
followed. For the handling of unstable wastes, HW staff members should be trained in Chemical
Compatibility and Storage within six months of hire or be supervised by trained staff; see SOG
on Hazardous Waste Training Program. Staff should also be provided annual refresher training,
to better understand the management of unstable wastes.

                           SAFETY AND HEALTH PRECAUTIONS

Safety Guidelines

    Staff should keep the movement of any suspected, unstable containers to an absolute
    Staff should take precautions to prevent any negative exposure or impacts to people,
     their surroundings or to the environment;
    To minimize the exposure of chemicals to staff members, no smoking, eating or drinking
     is allowed within the Facility waste processing areas;
    Staff should routinely look for immediate dangers to nearby staff and property and keep
     alert for suspicious activities or behaviors;

Health and Personal Protective Equipment (PPE) Guidelines

Engineering and work practice controls should be utilized to minimize or eliminate chemical
exposures. PPE should be worn if the potential for exposure remains after utilizing the most
effective work practice controls. When managing unstable waste, the minimum PPE should
consist of:

      Safety glasses with side shields, goggles, or equivalent eye protection;
      Footwear with reinforced toe or toe caps or equivalent foot protection;
      Nitrile gloves or equivalent hand protection;
      Chemical-resistant smock, coverall, apron, or equivalent body protection.
Emergency response

Only authorized emergency responders or licensed HW contractors should respond to incidents
requiring assistance beyond the capabilities of facility staff. Report chemical incidents to the
facility’s Emergency Response Coordinator (ERC). The ERC should be responsible for
notifying the County Hazardous Material team; see the SWM Contingency Response Plan.


Identification of unstable waste containers and contents

    Prompt action from facility staff following the discovery of unstable waste is critical.
     Staff should attempt to quickly examine any suspected waste at the time of drop-off.
    Examine the container’s integrity and markings to determine if segregation from other
     wastes is warranted or if the situation is an emergency. See the following Attachments
     of this SOG for a list of suspicious items or chemicals for which staff must be alert.
    Containers with a suspicious buildup of crystals on the cap or within the container
     require immediate staff attention and identification, as the situation may be dangerous.
    Do not move any suspected, unstable waste!

Staff who evaluate suspicious, unstable materials should attempt to learn as much as possible
about the waste from the customer. If they do not know the answers to the questions below,
consider the situation to be potentially dangerous and consider the waste to be a possible
hazard. If there are no markings on the waste container, staff should ask the participant:

      Do they have any ideas as to the contents of the container?
      When was the container last used; what was it used for?
      Did the container come from a cleaning cabinet, automotive garage or garden shed?
      Do they have any hobbies which could provide clues as to the contents?
      How old is the container?
      Is the container made of plastic or of darkened glass (photoreactive)?
      How often had the container been used and for what?

Explosive, Class 1 Materials

Untrained staff should not disturb or move containers which are suspected to be
potentially explosive, as detonation may occur by any physical movement; see the
Attachments of this SOG.

The HW collection center may accept small amounts of the following: Residential, Division 1.4
materials such as small caliber, low velocity ammunition (< 50 caliber), shotgun shells, roadside
flares, aerial marine flares, gunpowder with its original container/label and consumer-purchased
fireworks. Such items are normally disposed of through the assistance of the County Sheriff’s
Office and their Special Operations Team. In the event that larger, Division 1.1 thru 1.3 explosive
materials are turned in or dropped off at the facility, the Citrus County Bomb Squad or Sheriff’s
Department should be notified and arrangements made for pick-up and disposal of such material.
Firearms and guns will not be accepted by staff members and will be directed to the Citrus County
Sheriff’s Department for proper acceptance and disposal.


    Containers holding ignitable or reactive chemical waste should be located within a
     secondary containment area with their designated hazard class.

    HW staff should take precautions to prevent accidental ignition of ignitable waste. This
     waste should be separated and protected from sources of ignition including but not limited
     to: open flames, smoking, cutting and welding, hot surfaces frictional heat, sparks (static,
     electrical, or mechanical), spontaneous ignition (e.g., from heat-producing chemical
     reactions), and radiant heat. While ignitable waste is being handled, staff should confine
     smoking and open flame to a location which is distant from the collection area. "No
     Smoking" signs should be placed on the front HW gates and wherever there is a hazard
     from ignitable waste.

    Reactive wastes should receive such special handling and storage as needed to prevent
     unintentional reactions.

    Staff should continually monitor and be aware of chemical reactions. Visually inspect
     hazardous waste and containment to determine if any chemicals are reacting. Signs of
     reaction may include smoking, fizzing, or exothermic reactions (giving off heat); see
     ATTACHMENT C of this SOG to view the Reactive Chemical Guidance List.

Shock sensitive wastes

Many common chemicals have the potential for producing a violent explosion when subjected to
friction or shock (e.g., being struck, vibrated, agitated); see Attachment D of this SOG for
Shock Sensitive Chemicals. Staff should not relocate or move wastes until they are certain of
its content and that it is safe to do so. Staff should not assume that because the waste has
successfully made the trip into this facility that it is now safe to process.


Repackaging, bulking, or neutralizing of ignitable, reactive, or incompatible waste should be
conducted so that the material does not:

    Generate heat or pressure, fire or explosion, or violent reaction;
    Produce uncontrolled toxic vapors, dusts, or gases in sufficient quantities which could
       threaten human health;
    Produce uncontrolled flammable vapors, dusts, or gases in sufficient quantities to pose a
       risk of fire or explosion;
    Damage the structural integrity of the device or facility containing the waste; or
    Threaten human life, health or the environment.

Waste that is new or sealed and in a relatively new container may suggest that the contents are
uncompromised and, therefore, less dangerous.

Some wastes may need to be wetted to minimize fire or explosive risks. In such cases, defer
actions until they have received advice from the County’s Special Operations team.

Do not store wastes in the sun or a hot area, inside a vehicle, or at any location where it may be
disturbed. Higher temperatures create a more unstable condition in reactive wastes.

The purpose of this section is to prevent fires, explosions, gaseous emissions, leaching, or other
discharges of hazardous, explosive or reactive constituents which could result from the mixing of
incompatible waste or if a container breaks or leaks.

    Incompatible waste and materials should not be placed in the same container;

    Hazardous waste should not be placed in an unwashed container that previously held an
     incompatible waste or material;

    Incompatible wastes should be stored separately. They should be separated by a
     minimum of two impervious barriers such that, should any one container fail, no waste or
     vapors will come into contact with incompatible material or containers.

    The chart labeled ―Safe Storage of Chemicals‖, containing hazard categories,
     compatibilities and incompatibilities, and a checklist for safe storage of chemicals should
     be maintained and referred to at the household hazardous waste collection area.

Emergency response

Staff should immediately implement the following response steps, upon the discovery and
determination of an unstable waste material:

    Immediately notify the facility’s Emergency Response Coordinator who may make the
     decision to notify the local emergency responders (dial 911). Describe the situation and
     follow all instructions. Emergency response staff may summon the Special Operations,
     Bomb Squad or Hazardous Material Team, if the situation is deemed to be necessary.

    For an explosive ordinance, the Citrus County Sheriff’s Department bomb squad will
     assess the hazard of the situation. Only specially trained bomb squad personnel should
     remove neutralize or detonate explosive materials in a safe environment.

    If the suspected container is too dangerous to move, leave the participant vehicle where
     it is and evacuate all occupants. Ensure the occupants do not cause the vehicle to
     vibrate while exiting (i.e., leave vehicle doors open while exiting)..

    Evacuate the area and provide a safety radius of 300 feet away from the unstable
     waste. Restrict access and unnecessary entry into the area.

    Inform all members of the landfill, via radio, of the dangerous situation and the waste

    Staff may choose to continue accepting waste from the public during this time using an
     alternate receiving location (e.g. customer service area, driveway, parking lot or transfer
     station). Otherwise, it may be necessary to temporarily suspend facility operations until
     the incident is resolved.

                                      Attachment A

            Waste Items Demanding Immediate Staff Response

Staff should be constantly alert for unstable waste containers with the following labels,
markings, or chemicals:
1. Anhydrous ether
    an old can, labeled ―ether‖ may be explosive
    staff should not move or open these containers, especially if there is no participant
    crystals can form around inside container threads, in lids, or in solution which may not
      be visible
2. Blasting caps: fuse type or unknown type
3. Bombs
    metal or PVC pipe bombs
    may be in any shape
    may be wrapped in duct tape
    gel tubes or slurries (pink or white tubes sausage-looking: generally 2 inches in diameter
     and larger)
4. Dynamite
    brown or tan casing with 5-star fold at one end
    considered to be extremely dangerous if wet, glistening, or soft to the touch
    homemade explosive devices like tennis balls wrapped in duct tape
    may be labeled with unusual or hand-written markings indicating explosive hazards
    key words: nitro, explosive, shock sensitive, material should only be handled by a
      trained technician
    evidence that dynamite may be present includes detonation (det) cord, electric or shock
      tube blasting caps, multiple containers of black powder or smokeless powder
    items labeled high explosive (are explosive but require a charge to detonate)
5. Flares
    have strikers that will ignite through friction
    have orange or red casings (dynamite is usually brown)
    must be separated from other materials
    flares may not need to be managed as explosive waste types
6. Flash powder or photo-flash

7. Fireworks
    smokeless powder, pryrodex (as indicated on original container label)
    ammoniun nitrate (hobby powder)
    nitromethane (hobby rocket pellets)
    boosters (typically have no markings)
    ammunition or fireworks may not need to be managed as an explosive waste type

8. Military ordnance: grenades or shells (notify the Sheriff’s Special Ops Team)

9. Nitrogen: container shows evidence that the headspace has nitrogen blown into it

10. Pictric acid
      unknown, dry or white powders
      extremely shock sensitive material
      commonly found in medical or research laboratories
      used as a dye, chemical reagent, or in explosives/firework manufacturing
      in dry form, may explode if exposed to minute amounts of heat, flame, or shock
      is a strong oxidant which may react violently if exposed to metals, metal salts, amines,
       ammonia, bases, plaster, or concrete
      key words: Trinitrophenol, Dangerous When Wet, Shock Sensitive, Keep Dry
11. Sodium amide
     if uncontaminated, color will be a white to gray crystalline material
     has an ammonia odor
     the pure material will test to be water reactive
     if old or degraded, the color will be yellow to brown with discoloration beginning at the
       bottom and is a potential fire and/or explosion hazard
12. Unrecognizable wastes
     containers from inside lab or industrial buildings
     covered in wax
     sealed in metal or fiber containers
     often less than a quart in size
     markings indicating the container been (or need to be) refrigerated

                                          Attachment B

                  List of Potentially Unstable Chemical Wastes

The following is a list of potentially unstable chemical wastes. This list is not all-inclusive,
but includes wastes commonly processed at HW facilities. Please use this awareness list as a
general reference only.

Acetal                                          Hydrogen peroxide (>8%)
Activated charcoal                              ISOGropyl ether
Aldehydes                                       Lithium metal (powder)
Alkenes                                         Metal peroxides
Ammonium nitrate                                Metal turnings (non-DWW)
Benzoyl peroxide pastes                         Methyl acetylene
Benzylic hydrogen atoms                         Methyl ethyl ketone peroxide
Calcium hypochlorite (solid)                    Naphthalene (mothballs/flakes)
Calcium metal (powder)                          Nitrates
Charcoal (match-lite briquettes/screen/shell)   Paraformaldehyde powder (found in 2 part resin glue)
Chromates                                       Perchlorates
Cumene                                          Permanganates
Cyclohexene                                     Phosphorus black, red, white
Cyclooctene                                     Picric acid (wet)
Decahydronaphthalene                            Pool chemicals (solid)
Decalin                                         Potassium dichromate
Diacetylene                                     Potassium metal
Dicyclopentadiene                               Potassium nitrate
Diethyl ether                                   Sodium amide
Diethylene glycol                               Sodium hydrosulfite (iron out / water softener cleaner)
DiiSOGropyl ether                               Sodium hypochlorate
Dimethyl ether                                  Sodium hypochlorite (solid)
Dinitro compounds (wet)                         Sodium nitrate
Dinitro compounds (wet)                         Sodium perchlorate
Dioxane                                         Sodium sulfide (<30% water of crystallization)
Divinyl acetylene                               Tetrahydrofuran (THF)
Ethers, cyclic ethers, containing primary &     Tetrahydronaphthalene
secondary alcohol groups
Ethylene glycol dimethyl ether (glyme)          Tetralin
Fiberglass hardeners/resins                     Vinyl, vinyl acetate & vinylidene compounds
Fuses, roadside or aerial                       Vinylidene chloride

                                                  Attachment C

                                 Reactive Chemical Guidance List

Keep                       these… Away from these…                              Or they may get these!

Acids                                   Bases
                                                                                    Violent reaction
Acids or bases                          Reactive metals (aluminum, beryllium,       Fire
                                        calcium, lithium, potassium, magnesium,     Explosion
                                        sodium, zinc powder), metal hydrides        Hydrogen gas

Water or alcohols                       Concentrated acids or bases (calcium,       Heat
                                        lithium, potassium, metal hydrides, other   Fire
                                        waste reactives)                            Explosion
                                                                                    Flammable and toxic gases
Reactive organic compounds or           Concentrated acids or bases, reactive       Fire
solvents     (alcohols,    aldehydes,   metals and metal hydrides                   Explosion
nitrated hydrocarbons)

Cyanide or sulfide solutions            Acids                                       Toxic hydrogen
                                                                                    Sulfide gas
Strong oxidizers (chlorates,            Organic   acids,   concentrated   mineral   Fire
chlorine, chlorites, chromic acid,      acids, reactive metals, metal hydrides,     Explosion
hypochlorites, nitrates,                reactive organic compounds or solvents,
perchlorates, permanganates,            flammable or combustible waste

                                  Attachment D

                    Potential Shock Sensitive Chemicals

Acetylides                                      magnesium ophorite
Aluminum ophorite explosive                     mannitol hexanitrate
Amatol                                          mercury oxalatemercury tartrate
Ammonal                                         nitrated carbohydrate
Ammonium nitrate                                nitrated glucoside
Ammonium perchlorate                            nitrated polyhydric alcohol
Ammonium picrate                                nitrogen trichloride
Ammonium salt lattice                           nitrogen tri-iodide
Butyl tetryl                                    nitroglycerin
Calcium nitrate                                 nitroglycide
Copper acetylide                                nitroglycol
Cyanuric triazide                               nitroguanidine
Cyclotrimethylenetrinitramine                   nitroparaffins
dinitroethyleneurea                             nitronium perchlorate
dinitroglycerine                                nitrotoluene
dinitrophenol                                   nitrourea
dinitrophenolates                               organic amine nitrates
dinitrophenyl hydrazine                         organic nitramines
dinitrotoluene                                  organic peroxides
dipicryl sulfone                                picramic acid
dipicrylamine                                   picramide
erythritol tetranitrate                         picric acid
fulminate of mercury                            picryl chloride
fulminate of silver                             picyrl fluoride
fulminating gold                                polynitro aliphatic compounds
fulminating mercury                             potassium nitroaminotetrazole
fulminating platinum                            silver acetylide
gelatinized nitrocellulose                      silver azide
guanyl nitrosamino guanyltetrazene              silver stryphnate
guanyl        nitrosamino   guanylidene         silver tetrazene
hydrazine                                       sodatol
guanylidene                                     sodium amatol
heavy metal azides                              sodium dinitro-ortho-cresolate
hexanite                                        sodium nitrate-potassium
hexanitrodiphenylamine                          explosive mixtures
hexanitrostilbene                               sodium picramate
hexogen                                         syphnic acid
hydrazine mixtures                              tetrazene
hydrazinium nitrate                             tetranitrocarbazole
lead azide                                      tetrytolhydrazoic acid
lean mannite                                    trinitroanisole
lead mononitroresorcinate                       trinitrobenezene
lead picrate                                    trinitrobenzoic acid
lead salts
lead styphnate

                                      CHAPTER FOURTEEN
                                       HAZARDOUS WASTE
                                      HANDLING / STORAGE
                                                      (Revised April, 2010)

DOT and RCRA regulations apply whenever hazardous waste (HW) has been accepted,
packaged, filled, labeled, and/or placed into storage. For this SOG, lab packs, poly drums, fiber
drums, and metal drums will all be referred to as ―containers.‖

                        Regulatory and contractual requirements

The storage of HW is governed by the requirements established in the HW program,
Department of Transportation (DOT), 49 CFR 173.12 (b)(2)(iii), 173.12 (b)(1), and Occupational
Safety and Health Administration (OSHA) 29 CFR 1910.120 (a) and (q).

                                     Staff Qualifications

The designated staff person who will be responsible for ensuring Facility HW storage
compliance is the Hazardous Waste Coordinator. This Facility should have a training program
that describes waste processing and storage relevant to job duties and should include function-
specific training, safety, regulatory, and emergency procedures.

Staff should be trained within six months of hire or starting a new position at the facility, or be
supervised by trained staff until they have been trained. Refresher training should be conducted
annually and properly documented, see SOG on Hazardous Waste Employee Training
Program. Minimum training for assigned staff should include:

              DOT Regulations for Hazardous Materials Transportation (49 CFR 172.704)
              DOT Regulations for Haz-Mat Transportation Refresher (49 CFR 172.704)
              Chemical Compatibility and Storage (TREEO) (40 CFR 262, 49 CFR 172, 177)

                               Health and Safety Precautions
Safety requirements

Staff should follow safety requirements as outlined in the SWM facility’s Contingency Plan and
follow precautions to prevent any negative impacts to their person or the environment.

    No smoking, eating, or drinking is allowed in the waste processing areas of this Facility.
    Routinely look for immediate dangers to nearby staff and property. Keep alert for
     suspicious activities or behaviors in accordance with this program’s DOT Security Plan;
    Proper ergonomic techniques should be used while processing waste;

Personal protective equipment (PPE) requirements

    The HW Program will first implement engineered solutions appropriate to current
     environmental conditions and utilizing experienced staff judgment for unique situations.
     Secondly, the institution of adequate work practice controls will be instituted. Finally,
     PPE should be utilized if the potential for exposure yet remains.

    At a minimum, the following, minimum PPE should be used when processing HW:
      Safety glasses with side shields, goggles, or equivalent eye protection
      Footwear with reinforced toe, toe caps or equivalent foot protection
      Nitrile or chemical-resistant gloves or equivalent hand protection
      Chemical splash apron, Tyvek coveralls, or equivalent body protection

Medical monitoring requirements

Staff members who are exposed to open pesticides or certain hazardous substances for 30 or
more days per year should receive a medical monitoring examination annually, per current
OSHA regulations and industry standards; see SOG on Medical Monitoring Program.

Hazardous Waste storage

Facility staff should ensure that:

      No material is stored in any manner that impedes access to or exit from the Facility.
      HW stored on site does not exceed the maximum, 180 day storage period.
      Facility storage areas have flooring that is impermeable to the type of waste stored.
      Facility storage areas do not have a floor drain that leads to waterways or to open land.
      Access to the facility has been secured; see DOT Security Plan.
      Overhead roofing should protect HW containers from direct sunlight.
      Facility areas are marked with specific waste types or categories of containers stored.
      Storage areas will include secondary containment (e.g., dike, berm, wall, curb, other
       device) large enough to contain 110% of the largest container
      Storage areas should include a dike, berm, wall, curb, or other device to segregate
       potential spills from incompatible wastes (otherwise, wastes should be stored and
       separated by a distance of at least 10 feet).
      Staff has access to waste container moving equipment (e.g., cart, drum dolly, forklift).
      Spill kit is assembled and able to be quickly utilized; see SOG on Spill Response for HW
      Weekly facility inspections should be documented and maintained for future reference.

Containment Facilities

Storage containment areas should have:

    Organized rows with at least 36‖ of aisle space to facilitate product inspection,
     movement of personnel, carts and emergency equipment.
    Proper grounding for bulked flammable wastes; see SOG on Hazardous Waste Bulking.
    Integrity protection; products should not be packaged in breakable containers; 55-gallon
     drums should not be stacked more than two drums high; latex pallets should not be
     stacked more than two cubes high.
    Secure container closure and a secure confinement; see SOG on DOT Security Plan.
    While on-site, each container should be labeled with the appropriate DOT label, if
     required, and a description of the contents (e.g. used oil, waste thinners, waste paint).
     The proper placard category should be placed on the storage building door to describe the
     hazard properties of the materials stored inside.
    An up-to-date, inventory list of containers holding hazardous waste should be
    All household and hazardous waste products should be stored in the hazardous waste
     storage building, satellite storage drums, or secondary containment areas;
    All liquid waste should be stored within a secondary containment structure capable of
     containing 110% of the largest two (2) containers in storage.

    Storm water should be prevented from accumulating within the in-use containment
     structures, in amounts exceeding 10% of the primary containment volume.
    Containers holding liquid should be placed so that material escaping from a small leak in a
     non-pressurized container will not fall outside the containment structure.
    All non-liquid waste should be stored within secondary containment structures capable of
     containing all storm water reasonably expected to fall or run onto the structure in a 25 year
     flood or on a paved and sheltered surface which would be substantially unaffected by a 25
     year flood.
    Containers should be protected under roof and/or from deterioration due to excessive
     exposure to storm water or condensation.

Compatability Guidelines

To prevent reactions from incompatible chemicals, segregate HW canisters or containers,
within the storage area, into the following categories:

 Flammables                     All flammable and combustible liquids and solids, and any non-hazardous
                                material that is chemically compatible with flammables.

 Pesticides                     Department of Agriculture chemicals, poisons, and pesticides (that are not
                                oxidizers), and any nonhazardous materials that are chemically compatible
                                with pesticides may be stored in same area.

 Bases (Alkalines)              All corrosive liquids and solids that are alkaline, as well as any
                                nonhazardous materials which are chemically compatible with bases.

 Acids                          All corrosive liquids and solids that are acidic, as well as any nonhazardous
                                materials which are chemically compatible with acids.

 Oxidizers                      All oxidizers, including organic peroxides.

 Cyanides                       Store all cyanides away from acid wastes.

 Dangerous when wet             Store Dangerous When Wet wastes away from latex paint or any water-
                                based surfactants or solutions.

                     Categories of storage / handling / consolidating
  Waste Category /         Hazard Class /       Storage Package       How Waste Products are handled/consolidated
     Products                  Label              type and size
                                                                     These materials are collected only from
Ammunition /                     Explosives,    Poly, 5 gallon       household residents as HHW. They are not
Fireworks / Flares              Division 1.4    buckets w/ screw     accepted from businesses.
                                                top lid
                                                                     Ammunition, aerial flares, residential fireworks
                                                                     and shotgun shells are mitigated within a
                                                                     commercially- designed ammunition burner,
                                                                     operated by the sheriff’s office, as trained by
                                                                     State Fire Marshal’s officers. Use of this device
                                                                     minimizes the storage and handling hazards
                                                                     presented to staff workers. The by-products of
                                                                     this operation are the recyclable metals of lead
                                                                     and brass which are then recycled by Florida-
                                                                     registered contractors.

                                                                     Flares are mitigated on site through the use of a
                                                                     vented, heavy-steel box which allows the flares
                                                                     to be burned as intended.
                                                                     Cans are evacuated with a dedicated puncture
Paint-containing          Flammable Gases,      (1) 60 gallon cart   device and the aerosol paints are disposed of as
aerosols                           Class 2                           oil-base paint. The charcoal medium within the
                                                                     55 gallon propellant-filtration drum is to be
                                                                     replaced every four years, beginning in 2012.
Non-paint, mixed          Flammable Gases,      (2) 55 gallon        Non-paint aerosol cans are loose packed into
aerosols                           Class 2      drums, open top      drums and removed by a Florida TSD contractor.
Flammable liquids,        Flammable Liquid,     5 drums for <        Paints, thinners and fuels are consolidated into
paints, thinners, fuels            Class 3      2,500 total          55 gallon drums, labeled and removed by a
(bulk)                                          pounds               Florida-registered TSD contractor.
                                                                     Oil-based paints, tars and adhesives, in cans,
Oil-based paints, tars    Flammable Liquid,     Steel, 55 gallon     are stored in a plastic-lined, marked and labeled
and adhesives (in                  Class 3      drums, open top.     Gaylord cube where the contents of the cans are
cans)                                                                combined into 55-gallon drums for disposal by a
                                                                     registered contractor.
Flammable liquids,        Flammable Liquid,     Steel, 55 gallon     Small, oil-based paints, adhesives, fuels and
paints, thinners, fuel             Class 3      drums w/ open        lubricants are loose packed into 55 gallon drums
(loose pack)                                    top lids             for disposal by a Florida-registered TSD
                                                                     Reactive solids are stored in a plastic pail, loose
Reactive solids           Flammable Solids,     Poly, 5 gallon w/    packed, and shipped through a Florida-
                                     Div. 4.1   screw top lid        registered TSD contractor.
Oxidizers                 Oxidizer, Division    Poly, 5 gallon w/    Both liquid and solid oxidizer materials are lab
                                          5.1   screw top lid        packed by a Florida-registered TSD contractor.

Organic peroxides         Organic Peroxide,     1 gallon zip-lock    Organic peroxides are lab packed and sent for
                                   Div. 5.2     bag, labeled         disposal through a Florida-registered TSD
                                                                     Poisons are segregated in a storage locker into
Pesticides/Poisons          Poison, Class 6     Segregated by        three categories; flammable liquid poisons, non-
                                                solids & liquids,    flammable liquid poisons, and solid poisons.
                                                categories           Materials are lab packed and disposed of
                                                                     through a Florida-registered TSD contractor.
                                                                     Acids are received and stored in one section of
Acids                     Corrosive, Class 8    Consolidated or      the Corrosive locker. Profiled, inorganic acids
                                                lab packed into      have been approved for consolidation into 55-
                                                Poly, 55 gallon      gallon drums of hydrochloric acid, mixed acid
                                                drums and Poly,      and photo fixer. The remaining, solid and non-
                                                30 gallon drums      profiled acids are lab packed by a Florida-
                                                                     registered TSD contractor.

                                                                Bases are received and stored in one section of
Bases (Alkalis)       Corrosive, Class 8   Consolidated or      the Corrosive locker. Profiled bases have been
                                           lab packed into      approved for consolidation into 55-gallon drums
                                           Poly, 55 gallon      of mixed base solution, ammonia solution, and
                                           drums and Poly,      photo developer. Solid and non-profiled bases
                                           drums                are lab packed by a Florida-registered TSD
PCB Ballasts /           Miscellaneous,    Poly, 5 gallon w/    Ballasts and Capacitors which may contain PCBs
Capacitors                      Class 9    screw top lid        are loose packed into a container for disposal by
                                                                a Florida-registered TSD contractor.
                                           Steel, 55 gallon     Used oil is consolidated into any of two, 385
Used Oil for          Universal Waste      drum, open top lid   gallon, double wall, poly containers. Waste oil is
Recycling             Non-Hazardous        & 3 – 480 gallon     collected and recycled by a Florida-registered
                                           tanks                TSD contractor.
                                                                Used Antifreeze is consolidated in a 100 gallon,
Spent Antifreeze      Universal Waste      1 – 480 gallon       double-wall, poly container. The antifreeze is
Solution for          Non-Hazardous        steel tank           collected and recycled through a Florida-
Recycling                                                       registered TSD contractor.
                                                                Mercury devices, thermometers and mercury
Mercury               Universal Waste      Poly, 5 gallon w/    containers are loose packed into a container for
                      Non-Hazardous        screw top lid        recycling by a Florida-registered TSD contractor.
                                                                Spent fluorescent bulbs are deposited into
Spent Fluorescent     Universal Waste      Steel, 55 gallon     sealed and properly labeled containers.
Tubes for Recycling   Non-Hazardous        drums w/ open        Fluorescent tubes are crushed, on site, by
– Crushed in Drums                         top lids             trained staff. HID, CFL, metal halide, mercury
                                                                vapor, arc tube and high pressure sodium bulbs
                                                                are loose packed into sealed boxes. The drums
                                                                of crushed bulbs and boxes of loose-packed
                                                                bulbs are both disposed of through a Florida-
                                                                registered TSD contractor.

                                   CHAPTER FIFTEEN
                                LOOSE PACK OR LAB PACK
                 Hazardous        HAZARDOUS WASTE
                 Waste                                 (Revised 6/10)
                            Proper packaging procedures will guide the processing of
Hazardous Waste (HW) received at this Collection Facility. HW packaging includes both loose
packing and lab packing. Packing processes involve the screening of incoming materials and
ensure the proper preparation of HW for its transport and disposal.

                        Regulatory and contractual requirements

The packaging and packing of HW is governed by the requirements established within this HW
program, Department of Transportation (DOT) 49 Code of Federal Regulations, 49 CFR 173.12
(b)(2)(iii), 173.12 (b)(1), Environmental Protection Agency (EPA), 40 CFR 262.34, and
Occupational Safety and Health Administration (OSHA) 29 CFR 1910.120 (a) and (q).

                                      Staff Qualifications

The Program staff person responsible for ensuring that incoming HW is properly packaged and
prepared is the Hazardous Waste Coordinator. This person should enforce HW regulatory
standards, rules, and policies as they relate to staff actions and conduct.

Prior to sorting, managing, or preparing HW for highway transport, the staff should be trained in
Chemistry for the Non-Chemist, Chemical Compatibility and Storage, OSHA Health and Safety
Training for Hazardous Materials, and DOT Hazardous Waste / Transportation. Training should
be accomplished within six months of their date of hire or starting a new position or be
supervised by another, trained staff member (see SOG on Hazardous Waste Training
Program). Refresher training courses should be reviewed monthly, to be completed annually.

                               Health and safety precautions

Staff should not respond to or attempt to control situations requiring action beyond their training
and capabilities. This Program should make arrangements with appropriate emergency
response teams and/or contractors/suppliers for handling emergency situations. Unique
environmental conditions and the judgment of experienced Facility staff should also determine
the PPE level required for each situation. See SOG on Personal Protective Equipment.

When bulking wastes, staff members who may be exposed to HW substances greater than the
PEL-acceptable limits for 30 or more days per year should receive a medical monitoring
examination. It is the Facility’s responsibility to set up procedures to continually verify that the
medical monitoring program is meeting requirements; see SOG on Medical Monitoring.

Both engineering and work practice controls should be utilized to minimize or eliminate
chemical exposures for HW staff. Proper ergonomic techniques should be used whenever
handling wastes. This Program may choose to implement a more restrictive PPE policy.
Engineered solutions to environmental conditions and experienced staff judgment may be used
for unique conditions and situations. No smoking or eating should be allowed in the processing
area of this HW Facility. There should be designated areas set aside for smoking or eating
which are distant from waste processing or storage.

Personal protective equipment (PPE)

Program staff may choose a more restrictive PPE policy for themselves, depending on existing
conditions and decisions made by experienced staff members; see SOG on Personal Protective
Equipment. However, the minimum PPE used by staff members, when lab packing or loose
packing household and CESQG waste, should include:

      safety glasses, goggles, or equivalent eye protection
      Tyvek-type, chemical-resistant coveralls, smock, apron, or equivalent
      Safety footwear with reinforced toe or equivalent foot protection
      Nitrile or chemical-resistant protective gloves
      Air purifying respirator, as described; see SOG on Respiratory Protection Program

                                       Spill response

Staff should be responsible for removing incidental spills that may occur in the course of
packing HW. Facility staff should be trained and expected to respond to small, incidental spills.

Trained emergency responders, Hazardous Material Technicians or an emergency contractor
should be called only by the Emergency Response Coordinator (ERC), to control and clean up
those spills requiring assistance beyond the capabilities of Facility staff. This Facility should
have prior agreements with County emergency response teams or HW contractors who could
be used in case of an emergency: see SOG on Spill Response for HW and this facility’s
Contingency Plan.

                                  Equipment and supplies

Staff requires adequate space to process, separate, organize, pack and package hazardous
waste. A sorting area should be set up to segregate different wastes into marked and labeled
containment. This prevents the commingling of incompatible wastes and prepares the waste
for loose or lab packing. Waste packaging areas should have flooring that is impermeable to
the HW being processed and should be away from public drop off areas. Proper and adequate
equipment and supplies should be available to process all materials received, including:

    UN-approved containers and drums (e.g., metal, poly or fiber)
    Poly liners to be placed inside fiber/cardboard containers
    Compatible drum absorbents, for each waste type or packing category (e.g., clay type,
     oil dry, vermiculite, sodium bicarbonate, sawdust)
    Container inventory forms (as required by DOT or the HW disposal company)
    Facility drum log, as required
    Drum Marking pens, grease pencils
    Labels (hazardous waste categories, non-hazardous waste, non-regulated waste, etc.)
    Strapping tape or duct tape for Gaylord boxes
    Shrink wrapping, plastic wrap
    Material acceptance carts
                               Packaging Hazardous Waste

The HW packaging process takes place after presorting or prescreening has been completed.
The three primary methods of packaging HW for shipment involve bulking, lab packing, and
loose packing. Lab packs require a detailed inventory while loose packs do not require an
itemized inventory. Loose packs are sometimes referred to as a ―sorted waste stream.‖ For
details on bulking, see the SOG on Bulking Hazardous Waste.

Container selection

Select a container using approved DOT and HW contractor packaging and container
recommendations (per 49 CFR Part 173). Choose containers and absorbent materials that are
compatible with the waste stream, (e.g. do not place corrosive acids into metal containers).
Fiber containers must contain a 6 ml. poly, inner liner.

Container marking and labeling

Correctly mark or label the container before packaging waste. Each full container should be
marked appropriately with the following information:

    ―Hazardous Waste‖ or ―Non-Hazardous Waste‖ label, including the content description;
    The accumulation, start date; 55-gallon and smaller satellite containers should be
     marked and dated, once that container is full. Containers larger than 55 gallons should
     be marked and labeled with a Hazardous Waste label containing the accumulation start
    The DOT hazard class label (e.g., corrosive, flammable solid, oxidizer, etc.). For a list of
     lab pack classes, see ATTACHMENT C of this SOG.
    ―Up‖ arrow labels are required for lab packs and containers holding liquid wastes.

Each container should be marked with a unique number assigned by this Facility and/or the HW
contractor, to be used for tracking purposes. When applied, DOT container markings and
labels should be located within six inches of each other and visible for inspection. Only one of
each required label should normally be displayed on each package. However, duplicate labels
may be required on at least two, opposite sides or two ends of a Gaylord container, per 49 CFR
Part 172.400. Labels should be clearly visible and not obscured by other attachments.

                                         Lab Packing
Inventory / tally sheet

A complete inventory sheet (on a form provided or approved by the HW disposal company)
should accompany each lab pack. For a lab pack inventory form example see Attachment A of
this SOG. Based on the needs of the registered contractor and DOT regulations, tally sheets
may be used with or in place of an inventory sheet. Inventory forms should contain:

      A unique container number
      Itemized contents of the lab pack
      quantity, weight, or size of container
      physical state and chemical name of each item contained within.

Placing waste items into lab packs

Pour a thin layer (about 3 inches) of absorbent onto the bottom of the container. Staff should
ensure the absorbent material (e.g., clay type, oil dry, vermiculite, sawdust) is appropriate and
compatible for each waste type. Absorbent protects items from breakage and absorbs spills.

Containers holding liquids should be placed upright into the lab pack, with all container
openings facing up. Such containers should have an approved, ―up‖ arrow on the outside.
Place waste items into lab packs under the following guidelines:

    Ensure glass containers have at least one-half inch of space between each container to
     provide room for additional absorbent, although cardboard, plastic, and metal containers
     may be placed against each other.
    Place an additional 2 inches of absorbent between the waste container and the side of
     the outer container. Place a single layer of waste containers onto the absorbent, making
     sure each container does not exceed the maximum size limit (no single container placed
     into a lab pack should be larger than a five-gallon pail or have a weight greater than 50
    Fill the outer container space with alternating layers of waste containers and absorbent.
    Cover/top off the lab pack containers with 2 to 3 inches of absorbent material.
    If a fiber container has a poly liner, close and seal the liner by taping. Fold liner down,
     taping the plastic ends inside the container.
    For fiber containers without rings, securely fasten the container lid by securely taping
     the perimeter of the lid or folds of the container.
    Mark the container number on the lid of each drum and record this number into the
     facility Container Drum Log. This individual container number consists of the waste
     category and a facility-specific sequential number. For an example a drum log, see
     Attachment B of this SOG.
    Attach one copy of the completed inventory sheet to the container, submit one copy to
     the HW disposal contractor and keep one for Facility records. An example of an
     Inventory Sheet is found in Attachment A. Per Florida DEP, hazard manifests and
     inventory sheets must be kept on file for at least three years.


Loose-packing is a packaging method used to aggregate containers within an established
waste profile (as identified by the contracted, HW disposal company). This process eliminates
the need to complete an itemized inventory form. Waste streams which are commonly loose-
packed may include small solids containing flammables, aerosol paints and aerosol non-paints.
To bulk aerosol paints, see SOG on Aerosol Can Evacuation. To place solids containing
flammables and other aerosols into loose-packs:

    Place a one-inch layer of absorbent in the bottom of the package container, to prevent
     breakage and absorb spills.
    Limit the potential for spills by placing containers upright;
    Individual containers should be closed or have their spray nozzles removed, prior to
     placing items into the loose pack.
    Securely fasten or clasp the container lid. For fiber containers without rings, tape the
     perimeter of the container.
    Write the container number on the lid and record the container number into the facility
     Container Drum Log. For a drum log example, see ATTACHMENT B of this SOG.
    Prior to the shipment and disposal of HW containers, an up-to-date Container Drum Log
     should be faxed to the HW transporter,. A copy of this Log should be retained in our
     office with the contractor’s shipping manifest.

                                       ATTACHMENT A
       Example Inventory Sheet: Sample Contract HW Disposal
                            Lab Pack of Waste Organic Acids (example)

Generator name ______________________________ Container type/size _____________________________

Container number _________________________________________ Date _____________________________

Profile/manifest # ________________________ Gross weight of container _____________________________

Shipping name:        waste corrosive liquids, acidic, organic, n.o.s., 8, UN 3265, PG II_______

 Waste description              1 gallon    1 quart         1 pint     ½ pint         #

 Acetic acid <10%

 Acetic acid >10%


 Citric acid

 Coffee pot cleaners

 Glycolic acid

 Hydroxyacetic acid
 Lime-Away with
 hydroxyacetic acid and
 sulfamic acid
 Most wallpaper strippers
 (when pH is acidic)
 Oxalic acid

 Photo fixer with acetic acid

 Formic acid


                                 ATTACHMENT B
                                Container Drum Log
State-contracted HW Disposal Company: __________Clean Harbors Environmental Services, Inc.____ _

Facility location:___   Citrus County Solid Waste, 230 W Gulf-To-Lake Hwy., Lecanto, FL, 34461_____

       Container #                                     Gross      Cradle       Drum       Drum
    (est. ship month)      Profile #       UN ID      Weight       Birth       Size       Type /
     (CC-YYMM-00x)                        Number     (Pounds)      Date      (Gallons)   Material
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0
  CC-                   BTCTR-0

                                       CHAPTER SIXTEEN
                Hazardous             HAZARDOUS WASTE
                Waste                                   (Revised 6/10)
                             The term ―bulking‖ involves consolidating the contents of several
containers of similar material into a single container, usually a 55-gallon, steel, UN1A2 drum.
Waste materials such as flammable liquids, tars and adhesives, oil-based paint, latex paint,
waste motor oil, and waste antifreeze are often bulked. There is usually an economic
advantage to bulking (vs. lab packing) these waste types. This SOG should describe the proper
Hazardous Waste (HW) Program bulking method.

                       Regulatory and contractual requirements

The bulking of hazardous waste is governed by the requirements established within this HW
program, the Department of Transportation (DOT) 49 Code of Federal Regulations, 49 CFR
parts 173, 178, and 179 and the Environmental Protection Agency (EPA) 40 CFR, parts 262.30
– 262.34.

                                    Staff Qualifications

HW employees are responsible for ensuring that proper bulking procedures are followed. For
bulking hazardous wastes, staff members should be trained in OSHA Health & Safety,
Chemical Compatibility & Storage, Chemistry for the Non-Chemist, and Storage and DOT
Regulations for Hazardous Waste within six months of hire or be supervised by trained staff;
see SOG on the Hazardous Waste Training Program. Staff should also be provided annual
refresher training which describes proper bulking policies and procedures for hazardous
                                  Facility Requirements

For bulking operations, this Facility should be operated and maintained to avoid fires,
explosions, or chemical releases to the environment. Staff should document and retain weekly
inspections of equipment, containers, and HW storage areas. An up-to-date Container Drum
Log should be faxed to the HW transporter, prior to the shipment and disposal of HW
containers. A copy of this log should be retained with the contractor’s shipping manifest.

                             Health and Safety Precautions

Precautions for staff Health and Safety should be addressed, primarily through engineering
controls, written training and operational procedures, and personal protective equipment (PPE).
Staff should be trained to best consolidate wastes in a manner which prevents a negative
impact to their person and to the environment.

Precautions should be taken to avoid personal, chemical exposure during bulking operations,
since vapor particles are small and easily pass through skin and lung tissue to enter the blood
stream. For this reason, staff should wear appropriate personal protection equipment. Staff
should also maintain open windows and doors, to provide ample ventilation during the bulking

This Program should provide an ongoing safety training program for all HW staff members that
addresses consolidation, bulking and packing of hazardous wastes; see SOG on the
Hazardous Waste Training Program.
                                  Equipment and supplies

The following, minimum levels of PPE should be used when bulking wastes:
    safety glasses, goggles, or equivalent eye protection
    Tyvek-type, chemical-resistant coveralls, smock, apron, or equivalent
    Safety footwear with reinforced toe or equivalent foot protection
    Nitrile or chemical-resistant protective gloves
    Air purifying respirator, as necessary; see SOG on Respiratory Protection Program

                             Bulking specific waste streams

Solvent-based paint processing
    Ground all Class 3, flammable liquid drums, used for bulking; see Attachment A.
    Open each container using a paint can opener, screwdriver, or other device.
    Place the designed, paint removal collar / spade on top of a 55 gallon, bulking drum.
    Place paint can upside down onto spade, draining solvent-based paints into drum.
    The spade can be used to clean out the remaining materials from the drained container.
      Empty paint containers should be placed into a roll-off, dumpster for disposal or
       recycling, as permitted by the metal recycling company..
    Ensure the bulking drum contents have at least 3 inches of head space.
    Replace and secure the 55 gallon drum lid.
    Label drum as required for shipment and place into a locked storage area. Keep
       flammable liquids and bulked paint containers out of direct sunlight.
    Document the drum identity on the Container Drum Log.

Solvent-based tars and adhesives
    Ground all Class 3, flammable liquid drums for bulking; see Attachment A of this SOG.
    Open individual containers using paint can opener, screwdriver, or other device.
    Members may remove tars and adhesives from buckets or cans through the use of
       trowels, scrapers or other devices, transferring wastes into a 55 gallon drum.
      Empty, metal, tar and adhesive containers may be placed into a designated roll-off or
       dumpster for disposal or recycling, as permitted by the metal recycling company.
    Ensure that there remains at least 3 inches of head space in the bulking drum.
    Replace and secure the bulking drum lid.
    Mark and label the drum as required for shipment and place into locked storage. Keep
       Class 3, flammable liquid, tar and adhesive containers out of direct sunlight.
    Document the drum in the facility Container Drum Log.

Bulking flammable, solvent-based liquids

The following steps should be followed when bulking flammable liquids:
    Locate an area where there is adequate air circulation and no ignition sources within 50
       feet. Position a fan to keep workers upwind of vapor, as needed.
    Place layer of 6 mil plastic on ground where consolidation will take place, to catch spills
       and splatter of paint.
    A spill response kit and an ABC fire extinguisher should be located nearby. Spill
       response should include a plastic pail, absorbent, plastic shovel, extra gloves, and a
       broom. Program staff should know the location of the spill response kit and be trained
       how to use it properly.
    Ground all Class 3, flammable liquid drums for bulking; see Attachment A of this SOG.
    Open individual containers of flammable liquids, using non-sparking wrenches,
       screwdrivers or pliers.
    Place a non-sparking funnel specifically designed to bulk flammable liquids into the
       bung hole of a sealed drum.
    Staff will pour flammable liquids into the drum, first ensuring that the drum is bonded.
       Empty, metal, flammable liquid containers may be placed into a designated roll-off for
       recycling, if permitted by the metal recycling company.
    Filled, bulk drums require at least 3 inches of head space for safe handling and
    Replace and secure the bung and drum lid.
    Mark and label drum as required for shipment and place into locked storage. Keep
       Class 3, flammable liquid containers out of direct sunlight.
    Document the drum in the facility Container Drum Log.
Bulk materials in an area close to the outdoor air or near an exhaust fan. If bulking indoors, the
minimum air ventilation of one cubic foot per minute per one square foot of floor space should
be maintained. Staff should remain aware of the materials being bulked as well as the contents
of the existing drum, since severe reactions may occur if incompatible chemicals are bulked

If a solvent-based bulking container is bulging, do not attempt to open it. Evacuate the
immediate area and contact the contracted waste disposal company for directions; for further
information, see ATTACHMENT B, Management of Bulging Drums.

Examples of solvent-based liquids for bulking

      Oil or solvent-based paint                          Petroleum distillates
      Mineral spirits                                     Acetone
      Alcohol                                             Solvent
      Kerosene                                            Shellac
      Xylene                                              Turpentines

      Paint thinner
      Lacquer thinner
      Urethane
      Varathane
      Diesel fuel
      Non-chlorinated products
      Lamp oil
      Stain
      Adhesive
      Gasoline
      Varnish


Only aerosol paints, paint solvents and petroleum products may be punctured and bulked.
Aerosol paints, solvents and petroleum products are often bulked into a UN1A2, metal, 55
gallon drum which is later used and filled with bulked, solvent-based paints. For further
information on aerosol bulking, see SOG on Aerosol Can Evacuation Procedures.

Staff should loose-pack and should NOT puncture aerosol cans which contain the following:

      Ethyl ether
      Chlorinated solvents
      Oven cleaners
      Pesticides
      Freons and foamers
      Dioxin waste aerosols*
      Unknown aerosols with no labels

*Dioxin waste aerosols may include unknown herbicides, pentachlorophenol, silvex, 2,4,5-TP,
Woodlife, hexachlorophene, Ronnel, 2,4,5-T, trichlorophenol and fenchlorophos.

Used motor oil and automotive fluid

Waste motor oil, including similar, petroleum-based automotive fluids may be bulked together
into tanks which are located within the Citizen Service Area. These waste oil containers or
drums should be marked with the words ―Waste Motor Oil.‖ Waste motor oil is classified and
should be labeled as a recycled, non-hazardous waste. Automotive and petroleum wastes that
may be bulked together include unused or waste:

      Motor oil
      Brake fluid
      Power steering fluid
      Transmission fluid

Waste oil storage containers should be vacuumed and cleaned of debris at least annually.


Antifreeze and water-based materials containing ethylene glycol can be bulked into a tank that is also
located in the Citizen Service Area. The bulking container should be marked with the words ―Used
Antifreeze‖ or Waste Antifreeze.‖ Staff will take steps to ensure that waste antifreeze is not
contaminated with used oil, paint, or other chemicals.

Bulked motor oil and antifreeze are both recycled through a registered, oil recycling contractor.

Non-Hazardous Surfactants

Waste polymers and surfactants are a class of products received at this facility which are considered
non-hazardous. Such products consist of household-generated, consumer liquids which are water-
based, contain no petroleum distillates, no toxins or poisons, and have a non-corrosive pH reading of
between 4 and 10.         The bulking container should be marked ―Non-Hazardous‖ and/or
―Polymers/Surfactants‖. Bulked, waste surfactants are able to be processed with other, non-
hazardous, water-based products.

                       Preparing bulked, waste containers for shipment

Bulked paints, tars, adhesives, aerosol paints and flammable liquids are transported from this Facility
by a registered contractor for proper disposal; see SOG on Handling Hazardous Waste for Shipment.
The following additional steps are required prior to waste shipment:

    Ignitable, Class 3 wastes should be stored in locations at least 50 feet from the Facility property
       line. (This provision may be waived with approval from local fire marshal and local building
    Paint drippings on the exterior of each drum should be spray painted the same color as the
    The bulked drum should be marked and labeled according to DOT, CFR 49 Part 172.300 and
       172.400, in compliance with the hazardous waste disposal company’s standards.

Contingency Planning

Staff should not respond to or attempt to control situations requiring assistance beyond their training or
capabilities. This Program should make arrangements with appropriate emergency response teams
and/or contractors, during emergency situations. Unique environmental conditions and the judgment of
experienced Facility staff should determine the PPE level required for each situation. See SOG on
Personal Protective Equipment.

Engineering and work practice controls should be utilized to minimize or eliminate chemical exposures
for HW staff. Proper ergonomic techniques should be used whenever handling wastes. This Program
may choose to implement a more restrictive PPE policy. Engineered solutions to environmental
conditions and experienced staff judgment may be used for unique conditions and situations.

                                        Attachment A
   Grounding of containers exhibiting flammable characteristics

This procedure will ensure that appropriate grounding and bonding connections are in place whenever
materials are being poured in the Facility bulking area. Static charge hazards in the bulking area are
minimized by proper use and maintenance of bonding and grounding of equipment and containers. To
―bond‖ means to have contact between the metal drum and the metal container from which they are
pouring. To ―ground‖ means to have a physical connection between the drum and the grounding

Containers holding ignitable liquid wastes should be grounded when adding or removing waste from
the container. This category includes Class 3 flammable liquids, such as acetone, kerosene, diesel
fuel, fuel oil, lamp oils, chlorinated products, gasoline, and petroleum distillates. Other materials that
may require grounding include oil-based paints, stains, varnishes, and adhesives exhibiting flammable
or combustible characteristics.

                                      Static discharge hazards

When the electric charges of two objects are different, they strive to achieve equilibrium by emitting a
static discharge (spark). Electrical charges can form when materials are transferred/poured (due to
friction or from the material moving). To safely equalize this difference in charge, ground all drums with
conductors (copper wires) and attach to an electrical ground. This is particularly important in
environments where the potential for combustible or flammable vapors accumulate. In such an
environment, a spark can produce an explosion.

Specific bonding and grounding procedures

Grounding supplies:
    Insulated copper wire.
    Wire connector or metal clamps (crimped to the wire ends). Grounding clips are designed to
      prevent accidental removal during operational activities. Keep in mind cables and clips may be
      difficult to remove when containers or equipment are stored for long periods of time.
    Grounding rod, spike, or other source of electrical ground.

If possible, use plastic or spark-proof equipment (e.g. funnels, bung wrenches, and picks). Extra cables
and clips will be kept at the Facility for replacement, in the event a clip or cable becomes frayed or
damaged. Plastic or resin carts are recommended for container and product movement. Staff may
also utilize anti-static matting to stand on while bulking materials.

Drum grounding procedure

    Connect one end of the wire to the metal drum, ensuring that the clip is bonded ―metal to
     metal‖, to maintain a proper connection.
    Connect the other end of wire to a grounding source.
    If possible, at mobile collection events, ground fuel and solvent drums. Attach a grounding strap
     from the receiving drum to a grounded rod/spike (place rod into ground at least 24 to 36 inches
     into soil under collection site). Grounding will prevent static electric charging of the drum during
     the bulking process.
    Inspect drum grounding before each day’s bulking activity and whenever drum is moved or

                                        Attachment B
                        Management of Bulging Containers

NEVER attempt to open a bulging container. Contact the contracted hazardous waste disposal
company for venting directions. 55-gallon containers have the potential to build up significant pressure
once sealed. This is likely to happen if a chemical reaction (polymerization) occurs inside a container
that has already been sealed. Venting or relieving the pressure from a bulging container can be
extremely hazardous. Pressure can propel the lid upward with very high force, creating a projectile
hazard from the lid and ring on an open-top container, or a bung on a tight-head container. It is also
likely that liquid waste in the container can be expelled.

                                    Indicators to Look for
There are three major indicators of a bulging container:

   a. Appearance: Either the top or the bottom of the container appears bulged outward. If the
      seams or sides are bulging, the container is under extreme pressure. A container can have
      significant internal pressure even if there are no outward signs.
   b. Lid has pressure build-up: This can be determined by trying to depress the lid slightly with the
      palm of their hand. A container with no pressure should depress easily. As pressure builds up
      inside the container, the resistance increases so that it is very difficult to push in the lid at all. To
      detect bulging on the bottom of the container, gently rock the container to see if it is sitting
      squarely on the floor.
   c. Sound: Tap the center of the lid. Sound is a good indicator of potential pressure. An empty
      container or a container with no pressure will emit low and hollow sounds when tapped. Any
      type of hissing indicates that pressure is escaping from the container. Use extreme caution
      when approaching such a container.

                                  Pressure capacity of containers
Containers are designed for extremely low pressure, less than 2 pounds per square inch (psi). When
containers are pressurized, lids can blow upward violently to release pressure. As pressure in the
container increases, so does the hazard. With greater than 3,600 pounds of force being released,
container lids could blow higher than 25 feet. This could potentially result in serious injury or death.

                              Bulging-drum handling procedures
Even when following this procedure, the venting of bulging containers is considered a non-
routine task due to the high hazard potential. Containers that appear normal may be under
pressure. If a container is bulging from the sides, do not attempt to open it! Evacuate immediate area
and contact the contracted hazardous waste disposal company for appropriate venting instructions.

                                    Venting open-top containers
   a. Examine the container for the three signs of pressure listed above: bulging top, bottom or
      seams; difficult to depress lid with palm of hand; and high-pitched pinging noise when tapped. If
      any of these conditions are present, do not move or attempt to loosen bung or bolt.

                                b. If the container is highly pressurized or severely bulged, ASSUME
                                   IT IS TOO HAZARDOUS TO VENT. Immediately evacuate all
                                   persons from the immediate area and contact the contracted, HW
                Household          disposal company for further instruction.
                Waste           c. If container is considered safe to be vented, stand back from the
                                   container—never extend or place any body part over the lid.
   d. Use a cheater bar on the bung wrench, which allows staff to stand as far away as possible.
      Slowly loosen the bung (do not remove it completely). Turn 1/4 at a time until hissing is heard,
      indicating that pressure is being released. If the bung will come off, remove the bung
   e. Once the lid or bung is completely removed, allow the container to vent at least 24 hours before
      replacing the bung and lid.

                            Venting closed-top (tight-head) containers

Generally, these containers will self-release at the bottom if not properly vented—this may cause
contents to leak. These containers generally have a large bung and a small bung on the top, and the
lid cannot be removed. The larger bung often has small vent holes in the threads of the cap. To
depressurize these containers:

   a. Stand back and away from the top of the container as the bung may have extreme force.
   b. Attempt to prevent releases or spills. Have spill kit readily available to contain any liquid
   c. Using a cheater bar bung wrench, stand back from the container and slowly loosen the bung.
   d. Turn 1/4 at a time until hissing is heard, indicating that pressure is being released.
   e. Allow the container to vent until the hissing stops.
   f. Slowly remove the bung and let the container continue venting for 24 hours before re-capping.

                                            (Revised 6/10)
Aerosol can puncturing devices puncture and empty the aerosol cans, which classify them as being
―empty.‖ These processed cans no longer contain hazardous waste and, with permission, may be sold as
scrap metal for recycling. The contents of aerosol cans are generally liquid with gas propellants.
Propellants are considered hazardous materials and pose a safety hazard during the puncturing process
because container propellants are pressurized and flammable. Staff should use extreme caution when

utilizing the aerosol-can-puncturing devices at this facility.

                                    REGULATORY REQUIREMENTS

The bulking of hazardous waste is governed by the requirements established within this HW program,
Department of Transportation (DOT) 49 Code of Federal Regulations, 49 CFR 173.12 (b),
Occupational Safety and Health Administration (OSHA) 29 CFR 1910.120, Code of Federal Regulations
(CFR) 40, 261.7, and local building and fire codes.

                                               STAFF TRAINING

       The person or staff responsible for ensuring safety procedures are followed during the aerosol
        puncturing process is the Hazardous Waste Coordinator. This person should enforce standards,
        rules or policies as they relate to staff actions and conduct.
       This facility should have a written training program that describes the management and
        processing of aerosol containers relevant to job duties and should include aerosol disposal
        training, safety, regulatory and emergency procedures.
       Staff should be trained within six months of hire or starting a new position at this facility, or be
        supervised by trained staff until they are adequately trained. Refresher training should be
        conducted annually and properly documented.
       Staff should have a thorough knowledge and training prior to the use of this facility’s aerosol
        puncturing equipment. Staff should review the manufacturer’s operation manual prior to
        processing cans, becoming familiar with the equipment design, operation, and maintenance.
       Prior to sorting, managing, or evacuating aerosol waste for highway transport, staff should
        complete the required HazWoper, Chemical Compatibility and Storage and DOT’s Regulations for
        Waste Transport training courses. Refresher training should be reviewed monthly to be
        conducted annually; see SOG on Hazardous Waste Training.
       Staff should be trained on personal protective equipment (PPE) use and requirements. Staff
        should also be trained to respond to and mitigate minor spills, in accordance with this HW
        program and the SOG on Spill Response for HW.


PPE should be utilized if the potential for exposure remains, after the institution of engineered safety
controls. At a minimum, the following PPE should be used while processing aerosols:
         Safety glasses with side shields, goggles, face shield or equivalent eye protection
         Footwear with reinforced toe protection
         Nitrile or chemical-resistant gloves, or equivalent
         Chemical-resistant splash apron, coveralls, smock or equivalent
         Air purifying respirator with P100 filter cartridges for particulates and propellants.
                                         HEALTH PRECAUTIONS

           Select an open, well-ventilated area to perform the aerosol-puncturing process. Stay away
            from low-lying depressions, enclosed walls, and confined spaces. If puncturing aerosols
            inside the Facility ensure the process area is near exhaust fans, open doors or windows.

           No smoking is allowed within the HW facility or near the aerosol-puncturing area

           Precautions should 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,
            entering the blood stream.

          Some aerosol contents are classified as RCRA, flammable liquids (liquids with a flash point
           below 140 degrees Fahrenheit). When RCRA, flammable liquids are bulked or punctured
           indoors, the area should have a minimum ventilation of one cubit foot per minute per square
           foot of floor space.

          The major propellants of aerosol cans (propane and butane) are extremely flammable. Since
           propane and butane vapors are heavier than air, they will vaporize into the surrounding
           pedestrian area very quickly, during the puncturing process, producing a flammability hazard.

          The aerosol-evacuation filter (Carbtrol drum system) is filled with activated charcoal and is
           designed to absorb propellants, VOC vapors. Exhaust fumes from the Carbtrol filtration
           system are exhausted through a two inch pipe, to be mixed with fresh air, some ten feet above
           ground level.

Medical Monitoring

When bulking wastes, staff members who may be exposed to HW substances greater than the PEL-
acceptable limits for 30 or more days per year should receive a medical monitoring examination
annually, per industry standards and OSHA 29 CFR. It is the responsibility of this program to maintain a
medical surveillance program for all affected employees; see SOG on Medical Monitoring Program.

                                PROCESSING AEROSOL CONTAINERS

Tools for Processing Aerosols

 The following adjunct tools should be used when processing aerosol cans:
     55 gallon, UN1A2, metal container or bulking drum
     Carbtrol filtration system for aerosol drum
     Aerosol evacuation system, such as the one used from American Gas Products
     Grounding strap to be connected to the paint containment drum
     Screw driver and wrenches for connecting equipment

 Selecting a Drum for Aerosol Wastes to be Bulked Into

 Selecting containers in which to bulk aerosol wastes depends on the waste type being processed.
 Paints and aerosol can contents should be bulked into a newly refurbished 55-gallon, UN1A2, metal
 drum or container.

 Sorting Aerosol Containers

 Separate aerosol cans into three categories: empty, paint products and non-paint products.

 1.   Empty containers
   a) Staff should ensure aerosol cans, before or after puncturing, are completely empty prior to
      disposal (into trash or metal recycling) as the residues remaining in the cans may be subject to
      federal and state regulations.
   b) Aerosol cans with plastic lids may be disposed of in the trash. If the can is allowed to be recycled,
      remove the can lid prior to recycling the metal.

 2.   Paint Products
   a) Do not process gas cylinders or fire extinguishers with other waste aerosol cans;
   b) Place the unrestricted waste aerosol cans that have functioning spray nozzles onto the Facility
      product exchange or reuse shelf (if such program is in operation).
   c) Segregate cans into the applicable waste streams for processing. Aerosol cans requiring a
        separate waste stream should be lab packed separately. Aerosol cans containing pressurized
        paint-product may be shipped for HW disposal without draining the contents. Five through 55-
        gallon (UN1A2 metal or UN1H2 poly) containers or DOT cubic yard boxes are acceptable for
        storage and transportation of non-punctured aerosol containers.

  3.   Non-Paint Products
    a) The following, aerosol waste types should be loose-packed. Do not puncture aerosol cans with
       the following ingredients:
               Ethyl ether (starting fluid)
               Chlorinated compounds(containing hydrocarbons w/ a chlorine molecule)
               Oven cleaners
               Pesticides
               Freons and foamers
               Gas Cylinders
               Ammonia
               Corrosives
               Fire extinguishers
               Dioxins *
               Unknowns

* Dioxin waste streams include unknown herbicides, pentachlorophenol, silves, 2,4.5-TP, Woodlife, hexachlorophene,
Ronnel, 2,4,5-T, trichlorophenol, and fenchlorophos.

Puncturing Solvent-Based Aerosol Cans (using the American Gas Products extractor)

     Use an appropriate level of PPE, as listed above;
     Secure the puncturing device onto the top of a rust-free, DOT-approved, UN1A2, 55-gallon, open
      top drum
     The drum top should have one 2‖ product inlet and one 2‖ outlet for the Carbtrol filtration
     Facility staff should ground the steel drum prior to starting the aerosol-puncturing process.
     Ensure that the collection drum, Carbtrol filtration, and piping is securely connected
     Shake aerosol paint cans until the product is adequately agitated with the solvent
     Staff should use caution while loading aerosol cans into the puncturing cylinder
     Hold down tightly on the top of the puncturing device, to prevent the release of aerosol gas
     Push the side, pin lever to activate the puncturing device
     Expect a sudden rush of propellant gas and paint product to be released from each can
     Try to minimize any ―fume releases‖ around the drum and pipe joints, to ensure that propellants
      are adequately directed through the Carbtrol filtration unit
     Allow a few seconds of release time, before raising the top of the puncturing device
     Aerosol cans can be punctured in two or three locations, to evacuate more product
     Completely empty aerosol can by allowing contents to drain into the 55-gallon drum
     Remove the punctured can from unit and air dry in a well ventilated area prior to recycling, if such
      is permitted
     It is recommended that aerosols containing clear, petroleum-based solvents and lubricants be
      punctured last, to help clean out the puncturing unit
     Bulked drums should maintain a 3‖ head space on top of the product, for heat expansion;
     Any 55 gallon drum which has room for more solvent-based paint may be finish-filled with canned,
      solvent-based paint;
     Full, 55 gallon drums should be marked, labeled, and disposed of using a contracted, HW
      disposal company.

Waste Aerosol Container Markings

Mark the bulked container, containing paint and paint products, with:
                                 A Hazardous Waste label containing the words: ―Waste Oil-Based

                Household        A DOT, Class 3, Flammable Liquid label
                                 Any other markings as specified by the contract, hazardous waste
                                  disposal company

Mark the aerosol loose-pack container with:
    A Hazardous Waste label containing the words: ―Waste Aerosols‖
    A DOT, Class 2, Flammable Gas label
    A DOT, Class 6, Poison label, when poison aerosols are the primary aerosol product
    Any other markings as specified by the contract, hazardous waste disposal company

Disposing of empty and drained aerosol cans

Empty, steel aerosol cans may be accepted by some steel industry recyclers. Prior to recycling cans,
completely empty and remove the plastic lid. Spray nozzles do not need to be removed. Residues
remaining in aerosol container may be subject to federal and state regulations so try to ensure complete
product drainage.

Cleaning the Aerosol Puncturing Device

Proper cleaning and maintenance of puncturing equipment is required for safe, reliable, and on-going
use. The aerosol-can-puncturing device should be completely cleaned after each use. Remove and
clean the following parts on the American Gas Products extractor:

    The upper and lower chamber of the puncturing device
    Puncturing unit throat
    Pin-puncturing device
    Gasket on the outside of the lower chamber
    Nylon bung adapter and clear vinyl hose
    Lubricate the gasket and all moveable parts with white lithium grease

                CHAPTER EIGHTEEN
                                           (Revised 6/10)
Suitable packaging and preparation of hazardous waste material is necessary for hazardous material
storage and transportation. The Department of Transportation defines hazardous materials as those
substances capable of posing an unreasonable risk to health, safety. and property, when transported.
The DOT is responsible for developing, issuing, and enforcing HM regulations, as they relate to
transportation. Hazardous materials include hazardous wastes (HW), hazardous substances, marine
pollutants, or any materials subject to the EPA Uniform HW Manifest requirements. Since HW is
shipped from this Facility, staff should ensure that DOT regulations and requirements are being


Regulatory and contractual requirements

The handling of hazardous waste for transport is governed by the requirements established within this
HW program, the Department of Transportation (DOT) 49 Code of Federal Regulations, Parts 100 to
185, and Occupational Safety and Health Administration (OSHA) 29 CFR 1910.120 (a) and (q).

Staff Qualifications and Training

The staff person responsible for ensuring that hazardous waste is properly prepared for transport
should be the Hazardous Waste Coordinator. Only trained and designated HW employees are
permitted to handle and package hazardous waste materials for transport. Staff members should
complete their DOT compliance training within six months of hire or be supervised by trained staff.
Staff should receive annual refresher training on the handling and transportation of hazardous wastes.
 Accredited, DOT compliance refresher training should be taken every three years.

DOT compliance training

Prior to handling and packaging HW shipments, staff should be trained on DOT Regulations for
Hazardous Waste Transportation, to include:
     CFR 49, U.S. DOT regulations
     Hazard classification
     HW packaging
     Hazard communication
     HM loading, segregation and highway movement
     Incident reporting
     Transportation security

Health and safety precautions

Medical Monitoring Recommendations

Staff should abide by this Facility’s Medical Monitoring Program if exposed to certain hazardous wastes
for 30 or more days per year. Do not smoke, eat, or drink in this Facility’s processing or storage areas.
 Be aware of immediate dangers to nearby staff and property and keep alert for suspicious activities or
behaviors; see SOG on both the Medical Monitoring Program and the DOT Security Plan.
Safety requirements

Staff members should follow safety and emergency procedures as outlined in their HW Facility
Contingency Plan, Standard Operating Procedures and DOT Security Plan. Staff should maintain a
careful awareness of the safe handling of chemicals while processing hazardous waste.

This Program should continually verify that the medical monitoring program meets the current
requirements, regulations and industry standards for health and safety. Engineering and work practice
controls should be utilized to minimize or eliminate exposures.

Personal protective equipment (PPE)

Engineered solutions to processing problems and experienced staff judgment should be used for
unique conditions and situations. PPE should be utilized when the potential for exposure remains,
after the institution of work practice controls. This Facility may choose to implement a more restrictive

PPE policy while managing wastes. The minimum PPE should include:
   Safety glasses with side shields, goggles, or equivalent eye protection
   Footwear with reinforced toe or toe caps or equivalent foot protection
   Nitrile gloves or equivalent hand protection
   Chemical resistant smock, Tyvek apron or coveralls, or equivalent body protection

Emergency response

Only trained, emergency staff members should respond to incidents requiring assistance beyond the
capabilities of on-site staff. Any emergency response request should first be directed through the
Emergency Response Coordinator. This Facility should have prior arrangements with emergency
response teams, in case of an emergency.

                                  Preparations for shipping day

Advance preparations

Document each container being shipped out on the Facility Drum Log (e.g., date of shipment, weight,
profile number, etc.). Fax or email a copy of the Facility Drum Log to the TSD disposal company at
least five (5) business days before the desired shipment date. For any late additions to the amount of
waste being shipped, contact the disposal company as soon as possible, prior to the scheduled pickup

If this facility is lab packing its own drums, a copy of each drum’s packing list should be faxed to the
disposal company at least ten (10) business days before the desired shipment date. The disposal
company will contact this Facility if there are shipment concerns, including written instructions, if
repacking wastes is required. The following information should be forwarded to the disposal company:

    A Facility Drum Log indicating the number and type of waste containers to be shipped.
    Complete lab pack inventories or packing lists (retain a copy with each container; this would not
     be required for loose pack drums).
    Any ―Unknown Material‖ screening report forms.

Pre-transportation requirements include:

   Prepare containers for acceptance by the registered HW transporter, including:
    properly classifying the Hazardous Waste products
    selecting the proper container for that class of hazardous waste (DOT/UN approved)
    selecting the method of filling the container (e.g., lab packing, loose packing or bulking)
    securing the container closures, including a lock nut
    marking and labeling container with the proper drum number, hazard class label and yellow
      hazardous waste label
    loading, unloading, and handling the HW

Shipping day tasks

    Segregate the shipping containers from the materials destined to remain at the Facility.
    Ensure that approved DOT descriptions and labels are attached.
    To decrease the loading/processing time, use a drum dolly or forklift drum grabber to segregate
     and place containers in a staging area.
    Waste loading protocol is based on the total weight being offered for shipment, as balancing

     the transport truck axle weight evenly and throughout the entire load is required by DOT. Some
     waste containers may be left behind at the Facility if the weight on the vehicle is incorrect.
    HW should be shipped from this Facility by a contracted, registered transporter. The disposal
     company usually prepares all shipping paperwork (manifests), although this Facility is
     responsible for accuracy. Prior to signing, an authorized Facility staff member should review the
     manifest, bill of lading and land disposal restriction (LDR) documented information.
    Review and/or sign manifests or shipping documents; see SOG on DOT Shipping Papers

                              Transportation of Hazardous Waste


The first step in DOT compliance is to determine the correct hazard class and/or division. The DOT
hazard classes are as follows:
    Class 1: Explosives
    Class 2: Compressed gas
         Division 2.1: Flammable gas
         Division 2.2: Non-flammable gas
         Division 2.3: Poison gas
    Class 3: Flammable liquids
    Class 4: Flammable solids
         Division 4.1: Flammable solid
         Division 4.2: Spontaneously combustible
         Division 4.3: Hazardous when wet
    Class 5: Oxidizers
         Division 5.1: Oxidizer
         Division 5.2: Organic peroxides
    Class 6: Poisons (liquids and solids)
    Class 7: Radioactive materials
    Class 8: Corrosive liquids
    Class 9: Miscellaneous: HM that does not meet other class or division definitions

Package markings and documentation

Some HW generators may also qualify as DOT HM transporters. To view a sample checklist for
shippers and transporters, see Attachment A of this SOG. The purpose of this checklist is to help
determine whether the hazardous waste is properly:
     classified, packaged, marked and labeled
     described on shipping papers and manifests
     inspected for legal transport condition
     transported, according to current DOT placarding, packaging and loading standards.

The various methods to communicate a product’s hazards include:
    HW manifests or shipping papers (containing the proper shipping name, hazard class,
       UN identification number and packing group)
    Container labeling and markings (EPA HW label; a DOT label displaying the proper
       shipping name, hazard class and UN number)
    Accurate placarding of the transport vehicle


All HW containers for transportation should be in good condition, properly filled, closed, and
secured. Shipping containers should meet UN container ratings and display the UN symbol,

according to 49 CFR, Part 178.

Offering HM for transport

The designated, HW staff person should not transport HW or offer for transport HW unless the:
    manifest or shipping paper requirements are followed;
    the entire shipment is delivered to the designated destination point.
    the driver carries the manifests or shipping papers in the cab of the transport vehicle.
    an authorized contract with the HW transporter is signed, prior to transporting the HW to
      their authorized Facility.

Transporter requirements

Under our HW Facility’s Security Plan, facility staff should ensure that:
    The HW being offered for transport is accompanied by emergency response information
      (e.g., a 24-hour response contact phone number of a person with knowledge on the
      waste being transported and first aid for emergency situations).
    The HW is properly secured for storage and shipment
    The transporter is aware that they are responsible for their spill response.
    The transport vehicle is able to safely carry and contain the HW loaded on it.
    The driver is aware of the identification of the HW being transported.

Dual, infectious wastes

An infectious substance is a material known to contain a pathogen that causes disease. Waste
that is classified as both hazardous and infectious is called a ―dual‖ waste. This Program is not
permitted to accept infectious materials, biological substances, or regulated medical wastes.
For the disposal of such waste, consumers should contact the Citrus County Health

                                  CESQG Business Waste

Hazardous waste from a business may qualify to be shipped from this facility to a registered
collection site, under the Conditionally Exempt Small Quantity Generator (CESQG) exemption.
The Citrus County HW Collection Center is qualified and permitted to accept both household
and CESQG business waste. To qualify, the business must first be recognized and approved
by a Citrus County SQG Inspector as a CESQG generator.

                                     Materials of Trade

Code of Federal Regulations 49, Part 173.6 allows for additional relief of regulations for the
transportation of small amounts of certain classes of hazardous materials which are used day-
to-day by businesses. These products, used during the normal course of business, are termed
―Materials of Trade‖. Because of this, certain classes of transported, used-for-business,
Materials of Trade, may not be required to have:

      shipping papers or manifests
      placarding
      DOT labeling
      required hours of HW, DOT training

Drivers transporting Materials of Trade should be knowledgeable of the exemption and they
must be informed of the presence of the HW on the transport vehicle. The driver should be able
to recognize and demonstrate their knowledge of the HW being carried.

To qualify for the DOT 49, Materials of Trade exemption, hazardous materials should:

      Be packaged in the size limited by packing group or type of container used. No one
       container should have a gross mass or capacity greater than 66 pounds or 8 gallons (for
       packing group II and III).
      Be transported with a total weight of less than 440 pounds (aggregate gross weight).
      Be contained in sturdy, leak proof, closed, and sift-proof packages.
      Be secured against movement and protected from damage.
      Be marked with the correct DOT shipping name or common name.
      Not be manifested HW.
      Not be classified as Poison Inhalation Hazard (PIH).
      Materials of Trade should be restricted to the following classes or divisions:

                                     Hazard Class or Division
           2.1 - flammable gasses             6.1 - poison liquids or solids
           2.2 - non-flammable gases          6.2 – infectious substances
           3 -flammable liquids               8 -corrosives
           4.1 - flammable solids             9 -miscellaneous (e.g. mercury)
           5.1 - oxidizers
           5.2 - organic peroxides            ORM-D -Consumer commodities

                                          Attachment A
                                       Where is it in the CFR?
  Part                                                     Subject
Title 29      Occupational Safety and Health Administration (OSHA):
 1904         Recording and Reporting Occupational Injuries and Illnesses
 1910         Occupational Safety and Health Standards for General Industry
 1926         Occupational Safety and Health Standards for Construction
Title 33      Coast Guard Regulations Under the Oil Pollution Act; Navigation:
  154         Facilities Transferring Oil or Hazardous Material in Bulk
Title 40      EPA Regulations Under the Clean Air Act:
  50          National Primary and Secondary Ambient Air Quality Standards
  60          Standards of Performance for New Stationary Sources
  61          National Emission Standards for Hazardous Air Pollutants
  63          National Emission Standards for Hazardous Air Pollutants for Source Categories
  68          Chemical Accident Prevention Provisions
  70          State Operating Permit Programs
  75          Continuous Emission Monitoring
  82          Protection of Stratospheric Ozone
  112         Oil Pollution Prevention

  116      Designation of Hazardous Substances
  117      Determination of Reportable Quantities for Hazardous Substances
  403      General Pretreatment Regulations for Existing and New Sources of Pollution
405-471    Effluent and Pretreatment Standards for Specific Source Categories
Title 40   EPA Regulations Under the Safe Drinking Water Act (SDWA):
  141      National Primary Drinking Water Regulations
  144      Underground Injection Control Program
Title 40   EPA Regulations Regarding Pesticide Chemicals:
  180      Tolerances for Pesticide Chemicals in Food; Alphabetical Listing of Pesticide Chemicals
Title 40   EPA Regulations Under the Resource Conservation and Recovery Act (RCRA):
  258      Criteria for Municipal Solid Waste Landfills
  260      Hazardous Waste Management System: General
  261      Identification and Listing of Hazardous Waste
  262      Standards Applicable to Generators of Hazardous Waste
  263      Standards Applicable to Transporters of Hazardous Waste
  264      Standards for Owners & Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities
  265      Interim Status Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal
  266      Standards for the Management of Specific Hazardous Wastes and Specific Types of Hazardous Waste
           Management Facilities
   268     Land Disposal Restrictions
   270     EPA Administered Permit Programs: the Hazardous Waste Permit Program
   273     Standards for Universal Waste Management
  279      Standards for the Management of Used Oil
  280      Technical Standards and Corrective Action Requirements for Owners and Operators of USTs
Title 40   EPA Regulations Under the Comprehensive Emergency Response, Compensation and Liability Act
           (CERCLA) and the Emergency Planning and Community Right to Know Act (EPCRA):
  300      National Oil and Hazardous Substances Pollution Contingency Plan
  302      Designation, Reportable Quantities, and Notification
  355      Emergency Planning and Notification
  370      Hazardous Chemical Reporting: Community Right-to-Know
  372      Toxic Chemical Release Reporting: Community Right-to-Know
Title 40   EPA Regulations Under the Toxic Substances Control Act (TSCA):
  710      Inventory Update
  720      Premanufacture Notification
  721      Significant New Uses of Chemical Substances
  761      Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in Commerce, Prohibitions
  763      Asbestos
Title 49   DOT Hazardous Materials and Pipeline Safety Regulations
  105      Hazardous Materials and Oil Transportation; Definitions, Regulations and General Procedures
  106      Pipeline & Hazardous Materials Safety Administration; Rulemaking Procedures
  107      Hazardous Materials Program Procedures
  110      Public Sector Training & Grants for Hazardous Materials
  130      Oil Spill Prevention and Response Plans
  171      General Information, Regulations and Definitions
  172      Hazardous Materials Table, Special Provisions, Hazardous Materials Communications, Shipping Papers,
           Marking, Labeling, Placarding, Emergency Response, Security and Training Requirements
  173      Shippers – General Requirements for Shipments and Packagings
  174      Carriage by Rail
  175      Carriage by Aircraft
  176      Carriage by Water-going Vessels
  177      Carriage by Public Highway
  178      Specifications for Packagings

  179      Specifications for Tank Cars
  180      Continued Qualification and Maintenance of Packagings
191-192    Transportation of Natural and Other Gas by Pipeline

 Online resources
 To find the current version of federal regulations or to search for a regulation:
         Federal Register:
         CFR: Code of Federal Regulations - (updated annually)
         EPA:
         OSHA: (Contains annotated up-to-date rules, standard
                  interpretation letters, etc.)
         FDEP: Florida Department of Environmental Protection -
         Florida Department of Agriculture and Consumer Services: (Pesticide Regulation):

                                          Attachment B
         Hazardous Materials Shipper and Transporter Checklist

 Shipping papers – CFR 49, 172,200

         Is the proper format used? (e.g., the description entered first, highlighted, or in a
          separate HM column)
         Is proper shipping name shown? (as listed in the HMT hazardous material table)
         Are hazard classes and divisions shown? (e.g., 6.1)
         Is the identification number shown? Has it changed? (e.g., ―UN 1090‖ or ―NA 2761‖)
         Is packing group shown when needed? (―PGI‖, ―PGII‖, or ―PGIII‖)
         Is shipper certification complete and signed? (Unless excepted)
         Are quantities and weight shown (no decimals)? (―5 ctns‖, ―100 lbs‖, 200 kilograms‖, ―5
         Are no abbreviations or codes may be shown? (use proper shipping name)

      Is technical/chemical name for ―N.O.S.‖ description shown in parentheses? (―Corrosive
       Liquid, N.O.S. Caprytyl Chloride, 8 UN 1760, PGII‖, or ―Corrosive Liquid, N.O.S., 8 UN
       1760, PGIII contains Caprytyl Chloride‖)
      Is the 24-hour emergency response information shown?
      Is the emergency response information carried with the transporter? (Emergency
       Response Guidebook or shipping papers or manifests)

Hazardous Waste packages or containers – CFR 49, 172.300, 172.400, and 178

      Are containers marked with the proper shipping name and identification number?
      Is authorized packaging used?
      Are packages marked with UN specification numbers?
      Are containers marked with consignee’s name and address? (Unless excepted)
      Are subsidiary hazard classes entered in parenthesis in shipping descriptions?
       (UN2790, Acetic acid, glacial, 8 (3), II)
      Is the integrity of package containers compromised?
      Is package secured properly?
      Is package segregated from incompatibles? (see 49CFR, Part 177.848)
      Does all staff who prepares waste for shipments obtain DOT updates annually?

Placards (recommended but not required for government vehicles) – CFR 49, 172.504

      Table 1 listed Materials: Placard required for vehicle for ANY amount of these materials.
      Table 2 listed Materials: Placard required for vehicle when quantity is greater than 1,000
       pounds of Table 2 Materials (aggregate gross weight).

                                           CHAPTER 19
                                        UNIVERSAL WASTE
                Waste                     MANAGEMENT
                                                         (Rev. 6/10)

Universal‖ is a term used to describe specific wastes that may be managed in accordance with
reduced RCRA regulations. In addition, ―Universal Pesticides‖ (40 CFR 273.3) are accepted
under this program and are allowed to be commingled with HHW. Universal wastes are
collected by the Citrus County Hazardous Waste Program.

The intention of the universal waste program is to ease the regulatory burden on the facilities
that manage universal wastes. A waste must be a hazardous waste before it can be termed a
universal waste. Florida universal wastes include most rechargeable batteries; pesticides that
have been recalled or collected under a pesticide waste collection program; mercury-containing
thermostats and devices such as manometers and switches; mercury-containing lamps such as
fluorescent lamps that are recycled; and hazardous waste pharmaceuticals.

A handler of universal wastes can be a person who receives universal waste from other
handlers, accumulates the waste, and then sends it on to other handlers, recyclers or treatment
facilities, without performing the actual treatment, recycling, or disposal. This may include a
person who collects batteries, pesticides, or mercury-containing equipment from small
businesses and sends the waste to a recycling facility. The universal waste handler
requirements depend on how much universal waste a handler accumulates at any one time.

The Citrus County Solid Waste Facility is classified as a ―small quantity handler of universal
waste‖. Small quantity handlers (SQH) of universal waste may accumulate up to 5,000
kilograms (kg) (approximately 11,000 pounds) of all universal waste categories combined at
their locations at any time, and less than 1 kg of acutely hazardous pharmaceutical (P-listed)
waste. SQH are required to manage universal waste in a way that prevents releases to the
environment. SQH must also immediately respond to releases of universal waste. SQH must
distribute basic waste handling and emergency information to their employees, to ensure that
their staff is aware of proper handling and emergency procedures.

                       Regulatory and contractual requirements

The Florida Department of Environmental Protection adopted, by reference, 40 CFR Part 273
revised July 1, 2007. Universal Waste management is permitted at this facility in accordance
with the Florida Administrative Code, FAC 62-730.185 Standards for Universal Waste

                         Standard procedures for managing UW

Reduced hazardous waste management requirements Universal Waste is allowed to be
managed under the following reduced requirements:
     Small quantity handlers are not required to report to the EPA, for accepting UW if
        accumulation limits are below 5,000 kilograms (11,000 lbs.) of any one UW type.
     businesses are not required to obtain an HW generator license if accumulation limits are
        below 5,000 kilograms of any one UW type
     a shipping paper may be used in lieu of a HW manifest for shipments containing only
     a business may transport UW to this Facility using a business or personal vehicle
Recordkeeping A HW manifest is not required for shipments of universal waste. When a
―shipping paper‖ is provided, it should contain the following information:

      name and address of the originating UW from whom the waste was sent
      description of the materials shipped
      the quantity of each type of UW shipped
      shipment receiving date; see example in Attachment A of this SOG

When a facility partners with a recycling network (e.g., Rechargeable Battery Recycling
Corporation - RBRC), shipping papers for shipments of UW within those consolidation networks
are not required. These networks may require their own paperwork to accompany shipments. A
Facility receipt should be provided if participants are charged a UW disposal fee. Keep copies
of UW-tracking documents for at least 3 years from the date of issuance. Receipts should be
retained for household and non-household UW received to ensure that the storage limits for
small quantity handlers are not exceeded.

Packaging of UW. Universal waste should be packaged following the HW disposal company or
specific recycling company guidelines. All containers should be packaged to sufficiently contain
the waste at all times during transport. Some UW (e.g., batteries and thermostats) may only
find a sturdy cardboard box or poly pail is sufficient to meet this standard, while other waste

types may require a metal or poly container.

UW storage. UW should be stored in designated Facility areas sufficient to contain the waste
and components of the waste at all times.

Marking containers in storage. UW containers should contain applicable DOT shipping labels
and/or be marked to identify the type of waste. Markings should be provided on the waste itself
or the container in which the waste is contained. Label or mark the UW to identify the type of
waste or a short description of the waste, followed by the words ―for Recycling‖. For example:

      Battery containers destined for recycling should be marked with the words ―Batteries for
       Recycling‖ or ―UW—Batteries‖ or ―Waste Batteries.‖
      Pesticides containers accepted for HW disposal should be marked with the words ―UW-
       Pesticides‖ or ―Waste Pesticides.‖
      Thermostats containers destined for recycling should be marked with the words ―UW–
       Mercury Thermostats‖ or ―Waste Mercury Thermostats‖ or ―Used Mercury Thermostats.‖

Accumulation time limit. This Facility must be able to demonstrate the length of time that UW
has been accumulated since it became a waste or was received. Examples include:

      Mark or label a UW in a container with the earliest date that any UW in the container
       became a waste or was received.
      Marking or labeling the individual item of UW with the date it became a waste or was
      Maintaining an inventory system on-site that identifies the earliest date any UW in a
       group of UW items or a group of containers of UW became a waste or was received.
      Place UW in a specific accumulation area and identify the earliest date that any UW in
       the area became a waste or was received.
      universal waste should not accumulate for more than 1 yr from the date that the
       universal waste is generated, or received from another handler (40 CFR 273.15).

Treatment of UW

This Facility is prohibited from disassembling items defined as UW or from treating the waste;
the following activities are not considered treatment:

      responding to a release
      activities associated with accumulating or bulking wastes
      separating batteries by chemistry
      discharging batteries
      removing batteries from products or battery packs
      clipping the mercury ampule out of mercury-containing devices
      crushing of fluorescent bulbs with approved, drum-top bulb crushing equipment

Transporting and off-site management of UW

      Highway shipments of UW should be secured to prevent breakage.
      State contracts and/or UW recycling networks (e.g., RBRC, TRC) are available for UW
      This Facility should ship in universal wastes in compliance with all United States Postal
       Service, DOT and current shipping requirements.
                                               Attachment A
                       Universal Waste Shipping Paper (Example)

         This paper and any attached papers must accompany their shipment.
                     Only those wastes listed may be transported.

                                                                       Collection program name and site
Generator name:
                                                                       Citrus County Solid Waste Mgt.
EPA ID #:                                                              Hazardous Waste Collection
                                                                       230 W Gulf to Lake Blvd.
Emergency contact information                                          Lecanto, FL 34461

Phone number:

                                                                         Packing type          Total quantity
                                                                           & count              (List units of
Shipping description                                                                             measure)

Certification: I hereby declare that the contents of this consignment are fully and accurately described above
by proper shipping name and are classified, packed, marked, labeled and are in all respects in proper condition for
transportation by highway according to applicable national and international government regulations.

Company rep name: (print) _________________________ (sign) __________________________ Date ___________

Driver name: (print) _______________________________ (sign) __________________________ Date ___________

Date of acceptance by carrier: _____________________________

Certification: I certify I have received the waste listed on this shipping paper.

Program rep: (print) _______________________________ (sign) __________________________ Date ___________

                                       CHAPTER TWENTY
                                     DOT SHIPPING PAPERS
                                     AND WASTE TRACKING
                                                          (Rev. 6/10)

DOT hazardous waste (HW) rules require that generators and transporters of HW utilize a
tracking mechanism for any shipped product. This tracking provides a ―cradle-to-grave‖ record
from the time HW is first generated at the HW Facility (―cradle‖), to its’ ultimate neutralization,
destruction or recycled end (―grave‖). Tracking HW ensures that waste is properly managed
and disposed of in a manner that will not pose a risk to human health or the environment.

In certain circumstances, shipping papers or waste tracking invoices may be used in lieu of a
manifest form, to accomplish this tracking requirement. However, a manifest, shipping paper or
waste tracking invoice must accompany shipments of either regulated or exempted HW.

                        Regulatory and contractual requirements

The use of DOT shipping papers or waste tracking invoices are governed by the requirements
established by this HW program and the Department of Transportation (DOT) HMR 49 CFR
100-185, 172.704, 172.602 A-C and 172.604 A-B.

                          Tracking HW through Shipping Papers

Some wastes do not need to be accompanied by a manifest or waste tracking invoice, but still
require documentation, showing the proper waste shipment and disposal. Such wastes may be
transported using a shipping paper. Shipping papers may be utilized after a HHW Mobile
Collection event, when such waste is being transported from the mobile collection site to the
HHW collection facility, or may include the transportation of universal wastes.

Mobile Collection staff who are responsible for the signing of shipping papers should ensure
that all fields in the document are properly completed. To view a sample shipping paper, see
Attachment A of this SOG or Attachment A of the SOG on Universal Waste Management.
Shipping papers should include the:

      Generator’s name, address, and HW Identification Number
      Receiving Facility name and address
      Proper HW shipping names and quantities
      Emergency response contact information
      Transporters name, signature, and shipment date

Keep shipping papers inside the transporting vehicle (within driver’s reach). This Facility should
retain shipping paper copies for at least 3 years (preferably indefinitely).

               Tracking Recyclables through a Waste Tracking Invoice

A receipt from a Waste-Tracking Invoice hauler may be used to document the proper disposal
of certain, recyclable waste types which are destined for consolidation, recycling or reclamation.
Such a document would serve as the facility’s record, indicating recyclables have been turned
over to a registered hauler or recycler.

When shipping recyclables, generators may transport the waste themselves in their business or
personal vehicle, as long as containers are closed and secured in the vehicle. A waste-tracking
invoice may be utilized when shipping to a recycling or reclamation facility in the United States
unless the waste passes through a state which requires a manifest.

Recyclable waste types that may be tracked through a Waste Tracking Invoice include:

      lead acid batteries
      fluorescent lamps
      used oil, filters, and sorbents
      antifreeze
      dry-cell, rechargeable batteries
      cathode ray tubes
      circuit boards
      PCB lamp ballasts and small PCB capacitors
      liquid mercury and mercury-containing products (thermostats, switches, thermometers,
       relays, manometers, barometers, thermocouples, and gauges)

When this facility ships recyclable wastes through a approved shipper or recycler, the
shipments may be accompanied by a waste-tracking invoice. If so, ensure that the tracking
invoice contains the following information:

      this facility’s name and addresses;
      a 24 hour contact person at this facility;
      name and address of the facility to which the waste is being shipped;
      the date the shipment was initiated;
      a description of the waste; and
      the quantity/amount of waste being shipped.

                                               Attachment A
                             Example of a DOT Shipping Paper
Shipping Paper                                                   HW Facility name:
Only those wastes listed on this document may be                 Site address:
transported. This paper and any attached papers                  ___________________________________
should accompany the HW shipment.                                City, State, Zip:
Mobile collection or Facility site location:
                                                                 HW Facility ID Number:
___________________________________                              Emergency response contact information:

                     U.S. DOT description
Waste item      Include proper shipping name,            Physical state        Number             Size        Total quantity
    #              hazard class, or division
                 number, UN or NA ID number,             (liquid, solid,                                      (List the unit
                   and packing group(I, II,III)              sludge)                                           of measure)

  Certification: I hereby declare that the contents of this consignment are fully and accurately described above
  by proper shipping name and are classified, packed, marked, labeled, and are in all respects in proper condition for
  transportation by highway according to applicable national and international government regulations.
  Generator Contact:

  Shipper’s name:
  __________________________________________/_________________________________________ Date:
             (print)                                        (signature)

  Driver’s name:
  __________________________________________/__________________________________________ Date:
             (print)                                        (signature)

  Date of acceptance by driver/carrier: ____________________________________________________________

  Program certification: I certify I have received the waste listed on this shipping paper.
  HW Facility contact:____________________________/________________________________________ Date:
                                   (print)                       (signature)

                                  CHAPTER TWENTY ONE
                                DOT MANIFESTS AND LAND
                                 DISPOSAL RESTRICTIONS
                                                       (Revised 7/10)
                             Department of Transportation (DOT) rules require generators and
transporters of hazardous waste (HW) to use a waste tracking system. A shipping manifest is a
multi-page, waste tracking form that should accompany HW. This tracking provides a ―cradle-
to-grave‖ record from the time HW is first generated at the HW Facility (―cradle‖), to its’ ultimate
destruction or disposal (―grave‖). Even though the HW disposal company prepares the
manifest shipping papers, the generator is ultimately responsible for the accuracy of the
information. The tracking of HW helps to ensure it is managed and disposed of in a manner
that does not pose a risk to human health or the environment.

Land Disposal Restrictions (LDR’s) should accompany each manifest throughout the shipment
process. LDR’s prohibit the disposal of HW on land, unless the HW meets specified treatment
or disposal standards. The Citrus County HW Disposal Program is also a HW generator of its
own wastes and has been issued an EPA Identification Number, prior to shipping HW. This
EPA number is issued by the Hazardous Waste Compliance section of the Florida DEP. The
EPA ID number is also referred to as the Hazardous Waste ID Number.

                        Regulatory and contractual requirements

Shipping manifests are governed by the requirements established by this Program, EPA 40
CFR Parts 262 - 265 and the Department of Transportation (DOT) CFR 49, Parts 100-185 and
172.704, 172.602 A-C and 172.604 A-B. Title 40 CFR Part 262 Subpart B requires the use of
the Uniform Hazardous Waste Manifest (EPA Form 8700-22 and 8700-22a) for hazardous
waste shipments. Florida adopted 40 CFR 262 Subpart B by reference in FAC 62-730.160(1).

                                    Copies of the Manifest

Facility staff should become familiar with EPA’s form 8700-22, manifest document. Each
manifest sheet set includes 6 carbon copied sheets; the transporter will leave Copy 6 at the
generating Facility and the remaining five pages will accompany the waste. These copies will be
distributed as follows:

Copy 1–Designated Facility to Destination State Copy (if required); a designated TSD
facility is the end, HW disposal site. Copy 1 is sent to the destination state within 10 days after
waste has been picked up by the designated, HW Disposal Company.

Copy 2–Designated Facility to Generator State Copy (if required); sent to the generator’s
state agency within ten days.

Copy 3–Designated Facility to Generator Copy; sent to the generator within 30 days; also
referred to as the three signature copy or final copy. Copy 3 contains three signatures: the
HW Program, transporter and the designated (end disposal) facility. When the waste is
accepted at the designated facility, they will sign and date Copy 3 and mail it to the generator.

Copy 4–Designated Facility Copy; retained by designated facility or end disposal site.

Copy 5–Transporter Copy; retained by the transporter. After both the generator and the
transporter sign and date the manifest, copies 1-5 accompanies the waste during transport.

Copy 6–Generator’s Initial Copy; this bottom copy should be retained by the HW Program
and is sometimes called the two-signature copy or initial copy.

Final and proper manifest documentation and recordkeeping from each waste shipment
should include three pages; manifest Copy 3, manifest Copy 6, and the corresponding LDR.
Manifests and LDRs should be retained for at least 3 years (preferably indefinitely). Copies of
manifests and shipping papers should be made accessible for inspection by this HW Facility.

For regular shipments of hazardous waste, Florida does not require the submission of a
manifest copy to the Florida DEP. However, manifests must be retained for three (3) years and
are reviewed as part of hazardous waste compliance inspections conducted by FDEP.

When hazardous wastes are shipped under an emergency EPA/DEP identification number, as
defined in FAC 62-730.161, the generator must send a legible copy of all signed and returned
manifests to DEP within 45 days of the last shipment.

The owner/operator of a designated facility must submit to DEP any manifests for which a
significant discrepancy is discovered, as defined in 40 CFR 264.72 and 40 CFR 265.72, if the
discrepancy is not resolved within 15 days.

                                  Completing the Manifest

The manifest, EPA form 8700-22 is a multi-page document, so signing the document requires
the use of a good ballpoint pen. Press hard and print legibly. Ensure the last copy is as legible
as the first.

Staff responsible for signing manifests or shipping papers should ensure document accuracy.
Check each numbered line item on the manifest form. Completed manifests should include the:

    Generator’s HW ID Number, name, mailing address and site address
    Transporter’s HW ID Number and name
    Final, Designated Facility’s Generator HW ID Number, name and site address
    Proper shipping name, hazard class, waste ID number, packing group (S.H.I.P.), total
     quantity, unit of measure and waste codes
    HW generator, transporter and designated facility’s name, signature, & shipment date
    Correct number of pages, as indicated on the page one of the manifest
    24-hour emergency number and manifest discrepancy contact information

Florida requires the completion of the following sections of the manifest, in addition to those
required by federal regulations in accordance with Appendix I of 40 CFR 262.

Form 8700-22
    Items 1 - 16
    D and F - Transporter phone numbers
    H - Facility phone number
    I - Waste codes for each waste stream (as listed in 40 CFR 261 Subparts C and D)
    K - Handling codes for wastes

Form 8700-22a
    Items 21-32
    and Q - Transporter phone numbers
    R - Waste codes for each waste stream
    Handling codes for wastes

                                 Obtaining Manifest Forms

Florida does not supply manifests, but does supply a list of vendors from which copies of the
manifest may be obtained. Copies may also be available from hazardous waste transporters or
hazardous waste management facilities.

                       Tracking Hazardous Waste with Manifests
Shipping day

Compute 35 days from the day HW is shipped out and write this ―manifest return due-date‖ on
the Facility calendar or on a sticky note attached to Copy 6–Generator’s Initial Copy. Retain this
copy along with the LDR.

Manifest arrival

On the date Copy 3–Designated Facility to Generator Copy is received (within 35 days of
shipment), attach Copy 3 to Copy 6 and the corresponding LDR form (left on site, on the day of
shipment) and file all three documents in a location readily accessible for inspections. Indicate
on the Facility calendar that the matching manifest Copy 3 has been received.

If Copy 3–Designated Facility to Generator Copy does not arrive within 35 days

   1. If manifest Copy 3 has not yet been received, contact the HW disposal company to
      inquire as to it’s status.
   2. If Copy 3 does not arrive within 10 additional days (45 days after the shipment date),
      photocopy Copy 6. Draft a letter documenting the problem and all efforts made to
      resolve it.
   3. A small quantity generator, including this Facility, must submit a legible copy of a
      manifest to the Florida DEP if the signed manifest is not received from the designated
      facility within 60 days of shipment.

                            Land Disposal Restrictions (LDR)

The Hazardous and Solid Waste Amendments of 1984 greatly restricted the land disposal of
untreated wastes. Because of this, hazardous waste is now required to meet applicable
treatment standards prior to its land disposal.

If a particular waste meets LDR treatment standards, the generator should submit a notification,
which should accompany the manifest during shipment. This LDR form should include the:

      generator’s HW ID Number
      manifest number associated with the shipment
      applicable waste codes
      applicable subdivision for each waste code
      applicable wastewater or non-wastewater category
      waste analysis data (when available)

Land Disposal Restrictions (LDR) requirements generally apply to wastes that are a listed as
HW or are hazardous due to their hazardous characteristic (see hazardous materials in 49 CFR
172.101 and hazardous substances in 172.101 ATTACHMENT A). LDR information should be
kept with their corresponding manifests for a minimum of three years (preferably indefinitely).

                             Manifest Signature Authorization

Both the Department of Transportation (DOT) and FDEP Hazardous Waste rules require
Facility staff to obtain approval from an authorized representative prior to signing manifests on
behalf of that facility.

At this facility, those authorized to sign the manifest are the SWM Director, Hazardous Waste
Coordinator, Hazardous Waste Specialist and Customer Service Supervisor. No other Program
staff should sign manifests or shipping papers on behalf of this Facility unless the SWM
Director’s approval is granted.          Authorized persons must demonstrate a competent
understanding of the manifest process and related subject matter. Therefore, all staff
authorized to sign the manifest should first complete the TREEO course, DOT Regulations for
Hazardous Waste Transportation and should have passed the Manifest Sample Examination,
found in ATTACHMENT A.

Manifest signature Regulatory requirements

Manifest requirements are established by EPA 40 CFR Part 262, and DOT regulations:
172.205, 172.602 A-C, 172.604 A-172.702, and 172.704 (d).

Manifest signature responsibilities

Although the HW transporter may prepare the manifest as part of their waste management
service, the person who signs the manifest, representing Citrus County SWM, is ultimately
responsible for accuracy of all manifest contents, including:

      Generator HW ID number
      Facility name and address
      Correct shipper and transporter name, ID number, signature and shipment date
      Number of pages indicated on the first manifest page
      Required record keeping includes both the ―two signature‖ (copy 6) and ―three
       signature‖ (copy 3) manifest page(s) and the Land Disposal Restriction (LDR) Form

Name ____________________________ Date _____________________

                       Manifest Signature Authorization Test
                        Packing, Storage, and Transportation Test
                     (Keep a completed copy of this test in individual staff training file.)

1) When storing hazardous waste at this HW Facility, responsible staff need to:
   a) not worry about keeping incompatible materials away from each other since there is no
      danger of accidents.
   b) use any type of lab packs and drums, as DOT-approved containers are not important.
   c) stack drums several layers high to save space.
   d) place closed-out containers in designated Facility storage areas.

2) When preparing containers for shipment, labels are not required.
   a) True
   b) False

3) Waste disposal paperwork should be kept on file.
   a) True
   b) False

4) There is no reason to use pH paper on items that appear to be acids.
   a) True
   b) False

5) Labeling and marking of containers should be completed:
   a) when first opened.
   b) the day before the hazardous waste contractor has scheduled a pick-up.
   c) when closed out.
   d) only when staff can’t remember what was placed into the container.

6) All hazardous waste containers should be:
   a) inspected at least once a week for leaks.
   b) be properly marked and labeled.
   c) placed so all containers can be easily viewed (adequate aisle space).
   d) placed anywhere in the Facility where there is extra room.
   e) a, b, and c.

7) When arranging for a pick-up of hazardous waste by the contractor, staff should:
   a) have a vague idea of what will be shipped out.
   b) stack all containers outside a week ahead of time, so they are ready to go.
   c) send lab pack inventories and number of bulk drums to the contractor a week prior to the
      pick-up date.
   d) do nothing until the contractor arrives, since staff is unsure of how much truck space will be

8) To prepare for the scheduled hazardous waste pick-up day, staff should:
   a) separate all containers into distinct categories.
   b) stage containers to make it easier to load with a fork lift.
   c) have sufficient container aisle space.
   d) arrange containers so labels are visible.
   e) all of the above.

9) When lab packing hazardous waste, staff should wear a full-face respirator at all times.
   a) True
   b) False

10) It is necessary to open each container when lab packing hazardous waste.
    a) True
    b) False

11) If a lab pack container requires an inventory, keep a copy:
    a) in the Facility files.
    b) on the container.
    c) to forward to the disposal contractor.
    d) in the solid waste as no packing lists are needed.
    e) a, b, and c.

12) The use of poly, UN-approved drums is required for the lab packing of corrosives.
    a) True
    b) False

13) Using plastic liners in fiber lab pack drums is considered optional for lab packing corrosives.
    a) True
    b) False

14) Maximum allowed storage time for closed-out hazardous waste containers at this Facility is:
    a) one month.
    b) 90 days.
    c) 180 days.
    d) as long as needed.

15) Program staff is responsible for ensuring correct shipping labels and/or markings are used.
    a) True
    b) False

16) Class 8 corrosives can be loaded above or adjacent to ANY type of Haz Mat.
    a) True
    b) False

17) To safely transport Haz Mat, staff should ensure:
    a) all labels are facing in the same direction
    b) incompatible containers are segregated
    c) each container is secured against movement
    d) b and c
    e) all of the above

18) Common incompatible Haz Mat that should be segregated includes:
    a) acids and bases
    b) acids and cyanides
    c) acids and pesticides
    d) oxidizers and ignitables or flammables
    e) oxidizers and pesticides
    f) all of the above

19) Shipping paper and/or manifest accuracy is the responsibility of:
    a) the transporter shipping the Haz Mat
    b) the receiving or end disposal facility
    c) the generator
    d) a and b

20) Each class of Haz Mat is required to be transported in a specific type of container because:
    a) it prevents incompatibility and/or chemical reaction problems
    b) leaks will be contained
    c) all of the above
    d) none of the above

21) A container is considered to be DOT approved for shipment if it displays the UN symbol and:
    a) is compatible to the waste stored inside
    b) is securely closed
    c) is not leaking
    d) b and c
    e) all of the above

22) A green colored label is used to indicate:
    a) Organic liquids
    b) Dangerous When Wet
    c) Non-flammable gas
    d) None of the above

23) When receiving hazardous waste, staff should:
    a) pH each container.
    b) segregate items into specific hazard and packing classes.
    c) place all waste on a cart and lab pack whenever it is convenient to do so.
    d) mix as many container contents together as possible to save space and money.

24) It is okay to:
    a) lab pack acids and bases together since they are both class 8 corrosive materials.
    b) bulk unknown fluids into a solvent drum without prior testing.
    c) bulk liquid dioxins into a solvent drum since they are also flammable.
    d) lab pack small flammable items into a ―Direct Charge‖ container rather than bulking them.

25) When an UNKNOWN material is received, staff should:
    a) open the container immediately to see what is inside.
    b) place the container into a waste category staff thinks is most correct.
    c) ask the participant bringing in the item what the waste is.
    d) smell contents to determine waste type.

26) If picric acid is received, staff should first:
    a) open the container and bulk the contents with other acids.
    b) call the local police, who will contact the bomb squad since it will definitely explode
    c) visually inspect the container for crystallization and do not attempt to open.
    d) shake the container vigorously and watch for a reaction.

27) Hazardous waste items can be lab packed into any type of box, drum, or container.
    a) True
    b) False

28) Acceptable absorbent packing materials may include:
    a) crumpled up newspaper.
    b) Styrofoam or shipping peanuts.
    c) nothing.
    d) Vermiculite

29) All acids (organic and inorganic) may be packed together in the same lab pack.
    a) True
    b) False

30) Keep water base separate from oil base while bulking paints.
    a) True
    b) False

31) To document or track a lab pack or bulk container, staff should:
    a) assign a unique number.
    b) enter the waste type, weight or size, and date shipped into the Facility drum logbook.
    c) mark and/or label following DOT and hazardous waste regulations.
    d) All of the above.

32) Cyanide items should be:
    a) thrown into the solid waste since they pose no danger.
    b) packed per individual type.
    c) packed with other pesticides.
    d) placed on product reuse/exchange shelves.

33) When testing unknown wastes, if the pH paper indicates 0 to 1 pH, the item should be:
    a) packed as inorganic acid.
    b) packed as organic acid.
    c) packed as alkaline.
    d) poured into the sewer since 0 to 1 pH is considered neutral.

34) To qualify for the DOT 49 CFR, Materials of Trade exemption, which is not true:
    a) No one container should have a capacity of > 66 pounds or 8 gallons.
    b) The aggregate gross weight of the materials must be < 440 pounds.
    c) Materials must be secured from movement and protected from damage.
    d) All the above are true.

35) The difference between a DOT ―label‖ and a DOT ―marker‖ is that a label is:
    a) A ―hazardous waste‖ sticker placed on a container.
    b) A diamond-shaped hazard class logo used on non-bulk (< 119 gallons) containers.
    c) Contains the descriptive or technical name of the hazardous material.
    d) Must contain the shipper’s name and address.
    e) All the above

36) To properly categorize a waste type for lab packing, staff should refer to:
    a) the Haz Cat manual.
    b) Web reference sites such as
    c) chemical reference book.
    d) the State-contracted HW disposal company for help.
    e) any of the above

37) Only new drums/lab packs/boxes may be used as haz mat waste shipping containers.
    a) True
    b) False

                      Manifest Signature Authorization
                        Internal Exam Answer Key

Packaging, Storage, and Transportation Test Key:

1.                       d
2.                       b
3.                       a
4.                       b
5.                       a
6.                       e
7.                       c
8.                       e
9.                       b
10.                      b
11.                      e
12.                      a
13.                      b
14.                      c
15.                      a
16.                      b
17.                      d
18.                      f
19.                      c
20.                      c
21.                      e
22.                      c
23.                      b
24.                      d
25.                      c
26.                      c
27.                      b
28.                      d
29.                      b
30.                      a
31.                      d
32.                      b
33.                      a
34.                      e
35.                      b
36.                      e
37.                      b

                                   CHAPTER TWENTY TWO
                                    DOT SECURITY PLAN
               Household                               (Revised 7/10)
               Waste       The US Transportation and Security Administration reports that
                           terror groups could use hazardous materials as weapons. In
response to this, the Department of Transportation (DOT) promulgated Safety Requirements
for Offerors and Transporters of Hazardous Materials, 49 CFR, part 172, Subpart I.

To this end, as of October of 2010, the DOT will require that if shippers generate ―A shipment in
other than a bulk packaging of 2,268 kg (5,000 lbs.) gross weight or more of one class of
hazardous materials for which placarding is required;‖ such generator is required to formulate a
site security plan, per 49 CFR, part 172.800 (b) (7). This written Security Plan provides a
means for improving hazardous materials security, training of employees and restricting access
to unauthorized persons. This Security Plan should be understood and implemented in
conjunction with the SWM Emergency Incidents and Contingency Guidelines.

                                 Regulatory Requirements

Secure handling, storage and transportation of hazardous waste (HW) is governed by the
standards established for this HW Program, OSHA 29 CFR 910.120, 1910.141, 1910.151,
1910.157 and DOT regulations 49 CFR 172.704, 172.800, 172.802, and 172.804. This security
plan was developed within the guidelines of the DOT, Risk Management Self-Evaluation
Framework (RMSEF) methodology. Further DOT hazmat Security Plan information can be
found at
                                      Security Training

The staff member who has been designated as being responsible for ensuring the
development, revision and compliance of this DOT Security plan is the Hazardous Waste
Coordinator. This person should ensure that:
    new staff should receive pre-employment screening;
    the Security Plan is reviewed and updated on an annual basis;
    security threats are identified and prioritized so available resources can be allocated
       effectively to reduce or eliminate all risks;
    staff will continually improve the Program’s security efforts (e.g., identifying areas or
       methods of improvement);
    there will be a partnership with all parties involved (e.g., staff, customers, contractors,
       regulatory agencies) for ―securing‖ the HW management and transportation chain;
    disciplinary actions are taken when a staff member fails to follow security procedures;
    staff should be accountable for their authorized, assigned HW and Facility keys

Staff who manage hazardous waste should be able to demonstrate successful completion of
their DOT security training. They should demonstrate an understanding of the HW operational
guidelines, hazard precautions, hazmat management and transportation security, to include:
     the implementation of this DOT Security Plan;
     emergency evacuation procedures;
     safety and security actions, to protect Facility property and hazardous materials on site;
     specific preparedness, site diagrams, and security measures to prevent a contingency
        event from occurring;
     designating staff members for incident notification of regulatory agencies, law
        enforcement, and public service authorities;
     recognizing and responding to possible security threats;

    security policy details, including specific objectives and procedures;
    responsibilities and actions, in the event of a security breach; and
    awareness of security risks relating to HW transportation and storage

HW security training should be documented and recorded annually, per 49 CFR 172.704; see
Attachment A. This DOT Security Plan should be read, understood and reviewed annually by
all personnel who have access to, handle or who offer for transportation any HW material.

                                     Security Equipment

Staff should utilize all available and appropriate security measures. The level of security may be
enhanced based on the facility layout and its surrounding environment. Outside Facility security
enhancements should include:
    adequate lighting, illumination from dusk to dawn;
    surveillance, recording equipment, intrusion alarms, motion detectors;
    fencing and gates to restrict access;
    emergency notification contact number posting in the office and HW collection area; and
    signage clearly stating that Facility access is restricted to authorized staff only.

Security measures are meant to minimize the possibility for unauthorized entry. Staff should
ensure security precautions in all Facility areas (e.g., product exchange; waste processing, and
storage areas; air, water, gas, and utility equipment). Security items should be incorporated into
the Facility’s design, be maintained in good working condition, and include:
     a communication system which involves all staff members
     a controlled entry to the SWM area and HW Facility
     a 24-hour surveillance system

                     Security Specifications and Risk Management

Facility control measures Staff should regularly review their security risk ―control points‖ based
on the Facility’s degree of vulnerability and potential impact. The Facility should be maintained
and operated in a manner that provides adequate security, to include:
     a security walk-through performed each day the Facility is open, noting anything
        suspicious, and immediately reporting questionable activity to the Director of SWM.
     24-hour contact information is posted in both the HW Collection Center and the
        Administrative Office which identifies back-up staff and other agencies to be notified,
        depending upon the type of incident.
     Facility flow, floor, HW storage and schematic plans, which are maintained and kept in
        secure locations. Such plans are in the direct control of the designated staff responsible
        for ensuring DOT security plan compliance and should only be made available to staff,
        and local, state, or federal agencies.
     Unmarked or unidentifiable packages should be treated as suspicious and immediately
        reported. Facility staff should become familiar and recognize facility HW container
        markings, symbols, and designations.

Shipping waste - security measures

It is essential that HW containers are properly identified and accounted for at all times. Each
container offered for transportation should first be identified and labeled in accordance with
DOT, CFR 49 172.301. Drums for shipping should be identified on the Facility Drum Inventory

DOT requires there be documentation identifying the hazardous material being transported
(e.g., shipping paper, manifest and/or lab-pack sheet). Transfers and transactions between
shippers, transporters, and destination facilities should be clearly documented as a chain-of-
custody transfer. Manifests should be signed by the generator and receiving party prior to
relinquishing the shipment; see SOG on DOT Manifests and Land Disposal Restrictions.
When supervising a hazardous waste shipment, staff should determine the piece count of the
shipment and compare that with the number of containers documented on the manifest and
Facility Drum Inventory Sheet. Any discrepancy or other suspicious activity should be reported
to the on-site staff members of the HW transport agency, to ensure DOT security compliance.

Preventing unauthorized individuals from accessing containers of hazardous waste is critical to
maintaining security. Only specifically authorized Program staff should be provided access to:
        County or government-owned transport vehicle(s) loaded with hazardous wastes or
        Areas where containers holding hazardous wastes are stored.

Program vehicle control measures

Regardless of the type or quantity of hazmat transported or offered by this Program, security for
the shipment should be maintained at all times. To prevent unauthorized access, the driver of
any county facility Program vehicle should ensure that the vehicle:
        doors remain locked when unattended
        remains within sight during extended idling times
        is locked with access to a key (to allow for reentry if temporarily left unattended)

SWM should be responsible for providing appropriately sized locks or seals for Program
vehicles. The cargo portion of the vehicle should be locked or sealed from the time the driver
receives the shipment until delivered to the destination site. If it is necessary to load or unload
materials from the vehicle prior to reaching the final destination, it is the driver’s responsibility to
relock or apply a new vehicle lock or seal.

While transporting household wastes from mobile event collections, staff should take
appropriate action to prevent tampering with the shipment. This may include securing cargo
areas with tamper-proof locks or seals. Locks or seals are not needed when the vehicle is:
        not transporting household wastes
        parked at a secure Facility
        attended by Facility staff

Program drivers should be responsible for assuring that property and waste are secure during
transport. Drivers should strictly adhere to this Program’s personnel security policy, including:

         not allowing unauthorized persons to ride in or operate Program vehicles
         be alert to and aware of vehicle surroundings (e.g., suspicious people or activities,
          other vehicles following)
         satisfying all driver qualification requirements as outlined in the Federal Motor
          Carrier Safety Regulations
         complying with all applicable federal and state routing requirements (e.g., use
          designated hazmat routes; avoid tunnels, bridges, and heavily populated areas)
         carrying proper proof of personal identification (e.g., state-issued photo driver’s
          license appropriate to the vehicle driven)
         adhering to site-specific security rules while performing work at a work-site
         delivering shipments without delay and proceeding directly to the delivery point
          without intermediate stops

        limiting stops to only obtain rest, meals, perform vehicle inspection and maintenance
         activities, or complete scheduled pick-ups
        not stopping or exiting the vehicle at anyone’s request (other than law enforcement)
        immediately reporting injury or spill incidents to emergency responders and to the
         designated SWM Facility staff responsible for ensuring DOT Security compliance

Staff identification (e.g., the County-issued photo badge) should be kept on their person while
at work. The county-issued identification items should be returned upon employment or
termination. Drivers should use caution to not discuss shipment details or load-related
information (e.g., contents, delivery schedules, routing) with any person unrelated to the
shipment, see SOG on Mobile HW Collection.

                                   CDL Program Drivers

Staff members who require a commercial driver’s license with a hazardous material
endorsement should undergo further security background checks by the Department of Justice
in conjunction with CDL license issuance or renewal. Only staff with a valid commercial driver’s
license, proper endorsements, and a complete driver qualification file should be authorized to
operate a Program vehicle. A driver’s report should divulge information to the Dept. of Motor
Vehicles regarding their:
     criminal history (if convicted of a disqualifying criminal offense)
     education background
     social security number
     citizenship status (should be a U.S. citizen or a lawful permanent U.S. resident)
     general reputation, character, or personal characteristics
     motor vehicle driving record (disqualified for improper transport of HM and requires
        mandatory annual driving record reviews)
     previous supervisor contact (suspicious if no longer currently working with the applicant,
        if there are no names of direct supervisors, if previous employers are noted as ―being
        out of business,‖ or if the reasons for terminating employment are questionable).
     Previous history, for a driver showing:
        o gaps in employment
        o frequent job shifts
        o excess residence changes
        o mental instability (as adjudicated by a court, board, or other authority)

                     Use of contracted HW transportation services

This Program requires our hazmat transporters to have a documented security plan and to
adhere to the security measures as described in this SOG. These additional security measures
do not apply to contractors hired by this HW Program to handle universal or low hazard waste
shipments (e.g., latex paint) that pose a low security risk.

Contracted HW transporters are required to secure the cargo portion of their vehicles while
transporting this Program’s hazardous waste. When relinquishing a shipment to a contracted
HW transporter, the designated staff responsible for ensuring DOT security plan compliance
should be present to verify the vehicle is affixed with an appropriate tamper-proof security
device. Before a HW shipment leaves this Facility, staff should verify that the shipper displays
the necessary and appropriate placards, as demonstrated in 49 CFR 172.504, Table 1 and 2.
Prior to offering a shipment to a contracted HW transport company, program staff should verify
the identity of the contracted driver. Program staff should not release any HW shipment if there
is any concern regarding the driver’s identity or license validity.

                                 General Security Measures

Contractors may be left unattended provided they register/notify Facility staff of their presence
each day and display appropriate identification. Facility staff should maintain and enforce a
restricted HW Facility visitation policy, including the assurance that unauthorized persons:

        register;
        are prohibited from accessing restricted areas unless accompanied; and
        are only allowed to enter the Facility when necessary and at designated entrances

It is recommended that HW Facility gates, fences, and doors:
          are locked at all times when staff is not present;
          have controlled entry; and
          are at least six foot high, chain linked, and completely surround the Facility

Hazmat storage areas should be locked when Program staff is not on-site. Only the following
areas are acceptable for hazmat storage while at a satellite Facility or collection event:
        inside a locked vehicle;
        within a locked building; and
        inside a secured fence

Staff should be alert for suspicious activities such as soil excavation on Facility property.
Immediately verify if such operations are authorized.

Staff should implement a master and sub key system under the care and supervision of the
Customer Service Supervisor. It is recommended that HW Facility keys are:
        always accounted for;
        marked with the words ―do not duplicate;‖
        provided to emergency response teams; and
        changed or rotated annually; preferably during the month when this SOG is reviewed

This Facility should be open to the general public during its posted hours of operation.
Designated Facility areas that are not available to the general public should be posted
―Authorized Staff Only‖ and no public admittance should be permitted in those areas (unless
pre-arranged with Facility staff). Any persons (excluding Facility or Emergency Response staff)
who are on the premises after public hours should be considered trespassing and prosecuted

Emergency notification

Facility staff have a responsibility to observe and report any suspicious activity (e.g., known
thefts involving hazmat, missing containers, actions that threaten safety or security to
appropriate law enforcement and/or regulatory agencies). All threats should be treated as ―real‖
and adequately investigated and reported. The Program staff should periodically assess the
effectiveness of the Facility’s DOT Security Plan, including to:
         conduct weekly Facility inspections, incorporating security checks into the program;
         assess the security vulnerabilities at each work site;
         develop and implement specific security measures in response to vulnerabilities;
         educate staff about the importance of security; and
         implement and ensure policy compliance

                                           Attachment A
            U.S. DOT Security Plan Training Document

The Security Plan should be retained as long as it remains in effect. This plan
must be revised and updated annually, to reflect changing circumstances. Copies
should be made available to Facility staff who are responsible for implementing
the plan.

This documentation should be retained at the SWM facility, and should be
attached to a copy of each person’s annual, Citrus County Training Sheet.

Hazardous Waste Facility _______Citrus County SWM Hazardous Waste Collection Facility___

Located at ____________230 West Gulf-to-Lake Highway, Lecanto, FL 34461_____________

Name of Staff Member Receiving Training__                 Sue Heglund, HW Technician_____________

The above individual reviewed this facility’s SOG on the DOT Security Plan and the SWM Emergency Incidents and
Contingency Plans and received annual U.S. DOT Security Awareness training which reflects the following:

                               This training provided awareness of security risks associated with hazmat
                           √   management and transport.
                               This training provided awareness of methods designed to enhance hazmat
                           √   security.
                               This training provided awareness so I am able to recognize security threats.
                               This training provided awareness so I am able to respond to security threats.
                               This training was provided within 90 days of employment and/or was offered as
                           √   part of my DOT Regulations, tri-annual training, required 1 time every 3 years.
 Employee should initial
 their agreement to each
 of the above statements

 Signature of the HW Coordinator: ______________________________________ Date___________________

 Signature of HW Program Member: ____________________________________ Date___________________

                               CHAPTER TWENTY THREE
                              RESOURCE CONSERVATION
                              AND RECOVERY ACT (RCRA)
                                                       Revised 8/10

To encourage environmentally sound methods for managing household, municipal, commercial,
and industrial waste, Congress passed the Resource Conservation and Recovery Act (RCRA)
in 1976, found within the Code of Federal Regulations, 40 CFR Parts 260 thru 279. This act
requires the U.S. Environmental Protection Agency (EPA) to identify and regulate hazardous
waste and to develop a program to ensure that it is handled safely ―from cradle to grave‖ from
generation through transportation, treatment, storage, and ultimately to its disposal.

The goals of RCRA are listed as follows:
   1. To protect human health and the environment.
   2. To reduce waste and conserve energy and natural resources.
   3. To reduce or eliminate the generation of hazardous waste as expeditiously as possible.

                          Regulatory and contractual requirements

The Resource Conservation and Recovery Act (RCRA) of 1976, which amended the Solid
Waste Disposal Act, was the first substantial effort by Congress to establish a regulatory
structure for the management of solid and hazardous wastes. Subtitle C of RCRA addresses
the "cradle-to-grave" requirements for hazardous waste from the cradle of generation to the
grave of disposal. Most RCRA requirements are not industry specific but apply to any company
or HW Facility that generates, transports, treats, stores, or disposes of hazardous waste.

Although RCRA is a Federal statute, Florida adopted the RCRA program through its Florida
Administrative Code (FAC), Chapter 62-730. In addition, if lands or water have been
contaminated with hazardous waste, they may be subject to rules and requirements under the
Comprehensive Environmental Response, Compensation, and Liability Act, commonly known
as CERCLA or the Superfund Amendment.

On February 12, 1985, Florida received final authorization from the U.S. Environmental
Protection Agency to administer its own hazardous waste management and regulatory program
under RCRA. The most important feature of this authorization is Florida’s agreement to issue
permits that conform to the regulatory requirements of the law, to inspect and monitor activities
which would become subject to regulation, to take appropriate enforcement action against
violators and to do so in a manner no less stringent than the Federal program.

The Hazardous Waste Regulation Section, within the Florida Department of Environmental
Protection (FDEP), is responsible for implementing the ―hazardous waste‖ regulatory portion of
RCRA. It reviews and issues permits and coordinates compliance monitoring and enforcement
activities at hazardous waste generators, transporters and Treatment, Storage and Disposal
(TSD) facilities, through the FDEP regulatory district offices.

For a hazardous material to be regulated as a hazardous waste, it must be first included under
the definition of a solid waste, as described in 40 CFR 261, Identification and Listing of
Hazardous Wastes. Wastes are considered hazardous either by (1) exhibiting a characteristic
of a hazardous waste or by (2) falling under a category of ―listed‖ hazardous wastes; see
Attachment A.

                                    Staff Responsibilities

The SWM Division Director should be designated to ensure compliance with RCRA and HW
regulatory standards, rules, and policies as they relate to overall staff actions and conduct. The
application of these RCRA rules and regulations, as they apply to hazardous waste, should be
administered through the Hazardous Waste Coordinator.

               Generation and Identification of RCRA Hazardous Waste

Accurate Waste Determination
Accurate waste determination is the cornerstone of proper waste management. Each individual
and company must first determine how RCRA classifies the material in question so that they
may properly manage it. Each generator must then determine if the material in question is a
solid waste and/or hazardous waste.

Is Their Waste a Solid Waste?
To be considered a hazardous waste and be subject to regulation, material must first be
considered a solid waste. EPA defines ―solid waste‖ as garbage, refuse, sludge, or other
discarded material (including solids, semi-solids, liquids, and contained gaseous materials)‖.
Simply put, if their material has served its primary purpose and is ready to be disposed of, it is
considered to be a solid waste.

What is excluded from classification as a Solid Waste?
The provisions in 40 CFR 261 establish which solid wastes are considered hazardous waste
and are regulated under Subtitle C of the Resource Conservation and Recovery Act (RCRA).
These provisions also exclude or exempt certain wastes from regulation. Wastes are excluded
or exempted from coverage for a variety of reasons.

The original RCRA legislation excluded a number of wastes that did not present a significant
threat to human health or the environment or that were managed under other environmental
programs. Other wastes were excluded by EPA to encourage their recycling or reuse as feed
stock in manufacturing processes. Some exclusions or exemptions serve to establish when a
waste material becomes subject to regulation or when waste quantities are too minimal to be
fully covered by the Federal hazardous waste regulatory program. As new regulations have
caused the universe of RCRA generators and facilities to increase, the numbers of exclusions
and exemptions have increased as well. Eighteen separate exclusions are found within
regulation 40 CFR 261.4.

Is Their Waste a Hazardous Waste? (EPA bulletin EPA530-F-97-029)
If their waste qualifies as a solid waste, they must next determine if it is a hazardous waste. It
is their responsibility as a generator either to test their waste or use their knowledge of the
waste to make a determination about its properties. Once they know what is in their waste,
they can then determine if EPA considers it to be hazardous. EPA defines hazardous waste in
six ways:

1. Is the Waste a ―Listed‖ Hazardous Waste?
EPA developed several lists of hazardous wastes (40 CFR 261.30). If their waste appears on
any of these lists, it is hazardous. Wastes on these lists are hazardous regardless of the
concentrations of hazardous constituents in the waste. The lists also identify nonspecific
source wastes (261.31) which are material-specific wastes, such as solvent wastes, electro-
plating wastes or metal heat-treating wastes, commonly produced by a wide variety of
manufacturing and industrial processes, designated with “F” waste codes. An example of
such is wastewater treatment sludge from electroplating operations (F006).

Specific source wastes (40 CFR 261.32), which are wastes from specifically identified
industries such as wood preserving, petroleum refining, and organic chemical manufacturing.
These specific source wastes are designated with “K” waste codes. An example of such is
wastewater treatment sludge from the production of chrome pigments (K002).

Discarded commercial chemical products (261.33), which are off-specification products,
container residuals, spill residue runoff, or active ingredients that have spilled or are unused
and intended to be discarded (designated with “P” and “U” waste codes). If the intent is to
use the material or recycle it, it is not considered a hazardous waste. Examples: Aldicarb
(P070), parathion (P089), and vinyl chloride (U043). Florida has adopted the same "listed"
wastes under FAC 62-730.30. As such, the EPA listed wastes found in CFR 40 Part 261 are
thereby in effect.

2. Is the waste a ―Characteristic‖ Hazardous Waste?
The EPA identified four characteristics or traits of hazardous waste: ignitability, corrosivity,
reactivity, and toxicity. These four characteristics are designated with “D” waste codes. Their
waste is considered hazardous if it exhibits any of these four characteristics (40 CFR 261.20 -
24). The EPA characteristics found in CFR 40 Part 261 were adopted by Florida under the FAC
62-730.020.       These characteristics are measurable by standardized and available testing
methods that can be found in an EPA manual entitled Test Methods for Evaluating Solid Waste,
Physical/Chemical Methods (SW-846).

A chemical that exhibits one or more hazardous ―characteristic‖ is a hazardous waste. These
―characteristic‖ materials often include warning information and key words on the container
label which alert the public that the contents may be hazardous. These key words may include:
     DANGER – a highly toxic, flammable, or corrosive material
     POISON – highly toxic
     WARNING – moderately toxic
     CAUTION – less toxic
     NON-TOXIC – a safer product, although has no federal regulatory definition

3. Is the Waste a Mixture?
If their waste is a mixture of nonhazardous solid wastes and listed hazardous wastes, it is
considered hazardous (40 CFR 261.3). A few wastes are listed only because they are ignitable
or reactive. In these cases, if the resulting mixture no longer is ignitable or reactive, the mixture
is not considered a listed waste. For example, spent solvents (F003), such as methanol or
acetone, are listed hazardous wastes and are ignitable. If these solvents are mixed with a non-
ignitable nonhazardous waste, the mixture will still be considered hazardous, unless the mixture
is not ignitable.

4. Is the Waste a ―Derived-From‖ Hazardous Waste? Any solid waste generated (derived)
from the management (treatment, storage, or disposal) of a listed hazardous waste, including
sludge, spill residue, ash, emission control dust, or leachate, is considered hazardous waste
(40 CFR 261.3). For example, any ash or residue left from the incineration process at a
hazardous waste incinerator is considered hazardous waste.

5. Is the Waste considered Contaminated Media? Environmental media (ground water, soil or
sediment) sometimes comes in contact with listed hazardous waste. If these media become
contaminated with (and therefore contain) hazardous waste, they must be managed as a
hazardous waste. For example, if a tank leaks listed hazardous waste into ground water, the
ground water must be managed as a hazardous waste because it contains a listed hazardous

6. Is the Waste Contaminated Debris? Manufactured objects, plant or animal matter, and
natural geological material that exceeds 60 mm (2.36 in.) particle size and that is intended for
disposal are considered ―debris‖ (40 CFR 268.2). Debris is not considered a solid waste, but if
a hazardous waste is mixed with debris, it becomes hazardous waste. For example, rags,
personal protective equipment, or pallets that are contaminated with a hazardous waste must
be managed as a hazardous waste until they are decontaminated and no longer contain the
listed waste.

              Processing, Storing, and Transporting Hazardous Waste

The State of Florida requires all HW generators to properly manage their wastes. Therefore,
the Florida DEP recommends to hazardous waste generators that:

When it is necessary that generators store their HW indoors, they should:
   Follow all fire and building codes (including container grounding).
   Keep containers closed except when adding or removing wastes. Ensure all containers
      are closed at the end of the business day.
   Secure all bungs, lid rings, or lever-locks.
   Place containers holding liquids on a surface impermeable to that particular waste.
   Provide enough aisle space for easy access and visible inspections.
   Containers should be inspected at least weekly to ensure they are not leaking.
   Separate incompatible wastes with at least a 10-foot distance, or by using a dike, berm,
      or wall.
   Store wastes in an area without floor drains connecting to the environment.
   Keep waste containers away from equipment travel routes to prevent incidents.
   Ensure HW storage time limits are not exceeded (There is no limit to the number of
      days a HW can be stored at a CESQG facility, such as the Citrus County SWM).
   Secure and restrict access to be only staff responsible for managing the wastes.

When it is necessary that generators store their HW outdoors, they should:
   Follow all the requirements for indoor storage as listed above, along with:
   Protect wastes from the elements (e.g., temperature extremes, rain, storms & sunlight).
   Minimize risk of inadvertent damage to storage containers; see SOG on Waste Storage

Manifesting HW shipments
A manifest is a multiple-page document that will generally accompany each shipment of HW. It
is the tracking document used to show that hazardous wastes have reached their proper
destination (grave). While this facility’s contracted HW disposal company will prepare
manifests, this Program is ultimately responsible for the accuracy of each manifest document;
see SOG on DOT Manifests and LDRs.

Licensed CESQG consolidation sites
This facility is licensed by FDEP to accept both household hazardous waste and CESQG
wastes. Therefore, both household and CESQG hazardous waste may be commingled through
this facility’s HW Collection Program. Although each CESQG business must pay for the
disposal of their hazardous waste, this CESQG consolidation program is a convenient and low-
cost disposal option for businesses.

                    Emergency planning and training under RCRA

Staff members who are responsible for handling, sorting, packaging and shipping hazardous
waste must establish emergency plans and be trained under RCRA, per 40 CFR Part 265.16.
Under RCRA, an SQG and LQG must prepare and train for each of the following four categories:

Emergency planning

From RCRA, all HW generators need to prepare for an emergency. Such preparations include:

    An on-site telephone or communication system, for use in an emergency.
    Fire-control equipment suitable for the materials being used or stored.
    Spill kit, stocked and maintained.
    Decontamination equipment (e.g., emergency shower and eye wash station), routinely
     tested and maintained.
    HW storage areas, free of drains to the outside, to prevent environmental releases.
    Prior arrangements with local authorities/responders in the event of an emergency.
    Updated Emergency Contingency Plan

Spill response
This facility should insure that all employees are thoroughly familiar with proper waste handling
and emergency procedures, relevant to their responsibilities during normal facility operations
and emergencies (40 CFR 262.34(d)(5)(iii)). Staff is responsible for cleaning up incidental spills
that happen in the course of performing their duties and should not attempt to control or clean
up any spills requiring assistance beyond their capabilities; see SOG on Spill Response for
Hazardous Waste.

In the event of a spill, trained staff members should be responsible to contain the flow of
hazardous waste to the extent possible and clean up the waste and any contaminated materials
or soil as soon as possible (40 CFR 262.34(d)(5)(iv)(B)).

In the event of a fire, an explosion, a spill that has reached surface water, or any other release
that could threaten the health of people outside the facility, immediately notify the National
Response Center (NRC) at 800-424-8802. The following information must be provided: the
name, address, and identification number of the generator; the type of incident and the date
and time of the incident; the type and quantity of hazardous waste involved; a description of any
injuries; the quantity of materials recovered and the disposition of the materials. (40 CFR

Training staff
40 CFR 265.17 requires that employers are trained to comply with RCRA standards, within six
months of the date of their initial employment or of an assignment to their HW position.
Employees hired after this six months must not work in unsupervised positions until they have
completed each of the requirements found in 40 CFR 265.17 (a). This Program will train staff
according to their job responsibilities, per the SOG on Hazardous Waste Training Program.

                          RCRA-required Retention of Records

    Type of RCRA Records                Retention Period              RCRA Text Reference
 HW Generator Training                Permanent Retention                 40 CFR 265.16
                                 Permanent Retention w/ last 3
 Manifests & Biennial Report                                              40 CFR 262.40
                                 years available for inspection
                                 Permanent Retention w/ last 3            40 CFR 273.13
 RCRA - Universal Wastes
                                 years available for inspection           40 CFR 273.99

                                             Attachment A
If not excluded, a waste is considered to be hazardous if it is either characteristic or listed.

Characteristic – chemical type based on waste properties; for a complete list, see CFR 40 Section 261:

Ignitable                            D001                        40CFR 261.21
Oxidizers                            D001                        40CFR 261.21
Corrosive                            D002                        40CFR 261.22
Reactive                             D003                        40CFR 261.23
Toxic (or flammable, toxic)          D001, D004-D043             40CFR 261.24

Ignitable wastes:
        flash point of <140 degrees F
        spontaneously combustible
        includes ignitable, compressed gas
        defined as an oxidizer (DOT rules)
Oxidizer wastes:
        wastes that add oxygen to a fire
        often have ―per‖ at the beginning of the name, ―oxide‖ at the end of the name, or an ―ate‖ in its chemical
Corrosive wastes:
        any liquid able to corrode 1/4 inch of steel per year (battery acid)
        pH <2 (acidic)
        pH > 12.5 (basic)
        able to burn or destroy living tissues
Reactive wastes:
        unstable or explosive wastes (lithium batteries)
        reacts violently with water (lithium, sodium)
        forms toxic or explosive gasses (cyanide, sulfide)
Toxic or pesticide wastes:
        capable of causing injury or death through ingestion, inhalation, or absorption
        capable of causing cancer (carcinogens), genetic damage (mutagens), and fetal harm (teratogens)
        under acidic conditions, releases toxic metals, pesticides, or volatile organic chemicals (photographic fixers,
         chemical wastes)
        pesticide wastes are classified as ―Universal Waste‖

Listed – wastes generated from specific industry processes. Use MSDS sheets to identify the chemical
components in the product, then see if it appears on one of four lists: F, P, K, or U (see references in 40 CFR 261,
which include:

Non-specific sources       F-List             40CFR 261.31
Specific sources           K-List             40CFR 261.32
Acute                      P-List             40CFR 261.33(e)
Toxic                      U-List             40CFR 261.33 (f)

F-listed wastes:                                                         K – listed wastes:
        degreasing solvents                                                * wood preservative mfg. wastes
        paint/lacquer thinners                                             * pesticide manufacturing wastes
        brake/carburetor cleaners                                          * iron and steel manufacturing wastes
        dry clean solvents                                                 * others
        distillation
        others

P-listed wastes:                                                         U-listed wastes:
        Acutely hazardous                                                   * toxic wastes
        Fatal to humans in low doses (arsenic, strychnine, cyanides)        * others

                                   CHAPTER TWENTY FOUR
                                    SPILL RESPONSE FOR
                                     HAZARDOUS WASTE
                                                        Revised 8/10
                            Staff is responsible for cleaning up incidental spills that happen in
the course of performing duties and should not attempt to control or clean up any spills
requiring assistance beyond their capabilities.

                        Regulatory and contractual requirements

Safe management of Hazardous Waste is governed by the requirements established in this
Facility, the HHW Contingency Plan, 40 CFR 261.3, OSHA 29 CFR 1910.38, 1910.120 (a) and
(q), 1910.132, and 1910.157 and Florida Administrative Code Chapter 62-730.

                                      Staff qualifications

Each staff responsible for any aspect of HW spill response should be trained within six months
of hire or of starting a new position at a management facility, or should be supervised until
trained by classroom exercises or by experienced staff. Training and precautions should be
taken to ensure staff’s overall health and safety, including training and personal protective
equipment (PPE) requirements. Staff members will be trained to prevent or mitigate negative
impacts to the environment.

                                    Spill kits/carts/lockers

Staff should ensure that spill kits/carts/lockers are stocked and readily available. They should
routinely inspect spill locker contents and replace items as needed. A recommended list of spill
kit contents is included in Attachment A.

                      Preventing environmental impacts from spills

Storage site

This Facility should be maintained and operated to avoid fires, explosions, or unplanned release
of materials to air, land, or water. To prevent an unplanned discharge, this Facility should not
have a floor drain which openly leads to groundwater, ditches and sewer or to the environment.

Storage containers

Hazardous Waste should be maintained within sturdy, non-pervious containers or lockers.
Waste types that expand as they freeze and thaw should be protected from freezing in order to
maintain container integrity. Aisle space between storage containers should be maintained in
order to ensure the unobstructed movement of personnel and emergency personnel.

Containers in the Facility storage area should be visible for inspection of their labels, integrity,
spillage, etc. Leaking containers should immediately be placed in secondary containment and
any spill cleaned up. Containers should never be placed in high traffic paths or in areas where
accidents could happen with the operation of forklifts or other equipment.


If a material container is brought to the collection center (or mobile collection) in an open or
leaking condition, site personnel should place the container and/or material into a larger,
appropriate (e.g. plastic or metal) receptacle (i.e. zip lock bag or 5 gallon bucket) and accurately
label the container. Any spilled material should be soaked up with absorbent material (vermiculite,
bicarbonate of soda, or oil-dry), which is stored in the equipment shed. This contaminated,
absorbent material should also be handled as a hazardous material, packaged, labeled and
sealed in an appropriate container and stored in the chemical storage shed for collection.
Exception – if less than 25 gallons of waste motor oil or petroleum waste has been absorbed into
absorbent pads, socks or vermiculite, such absorbent material can be disposed of as a de minimis
quantity of solid waste (40 CFR, Part 261.3(a)(IV)(D)).

                              MANAGEMENT OF CONTAINERS

1.     If a container holding hazardous waste is not in good condition or if it begins to leak, the
       operator should over-pack the container and its contents into a larger container that is in
       good condition, or manage the waste in some other way that complies with the
       requirements of this part.
2.     The operator should use containers made of or lined with materials which will not react
       with, and are otherwise compatible with, the hazardous waste to be stored, so that the
       ability of the container to contain the waste is not impaired.
3.     A container holding hazardous waste should always be closed during storage, except
       when it is necessary to add or remove waste.
4.     A container holding hazardous waste should not be opened, handled, or stored in a
       manner which may rupture the container or cause it to leak.
5.     The Facility Site Supervisor, Assistant or Staff should inspect areas where containers are
       stored, at least weekly, looking for leaks and for deterioration caused by corrosion or other
       factors. The operator should keep records and results of inspections.

                                      SPILL RESPONSE

Staff responsible for cleaning up incidental spills should use appropriate PPE. At a minimum,
the following PPE should be used when managing spills that pose a potential safety or health
    o Tyvek coverall or equivalent
    o safety glasses or goggles
    o chemical resistant gloves
    o chemical resistant boot covers
    o respiratory protection according to this Facility’s respiratory protection plan

Staff should be responsible for cleaning up incidental spills that may occur in the course of
performing their assigned duties for which they are already using the appropriate personal
protective equipment.

Facility staff should not attempt to control or clean spills which would require assistance beyond
their own capabilities. Large spills should only be responded to by utilizing the county’s special
operations, emergency response team. The Emergency Response Coordinator should contact
the necessary agency by dialing 911.

Petroleum spills of any size or amount into a waterway, and any spill or release of over 25
gallons onto a landmass or soil must also be reported to the Florida State Warning Point by
dialing (877) 272-8335.
This Program’s HW transporter is also responsible for immediately reporting spills which may
impact the environment. The transporter should have and be able to implement a safety and
spill response plan, during transport, for any HW shipments from this facility.

Spill Response or Incident Response Equipment

Facility staff should 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 should respond to control and/or cleanup spills which
require the assistance beyond the capabilities of Facility staff. Facility staff should be trained and
able to respond to small spills only. This Facility should make prior agreements with emergency
response teams or HW contractors who could be used in case of emergency.

If a spill, leak or discharge of petroleum oil, thinners, solvents or fuels is discovered, the
hazardous waste staff should work with equipment operators and other SWM employees, to
help identify the problem, mitigate the leak or spill, and to dike, contain and absorb any
petroleum product release.

During normal hours of operation the facility should be equipped with the following spill response

      A means of voice communication, including hand-held, two-way radios, should be provided
       to all Facility personnel, for immediate operational or emergency notification;

      A means of voice communication capable of communicating operational needs or
       summoning emergency assistance from the local police department, fire department, or
       local or state emergency response teams;

      Adequate, portable, Class ABC, fire extinguishers;

      Spill control equipment, including appropriate Personal Protective Equipment, absorbent
       pads, powders, and decontamination chemicals, tools and equipment;

      When necessary, there is equipment at the Landfill which is capable of providing water at
       adequate volume and pressure to supply water hose streams, or to provide water spray
       systems for first-responder decontamination. Such equipment should not be used by staff
       for fire extinguishment or the dilution of contaminates.

      Emergency shower and eyewash station.

                                       Attachment A
                                   Spill Kit Contents

Staff should ensure that spill kits/carts/lockers are stocked and readily available. They
should routinely inspect spill locker contents and replace items as needed. Refill kit
contents as they are used. Contents include:

      Universal, liquid sorbent pads or pillows
      Petroleum-base sorbent pads or pillows
      Sorbent dikes or socks (cellulose)
      Kitty litter, oil-dry and/or vermiculite
      Baking soda (sodium bicarbonate) or calcium bicarbonate
      Flat-bottom shovels
      Brooms
      Five gallon pails
      Disposal bags (various, multi-gallon sizes)
      30 and 55 gallon drums and drum liners
      Tyvek-type or chemical-resistant coveralls
      Nitrile or chemical-resistant gloves
      Safety glasses or goggles
      DOT Emergency Response Guidebook

                                     CHAPTER TWENTY FIVE
                                      MANAGING MERCURY
                                                       Revised 8/10
                             Mercury is a highly toxic metal and is hazardous to both humans
and the environment. Once mercury vapor is released, the waste cannot be reclaimed or
eliminated. Mercury wastes should either be recycled or disposed as a hazardous waste.
Mercury-containing devices include thermometers, barometers, switches, and thermostats.

                        Regulatory and contractual requirements

The State of Florida attempts to manage mercury wastes through the adoption of Chapter 62-
737 of the Florida Administrative Code (FAC) and through 40 CFR Part 273, as adopted by
reference, under Rule 62-730.185, F.A.C. The Florida regulation governing the use of universal
waste lamp crushing equipment for volume reduction is 62-737.400 (6)(b), F.A.C.

                               Health and safety precautions

The greatest health danger from elemental mercury is through inhalation (breathing in the
mercury vapor). Elemental mercury vaporizes slowly when spilled or exposed to the air.
Mercury will vaporize more quickly in a warm environment (e.g., on a kitchen range or a hot
plate), resulting in higher indoor mercury levels. In its’ vapor form, mercury is extremely toxic.
Skin contact with mercury may cause irritation. If exposure occurs, the person should shower
with soap and water. For a video demonstration regarding mercury vapors and exposure, go

Existing environmental conditions and the judgment of experienced Facility staff should
determine the PPE level required for each mercury exposure situation; see SOG on Personal
Protective Equipment. Take immediate, protective action if exposure threatens staff and/or
                              Evaluating and managing mercury

Staff accepting mercury waste should immediately assess the integrity of the holding container
or device. Leaking containers should immediately be placed in a plastic zip-lock bag or other
type of secondary containment. If the incoming mercury waste is classified as a RCRA
hazardous waste, the product waste should be properly packaged and stored in compliance
with DOT regulations. Mercury HW should be commingled and lab-packed with compatible
hazards or devices. RCRA, mercury containing products should be classified and labeled as a
Class 8, Corrosive, under UN 2809.

If the SWM facility staff discovers small quantities of spilled mercury, a member of the
Hazardous Waste staff should be notified. Staff members have access to a portable Mercury
Cleanup Kit and should follow the kit’s directions on how to mitigate small mercury spills.
Mercury spill waste should be packaged into a ziplock plastic bag and retained with the other
mercury waste products, with which it can be properly disposed.

     Disposal of Mercury-Containing Fluorescent Tubes as a Universal Waste

The Citrus County Hazardous Waste Collection Center recycles fluorescent and HID lamps by
following Chapter 62-737 of the Florida Administrative Code. This facility will dispose of
Universal Waste (Fluorescent) Lamps in accordance with FAC 62-737.400 (6)(b), which states:

―A generator of universal waste lamps may use crushing equipment on site to reduce the
volume of the stored lamps provided that: this is done in a final accumulation container; the
lamps are crushed in a controlled manner that prevents the release of mercury vapor or other
contaminants; the crushing operations and maintenance of the unit are performed in
accordance with written procedures developed by the manufacturer of the equipment, including
specific instructions for the frequency of filter changes; and the employees using this equipment
are thoroughly familiar with these written procedures and emergency procedures should
equipment malfunction occur.‖

The crushing of universal waste lamps at this facility is done for volume reduction, using
equipment called a drum top crusher (DTC). This equipment is commercially produced,
electrically powered apparatus that attaches to the top of a steel drum, breaks or crushes
fluorescent bulbs as they are manually fed into an intake one at a time. The machine directs
vapors released during the crushing operation through a two-step filtration system that absorbs
or removes mercury vapors, and deposits the crushed lamps into the drum to which the
apparatus is attached.

Drum top crushers have been approved for use at Florida household hazardous waste facilities,
including this one, to crush lamps from both households and conditionally exempt small quantity
generator facilities. Under 40 CFR 273.8 (a) and (b), both HHW and CESQG wastes may be
managed as universal wastes.

Because this HHW facility manages comingled quantities of HHW and CESQG mercury-
containing waste lamps, as allowed in 40 CFR 273.8, our facility becomes the generator of
these universal wastes. As a generator, this facility is permitted to use crushing equipment on-
site to reduce the volume of the stored lamps, per 62-737.400(6)(b), FAC.

As a recycler, this facility does not place used lamps from households, business, industry or
institutions in the regular trash.

This facility stores fluorescent bulbs in capped containers, over a concrete containment area, to
be crushed in the ―Bulb Eater‖ crusher. The sealed storage containers are marked ―Universal
Waste – Lamps‖, per 40 CFR 273.13.

Since this facility accumulates less than 2,000 kilograms (up to 8,000 lamps) at any one time
and hold them for less than one year, it qualities to be regulated as a ―small quantity generator‖.

Records and receipts for shipments of crushed and packaged lamps will be maintained and
available for inspection by DEP and local inspectors. Receipts will show the quantity or volume
of bulbs shipped, the date of shipment, and the name and address of the handler or recycling
facility which receives the shipped lamps. Records of receipts and shipments should be
maintained by this facility for a period of not less than three years from the date of shipment.

When universal waste lamps are shipped to a recycling facility within Florida, a hazardous
waste manifest and a licensed hazardous waste transporter are not required. When shipping
intra-state, a simple shipping paper may be utilized; see the SOG on DOT Shipping Papers.

           Model 55 VRS-U Premium Bulb Crusher Operating Procedures

The Model 55 VRS-U Premium Bulb Eater is currently being used at this facility to crush
incoming, spent fluorescent tubes from household and CESQG customers. To properly use the
Bulb Eater lamp crushing system, staff should:

Read the available, operating manual, before being allowed to operate the bulb crusher.

Make every effort to crush lamps in a well-ventilated area.

Wear safety glasses and protective gloves at all times while machine is in operation. A NIOSH-
approved filtration mask should be worn, after the operator has been properly trained.

Screw in the appropriate entry tube (either T12 or T8). Once the entry tube is screwed into the
drum lid, remove the rubber plug from the top of the entry tube and turn on the machine. A
separate, U-shaped bulb, entry system is also available for these type bulbs.

Once the system is running, place hand over the lamp entry tube to check for suction (i.e.
negative pressure. If you do not feel suction on your hand, turn off the machine and call the
customer service department at Air Cycle for assistance.)

Low suction pressure normally indicates that a filter is full and needs to be changed. The 1 st
stage filter bag should be changed after every half drum of crushed lamps, or as needed. The
2nd stage (hepa) filter cartridge should be changed after every 10 full drums of crushed lamps,
or as needed. A filter change schedule sheet is maintained and updated after each filter

Once it is determined that the drum is under negative pressure, you can now safely crush dry
fluorescent lamps. Do not crush any wet lamps. Lamps that have been stored in wet
environments need to be dry before crushing.

Line up the fluorescent tube over the entry tube and allow for roughly 3 inches of the lamp to
enter the tube. Let the vacuum pull the lamp into the drum. Do not force the lamp down the
entry tube.

Do not crush more than one full drum of lamps per 8 hour period per employee. This will
help ensure that OSHA Safety Standards are met.

After crushing, let the machine sit “off” for at least 15 minutes after the purge cycle is done,
to allow dust to settle before opening the lid. Otherwise, seal the top of the entry tube with the
rubber plug once the purge cycle is complete.

When bulb crushing has been completed, make sure that all openings are sealed. The entry
tube should be removed and stored on the side of the machine and the Bulb Crusher covered
from the weather with a protective cover.

If broken bulbs or glass are discovered, attempt to manage the spill or breakage in the following
manner described in ATTACHMENT A.

                                       Attachment A
            Residential Mercury Spill Response and Cleanup Hints
A. Mercury spill response for residential facilities
   Mercury spills in the home typically involve small amounts of mercury. Common mercury
   sources in a household include thermostats, thermometers and fluorescent light bulbs. No
   matter how small the amount of mercury spilled, every spill should immediately and properly
   be cleaned up to protect the health of the people in the home, especially children and
   pregnant women. When mercury is spilled, it can form very small beads that can be spread
   considerable distances from the spill site making cleanup very difficult. Mercury also
   contaminates the air and can be easily breathed in. Cleanup guidelines a homeowner can
   use following a mercury spill include:

       Isolate the spill area. To prevent the spread of mercury keep people and pets out of
        the spill area and close doors to the room. Close cold air returns and ventilate the room
        to the outside.
       Assess the spill for cleanup. Small mercury spills may be safely cleaned up by a
        homeowner and sealed into a ziplock bag. Larger quantities or spills on carpet, textiles,
        and surfaces with lots of cracks and crevices should be cleaned up by a professional. A
        household mercury spill may be cleaned up by the homeowner if it is:
           A small amount, such as a thermometer (this volume is about the size of a pencil
           Isolated to a small area and the mercury has not been spread around.
           On a hard and smooth surface (tile, linoleum, wood floors).
           On a small, porous item (area rug).

B. Mercury spill cleanup preparations

   1. Do not vacuum a mercury spill. Their vacuum will become contaminated if used for
      spill clean up and makes clean up much more difficult. If this should happen, bring the
      vacuum bag into a HW Facility and dispose of the vacuum machine in the trash. The
      contaminated vacuum machine cannot be reused at it will continue to spread mercury.
      The vacuum process will break the mercury beads into smaller droplets and increase
      the mercury vapor in the air.
   2.     Supplies. For proper clean up of mercury spills, collect the supplies listed below:
        a. Rubber, vinyl, nitrile or latex gloves
        b. Small sealable plastic bags or a glass or plastic jar
        c. Large plastic trash bags
        d. Paper towels, napkins, tissue, or toilet paper
        e. Flashlight
        f. Tape (e.g. Duct, packing or masking)
        g. Eyedropper
        h. Single edge razor blades or stiff paper (e.g., index cards, cardboard)
        i. Old, disposable clothing to be worn during clean up
   3. Protective clothing. Before attempting to cleanup spilled mercury check their shoe soles
        to make sure they are not tracking mercury throughout the house. Remove any jewelry
        (mercury will adhere to metals and is difficult to clean), put on old clothes, gloves and
        place plastic bags over shoes to keep them clean.

C.      Mercury spill cleanup

     1. On hard surfaces (countertops, linoleum, tile)
        a. Label a container (sealable jar or plastic bag the waste will be placed into) and label
           or mark the container with the words ―Mercury Waste.‖
        b. Collecting broken glass: wrap glass in a paper towel to prevent puncturing a plastic
           bag and place in the labeled container.
        c. Collect the liquid mercury:
           1) Push the beads of mercury together using two razor blades or stiff paper. Use a
               flashlight to search in any cracks and crevices for mercury beads and glass
           2) The eyedropper works well to pick up the mercury beads. Carefully transfer the
               mercury beads into the ―Mercury Waste‖ labeled container.
           3) Use tape to pick up any remaining droplets of mercury and pieces of glass and
               place into the ―Mercury Waste‖ labeled container.
        d. Wipe up the spill area:
           4) Moisten a paper towel and thoroughly wipe up the spill area and place into a
               ―Mercury Waste‖ labeled container.
           5) Place all mercury contaminated cleanup materials in a plastic bag, seal, label
               with ―Mercury Waste‖ and bring to their local HW Facility for proper disposal.

     2. On carpet, furniture, or other porous surfaces: Carpet spills should be cleaned up by
        a professional contractor. A mercury detecting meter may be needed to determine how
        far the mercury has spread. For the cleanup of a broken fluorescent light bulb, see
        Section 3.3. If the homeowner has been advised by the Florida DEP to perform the
        clean up without professional assistance; the following steps should be taken:
        a. Locate the affected area of the carpet.
        b. Cut and remove the section of carpet and pad affected by the spill.
        c. Fold the contaminated piece so the mercury is trapped inside.
        d. Place the contaminated item and all items used for cleanup into a plastic bag.
        e. Use a flashlight to search surrounding spill area for any additional mercury beads.
        f. Seal the bag and label with ―Mercury Waste‖ and bring to their local HW Facility for
            proper disposal.

     3. Broken fluorescent bulbs. Fluorescent bulbs contain mercury and must be disposed of
         properly. The Citrus County HW collection facility accepts and recycles florescent bulbs.
         Mercury-containing bulbs include; tubes, compact fluorescent lights (CFLs), U-shaped,
         round, or high intensity discharge (HIDs), but does not include the light fixture itself.

        a. If one bulb breaks on a carpeted surface, if they choose to clean it theirself, they
           may cautiously use a vacuum to perform the clean up. When the clean up is
            Take the vacuum outside and remove the bag or contents from the waste trap
               (for bag-less vacuums) and place in a plastic bag.
            Seal the bag and bring it to the HW Collection Center for proper disposal.
            Allow the vacuum cleaner to remain outside of their home to air out, and do not
               use for 2 days. It is best if the cleaner is disposed of in the regular trash.

         b. If more than one fluorescent bulb breaks on a carpeted surface:
             Follow the suggestions as listed in section C-2, above
         c. If the fluorescent bulb breaks on a hard surface:
             Collect the broken glass and place in the trash.
             Moisten a paper towel(s), thoroughly wipe up the spill area, and place towel(s)
                 into the trash.
     4. Outdoors: If on soil:
         a) Use a disposable tool to scoop up the mercury, along with the surrounding soil, and
            place in a container along with the clean up tools.
         b) Seal the container (screw on lids or tape plastic bags), label with ―Mercury Waste‖
            and bring to their local HW Facility for proper disposal. Ensure container size does
            not exceed five gallons. If on a hard surface, see section C-1.

D.       After cleanup is complete
        Carefully remove items in the following order:
         1. their clothes
         2. plastic bags used to cover shoes
         3. gloves (Nitrile, vinyl or latex gloves can be turned inside out as peeled off)
        Place all clothes that have come into contact with the mercury into a sealable plastic
        Seal the bag and dispose in regular trash.
        Immediately after the cleanup, wash hands thoroughly and take a shower.
        Isolate the room by closing the doors and sealing the vents. Ventilate the area by
         opening windows and exterior doors and use fans to force contaminated air out. Do this
         for at least two days after cleanup.

     3. Disposing of mercury waste
     Waste from a mercury spill may be brought to their local HW Collection Program or placed
     into the trash, as directed above. Any homeowner or contractor (hired to assist the
     homeowner) should contact their local HW Collection Program before transporting the
     mercury waste, to confirm the proper acceptance procedures. All mercury waste should be:
      Packaged in sealed containers no larger than 5 gallons.
      Placed in a container labeled as ―Mercury Waste.‖
      Stored outside the home or in a well ventilated area until it has been properly disposed.

     4. Additional information
     For health concerns regarding possible mercury exposure, call their personal physician or
     contact the Florida Department of Environmental Protection. The information for this
     Attachment is taken from
     For additional questions on fluorescent bulbs or mercury, please email the Citrus County
     Division   of    Solid   Waste      Management,       Hazardous   Waste     Program    at or they can call Citrus County SWM at (352) 527-7670.

                                      CHAPTER TWENTY SIX
                                      MANAGING ASBESTOS
                                                           Revised 7/09
                              Asbestos waste should be examined at the time of drop off to
determine if the material is friable. The term ―friable‖ indicates the asbestos fibers (dust) are or
could become airborne, creating a serious inhalation hazard. A material is friable when it can be
crumbled, pulverized, or reduced to powder by hand pressure when dry. Asbestos materials
can become friable by degradation from weather or time, sanding, sawing, drilling, crushing,
grinding, dropping, or breakage.

This HW Program should not accept ―friable‖ asbestos wastes, for recycling or disposal. In the
event asbestos-containing waste is required to be managed by this program, staff should follow
safe management practices. Program staff should evaluate each situation and determine an
appropriate response to ensure the safety of Facility staff and the general public.

                                  Regulatory requirements

Regulatory information has been obtained through Chapter 62-701, F.A.C., OSHA, Section 29
C.F.R. 1910.1001, and Section 40 C.F.R. Parts 61.149, 61.150, 61.151, 61.154, Subpart M-
National Emission Standard for Asbestos, July 1, 1992.

                               Health and safety precautions

Exposure to asbestos dust may cause lung cancer, asbestosis, and mesothelioma. There is a
latency period of 10 to 40 years between exposure and illness. Asbestos is invisible to the
naked eye, odorless, tasteless, and undetectable without the use of monitoring equipment.

Recognizing materials that are likely to contain asbestos and using safe work methods when
handling these materials is the best way to prevent exposure. A list of the most common
asbestos materials can be found in Attachment B of this SOG.

This Program requires that asbestos training be provided prior to the time of initial assignment
and at least annually thereafter.

This Program should not respond to requests for asbestos removal or attempt to control
situations requiring assistance beyond the capabilities of the Facility staff. This Program should
make agreements with appropriate response teams to use in emergency situations. Unique
environmental conditions and the judgment of experienced Facility staff should determine the
PPE level required for each specific situation. For more information, members should refer to
the SOG on Personal Protective Equipment.

                                 Evaluating friable asbestos

Staff members who accept friable asbestos materials should first attempt to learn as much as
possible from the participant, prior to becoming exposed to asbestos fibers. If necessary, tax
records or proof from driver’s license may be utilized to verify the county of residence.
Questions should be asked as to where the material was generated, stored or located, or its
intended use.

In non-friable asbestos materials, the asbestos fibers are bound and unlikely to become
airborne as long as the material remains in good condition. Non-friable materials (e.g., asbestos
roofing tar, cement asbestos board or transite, vinyl asbestos tiles) pose very little health
hazard when handled carefully. In these materials, the asbestos fibers are bound in a matrix
that holds the fibers tight. This matrix can degrade over time, if it is damaged or broken,
allowing the fibers to become friable. This HHW Program should accept only non-friable
asbestos waste to commingle and properly process with other like wastes.

                       Non-routine asbestos incident safety plan

Assigned, HW Facility staff should be authorized to implement the Non-Routine Asbestos
Incident Safety Plan. Any trained, HW Program staff member may implement the non-routine
incident safety plan, as conditions warrant. Only trained and experienced Facility staff members
may assist the participant to evaluate asbestos waste, to determine if implementation of this
plan is necessary. This designated person should follow the procedures listed below:

   1. Asbestos waste should be visually examined at the time of drop off to determine if it is
      friable. Assume any suspect asbestos material to be friable. Visible emissions of dust or
      fibers are situations beyond the capacity of this Program. If friable asbestos is present,
      immediately evacuate customers and staff from the area.
   2. Have the participant keep the unsecured, suspect material outside the Facility and place
      in a secure area, located upwind or out of wind from all participants and staff.
   3. Explain to the participant that the material poses a serious health hazard, and it may
      take a few minutes to evaluate the situation to determine the most appropriate safety
   4. It is recommended that the Emergency Preparedness Director consult with a contracted
      hazardous waste disposal company to determine how to properly manage any on-site,
      friable asbestos waste.
   5. Inspect other materials delivered with the same load for asbestos dust. These
      containers may need to be sprayed with water, wiped down with wet towels, or
      vacuumed with a HEPA vacuum (by the asbestos abatement contractor).

                                       Attachment A
                    Guidance for the Disposal of Asbestos by Citizens

Since asbestos is not classified as RCRA hazardous waste and/or is not regulated, it may be
disposed of as solid waste. Review local solid waste ordinances and requirements on proper
asbestos management as friable materials are only allowed to be disposed of at solid waste
facilities permitted to accept asbestos. Facility staff should not assist the participant in properly
containing their asbestos load for solid waste disposal. If the participant chooses to transport
the asbestos material to a permitted solid waste facility for proper disposal, Facility staff should
recommend the following disposal methods to citizens:
1.     Request the participant to move their vehicle to an appropriate area out of the Facility
       receiving driveway to a designated restricted access area and keep Facility staff away.
2.     Do not allow the asbestos material inside any Facility buildings as all containment
       should be done outdoors.
3.     Place a sheet of plastic on the ground to prevent contamination during the containment
4.     Check the integrity of the asbestos container and duct tape any holes.
5.     Spray down the entire area before disturbing any of the material (surfactant additive is
       commercially available for use in sprayers, or substitute a mixture of 1 part mild
       detergent or dish soap to 10 parts water).
6.     Avoid breaking the material, which may create asbestos dust.
7.     Spray in the air above the material to let the mist capture airborne fibers.
8.     Thoroughly wet the material—remember the rule: ―No visible emissions.‖ If dust is
       present and becomes airborne, or if there are releases from the packaging, the material
       is not wet enough.
9.     Immediately place the wetted materials into secondary containment (e.g., shovel, lift in).
10.    Store all wastes in a closed container or double bag into a plastic bag and seal with duct
11.    Mark container with an asbestos warning label or with the words ―Asbestos Waste.‖
12.    Clean up the area and remove all visible debris.
13.    Wet entire area if using brooms.
14.    Use a HEPA filter if vacuuming dust.
15.    Thoroughly wet the entire load and surrounding area.
16.    Contain all waste and have participant transport to a permitted solid waste landfill for
       proper disposal.
17.    Instruct the participant to notify the scale house employees, at the solid waste landfill, of
       the incoming load (provide contact information if necessary).
18.    Thank the participant for taking steps to correctly and safely dispose of this and future
       asbestos waste.
                                   Attachment B
Common Asbestos Waste Materials Displaying Possible Hazardous Characteristics

  o   Roofing tars (normally flammable under RCRA) containing asbestos fibers (non-friable)
  o   Asbestos board (narrower than cement board, but looks similar) - friable
  o   Asbestos ceiling tiles (breakable, soft, often in 12‖x12‖ squares) - friable
  o   Stove piping (asbestos inside the piping) - friable
  o   Safes (often flameproof containers with asbestos encased within the walls) - friable
  o   Pipe wrap (normally white, breakable and soft insulation) - friable
  o   Heat reflective material (pads for hot cooking pans) - friable
  o   Engine sheeting (looks like paper rolls and is usually found in garages) - friable
  o   Old brake pads- friable

                                 CHAPTER TWENTY SEVEN
                                      MANAGING PCB WASTE
                                                       Revised 8/09
               Waste       The acceptance of fluorescent light bulbs often includes receiving
                           the accompanying ballast. Ballasts act as insulators in electrical
equipment and may contain polychlorinated biphenyl (PCB) waste. PCBs are also found in
insulators and motor start capacitors in home appliances and industrial equipment. This
Program is licensed by the State of Florida to collect hazardous wastes from both residents and
Conditionally Exempt Small Quantity Generator (CESQG) customers.
                        Regulatory and Contractual Requirements
PCB ballast management is permitted in accordance with the Operational Contract between
this HW Program and the State of Florida, the Toxic Substance Control Act (TSCA), 40 CFR
761, and those rules and procedures adopted by the Florida DEP.
                              Health and Safety Precautions

Upon accepting PCB wastes, this Facility is responsible for its proper recycling or disposal. The
staff member who is ultimately responsible for ensuring PCB waste compliance is the Facility
Manager. PCB waste management is the responsibility of the HW Coordinator. Staff should be
trained on the acceptance and management of PCB wastes, including the proper use of PPE.
                     Managing PCB Ballasts, Insulators and Capacitors

Acceptance of PCB–related electrical equipment

      Electrical equipment which contains PCBs should be recycled through a legally licensed
       contractor and should not be placed into solid waste.
      Household-generated electrical equipment does not require a shipping manifest,
       although such will be required from a business.

Businesses who generate ballast PCB waste

CESQG businesses should first contact this Facility to obtain all necessary information, prior to
supplying us with PCB waste. A business may transport its waste using a personal or business
vehicle. However, a manifest is required during transport since unmarked ballasts are
assumed to contain more than 50 ppm of PCBs. A shipping paper may not be used in lieu of a
manifest for business-generated PCB waste.

A manifest is required for transporting PCB-equipment from the business site to this Facility and
terminates upon arrival. Staff may provide the business with a properly completed manifest
prior to transporting the waste; see Attachment A of this SOG.

      Box 1 of the manifest form requires a 12-digit hazardous waste (HW) Generator
       (Identification) ID Number. EPA regulations allow for the use of a generic HW Generator
       ID number for one-time generators (OTG) of PCB ballast waste only. While completing
       Box 1 on the manifest form, it is acceptable to use ―40CFRPART761‖ as the ID number.
       This generic number can only be used one time per generator and does not apply to
       businesses that already have an EPA ID Number.
      Box 14 of the manifest form requires an approximate out-of-service date. This Facility
       should use the business shipment date as the out-of-service date. Because of the out-
       of-service date requirement, it is imperative Facility staff ensure generators do not forget
       to write in this date while signing the manifest. Both this Facility and the generator are
       required to keep manifest documents for at least 3 years from the date of issuance
       (preferably indefinitely).

             Prior to ballast transport from the business site to the Facility

Staff should provide direction (e.g., a manifest, markings, labels) prior to a business bringing
PCB ballast waste to this Facility, including:


Leaking and non-leaking PCB ballasts should be stored in separate containers and have
sufficient material in the disposal container to absorb any liquid. Containers should be kept
tightly sealed and marked with the PCB label. Individual ballast containers may not be
transported in excess of 800 pounds (the typical container size used is 5-gallons and should
only be filled ¾ full). The shipping container should be properly secured, marked, and labeled
during transport; see Attachment B of this SOG.

Markings and labels

Complete the information on the PCB label and attach to the waste shipping container.
Required markings should be placed on all closed outer packaging containers to comply with
DOT manifest and transportation requirements, as in Attachment B.


This Facility should ensure the business is provided with the information to correctly complete
their manifest and package markings.

                               Processing incoming ballasts

In Florida any PCB wastes containing greater than 50 parts per million of PCBs are prohibited
from disposal at Municipal Solid Waste disposal facilities per Rule 62-701.300(5) F.A.C.. Staff
should assume that ballasts or capacitors contain PCBs unless the items were known to be
manufactured after 1979, or are labeled with the words ―No PCBs‖ or ―Contains No PCBs.‖ All
such items may be placed in the trash.

Spent ballasts should not be placed on any product exchange or reuse shelves. This Facility is
prohibited from treating or disassembling PCB ballasts. PCB containers should exhibit the PCB
label and be stored away from public access and in designated Facility areas sufficient to
contain the waste.

State-contracted HW disposal and/or fluorescent light bulb companies are available for PCB
ballast recycling or disposal. Ballasts should be packaged following the specific recycling
company guidelines and in containers sufficient to contain all spills.


This Facility should provide CESQG participants with a receipt to the business generator,
detailing the cost and the type waste which is being disposed. The business may use a copy of
this receipt to demonstrate proof of proper disposal. Receipt information should include:

      Generator business name, address, and phone number
      Waste type and quantity
      Delivery date and
      The words: ―Keep this receipt for three years.‖

            Attachment A
Draft Example of a Manifest for Ballasts

                                     ATTACHMENT B
     Markings for a PCB, Ballast shipping container

Proper US DOT Marking:

PCB Waste

Instructions for proper marking:

  1. Complete the above label contact and telephone information using a permanent marker.
  2. Attach the above PCB Ballast Waste marking on all closed outer packaging containers prior
     to bringing PCB ballast waste to this Facility.
  3. For additional copies of this label, either:
         color copy this sheet or
         purchase the above label and attach it to the shipping container side
  4. The PCB Waste Label, a properly completed Hazardous Waste Shipping Label and a Class
     9 Warning Label should be attached to the shipping container, prior to shipment

                               CHAPTER TWENTY EIGHT
                              MANAGING METH LAB WASTE
                Household                            Revised 8/09
                Hazardous Methamphetamine laboratory (meth lab) wastes are generated at
                Waste     illegal sites and may create environmental hazards. This stimulant
                          drug is made from cold medicine containing ephedrine and common
household chemicals. The controlled, meth substance manufactured at clandestine meth labs
cannot legally be accepted by this Program. When methamphetamine lab waste is presented,
experienced Program staff should evaluate each situation and determine the best method for
proper disposal. In the event meth lab waste must be managed, this SOG outlines this
Program’s meth lab waste policy.

                         Regulatory and contractual requirements
                              Health and safety precautions

Meth waste management is governed by the requirements established in the HW Program
policy and Florida DEP Hazardous Waste Rules. In addition, Florida Drug Enforcement
Administration (DEA) regulations apply if the material received is determined to be a controlled
(methamphetamine) substance. If abandoned or incoming meth lab materials are discovered,
contact the Citrus County Sheriff’s Office.

This Program should have a written training program which includes methamphetamine lab
material waste recognition and management procedures relevant to job duties. When a meth
lab material is identified, precautions for Facility staff and the public’s overall health and safety
should immediately be addressed to avoid potential exposures. Isolate and/or store all meth lab
waste materials away from public access.

The Program should not handle situations or take charge of situations requiring assistance
beyond the capabilities or legal responsibilities of Facility staff. This Program should have
agreements with appropriate County response teams, to contact in emergency situations.

This Program should not go off-site to manage meth lab wastes, but should act only as a
receiving facility for hazardous wastes or solid wastes which do not contain controlled
substances. Unique environmental conditions and the judgment of experienced Facility staff
should determine the PPE level required for each specific situation; see SOG on Personal
Protective Equipment. Take immediate action if a danger threatens staff and/or property. Keep
alert for suspicious activities or behaviors in accordance with the Program’s DOT Security Plan.

                            Methamphetamine waste acceptance

Individual products used in the manufacturing process of meth are not considered to be
controlled substances and can be managed by this Program.

This Program should not accept finished methamphetamine drugs or other controlled
substances. Staff should contact the Citrus County Sheriff’s Department to report the discovery
of a meth lab product, needles, or any other drug paraphernalia. Instruct local law enforcement
to properly dispose of a finished meth product through their established channels of disposal.

Local law enforcement may request approval to bring meth lab wastes to this Facility`, in their
possession, for proper disposal. This Program should have an agreement in place with local
law enforcement agencies which requires an identification and notification procedure. If waste is
presented from local law enforcement, the waste should be examined at the time of drop off to
determine if it has been properly packaged and labeled. If waste has not been properly
packaged or labeled, Program staff will immediately and properly re-package the wastes.

                          Methamphetamine Waste Management

Staff accepting meth waste should attempt to identity the materials by:
    Asking the participant questions.
    Observing container labeling or markings.
    Utilizing staff knowledge about the waste stream.
    Performing preliminary testing on the waste material (e.g., pH, ignitability).
    Reviewing this SOG

Do not accept meth lab waste containing anhydrous ammonia (e.g., in propane cylinders,
compressed gas cylinders, duct-taped coolers, thermos, fire extinguishers, sealed insulated
containers). Be alert for green or blue color cylinder ends or pipe fittings, caused by
contact with anhydrous ammonia. If discoloration is noted, do not touch these containers as
they may be very unstable!

If a cylinder has suspicious colors on the pipe fittings, do not disturb it. Immediately contact the
local Fire/Rescue hazmat team or County Sheriff’s Department bomb squad for assistance.

Properly contain, segregate, and categorize incoming meth lab materials. Once properly
categorized, meth lab wastes may be commingled with Facility hazardous wastes. Meth lab
recipes use common household products and may create wastes, which may include:

      Engine starter – ether
      Alcohol – rubbing, iSOGropyl, methanol
      Gasoline additives – “HEET”
      Acids – muriatic, hydrochloric, sulfuric
      Brake cleaner – toluene
      Pharmaceuticals – ephedrine, pseudoephedrine cold tablets
      Drain cleaner
      Gun scrubber – tricholoroethane
      Veterinarian products – iodine
      Salt – table rock
      Batteries – lithium
      Propane tanks – anhydrous ammonia, phosphine gas
      Lye – sodium hydroxide
      Sodium metals
      Matches or flares – red phosphorus
      Solid waste – meth processing equipment that may contain residue

Staff should be aware of the potential risks of managing meth lab wastes. Be cautious of hard-
to-identify and acutely hazardous wastes (from the above list). Use caution while managing
containers with raw meth material (e.g., product, liquid, solid by-products) since chemical
exposure dangers may still remain.

Acute, chemical exposure waste hazards may include:

    Lithium and sodium metals may be explosive with water.
    Phosphine gas may be toxic and explosive with air.
    Red phosphorus may be flammable and explosive.
    Anhydrous ammonia is a corrosive inhalation and contact hazard.
    Acids and bases are a contact hazard.

Staff should use caution while handling methamphetamine containers to avoid exposure from
acids or bases which may have been spilled. Be especially cautious of containers that may hold
hydrochloric or sulfuric acids which often arrive in gallon gasoline cans with a hose taped to the
Manage solid waste items carefully as exposure hazards may still remain from meth lab
residues. Containers with significant residue should be processed as a hazardous waste. Place
empty equipment in a heavy garbage bag and close tightly and place in solid waste disposal
areas. Meth lab solid waste equipment may include:

    Glass heat-resistant dishes
    Bottles
    Measuring cups
    Canning jars
    Laboratory beakers
    Paper towels
    Coffee filters
    Cheesecloth
    Funnels
    Tubing
    Empty aerosol containers
    Strainers
    Aluminum foil
    Pails
    Plastic storage containers
    Ice chests
    Gloves
    Tape
    Clamps
    Blenders
    Hotplates or heating units
    Floor and wall coverings

                                   CHAPTER 29
                               MANAGING RADIOACTIVE
                                                       Revised 8/09
This Program should not accept radioactive waste or materials under normal circumstances.
When radioactive wastes are presented, this Program should reject such materials, due to the
negative potential effects and the high cost of disposal. Whenever radioactive material is
accepted, this Program becomes the generator and is responsible for its proper and legal
disposal. In the event radioactive waste is required to be managed, this SOG outlines a more
safe work environment for Facility staff and the general public.

This Program is only slightly better able to safely manage unwanted and unusable radioactive
materials than the general public. This Program will manage radioactive materials on an
emergency basis, only for proper management and removal from public access. Even then,
only specially trained personnel should relocate and handle such radioactive materials.

Radioactive waste may include items generated from radioactive sources (e.g., gas
chromatographs, well logging, moisture density devices, smoke detectors, thorium mantles,
lock illuminators). Such materials also include items which have become radioactive through
exposure to neutron radiation. This waste typically consists of contaminated personal
protective equipment (PPE) and/or operating equipment (e.g., shoe covers and clothing,
wiping rags, mops, filters, reactor water treatment residues, tools, luminous dials, medical
tubes, swabs, injection needles, syringes, source salts). Radioactivity can range from just
above background levels found in nature to very highly radioactive levels (e.g., parts from
inside the reactor vessel in a nuclear power plant).

                      Regulatory and contractual requirements

The proper management and regulation of radioactive hazardous waste (HW) is governed by
the requirements established in this HW collection program, the HW Contingency Plan, and
the Florida Department of Health. For immediate or crucial information, contact a state-
contracted HW disposal company, the Citrus County Haz Mat Team, or the Nuclear
Regulatory Commission at: 301-415-8200, Fax: 301-415-2234, or on the web at

                             Health and safety precautions

This Program should have a written training program, which includes radioactive material
awareness and management procedures relevant to job duties, including the implementation
of an emergency contingency plan. When radioactive material is identified, precautions for
Facility staff and the public’s overall health and safety should immediately be addressed.
Avoid potential exposures if radioactive levels are unknown.

This Program should not respond to or attempt to control situations requiring assistance
beyond the capabilities or training of Facility staff. This Program should make agreements
with appropriate response teams, along with the HW Contingency Plan, to utilize during an
emergency. Unique environmental conditions and the judgment of experienced Facility staff
should determine the PPE level required for each specific situation. Take immediate action if
danger threatens staff and/or property. Keep alert for suspicious activities or behaviors in
accordance with this Program’s DOT Security Plan.

                                   Equipment and Supplies

A Geiger counter is the primary method used to detect levels of radioactivity being emitted.
Radiation detection equipment varies based on specific radioactive levels and types being
measured. Maintain available detection equipment according to manufacturer specifications.

                      Procedures for managing radioactive wastes

Waste identification

Visually inspect all incoming containers to determine if the contents may be potentially
radioactive. Staff should attempt to identify the party responsible for generating the waste.
Attempt to learn any information about the radioactive material from the participant bringing in
the waste. When appropriate, refer the generator of the waste to appropriate regulatory
authorities (local Sheriff’s Office, County Health Department, or Federal regulatory program).

Look for markings, key words, or labels indicating ―Radioactive.‖ Laboratory mixtures or
solutions containing uranium or thorium may be radioactive. For a list of common radioactive
materials; see Attachment A of this SOG. Any markings indicating radioactive materials
require immediate attention. Be alert for the following markings:

      Trefoil (the radioactive symbol), shown in Attachment B of this SOG.
      Specific Department of Transportation nomenclature; Low Specific Activity (LSA) or
       Surface Contaminated Objects (SCO)
      Uranium
      Thorium

Elements which are followed by a number (e.g., polonium-210, radium-226, H-3)
Radionuclides and/or the activity may also be listed on the container and the nomenclature
may differ (cesium-137 may be written as 137-Cs, Cs-137, or 137Cs)

Radionuclides activity levels will generally be listed in terms of:

      Quantity – Curie, milliCurie (mCi), microCurie (μCi), or
      Exposure rate – Roentgen per hour (R/hr, mR/hr, μR/hr) or
      Rem – rem/hr, mrem/hr, μrem/hr

Determine the radioactive level

Avoid handling the waste material and do not disturb the container until a preliminary
evaluation is completed. Treat suspect material as if it is radioactive and limit the number of
staff near the immediate area of suspected radioactive materials. If detection equipment is
available and staff is properly trained in its use, follow the directions contained in the
manufacturer’s operation manual to determine the radioactivity level.

Securing radioactive material

Staff should ensure the safe and proper management of the materials and/or situations on a
case-by-case basis. If radioactive materials are inadvertently received, the SWM Emergency
Coordinator should immediately contact the Nuclear Regulatory Commission, local hazmat
team or the state-contracted HW disposal company for further direction.

If a potentially radioactive material is discovered, evacuate all persons from the immediate
area until further help or investigation has been completed. For a list of common radioactive
materials see Attachment A of this SOG.

Inadvertent radioactive waste received during a collection event or at this Facility should be
segregated from other waste and properly managed prior to its disposal or transport. If the
suspected radioactive material needs to be moved, have the participant gently remove it and
place it within secondary containment or in a specifically staged area away from the public,
staff and traffic until radioactive levels are determined and/or proper authorities are notified.

Radioactive materials require pre-approval for disposal with this Facility’s state-contracted HW
disposal company and may not be lab packed with other wastes. Use the appropriate disposal
form as provided by the HW disposal company; see Attachment C of this SOG.

                         Attachment A
                   Common radioactive materials
                  Please use the following list for general guidance only.

Name (synonym)
Cesium-137 (Cs-137, 137Cs)          Commonly used in various sources.
Cobalt-60 (Co-60, Co)               Used in various sources.
Nickel-63 (Ni-63, 63Ni)             Used in electron capture devices for gas
Hydrogen-3 (H-3, H, tritium)        Used in exit signs and other sources.
Thorium (Th-232, Th)                Natural radionuclide used in some sources and old
                                    gas mantles.
Uranium (U-238, 238U, U-Nat, EU(%), Natural radionuclide unless processed, used in
DU, yellowcake)                     various applications, including old ceramic glazing,
Uranyl nitrate (common in school sources, and counterweights.
Americium-241 (Am-241, 241Am)       Used in smoke detectors and other sources, including
                                    moisture density gauges.
Phosphorous-32 (P-32, P)            Used in laboratory research.
Iodine-123 (I-123, 123I)            Used in medical treatments.
Iodine-131 (I-131, I)               Used in medical treatments.
Smoke detectors                     May emit low amounts of radioactive particles; place
                                    unwanted smoke detectors in or with other solid
                                    waste / trash, or return them to the manufacturer.

                         Attachment B
                     Common radioactive labels

DOT Package Labels

DOT Radioactive (Class 7) Placard
                      Attachment C
        Example of a Radioactive Approval Checklist

Date: ________________________

_____ 1. Waste # ______________
_____ 2. Waste completed and signed
_____ 3. MSDS current and legible
_____ 4. Sample, if used or process waste
_____ 5. DOT UN number ____________

For devices:
_____ 6. Diagram, schematic, drawing, photo of device.
Note: When taking a photo, place a ruler or other common object next to the device to
assist with size/scale determination, e.g., a penny next to a blasting cap.

_____ 7. Gross weight of each device _______________________
_____ 8. Net radioactive weight of device _________________
      (amount of radioactive in device in pounds)

_____ 9. Size of each device ___________
_____ 10. Number of devices per container ________________
_____ 11. Radioisotope date and activity (reading) ________________
_____ 12. Radioisotope model # and manufacturer ________________
_____ 13. Radioisotope equipment approximate dimensions ________________

Additional information:




    Radioactive waste disposal must be scheduled three weeks in advance.
    Allow two weeks for a paperwork approval, three weeks for a sample approval.
    Changes in the schedule date must be approved by the HW disposal company.

                                      CHAPTER THIRTY
                                   EQUIPMENT OPERATION
                                     AND MAINTENANCE
                Waste                                  Revised 9/09

This Program should establish written procedures for machine-specific equipment use and
maintenance. Refer to each manufacturer’s operating manual for the correct operating
procedure of Facility equipment (e.g., Bulb Eater, air compressor, forklift, hand-fed or
mechanical can puncture equipment, floor scale, air impact wrench, etc.).

                       Regulatory and contractual requirements

Equipment operation and maintenance is governed by OSHA 29 CFR 1910.106(e)(3)(v),
1910.242, 1910.243, 1910.147, 1910.178, and the requirements which are established by this
HW program.


All new staff members working within the HW program should receive job-specific training on
the proper equipment operation and maintenance, as part of their initial, in-house, SWM
orientation. Staff not involved with equipment operations, at the minimum, should be trained to:

    not touch or operate the equipment at any time, prior to receiving training and
    be aware of its operation and/or driving paths.

Staff members who operate equipment should be trained in all steps of proper equipment use,
associated hazards and precautions, after hire, specific to their particular job.

                              Health and safety precautions

Precautions should be followed at all times to assure the safety of both the general public and
staff while operating equipment.

This Program should provide appropriate personal protective equipment (PPE) to staff and will
ensure that employees are trained and are using their PPE while operating equipment.

A hearing conservation program will be required when exposure to equipment noise is equal to
or greater than the action level of an 8-hour time-weighted average of 85 dB.

Adequate air flow should be provided in work areas, to lessen potential exposures to vapors or
gases emitted from the process or from equipment.

                                     Equipment safety

Staff should inspect HW equipment prior to its use to ensure that no problems exist that would
make it unsafe. Any problems or defects found should be brought to the attention of a
supervisor or experienced and qualified staff members, to immediately be repaired or replaced.

Ladders. Staff should ensure ladders are used for their manufacturer-designed purpose and
rating. Staff should never use the top step or use on unstable surfaces.

Forklifts. This Facility, using powered industrial trucks (e.g., forklifts, platform lifts), should
comply with the safety requirements pertaining to its use and maintenance. Employees should
receive their Forklift Safety Certification prior to operating the forklift.

Loading platforms. All Facility stairways, open-sided floors, and loading docks should contain
perimeter or fall protection devices, per OSHA standards (e.g., a removable guardrail, a
guardrail fence, chains strong enough to withstand the weight of someone sitting on it).

Can crushers. A safety guard or mechanism should be in place over any can crusher opening,
to prevent staff injury.

                                    Equipment maintenance

Clean-up and regular maintenance is important for keeping equipment in good working order.
Refer to the manufacturer’s operation manual for recommended equipment scheduled
maintenance, repair, and/or adjustments. Equipment repairs/maintenance needs should be
reported to the SWM Maintenance supervisor.

                                      Facility Maintenance

The HW Collection Center staff should be responsible for the necessary housekeeping and
maintenance of the Facility. The following maintenance activities will be applicable to this Facility:

Daily: Pick up debris/trash, clean up spills, keep parts clean, clean up after theirself, report repair

Weekly: Document the Weekly Inspection Report of the HW facility. Clean floors, storage rooms
and containment areas; inspect all above-ground storage drums and containment cubes, pick up
the participant drive-thru area;

Quarterly: After each shed cleanout, clean/debug the chemical storage sheds, hose down floors
of the chemical storage sheds, hose down containment areas, pump out the storage shed sump
area, as needed;

Annually: Sweep/clean the customer drive-thru area, pressure-wash the processing areas. Any
completed maintenance activity should be noted on the Weekly Inspection Sheet.

Potential Facility hazards:

    Exposure to or slipping on leaking or spilled material
    Exposure to sharp edged or broken containers
    Injury through lifting or carrying

Safety Equipment / PPE required:

      County issued safety shoes
      Gloves
      Apron
      Safety glasses or splash shield

                                     CHAPTER THIRTY ONE
                                     LOCK OUT / TAG OUT
                Household                               Revised 9/09
                Hazardous    This document establishes minimum performance requirements for
                Waste        the control of unexpected start-up or energization (release of stored
                             energy) of equipment during routine adjustment or maintenance.
Lock-Out / Tag-Out (LOTO) requirements include mandatory staff training for any equipment
that has the potential for unexpected start-up.

                        Regulatory and contractual requirements

LOTO requirements are established in the HW program and state agency contract (Exhibit A,
part B) and in OSHA General Industry Standard 29 CFR 1910.147-150. To review LOTO
definitions, see Attachment A of this SOG.

                             Implementing the LOTO program
Necessary steps
1.   Perform risk assessment to determine which equipment requires a LOTO program.
2.   Formulate necessary LOTO steps and procedures.
3.   Provide staff training on proper LOTO procedures.
4.   Perform LOTO inspections and audits.
5.   Document the completion of the above steps to ensure procedures are followed.

1. Perform risk assessment to determine which equipment requires a LOTO program:
     A designated staff person should be responsible for LOTO program implementation. For
       this Program, the authorized and designated LOTO person is the Director of SWM.
     Determine if hazardous energy sources are present in the Facility.
     Evaluate Facility equipment to determine if it requires a LOTO program.
     Determine if staff will require LOTO training .

2. Formulate necessary LOTO steps and procedures:
     Recognize the means and methods of isolating energy.
     Verify effective energy control.
     Manage energy by the magnitude and type.
     Implement a flexible program specific to this Facility.
     Provide provisions for staff safety when specific work situations arise (e.g.,

3. Provide staff training on proper LOTO procedures:

Training content. LOTO training includes both initial and refresher training. The designated
LOTO person should authorize appropriate staff to receive mandatory training, to include:
     Understanding the energy controls purpose, scope, and procedures used.
     Reviewing changes in equipment practices or processes.
     Encouraging individual responsibility during the LOTO process.
     Ensuring that Facility staff affected by the energy control procedures are instructed
       about the prohibition relating to attempts to restart or reenergize equipment.
     Ensuring that training is not performed by staff utilizing the energy control procedure
       being inspected, but by outside, knowledgeable personnel.
     Staff should view the County H.R. training video, Tag, You’re It – Lock Out/Tag Out.

Affected staff types
Facility staff whose occupation requires equipment operations will be subject to the LOTO
requirements. LOTO training is based on the relationship of the equipment being de-energized
and the degree of knowledge that staff possess with regards to hazardous energy. There are
three types of affected staff:

―Authorized‖ staff are those who perform the actual energy control procedure. They know the
details, how the hazards should be controlled and isolated, and have the proper knowledge and
skills required (e.g., electricians, maintenance engineers, staff with expertise).

―Affected‖ staff are those who normally use the equipment that is undergoing repair. They may
be in the area during equipment LOTO and repair.

―All‖ staff refers to any person near LOTO equipment as they need to understand the
importance of these procedures.

Refresher training; Authorized or affected staff should receive additional training when:
    Their job assignments change.
    New hazards are introduced into the work environment
    Energy control procedures change.
    Inspections reveal deviations from or inadequacies in the energy control procedures.
    Inspections reveal deficiencies in the program or staff knowledge.

4. Perform LOTO inspections and audits
     Assessing procedures and correcting deviations of inadequacies identified during an
     Enforcing compliance and immediately ceasing equipment operations if violations are
     Specific equipment testing procedures are in place to determine the effectiveness of
       LOTO and other energy control devices; see Attachment B of this SOG.

5. Document the completion of the above steps
   The designated LOTO person should provide and maintain documentation of their hazard
   analysis. This should be developed to aid in determining program adequacy and to ensure
   procedures are followed correctly, including:
     Verify and document that all qualified persons have had appropriate LOTO training.
     Review of the LOTO program for compliance on an annual basis.
     Review of injuries related to equipment operations.
     Provide common procedures used for specific equipment, identified by type and location
       used to control hazardous energy (including shutdown).

Document periodic inspections
    Provide evaluation. See Attachment C of this SOG.
    Revise the written LOTO program as required. See Attachment D of this SOG.

Facility exemption. Electrical equipment (electrified with a cord and plug) that is being
serviced is exempt from LOTO requirements if the plug is under direct control of the person
providing the maintenance service. Such person should ensure that the equipment is
unplugged prior to servicing.

                             Attachment A
                      Lock Out / Tag Out Definitions
Authorized service staff: The person who is responsible for LOTO of machines or equipment
in order to perform servicing or maintenance. This staff person should be appointed by the
designated LOTO person.

Designated LOTO person: Specific and designated Facility staff (SWM Director) who is
responsible for implementing the LOTO Program and meeting all requirements therein.

Energized: Connected to an energy source or containing residual or stored energy.

Energy control program: LOTO or energy control procedures that are designed to prevent
unexpected start up or energization of equipment.

Energy isolating device: Energy isolating devices include any mechanical mechanism that
physically prevents, blocks, or isolates energy transmission release. These may include an
on/off switch or:
* Electrical disconnect switch                * Ball Valve Releases
* Line valve                                  * Wheel Valve Covers
* Line block                                  * Blank or Blind Flanges
* Chains                                      * Circuit Breaker Covers
* Manually operated electrical circuit breaker
* Manually operated switch by which the conductors of a circuit can be disconnected from all
*Ungrounded supply conductors (no pole can be operated independently)

Push buttons, selector switches, and other control circuit type devices are not energy isolating

Energy source: Any source capable of emitting energy, including:
Electrical                       Thermal               Vapors/gas
Mechanical                       Gravity      Water pressure/steam
Hydraulic                        Vacuum                Nuclear
Pneumatic/air                    Solar                 Thermal
Chemical                         Wind
Live-dead-live rule: A test for zero energy state where the operator tries to start the
equipment, then shuts it down, then tries to start it again.
Lock-out: The placement of a LOTO device on an energy isolating device (in accordance with
established procedures) to ensure that the energy isolating device and the equipment being
controlled cannot be operated until the LOTO device is removed.

LOTO devices: A device that utilizes a secure means, such as a lock (either key or
combination type), to hold an energy isolating device in the safe position and prevent the
energizing of machines or equipment. LOTO devices should be:
   durable
   standardized by color, shape, or size
   substantial
   identifiable
   secured to prevent accidental removal (e.g., they have to be removed by force)

Qualified person: Staff familiar with construction or the operation of equipment and the
hazards involved. This qualified person has the skills and the techniques to distinguish live
parts from other parts of electric equipment. This person can also determine the nominal
voltage of exposed live parts and can maintain the clearance distances specific for the voltages
on which they should be working.

Servicing and/or maintenance: Workplace activities such as constructing, installing, setting
up, adjusting, inspecting, modifying, and maintaining or servicing machines or equipment.
These activities include lubrication, cleaning, unjamming, and making adjustments or tool
changes, where staff may be exposed to the unexpected energization or start-up of the
equipment or release of hazardous energy.

Tag-out: The placement of a tag on an energy isolating device in accordance with an
established procedure, to indicate that the equipment being tagged out should not be operated
until the tag is removed.

Tags: Energy isolating devices includes items which can be locked out and those which cannot
be locked. When the device cannot be locked out, Facility staff may use tags (not bypass tags),
providing they are:
   legible and understandable by all staff
   able to withstand the work environment
   securely attached to the equipment
   only used when the employer can guarantee staff protection by using the tag-out system
   only used as warning devices and do not evoke a false sense of security.
                                         Attachment B
            Lock-Out/Tag-Out Annual Inspection Form
Ensure Facility staff is able to perform the following functions to ensure energy control
procedures are correctly being followed:

   How to perform a shutdown.

   How to isolate equipment.

   How to apply and remove LOTO devices.

   How to safely release stored energy to ensure a zero-energy state exists.

   Authorized staff performing the LOTO inspection certifying it has been performed:


   Date of inspection: _____________________

   Specific machine or equipment: _____________________________________

   List all applicable Facility staff included in the inspection:









                                   ATTACHMENT C
Lock-Out/Tag-Out Procedure Compliance Checklist
1. Is all machinery or equipment capable of movement required to be de-energized or disengaged,
   blocked, and locked-out during cleaning, servicing, adjusting or set-up operations?

2. If disconnecting the power does not also isolate the electrical control circuit
      Are the appropriate electrical enclosures identified?
      Are means provided to assure control of the circuit?

3. Are all equipment control handles provided with a means for LOTO?

4. Does the LOTO procedure require that stored energy (mechanical, hydraulic, air, etc.) be
   released or blocked before equipment is locked-out for repairs?

5. Is authorized staff required to keep personal control of their key(s) while safety locks are in use?

6. Is it required that only authorized staff exposed to the hazard place or remove the LOTO

7. Is it required that authorized staff check the safety of the lock-out by attempting a start-up after
   making sure no one is exposed?

8. Is authorized staff instructed to always push the control circuit stop button prior to re-energizing
   the main power switch?

9. Is there a means provided to identify authorized staff working on LOTO equipment by their locks
   or accompanying tags?

10. Are a sufficient number of accident preventive signs or tags and safety padlocks provided for
   any reasonably foreseeable repair emergency?

11. When machine operations require staff to leave the control station, and part of the machine
   could move, is the machine required to be locked or blocked out?

12. In the event equipment cannot be shut down with LOTO, is a safe job procedure established
   and rigidly followed?

                                      ATTACHMENT D
                       The Lock Out / Tag Out Process
1. Preliminary steps
     Only authorized staff responsible for controlling hazardous energy should ensure that procedures
   are followed for the safe operation of equipment. Unauthorized staff should never attempt to start up
   a piece of equipment that has been properly LOTO. LOTO should occur when servicing takes place
   during Facility operations or when any of the following conditions exist:

    If staff must bypass guards or interlocks to perform the repair at the point of operation.

    If staff must place part of their body in contact with the point of operation source or into a danger

  2. Prepare for shutdown
     Staff should obtain assistance when necessary to properly repair or service a piece of equipment.

     Notify appropriate staff that equipment needs repair or adjustment.

     Ensure only authorized staff are performing service or maintenance operations.

     Ensure only authorized staff use appropriate testing devices on the circuits according to the
      voltage level.

     Notify appropriate staff that ―STOP‖ buttons, interlocks, or other devices on equipment are not
      acceptable LOTO devices.

  3. Application of locks and tags
     Equipment not designed to accept locks should be tagged out of service. (This can only be done
      when it can be demonstrated that tagging should provide an equivalent means of safety.)

     Place locks and tags on the equipment used to de-energize circuits on which the work is to be

     Attach a lock to ensure that unauthorized personnel cannot re-open the circuit.

     Place a ―Danger—Do Not Operate‖ tag on the energy source and/or control panel prior to working
      on the equipment. The tag should state that unauthorized use is forbidden and that the tag cannot
      be removed.

     Only the person who applied the lock(s) and tag(s) may remove LOTO devices. The only instance
      in which a LOTO device may be removed is when staff is not at work to remove it and the
      ―qualified person‖ contacts the staff to receive permission that it is acceptable to remove their
      LOTO device.

 Isolating circuits
   Shut down of the equipment or circuitry ensures de-energization prior to servicing, or when the
    potential for unexpected release of energy exists.

   When LOTO is implemented, shut down, isolate, block, and secure equipment.

   Equivalent means of safety may include removal of an isolating circuit element, opening of an
    extra disconnecting device, or blocking a controlling switch.

   All LOTO devices should be left in place while equipment is being repaired or adjusted.

   Stored non-electrical energy that could re-energize the electrical circuits should be blocked or
    relieved to the extent possible.

   Verify isolation by testing the equipment.

   Ensure safe positioning of Facility staff and make them aware of equipment or areas requiring

   Perform test procedures to verify that equipment that is back fed or has induced voltages has
    indeed been de-energized.

   Verify alternate sources of power that could be introduced into the electrical circuit.

   Shut down the equipment or circuitry equipment.

   Prior to working on the equipment, ensure all energy sources are locked out and verify that no
    residual energy exists following LOTO (e.g., live-dead-live rule).

5. Repair, re-energization, and LOTO removal

   Review equipment safety manuals.
   Repair, adjust, replace, or inspect the equipment.
   Do not attempt to restart equipment until it is verified that it is safe to do so following repair.
   Following the servicing, verify all staff are clear of the circuits and equipment when it is re-
   only authorized staff should perform tests and visual inspections to ensure re-energization can
    take place.
   staff who are present at the re-energization should be informed of any hazards and warned again
    to stay clear of the process.
   remove all electrical jumpers, grounds, shorts, and other devices prior to re-energization.
   remove locks and/or tags.
   Re-energize the equipment.
   notify affected staff that equipment servicing and/or maintenance has been completed.

                                   CHAPTER THIRTY TWO
                                    ERGONOMIC SAFETY
                                                       Revised 9/09
                          This Household Hazardous Waste (HHW) Facility should implement
                          an ergonomics program to prevent temporary or permanent staff
injury. This can occur when incorrect or repetitive body motions are performed during normal
operations. This Facility should establish a process for developing task specific guidelines to
assist in recognizing and controlling potential ergonomic hazards.

                         Regulatory and contractual requirements

Ergonomic requirements are established by this Program, under the direction of OSHA 29 CFR
General Duty Clause, Section 5(a)(1).

                             Safety and health requirements

The person designated to ensure that proper ergonomic techniques are implemented for this
HW Program is the Customer Service Supervisor. This person should:
    recognize the potential of ergonomic stressors that could adversely impact Facility staff
      health and safety;
    implement corrective actions to reduce the duration, frequency, and severity of exposure
      to ergonomic stressors (establish controls such as addressing proper work-related
      techniques or provide on the job training);
    ensure staff reporting ergonomic-related symptoms are referred to the nearest medical
      facility for surveillance or treatment; and
    perform worksite analysis or surveys to validate whether efforts to eliminate or reduce
      ergonomic risk factors have been effective to the extent feasible.

Each staff handling HW should participate in safety and health trainings (initial and annual)
offered through the County and HW Facility, or may attend equivalent training courses. All new
staff should receive job specific training in accordance with this Facility’s written training

                                     Worksite analysis

This program should attempt to be aware of common contributing ergonomic-related problems
or conditions at other HHW facilities, as they may also be a concern for this Program.
Ergonomic worksite analysis should emphasize an evaluation of work place practice controls
and operational tasks. These may include the following questions:
    Did this Facility strive to keep the workplace free of hazards?
    Do hazards exist which may cause death or serious physical harm?
    Have potential hazards been recognized?
    Is there a feasible means of abatement for those hazards?
    Is staff reporting ergonomic-related symptoms?
    Does staff ensure proper ergonomic improvements are implemented in their specific
       work area(s)?
    Does staff consistently follow suggested ergonomic improvements?

For further information, refer to:

Review the injury and illness records. If access is available, the designated Program staff
person responsible for maintaining health and safety records should review staff injury and
illness records for potential ergonomic-related problems. These records may include:
      Workers’ compensation claims
      Group health insurance records
      First aid logs
      Absentee and turnover records
      Records of staff complaints or grievances
      First report of injury / OSHA 300 log

Identify potential musculoskeletal disorders. After review of the above information sources,
identify entries that may indicate the presence of musculoskeletal disorders (MSDs). While
there is no single diagnosis for MSDs, the conditions identified below are commonly included in
the range of conditions that potentially constitute an MSD:
     tendonitis
     tenosynovitis
     epicondylitis
     carpal tunnel syndrome
     bursitis
     deQuervain’s disease
     ganglion cyst
     thoracic outlet syndrome
     sprains, strains, or tears
     pain

Categorize hazards. Once recognized, categorize the MSD cases as related to work tasks to
pinpoint where patterns or trends exist.

Seek staff input. Request information from staff about the existence of ergonomic problems
related to particular jobs or tasks. This will be accomplished by:
     speaking with staff
     conducting symptom surveys
     providing staff with questionnaires
     ensuring effective housekeeping to minimize the potential for slips, trips, and falls

                          Hazard control recommendation plan

If ergonomic hazards are identified, draft a written hazard control plan and update it as needed,
      descriptions of specific jobs
      details of all potential hazards associated with the job task; see Attachment A of this
      possible approaches to controlling the hazard
      descriptions highlighting the effectiveness of each control approach

                                              Attachment A
           Ergonomic-related Hazards and Controls
The following is a list of HHW tasks, potential ergonomic hazards, and possible control
methods. Note: not all hazards have been identified. Some solutions may work for multiple
situations, but may not always work for each task or individual.
                                 Receiving and unloading containers from vehicles

     Issues                                                       Prevention

Lifting,                  Slide waste load toward edge of                        Rotate staff to reduce time spent lifting
                          tailgate/trunk, closer to body                          Request assistance for large or
                         Use proper lifting technique                             awkward loads
twisting, or              Do not twist with the load, move their                 Use a hook to slide containers toward
carrying                  feet                                                     the back of trunks or truck beds
                         Reduce the size of the load                             Use a two-wheel cart
waste loads
                         Have cart located near the vehicle to                   Use back belts
                          reduce carrying distance                                Have the participant unload their own
                         Utilize top cart shelf to avoid                          vehicle
                          physically lowering the load                            Ensure adequate numbers of staff are
                         Take frequent breaks                                     available

     Issues                                                       Prevention

Standing,                Elevate receiving container                              Rotate staff and tasks
                         Anti-fatigue, anti-static, or rubber mats                Smaller, shorter/lower gaylord height
trips, twisting,
                         Minimize twisting or sharp movements                     Hook in gaylord to reach containers
or bending
                         Adjust table heights                                     Gaylords with sides that open
                         Platforms or stools                                      Roller or conveyer system
                         Shoe inserts                                             Wrist support
                         Have table and cart at the same height                   Take adequate breaks
                                 Transferring containers to gaylords or lab packing

     Issues                                                       Prevention

Bending,                 Purchase or create gaylords that open                      Restrict time on each task
                          on one side                                                Hook in gaylord to reach containers
                          Hoist or scissor platform (spring) inside
lowering                  the gaylord
waste loads,
or contact

                       Lifting/transferring large objects and car batteries to bins or gaylords

     Issues                                                       Prevention

Lifting loads,           Training on proper lifting techniques                      Forklift to move pallet closer to
                         Elevating battery storage bins                              storage bins (vs. transferring one
repetition,                                                                           battery at a time)
                         Back belts
twisting                                                                             Pneumatic lift or platform
                          Have the participant unload their own
                         Use more people to assist

                                          Lifting 5-gallon containers

     Issues                                                  Prevention

Lifting,           Proper lifting techniques (correct                   Transfer waste into smaller
                    posture, wrist and arm placement)                     containers prior to final bulking
repetition,                                                               procedure
                    Proper lifting device (hoist, pulley,
twisting, or        forklift, platform)                                  Allow someone else to lift the
                   Ensure an adequate number of staff is                 container Auto-siphons
pouring waste
                    available to assist                                  Low profile funnel
                    Have gradual work heights to lift from              Ensure working surfaces are at the
                    floor height                                          same height as the container
                   Tilt can to empty (vs. lift)                          receiving waste
                   Back belts
                                      Opening and bulking paint cans

     Issues                                                  Prevention

Repetition,        Avoid screwdrivers to open containers                Limit number of cans to process
                    Paint can opener, hatchet or vice grip               (open only newer cans for reuse)
                    for opening containers                               Wrist supports
wrist angle,       Switch hands to reduce fatigue                       Loosen lid with hammer
lifting,           Re-engineer design of can openers                    Ship un-bulked in gaylords or lab
                   Reduce work time                                      packs to avoid opening
                   Rotate the job task and shifts                       Can crusher, puncturing device or
stirring, and                                                             pneumatic opener
                   Hire additional staff
long periods                                                             Crown punch or machine to cut
                   Mounted scraper
                                                                          container tops out
of standing

                              Moving Large Containers or 55-gallon Drums

     Issues                                                  Prevention

Repetition,        4-wheel cart or 4-wheel base                         Drum-righter tool
                   Secure the load                                      Back belts
                   Forklift with drum grabbers                          Use additional staff while moving
bending                                                                   containers on ramps
                   Move containers on smooth, flat
                    surfaces vs. gravel                                  Drum dolly (use two staff to tip)

     Issues                                                  Prevention

Neck strain        Take breaks and limit the amount of use              Change cartridge type from dual to
                     / time                                               chemical cartridge with a pre-filter

                               CHAPTER THIRTY THREE
                              OSHA: HEALTH AND SAFETY
                Household                               Revised 9/09
                Hazardous   If there is potential for hazards during the course of normal job
                Waste       responsibilities, this Household Hazardous Waste (HHW) Program
                            should make detailed efforts to provide a safe and healthy
workplace. Because not all hazards can be foreseen, this Program should look for and abate
hazards, even if the Occupational Safety and Health Administration (OSHA) has not created
specific standards to cover them.

                        Regulatory and contractual requirements

OSHA requirements and procedures are established in this HHW program, Florida Statutes
(F.S.) Section 284.50, 29 CFR 1910, 1910.151, 1910.120 (q), and 1904. Florida has adopted
and incorporated portions of Title 40 CFR, Parts 260-270 and 273, and 284.50 into its Florida
Administrative Code (F.A.C.), Chapter 62-730.

                                   Hazard communication

Establishing a safety and health policy

The designated Program staff member responsible for OSHA compliance (e.g., site safety and
health) is the Division Director. This person should enforce OSHA standards, rules, or policies
as they relate to staff actions and conduct. There may be fines or citations for failing to comply
with OSHA regulations.

The person responsible for OSHA compliance should ensure work-related hazards and controls
are communicated to all staff working on behalf of the Program. This person should ensure that
safe engineering controls and equipment are used on site. This Program should develop a site-
specific safety and health policy which should:
     be measured, maintained, and reviewed annually
     provide detailed safety information that establishes a commitment to protection of health
        (e.g., function-specific training, safety information, regulatory updates, education)
     identify, analyze, and demonstrate control on new or existing hazards, conditions, and
     ensure proper management procedures are followed
     ensure staff obtains adequate preparation for safety incidents
     include emergency procedures relevant to job duties (e.g., recognition of hazards in the
        workplace, suggests approaches or options for solving a safety and health problem,
        identifies assistance sources)

A Right-to-Know written program should be implemented for staff potentially exposed to
hazardous substances, harmful physical agents, or infectious agents; see the attached SOGs
on Hazardous Waste Training, Employee Right to Know (RTK) Program, Ergonomic Safety,
and the Medical Monitoring Program.

The purpose of hazard communication standards is to:
    ensure evaluation of all hazards associated with chemicals in the workplace
    inform staff of potential hazards so protection can be obtained prior to exposure
    provide instant access to chemical hazard information

The OSHA Recordkeeping Rule has requirements for work-related injury, illness, and hearing
impacts, which should be documented or recorded. New staff should be informed of the:
    existence, location, and availability of any medical or exposure records
    person responsible for maintaining records
    right of access to records

Accurate assessment of PPE is based on hazards in the workplace and staff compliance. PPE
should be provided at no cost, and staff should be properly trained on its use.

An Exposure Control Plan is necessary if staff is responsible for rendering first aid, CPR, or if
contact with blood or other potentially infections materials can occur as a result of job duties. All
staff should follow the procedures as set forth in Chapter 6: Bloodborne Pathogens.

Safe clearances for equipment (e.g., forklifts) should be maintained in Facility aisles, loading
docks or doorways.

Lock-out-tag-out (LOTO) controls the unexpected start-up of equipment which could potentially
cause injury.

As part of this Facility’s Emergency Contingency Plan, this Program should:
    designate a procedure for safe and orderly emergency evacuations
    list lead roles and specific staff responsibilities
    outline fire and emergency response procedures
    train for incident prevention (e.g., fire alarms, fire extinguishing methods and use).

Since this Facility may be presented with asbestos, a written plan should address an incident
response procedure; see Chapter 26: Managing Asbestos Wastes.

Health and safety policy goals

   1) Staff involvement and accountability: Assign responsibility to staff while holding
      supervisors accountable for their role.

   2) Promote safety: Keep staff safe by enforcing disciplinary actions for unsafe acts. Include
      safety issues in performance evaluations and assess safety efforts as performance

   3) Proactively identify and document hazards: Perform a workplace analysis to identify
      hazards through baseline surveys or self-inspections. Notify supervisors about
      hazardous conditions and investigate ―near-miss‖ incidents. Look for trends when
      analyzing injury or illness records. If a hazard is identified, take immediate steps to
      correct it.

   4) Hazard prevention and control: Administrative controls lead to safer work practices (e.g.,
      following established SOGs, preventing violence in the workplace through improving
      customer service). Staff should utilize engineering techniques and proper PPE use to
      ensure hazards are minimized or eliminated.

   5) Training: Ensure all staff understands the hazards of their job, how to prevent harm and
      recognize individual responsibility. Ask three questions to ensure qualified trainers meet
      OSHA standards:

       Did they train? Deliver pertinent information.
       Did they test? Ensure staff retains the knowledge or skill (test or quiz).
       Did they document? Class certificates listing trainer name, date, and key elements

   6) Evaluate: Routinely evaluate Program health and safety training and procedures.

                                  General duty clause

Meeting the OSHA general duty requirement means to ―generally‖ provide a safe workplace
and identify and minimize or eliminate hazards. These areas and hazards may include:

       Processing, receiving, storing, and shipping wastes – equipment, job planning,
        process flow, materials handling, storage methods
       Facility and surrounding area – floors, protection from the sun, exits, walkways,
        driveways, aisles
       Housekeeping – waste disposal, timely management of incoming materials, tools,
        leaks and spills, cleaning methods, mobile collection event areas, waste storage
        areas, clutter free
       Electricity – equipment, switches, breakers, junctions, tools, motors, grounding,
        protection in wet areas, ground fault interrupters (GFI)
       Lighting, HVAC – explosion proof (in waste bulking area or if required by local fire
       Chemicals – handling, storage, spills, toxicology, warning signs, PPE
       Fire prevention – extinguishers, alarms, no-smoking rules, exits, separation from
        flammable materials
       Maintenance – effectiveness, records management, LOTO
       PPE – types, sizes, storage, rules of use, method of assignment

                                 OSHA-cited violations

The following list consist of the most common OSHA violations which apply to HHW Facilities
(cited in order from most to least):

         Hazard communication, written
         Hazard communication, training
         Fall protection
         Control of hazardous energy
         Respiratory protection program
         PPE
         Bloodborne pathogens
         Fall protection training
         Portable fire extinguishers

                                    Attachment A
                               Health and Safety Resources
Bomb Squad
If necessary, the Emergency Coordinator should call 911. They will dispatch the bomb squad.

Hazardous Material Spill
For Emergencies: releases, spills, chemicals, radioactive materials, bomb/explosives, etc. When
necessary, the Emergency Coordinator should call 911. Dispatchers will notify the County Haz-Mat

Florida Department of Health, Division of Emergency Medical Operations
Diseases, radioactive wastes, meth labs, etc.  (850) 245-4440

OSHA – Tampa area office of the U.S. Department of Labor (OSHA)
                                             (813) 626-1177

Florida Pollution Prevention (P2) Agency                 (850) 245-2118

Florida DEP HHW Program

Chemical/MSDS Resources                                      MSDS for common household products   MSDS (Cornell Univiversity) access to other sites                    chemical backgrounders – National Safety Council             ATSDR ToxProfiles 2003 (CD ROM, call 888-422-8737)                     National Library of Medicine                   National Toxicology Program – Report on Carcinogens                               Oregon State University – pesticide information                        Household products database

Publication requests:
Pocket guide (97-140) – CD ROM (2004-103)

OSHA (Federal)            
      ―C‖ Chemical Reactivity Safety
      ―E‖ Emergency Preparedness
      ―E‖ Evacuation Plan & Preparedness (eTool)
      ―E‖ eTools, to Expert Advisor to ―e-HASP‖
      CPL 02-02-071 Hazardous Waste Site Compliance directive

                ATTACHMENT B - HHW Weekly Inspection Report

For the Week Beginning: ___________________________________________

Inspected By: ____________________________________________________
                                                                 Yes   No    Comments
1. Bulk, Waste Storage in Drums:
          a. Storage Drums Free from Dents, Leaks, Damage?
          b. Appropriate Label(s) and Names Visible?
          c. Lids and Bungs secured in Place when not used?
          d. Empty Drums Stored in Proper Location?
          e. Satellite Drums Covered at end of day?
           f. Satellite Drums in secondary containment?
           g. Hazardous Waste Labels applied when full?
           h. Accumulation Dates on Satellites when full?
           i. Number of 55-gal. Steel Drums in inventory?                    Steel Drums
           j. Number of 55-gal. Poly Drums in inventory?                     Poly Drums
           k. Number of clean, 5 gal. Buckets in inventory?                 Poly Buckets

2. Solvent-based Storage in Cubic Yard Containers:
          a. Boxes free from leaks, breakage or damage?
          b.   All paints, tars and adhesives properly stored?
          c. Appropriate Labels and Names visible?
          d. Hazardous Waste Labels w/ Start Date?

3. Chemical Lockers:
          a. Lockers free from leaks, breakage or damage?
          b. Chemicals properly categorized & stored?
          c. Shelf padding/absorbents in good condition?
          d. Fans and lights in proper working order?
          e. Floors and shelves free from dirt & debris?
          f. Satellite Drums with proper Labels & Names?

                                    CONTINUED ON BACK

                             HHW Weekly Inspection Report

                                                                 Yes   No   Comments
4. Miscellaneous:

          a. Adequate amount of Stored Padding Absorbents?
          b. Adequate amount of Stored Absorbents?
          c. Adequate amount of Stored Neutralizers?
          d. Adequate number of zip-lock bags available?
          e. Floors & Workspace Clear, Clean, Swept?
          f. Adequate PPE Coveralls, Smocks, Aprons?
          g. Adequate PPE Respirators, Canisters, Masks?
          h. Adequate amount PPE Gloves, Sleeves, Boots?
          i. Are PPE properly cleaned & stored safely?
          j. All Spills, Leaks and Absorbents cleaned up?
          k. All secondary containment drains/pipes closed?
          l. Unused tools, wrenches put in their proper place?
          m. Fire Extinguishers gauges reading OK? (due 8/10)
          n. Paint Consolation Area / Equipment Clean?
          o. Adequate cleaning supplies & Simple Green on hand
          o. Weekly operation check of the Passport analyzer
          p. Right to Know (RTK) Manual & MSDS updated

Comments or Repairs Needed:








                                   CHAPTER THIRTY FOUR
                                    CESQG HAZARDOUS
                                   WASTE MANAGEMENT
               Waste                                   Revised 11/09

The following is taken from the Florida Department of Environmental Protection website,
QGs.pdf and is used as a benchmark for determining whether a business qualifies as a CESQG,
for inspection purposes. If it does, this HW Collection Facility is permitted to accept their
CESQG waste.

               Florida Department of Environmental Protection

Many businesses, both large and small, use hazardous materials in their processes. Many of
these processes produce wastes. A portion of these wastes are considered hazardous. The
method a business manager employs to manage hazardous waste will have a direct influence
on business profits and future liabilities for the property, the business, and its owners.

The purpose of this chapter is to provide basic information regarding industrial and public
agencies that may be generators of small quantities of hazardous waste.


All generators of waste materials are required by law to identify and evaluate their waste.
Evaluating waste streams means determining whether or not the waste is hazardous. Evaluate
each waste they produce using Step 1, below to determine whether they are a generator.

Step 1: Evaluate their waste
First, inventory and assemble information about their waste. An inventory consists of identifying
all wastes that the business discards including sewered and recycled waste, unusable products,
and by-products. Material Safety Data Sheets (MSDSs) for the raw materials can be used to
help identify their waste. A Trade Association may also be a good source of information. They
can provide assistance for evaluating their wastes as well as assistance in handling, packaging
and labeling their waste. If they have no information about their waste, it may be necessary to
have the waste analyzed by a laboratory. To determine whether their waste is hazardous,
answer the following questions for each waste on their inventory.

1. Is the waste exempt from regulation? (i.e., recycled used oil, lead acid batteries that are
reclaimed, domestic sewage, permitted industrial discharges; see Table 1)
2. Is the waste listed as a hazardous waste? (i.e., spent halogenated and certain non-
halogenated solvents; Table 2)
3. Is the waste hazardous because it exhibits a hazardous characteristic? (ignitable, corrosive,
reactive, toxic; see Table 3)

If the waste is not exempt in question 1 and they answered yes to questions 2 or 3 for any
waste produced, then their business is a generator of hazardous waste.

Step 2: Determine Generator Size
The amount of all hazardous waste generated or accumulated at their business will determine
which category they fit in; see Table 4. Each category has its own requirements for waste
management. If they generate less than 100 kg (220 lbs.) in any one month of hazardous waste
and no more than 1kg (2.2 lbs.) of acutely hazardous waste in any one month, they are a
conditionally exempt small quantity generator (CESQG) and the RCRA hazardous waste
regulations require them to:

    Determine whether the generated wastes are regulated as hazardous waste under
     RCRA law (see Steps 1 & 2).
    Keep the amount of hazardous waste they generate in any one month less than 220
     pounds or under 2.2 pounds for an acute hazardous waste (i.e., arsenic and cyanide
     compounds) in one month.
    Keep the amount of hazardous waste they have accumulated on their site less than
     2,200 pounds.
    Dispose of their waste only at a site that is approved by the Florida Department of
     Environmental Protection (DEP).

Step 3: Record Keeping
A conditionally exempt small quantity generator (CESQG) that chooses to send its hazardous
waste to an off-site treatment, storage or disposal facility shall document delivery of its
hazardous waste through written receipts and other records, which are retained for at least
three years. The written receipts and other records shall include:

      Name and address of the generator and the treatment, storage or disposal facility,
      Type hazardous waste delivered,
      Amount of hazardous waste delivered, and the
      Date of shipment.

                            Acceptance of Waste from a CESQG

When a business attempts to bring hazardous waste into this facility, staff members must first
determine the volume status and classification of that business. Generator status is based on
the amount of HW generated by that business within a calendar month. There are three status
categories of HW generators:

     less than 100 kilograms2 in any one month (about ½ a 55-gallon drum3) of hazardous waste, or
     they generate less than 1 kilogram of an acute hazardous waste (see P-list4), and
     they never accumulate more than 1,000 kilograms (2,200 lb.) of hazardous waste at any time.

     more than 100 kilograms but less than 1,000 kilograms in any one month (about ½ to 5 -55 gallon
      drums) of hazardous waste.
     ship stored waste within 180 days after the waste was first put into the container, and
     they never accumulate more than 6,000 kg (13,200 lb.)

     more than 1,000 kilograms in any one month (about 5 -55 gallon drums) of hazardous waste, or
     they generate 1 kilogram or more of an acute hazardous waste in any one month, and they must
     ship stored waste within 90 days after the waste was first put into the container unless storage
       facility permit is obtained.

The Citrus County Hazardous Waste Collection Program is identified as a CESQG generator
and is licensed through the Florida DEP. This Facility is licensed to accept only Citrus County-
generated household hazardous waste and/or CESQG hazardous waste.

This facility will not accept hazardous wastes which are generated from any other Citrus County
governmental agencies, unless the volume and category of the hazardous waste being
generated qualifies such department or agency as a CESQG.

Generator HW Identification Numbers
Both Small Quantity Generator and Large Quantity Generator hazardous waste programs are
required to obtain a HW Identification Number from the Florida DEP (formally called an EPA ID
Number). Once licensed, that business will be required to provide HW generation information
for their annual license renewals and fees. For additional information on the Small Quantity
Generator requirements, refer to the following, in-house reference manual:

Revised January 26, 2007

                       Florida Department of Environmental Protection
                       Hazardous Waste Management Section, MS4555
                       2600 Blair Stone Road
                       Tallahassee, Florida 32399-2400
                       Phone: (850) 245-8707

            EPA Hazardous Waste Tables and Codes

    Domestic sewage;
    Irrigation waters or industrial discharges permitted under the Federal Water Pollution Control Act;
    Certain nuclear material as defined by the Atomic Energy Act;
    Household wastes, including hazardous waste;
    Certain mining wastes;
    Agricultural wastes, excluding some pesticides;
    Used oil filters that have been properly drained and recycled;
    Recycled used oil and lead acid batteries that are reclaimed;
    Universal Wastes (hazardous waste batteries, pesticides and mercury thermostats) managed
     under 40 CFR, Part 273;
    Mercury containing lamps and devices destined for recycling (Chapter 62-737, F.A.C.)


    Ignitability-D001: a liquid waste having an alcohol content greater than or equal to 24% or has a
     flash point of less than 140o F. Examples are solvents and paint thinners;
    Oxidizer-D001: wastes that add oxygen to a fire. Oxidizing substances often have ―per‖ as the
     beginning of the name, ―oxide‖ as the ending of the name, or ―ate‖ in its chemical name.
     Examples are ammonium nitrate, perchlorates, and peroxides;
    Corrosivity-D002: a liquid waste material having a pH of less than 2.0 or greater than 12.5.
     Examples are acids and caustics;

    Reactivity-D003: waste materials that react to water, shock, heat, and pressure, and undergo a
     rapid or violent chemical reaction. Some examples are explosives and cyanides wastes;
    Toxicity-D004-D043: waste which release toxic metals, pesticides or volatile organic chemicals
     above certain limits under acidic conditions. Includes 8 heavy metals and 31 organic chemicals
     including 10 pesticides. Wastes in this category need only contain small amounts of mercury,
     arsenic, lead, or one of the other heavy metals, or organics such as benzene, trichloroethylene,
     perchloroethylene, methyl ethyl ketone, or one of the ten pesticides.


Hazardous wastes from non-specific sources (40 CFR Part 261.31)
F – Codes:
     F001: spent halogenated solvents used in degreasing such as trichloroethylene, methylene
       chloride, 1,1,1-trichloroethane, and carbon tetrachloride;
     F002: spent halogenated solvents such as those above but not used as degreasers; other
       examples are 1,1,2-trichloro-1,2,2- trifluoroethane and chlorobenzene;
     F003: spent non-halogenated, ignitable-only solvents such as xylene, acetone, methanol, and
       methyl isobutyl ketone;
     F004: spent non-halogenated solvents such as cresols, cresylic acid, and nitrobenzene;
     F005: spent non-halogenated solvents such as toluene, methyl ethyl ketone, carbon disulfide, and
       benzene; Spent solvent mixtures/blends containing 10% before use of F001, F002, F004 and/or
       F005; and, distillation bottoms from recovering solvents; Hazardous waste from specific sources
       such as certain plating bath solutions; wastewater treatment sludge; and, wastes from the heat
       treatment of metals (see K-list); Discarded commercial chemical products, off-specification
       products, containers and/or spill residues (see P and U-lists).
     F006 – F039: other solid wastes that are listed hazardous wastes from non-specific sources
       unless they are excluded under 40 CFR Part 260.20 and 260.22 and listed in appendix IX.

Hazardous wastes from specific sources (40 CFR Part 261.32)
K – Codes:
     Wood Preservation Sludge
     Inorganic Pigments
     Organic Chemicals
     Inorganic Chemicals
     Pesticides
     Explosives
     Petroleum Refining
     Iron and Steel
     Primary Copper, Lead, Zinc, Aluminum
     Ferroalloys and Secondary Lead
     Veterinary Pharmaceuticals
     Ink Formulation
     Coking

P – Codes: Acute Hazardous Waste, discarded commercial chemical products, (40 CFR 261.33,
    listed alphabetically)

U – Codes: Toxic, Non-Acute Hazardous Waste, discarded commercial chemical products, (40 CFR
     261.33, listed alphabetically)


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