hazardous waste and chemical management glenn magley mkc enterprises, inc. [email protected]...
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Hazardous Waste Management Learning Objectives
The generator of hazardous waste will be able to:
1. Identify hazardous waste
2. Ensure it is properly managed
1.2.
3.4.
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Hazardous Waste Module
State and federal regulations require that employees who produce (generate) hazardous waste must be trained.
This module has been developed to meet this expectation.
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By Katheleen Conti, Boston Globe Staff | April 10, 2005
Chemistry lesson one: Accidents happen, like the recent spill at Exeter High School in New Hampshire, when fumes in a lab class sent three students to the hospital and shut down the school for the day.
Chemistry lesson two: Adding unknowns to the mix -- like improper storage and handling of toxic substances -- can be a formula for disaster.
In January, firefighters responding to an alarm triggered by a chemistry experiment at Pope John XXIII High School in Everett found a jar containing a potentially volatile material that is used to produce rocket fuel. Deemed unstable, the chemical -- 2, 4-dinitrophenol -- was detonated by the State Police Bomb Squad.
Hidden HazardsDangerous chemicals in school labs an explosive situation
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By Tarron Lively, THE WASHINGTON TIMES, Published March 25, 2005
D.C. Public Schools Superintendent Clifford B. Janey issued a protocol yesterday for removing potentially dangerous chemicals from schools, after a series of mercury contaminations and the revelation that a previous removal effort was incomplete. The nine-page protocol lists more than 200 chemicals including mercury, chlorine, chloroform, ether, hexyl alcohol and nicotine. The protocol was issued to the principals of each of the city's roughly 150 public schools. The school system's Hazmat Removal Team, D.C. Fire and Emergency Medical Services and the American Association for the Advancement of Science helped create the protocol and will handle the removal and disposal of the materials. School administrators ordered all potentially hazardous materials removed after an October 2003 mercury spill at Ballou High School in Southeast. The incident closed the building for more than a month, and cleanup cost at least $1 million. A student who was charged in the case had taken the mercury from a science lab. However, investigations into the recent mercury incidents at Cardozo High School and Hardy Middle School revealed that potentially hazardous materials were still inside schools.
Chemicals Ordered Removed
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99% had inherited their inventories 98% had incompatible storage 94% had shock sensitive compounds 85% had inadequate chemical hygiene plans 65% had inadequate functioning fume hoods 30% had explosive chemicals 15% had radioactive materials
They Reported:
Recently In Colorado, 300 schools were inspected.
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The EPA “Reaches Out”
In February 2007, EPA Region 4 launched the Colleges and Universities Compliance Incentive Initiative, encouraging. Region 4 mailed letters to public and private colleges in the southeastern United States to “highlight the opportunity to take advantage of voluntary environmental self-audits” .This provides incentives for schools to voluntarily discover, disclose, and correct non-compliance.Disclosures may receive a partial or complete reduction in financial penalties.
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Summary of Incentives under
EPA’s Audit Policy
Penalty mitigation
No recommendation for criminal prosecution.
No routine requests for audit reports.
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Contact: Sheryl Rosner, EPA Office of Public Affairs, (617) 918-1865
For Immediate Release March 3, 2005; Press Release #sr050301
The U.S. Environmental Protection Agency announced today that it has proposed a $171,050 penalty against Plymouth State University, in Plymouth, NH for violations of hazardous waste laws. ….
Specifically, EPA claims that the University failed to:• make hazardous waste determinations; • properly store hazardous waste; • maintain spill and fire control equipment; • post “no smoking” signs; • post emergency telephone numbers;• keep hazardous waste containers closed; • mark hazardous waste containers with accumulation dates;• conduct inspections of hazardous waste storage areas.
EPA seeks $171,050 from Plymouth State University, Plymouth, NH for Hazardous Waste Violations
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The U.S. Environmental Protection Agency (EPA) has cited the University of Puerto Rico (UPR) in Mayagüez for violating EPA Regulations… and proposed that the university pay nearly $1 million in penalties for these violations. …….
UPR submitted self-disclosures under EPA's Audit Policy … Normally, EPA would grant relief from financial penalties for self- disclosed violations, but it was determined that UPR was not eligible for full relief because UPR was not correcting all its violations. As a result, EPA conducted its own comprehensive inspection .. and found numerous violations.
EPA and the Commonwealth found that UPR failed to operate its facility in a manner that would minimize the risk of releasing hazardous wastes … The containers held wastes ranging from used oil, various acids and spent solvents to formaldehyde. UPR was also storing hundreds of containers of old and expired chemicals, such as picric acid, in an unsafe manner.
EPA Cites Puerto Rico University at Mayaguez for Multiple Violations of Environmental Safety RulesWednesday, October 5, 2005
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What is a Waste?
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EPA describes several ways something becomes a waste:•Discarded•Inherently waste-like (dioxins)•Use constituting disposal•Speculative accumulation•40 CFR Part 261 (www.access.gpo.gov)
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Speculativeaccumulation:pack rats
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Compliance Tips
Helpful Tip #1: How do you tell whether it’s waste?
• Is it in good condition and labeled?• Is it currently legal for use in the
U.S.?• Has anyone used it in the last year
or two? Be honest.• Will anyone use it in the next year
or two? Be brutally honest.
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Compliance Tips
Helpful Tip #2: How old is that bottle?
• Plastic Screw Caps: 1912• Fisher Scientific incorporated: 1926 • ZIP codes: 1963• CAS numbers: 1966
You DO date your bottles, don’t you?
Is it a Hazardous Waste?
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Hazardous Waste Classification
Can be a:SolidLiquidGasSludge
Hazardous waste is a material that no longer has an intended value
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Hazardous Waste Definition
The following categories are not considered hazardous waste:
1. Sewage
2. Regular trash
3. Radioactive waste
4. Biohazard waste
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Determination of Waste Status
The burden of proof to determine if a waste material is defined as “hazardous” is on the generator
May need to analyze the waste to determine its status
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Waste is Hazardous for:
Characteristics:
• Ignitability: Flash Point <140°F (60C): diethyl ether, acetone, magnesium, perchlorates
• Corrosivity: pH <2 or >12.5, 10% solution
• Reactivity: water-reactive, pyrophoric, generates sulfides or cyanides, shock-sensitive: picric acid, white phosphorus, sodium, NaCN, NaS
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Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Benzene
Carbon tetrachloride
Chloroform
Methyl ethyl ketone
Pyridine
Tetrachloroethylene
Trichloroethylene
Vinyl chloride
Plus……
Toxicity:Waste is Hazardous for:
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Beryllium powder Carbon disulfideDieldrin
Vanadium pentoxide
Acetaldehyde
Acrylamide
Creosote
Diethylstilbesterol Formaldehyde
Maleic anhydride
Phenol
Plus…..
Listed wastes:
Waste is Hazardous for:
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Some
hazardous
wastes are
obvious
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Some are not
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How do you tell it’s hazardous?
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Hazardous Waste 101
How do you tell?• Ask the vendor• Use the MSDS Book• Use the MSDS
Online
Hazardous Waste
Examples of hazardous waste:Mercury from a broken thermometerAcetonitrile from HPLC Ethidium bromide Flammable Paints and SolventsWaste isopropyl alcoholAerosolsElectronic circuit boards (lead solder)
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Hazardous Waste Locations
Laboratories and Classrooms
Maintenance Facilities (paint, pesticides, maintenance fluids)
Light Bulbs
Nursing Schools / Health Services
Buildings repurposed from science curriculum
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What do I do once I found it?
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Improper Waste Management
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Separate incompatible material
Label Each Waste Container
Seal each waste container
Keep track of constituents (rough quantities)
Store waste in appropriate locations (cabinets, not in active hoods)
Management of Chemical Waste
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Proper LabelingAll waste containers must be properly labeled.Hazardous Materials Must have the words “Hazardous Waste”“Used Oil”“Universal Waste -- Lamp(s),” or “Waste Lamp(s),” or “Used Lamp(s)", Must include all hazardous components
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Improper Labeling
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Improper Methods of Disposal for Hazardous Waste
Hazardous waste should not be:Placed In regular trashMixed with biohazard waste (red bag or
sharps)Flushed down the drainAllowed to reach surface water (rivers,
lakes) via storm sewer systemAllowed to evaporate (note - open
containers imply evaporation)
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Where did the waste go?
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Satellite Accumulate Area
Satellite accumulate area – is defined as the area (typically a room) where the hazardous waste is generated. Must be designated with signsContainers must remain closed except when adding material.Containers must be marked with the words “Hazardous Waste”.
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Satellite Accumulation Area
Can accumulate up to 55 gallons of hazardous waste or a maximum of one quart of acutely hazardous waste
May need to segregate chemicals and provide secondary containment
Do not date hazardous waste label until the container is moved out of lab
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Reduction of Chemical Waste
Replace reagents with less toxic alternatives (green chemistry)Work in smaller scalesCentralize purchasingBuy only what you need for 1 yearSupervise what is coming into stock
Neutralize acids and bases (not chromic or fuming acid)
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Containers
Contents must be compatible with container material
Problems: Certain solvents
placed in plastic containers
Hydrofluoric acid in glass containers
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Containers
Do not mix incompatibles that will produce: Heat Violent reactions Fire/Explosion Flammable or toxic
gases
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Empty Containers
Empty containers that once held a hazardous material may be placed in the regular trash.
Containers that held acutely toxic materials (selected list from EPA) are considered hazardous waste and may not be placed in regular trash.
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Empty Container Definition
An empty container is defined as: All waste has been
emptied using common practice
Maximum of 1 inch of product remains in container
No more than 3% by weight of the container remains (tanks <110 gallons)
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Examples of Violations
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Summary of Most Common Violations
Waste containers were not marked “Hazardous Waste”
Waste Containers without dates of accumulation
Waste Containers are not closed
Universal waste light bulbs were not being managed properly
Training of employees who handle hazardous waste is not documented
Inspections were not recorded on a weekly basis
Onsite Treatment of wastes is occurring.
Waste material has not been determined as being hazardous
Not all MSDS’s47
Violations
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Violations (cont.)
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Liabilities
Injury to Students / Personnel
Violations can be up to $5,000 each Willful Neglect Repeat Offenses
Violations with Immediate Threat to Human Health or Environment - $25,000 Unreported spills, Dumping, Misrepresentation
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Chemical Management and Handling
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Be certain to label all containers including date of receipt or formulation. Ink should be waterproof and fade resistant.
Must have accurate chemical inventory and MSDS’s accessible throughout school.
Labeling
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Placement of the items on a stockroom shelf should be based upon compatibility--not alphabetical succession.
• Ammonium nitrate + acetic acidmixture will ignite especially if acid is concentrated
• Cupric sulfide + cadmium chlorateexplode on contact
• Sodium + sulfurreaction proceeds with explosive violence
• Sodium cyanide + sulfuric acidrelease of HCN gas, death vigorous reaction, highly exothermic
The Flinn Scientific Catalog has an excellent system to store chemicals based upon their compatibility.
Arrangement
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Improper Arrangement
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Shallow trays (e.g. Rubbermaid) will provide spill protection.
Shelving needs to be secured to a wall or floor.
Shelves with raised lips help to prevent bottles being pushed onto the floor.
Shelving
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Improper Shelving Usage
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Large containers should be avoided by ordering chemicals in the smallest practical size. (The initial cost savings are not worth the disposal costs and liability.)
They should be placed on lower shelves.
Large Containers
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Flammable liquids should be stored in safety cabinets.
Appropriate cabinets for Organic Acids, Inorganic Acids (at least separate trays in cabinet), and Nitric Acid should be used if volumes appropriate.
Bases need to be stored separately.
www.lab-safety.com
Flammables / Acids / Bases Storage
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Acid Cabinet Too Full
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Compressed gas cylinders should be avoided.
If cylinders are in a stockroom they should be secured to a fixed object (e.g. a wall).
Compressed Gasses
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Unsecured Cylinder
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Health and Safety Equipment
Safety showers and Eye Washes (accessible and inspected)Laboratory Fume Hoods (inspected and clear)Personal Protective Equipment (PPE) (used and required in lab, posted)
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Chemicals to Remove
Anything not used last year this year or next year.Reactive ChemicalsHygroscopic (Wet) ChemicalsLow molecular weight organicsStrong OxidizersOlder than 10 yearsPoor packaging (repackage?)Unlabeled / Unknowns
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Should occur often and be recorded.
Looking for material that may be leaking, not properly closed, or out of place.
Annually the shelves should be examined and any chemicals disposed of that will not be used in the next year.
Inspections
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Unacceptable Storage Found in Inspection
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Spilled / Leaking Chemical
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LABORATORY SAFETY INSPECTION CHECKLIST Page 1
This form shall be used as a guideline for performing a laboratory inspection; it is not intended to bring a lab into full compliance. The design of the form is to identify areas that need improvement with respect to regulatory compliance. “Y” answers indicate a satisfactory situation, while “N” indicates an area that needs improvement. These areas can then be prioritized in order of severity. “N/A” indicates a not applicable situation. Building #:________
Room #:______ Date:____________ Time:_______
Principal Investigator:___________________________
Department:__________________________
Survey Conducted By:______________________________________________________________ Y - Satisfactory N - Needs Improvement N/A - Not Applicable
Y N N/A HAZARDOUS MATERIALS
1. DOCUMENT AVAILABILITY
a. Chemical inventory is complete, current and readily accessible to employees at a central location. Location: ______________________________________
b. MSDSs are on file in department and readily accessible to employees. Location:_______________________________________
Laboratory Inspection Sheet
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Helpful ReferencesMIT Environmental Virtual Campus www.c2e2.org/evc/home.html
USEPA Website for Reference http://www.epa.gov/epa
Chemical Safety Information http://wiser.nlm.nih.gov/
www.mkcenterprises.com
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www.mkcenterprises.com
Thank You
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