Hazardous Materials & Hazardous Waste Training

1. Hazardous Materials & Hazardous Waste Training September 10, 2008 Drug & Laboratory Disposal, Inc. 331 Broad Street Plainwell, MI 49080 Steve Barker, CHMM

2. There are many training requirements with which to comply under various Federal regulations. EPA, DOT & OSHA are the primary agencies that enforce specific training requirements related to management of hazardous waste.

4. Provides a systematic approach to managing hazardous waste EPA – Environmental Protection Agency

5. Regulates hazards during transportation DOT – Department of Transportation

6. OSHA –Occupational Safety and Health Administration Regulates workplace conditions and practices

7. EPA Training Requirements 40 CFR 262.34 (d)(5)(iii)Hazardous waste managementRCRA in 1976

8. Anyone who could cause non-compliance at a facilityAnyone with duties which ensure the facility’s compliance Annual review of written training plan EPA Training Requirements

9. Must include job-specific waste management proceduresMust be completed within 6 months of assignment to the facilityMust have supervision until trainedTraining must be reviewed annually EPA Training Requirements

10. DOT Training Requirements 49 CFR 172.700; 173.1 (b)Hazardous materials transportation

11. Employees who directly affect transportation safetyRepeated at least every 3 yearsChange in rules requires additional training. DOT Training Requirements

12. DOT Training Requirements General awarenessFunction-specific trainingSecurity trainingSafety training

13. Must include test and be kept for 3 yearsTraining completed within 90 days of employment, during which they may not work with hazardous materials unless under supervision of trained and knowledgeable employee DOT Training Requirements

14. OSHA Training Requirements 29 CFR 1910.1200(h)Hazardous chemicals workplace safety

15. Any employee who could be exposed to any physical or health hazardRecognize hazards and protect employees from hazards through proper communicationEstablish a written hazardous communication program OSHA Training Requirements

16. OSHA Training Requirements Must be trained how to work with hazardous chemicals to prevent illnesses, injuries, or deathMust include container management techniques, safe chemical use, proper protective equipment use, and spill response training

17. OSHA Training Requirements Labels on incoming containers of hazardous chemicalsHave MSDS readily accessible for each work shiftFor waste shipment, have containers labeledInitial training and whenever new physical or health hazards are introduced

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20. Step 1: Classification

21. Step 1: Most important; everything hinges on generator knowledge, materials, and processes used. What is it and is it a hazardous materialMust determine the type of hazard and the degree of hazard

22. Step 1: We need to know the physical and chemical properties.-Physical state (liquid, solid, gas)-Flashpoint or boiling point-Will it kill people (toxicological effect)-What does it do to your skin-Is it reactive to air, water, other chemicals-Is it radioactive

23. Step 1: Get information from:MSDSText booksManufacturer’s dataAnalytical results

24. Step 1: 3 ways to become a hazardous material:Meets a hazard class definition from 1 – 8The DOT says so with a “+” entryMiscellaneous class 9

25. Step 1: Hazard class definitions 1 Explosives 2.1 Flammable Gas 2.2 Non-Flammable Gas 2.3 Poisonous Gas 3 Flammable Liquid 4.1 Flammable Solid 4.2 Spontaneously Combustible Material 4.3 Dangerous When Wet Material

26. Step 1: Hazard class definitions 5.1 Oxidizer 5.2 Organic Peroxide 6.1 Poisonous Materials 6.2 Infectious Substance 7 Radioactive Naterial 8 Corrosive Material 9 Misc. Hazardous Material ORM-D Other Regulated Material

27. Step 1: The DOT says so with a “+” entryAbout 50 chemicals from a list of 3000Must be shipped under this classificationExamples: phenol, magnesium arsenate

28. Step 1: Miscellaneous Class 9If it doesn’t meet a hazard class and meets one of the following;It has airplane hazards (Crew safety)It is a hazardous waste (EPA number)Marine pollutantSeparate list by DOTElevated temperature material Molten or hot

29. Step 1: Forbidden materialsMay not legally be offered for transportation or transportedUsually have to meet specific conditions for safety before transportation

30. Step 1: Determine the degree of hazard:PGI indicates greater dangerPGII indicates medium dangerPGIII indicates minor danger

31. Step 1: Indicated by packing group, used in packaging the material Some hazard classes don’t have packing groups. (2, 7)Not safe to over classify. (responders and employees safety)

32. Step 1: Division 3 Packing Groups

33. Step 1: Division 6.1 Packing Groups

34. Step 2: What is the best proper shipping name and waste code?

35. Step 2: A material may meet the defining criteria for more than one hazard class but is assigned to only one hazard class.Lots of chemicals are toxic.

38. Step 2: Select from column 2Be accurateBe specific (technical names, chemical family, end use, n.o.s. use)

39. Step 2: Waste characteristics and waste code numbers-Characteristic D codes-F listed solvents-P & U toxic waste codes-Act 451 industrial liquid codes

40. Characteristic D CodesD001 Ignitable waste codeD002 Corrosive waste codeD003 Reactive waste codeD004 – D011 Toxic heavy metals waste codesD012 – D043 Toxic organic codes

41. F Listed SolventsF001 - Used in degreasing (6 solvents)F002, F003, F004, F005 - Spent Solvents (28 solvents) Examples: methanol, xylene, methylene chloride

42. P & U Toxic Waste CodesCommercial chemical products – pureP codes - acutely toxicU codes – toxicExamples: nickel cyanide, bromoform

43. Act 451 Industrial Liquid CodesAct 451 Part 121 liquid industrial wastesNot EPA waste codesCan be DOT shipping nameExamples: Antifreeze, crankcase oil

44. Act 451 CodesMixed Solvents (Solvent Solutions) 007LPharmaceutical 014LAutomotive Oil 017LCoolants and Water Soluble Oils 019LOther Oil 021LPolychlorinated Biphenyls 026LOther Waste 029LAntifreeze 030LStorm Sewer Cleanouts 031LSanitary Sewer Cleanouts 032LX-Ray/Photo Solutions 033LWater Based Cleaning Solutions 034LGrease Trap Wastes 036L

45. Universal WasteThere are certain hazardous wastes that a business can choose to manage in an alternative manner in place of the more complex hazardous waste regulations.

46. Advantages of Universal Waste Regulations - Waste can be accumulated up to one year - A Hazardous waste manifest is not required - Volume is not included in determining generator status - Less labeling is required

47. Types of Universal Waste - Batteries - Electric Lamps - Electronic components - Mercury-Containing Devices - Pesticides - Pharmaceuticals

48. Electronic Equipment – Computer Monitors & TVsCRT’s (cathode ray tubes) in monitors and TV’s have been tested and show lead levels exceeding the regulatory limit of 5.0 mg/L. Some models also contain barium, chromium, or mercury. Meeting the definition of hazardous waste allows these electronics to be managed as universal waste.

49. Regulated Medical WasteIntended to help employees avoid injuries and disease. Regulated medical waste, n.o.s., 6.2, UN3291, PG IIWaste code possibilities: 029L or N/A

50. Blood borne PathogensUse OSHA’s universal precaution method. Treat all blood as dangerous. -Blood-soaked bandages-Discarded surgical gloves and instruments -Cultures-Hepatitis-Tetanus-HIV