USC EH&S Hazardous Waste Training

1. USC EH&SHazardous Waste Training

2. Hazardous Waste training is an ANNUAL requirement. Please plan to attend this training again within one year of today’s date if you are still working in a lab and may be handling hazardous waste. • Training options: • Training class • Online refresher

3. Training Agenda • Terminology • Why we train? • What is a WASTE? • Selecting a Container • Labeling • Collecting Waste – Compatibility Check • Storing Waste • Inspecting Storage Area • Requesting Waste Removal • Hot Topics/Noncompliance

4. Terminology Cont. • Accumulation Areas- • Labs • Requirements: • Must be near the site of accumulation • Limitations: • 55 gallons (total) of hazardous waste or one (1) quart of P-Listed Waste • P-listed Chemicals- • Acutely Toxic Chemicals • Product • Requirement of Empty bottles- 3x rinse/collect • Contamination Risk

5. Why we train • Safety • EPA Environmental Auditing – Common violations found at Colleges and Universities: 3. Failure to train 2. Improper labeling, unlabeled containers 1. Open containers

6. Define WASTE… • A waste is ANY solid, liquid or contained gaseous material that • is beyond it’s expiration date • OR • is no longer viable for it’s intended purpose and is to be discarded.

7. Types of Hazardous Waste • Listed Hazardous Wastes • F-listed – non-specific source wastes • Example – Spent Acetone • K-listed – specific-source wastes • P-listed – pesticide, toxic organic and metal wastes • U-listed – organic wastes

8. Types of Hazardous Waste • Characteristic Hazardous Waste • Ignitability (flammable liquids and gases – flashpoint <140°F, oxidizers) • Corrosive (pH  2, acidic, or pH  12.5, basic) • Reactivity (air and water-reactive, produce toxic fumes) • Toxicity (potentially threaten human or wildlife health)

9. Empty Containers • Regulated under 261.7 of the RCRA Regulations • “RCRA Empty” • Waste chemicals removed by normal means (pouring, pumping, aspirating, etc) • No more than 1” of residue at bottom • No more than 3% by weight of the total capacity (0.3% if container > 100 gallons) • Compressed cylinders are not empty until pressure approaches atmospheric • 3x rinse requirement for p-listed chemicals

10. Container Selection • By request, USC Environmental Health and Safety provides HDPE containers for the accumulation of hazardous waste. • Container requests can be made through the Waste Database. • Containers used to store HW must be kept closed unless waste being actively added

11. Container Selection • If you opt to store hazardous waste in a container not provided by USC EH&S, please follow these guidelines: 1. Check MSDS for container/waste compatibility 2. Make certain container is capable of closing and keep it closed except for when waste is added.

12. Labeling Requirements • Must have Federal/State statement…”If found, contact Hazardous Waste Manager at 777-5269, USC Police at 777-9111 or the SC Department of Health and Environmental Control. • PI Name, Phone Number, Building and Room Number • Chemical Identity – NO Trade Names or Chemical Formulas, ONLY Technical Names

13. USC Pre-Printed Labels Belinda Gravel 7-5269 306 Benson Ethanol 35 Tetrahydrofuran 25 Water 40 LEAVE BLANK 10 L 10L Carboy 6.8

14. Waste Collection • Check MSDS for chemical compatibilities • Commingling waste is NOT recommended, however if this is your chosen method 1. Separate Acids from Bases, Organics from Oxidizers and Organics from Acids 2. Test Compatibility in Small Quantities prior to pouring off.

15. Housekeeping • Please ensure that all waste is handled cautiously. • Spills must be cleaned up immediately. • Spill materials that are contaminated with hazardous waste must be handled as hazardous waste. • It is not the responsibility of custodial staff to clean up chemical spills!! .

16. Inspecting Storage Area • Consistently check laboratory hazardous waste storage areas for the following: 1. Containerlabels and their accurate completion, 2. Closed containers, 3. Bulging containers, 4. Cracked containers, 5. Spills and Housekeeping.

17. Maintenance and Modifications in Laboratories • Maintenance – It is the PI and laboratory personnel’s responsibility to ensure that maintenance personnel are working in a safe, chemical free environment. • Modifications in lab • Plumbing • Hood • Other

18. Glove Disposal • If gloves are contaminated with a hazardous waste they must be disposed of as a hazardous waste. • Laboratory personnel should use their best judgment and knowledge of their laboratory processes to determine whether gloves have become contaminated.

19. Cylinder Management Cylinders are a DOT Hazardous Material. Leaking Cylinders must be repaired or replaced immediately. Do not ship any cylinder which is leaking. Hydrogen Sulfide Example USC Cylinder Vendors: National Welders/Airgas, Praxair. Please inventory all of the cylinders in your laboratory (> lecture size) and create a list of those that are not owned by one of the vendors above. Recycling/Reuse Opportunity

20. Shipping HazardousMaterials • The shipment of hazardous materials is heavily regulated. Any person who ships a hazardous material must be trained and certified to do so. • You Must contact Wesley Seigler or other trained EH&S personnel at 777-5269 for chemical shipping information or to initiate a shipment.

21. Shipping, con’t. Due to Dept. of Homeland Security restrictions, the University of South Carolina is prohibited from shipment of the following chemicals: If you need to ship one of the above chemicals please contact EH&S Personnel at 803-777-5269.

22. In Case of Emergency • Campus Emergency Number 777-9111 • EH&S 777-5269 • Fire – is it too big? Proper extinguisher? • Chemical Spill • Is it too big? • Known vs. unknown? • Bodily Injury

23. Logging in to the Waste Database • https://webapps.csg.sc.edu/hwaste/

24. Logging in to the Database • Update personal information if necessary.

25. Requesting Lab Assignment • Click on the “Lab Assignments and Lab Update” in the garnet column on the left of the page. The labs that you are currently associated with will be listed under “Current Assignments”

26. Requesting a lab assignment • Enter the lab that you will be associated with. In the example below Benson 308A was entered.

27. Requesting a Waste Pickup • Click on Hazardous Waste Disposal Requests Update

28. Hot Topics • Old “Crusty, Dusty & Rusty” chemicals • failure to make a waste determination • 40CFR 261.2 (solid waste determination) • 40CFR 262.11 (hazardous waste determination) • Waste Minimization • Do not mix hazardous materials with non-hazardous materials • Broken Fluorescent Bulbs are considered Hazardous Waste and must be handled accordingly!

29. Waste containers were stored under a fume hood. Many containers were not labeled or improperly labeled and open. Incompatible waste were stored together under the hood. Examples of Improperly Stored Hazardous Waste If found by an EPA/SCDHEC inspector the violation would be: Improperly label container Failure to segregate incompatible material Open Containers Release of hazardous material into the environment

30. Consequences of Noncompliance • In accessing a violation, EPA/DHEC considers: • Deviation from Regulation • Potential Harm to Human Health and the Environment • Possible civil enforcement action. • Up to $25,000 per violation per day penalty. • Possible criminal enforcement action. If your Department is sent to enforcement and receives a civil penalty your Department will be responsible for paying the fine.

31. and FINALLY… • Please visit the USC EH&S website @ http://ehs.sc.edu • If you have any questions or need any additional information, please contact Wesley Seigler, CHMM University of South Carolina Hazardous Waste Manager seiglerw@mailbox.sc.edu (803) 777-5269 office (803) 777-5275 fax