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Hazardous Waste Training

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Hazardous Waste Training

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    1. Hazardous Waste Training Environmental Health & Safety May 2008

    2. EH&S Contact Information Linda Vishino Environmental Compliance Officer vishinol@wustl.edu 935-7864 Donna Hall Environmental Compliance Manager (Danforth Campus) dhall22@wustl.edu 935-4650 Livi Isringhausen Environmental Compliance Manager (Medical School Campus) isringhausenm@wusm.wustl.edu 362-6735

    3. Overview Regulatory Reviews Review of Hazardous Waste Regulations Virtual Tour

    4. Hot Topics – Regulatory Inspections

    5. Hot Topics – Regulatory Inspections

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

    7. Other Potential Inspections Additional Nuclear Regulatory Commission (NRC) inspections Now regulating cyclotron produced materials Increased Controls – security requirements (e.g. fingerprinting) New decommissioning requirements Alcohol Tobacco Firearms (ATF) – alcohol usage in research laboratories EPA return visits Check progress on areas where there were issues Will return for surprise visits every year for next few years Missouri Department of Natural Resouces (MDNR) hazardous waste inspections Other?

    8. Hot Topics – Decommissioning Laboratories or Lab Areas When Faculty, Staff and Students Leave Give EH&S a minimum of two weeks advance notice before initiating any large scale cleanout of chemical containers Greater than 50 containers When faculty, graduate students, post docs or staff leave: Follow EH&S “Closing Laboratories” requirements http://ehs.wustl.edu/new/safetycommittee.htm

    9. Review of Hazardous (Chemical) Waste Regulations EPA’s Emphasis During Recent Inspections

    10. Main issues raised by EPA People saying “That’s not my responsibility” or “I don’t know” (how to manage hazardous waste) Containers missing labels or labels not filled out properly Full waste containers in labs longer than three (3) days Waste containers in labs longer than one (1) year Moving waste containers from one room to another Open containers Multiple full waste containers of the same waste stream Not dating containers with earliest date waste was collected High Performance Liquid Chromatography (HPLC) waste collection container lids with open holes Not having written documentation from EH&S that chemicals are permitted to be sewered

    11. Guidance on EH&S Web Site http://ehs.wustl.edu/hazmats/hazwaste.htm

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

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

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

    15. Hazardous Waste Management Hazardous waste label applied to container Include: Description (no acronyms or abbreviations) Principal Investigator (PI) name and location Start date: MO/DAY/YR Send Request For Pickup to EH&S when filled or <1 year

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

    17. Hazardous Waste Labeling Containers without labels will not be picked up!

    18. Bad Label Examples

    19. Chemical Disposal Request for Pickup (RFP) Chemical RFP Form required by regulation Must be filled out completely Submit electronically: ehs.wustl.edu

    20. Use on-line RFP to request disposal of chemicals

    21. Solid Hazardous Waste Tubes, tips, pipettes, microplates containing trace or residual hazardous chemicals Cannot be placed in regular trash Collect in sealable plastic bags or plastic-lined cardboard boxes Apply hazardous waste label to bag or container and treat as normal hazardous waste Bag or container must be kept sealed at all times Add waste to container inside fume hood to avoid occupational exposure Waste container can be placed in a chemical storage cabinet within the same lab

    22. Problem Hazardous Waste Shock or temperature sensitive materials Old ethers, organic peroxides, dry picric acid or picrates, etc. Air or water reactive compounds Gas cylinders/lecture bottles Poison by inhalation compounds Extremely toxic (LD50<5mg/kg) Mixed waste Chemical & radioactive Must meet both NRC and hazardous waste requirements Biohazard & chemical Contact EH&S immediately

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

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

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

    26. Hazardous Waste Unless you have in writing from WU EH&S that a waste stream is nonhazardous, assume that it is hazardous and needs to be sent through the EH&S hazardous waste collection program http://ehs.wustl.edu/hazmats/hazwaste.htm

    27. Equipment Disposal Hazardous material disposal required for: Refrigerated equipment Computers, monitors, and other circuitry Lamps HID Germicidal Fluorescent Metal halide X-ray or photo film containing silver Non-alkaline batteries Follow labeling, container closure and storage requirements found on EH&S web page

    28. Hazardous Waste Management Everyone in a laboratory, shop, art studio, or location where chemical waste is generated needs to know: How to properly manage the chemical waste What are the hazards of the chemical waste and how to protect themselves from the hazards What to do in the event of spill, release to the environment or exposure EPA will ask lab occupants at random to explain the process

    29. Hazardous Waste Management Penalties for: Hazardous waste label not filled out properly Start date is not on the label Lid is not secure Container is stored longer than one (1) year Notify EH&S through the on-line system to collect the container before the one year deadline passes, even if the container is not full Container is stored longer than three (3) days after the container is filled EH&S must be notified through the on-line system to collect the material the day the container is full To avoid this problem, contact EH&S before the container is full Waste is moved to another area/room Container and/or lid is leaking or damaged Container is stored next to incompatible materials Improper disposal Reminder – departments are responsible for any fines or penalties that are the result of violations in their areas

    30. Hazardous Waste Management EH&S needs a minimum of two weeks notice prior to cleaning out a laboratory or shop Dependent on size and timing of cleanout, outside vendors may be called in to assist at the expense of the department

    31. Chemical Inventories Required Contact EH&S to learn about inventory requirements Environmental Database Specialist 935-9845

    32. End of Hazardous Waste Management Section Questions?

    33. Virtual Tour Both Good and Bad Examples – You Decide

    35. Virtual Tour

    37. Virtual Tour

    38. Virtual Tour

    39. Virtual Tour

    40. Virtual Tour

    41. Virtual Tour

    43. Virtual Tour

    44. Virtual Tour

    45. Virtual Tour

    47. Environmental Health & Safety Phone: 362-6816 Website: www.ehs.wustl.edu Email: esafety@msnotes.edu Fax: 362-1995

    48. Questions?

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