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HARVARD INSTITUTES OF MEDICINE/NEW RESEARCH BUILDING

HARVARD INSTITUTES OF MEDICINE/NEW RESEARCH BUILDING. HAZARDOUS WASTE TRAINING For Laboratory Personnel. ENVIRONMENTAL, HEALTH, & SAFETY (EH&S) OFFICE. Office information: 617-432-2762 phone 617-432-6186 fax STAFF: Christopher Neal Jessica Sgrignuoli Daniel Colasante WEBPAGE:

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HARVARD INSTITUTES OF MEDICINE/NEW RESEARCH BUILDING

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  1. HARVARD INSTITUTES OF MEDICINE/NEW RESEARCH BUILDING HAZARDOUS WASTE TRAINING For Laboratory Personnel

  2. ENVIRONMENTAL, HEALTH, & SAFETY (EH&S) OFFICE Office information: 617-432-2762 phone 617-432-6186 fax STAFF: Christopher Neal Jessica Sgrignuoli Daniel Colasante WEBPAGE: http://www.himnrbehs.com/himnrbehs/

  3. TRAINING AGENDA • Regulatory Requirements • Hazardous Waste Definition • Container Requirements • Labeling Requirements • Satellite Accumulation Area • SAA Contact Responsibilities • Waste Removal • MWRA Requirements • Summary

  4. REGULATORY REQUIREMENTS • 40 Code of Federal Regulations (CFR) 260-272 • Chemical Waste Management • Emergency Response • 310 Code of Massachusetts Regulations (CMR) 30.000 • Definition of Hazardous Waste • Labeling Requirements • Satellite Accumulation Areas • Training • Emergency Response • Governing Agencies • Environmental Protection Agency (EPA) • Massachusetts Department of Environmental Protection (DEP)

  5. REGULATORY REQUIREMENTS (continued) • Resource Conservation and Recovery Act (RCRA) • Required to maintain records from generation to disposal (“Cradle to Grave”) • Covers collection, storage, transportation, and disposal • EPA has the responsibility for the creation and enforcement of the regulations • Unannounced Inspections: • Harvard University (EPA Spring 1999) • MGH (EPA May 1998, DEP) • BWH (DEP Summer 1999) • HIM/NRB BIDMC (DEP November 2005)

  6. REGULATORY REQUIREMENTS (continued) • Inspectors consider containers with the following as hazardous waste: • Displaying word “Hazardous Waste” • Showing signs of aging • Are rusted • Are expired • Are no longer in use by the laboratory

  7. REGULATORY REQUIREMENTS (continued) • Fines are extensive but dependent on extent of deviation and potential for harm POTENTIAL FOR HARM

  8. HAZARDOUS WASTE DEFINITION • Waste can be divided into five categories: • Ignitable • Liquids with a flash point of 140°F (60°C) or less • Solids that may cause fire through friction or the adsorption of moisture • Oxidizers: Liquids and Solids • Corrosive • Strong acids and bases with a pH less than or equal to 2.0 or greater than or equal to 12.5 • Reactive • Unstable, reacts violently with water, explosive, or products toxic gases when mixed with water or acid

  9. HAZARDOUS WASTE DEFINITION (continued) • Waste categories (continued): • Toxic • Can leach toxic chemicals as determined by a special laboratory test • Listed on EPA’s P-list • Non-Hazardous • Does not meet the definition of the other four categories • A mixture is hazardous waste if any part of the mixture is considered hazardous waste

  10. HAZARDOUS WASTE DEFINITION (continued) Ways to determine the hazard category for a chemical: • See if chemical is listed on: • EPA’s U-List: Hazardous Waste • EPA’s P-List: Acutely Hazardous Waste • Refer to “Hazards Associated with Commonly Collected Chemicals at HIM/NRB” • Material Safety Data Sheet • NFPA Diamond for Chemical • Conduct a pH Test • Call HIM/NRB EH&S Office at 617-432-2762

  11. CONTAINER REQUIREMENTS Hazardous Waste Containers MUST: • Be compatible with waste • Have original label defaced • Remain sealed when not adding waste • Stored in secondary containment bin • Have a completed hazardous waste label • Have only one container per waste stream

  12. LABELING REQUIREMENTS Chemical Waste must be labeled with a tag as the waste is being collected. Waste tags must: • Declare “Hazardous Waste” • Have contents listed with no abbreviations including chemical abbreviations • Have applicable hazards checked off • Dated only when full

  13. LABELING REQUIREMENTS What specific problems can you find with this waste label?

  14. SATELLITE ACCUMULATION AREA (SAA) • SAAs should be: • In a low traffic area • At or near a point of generation of the waste • Away from sinks and floor drains NOTE: We recommend placing it in fume hood

  15. SAA (continued) SAA Requirements: • All waste must be in secondary containment • A red SAA sign with the SAA contact information on it • A telephone in the vicinity • The SAA Must be inspected on a weekly basis

  16. SAA CONTACT RESPONSIBILITIES • Know the applicable rules and regulations. Refer to the EH&S web page under Waste Disposal tab and Fact Sheets tab • Work in the laboratory • Be familiar with: • Characteristics of the waste • The operations generating the waste • Inspect SAA on a weekly basis NOTE: REFER TO THE RED SIGN POSTED AT SAA FOR INSTRUCTIONS

  17. WASTE REMOVAL For Full Containers • Date label when container becomes full, or no longer used by laboratory • Go to Hazardous Waste Work Order Webpage. Here is the information: http://www.himnrbehs.com/himnrbehs/hazwaste.aspUsername: EH&S Password: HazWaste1 • Call 617-432-6184 to request a chemical waste pickup. Call before noon the day before the pickup. • Include name, building, room number, quantity of containers or bottles, and type of waste (ethanol, acetone etc.) • Waste is picked up on Mondays and Thursdays NOTE: NEVER MARK A CONTAINER UNKNOWN

  18. WASTE REMOVAL (continued) • Waste from the SAA is transported to the Main Accumulation Area (MAA) within HIM/NRB • The hazardous waste subcontractor picks up the hazardous waste from the MAA • The waste is transported to an off-site facility for one of the following disposal methods: • Fuels blending • Incineration • Landfill

  19. WASTE REMOVAL (continued) The waste hauler WILL NOT accept the following: • Biohazardous Waste • Infectious Waste • Waste packaged in Red Biohazardous Bags • Waste displaying the Biohazardous Symbol • Radioactive Waste • Radioactive and Chemical Waste

  20. WASTE REMOVAL (continued) • For chemical and radioactive waste: • Please contact Harvard University’s Radiation Safety Office at 617-495-2060. • For biological and chemical waste: • Render the biological component non-infectious (add 10% bleach) • Dispose of as chemical waste

  21. MWRA REQUIREMENTS • The Massachusetts Water Resource Authority (MWRA) issued the facility a Sewer Use Discharge Permit to enable the HIM/NRB facility to discharge into Boston’s sanitary sewer. • In order to ensure compliance with the permit, the following are prohibited from being dumped down the drain: • Volatile Organic Compounds (solvents, formaldehyde, alcohols) • Strong Acids and Bases • Heavy Metals – Mercury-containing materials • Oils – Fuel, lubricating, cruel • Waste water with pH lower than 5.5 or higher than 12.0 NOTE: NEVER PUT ANY CHEMICALS DOWN THE DRAIN

  22. SUMMARY OF TOPICS • Know the waste in your laboratory’s SAA • Conduct weekly inspections • Check the labels • Ensure that full containers are dated then removed within three (3) days • Ensure that there is only one container per waste stream or chemical • Ensure containers remain sealed unless adding waste to the container

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