Hazardous Waste Training Notes
Handling of Hazardous Waste
Lehman College generates chemical, radioactive, and biological wastes. It is important to responsibly manage laboratory wastes to ensure the safety of personnel, and protect facilities and the environment, thereby maintaining compliance with Environmental Protection Agency (EPA) and New York State Regulations.
The purpose of this training is to raise employee awareness of common hazardous waste management issues and current college procedures for the accumulation and removal of hazardous wastes from laboratory and shop areas. Applicable regulations and waste management practices will be briefly discussed in this program. The discussion covers chemical, radiological, and biological waste management procedures. Training will take about thirty minutes.
When is a Waste “waste”
To better understand waste management issues, we must consider some basic terms and conditions. Wastes are materials that are discarded by being abandoned, disposed, or considered inherently waste-like, regardless of recycling, recovery, or reuse considerations. The concept of abandoned and disposed materials is fairly simple.
Common Waste Violations
There are eleven key issues that every generator of hazardous chemical waste must be aware of, and for which citations may be issued.
Inherently Waste like
- “Inherently waste-like” is a term that may include outdated, degraded, or contaminated products or reagents; secondary materials; and materials in deteriorating containers.
- The “waste” decision is made by the lab (generator) when the material is removed from the process, whether that process is storage or use. Although most materials will be discarded as waste, some materials in good condition are suitable for use by others and may be redistributed rather than declared “waste”.
- It is the responsibility of the laboratory or studio to ensure materials are properly managed, including storage, use, and accumulation prior to disposal.
- EPA Regulation requires work areas where hazardous wastes are initially accumulated MUST be under the control of the process operator (generator).
- Laboratory, studios, and chemical storage areas at Lehman College must be under the control of an individual, and not the broad control of a department. Hazardous wastes should be accumulated at or near the point of generation. NO ONE is permitted to accumulate hazardous wastes in areas not under their control.
- Hazardous wastes generated in areas under the control of more than one PI should be maintained separately. This ensures greater accountability for the waste. This also helps minimize the mixing of incompatible materials and may limit the mixing of hazardous with non-hazardous wastes.
- Wastes from adjacent rooms or shops under the control of the same PI may be accumulated in a location central to the group of rooms. Wastes from other floors, or even “down the hall”, may not be brought to this central location even when from the same PI. Any location found to be operating as an accumulation area “not under the control of the process operator” (such as a departmental area) is required to meet several regulatory requirements, including documented weekly inspections, annual hazardous waste training, and contingency planning. Environmental Health and Safety manages Main accumulation areas where wastes are dropped off from various generators.
Safe work area
EPA Regulation requires work areas to minimize the potential for fire or chemical release. This includes management of chemicals, equipment, supplies, and other materials.
What this means is work areas must be maintained in an orderly fashion. From chemical storage to equipment layout, accident prevention is a necessary consideration. Materials should be stored with chemical compatibility in mind. Spills may occur, with the possibility of chemicals coming in contact with each other, resulting in potentially serious chemical reactions. Safety issues related to dispensing materials, attendance of laboratory operations, and maintenance and inspection of equipment all play a part in minimizing the potential for a serious occurrence.
Cluttered work area
One can also be cited if “clutter” is present to the point that it prohibits a safe and accessible work area. This “clutter” may be described as books, papers, dirty glassware, unused experimental apparatus, and other assorted materials.
EPA and OSHA Regulations include requirements that aisle space MUST be sufficient to allow egress and unobstructed movement of emergency personnel and equipment to ANY area where hazardous materials are used or stored. Adequate aisle space reduces the potential for accidents and injuries while working in a lab or shop. Storage of containers in aisles or near points of egress may pose a tripping hazard, or otherwise increased potential for spills.
Emergency personnel are not expected to move heavy equipment, climb over furnishings, or crawl under apparatus in performing their job. This poses an unnecessary risk for personnel wearing chemical protective clothing, and places an undue burden on those carrying fire-fighting or rescue equipment.
- Chemical wastes do not belong in the trash, as this may pose a hazard to personnel and the environment, and poses potential perception issues. Regardless of the legal or regulatory issues, it is difficult, time-consuming, and unnecessarily expensive to identify the “mysterious powders” or other materials placed in the trash.
- Drain disposal of chemical wastes poses similar issues, with potential exposures to maintenance personnel, building occupants, and hazards to the wastewater treatment process. Corrosive materials, flammable or combustible liquids, solvents, heavy metals, toxic chemicals, and biocides MUST NOT be poured down drains.
Waste accumulation involves two levels of containment at the source of generation. In general terms, wastes are removed from a process (storage, reaction, etc.) and transferred to an initial accumulation area. The initial accumulation area consists of a secondary containment device, such as a tray or pan that is intended to contain, at a minimum, any incidental spills that may occur. The waste container is placed in this secondary device for the purpose of waste accumulation, either as a full container or as one that will be receiving waste over a period of time
No Secondary Containment
EPA Regulations require areas where wastes are initially accumulated MUST have secondary containment for the purpose of collecting incidental spills or container leakage. Although required for liquid wastes, it is recommended for solid wastes as well. It is also recommended that all areas where waste materials are stored by the generator have secondary containment.
- Secondary containment is the use of a tray, pan, or other device to contain spills or leaks from a primary container. As such, the capacity should be large enough to contain the full volume of the largest container in the unit. The unit should be sufficiently compatible with the material contained to allow collection of spilled material.
- Most labs use plastic or metal trays or pans for secondary containment. Larger containers, such as drums, should have either a containment sump/skid or a bermed area capable of containing the material. Placement of secondary containment units should take into consideration other safety factors, such as ventilation in fume hoods, possible tripping hazards on floors, or decreased work spaces.
- Exercise care when adding wastes to containers to prevent spillage. Using secondary containment where wastes are first accumulated limits the area of contamination.
- Clean all spills immediately, using appropriate equipment and materials. It may be necessary to use neutralizing agents or decontamination solutions to clean waste containers and secondary containment units. Materials used to clean spills must be managed in accordance with hazardous waste procedures.
- EPA Regulation requires waste containers MUST be in good condition and suitable for their contents, including appropriate closures. University procedures include the following:
- - Liquids are to be in screw-capped bottles or carboys, or in drums with non-removable heads.
- - Solids are to be in large-mouth jars or bottles, sturdy bags, boxes, or drums with removable heads.
- Rusted cans or drums, cracked containers, torn bags, and deformed containers are not considered “in good condition” and should be overpacked or their contents transferred to another container.
Ensure waste containers and their closures are appropriate for their contents. Beverage and other food product containers; flasks or other containers with cork, ground glass, or rubber stoppers; and any snap-cap containers as primary containers are not appropriate for hazardous wastes.
- Parafilm, wax paper, plastic wrap, and foil are not appropriate closures in laboratory accumulation areas or when wastes are offered for disposal.
- Low-boiling or highly volatile liquids, and those that naturally off-gas, may warrant additional controls such as vented closures.
- EPA Regulation requires that all hazardous waste containers MUST be kept securely closed except when adding or removing material.
- Hazardous waste containers must be kept securely closed with appropriate closures such as screw caps, bungs, clamps, etc.
The only types of funnels allowed to remain in a waste container are those specifically designed and maintained to provide a fixed closure that will not leak should the container be tipped over.
- Accumulation containers connected to analytical equipment by drain lines should have a secure closure with positively connected lines.
- Hazardous waste containers should be open only when waste is being added or removed, and MUST be attended while open.
Empty bottles may be allowed to dry in a fume hood when there is minimal residual liquid. It is not acceptable to minimize waste volumes by allowing liquid to evaporate, whether from bottles or solvent-soaked rags.
Label Your Waste
All hazardous waste containers MUST be marked with the words “Hazardous Waste”, and other words that describe the material as “waste” and warn personnel of hazards. OSHA regulations require “hazard communication”, whereby all materials present in the work area are identified, and their hazards made known to employees.
Properly label Waste
Labels MUST be physically on the specific waste containers, and not solely on an accumulation area surface.
Properly label Mixture
It is acceptable to mix compatible wastes in one container such as Non-Halogenated Solvents. Label the container “Hazardous Waste Non-Halogenated Solvents” and keep an itemized list of the exact chemicals mixed in the container and . . .
Unidentified materials constitute a violation of OSHA and/or EPA regulations. EH&S CANNOT accept unknown chemical wastes from laboratory or shop areas.
To properly dispose of unidentified materials, EH&S will schedule testing by waste technicians who will characterize small quantities of waste for disposal at a fee. Quantities greater than 5 gallons may require additional testing, resulting in higher costs, to ensure proper disposal. Gas cylinders must be handled separately, and are generally more costly to identify. The generator will be held accountable identifying unknown.
- EPA Regulation requires waste containers MUST be free of external contamination. Waste containers and secondary containment devices are usually contaminated by incidental spills that occur while adding wastes. Some may also be contaminated by materials while in storage, such as the residues seen where hydrochloric acid or other reagents are stored. Residual contaminants may appear as a film, stain, or “crust” on the container, and are indicative of spills that were not properly cleaned up. Inks that run or “bleed” may also be indicative of waste spills.
- Contaminants may pose an unnecessary risk to personnel coming in contact with the waste containers, whether through continued addition of waste materials, container movement within the laboratory, or collection by waste personnel.