oeso environmental programs. in october 2009, duke university participated in an epa voluntary...
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OESO Environmental Programs
In October 2009, Duke University participated in an EPA voluntary multi-media audit of the campus.Numerous teaching and research laboratories,
classrooms, cold rooms, film processing rooms, maintenance areas, boilers, chillers, emergency generators, and etc. were surveyed during these audits.
During the audit, the following violations were During the audit, the following violations were noted:noted:
Wastes not labeled with “waste (name of chemical)” and Wastes not labeled with “waste (name of chemical)” and dateddated
Waste were stored in open containersWaste were stored in open containers Wastes stored without secondary containmentWastes stored without secondary containment Wastes from multiple locations consolidated in one roomWastes from multiple locations consolidated in one room
Laboratory Chemical Waste Practice
Practice covers the following topics: Accumulation of waste chemicals Container Labeling and Marking Container Management Storage of Waste Acutely Hazardous Chemicals Unused, Unopened, or Unknown Chemicals Obsolete Chemicals or Substances Chemical Inventory Sink Disposal of Chemical Substances
Collection of Waste ChemicalsWaste chemicals collected either during the
operation of a process or otherwise accumulated in the laboratory must be placed into containers that are in good condition, compatible with the contents, and able to contain the contents without leaking.
Container Labeling and MarkingContainer Contents
Containers used to collect waste chemicals must be clearly marked with the words “Waste (name of chemical)”
Containers must be marked or labeled at the time waste is first placed in the container (label templates can be found on the OESO EP website)
Container Labeling and MarkingWaste Collection Dates
Containers must have an “open date” listed on the container label, and when full or no longer being filled, a “fill date”.
The “open date” is the earliest date that waste is placed in the container whereas the “fill date” is the date that the container is filled and will no longer be used to accumulate waste.
Container Labeling and MarkingUnused, unwanted, or unopened chemicals that are to be
discarded must be labeled with the words “Waste (name of chemical) and the date that they were determined to be unwanted or unusable.
Small or odd shaped containers that are difficult to place a label on must be placed in a larger sealed container and labeled on the outside. (zip-lock bags, plastic containers, etc.)
Containers holding chemicals that cannot be identified by chemical name, chemical constituents, or process generating the waste must be labeled as “Waste Unknown” with the date that they are considered to be no longer needed.
Unused, Unopened, or Unknown Chemicals
Chemicals identified by the Lab as no longer needed and that are unused, unopened, or unknown must be removed from the laboratory no later than 30 days after being designated as no longer needed.
Container ManagementWaste containers must be compatible with
their contents.Waste containers must be kept closed except Waste containers must be kept closed except
when adding or removing wastes.when adding or removing wastes.Waste containers should be kept clean with
no visible contamination on the outside of the container.
Waste labels and markings must be readable and not defaced.
Container ManagementAreas where waste chemicals are accumulated
must have secondary containment sufficient to collect any incidental spills from container failure.
Waste containers should not be overfilled. Full containers must have at least a 10% headspace to allow for expansion.
Filled waste containers must be stored in a secure area under the control of the operator
Waste containers must be stored for pick up in the room in which they were generated
Container ManagementFilled containers of chemical wastes must
be removed from the laboratory within 90 days of the accumulation start date or the date a chemical becomes a waste. In addition, no more than 50 gallons of chemical waste may be stored in a laboratory at any one time.
Correct labeling and storage of a waste chemicalCorrect labeling and storage of a waste chemical
Container ManagementWastes collected during processes:
Wastes that are collected as part of a continuous process (such as HPLC wastes) must be collected via tubes that are fed through a cap or other container closure to insure that the container is kept closed. This closure must be a positive closing lid. Parrafilm and similar closures will not be acceptable.
Containers used to collect waste chemicals on a frequent, routine basis must be closed when a procedure or experiment has been completed.
EXAMPLE: Containers used to collect acetone washes must be kept closed except when actively adding or removing wastes from the container.
Correct labeling and storage of a HPLC waste chemicalCorrect labeling and storage of a HPLC waste chemical
Acutely Hazardous ChemicalsCommercial chemical products that are
considered “acutely” hazardous when discarded are labeled as “P-List” waste by the US EPA and are subject to additional regulatory requirements.
A list of these chemicals can be found on the Environmental Programs Compliance Webpage.
“P-List” chemicals must be segregated into separate containers, clearly marked with the words “Waste (name of chemical)”, and labeled with the date waste is first placed into that container.
Acutely Hazardous Chemicals• An inventory of the amount (in pounds) of “P-
List” waste accumulated in the laboratory must be maintained by laboratory personnel.
• An example of a Waste Log can be found on the Environmental Programs Compliance Webpage.
• The inventory must be included in the Chemical Waste Pick-Up Request. Laboratories may not accumulate more than 2 pounds or 1 quart of “P-List” waste at any time.
• Note: Empty containers of “P-List” chemicals must also be submitted for pick-up.
Obsolete Chemicals or Substances
An obsolete chemical or substance is a chemical or substance that will no longer be used for its intended purpose or will not be used again and needs to be discarded.
Routine inventory reviews should be conducted to identify any obsolete chemical or substances at least once per quarter.
Any obsolete chemical or substance should be removed from storage, placed into the Laboratory’s chemical waste storage area, and properly labeled and marked
Unknown obsolete chemicals should be handled in the same manner as an unknown or unused chemical discussed in the previous slide.
Chemical InventoryPIs or designated personnel need to develop and
maintain a chemical inventory. The inventory Should be reviewed and updated quarterly
Chemicals identified as expired or no longer needed should be
removed from storage, placed into the Laboratory’s chemical waste storage
area, properly labeled and marked, and removed from the laboratory within 30 days.
Drain DisposalCertain classes of chemicals cannot be poured down the
drain – they must be collected for disposal as hazardous waste. Some of which include:
Any flammable liquids with a flashpoint less then 140oF - including but not limited to any quantity of gasoline, kerosene, naptha, benzene, toluene, xylene, fuel oil, ethers, ketones, aldehydes, chlorates, perchlorates, bromates, carbides, hydrides, and sulfides. This list does not include aqueous solutions of compounds that have a flashpoint greater than 140oF.
Explosive chemicals Mercury and mercury compounds Radioactive materials Photographic used fixer solutions unless they are first passed
through a silver recovery system Rinsate from highly hazardous P-listed wastes or any other chemical
that would be classified as a hazardous waste. Ethidium Bromide buffer solutions at concentrations greater than 10
µg/ml For a complete list see Guidelines For Sink Disposal of Chemical
Substances on OESO EP website for more details
Drain DisposalCertain substances in concentrations above
what is listed below can not be poured down the drain without a permit
Arsenic – 0.003 mg/l Cadmium – 0.003 mg/l Copper – 0.061 mg/l Cyanide – 0.005 mg/l Lead – 0.049 mg/l Nickel – 0.021 mg/l Silver – 0.005 mg/l Total Chromium – 0.050 mg/l Zinc – 0.175 mg/l Ammonia – 25 mg/l
Acceptable Substances for Drain Disposal
Chemicals that can be disposed of down the drain, providing the solution does not contain prohibited materials, include:
Aqueous solutions such as salts or buffer solutions within the pH range of 5.0 to 12.0.
Solutions with a flashpoint greater than 140F (60 C). Chemicals that are water soluble and not hazardous by definition. Acids and bases that have been neutralized to fall within the 5.0
to 12.0 pH range. Biological liquids that have been treated with disinfectant or
autoclaved. Buffer solutions containing less than 10 µg/ml ethidium bromide. Aqueous solutions containing alcohols at a concentration of 24%
by weight or less. Aqueous solutions containing formalin at concentrations less than
10% by weight.
Aerosol Can ManagementAerosol cans may be handled as solid (non-
hazardous) waste if they meet the following criteria:The aerosol products have been used for their intended
purposes so that when holding the cans upright and pressing down on their nozzles, not enough product comes out for them to be useful anymore, and
No more than 3% of the original net content weight remains in the cans, or b) No more than one inch of liquid remains in the bottoms of the cans, and
The cans did not hold chemical formulations with sole active ingredients identified in the F027 (used and unused formulations for wood preserving) or P-list hazardous waste listings.
Aerosol Can ManagementAerosol cans that are not empty or may be
hazardous should be managed according to the Chemical Waste Management Practices.
Aerosol cans that are still in use are not considered a waste. Once the user decides they no longer need the can, the correct disposal path for the can should be made using the criteria listed above.
Emergency Planning and Community Right to Know Act
(EPCRA)Designed to promote the discovery and
mitigation of risks associated with chemical use; and
To provide a data-gathering process to increase awareness of chemical risks in the community.
Also requires that operating areas where hazardous chemicals and substances are present to have, or have access to, MSDSs for all hazardous chemicals used or stored.
Targeted EHS Reporting OnlineTo determine the extent to which EPCRA
applies to your area: Complete online reporting of Targeted Extremely
Hazardous Substances (EHS) Determine the quantity of targeted chemicals present
in your lab and submit report (must answer 5 TSCA question to complete report)
Should be reviewed and updated quarterly OESO will compile the reports to determine reporting
requirements to local, state and federal agencies (Tier II)
Update the report within 30 days of the addition of any hazardous chemicals or substance to your area.
Toxic Substance Control Act (TSCA)
What is it?Enacted in 1976Gave EPA the authority to require reporting,
recordkeeping and testing requirements, and restrictions relating to chemical substances and/or mixtures
Certain substances are generally excluded from TSCA, including, among others, food, drugs, cosmetics and pesticides.
TSCA Compliance at Duke
Unlike hazardous waste handling and most other environmental laws, TSCA compliance activities are focused on specific laboratory operating practices. For this reason, compliance responsibility rests almost entirely with the laboratory.
TSCA Compliance at Duke• If you determine that your lab is not subject
to TSCA, complete the Applicability Form and you are compliant with the regulation.
• If you determine that you are subject to TSCA regulations, you may be subject to import/export, chemical transport, and other facets of the regulation. Please contact OESO at 684-2794 to discuss you lab’s potential issues.
• Once you have determined your TSCA status, a TSCA applicability form must be completed for each laboratory, submitted to OESO, and a copy must be kept in the Lab.
The from must be completed even if you are not subject to the TSCA rules.
Note – Applicability Form must be updated annually
Environmental Programs DivisionBox 3914684-2794