BRIGHAM AND WOMEN’S HOSPITAL
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Transcript BRIGHAM AND WOMEN’S HOSPITAL
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:
http://www.himnrbehs.com/himnrbehs/
TRAINING AGENDA
Regulatory Requirements
Hazardous Waste Definition
Container Requirements
Labeling Requirements
Satellite Accumulation Area
SAA Contact Responsibilities
Waste Removal
MWRA Requirements
Summary
REGULATORY REQUIREMENTS
40 Code of Federal Regulations (CFR) 260-272
310 Code of Massachusetts Regulations (CMR) 30.000
Chemical Waste Management
Emergency Response
Definition of Hazardous Waste
Labeling Requirements
Satellite Accumulation Areas
Training
Emergency Response
Governing Agencies
Environmental Protection Agency (EPA)
Massachusetts Department of Environmental Protection (DEP)
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)
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
REGULATORY
REQUIREMENTS (continued)
Fines are extensive but dependent on
extent of deviation and potential for harm
EXTENT OF DEVIATION FROM REQUIREMENT
POTENTIAL
FOR HARM
MAJOR
MODERATE
MINOR
MAJOR
$22,000 to
$27,500
$16,500 to
$21,999
$12,100 to
$16,499
MODERATE
$8,800 to
$12,099
$5,500 to
$8,799
$3,300 to
$5,499
MINOR
$1,650 to
$3,299
$550 to
$1,649
$110 to
$549
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
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
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
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
LABELING REQUIREMENTS
Chemical Waste must be
labeled with a tag as the
waste is being collected.
Waste tags must:
1. Declare “Hazardous Waste”
2. Have contents listed with
no abbreviations including
chemical abbreviations
3. Have applicable hazards
checked off
4. Dated only when full
LABELING REQUIREMENTS
What specific problems can
you find with this waste
label?
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
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
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
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.asp
Username: 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
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 offsite facility for one of the following
disposal methods:
Fuels blending
Incineration
Landfill
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
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 noninfectious (add 10% bleach)
Dispose of as chemical waste
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
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