Hazardous Waste Compliance Ami Ruffing, CEHS

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Hazardous Waste ComplianceAmi Ruffing, CEHS
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SIU History of Noncompliance

• Resource Conservation Recovery Act (RCRA) passed
  in 1986, phased in for higher education
• First RCRA inspection in 1990
• 40 noncompliance citations
• Temporary closure of basement storeroom
• Criminal negligence
• Resulted in formation of the Center for
  Environmental Health and Safety

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Recent Noncompliance

• Inspection July 6, 2007 by Illinois Environmental
  Protection Agency
• Notice of violation issued August 23
• SIU will respond by October 11 with a compliance
  commitment agreement, including proposed remedies
  
• EPA may accept or reject our remedies and may
  then issue a fine

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Hazardous Waste Observed Noncompliances

• Excess accumulation
• Leaking containers
• Open containers
• Unlabeled containers
• Accumulation for more than 90 days
• No regular inspection of satellite accumulation
  areas

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• No training records
• Outdated emergency plans posted
• Glass containers on the floor, near the sinks,
  and near the edges of counters
• Product mixed with waste
• Equipment cluttering satellite accumulation areas

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• Blocked fire exits
• Waste bottles outside of satellite accumulation
  areas
• ANY unlabeled container is deemed to be
  uncharacterized and unidentified hazardous waste

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What is wrong with these pictures?
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What do we have to do to remedy the
noncompliances?

• Within the next three weeks, we must
• Establish a hazardous waste satellite
  accumulation area in each laboratory that
  produces waste
• Begin inspecting the areas at least monthly
• Keep a written record of these inspections

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How to Establish a Hazardous Waste Satellite
Accumulation Area

• Choose a location for the satellite waste
  accumulation area
• Clearly define the boundaries
• Post the sign
• Put yellow labels on all the bottles
• Put lids on all the bottles!

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What do we have to do to remedy the
noncompliances?

• Within the next three weeks, we must
• Remove anything from the waste area that is not
  waste, including reagents and equipment
• Get ALL glass bottles away from sinks, away from
  the edges of countertops, and off the floor
• Hang up new emergency contingency signs

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What do we have to do to remedy the
noncompliances?

• Monthly inspections of satellite waste
  accumulation areas
• Performed by one person in your lab
• Keep paper copy in a file for the inspector
• Form will be available electronically on our
  website

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What do we have to do to remedy the
noncompliances?

• Within the next three weeks, we must
• Remove excess waste containers from the labs
  (only one waste container for each waste stream)
• Remove all unlabeled containers from the labs
  (20 for each unknown)

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How to Request a Waste Pickup for Identified
Waste

• Put waste in a bottle with a screw-on lid no
  rubber stoppers, no parafilm, no ground glass
  stoppers
• Put a yellow Hazardous Waste label on the
  bottle, listing all the contents
• Get on our website and fill out the chemical
  waste pickup request form
• http//www.cehs.siu.edu/Chemical/chempickup.htm

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How to Request a Pickup for Unknown Waste

• Put the waste in a bottle with a screw-on lid
• Put a yellow Hazardous Waste label on the
  bottle that says Unknown
• Fill out a requisition form put an account
  number on it and get a fiscal officer signature
  http//www.cehs.siu.edu/Requisition.pdf
• Get on the website and fill out a chemical waste
  pickup request
• We will pick up the unknowns and the form

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What do we have to do to remedy the
noncompliances?

• Within the next two months, we must establish a
  training record for every employee who handles
  hazardous chemicals
• Two forms
• Each employees training file should be kept in
  the lab or in the lab supervisors office
• UPDATE ANNUALLY

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What do we have to do to remedy the
noncompliances?

• Within the next three weeks, we must
• unblock all of the lab exits
• make sure that the fire extinguishers are
  accessible
• flush eyewash stations weekly
• store all chemicals properly

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Chemical Storage

• Chemicals should be grouped by hazard category
• Stored at or below eye level
• Stored in a cabinet with a door, or on a shelf
  with a lip, or on a shelf in secondary containment

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General Hazard Category for Chemical Storage

• Liquid inorganic acids
• Liquid organic acids
• Liquid inorganic bases
• Liquid organic bases

• Flammable solvents
• Nonflammable solvents
• Solid organics
• Solid inorganics
• Oxidizers

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• Fire regulations limit the amount of flammable
  liquids that we can store in the lab
• No more than 10 gallons unless the liquids are in
  flame-proof containers or cabinets
• The 10-gallon limit includes waste

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Required Documents

• Chemical hygiene plan
• Chemical waste management guide
• Training records
• Chemical waste satellite accumulation area poster
  
• Chemical waste satellite accumulation area
  inspections monthly
• Emergency plan near door

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Forms Available in the Back

• Chemical waste pickup request form
• Two training forms
• Emergency posters
• Chemical waste satellite accumulation area
  posters
• Chemical waste accumulation inspection forms
• Requisition for unknowns
• General guidelines for satellite accumulation
  areas

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Contact Information

• Ami Ruffing
• aruffing_at_cehs.siu.edu
• Desk phone [phone]
• CEHS Main Phone [phone]
• http//www.cehs.siu.edu