HARVARD INSTITUTES OF HARVARD INSTITUTES OF MEDICINE/NEW RESEARCH MEDICINE/NEW RESEARCH

BUILDINGBUILDING

HAZARDOUS WASTE HAZARDOUS WASTE TRAININGTRAINING

For Laboratory PersonnelFor Laboratory Personnel

ENVIRONMENTAL, HEALTH, & ENVIRONMENTAL, HEALTH, & SAFETY (EH&S) OFFICESAFETY (EH&S) OFFICE

Office information:Office information:617-432-2762 phone617-432-2762 phone

617-432-6186 fax617-432-6186 faxSTAFF:STAFF:

Christopher NealChristopher NealJessica SgrignuoliJessica SgrignuoliDaniel ColasanteDaniel Colasante

WEBPAGE: WEBPAGE:

http://www.himnrbehs.com/himnrbehs/http://www.himnrbehs.com/himnrbehs/

TRAINING AGENDATRAINING AGENDA

Regulatory RequirementsRegulatory Requirements Hazardous Waste DefinitionHazardous Waste Definition Container RequirementsContainer Requirements Labeling RequirementsLabeling Requirements Satellite Accumulation AreaSatellite Accumulation Area SAA Contact ResponsibilitiesSAA Contact Responsibilities Waste RemovalWaste Removal MWRA Requirements MWRA Requirements Summary Summary

REGULATORY REGULATORY REQUIREMENTSREQUIREMENTS

40 Code of Federal Regulations (CFR) 260-27240 Code of Federal Regulations (CFR) 260-272 Chemical Waste ManagementChemical Waste Management Emergency ResponseEmergency Response

310 Code of Massachusetts Regulations (CMR) 310 Code of Massachusetts Regulations (CMR) 30.00030.000

Definition of Hazardous WasteDefinition of Hazardous Waste Labeling RequirementsLabeling Requirements Satellite Accumulation AreasSatellite Accumulation Areas TrainingTraining Emergency ResponseEmergency Response

Governing AgenciesGoverning Agencies Environmental Protection Agency (EPA)Environmental Protection Agency (EPA) Massachusetts Department of Environmental Protection Massachusetts Department of Environmental Protection

(DEP)(DEP)

REGULATORY REGULATORY REQUIREMENTS REQUIREMENTS

(continued)(continued) Resource Conservation and Recovery Act Resource Conservation and Recovery Act

(RCRA)(RCRA) Required to maintain records from generation to Required to maintain records from generation to

disposal (“Cradle to Grave”)disposal (“Cradle to Grave”) Covers collection, storage, transportation, and Covers collection, storage, transportation, and

disposaldisposal EPA has the responsibility for the creation and EPA has the responsibility for the creation and

enforcement of the regulationsenforcement of the regulations Unannounced Inspections:Unannounced Inspections:

Harvard University (EPA Spring 1999)Harvard University (EPA Spring 1999) MGH (EPA May 1998, DEP)MGH (EPA May 1998, DEP) BWH (DEP Summer 1999)BWH (DEP Summer 1999) HIM/NRB BIDMC (DEP November 2005)HIM/NRB BIDMC (DEP November 2005)

REGULATORY REGULATORY REQUIREMENTS REQUIREMENTS

(continued)(continued)

Inspectors consider containers with Inspectors consider containers with the following as hazardous waste:the following as hazardous waste:

Displaying word “Hazardous Waste”Displaying word “Hazardous Waste” Showing signs of agingShowing signs of aging Are rustedAre rusted Are expiredAre expired Are no longer in use by the laboratoryAre no longer in use by the laboratory

REGULATORY REGULATORY REQUIREMENTS REQUIREMENTS

(continued)(continued)

Fines are extensive but dependent on Fines are extensive but dependent on extent of deviation and potential for extent of deviation and potential for harmharm

EXTENT OF DEVIATION FROM REQUIREMENTEXTENT OF DEVIATION FROM REQUIREMENT

MAJORMAJOR MODERATEMODERATE MINORMINOR

MAJORMAJOR $22,000 $22,000 to to $27,500 $27,500

$16,500 to $16,500 to $21,999$21,999

$12,100 $12,100 to to $16,499$16,499

MODERATEMODERATE $8,800 to $8,800 to $12,099$12,099

$5,500 to $5,500 to $8,799$8,799

$3,300 to $3,300 to $5,499$5,499

MINORMINOR $1,650 to $1,650 to $3,299$3,299

$550 to $550 to $1,649$1,649

$110 to $110 to $549$549

POTENTIAL FOR HARM

HAZARDOUS WASTE HAZARDOUS WASTE DEFINITIONDEFINITION

Waste can be divided into five categories:Waste can be divided into five categories: Ignitable Ignitable

– Liquids with a flash point of 140Liquids with a flash point of 140°°F (60F (60°C)°C) or less or less– Solids that may cause fire through friction or the Solids that may cause fire through friction or the

adsorption of moistureadsorption of moisture– Oxidizers: Liquids and SolidsOxidizers: Liquids and Solids

Corrosive Corrosive – Strong acids and bases with a pH less than or equal Strong acids and bases with a pH less than or equal

to 2.0 or greater than or equal to 12.5to 2.0 or greater than or equal to 12.5 Reactive Reactive

– Unstable, reacts violently with water, explosive, or Unstable, reacts violently with water, explosive, or products toxic gases when mixed with water or acidproducts toxic gases when mixed with water or acid

HAZARDOUS WASTE HAZARDOUS WASTE DEFINITION (continued)DEFINITION (continued)

Waste categories (continued):Waste categories (continued): ToxicToxic

– Can leach toxic chemicals as determined by a Can leach toxic chemicals as determined by a special laboratory testspecial laboratory test

– Listed on EPA’s P-listListed on EPA’s P-list Non-Hazardous Non-Hazardous

– Does not meet the definition of the other four Does not meet the definition of the other four categoriescategories

A mixture is hazardous waste if any A mixture is hazardous waste if any part of the mixture is considered part of the mixture is considered hazardous wastehazardous waste

HAZARDOUS WASTE HAZARDOUS WASTE DEFINITION (continued)DEFINITION (continued)

Ways to determine the hazard Ways to determine the hazard category for a chemical: category for a chemical:

See if chemical is listed on:See if chemical is listed on: EPA’s U-List: Hazardous WasteEPA’s U-List: Hazardous Waste EPA’s P-List: Acutely Hazardous WasteEPA’s P-List: Acutely Hazardous Waste

Refer to “Hazards Associated with Commonly Refer to “Hazards Associated with Commonly Collected Chemicals at HIM/NRB”Collected Chemicals at HIM/NRB”

Material Safety Data SheetMaterial Safety Data Sheet NFPA Diamond for ChemicalNFPA Diamond for Chemical Conduct a pH TestConduct a pH Test Call HIM/NRB EH&S Office at 617-432-2762Call HIM/NRB EH&S Office at 617-432-2762

CONTAINER CONTAINER REQUIREMENTSREQUIREMENTS

Hazardous Waste Containers Hazardous Waste Containers MUSTMUST::

Be compatible with waste Be compatible with waste Have original label defacedHave original label defaced Remain sealed when not adding Remain sealed when not adding

wastewaste Stored in secondary containment Stored in secondary containment

binbin Have a completed hazardous Have a completed hazardous

waste labelwaste label Have only one container per Have only one container per

waste streamwaste stream

LABELING REQUIREMENTSLABELING REQUIREMENTS

Chemical Waste must be Chemical Waste must be labeled with a tag as the labeled with a tag as the waste is being collected. waste is being collected. Waste tags must:Waste tags must:

1.1. Declare “Hazardous Declare “Hazardous Waste”Waste”

2.2. Have contents listed with Have contents listed with no abbreviations including no abbreviations including chemical abbreviations chemical abbreviations

3.3. Have applicable hazards Have applicable hazards checked offchecked off

4.4. Dated only when full Dated only when full

LABELING REQUIREMENTSLABELING REQUIREMENTS

What specific problems can you find with this waste label?

SATELLITE SATELLITE ACCUMULATION AREA ACCUMULATION AREA

(SAA)(SAA)

SAAs should be:SAAs should be: In a low traffic areaIn a low traffic area At or near a point of generation of the At or near a point of generation of the

wastewaste Away from sinks and floor drainsAway from sinks and floor drains

NOTE: We recommend placing it in fume hoodNOTE: We recommend placing it in fume hood

SAA (continued)SAA (continued)

SAA Requirements:SAA Requirements: All waste must be in All waste must be in

secondary containmentsecondary containment A red SAA sign with the A red SAA sign with the

SAA contact information SAA contact information on iton it

A telephone in the vicinityA telephone in the vicinity The SAA Must be The SAA Must be

inspected on a weekly inspected on a weekly basis basis

SAA CONTACT SAA CONTACT RESPONSIBILITIESRESPONSIBILITIES

Know the applicable rules and Know the applicable rules and regulations. Refer to the EH&S regulations. Refer to the EH&S web page under Waste Disposal web page under Waste Disposal tab and Fact Sheets tabtab and Fact Sheets tab

Work in the laboratory Work in the laboratory Be familiar with:Be familiar with:

Characteristics of the wasteCharacteristics of the waste The operations generating the The operations generating the

wastewaste Inspect SAA on a weekly basisInspect SAA on a weekly basis

NOTE: REFER TO THE RED SIGN NOTE: REFER TO THE RED SIGN POSTED AT SAA FOR POSTED AT SAA FOR

INSTRUCTIONSINSTRUCTIONS

WASTE REMOVALWASTE REMOVAL

For Full ContainersFor Full Containers Date label when container becomes full, or no longer Date label when container becomes full, or no longer

used by laboratoryused by laboratory Go to Hazardous Waste Work Order Webpage. Here is Go to Hazardous Waste Work Order Webpage. Here is

the information: the information: http://www.himnrbehs.com/himnrbehs/hazwaste.asp Username: EH&S Username: EH&S Password: HazWaste1 Password: HazWaste1

Call 617-432-6184 to request a chemical waste pickup. Call 617-432-6184 to request a chemical waste pickup. Call before noon the day before the pickup.Call before noon the day before the pickup.

Include name, building, room number, quantity of Include name, building, room number, quantity of containers or bottles, and type of waste (ethanol, containers or bottles, and type of waste (ethanol, acetone etc.)acetone etc.)

Waste is picked up on Waste is picked up on Mondays and ThursdaysMondays and Thursdays NOTE: NEVER MARK A CONTAINER UNKNOWNNOTE: NEVER MARK A CONTAINER UNKNOWN

WASTE REMOVAL WASTE REMOVAL (continued)(continued)

Waste from the SAA is transported Waste from the SAA is transported to the Main Accumulation Area to the Main Accumulation Area (MAA) within HIM/NRB(MAA) within HIM/NRB

The hazardous waste The hazardous waste subcontractor picks up the subcontractor picks up the hazardous waste from the MAAhazardous waste from the MAA

The waste is transported to an off-The waste is transported to an off-site facility for one of the following site facility for one of the following disposal methods:disposal methods: Fuels blendingFuels blending IncinerationIncineration LandfillLandfill

WASTE REMOVAL WASTE REMOVAL (continued)(continued)

The waste hauler The waste hauler WILL NOTWILL NOT accept the following:accept the following:

Biohazardous Waste Biohazardous Waste Infectious Waste Infectious Waste Waste packaged in Red Waste packaged in Red

Biohazardous BagsBiohazardous Bags Waste displaying the Waste displaying the

Biohazardous SymbolBiohazardous Symbol Radioactive WasteRadioactive Waste Radioactive and Chemical Radioactive and Chemical

WasteWaste

WASTE REMOVAL WASTE REMOVAL (continued)(continued)

For chemical and radioactive waste:For chemical and radioactive waste: Please contact Harvard University’s Please contact Harvard University’s

Radiation Safety Office at 617-495-Radiation Safety Office at 617-495-2060.2060.

For biological and chemical waste:For biological and chemical waste: Render the biological component non-Render the biological component non-

infectious (add 10% bleach)infectious (add 10% bleach) Dispose of as chemical wasteDispose of as chemical waste

MWRA REQUIREMENTSMWRA REQUIREMENTS The Massachusetts Water Resource Authority The Massachusetts Water Resource Authority

(MWRA) issued the facility a Sewer Use Discharge (MWRA) issued the facility a Sewer Use Discharge Permit to enable the HIM/NRB facility to Permit to enable the HIM/NRB facility to discharge into Boston’s sanitary sewer. discharge into Boston’s sanitary sewer.

In order to ensure compliance with the permit, In order to ensure compliance with the permit, the following are prohibited from being dumped the following are prohibited from being dumped down the drain:down the drain: Volatile Organic Compounds (solvents, formaldehyde, alcohols)Volatile Organic Compounds (solvents, formaldehyde, alcohols) Strong Acids and BasesStrong Acids and Bases Heavy Metals – Mercury-containing materialsHeavy Metals – Mercury-containing materials Oils – Fuel, lubricating, cruelOils – Fuel, lubricating, cruel Waste water with pH lower than 5.5 or higher than 12.0Waste water with pH lower than 5.5 or higher than 12.0

NOTE: NEVER PUT ANY CHEMICALS DOWN THE DRAINNOTE: NEVER PUT ANY CHEMICALS DOWN THE DRAIN

SUMMARY OF TOPICSSUMMARY OF TOPICS

Know the waste in your laboratory’s SAAKnow the waste in your laboratory’s SAA Conduct weekly inspections Conduct weekly inspections Check the labelsCheck the labels Ensure that full containers are dated Ensure that full containers are dated

then removed within three (3) days then removed within three (3) days Ensure that there is only one container Ensure that there is only one container

per waste stream or chemicalper waste stream or chemical Ensure containers remain sealed unless Ensure containers remain sealed unless

adding waste to the containeradding waste to the container