HAZARDOUS WASTE INSPECTIONS Revised July 2013

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1 HAZARDOUS WASTE INSPECTIONS Revised July 2013 EH&S performs inspections to identify, mitigate and correct non-compliance issues related to the management of hazardous materials and waste. Information obtained is used to assist persons responsible for these areas to comply with waste regulations. The inspection forms provide documentation of the use of the room, the presence or absence of hazardous materials and waste, and basic hazardous waste compliance concerns. The Hazardous Waste Assessment form addresses most of the issues that state and federal inspectors look for when inspecting University labs and shops. Appearance or perception issues have some basis in regulatory interpretation and applicability, and may include housekeeping practices and operational indicators such as: General appearance of lab or shop; General appearance and presence of equipment and/or chemicals; Contaminated surfaces, including containers, countertops, and containment systems, are indicative of a release (spill or leak) that has not been cleaned and may therefore pose an unnecessary risk to persons or the environment; Stained sinks are indicative of waste discharges; Residues in buckets, glassware, or other containers may be regarded as wastes, possibly leading to open container and identification issues; and Inherent wastes, such as abandoned materials (e.g., professor leaves and no one assumes immediate responsibility for materials) or old chemicals in deteriorating condition or containers. The following is an explanation of each item reviewed during campus waste inspections. Orderly Work Area Safe and clean work areas are necessary for quality assurance and minimizing exposures, whether in a lab, warehouse, or shop. Good laboratory practices are designed to protect the quality of the research, including reagents and products, and should incorporate waste management procedures. Shops and other non-laboratory areas should have similar procedures in place. Subjective: There is a reasonable amount of clear work space where chemicals are dispensed, handled, and used, including reactions/equipment in fume hoods and initial waste accumulation areas. Combustible materials (e.g., paper, chemicals) are away from electrical outlets, ventilation panels on equipment, etc. Work areas appear to use good housekeeping practices. Corrective actions: Remove excessive clutter (papers, dirty glassware, and assorted junk ) to allow for a safer and more accessible work area. Aisle Space Under EPA regulations, aisle space must be sufficient to allow unobstructed movement of emergency personnel and equipment to any area to contain or control fires or spills. EH&S and OSHA guidelines have established this to be a minimum of approximately 30 inches, with 36 inches required for means of egress (exit doors and hallways). Definitive: Although estimation is acceptable, floor tiles or measuring tools (ruler, yardstick, tape measure) may be used to confirm the recommended 30 inches for aisle space. Consider furniture, movable equipment, gas cylinders, and other obstructions as subject to this rule. Corrective actions: Although 30 inches is the recommended standard, areas cited generally had less than 24 inches of aisle space. Some areas by design cannot meet the aisle space requirements, and may warrant special protective measures. Remove obstructions to ensure aisle space requirements are met.

2 Spills Contaminated surfaces, such as containers, countertops, or containment systems, are indicative of a release (spill or leak) that has not been cleaned and may therefore pose an unnecessary risk to persons or the environment. The simple act of pouring liquids into a funnel may create a splash, resulting in drops of liquid contaminating surfaces. Contaminants are generally considered to expose several thousand people, as they are presumed to be spread from the work area. Spilled materials are often found in secondary containment units, at weighing or dispensing stations, in fume hoods, in storage units (shelves or cabinets) and other areas where materials are handled. Spilled materials are considered by EPA to be waste. As such, the material must be identified and immediately placed in containers. Although stains may be indicative of a spill, residues are of more concern due to the greater potential for spreading contaminants. Definitive: All spills regardless of size must be promptly collected and managed in accordance with waste regulations. Materials must be identified, placed in containers, and not intentionally evaporated. Residues should not be readily removable (discoloration may not be removed as easily as crust or film). Corrective actions: Areas cited had spilled materials and/or removable residues that were not placed in containers. Chemicals and Hazardous Materials EPA includes storage as a process, thereby placing specific emphasis on continuing responsibility for material management. Departments must have provisions for assuming control of materials and wastes resulting from retirement, resignation, or other departure of personnel responsible for material management. Chemicals that are no longer intended for use must be redistributed or disposed. Contaminated or deteriorating reagent bottles raise concern over product quality. Age, shelf life, and storage conditions are factors affecting the quality of the reagent, which in turn affects the quality and safety of research and education. Presence of hazardous materials indicates a potential for waste generation. Processes will generate wastes at some time, which must be accumulated and evaluated for compliance with disposal requirements. EPA considers chemicals that are improperly stored, degraded, or in degraded or contaminated containers to be waste (abandoned by neglect). a. Note the presence of chemicals or other hazardous materials. Hazardous materials of concern include hazardous articles in storage (e.g., fluorescent lamps, capacitors, ballasts, and batteries that are not in use). b. Chemicals and their containers must be appropriately marked or labeled, and both the container and the contents must be in good condition. Broken caps, faded or damaged labels, rusting or deteriorating containers, and outside contamination are examples of containers in unsatisfactory condition. The product name and/or hazard information is required for hazard communication. Materials that have deteriorated may include those that have discolored, solidified (including crystals that become a solid non-dispensable mass), or have otherwise become unsuitable for the intended use. Containers with a film or other residue on the outside, or in poor condition, are indicative of materials being managed as if they have no value, warranting a waste determination. Definitive: Chemical (not just waste) containers and their contents must be managed in a manner that demonstrates they have value. Labels must be legible and specify the name of the material. Containers must be clean and free of outside contamination. Corrective actions: Verify materials are actually needed for the work area. Dispose of materials that are in poor condition or no longer needed. Replace defective caps or closures. Ensure all materials are properly labeled and containers are in good condition.

3 Room Description Wastes must be managed: in the shop or lab where they are generated, or in an adjacent or adjoining lab or shop, which is directly connected to the laboratory or shop of origin, access is easily monitored from the lab or shop, and under the direct control of the same waste generator. Directly connected means the rooms are connected by an interior doorway and wastes do not pass through hallways or other common areas. Discussions with NCDENR indicated that waste could be accumulated in an adjoining room as described, resulting in a one door rule whereby wastes can only pass through one door or doorway. Each situation must be evaluated to ensure waste areas remain visible to personnel and verify the need for storage in the adjacent room. Waste must be under the control of the control of the person who generated the waste. This involves attendance and security issues, and is reflected in the examples of directly connected areas. Attendance (ability to directly observe) is reduced as distance and number of partitions increase, or as access points to the waste storage area increase. The waste area must be under the control of an individual, and not the broad control of a department. NO ONE is permitted to accumulate hazardous wastes in areas not under their control. Safety Plans may be used to identify areas under an individual s control. Central Accumulation is when wastes are placed in a separate location from the shop or lab where they are generated, which is not directly connected or adjacent to the laboratory or shop where the waste was generated, regardless of whether it is under control of the same person. This also includes a satellite accumulation area that exceeds quantity limitations (55 gallons of hazardous waste or 1 quart of acutely hazardous) for more than three days. Because most generators are on the Main and Centennial Campuses, and any other site may become a large quantity generator, central accumulation areas may accumulate waste for only 90 days. Central accumulation is allowed only for EH&S facilities and prohibited for labs and shops. Definitive: Chemicals and wastes appear to be managed in the same room as generated. Corrective actions: Ensure wastes are accumulated in the room where generated. Minimize any transfers of waste between rooms. Select containers of an appropriate size and ensure wastes are submitted for collection as containers are filled. Presence of Waste in Lab/Shop Wastes of concern are chemical, radioactive, and biological wastes, including contaminated debris (e.g., broken glass, sharps, used absorbents, etc.), deteriorated chemicals/containers, chemicals for recycling or reclamation (distillation, treatment) and articles such as used batteries and lamps. This is not intended to involve the normal trash or office recycling. Most wastes are accumulated in fume hoods, in proximity to benches or other work areas, or in chemical storage cabinets. Stained sinks are indicative of potentially improper waste disposal. Beakers, flasks, buckets, and other containers may have material in them. Verify the status of the containers as waste or product. Definitive: Chemicals or containers in poor condition, unidentified materials, containers marked as waste, other containers described as waste or otherwise managed as if their contents had no value are all waste materials. Corrective actions: Determine compliance with waste management rules (remaining topics of inspection).

4 Generator Control Areas inspected must be under the control of the Principal Investigator. Wastes generated in shared spaces (multiple PIs) should be maintained in separate containers. Consider waste may pass through only one doorway from point of generation to point of accumulation or storage. EPA may consider chemicals that are improperly stored, appear to be in poor condition, or in degraded or contaminated containers to be waste (abandoned by neglect). Wastes are initially collected at the process where they are generated, and may be transferred to appropriate containers in an area that can be observed by the person(s) generating the waste. All recycling and reclamation activities must also be conducted in the same room as waste accumulation. Subjective: Waste is accumulated in the lab or shop where generated. Waste does not appear to be coming from another room. Note: Hazardous waste personnel will determine if accumulation of wastes from other rooms is acceptable based on conditions specific to the room. Definitive: Abandoned materials include materials inherited by the PI, such as those left behind by previous researchers (PIs or students) and construction/finishing materials (e.g., paint) after a project is completed. Materials that a PI has determined he has no further use for should be redistributed (typically through the department) or disposed through the waste program. Corrective actions: It must be clear who is responsible for work areas, or where wastes are coming from. Implement appropriate controls to ensure areas and wastes are under control of the Principal Investigator, and wastes are accumulated in the room where generated. Ensure materials present are necessary for the work conducted, and unwanted materials are redistributed or disposed. Waste program personnel will evaluate the area to determine whether the area is subject to rules for satellite or central accumulation areas. Container Selection Containers must be in good condition, physically and chemically compatible with their contents, and fully capable of containing the waste under normal handling conditions. Liquids are accumulated in narrowneck screw-capped bottles, carboys, or drums. Collapsible containers for liquids must be in rigid outer packaging. Solids may be accumulated in wide-mouth screw-capped bottles, sturdy bags, boxes, or drums. Staining of boxes is indicative of a leak (from an inside container) or potential defect (got wet in storage). Corrosives should be in plastic or glass (hydrofluoric acid in plastic only, nitric acid in glass only). Flasks, beakers, and other lab glassware may be used for initial accumulation of waste only while attended (person must be in close proximity to the container, with container in plain view, and not conducting extensive activities that would distract his/her attention from the waste container). These are inappropriate for unattended waste accumulation because they cannot be properly closed or have rounded bottoms (cannot stand without support). Food or beverage containers are not appropriate for use as waste containers. Definitive: Containers must include secure closures and be appropriate for their contents. Beverage containers and containers with cork, rubber, or ground glass stoppers are not appropriate for waste. Corrective actions: Ensure containers and their closures are appropriate, in good condition, and compatible with the chemical and physical properties of the wastes.

5 Closed Containers Containers must be sufficiently closed to minimize leaks, spills, evaporation, or other releases. Definitive: Containers must be closed except when adding or removing waste. Some processes warrant keeping the container open for an extended period, which may be acceptable only if attended (person must be in close proximity to the container, with container in plain view, and not conducting extensive activities that would distract his/her attention from the waste container). Although empty bottles may be allowed to dry, it is not acceptable to minimize wastes by evaporation. Waste containers connected to equipment, such as HPLC s or GC s, must be disconnected and closed or have the drain line securely fitted to the bottle whereby spills will not occur if the collection bottle is tipped over. Any non-contact water condensate line may be isolated and continually drained to a separate container. Funnels with latching covers are acceptable closures only if the lid is latched and the funnel is secured (threaded) to the container. Unacceptable closures for waste containers include stoppers (e.g., ground glass, rubber, or cork), illfitting screw caps, damaged spouts (usually on 5-gal. cans), damaged or stretched gaskets (drums), cracked caps, foil, and parafilm when used by itself or in any combination of the above. Corrective actions: Ensure containers are kept closed with appropriate closures (caps, bungs, etc.), opening them only when adding or removing wastes. Some processes warrant keeping the container open for an extended period, which may be acceptable only if attended (person must be in close proximity to the container, with container in plain view, and not conducting extensive activities that would distract his/her attention from the waste container). Funnels must be of a specific design if they are to remain in an otherwise closed container. Although empty bottles may be allowed to dry, it is not acceptable to minimize wastes by evaporating in a fume hood. Filling of Containers Containers of liquid wastes require adequate headspace (10%) to allow for thermal expansion. Containers must not be filled whereby they cannot be closed. Containers must be able to handle the weight and other physical hazards of the waste. Definitive: Do not fill above shoulder of bottle, (where the curvature starts to become more horizontal). Allow at least one inch of headspace for five-gallon containers, and three inches for 55-gallon drums. Debris and articles (lamps, pipettes, tubing, etc.) must be fully enclosed in the container. Corrective actions: Ensure containers of liquid wastes have sufficient headspace. Transfer excess to another container. Ensure debris and other solid wastes are fully contained. Container Handling Containers, including hazardous articles such as fluorescent lamps, must be managed in a manner that minimizes the potential for breakage, spills, or leaks. Lamps must be in boxes that meet container management requirements (closed, properly marked, and dated). Containers shall not be stacked when filling. Containers shall not be stored in such a way that a release may go down a drain. Processes must not be designed for disposal to drains or trash without a documented hazardous waste determination. Definitive: Chemicals/wastes are not used or stored in sinks. Containers that appear to be in use (collecting waste or dispensing product) are not stacked or otherwise stored in an unsafe manner. Fragile hazardous articles, such as fluorescent lamps, are protected and managed in closed, labeled boxes. Corrective actions: Ensure containers and hazardous articles are stored safely, and potential spills do not go down drains.

6 Secondary Containment Secondary containment is the use of a device to minimize the uncontrolled release of material. This may be a tray or pan, dike or berm, or similar open containment system where waste is initially accumulated (poured into a container). All materials in a secondary containment unit should be compatible with the containment unit and chemicals present. Materials that may react and pose a risk of fire, explosion, or generation of toxic gas shall not be placed in the same secondary containment unit. Evaluate waste accumulation areas for potential release routes (discharges). This should focus on location of drains and potential for spills. Many fume hoods have small sinks, and would only require preventive measure protecting the drain from spills (e.g., dike, berm, capped drain line). Some fume hoods may have cabinets vented to the hood, leaving a small hole in the working surface which will also need to be protected from spills. Ideally, any loss of material should be contained to the smallest area to accommodate cleanup and/or recovery and minimize potential damages. The presence of floor drains, and potential seepage through floors, warrants secondary containment for containers stored on the floor. For accumulation where waste is generated, the presence and use of secondary containment is of more concern than the capacity of the secondary containment. We do not require secondary containment where labs/shops accumulate closed containers in storage (typically in a cabinet, not to be opened, no wastes added or removed). Also, we are not looking at capacities being the greater of 100% of the largest or 10% of all containers; rather a simple system to collect incidental spills that may occur while adding waste based on the presumption that small containers will have small volumes added at a time, while large containers will have relatively large volumes added at a time. Minimum requirements should be considered as: Containers up to 4 liters capacity may use a shallow tray (cafeteria-type), without regard to cumulative capacity (not practical to have more than four 4-liter bottles on a tray). Containers up to 15 gallons capacity may be in a shallow pan (sides typically 1-4 inches high, depending on size of pan relative to size of container). The larger the container, the greater the recommended containment capacity. A dike, curbing, or berm of sufficient height to minimize the potential for liquids to enter a sink or drain. Laboratory reaction vessels (e.g., beakers, flasks, similar small containers) do not require secondary containment until removed from the process and determined to be waste. Areas where liquid wastes are first accumulated must have secondary containment for collecting incidental spills while adding waste to containers (e.g., pouring from flask or beaker into bottle). Secondary containment is typically an open container, and must be maintained free of cracks and gaps, with spills promptly cleaned up. Definitive: Secondary containment requirements may be satisfied when the lab/shop uses appropriate containment trays or pans, or has taken measures to protect drains and other openings from potential spills or leaks. Corrective actions: Secondary containment needs to be provided for liquid wastes, especially in areas where wastes are poured into containers. EH&S may assist with evaluating options. EH&S may provide a limited number of trays or pans for containers up to 5 gallons capacity where they are not currently available.

7 Clean Containers Containers, including secondary containment systems, should be reasonably clean with no visible outside contamination. Indicators may include inks that have bled, stains, or residual contaminants or films. Definitive: Clean container requirements apply to both containers and secondary containment units. Containers and containment units should be clean, with no visible outside contamination (oily residues, dried solids, etc.). Stains, ink runs, and other indicators of wastes not getting into the container may attract attention, and the PI or supervisor should be prepared to describe the materials that caused the problem and what was done to clean or remove the hazard. Corrective actions: Containers were contaminated by spills that occurred while adding wastes. Clean outside of containers and/or secondary containment units. Review filling procedures, and ensure appropriate equipment and material are available for this activity. Container Markings Container markings should clearly indicate the container contents. Many containers in use were previously labeled, whether by the manufacturer or the user. Old labels must be defaced prior to the container being reused for another material or waste. Chemical formulas and abbreviations are inappropriate for identifying materials. It is not acceptable to simply mark a location designated for a particular type of waste without also marking the container. Containers are labeled as Hazardous Waste or Waste (chemical name) and identified with a chemical or product name. Hazard communication and right-to-know requires chemical names and/or constituents to be associated with waste containers. EPA encourages descriptions (e.g., waste solvent is preferred over hazardous waste, waste non-halogenated solvent is preferred over waste solvent, etc.) that provide greater communication of potential hazards for area and emergency personnel. Descriptions must be relevant to the hazard (e.g., waste vials does not indicate contents or contaminants of the vials). Small items may be placed in a larger container (bag or box) to allow sufficient labels. Containers of oil for disposal or recycling are labeled Used Oil and not Waste. Batteries, fluorescent lamps, and other universal wastes are labeled Universal Waste and the accumulation start date is recorded on the box or individual item. Definitive: Oil is the only material for discard that requires the term used ; the term waste is not to be used on any container of oil. All other containers accumulating waste must have the word waste clearly marked, regardless of whether it is disposed of through EH&S or accumulated for recycling (e.g., distillation). General descriptions on containers must be supplemented by specific chemical information attached to or associated with the container (e.g., log sheet referencing container number and chemical contents). Chemical formulas or abbreviations are not acceptable as sole identifiers (chemical names required). Waste containers are often reused reagent bottles. Labels must be defaced before waste is added to avoid confusion as to contents. It may be necessary to ask lab or shop personnel what is in some containers. Subjective: Dates when wastes are generated or taken out of service should be recorded on the container when wastes are first added. Corrective actions: Ensure oils for discard are marked used oil. Ensure all other containers are clearly marked with the words Hazardous Waste or Waste (chemical/process name) and all previous markings or labels are defaced. Specific chemical names must be associated with the container. Ensure markings are legible.

8 Quantity Limits Areas must not exceed the limit of 55 gallons total of hazardous waste, or 1 quart of acute hazardous waste. Note this requirement is by volume and not by weight. Typically, acute hazardous waste involves certain unused products that are outdated, physically mixed with other wastes or materials, or abandoned. Areas that exceed the hazardous waste accumulation limits will be evaluated by waste program personnel. Definitive/Subjective: Some shops are likely to exceed the 55-gallon limit, particularly for used oil and paints. Latex paint and most oils are not regulated as hazardous wastes (but require proper management and disposal), while oil- or lead-based paints, fuel oils, and some refrigeration oils are hazardous waste. Labs are restricted to 30-gallon drums, but some may have more than one in use. Bags of debris may be difficult to evaluate, but should be included with the estimated volume limit. Corrective actions: (1) Ensure appropriate container sizes and timely removal of waste materials. Excess waste must be removed within 3 calendar days. Submitting chemical waste forms over the internet informs EHSC of the type and quantity of waste materials in an area. Wastes are scheduled for pickup based on location (building), and consideration of quantity or significant hazard. (2) If it is necessary to store more than 55 gallons of hazardous waste in a single room, coordinate options with EH&S. It may be feasible to designate (by signs or other means) accumulation areas for specific wastes. For example, a 55-gallon drum is likely to be associated with a specific process and/or disposal option and placed in one area of the lab/shop, while various small containers may result from other steps or processes in the same room and placed in a designated area nearby (but still in the same room, i.e., near the point of generation and under the control of the process operator ). Each designated area would have a 55-gallon limit. Note that this is not an option for areas where wastes are accumulated or stored in an adjacent room (see guidance with Room Description and Generator Control). Emergency Preparedness All areas where hazardous materials are used or stored, or where hazardous processes may be conducted, are required to be covered by current Safety Plans, which outline chemical inventories, standard and emergency procedures, and availability of equipment. The Principal Investigator is responsible for providing a complete inventory of hazardous materials, including chemicals, biological and radioactive materials, and compressed gases. Work areas should have ready access to telephones, and emergency numbers should be posted. Emergency equipment (fire extinguishers, spill supplies) should be available, and authorized or designated personnel should be familiar with their use. Definitive: A current Safety Plan is present in the work area. Emergency equipment and supplies are present to the extent area personnel are authorized to use. Corrective actions: Ensure safety plans are prepared for all areas where hazardous materials are used or stored. Ensure safety plans are updated on an annual basis, and when significant changes are made to processes or inventories. Notify EHSC of area reassignments, and provide updated plans as soon as possible. Ensure access to emergency and communication equipment and emergency numbers are posted. Ensure personnel are familiar with means of protecting themselves in the event of an emergency.