2. Introduction
MSOE strives to set an exemplary standard for
occupational safety and environmental health in its
laboratories.
This commitment places MSOE at the forefront of
professional educators who recognize that safety and
health must be integrated into all aspects of university
operations and curriculum.
3. Purpose
MSOE’s waste streams are:
Highly variable
Generated at multiple points
Numerous
Generated in small volumes – short time frames
Hazardous waste management in university settings is
challenging for these reasons.
To overcome these challenges, MSOE has developed a Lab
Management Program (LMP) to govern the handling of
unwanted materials (waste) in our facilities.
This training program provides a review of regulatory
requirements and MSOE’s LMP.
4. Training Outline
Hazardous Waste on Campus – Basic Facts
EPA Regulatory Requirements (Subpart K)
MSOE’s Lab Management Plan Requirements
Hazard Communication Program
Emergency Response Program
5. Basic Facts
MSOE: 3 EPA Site IDs
Science/Engineering 429 East State Street (Small
Quantity Generator <2200 lbs haz waste/month)
Krueger Hall 820 N Milwaukee Street (Conditionally
Exempt Small Quantity Generator <220 lbs. haz
waste/month)
Kern Center & Residence Hall Complex 1245 N Broadway
(Conditionally Exempt Small Quantity Generator < 220
lbs. haz waste/month)
MSOE’s Hazardous Waste Management Firm: Veolia
2010: MSOE shipped 838 lbs. of hazardous waste to
certified treatment facilities
(flammables, oxidizers, mercury salts and
solutions, acids, bases, elemental mercury, aerosols)
6. Basic Facts
MSOE has 3 Central Accumulation Areas for the storage of
hazardous waste
Science/Engineering Building
Margaret Loock Residence Hall
Krueger Hall
MSOE has 4 individuals trained in EPA’s Resource
Conservation and Recovery Act (RCRA) – these are the only
individuals who can transport unwanted materials to
MSOE’s Central Accumulation Areas
Julie LaRose Pete Hanson
Eric Homann Tom Barsokine
MSOE was one of the first universities in the country to opt
into the EPA’s New Hazardous Waste Regulation for
Academic Laboratories Rule (Subpart K)
7. Subpart K: Hazardous Waste Standard
for Academic Labs
Subpart K establishes criteria for trained professionals to perform
hazardous waste determinations of unwanted materials generated by
laboratories.
Subpart K details container labeling and container management
requirements for unwanted materials.
Subpart K requires laboratories to develop a Lab Management Plan
(LMP) to govern the safe handling, storage and removal of unwanted
materials from laboratories. MSOE has elected to require labs to
incorporate their chemical hygiene procedures into their LMPs.
Subpart K includes incentives for labs to conduct “laboratory clean-
outs”
8. MSOE Definitions
Laboratory – an area:
that conducts tests, experiments, or investigations through research or teaching
where nursing practices, artistic endeavors or architectural engineering projects take shape
where chemicals or radioactive materials are used
Any academic or research area where engineering principles are discovered or pursued
“Hard” Lab – a lab in which chemicals are allowed
“Soft” Lab – a lab in which chemicals are prohibited
To maximize faculty, staff, and student awareness of and protection from various safety issues beyond the
requirements of Subpart K, MSOE’s LMP is designed to cover as many academic and engineering areas as
possible.
A “soft” lab prohibits the use of chemicals and therefore need not address Subpart K
requirements, but the lab may be required to meet OSHA regulations and/or standards or other
“best practice” safety elements. There are some labs that may only need to address the following
minimum for training purposes:
Laboratory hours
Statement that chemicals are prohibited
MSOEs emergency planning and evacuation routes for that room
9. MSOE Lab Management Program Key
Requirements
Unwanted Material Labeling Standards
Container Standards
Training Requirements
Removal Frequency of Unwanted Materials
Making the Hazardous Waste Determination
Laboratory Clean-outs
Laboratory Management Plan
10. Unwanted Material
Any chemical, mixture
of chemicals, products
of experiments or other
material from a lab that
is no longer
needed, wanted or
usable in the lab.
Issues with stockpiling
11. Labeling Standards
Information that must be affixed or attached
to the container:
The words “Unwanted Material” or another
equally effective term
Sufficient information to alert emergency
responders to the contents of the container
(e.g. name of the chemical(s) in the container
or a descriptive phrase such as “inorganic
solvents”)
Sufficient information so “trained
professionals” can make a hazardous waste
determination
Date unwanted material first started
accumulating in the container
Date unwanted container placed in SAA
12. Satellite Accumulation Areas
Satellite Accumulation Area:
located in or near each lab
where unwanted materials
are generated.
May be located in a chemical
cabinet, under a bench or in
a designated, controlled
space in the lab.
MSOE has designated 19
SAAs.
SAAs must be identified in
the LMP.
13. Unwanted Material Label
The words Unwanted
Materials or equally
effective term used
consistently and written UNWANTED MATERIAL Information to
in Part I of the LMP (e.g. alert Emergency
Spent Acetone
Lab Waste) Responders to
the contents of
Contents: the container
(Flammable) And
Information to
make a HW
S252
Determination
SAA Location:
8/1/2010
Indicate SAA Location (in
the event there are
Date Place in SAA: questions about the
material)
14. Container Standards
Performance-based container management
standards in order to prevent
leaks, spills, emissions to the air, adverse chemical
reactions, and to avoid dangerous situations
Containers must be kept in good condition
Containers must be compatible with their contents
Containers must be kept closed
Containers must only contain compatible wastes
15. Improperly Stored Unwanted
Material
No MSOE labels
No secondary
containment
No segregation
Containers covered with
residue
16. Improperly Stored Unwanted
Materials
No MSOE labels
No secondary
containment from hood
drain
No segregation
Container not sealed
properly (open funnel)
17. Working Containers
May be open until the end of the
procedure or work shift, or until it is
full, whichever comes first
At end of procedure or work shift, or
when it’s full, it must be closed or
emptied into a container which is
then closed
Includes provision for other
situations where container cannot
be kept closed (e.g when it must be
vented to avoid dangerous pressure
build-up) – provisions to contain
Can be no larger than 2 gallons in
size
18. Unwanted Material Label
Working Container
The words Unwanted
Materials or equally
effective term used UNWANTED MATERIAL
consistently and written Information to
in Part I of the LMP (e.g.
Lab Waste)
WORKING CONTAINER alert Emergency
Responders to
Contents: Halogenated Organics the contents of
the container
(Toxics) And
Course: CH222 Lab Tech Information to
make a HW
II Determination
Start Accumulation Date: 8/1/2010
SAA Location:
S252
20. Removal Frequency of Unwanted Materials
Unwanted materials must be removed from labs at regularly scheduled
intervals (not to exceed 6 months).
MSOE has elected to schedule quarterly hazardous waste removals with
Veolia. These removals are scheduled for the first week of January, the first
week of April, the first week of July and the first week of October.
Unwanted materials must be removed from the laboratory within 10 days of
exceeding the maximum allowable quantity (55 gallons of waste or 1 quart of
acutely hazardous waste)
Must date all containers with the date the 55 gallons is exceeded
Must date all acutely hazardous waste containers with the date the 1 quart is
exceeded
MSOE removes “unwanted materials” from each lab as requested by
the lab. To request removal, lab personnel file an on-line pick-up
request.
21. Unwanted Material
Removal
To Request a Pick-Up,
(1) Go to the MSOE intranet site
(http://inside.msoe.edu)
(2) Look under the Environmental Health
and Safety Department
(3) Refer to the Environmental Protection
Section
22. Additional Waste Item Pick-Up Requests
Universal Wastes Electronic Waste
Batteries Media, CDs, Floppy Discs
Ni-Cd, metal Hard drives
hydride, lithium, alkaline or small
sealed lead-acid Laptops, Monitors, Keyboard,
Mercury-containing Mouse
equipment (MCE) AV Equipment
Thermostats, barometers, thermometers, press
ure relief gauges, temperature gauges, mercury
switches (light switches in vehicles)
Pesticides Aerosol Paint Spray Cans
FIFRA
Unused household
Anti-Freeze
Lamps—lighting devices with a
hazardous component
Fluorescent tubes and bulbs, high-
intensity discharge
Neon, mercury vapor
High-pressure sodium, metal halide
23. Central Accumulation Areas
MSOE has three EPA Hazardous Waste
generator id numbers and has
established a Central Accumulation
Area (CAA) for each EPA ID number.
The CAAs are located:
Room on the ground floor of the Science &
Engineering building
Basement of MLH
RPC in Krueger Hall
24. Training Requirements
Training for “trained professionals”
Must be in accordance with the applicable RCRA (hazardous waste) training
requirements
Training for “laboratory workers” and students:
Must be sufficient for them to understand and implement the requirements of
Subpart K, commensurate with their duties
Can be accomplished in a variety of ways (e.g. instruction, electronic/written, on-
the-job, etc.)
Training must be documented
MSOE provides training to faculty via this presentation. Faculty are
responsible for providing awareness training to students using the Lab
Management Plan Training protocols/documents prepared for each
individual lab.
25. Making the Hazardous Waste Determination
Determining whether an unwanted material is a hazardous
waste can become complicated
EPA Standards
WI Department of Natural Resources (DNR) Standards
Milwaukee Metropolitan Sewerage District (MMSD) Discharge
Limitations
Subpart K provides some flexibility in where and when the
hazardous waste determination is made.
MSOE’s Hazardous Waste Vendor or the MSOE RCRA
trained professional will determine whether the
unwanted material is a hazardous waste
Before the container is removed from the SAA; or
Within 4 days of the container’s arrival in the CAA.
26. Hazardous Waste Determination
EPA Listed Wastes Characteristic Wastes
P Listed: Unused Acutely Ignitability
Hazardous Waste Corrosivity
U Listed: Unused Non-Acutely Toxicity
Hazardous Waste Reactivity
K Listed: Waste from Specific
Sources
F Listed: Waste from Non-
Specific Sources
Examples of EPA U Listed Waste on Campus:
Acetone, Acetonitrile, Acrylamide, 1-
Butanol, Dichloromethane, Ethidium Bromide, Ethyl
acetate, Toluene, Xylene
27. Ignitable Wastes
A liquid that has a flash point of <140° F
Flammable solids, such as road flares or carbon.
An ignitable compressed gas (propane) or an oxidizer as defined by the Department of
Transportation (DOT)
Ignitable materials are represented by a D001 waste code.
28. Corrosive Wastes
Have a pH of 2 or less or 12.5 or more.
A liquid that corrodes steel at a rate of 6.35
mm or more per year as determined by the
National Association of Corrosion
Engineers. Potassium Tert-butoxide,
a flammable solid
Examples: nitric acid, aqueous sodium
hydroxide, hydrochloric acid.
Corrosive materials are represented by a
D002 waste code.
29. Reactive Wastes
Materials that undergo violent change:
- react violently with water or air
- capable of detonation
- create toxic gases when exposed to pH extremes
Examples: sodium metal, extremely dry picric acid, and organic peroxides.
Reactive materials are represented by a D003 waste code.
30. Toxic Wastes
- Materials that are poisonous, harmful and potentially deadly
- Examples: lead acetate, mercuric chloride, benzene.
The wastes are represented by codes from D004 – D043. These codes are specific to
material types. For example: Mercury has a D009 code, Benzene has D018.
31. Examples of Toxic Contaminants
Heavy Metals: Organics, continued:
arsenic, barium, cadmium, chrom cresol, 1,4-dichlorobenzene, 1,2-
ium, copper, lead, mercury, moly dichloroethane, 1,1-dichloroethylene, 2,4-
bdenum, nickel, selenium, silver, dinitrotoluene, hexachlorobenzene, hexac
zinc hlorobutadiene, hexachloroethane, methy
l ethyl
ketone, nitrobenzene, pentachlorophenol,
Pesticides:
Chlordane, 2,4- pyridine, tetrachloroethylene, trichloroeth
D, Endrin, Lindane, Heptachlor, Me ylene, 2,4,5-trichlrophenol, 2,4,6-
thoxychlor, Silvex (2,4,5- trichlorophenol, vinyl chloride.
TP), Toxaphene.
• In bold, Milwaukee Metropolitan
Organics: Sewerage District (MMSD) strict
benzene, carbon discharge limits.
tetrachloride, chlorobenzene, chloro • MMSD also strictly governs the
form, discharge of ammonia, cyanide
and hexane.
32. Shipping Hazardous Materials
The shipment of hazardous materials and/or dangerous
goods must conform to the many regulations stipulated by
the US Department of Transportation (DOT: ground
transport) and the International Air Transport Association
(IATA: air transport).
These regulations must be followed by a faculty or staff
member wishing to:
1. Ship a research sample for testing.
2. Send hazardous materials to a collaborator in industry or at
another university.
3. Return a hazardous material to the manufacturer.
4. Ship a sample packaged in dry ice.
33. DOT Hazard Classes Consult with MSDS to identify DOT
Hazard Class and then contact EHS
Department.
Department of Transportation (DOT) Hazard Class
Diamonds and Placards
Containers and trucks are marked with diamonds to inform you of the
material’s hazard class
Class 1 – Explosives Class 6 – Toxic Materials and Infectious
Substances
Class 2 – Gases Class 7 – Radioactive Materials
Class 3 – Flammable Liquids Class 8 – Corrosive Materials
Class 9 – Miscellaneous Hazardous
Class 4 – Flammable Solids Materials
Class 5 – Oxidizers and Organic
If uncertain whether a material is
Peroxides
regulated by the DOT as a hazardous
material, refer to the MSDS.
35. Laboratory Clean-outs
Incentive for not keeping materials on-site that will likely never be
used
Wastes disposed of from lab clean-outs do not have to be counted
toward the facility’s generator status
30-day period to sort through and evaluate lab inventory
Only one lab clean-out allowed per lab per year
The clean-out only pertains to unused chemicals not waste, by-
product chemicals
MSOE’s EHS Department will organize and document the lab
clean-outs. The EHS Department will work cooperatively with the
lab techs to conduct the clean outs. Orange clean out labels are
available through the EHS Department.
36. Laboratory Management Plan
The goal of the LMP is for the college or university to plan how it is
going to implement Subpart K’s performance-based requirements
for safely managing unwanted materials generated in laboratories
MSOE has a “Master Plan” LMP and each lab has developed an
LMP specific to the unwanted materials generated in the lab.
The EHS Director is responsible for maintaining and reviewing the
Master Plan LMP on an annual basis.
Faculty and Staff are responsible for developing individual LMPs
that are specific to their labs. The EHS Director serves as a
technical resource in the development of these plans.
MSOE’s Master LMP and the LMPs of individual labs are located
on the EHS Department’s intranet site.
37. LMP Contents Overview
Part 1: two mandatory elements (enforceable)
1. Describe procedures for container labeling
2. Identify which method will be used for the removal of unwanted
materials
Part II: seven mandatory elements (not enforceable)
1. Describe intended best practices for container labeling and management
2. Describe intended best practices for providing training for laboratory
workers and students
3. Describe intended best practices for providing training to ensure safe on-
site transfers of unwanted materials by trained professionals
4. Describe intended best practices for removing unwanted material from the
lab
5. Describe intended best practices for making hazardous waste
determinations
6. Describe intended best practices for laboratory clean-outs
7. Describe intended best practices for emergency prevention
38. Educating Students at MSOE
There are Lab Management Plan Training programs for each lab at MSOE
Instructors are responsible for reviewing the lab-specific Lab Management Plans with each
student prior to using the lab
This training must be documented using the LMP training sign-off sheet.
Lab Management Plan Training protocols consist of:
General lab rules (e.g. hours, buddy system, clothing requirement, food/drink restrictions. etc.)
Emergency Response Plan
Fire Emergency (evacuation, assembly area, fire extinguishers)
Personal Injury Response (eye wash, emergency shower)
Chemical Spill Response
Hazard Communication or “Right to Know” (potential hazards, MSDSs, chemical labels)
Chemical Handling
Chemical Storage
Chemical Disposal (SAA, trained professionals for transport out of lab)
PPE
Chemical Fume Hoods
The Lab Management Plans are posted on the EHS Intranet Site.
The LMP Training Sign-Off Sheet is also posted on the EHS Intranet Site.
39. Subpart K Recordkeeping
The following records/documentation is maintained by
the EHS Department:
Training records for laboratory workers, students and
faculty
Documentation of laboratory clean-out
activities, including:
Identity of the lab
The date the clean-out begins
The date the clean-out is completed (cannot be longer than 30 days)
The volume of hazardous waste generated during the clean-out
Campus-wide LMP and lab specific LMPs
40. Program Summary
MSOE identifies items to be discarded from the lab as ‘Unwanted Materials’.
MSOE has three EPA hazardous waste generator id numbers (Science &
Engineering building, Kern Center/Residence Hall Complex, and Krueger Hall).
Each lab can store unwanted materials in its designated area (known as a Satellite
Accumulation Area or SAA). Unwanted materials must be labeled with the words
“unwanted material” as well as the contents , the SAA location and the date that
the container was placed in the SAA.
MSOE has three Central Accumulation Areas (Science & Engineering
building, MLH, and Krueger Hall).
Only ‘Trained Professionals’ are authorized to transport unwanted materials to the
CAAs. There are currently four trained professionals at MSOE.
Unwanted materials are removed from individual lab SAAs to the CAAs at the
request of each lab. The opportunity for unwanted material removal from the
campus is scheduled on a quarterly basis. There is an on-line removal request form
which must be completed to request pick-up.
41. General Safety
Lab hours policy:
Normal hours for labs are between the hours of 7 am and 10 pm on regular
school days. After hours (including weekend and holiday) usage of labs is
not allowed without the authorization from the related supervisor and/or
instructor. Depending on the lab and/or the activity, the
supervisor/instructor may require use of the buddy system to work in the lab
during “off” hours.
Working alone should be avoided in “hard” labs. Use of the
buddy system is required in the following cases:
When the procedures being conducted are hazardous
When the lab-specific LMP Training plan indicates the buddy system is
required for the particular lab
When the instructor and/or the lab-specific LMP Training plan indicates
the buddy system is required for a particular activity
Food and drink are not allowed in labs. (Exception for “soft”
labs where chemicals are prohibited). Note: MSOE is using
the term “soft lab” for labs where chemicals are prohibited and
the term “hard lab” for labs where chemicals are used/allowed.
42. Hazard Communication and Safety
Each department is required to assess the potential hazards and the
appropriate engineering controls and/or personal protective equipment (PPE)
for each lab.
Students and laboratory workers must be made aware of any potential hazards
in the lab (chemical and other hazards).
Students and laboratory workers must wear appropriate PPE.
Chemicals must be stored by compatibilities.
Each lab must have a current inventory of hazardous materials used in the lab.
A Material Safety Data Sheet (MSDS) must be available for each chemical used
in the lab.
MSOE has an on-line MSDS system which is accessible from the MSOE
intranet.
(https://cisprolive.chemswlive.com/CISPro/login_msds.asp?accessid=686)
Every chemical container must be labeled with the contents and hazard
warnings (no mystery containers).
43. Hazardous Materials Identification
System(HMIS) Label
Colors, numbers, and letters are used to communicate the potential hazards of
a material as well as what kind of protective equipment should be worn.
HEALTH 0-4
FLAMMABILITY 0-4
REACTIVITY 0-4
44. HMIS: Health Hazard
Number Rating Word Rating Description of
Degree of Danger
0 minimal Little or no damage, even
with heavy exposures.
1 slight Irritation or minor injury
that can be cured.
2 moderate M ay cause temp. or perm.
minor injury or make you
unable to function.
3 serious Short exposure may cause
serious injury and requires
quick medical attention.
4 severe Short exposure may cause
death or serious injury.
45. HMIS: Flammability Hazard
Number Rating Word Rating Description of Degree
of Danger
0 minimal Does not normally burn even
when heated to 1500 deg F
1 slight Will burn but must be
heated, FP200°F
2 moderate Must be heated somewhat
before burning or may form
harmful gases if heated.
FP=100°-200°F
3 serious Can be ignited easily, burns
rapidly or ignites on
exposure to air. FP=<100°F
4 severe Gives off explosive vapors at
room temperature (73°F)
46. HMIS: Reactivity Hazard
Number Rating W ord Rating Description of Degree of
Danger
0 minimal Usually does not change even
during conditions of fire.
1 slight Usually does not change, but
may release some energy at high
temperatures and pressures.
2 moderate Usually changes easily, may
undergo strong changes (not
releasing energy suddenly/not
exploding) although it may be
explosive in water.
3 serious M ay explode but needs a strong
start (example - high
temperature, pressure, or shock).
4 severe Slight shock, pressure, or
temperature may cause an
explosion.
49. Emergency Response
MSOE has developed an Emergency Response Plan (ERP) covering specific types
of emergencies (e.g. fire, severe weather, medical, chemical spill, etc.)
This plan has been summarized in a emergency procedures flip chart which is
provided to faculty and staff and it is posted in every lab.
Call Public Safety at 7159 in case of emergency (spill, injury, fire, etc.)
Safety equipment is located in individual labs (eye wash, emergency shower, spill
response equipment, first aid kit, fire extinguisher, fire blanket)
Note: Not every lab necessarily needs each of the above safety equipment
Note: Lab techs are responsible for testing eye wash operation on a weekly basis
• Emergency evacuation procedures and assembly areas should be reviewed with
students in the course of the LMP training.
Evacuation routes are posted in every lab
50. Training Program Summary
Hazardous Waste on Campus – Basic Facts
EPA Regulatory Requirements (Subpart K)
MSOE’s Lab Management Plan Requirements
Hazard Communication Program
Emergency Response Program
51. ?? Questions ??
If you have questions on the information presented, you
may contact:
Julie LaRose (MSOE)
larose@msoe.edu
x7144
Notas do Editor
My name is Julie LaRose and I am the Environmental Health and Safety Director for the Milwaukee School of Engineering. I appreciate your participation in MSOE’s Lab Management Plan training.
One of my primary goals is to ensure that MSOE sets…With many of the safety and health programs we have implemented in the past year, MSOE has become an institution that others want to emulate.Institutions like Marquette, Medical College, UWM and Madison are watching programs unfold at MSOE and are pursuing a similar path.This is consistent with our mission to be at the forefront of professional educators who recognize….
Discuss how MSOE is different than industry
Our training outline is ambitious. I would like to review the following:There will be opportunities in the upcoming year for faculty and staff to enroll in additional training which will elaborate on the topics presented here.
Acute Waste>2.2 lbs/month generation or > 2.2 lbs accumulation at any time makes you a LQG2200 lbs. (1000 kg) is about five 55-gallon drums
Location of CAAsRCRA training is required every year and it is very detailed training.MSOE was at the forefront of environmental health when the university voluntarily opted in to the EPAs New Hazardous Waste Regulation. Some universities are still trying to manage their waste using standards that were designed for industry.
For years, the EPA has recognized that universities do not generate hazardous waste in the same manner as industry. Hazardous waste generation in industry is much more predictable, less variable and more easily controlled. The EPA estimates that laboratories will typically account for approximately 75% of the waste generated by a university. Previously, the EPA operated under the assumption that PhDs in the lab were making hazardous waste determinations and waste was being handled in compliance with EPA’s hazardous waste standards. Upon further investigation, it was discovered that students and untrained lab personnel were making these determinations and many of these individuals had no knowledge of hazardous waste standards.The LMP should not only address the handling of unwanted materials, it must also address the safe handling and storage of all chemicals in the labs.
Initially, there was confusion about what constituted a lab, MSOE has defined its laboratories – set up its central accumulation areasLaboratory – an area where relatively small quantities of chemicals and other substances are used on a non-production basis for teaching or research and are stored and used in containers that are easily manipulated by one personA primary distinction here at MSOE is the difference between hard and soft labs.A soft lab may meet one of the criteria above, but the lab does not contain chemicals of any kind. As a result, these labs do not need to generate chemical handling or disposal procedures.
In some labs, every material is wanted regardless of its age or whether it has long past its shelf life.Labs that stockpile chemicals introduce a variety of issues.These labs do not systematically eliminate unwanted materials. Generally, chemical storage is disorganized, incompatible chemicals are stored next to each other, expired chemicals are maintained for years and an accurate chemical inventory does not exist. The manufacturers of extremely old chemicals may no longer exists so a material safety data sheet may not exist. Often, lab personnel will continually reorder chemicals in stock simply because they can’t find the chemical in storage.Labs that stockpile unwanted materials put the university at risk of becoming a large quantity generator to accommodate the clean out of stockpiles. This forces the university to comply with numerous additional regulatory requirements.We are promoting regular reviews of chemical stocks and the elimination of unwanted materials. We recently requested and were granted small quantity generator status and we want to maintain this status.There are certain chemicals that we attempt to recycle.We try to recycle petroleum-based oils used for lubrication of engines and machinery. This includes centrifuges, diffusion pumps and vacuum pumps used in laboratories. Try not toallow cleaning solvents or other materials to be combined with used oils. Uncontaminated instrument and machine oils such as centrifuge, diffusion pump and vacuum pump oils can be recycled.
How do we systematically identify unwanted materials on campus?We label the container with a Neon Green Unwanted Material sticker.This sticker must include specific information.
We have encountered situations where containers or other wastes are left outside the CAA in the Science Building. This is a bad idea for several reasons. First, storing waste in a means of egress is a bad idea. Second, this hallway is prone to flooding and items left on the ground could become a hazardous waste clean up.
Containers that are not labeled appropriately will not be removed from the SAA.We cannot afford mystery containers in the CAA and retroactively figuring out where a container came from is time consuming.
Not only of hazardous waste containers, but chemical containers themselvesHazardous waste containers must be compatible with the waste stored –this is particularly true of corrosives.UW-Madison exampleA graduate student sitting as a lab computer was surprised by chemical waste bottle which burst and sprayed nitric acid and glass shards. About 2L of nitric acid waste had been accumulated in a chemical waste bottle which originally held methanol. Over a 12-16 h period, some residual methanol reacted with the nitric acid and created enough CO2 to overpressurize the container.
These are some of the issues that will be evaluated during MSOE’s mandatory EPA audit. This audit will be conducted in Spring of 2012.
Remove funnel and close container when not adding waste
There are specific labeling requirements for working containers.Information from CAMEO chemicalsFlammability is variable – Reactivity is variable Examples vinyl chloride, trichlorobenzene, PCBs, Methylene chloride, chloroform
The signage can be acquired by contacting the EHS Department.
Media, CDs, Floppy Discs, Hard Drives – all go to Sandy Haro in the Treasurer’s Office (has a contract with Piranha)
As you can see, we have great response to our calls to clean out and our clean outs thus far have been very successful.
The new standard requires a higher level of training from the hazardous waste handlers down to students.
Provides flexibility because there is a recognition that this determination can become complicated and requires extensive knowledge of EPA standards, local WI DNR standards and Milwaukee Metropolitan Sewerage District requirements.For this reason, MSOE has elected to use the hazardous waste chemists of our hazardous waste vendor to make these determinations.
EPA hazardous wastes consist of chemical wastes that exhibit the characteristic of corrosivity, ignitability or reactivity or fail the toxicity characteristic leaching procedure (simulates the ability of a compound to leach out of a landfill and enter groundwater.EPA hazardous waste must not be disposed of by certain polluting methods. EPA hazardous wastes must not be disposed: in the normal trash, in the garbage or refuse not in recycling bins, glass receptacles, sharps containers or red bags; by evaporation; by dilution (If EPA hazardous wastes are diluted or combined with a nonhazardous material, the resultant material is still regulated as an EPA hazardous waste. Toxic and ignitiable solvents must NEVER be intentionally evaporated to dispose of themListed Wastes Mismanaged waste streams from certain industrial processes can have a negative impact on human and environmental health, even at low concentrations. So-called "listed wastes" are specific industrial waste streams that appear on one of four lists ("F," "K," "P" or "U") as defined in the Code of Federal Regulations Title 40, Part 261, Subpart "D." "F" List Wastes Wastes on the "F" list are produced during common industrial or manufacturing processes such as degreasing. Because "F" list wastes are not specific to any particular sector of industry, they are also called "non-specific source wastes." Examples from this extensive list include wastewater treatment sludge from certain electroplating operations and spent degreasing solvents such as tetrachloroethylene, trichloroethylene, 1,1,1-trichloroethane and carbon tetrachloride. "K List Wastes "K" list, or source-specific, wastes are waste streams generated by specific industrial sectors, such as ink formulators, petroleum refineries and producers of veterinary pharmaceuticals, explosives, pesticides and inorganic pigments. The Code of Federal Regulations Title 40, Part 261.32 provides a full listing of these wastes. "P" and "U" List Wastes Both "P" and "U" lists involve discarded commercial chemical products, or unused pure or commercial-grade chemical products. Chemicals on the "P" list are fatal or irreversibly damaging to humans and animals at low doses. Those on the "U" list pose a hazard to human or environment health when improperly managed. Compounds appearing on these lists include pesticides and pharmaceuticals. The Code of Federal Regulations Title 40, Part 261.33 defines "P" and "U" list wastes in full.
Ignitable compressed gas DOT list 49 CFR 173.300Oxidizer defined by DOT 49 CFR 173.151
PenaltiesIndividuals who improperly ship hazardous materials may be subject to criminal and civil penalties. Fines to the University can range from $250 to $500,000 per violation.Classes of Hazardous MaterialsThe following classes of shipping hazards are defined and regulated.Class 1: Explosives1.1 Explosives with a mass explosion hazard (nitroglycerin/dynamite)1.2 Explosives with a blast/projection hazard1.3 Explosives with a minor blast hazard (rocket propellant, display fireworks)1.4 Explosives with a major fire hazard (consumer fireworks, ammunition)1.5 Blasting agents1.6 Extremely insensitive explosivesClass 2: Compressed Gases2.1 Flammable gases (propane, hydrogen)2.2 Non-flammable gases (helium, nitrogen)2.3 Poison gases (chlorine, phosgene)2Class 3: Flammable Liquids (gasoline, some alcoholic beverages)Class 4: Flammable Solids4.1 Flammable solids (magnesium powder, red phosphorus)4.2 Spontaneously combustible materials (white phosphorus)4.3 Water reactive materials (sodium, potassium)Class 5: Oxidizing Materials5.1 Oxidizers (ammonium nitrate, hydrogen peroxide)5.2 Organic peroxides (benzoyl peroxide)Class 6: Toxic and Infectious Materials6.1 Poisonous liquids or solids (potassium cyanide, mercuric chloride)6.2 Infectious/biohazardous substances (anthrax, HIV)6.3 Liquids and solids with a lower toxicity than those in group 6.1.Class 7: Radioactive Materials7.1-7.3 Radioactive I, II, III (uranium, plutonium, radioactive waste)Class 8: Corrosive Materials (sodium hydroxide, sulfuric acid)Class 9: Miscellaneous Dangerous GoodsMaterials that are hazardous during transportation but do not meet the definition of any of theother hazard classes (dry ice in an airplane).ExceptionsSmall quantity exceptions (49 CFR 173.4 and IATA 2.7) may exist for authorized materials:- 30 mL limit for liquids- 30 g limit for solids
Our training outline is ambitious. I would like to review the following:There will be opportunities in the upcoming year for faculty and staff to enroll in additional training which will elaborate on the topics presented here.