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Range of Compliance Obligations for Colleges & Universities. Resource Conservation & Recovery Act 4. Emergency Preparedness & Community Right to Know Hazardous Waste Management Laboratory Chemical Wastes 5. Federal Insecticide, Fungicide & Rodenticide Act

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Range of Compliance Obligations for Colleges & Universities

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Range of Compliance Obligations for Colleges & Universities

  • Resource Conservation & Recovery Act 4. Emergency Preparedness & Community Right to Know

    • Hazardous Waste Management

      • Laboratory Chemical Wastes 5. Federal Insecticide, Fungicide & Rodenticide Act

      • Hazardous Drugs Wastes .

      • Operations & Maintenance 6. Toxic Substances Control Act

      • Student Health Drug Wastes > Import/Export Notification

    • Universal Wastes > Preserving Laboratory Exemptions

    • Underground Storage Tank Standards > PCBs in Equipment

  • Clean Air Act

    • Title V Permit Compliance

      • Steam Plant Permit Compliance

      • Emergency Generators

      • Ethylene Oxide Sterilizers

      • Small Animal Incinerator

    • Section 112r Risk Management Planning

    • Stratospheric Ozone Protection

    • State Permits to Construct and Operate

  • Clean Water Act

    • Spill Prevention Control and Countermeasure Plans

    • Stromwater Management Permits

    • Discharges to local POTW and Pretreatment


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Emergence of Regulations to Manage Hazardous Wastes

  • Growing awareness of the impact and magnitude of abandoned waste sites on the environment and human health (Love Canal).

  • The exponential growth of manufactured chemicals entering the environment.


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  • The Comprehensive Environmental Response,Compensation, and Liability Act (CERCLA), commonly known as Superfund was enacted by Congress on December 11, 1980. This law created a tax on the chemical and petroleum industries and provided broad Federal authority to respond directly to releases or threatened releases of hazardous substances that may endanger public health or the environment. CERCLA:

  • established prohibitions and requirements concerning closed and abandoned hazardous waste sites;

  • provided for liability of persons responsible for releases of hazardous waste at these sites; and

  • established a trust fund to provide for cleanup when no responsible party could be identified.

  • The law authorizes two kinds of response actions:

    Short-term removal actions, where actions may be taken to address releases or threatened releases requiring

    prompt response.

    Long-term remedial response actions, that permanently and significantly reduce the dangers associated with

    releases or threats of releases of hazardous substances that are serious, but not immediately life threatening.


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  • Resource Conservation and Recovery Act

  • The Resource Conservation and Recovery Act (RCRA) of 1976 was the first substantial effort by Congress to establish a regulatory structure for the management of solid and hazardous wastes.

  • Subtitle C of RCRAaddresses "cradle-to-grave" requirements for hazardous waste from the point of generation to disposal.

  • Subtitle D of RCRA contains less restrictive requirements for non-hazardous solid waste.


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RCRA – Cradle to Grave Waste Management


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A cradle-to-grave system to track and monitor hazardous waste

Established management standards for anyone who generates, recycles, transports, treats, stores, or disposes of hazardous waste.

Authorized States to implement RCRA programs equal to or more stringent than federal program.

Goals –

Ensure that wastes are managed in manner that protects human health and the environment

Reduce/eliminate the amount of waste generated, including hazardous wastes

Conserve energy and natural resources through waste recycling and recovery.

Banned open dumping

Provided a comprehensive national program to encourage source reduction, recycling, and safe disposal of solid waste.

Mandated strict requirements for treatment, storage, and disposal of hazardous waste to minimize present and future risks.

First hazardous waste facility permit was issued in October, 1981.

Resource Conservation and Recovery Act -1976


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RCRA’s Three Interrelated Programs

Subtitle D

Subtitle C

Subtitle I

Underground

Storage Tank

Program

Solid Waste

Management

Hazardous

Waste

Management


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Hazardous Waste Identification

Hazardous Waste Recycling and Universal Wastes

Standards Governing Hazardous Waste Generators

Standards Governing Transporters

Standards Governing Treatment, Storage and Disposal

Land Disposal Restrictions

Hazardous Waste Combustion

Permitting of TSD Facilities

Corrective Action to Clean Up Hazardous Waste

Enforcement of Regulations

Authorization of State Programs

RCRA Hazardous Waste Management Scheme


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A Hazardous Waste is:

A "solid waste" which because of its quantity, concentration, or physical, chemical, or infectious characteristics may:

Pose a substantial present or potential hazard to human health or the environment when improperly treated, stored or disposed of, or otherwise mismanaged; or

Cause or contribute to an increase in mortality, or an increase in irreversible or incapacitating illness.


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Is the material a solid waste?

Recycled materials

Secondary materials

Excluded wastes

Some solid wastes

Exempt hazardous wastes

Raw or process wastes

Waste samples

Is the waste a listed hazardous waste?

Listed hazardous wastes

Waste listed due to certain characteristics

Hazardous Waste Characteristics

Ignitibility

Corrosivity

Reactivity

Toxicity

Special Wastes

Mixtures

Derived-from rule wastes

Contained-in rule wastes

Defining Hazardous Waste


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Hazardous Waste Identification

Hazardous Waste Recycling and Universal Wastes

Standards Governing Hazardous Waste Generators

Standards Governing Transporters

Standards Governing Treatment, Storage and Disposal

Land Disposal Restrictions

Hazardous Waste Combustion

Permitting of TSD Facilities

Corrective Action to Clean Up Hazardous Waste

Enforcement of Regulations

Authorization of State Programs

RCRA Hazardous Waste Management Scheme


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Requirements for Hazardous Waste Generators

Regulated generators

  • Large Quantity

  • Small Quantity

  • Conditionally Exempt

    Waste identification

    Registration & ID number

    Accumulation times

    Preparation of waste for transport

    Waste manifests

    Recordkeeping and reporting

    Emergency procedures and

    Contingency planning

    Personnel training


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Hazardous Waste Identification

Hazardous Waste Recycling and Universal Wastes

Standards Governing Hazardous Waste Generators

Standards Governing Transporters

Standards Governing Treatment, Storage and Disposal

Land Disposal Restrictions

Hazardous Waste Combustion

Permitting of TSD Facilities

Corrective Action to Clean Up Hazardous Waste

Enforcement of Regulations

Authorization of State Programs

RCRA Hazardous Waste Management Scheme


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Oxidation – Strong oxidizing agents breakdown hazardous wastes into less toxic or less mobile constituents.

Deactivation – A process that removes the hazardous nature of waste by neutralizing characteristics such as ignitibility, corrosivity, or reactivity.

Incineration – High temperature oxidation of waste, usually at temperatures ranging from 1600 to 2500 F.

Industrial Furnace – Uses thermal energy to recover energy or materials. Includes cement kilns, lime kilns, coke ovens, blast furnaces, and smelting furnaces.

Micro-encapsulation – A process that coats the surface of the waste material with a thin layer of plastic or resin to prevent leaching.

Neutralization – A process used to treat corrosive hazardous waste streams.

Stabilization – A process that reduces the mobility of hazardous waste constituents.

Treatment in Tanks – Mechanical settling, gravity settling, or chemical oxidation to remove hazardous constituents.

Hazardous Waste Treatment


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Hazardous Waste Treatment & Disposal Standards

  • Permits to Operate

  • Performance Standards

  • Recordkeeping & Reporting Requirements

  • Groundwater Protection

  • Corrective Action

  • Emergency Preparedness & Contingency Planning


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Laboratory Waste Management

Healthcare Compliance Initiative

Regulated electronic wastes

Some Cases -


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Managing Waste Chemicals


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Management of Waste Chemicals Generated in Laboratories

Large Quantity Generator

Waste Management

Standards –

Part 262 RCRA

Labs can be subject to

Satellite Accumulation

Standards – Part 262.34

Best Management

Practices –

HHMI Proposal


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Waste Management Diagram


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Distribution of Wastes Shipped to TSDF – 524,352 lbs Collected


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Project XL – New England Laboratory Project –

Evaluated flexible application of generator rules to academic research laboratories.

HHMI Report to Congress – October 2001 –

Proposed a set of best practices for the management of laboratory wastes.

Nat’l Assoc. of College and University Business Officers – March 2002 – Environmental Excellence in Higher Education

Addressed the application of waste management regulations to the activities of colleges and universities.

US EPA Notice for Information on the Effectiveness of RCRA Generator Program and Areas for Improvement – October 2003.

Meeting of agencies and stakeholders on rules flexibility

US EPA Memorandum – March 2004 –

Clarification regarding satellite accumulation practices.

US EPA Notice Concerning hazardous waste generator program – April, 2004.

US EPA Final Rule – Standards Applicable to Generators of Hazardous Waste; Subpart K – Academic and Research Laboratories – December 2008.

Defining Hazardous Waste Management in Academic Laboratories


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Subpart K Changes

Container Labeling –

Chemicals, products of experiments or other materials no longer needed can be labeled as “unwanted materials.

The label must contain a general description of the contents and sufficient information to alert emergency responders.

The date of initial accumulation in a container must be recorded.

Accumulation Time in the Laboratory –

Unwanted materials must be removed once every six months or whenever 55 gallons is accumulated.

Point of Hazardous Waste Determination –

Waste determinations must be made by a “trained professional”

Unwanted material moved to an on-site central accumulation area must be identified as hazardous waste within 4 days.

Laboratory Management Plan (LMP)


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Healthcare Compliance

Hazardous Drugs Disposal

Chemotherapeutics

Electronic Wastes

Emerging Issues -


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What’s Regulated as a Hazardous Waste?

  • Certain chemotherapeutic drugs

  • Drugs that are “listed hazardous waste”

  • Drugs that are “characteristic waste”

  • Containers that held regulated drugs


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Duke Hospitals Formulary


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Hospital Waste Streams

Hazardous Pharmaceutical waste (15%)

Non-hazardous pharmaceutical waste

(~ 85%)

Sharps and RMW

Trace chemotherapeutic waste

Empty/trace vials, syringes, IV bags

Gowns, gloves,

goggles, tubing,

wipes

All waste pharmaceuticals

in inventory not identified

as hazardous

RCRA Waste (5%)

P-listed waste

U-listed waste

D-listed waste

> Ignitable waste

> Toxic waste

> Corrosive waste

> Oxidizers

Chemo spill materials

RCRA listed chemo agents

(residues & bulk)

Non-empty -

> vials, syringes, IVs

Non-RCRA Waste (~ 10%)

Non-listed chemotherapeutics

NIOSH hazardous drugs

Carcinogens

Endocrine disruptors

Toxic drugs – LD50 < 50 mg/kg

Formulations containing listed

waste not the sole active ingredient

RMV Red or Sharps Box

Blue

bin


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Waste Management

Process Proposal

Regulated medical waste

Pharmaceutical Waste -

Sharps

Non-Hazardous Waste

(85%)

Hazardous Waste (15%)

Sewer

System

Municipal

Waste

Hazardous Waste Container

Sharps Container

Check with local wastewater treatment plant for limits, etc.

Recycle as much paper, glass, plastic as possible

Bio-Red Bag waste container

Collect & Segregate

Non- RCRA hazardous

drugs

REGULATED MEDICAL

WASTE INCINERATOR

FEDERALLY PERMITTED HAZARDOUS WASTE INCINERATOR (HIGH TEMPERATURE)

RCRA Hazardous Waste

RESIDUE TO NON-HAZARDOUS WASTE LANDFILL

Waste to Energy TREATMENT FACILITY

RESIDUE TO LINED HAZARDOUS WASTE LANDFILL


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