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Environmental Compliance Review. OESO Environmental Programs. In October 2009, Duke University participated in an EPA voluntary multi-media audit of the campus.

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environmental compliance review

Environmental Compliance Review

OESO Environmental Programs


In October 2009, Duke University participated in an EPA voluntary multi-media audit of the campus.

    • Numerous teaching and research laboratories, classrooms, cold rooms, film processing rooms, maintenance areas, boilers, chillers, emergency generators, and etc. were surveyed during these audits.

During the audit, the following violations were noted:

      • Wastes not labeled with “waste (name of chemical)” and dated
      • Waste were stored in open containers
      • Wastes stored without secondary containment
      • Wastes from multiple locations consolidated in one room
laboratory chemical waste practice
Laboratory Chemical Waste Practice
  • Practice covers the following topics:
      • Accumulation of waste chemicals
      • Container Labeling and Marking
      • Container Management
      • Storage of Waste
      • Acutely Hazardous Chemicals
      • Unused, Unopened, or Unknown Chemicals
      • Obsolete Chemicals or Substances
      • Chemical Inventory
      • Sink Disposal of Chemical Substances
collection of waste chemicals
Collection of Waste Chemicals
  • Waste chemicals collected either during the operation of a process or otherwise accumulated in the laboratory must be placed into containers that are in good condition, compatible with the contents, and able to contain the contents without leaking.
container labeling and marking
Container Labeling and Marking
  • Container Contents
    • Containers used to collect waste chemicals must be clearly marked with the words “Waste (name of chemical)”
    • Containers must be marked or labeled at the time waste is first placed in the container (label templates can be found on the OESO EP website)
container labeling and marking1
Container Labeling and Marking
  • Waste Collection Dates
    • Containers must have an “open date” listed on the container label, and when full or no longer being filled, a “fill date”.
    • The “open date” is the earliest date that waste is placed in the container whereas the “fill date” is the date that the container is filled and will no longer be used to accumulate waste.
container labeling and marking2
Container Labeling and Marking
  • Unused, unwanted, or unopened chemicals that are to be discarded must be labeled with the words “Waste (name of chemical) and the date that they were determined to be unwanted or unusable.
  • Small or odd shaped containers that are difficult to place a label on must be placed in a larger sealed container and labeled on the outside. (zip-lock bags, plastic containers, etc.)
  • Containers holding chemicals that cannot be identified by chemical name, chemical constituents, or process generating the waste must be labeled as “Waste Unknown” with the date that they are considered to be no longer needed.
unused unopened or unknown chemicals
Unused, Unopened, or Unknown Chemicals
  • Chemicals identified by the Lab as no longer needed and that are unused, unopened, or unknown must be removed from the laboratory no later than 30 days after being designated as no longer needed.
container management
Container Management
  • Waste containers must be compatible with their contents.
  • Waste containers must be kept closed except when adding or removing wastes.
  • Waste containers should be kept clean with no visible contamination on the outside of the container.
  • Waste labels and markings must be readable and not defaced.
container management1
Container Management
  • Areas where waste chemicals are accumulated must have secondary containment sufficient to collect any incidental spills from container failure.
  • Waste containers should not be overfilled. Full containers must have at least a 10% headspace to allow for expansion.
  • Filled waste containers must be stored in a secure area under the control of the operator
  • Waste containers must be stored for pick up in the room in which they were generated
container management2
Container Management
  • Filled containers of chemical wastes must be removed from the laboratory within 90 days of the accumulation start date or the date a chemical becomes a waste. In addition, no more than 50 gallons of chemical waste may be stored in a laboratory at any one time.
container management3
Container Management
  • Wastes collected during processes:
    • Wastes that are collected as part of a continuous process (such as HPLC wastes) must be collected via tubes that are fed through a cap or other container closure to insure that the container is kept closed. This closure must be a positive closing lid. Parrafilm and similar closures will not be acceptable.
  • Containers used to collect waste chemicals on a frequent, routine basis must be closed when a procedure or experiment has been completed.
      • EXAMPLE: Containers used to collect acetone washes must be kept closed except when actively adding or removing wastes from the container.
acutely hazardous chemicals
Acutely Hazardous Chemicals
  • Commercial chemical products that are considered “acutely” hazardous when discarded are labeled as “P-List” waste by the US EPA and are subject to additional regulatory requirements.
      • A list of these chemicals can be found on the Environmental Programs Compliance Webpage.
      • “P-List” chemicals must be segregated into separate containers, clearly marked with the words “Waste(name of chemical)”,and labeled with the date waste is first placed into that container.
acutely hazardous chemicals1
Acutely Hazardous Chemicals
  • An inventory of the amount (in pounds) of “P-List” waste accumulated in the laboratory must be maintained by laboratory personnel.
      • An example of a Waste Log can be found on the Environmental Programs Compliance Webpage.
  • The inventory must be included in the Chemical Waste Pick-Up Request. Laboratories may not accumulate more than 2 poundsor 1 quart of “P-List” waste at any time.
        • Note: Empty containers of “P-List” chemicals must also be submitted for pick-up.
obsolete chemicals or substances
Obsolete Chemicals or Substances
  • An obsolete chemical or substance is a chemical or substance that will no longer be used for its intended purpose or will not be used again and needs to be discarded.
      • Routine inventory reviews should be conducted to identify any obsolete chemical or substances at least once per quarter.
      • Any obsolete chemical or substance should be removed from storage, placed into the Laboratory’s chemical waste storage area, and properly labeled and marked
      • Unknown obsolete chemicals should be handled in the same manner as an unknown or unused chemical discussed in the previous slide.
chemical inventory
Chemical Inventory
  • PIs or designated personnel need to develop and maintain a chemical inventory. The inventory
      • Should be reviewed and updated quarterly
  • Chemicals identified as expired or no longer needed should be
      • removed from storage,
      • placed into the Laboratory’s chemical waste storage area,
      • properly labeled and marked, and
      • removed from the laboratory within 30 days.
drain disposal
Drain Disposal
  • Certain classes of chemicals cannot be poured down the drain – they must be collected for disposal as hazardous waste. Some of which include:
      • Any flammable liquids with a flashpoint less then 140oF - including but not limited to any quantity of gasoline, kerosene, naptha, benzene, toluene, xylene, fuel oil, ethers, ketones, aldehydes, chlorates, perchlorates, bromates, carbides, hydrides, and sulfides. This list does not include aqueous solutions of compounds that have a flashpoint greater than 140oF.
      • Explosive chemicals
      • Mercury and mercury compounds
      • Radioactive materials
      • Photographic used fixer solutions unless they are first passed through a silver recovery system
      • Rinsate from highly hazardous P-listed wastes or any other chemical that would be classified as a hazardous waste.
      • Ethidium Bromide buffer solutions at concentrations greater than 10 µg/ml
      • For a complete list see Guidelines For Sink Disposal of Chemical Substances on OESO EP website for more details
drain disposal1
Drain Disposal
  • Certain substances in concentrations above what is listed below can not be poured down the drain without a permit
          • Arsenic – 0.003 mg/l
          • Cadmium – 0.003 mg/l
          • Copper – 0.061 mg/l
          • Cyanide – 0.005 mg/l
          • Lead – 0.049 mg/l
          • Nickel – 0.021 mg/l
          • Silver – 0.005 mg/l
          • Total Chromium – 0.050 mg/l
          • Zinc – 0.175 mg/l
          • Ammonia – 25 mg/l
acceptable substances for drain disposal
Acceptable Substances for Drain Disposal
  • Chemicals that can be disposed of down the drain, providing the solution does not contain prohibited materials, include:
      • Aqueous solutions such as salts or buffer solutions within the pH range of 5.0 to 12.0.
      • Solutions with a flashpoint greater than 140F (60 C).
      • Chemicals that are water soluble and not hazardous by definition.
      • Acids and bases that have been neutralized to fall within the 5.0 to 12.0 pH range.
      • Biological liquids that have been treated with disinfectant or autoclaved.
      • Buffer solutions containing less than 10 µg/ml ethidium bromide.
      • Aqueous solutions containing alcohols at a concentration of 24% by weight or less.
      • Aqueous solutions containing formalin at concentrations less than 10% by weight.
aerosol can management
Aerosol Can Management
  • Aerosol cans may be handled as solid (non-hazardous) waste if they meet the following criteria:
    • The aerosol products have been used for their intended purposes so that when holding the cans upright and pressing down on their nozzles, not enough product comes out for them to be useful anymore, and
    • No more than 3% of the original net content weight remains in the cans, or b) No more than one inch of liquid remains in the bottoms of the cans, and
    • The cans did not hold chemical formulations with sole active ingredients identified in the F027 (used and unused formulations for wood preserving) or P-list hazardous waste listings.
aerosol can management1
Aerosol Can Management
  • Aerosol cans that are not empty or may be hazardous should be managed according to the Chemical Waste Management Practices.
  • Aerosol cans that are still in use are not considered a waste. Once the user decides they no longer need the can, the correct disposal path for the can should be made using the criteria listed above.
emergency planning and community right to know act epcra
Emergency Planning and Community Right to Know Act (EPCRA)
  • Designed to promote the discovery and mitigation of risks associated with chemical use; and
  • To provide a data-gathering process to increase awareness of chemical risks in the community.
  • Also requires that operating areas where hazardous chemicals and substances are present to have, or have access to, MSDSs for all hazardous chemicals used or stored.
targeted ehs reporting online
Targeted EHS Reporting Online
  • To determine the extent to which EPCRA applies to your area:
      • Complete online reporting of Targeted Extremely Hazardous Substances (EHS)
        • Determine the quantity of targeted chemicals present in your lab and submit report (must answer 5 TSCA question to complete report)
        • Should be reviewed and updated quarterly
        • OESO will compile the reports to determine reporting requirements to local, state and federal agencies (Tier II)
      • Update the report within 30 days of the addition of any hazardous chemicals or substance to your area.
toxic substance control act tsca
Toxic Substance Control Act (TSCA)

What is it?

  • Enacted in 1976
  • Gave EPA the authority to require reporting, recordkeeping and testing requirements, and restrictions relating to chemical substances and/or mixtures
  • Certain substances are generally excluded from TSCA, including, among others, food, drugs, cosmetics and pesticides.
tsca compliance at duke
TSCA Compliance at Duke
  • Unlike hazardous waste handling and most other environmental laws, TSCA compliance activities are focused on specific laboratory operating practices. For this reason, compliance responsibility rests almost entirely with the laboratory.
tsca compliance at duke1
TSCA Compliance at Duke
  • If you determine that your lab is not subject to TSCA, complete the Applicability Form and you are compliant with the regulation.
  • If you determine that you are subject to TSCA regulations, you may be subject to import/export, chemical transport, and other facets of the regulation. Please contact OESO at 684-2794 to discuss you lab’s potential issues.

Once you have determined your TSCA status, a TSCA applicability form must be completed for each laboratory, submitted to OESO, and a copy must be kept in the Lab.

        • The from must be completed even if you are not subject to the TSCA rules.
    • Note – Applicability Form must be updated annually
questions concerns

Questions / Concerns

Environmental Programs Division

Box 3914