Hazardous Waste Inspections Update

Inspections by the North Carolina Department of Environment and Natural Resources (NCDENR) have emphasized appearance and perception issues, in addition to those of “normal” chemical waste management. The issues that were routinely targeted or cited during previous inspections involve:

• Generator control issues, including accumulation at or near the point of generation;
• Orderly work areas, minimizing the potential for fire or releases/spills;
• Aisle space, allowing unobstructed movement of emergency personnel and equipment;
• Container selection, suitable for contents and in good condition;
• Containers must be kept closed except when adding or removing material;
• Containers must have at least 10% head space to allow for thermal expansion;
• Areas where wastes are initially accumulated must have secondary containment;
• Containers must be clean, with no visible outside contamination;
• Waste containers should be clearly identified with the words “hazardous waste” or “waste chemical / process name”;
• Areas must not exceed a total of 55 gallons of hazardous waste, or 1 kilogram of acutely hazardous waste; and
• Emergency preparedness: typically Safety Plans are prepared and maintained, access to emergency and communication equipment is ensured, and emergency numbers are posted.
• If you consolidate waste in a container such as "Chlorinated waste", the label must say "Hazardous Waste, Chlorinated". However you must also list the names of each waste constituent added to the container. This list will be used to conplete the Hazardous Waste Submission Form.

Appearance or perception issues have some basis in regulatory interpretation and applicability, and can be more tedious to comply with. These issues may include housekeeping practices and operational indicators, including:

• Clean secondary containment pans;
• Residual contaminants may appear as film or stain on containers;
• Inks that “run” or “bleed” may be indicative of solvent contamination;
• Residues in reaction vessels 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 containers).

Contaminated surfaces, whether 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.

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. These same good practices must also address waste management, resulting in a clean work area to continue quality research and education.

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, death, or other departure of personnel responsible for material management. Chemicals that are no longer intended for use must be redistributed or disposed of. 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.

Contact Rob Pecarina at 515-6863 for further information.