Areas inspected must be under the control of the Principal Investigator,
with only his/her waste being accumulated at or near the point of generation.
No one else has waste, including abandoned materials, in that specific
location. Wastes generated in areas under the control of more than one
PI should be maintained separately. Wastes from adjacent rooms under
the control of the Principal Investigator may be acceptable, while those
from Adown the hall@ are not, even when from the same PI.
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 at or near the point of generation.
Although a fairly subjective judgment, most work areas can be evaluated
as "reasonably orderly", with demonstrated efforts to minimize the potential
for fire or spill.
Remove excessive clutter (papers, dirty glassware,
and assorted "junk") to allow for a safer and more accessible work area.
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. In general,
this is understood to be a minimum of approximately 30 inches. Work areas
will typically be cited if they have less than 24 inches of aisle space,
or if equipment must be moved to provide sufficient access.
Ensure sufficient aisle space throughout work areas, or sufficient notice
of how access may be made by emergency personnel around obstructions.
Emergency personnel should not be expected to move heavy equipment, climb
over tables, or crawl under equipment.
Containers must be suitable for their contents, including appropriate
closures. Liquids should be in screw-capped bottles, carboys, or drums.
Solids may be in large-mouth jars, sturdy bags, boxes, or drums. Containers
must be in good condition and compatible with their contents. Beverage
containers, flasks, and containers with cork, rubber, or ground glass
stoppers are not appropriate for waste.
Ensure containers and their closures are appropriate
Containers must be kept closed except when adding or removing material.
Parafilm or similar material does not satisfy requirements for closure.
Funnels must be of a specific design (fixed lid that ensures closure)
if they are to remain in a container (few funnels of this design have
been found to be in use, and are usually more expensive). Although empty
bottles may be allowed to dry, it is not acceptable to minimize wastes
by venting them in a fume hood.
Ensure containers are kept closed with appropriate
closures (caps, bungs, etc.), opening them only when adding or removing
wastes. State inspectors have applied a five-minute “rule”,
implying that it should not take more than five minutes to close a
container after adding or removing waste materials. Beyond this five
is likely that the container may be upset, misused, forgotten, or unattended.
Containers must have at least 10% head space to allow for thermal expansion.
Ensure bottles/carboys are not filled over
the "shoulder" of the container (where the curvature starts to become
A minimum of one inch head space is required for five-gallon cans or
drums. Three inches is required for 55-gallon drums.
Areas where wastes are first accumulated must have secondary containment
for collecting incidental spills while adding waste to containers.
Secondary containment needs to be provided for liquid
wastes, especially in areas where wastes are poured into containers.
EHSC can provide assistance, through departmental offices, by providing
a limited number of trays or pans for containers up to 5 gallons capacity
where they are not currently available.
Containers should be reasonably clean, preferably with no visible outside
Containers are usually contaminated by spills that
occurred while adding wastes. Review filling procedures, and ensure
appropriate equipment and materials are available for this activity.
Containers must be marked with the words "Hazardous Waste", or "Waste
(chemical/process name)", or similar words that identify the contents.
It is not acceptable to simply mark a location designated for a particular
type of waste without also marking the container.
Ensure containers are clearly marked with the words
"Hazardous Waste" or "Waste (chemical/process name)". Terms such as
"organic waste" or "aqueous waste" do not adequately identify the material.
markings may become illegible as a result of spills while filling the
container, or using pencil or other easily defaced markers.
Areas must not exceed the limit of 55 gallons total of hazardous waste,
or 1 kilogram of acutely hazardous waste. Typically, "acutely hazardous
waste" involves unused products that are outdated, physically mixed
with other wastes or materials, or abandoned.
(1) Ensure appropriate container sizes and timely
removal of waste materials. 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 an area, designate (by signs, partitions, or other means) accumulation
areas for specific wastes. For example, a 55-gallon drum may be associated
with a specific process and/or disposal option and placed in one area
of the lab/shop, while various small containers may come 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.
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. Work areas should have ready access to
telephones, and emergency numbers should be posted. Emergency equipment
(fire extinguishers, spill supplies) should be available, and personnel
familiar with use or restrictions.
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 (Mahdi Fahim at 513-1282 and Rob Pecarina) of
area reassignments, and provide updated plans as soon as possible. Ensure
personnel are familiar
with means of protecting themselves in the event of an emergency.