Hazardous Waste Inspection Concerns

Generator Control
Orderly Work Area
Aisle Space
Container Selection
Closed Containers
Filling of Containers
Secondary Containment
Clean Containers
Container Markings
Quantity Limits
Emergency Preparedness

Generator Control

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.

Corrective actions:

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.

Orderly Work Area

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.

Corrective actions:

Remove excessive clutter (papers, dirty glassware, and assorted "junk") to allow for a safer and more accessible work area.

Aisle Space

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.

Corrective actions:

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.

Container Selection

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.

Corrective actions:

Ensure containers and their closures are appropriate and compatible.

Closed Containers

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.

Corrective actions:

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 minutes, it is likely that the container may be upset, misused, forgotten, or unattended.

Filling of Containers

Containers must have at least 10% head space to allow for thermal expansion.

Corrective actions:

Ensure bottles/carboys are not filled over the "shoulder" of the container (where the curvature starts to become more horizontal). A minimum of one inch head space is required for five-gallon cans or drums. Three inches is required for 55-gallon drums.

Secondary Containment

Areas where wastes are first accumulated must have secondary containment for collecting incidental spills while adding waste to containers.

Corrective actions:

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.

Clean Containers

Containers should be reasonably clean, preferably with no visible outside contamination.

Corrective actions:

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.

Container Markings

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.

Corrective actions:

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. Container markings may become illegible as a result of spills while filling the container, or using pencil or other easily defaced markers.

Quantity Limits

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.

Corrective actions:

(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.

Emergency Preparedness

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.

Corrective actions:

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.