EHS_Midterm

Under RCRA, who is responsible for the proper management of hazardous waste?

The generator themselves

Under RCRA, what creates a strong incentive for regulatory compliance? Why is it so strong?

Stringent liability (basically, they fine you a lot of money); can hold so strictly liable because of the crade to grave system

Under RCRA, handling and storage of hazardous waste must be conducted by trained personnel (T/F)

T

What is a hazardous waste? Ex?

Difference from hazardous material?

Generally, defined as a material, which is discarded, including materials that are either spent or intended to be thrown away (or it’s not used properly: ex. mercury is a hazardous material, but mercury in soil is a hazardous waste) (or not stored/transported properly - if there’s a crash, it becomes hazardous waste)

Material is just anything that is hazardous but is not meant for disposal

Typical hazardous wastes?

Spent acids and solvents (like methanols, ethanols, acetones), used chemicals, waste paint, waste oil (if recycled, not a waste), unlabeled or unwanted chemicals, container once holding chemicals

2 resources for hazardous waste compliance 1/2

EPA 40 CFR and State regulations (TCEQ)

What are some hazardous waste procedures for EH&S Safety Professionals? 4/9

Waste Identification, storage, packaging, manifesting, shipping, disposal, reporting, recordkeeping, and person training

Under RCRA, what determines the complexity of regulations hazardous waste generators have to comply with?

Their generator status

VSQG: less than 220 lbs

SQG: 220-2200 lbs

LQG: >2200 lbs

Hazardous waste is a particular class of “solid” waste. What is considered solid?

Solids, semi-solids, liquids, and contained gas material

How many toxic constituents under RCRA’s toxic list? 3 categories? 1/3 (list examples of the other 2)

40 constituents

• 8 heavy metals (arsenic, barium, cadmium, chromium, lead, mercury, selenium, silver)

• 6 pesticides

• 26 solvents and other organics (chloroform, cresol, chlordane)

What are Class I Wastes?

Not considered hazardous by the EPA, but is by Texas and is regulated by TCEQ

Examples of class I wastes? 3/8

1. soils contaminated with petroleum hydrocarbons

2. sandblasting sand with lead

3. used oil

4. regulated asbestos containing material

5. empty containers which held hazardous substances

6. soils with equal waste from corrosive

7. waste containing more than 50 ppm of PCBs

8. liquids, solids, and semi-solids considered to be ignitable waste associated with exploration, development, and production of crude oil

Under RCRA, labeling properties for hazardous waste? 2/3

What are labels different from?

Containers have to be labeled with “Hazardous Waste” “Waste Oil”

Labeled with associated hazards (no abbreviations)

Accumulation start date

Labels different from waste tags

Two main storage types?

Satellite Accumulation Area and Main Accumulation Storage Area

How much hazardous waste is allowed in satellite accumulation areas? How many of P list is allowed? What must you do when it’s full (in how much time)?

Does the container have to be closed?

Max of 55 gallons of hazardous waste (1 quart of P list)

Once it’s full, have 3 days to move to the main accumulation storage area

Yes, close it!

Ex of a satellite accumulation area?

Labs (each one is a satellite)

How long are you allowed to accumulate hazardous waste at the Main Accumulation Storage Area?

Based on generator status

LQG: 90 days

SQG: 180 days

VSQG: no limit

Hazardous wastes can be stored around drains or sinks.

False

How should hazardous wastes be stored in the Main Accumulation Storage Area?

With compatible wastes, funnels can’t permanently be on top, in a secure area near generation

Hazardous wastes must be shipped with special shipping papers called….

HW Manifest (a tag, papers are a thick packet that has the document and copies with different colors (manifest sheets))

How long are facilities required to keep manifest copies? What does SFA do?

Minimum of 3 years (SFA keeps it forever)

TSDF acronym?

Treatment, Storage, and Disposal Facility

How is the transportation and disposal of Hazardous Waste regulated?

Must be transported by a licensed HW transporter, and can only be sent to a licensed treatment/storage/disposal facility

What HW regulation requires generators to comply with emergency preparedness and prevention requirements?

HAZWOPPER SARA Title III (must be trained)

What act makes HW generators make arrangements with LEPCs, fire and police, and spills?

SARA

Waste Minimization techniques? 5/6

Substitution, procurement, microchemistry, redistilling, in-lab destruction, proper segregation

Under RCRA, if you can’t minimize, you should

What do you need if you want to recycle it?

Recycle (requires permit), Redistribute (if new or unopened), or reuse before disposal if possible

Timeline of HW training for personnel? What CFR number states this?

Training within 6 months and then annually thereafter

40 CFR (EPA)

Requirements of training are based on…

Details

What is the required duration of training?

Generator Status

LQG: same training as TSDF

SQG: just thoroughly familiar

EPA doesn’t determine duration, based on cite needs

What happens if SQG exceeds their limits and generated LQG?

Have to get training immediately

Two most common OSHA trainings regarding working with Hazardous wastes?

Hazcom and Hazwopper

DOT Training requirements?

Security Awareness, General Awareness, Function Specific, Safety, Other

Must do an additional 4 hours of training and done every 3 years

ERG webpage and video: Emergency Response Guidebook

What must be reported by generators?

Generators have to submit biennial HW report with waste generation amounts to the state (VSQG doesn’t need to)

Generators must report any changes in generation status to the state (all 3)

Inspection requirements under RCRA?

How long do you keep the inspection reports?

Must inspect Satellite Accumulation Areas and Main Storage Accumulation Areas weekly for LQG and SQG

Keep inspections for 3 years

Record keeping requirements under RCRA? 4/5

The following records have to be kept for 3 years:

• Waste Analysis/determination records

• Manifests

• biennial reports

• exception reports

Also Land Disposal Restriction (LDR), which accompany HW manifests, must be maintained for 5 years

Important policy regarding DOT and hazardous waste?

Hazardous Material Transportation Act of 1975 (granted DOT authority to establish criteria for packaging, labeling, placarding, and shipping of HW)

Requirement for DOT Labels?

DOT Placards are 4 inch diamond shapes on 55 gallon jugs (a color specific sticker that designates hazard class of packed material) (for non-bulk containers less than 119 gallons/8821 lbs), also includes shipping name and ID# of substance in container (D001-D004)

Freight containers, vehicles, and bulk packages (like 18 wheelers) have 10.7 inch placards that are color-specific diamonds, 4 letter with number ID placed on each side and end of container/vehicle

Steps of the waste stream determination and documentation guidance?

1. make a list of all waste streams (document how many pounds of each waste stream generated each month)

2. Check if waste meets definition of solid waste (40 CFR)

3. Record how the analysis of the waste was made (methods, outside documentation for analysis like SDS sheet or an EHSRM-certified library)

4. Prepare a document that states whether or not the waste is hazardous (list applicable waste codes)

Maintain documentation of these 4 steps for 3 years from the last date the waste was shipped

What are the big 3 regulators of labs?

OSHA: Occupational Exposure to Hazardous Chemicals in Lab

HAZCOM (SARA Title I)

National Fire Protection Association (NFPA 45): Fire Protection for Labs

What does the Occupational Exposure to Hazardous Chemicals in Lab require? got the main one but there’s like 10 others

A chemical hygiene plan (a life cycle and how to do things right) for labs with hazardous chemicals, define responsibilities of individuals, addresses chemical handling, storage, inventory, exposure control, housekeeping, emergency procedures, trainings, and inspections

What does OSHA and the Texas Hazard Communication Act (HAZCOM) require?

What specific thing must be created?

It’s the right to know; To create a Hazard Communication Program (let workers/community know what chemicals are being used in the workplace); has list of chemicals and hazards associated with them, labels and GHS pictograms, SDS, etc.

Main sections of the chemical hygiene plan outlined in OSHA’s Occupation Exposure to Hazardous Chemicals in Lab? 3/4

1. Procurement

2. Storage area/stock room

3. transportation (in secondary containers)

4. Labels

What piece of equipment should be in a chemical storage area/stock room? Why?

Fume hood (for exhaust ventilation)

Labeling for hazardous materials/chemicals? ~2/3

Containers must be labeled with identity of chemical, hazard warning (pictogram), + name and address of manufacturer

Primary vs. secondary container? Alt def?

Primary: the container that is received directly from the manufacturer

Secondary: the container the primary container chemical is poured into (another definition: the second container a chemical is stored in, so primary container is placed in the secondary container)

When can chemicals be stored in alphabetical order in a lab?

When it is done within their segregated groups

Important step before storing a chemical in a lab? 1/2

Read the label and SDS

How are normal fridges different from lab fridges?

Lab fridges are intrinsically safe

What happens if you’re using a fume hood as a permanent storage location and some of the chemical evaporates out?

We accidentally became a TSDF because we treated the waste

Why shouldn’t flammable chemicals be stored in fridges?

Because has multiple ignition sources that could ignite vapors

What is the biggest hazard associated with compressed gas cylinders?

If the valve is damaged, the cylinder can become a projectile and can cause severe injuries

How to avoid hazards associated with compressed gas cylinders?

Always store upright (so not on the valve) and secure it with a proper chain/strap/stand, ensure valve is tightly closed, use smaller compressed gas cylinders if possible, leave the valve protection cap in place, also don’t roll them, and treat “empty” cylinders as full because we can never fully get all of the pressure out

What is an example of making something safer with engineering controls? Definition?

Fume Hoods (a partially enclosed workspace that is exhausted, in most cases, to the outside of the building)

What is the optimum airflow for a fume hood? What is it measured with?

What if airflow is too low/high?

80-120 feet per minute (measured with a venometer)

Too low/high: contaminants can escape

What are the different parts of a fume hood? 6/7

1. Hood body: what actually contains the hazardous gas and chemicals

2. Sash: sliding glass door/panel (12 to 18 inches)

3. Airfoil: bottom lip of the hood, leaves gap between sash and itself to leave a little air flow

4. Work Surface

5. Baffles: adjustable slates along the back of the hood body (helps keep airflow uniform across the slash opening)

6. Exhaust Plenum: helps keep airflow even across face of the hood

7. Face: plane that runs from bottom of sash to the work surface (where face velocity of the hood is measured)

Recommended working heights of the fume hood?

12 to 18 inches

Lab rules regarding fume hoods? 3/4

Don’t use for storage, make sure it’s on when in use, keep foot traffic at a minimum when in use, keep lab doors and windows shut

What does the certification of fume hoods involve?

An annual inspection which involves the measurement of the fume hood face velocity, and it must be done my a qualified individual

According to ANSI, how far should emergency showers/eye wash stations be?

No more than 10 seconds or greater than 100 feet from the hazard (so safety shower every 200 feet)

ANSI acronym?

American National Standards Institute

Requirements for eye wash stations?

Provide a gentle, continuous, low pressure flow of tempered aerated potable water at 0.4 gallons per minute for at least 15 minutes

How often should eye wash stations be activated? Why?

Once a week to flush lines

Issue with chewing gum in labs?

Gum can absorb chemicals

What is the general rule for training employees in labs? Exs of things they should be trained on? 3/6

Annually or when a new chemical in introduced

Exs: SDS info, lab safety, Hazcom, location of and how to use PPE, emergency procedures, location of and how to use fire extinguishers

THECB?

Texas Higher Education Coordinating Board

What is this Memo of Understanding between the TX DPS (Public Safety) and THECB?

Requires Higher Education to monitor stuff involving controlled substances and report any missing materials

What information should signs on lab doors have? 2/3

Room number, lab supervisors name, and emergency contacts

Where is the NFPA 704 placard typically located? 1/2

In a warehouse or storage area

What does a NFPA 704 placard look like?

How does it rate the hazards?

Just know the different numbers for flammability

A diamond with 4 colors (from the top, clockwise)

Red: flammability (1: above 200 F, 2: below 200, 3: below 100, 4: below 73; 0: will not burn)

Yellow: instability

White: special hazard

Blue: health hazard

1-4, 4 is the worst

GHS Placard aka? Describe how it looks.

Rating system?

HMIS placard; is a square

Health (blue)

Red (flammability)

Yellow (physical hazard)

White (PPE)

1-4, 1 is the worst

HMIS acronym?

Hazardous Material Information System

How effective is the Hepatitis B vaccine?

95%

What are universal precautions?

Things Bloodborne Pathogens can be present in (so there’s blood and OPIM: other potentially infectious materials - these are the universal precautions I think, so semen, saliva (if blood is present), body fluid, tissues, organs))

Different ways diseases are transmitted?

Inhaled, ingested, contact

Different pathogens of illnesses? 3/4

viruses, bacteria, fungi, parasites

Exs of illnesses caused by viruses?

AIDS, Hep B, flu, colds

Exs of illnesses caused by bacteria? 1/2

intestinal diseases and TB

Exs of illnesses caused by fungi? 2/4

asthma, allergies, athlete’s foot, farmer’s lung

Exs of illnesses caused by parasites? 1/3

malaria, giardiasis, trichinosis

The big 3 of BBP?

Hepatitis C, B, and HIV

How long can Hep B live for on dried blood?

7 days

What is a disease custodians and plumbers often get shots for?

Hep B

Most common chronic bloodborne infection in the US?

Hep C

Incubation period of HIV?

10-12 years

What is an Exposure Control Plan (which SFA has)?

A plan to eliminate/minimize your risk of exposure

Examples of equipment and safer medical devices for exposure controls of BBP? 2/3

Sharps disposal containers, ventilation hoods, needleless systems

Other group of exposure controls of BBPs?

Safe work practices (like not eating in dangerous work areas, placing food in fridge of work areas)

What can you use to clean chemicals? 1/2

Bleach and water

What is needed to clean blood?

Absorbent materials

What is the standards precautions rule?

Treat all body fluids as if they’re infectious

What is the proper color for biohazard bags?

Red/orange or red

Where is broken, contaminated glass disposed of if it was somewhere with bloodborne pathogens?

Cardboard boxes with biohazard label

Examples of regulated wastes? 2/3

Blood or OPIM

Contaminated sharps

Items caked with dried blood or OPIM

How many shots with Hep B Vaccine?

3

What are the two regulatory agencies for BBPs? ½

What do they deal with/regulate?

Texas Department of State Health Services (deals with biohazards)

TCEQ (Regulates the biohazard wastes)

What must you sign if you choose not to get the Hep B vaccine in the workplace?

Hepatitis B Vaccine Declination

SPCC acronym?

Spill Prevention Control and Countermeasures

Who regulates the SPCC?

EPA

Who must stamp a SPCC plan?

An engineer

SPCC purpose?

Prevent oil discharges from reaching navigable waterways, and ensure effective response to oil discharges