The Sentinel Event During a routine annual hazardous waste management inspection by the Hazardous Waste Section of NC DENR, violations in laboratory practices were identified, citations were issued, and an administrative penalty was assessed. As part of the Consent Order, Duke agreed to develop a laboratory chemical waste management practice.

The Sentinel Event During the inspection, the following violations were noted: Duke failed to make waste determinations for waste generated in some labs. Waste was stored in a defective container and not transferred to a container in good condition. Certain wastes were not properly marked with the words “Hazardous Waste” or “Waste Chemical”. Wastes were stored in open containers. This informational presentation will familiarize you with the requirements of the Laboratory Chemical Waste Management Practice. Once you have read through the practice, please contact OESO EP with any question you may have.

Laboratory Chemical Waste Management Practices Occupational and Environmental Safety Office Environmental Programs Division

Purpose / Background Research, teaching and clinical laboratories produce a variety of waste chemicals that may be subject to regulatory management standards. If improperly managed in the laboratory, waste chemicals could pose a risk to human health and the environment.

Purpose / Background Laboratory chemical wastes are regulated by the Environmental Protection Agency and the North Carolina Department of Environment and Natural Resources The Occupational and Environmental Safety office is tasked with ensuring that all laboratories understand and comply with these regulations

Scope This practice applies to all teaching, research, and clinical laboratories at Duke University, Duke University Medical Center, and Duke University Health Systems

Procedures Any laboratory that will generate waste chemicals must obtain a generator ID by registering with the Occupational and Environmental Safety Office Environmental Programs Division (OESO EP) prior to beginning processes that will generate chemical waste Waste chemicals generated in a laboratory must be managed in accordance with the following procedures

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 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 OESO EP will provide pre-printed labels for laboratories

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 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.

Container Labeling and Marking 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.)

Unknown Chemicals 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.

Removal of Unknown Chemicals Chemicals identified by the laboratory as an unknown must be removed from the laboratory no later than 30 days after being designated as no longer needed.

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 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

Improper labeling and storage of a waste chemical Open when not in use/ funnel left in container Unlabeled container No secondary containment

Correct labeling and storage of a waste chemical

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.

Improper labeling and storage of a HPLC waste chemical Open Container Unlabeled container No secondary containment

Correct labeling and storage of a HPLC waste chemical

Container Management 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.

Laboratory Shutdowns or Closeouts Whenever a laboratory is shut down or closed out the principal investigator must insure that all waste chemicals are properly identified and labeled so that they can be removed. Laboratory closeout procedures can be found in section 5 of the Laboratory Safety Manual at: http://www.safety.duke.edu/SafetyManuals/LabManual/index.htm

Roles and Responsibilities Principal Investigators, Laboratory Directors Principal Investigators or Laboratory Directors are responsible for insuring that these practices are implemented in the laboratory. They may choose to assign or designate a laboratory waste manager to implement this practice

Roles and Responsibilities Laboratory Waste Manager Laboratory waste managers are responsible for insuring that all processes generating chemical wastes comply with these practices on a day to day basis.

Roles and Responsibilities OESO EP OESO EP will provide support and oversight to the laboratories through education, training, routine assessments of laboratory performance, and timely removal of chemical wastes from the laboratory.

Chemical Waste How do we get waste picked up? First you must determine - Are you or your group registered generators? If no, call 684-2794, ask for chemical waste personnel and request set up as a generator. You will receive a packet of information containing your generator ID number, labels, barcode labels, and a waste pick up request form. If yes, Place one barcode label on the waste container. Place the matching barcode label on the pick up request form. Fill out the chemical description and container size that corresponds to that barcode number. Repeat the above steps for additional waste containers.

Chemical Waste Fax (684-2422) or email (env.programs@mc.duke.edu) the completed form to OESO EP. Once OESO EP receives a request, it will be entered into our database and the waste will be picked up within 5 business days. A member of OESO EP will contact your lab if there is a problem with the pick up request. A summary of the waste pick up process can be found at OESO EP General Guidance for Chemical Waste Pickups.

Environmental Programs Division Questions / Concerns A copy of the Laboratory Chemical Waste Management Practice can be found here. Any other inquiries: Environmental Programs Division Box 3914 684-2794 env.progs@mc.duke.edu www.safety.duke.edu