USC EH&S Hazardous Waste Training

Hazardous Waste training is an ANNUAL requirement Hazardous Waste training is an ANNUAL requirement. Please plan to attend this training again within one year of today’s date if you are still working in a lab and may be handling hazardous waste. Training options: Training class Online refresher 11/28/2018

Training Agenda Terminology Why we train? What is a WASTE? Selecting a Container Labeling Collecting Waste – Compatibility Check Storing Waste Inspecting Storage Area Requesting Waste Removal Hot Topics/Noncompliance 11/28/2018

Terminology Cont. Accumulation Areas- P-listed Chemicals- Labs Requirements: Must be near the site of accumulation Limitations: 55 gallons (total) of hazardous waste or one (1) quart of P-Listed Waste P-listed Chemicals- Acutely Toxic Chemicals Product Requirement of Empty bottles- 3x rinse/collect Contamination Risk 11/28/2018

Why we train Safety EPA Environmental Auditing – Common violations found at Colleges and Universities: 3. Failure to train 2. Improper labeling, unlabeled containers 1. Open containers 11/28/2018

Define WASTE… A waste is ANY solid, liquid or contained gaseous material that is beyond it’s expiration date OR is no longer viable for it’s intended purpose and is to be discarded. 11/28/2018

Types of Hazardous Waste Listed Hazardous Wastes F-listed – non-specific source wastes Example – Spent Acetone K-listed – specific-source wastes P-listed – pesticide, toxic organic and metal wastes U-listed – organic wastes 11/28/2018

Types of Hazardous Waste Characteristic Hazardous Waste Ignitability (flammable liquids and gases – flashpoint <140°F, oxidizers) Corrosive (pH  2, acidic, or pH  12.5, basic) Reactivity (air and water-reactive, produce toxic fumes) Toxicity (potentially threaten human or wildlife health) 11/28/2018

Empty Containers Regulated under 261.7 of the RCRA Regulations “RCRA Empty” Waste chemicals removed by normal means (pouring, pumping, aspirating, etc) No more than 1” of residue at bottom No more than 3% by weight of the total capacity (0.3% if container > 100 gallons) Compressed cylinders are not empty until pressure approaches atmospheric 3x rinse requirement for p-listed chemicals 11/28/2018

Container Selection By request, USC Environmental Health and Safety provides HDPE containers for the accumulation of hazardous waste. Container requests can be made through the Waste Database. Containers used to store HW must be kept closed unless waste being actively added 11/28/2018

Container Selection If you opt to store hazardous waste in a container not provided by USC EH&S, please follow these guidelines: 1. Check MSDS for container/waste compatibility 2. Make certain container is capable of closing and keep it closed except for when waste is added. 11/28/2018

Labeling Requirements Must have Federal/State statement…”If found, contact Hazardous Waste Manager at 777-5269, USC Police at 777-9111 or the SC Department of Health and Environmental Control. PI Name, Phone Number, Building and Room Number Chemical Identity – NO Trade Names or Chemical Formulas, ONLY Technical Names 11/28/2018

USC Pre-Printed Labels Belinda Gravel 7-5269 306 Benson Ethanol 35 Tetrahydrofuran 25 Water 40 LEAVE BLANK 10 L 10L Carboy 6.8 11/28/2018

Waste Collection Check MSDS for chemical compatibilities Commingling waste is NOT recommended, however if this is your chosen method 1. Separate Acids from Bases, Organics from Oxidizers and Organics from Acids 2. Test Compatibility in Small Quantities prior to pouring off. 11/28/2018

Housekeeping Please ensure that all waste is handled cautiously. Spills must be cleaned up immediately. Spill materials that are contaminated with hazardous waste must be handled as hazardous waste. It is not the responsibility of custodial staff to clean up chemical spills!! . 11/28/2018

Inspecting Storage Area Consistently check laboratory hazardous waste storage areas for the following: 1. Container labels and their accurate completion, 2. Closed containers, 3. Bulging containers, 4. Cracked containers, 5. Spills and Housekeeping. 11/28/2018

Maintenance and Modifications in Laboratories Maintenance – It is the PI and laboratory personnel’s responsibility to ensure that maintenance personnel are working in a safe, chemical free environment. Modifications in lab Plumbing Hood Other 11/28/2018

Glove Disposal If gloves are contaminated with a hazardous waste they must be disposed of as a hazardous waste. Laboratory personnel should use their best judgment and knowledge of their laboratory processes to determine whether gloves have become contaminated. 11/28/2018

Cylinder Management Cylinders are a DOT Hazardous Material. Leaking Cylinders must be repaired or replaced immediately. Do not ship any cylinder which is leaking. Hydrogen Sulfide Example USC Cylinder Vendors: National Welders/Airgas, Praxair. Please inventory all of the cylinders in your laboratory (> lecture size) and create a list of those that are not owned by one of the vendors above. Recycling/Reuse Opportunity

Shipping Hazardous Materials The shipment of hazardous materials is heavily regulated. Any person who ships a hazardous material must be trained and certified to do so. You Must contact Jeff Brannon or other trained EH&S personnel at 777-5269 for chemical shipping information or to initiate a shipment. 11/28/2018

Shipping, con’t. Due to Dept. of Homeland Security restrictions, the University of South Carolina is prohibited from shipment of the following chemicals: Acetone cyanohydrin, stabilized Lithium nitride Potassium phosphide Aluminum phosphide Magnesium phosphide Sodium cyanide Calcium phosphide Methyldichlorosilane Sodium phosphide Chloroacetyl chloride Phosphorus pentasulfide Strontium phosphide Diphenyldichlorosilane Phosphorus trichloride Trichlorosilane Lithium amide Potassium cyanide If you need to ship one of the above chemicals please contact EH&S Personnel at 803-777-5269. 11/28/2018

In Case of Emergency Campus Emergency Number 777-9111 EH&S 777-5269 Fire – is it too big? Proper extinguisher? Chemical Spill Is it too big? Known vs. unknown? Bodily Injury 11/28/2018

Logging in to the Waste Database https://webapps.csg.sc.edu/hwaste/ 11/28/2018

Logging in to the Database Update personal information if necessary. 11/28/2018

Requesting Lab Assignment Click on the “Lab Assignments and Lab Update” in the garnet column on the left of the page. The labs that you are currently associated with will be listed under “Current Assignments” 11/28/2018

Requesting a lab assignment Enter the lab that you will be associated with. In the example below Benson 308A was entered. 11/28/2018

Requesting a Waste Pickup Click on Hazardous Waste Disposal Requests Update 11/28/2018

Hot Topics Old “Crusty, Dusty & Rusty” chemicals Waste Minimization failure to make a waste determination 40CFR 261.2 (solid waste determination) 40CFR 262.11 (hazardous waste determination) Waste Minimization Do not mix hazardous materials with non-hazardous materials Broken Fluorescent Bulbs are considered Hazardous Waste and must be handled accordingly! 11/28/2018

Examples of Improperly Stored Hazardous Waste Waste containers were stored under a fume hood. Many containers were not labeled or improperly labeled and open. Incompatible waste were stored together under the hood. If found by an EPA/SCDHEC inspector the violation would be: Improperly label container Failure to segregate incompatible material Open Containers Release of hazardous material into the environment 11/28/2018

Consequences of Noncompliance In accessing a violation, EPA/DHEC considers: Deviation from Regulation Potential Harm to Human Health and the Environment Possible civil enforcement action. Up to $25,000 per violation per day penalty. Possible criminal enforcement action. If your Department is sent to enforcement and receives a civil penalty your Department will be responsible for paying the fine. 11/28/2018

and FINALLY… Please visit the USC EH&S website @ https://sc.edu/ehs If you have any questions or need any additional information, please contact Jeff Brannon University of South Carolina Hazardous Waste Manager brannonm@mailbox.sc.edu (803) 777-5269 office (803) 777-5275 fax 11/28/2018