HARVARD INSTITUTES OF MEDICINE/NEW RESEARCH BUILDING HAZARDOUS WASTE TRAINING For Laboratory Personnel

ENVIRONMENTAL, HEALTH, & SAFETY (EH&S) OFFICE Office information: phone fax STAFF: Christopher Neal Jessica Sgrignuoli Daniel Colasante WEBPAGE:

TRAINING AGENDA Regulatory Requirements Regulatory Requirements Hazardous Waste Definition Hazardous Waste Definition Container Requirements Container Requirements Labeling Requirements Labeling Requirements Satellite Accumulation Area Satellite Accumulation Area SAA Contact Responsibilities SAA Contact Responsibilities Waste Removal Waste Removal MWRA Requirements MWRA Requirements Summary Summary

REGULATORY REQUIREMENTS 40 Code of Federal Regulations (CFR) Code of Federal Regulations (CFR) Chemical Waste Management Chemical Waste Management Emergency Response Emergency Response 310 Code of Massachusetts Regulations (CMR) Code of Massachusetts Regulations (CMR) Definition of Hazardous Waste Definition of Hazardous Waste Labeling Requirements Labeling Requirements Satellite Accumulation Areas Satellite Accumulation Areas Training Training Emergency Response Emergency Response Governing Agencies Governing Agencies Environmental Protection Agency (EPA) Environmental Protection Agency (EPA) Massachusetts Department of Environmental Protection (DEP) Massachusetts Department of Environmental Protection (DEP)

REGULATORY REQUIREMENTS (continued) Resource Conservation and Recovery Act (RCRA) Resource Conservation and Recovery Act (RCRA) Required to maintain records from generation to disposal (“Cradle to Grave”) Required to maintain records from generation to disposal (“Cradle to Grave”) Covers collection, storage, transportation, and disposal Covers collection, storage, transportation, and disposal EPA has the responsibility for the creation and enforcement of the regulations EPA has the responsibility for the creation and enforcement of the regulations Unannounced Inspections: Unannounced Inspections: Harvard University (EPA Spring 1999) Harvard University (EPA Spring 1999) MGH (EPA May 1998, DEP) MGH (EPA May 1998, DEP) BWH (DEP Summer 1999) BWH (DEP Summer 1999) HIM/NRB BIDMC (DEP November 2005) HIM/NRB BIDMC (DEP November 2005)

REGULATORY REQUIREMENTS (continued) Inspectors consider containers with the following as hazardous waste: Inspectors consider containers with the following as hazardous waste: Displaying word “Hazardous Waste” Displaying word “Hazardous Waste” Showing signs of aging Showing signs of aging Are rusted Are rusted Are expired Are expired Are no longer in use by the laboratory Are no longer in use by the laboratory

REGULATORY REQUIREMENTS (continued) Fines are extensive but dependent on extent of deviation and potential for harm Fines are extensive but dependent on extent of deviation and potential for harm EXTENT OF DEVIATION FROM REQUIREMENT MAJORMODERATEMINOR MAJOR $22,000 to $27,500 $16,500 to $21,999 $12,100 to $16,499 MODERATE $8,800 to $12,099 $5,500 to $8,799 $3,300 to $5,499 MINOR $1,650 to $3,299 $550 to $1,649 $110 to $549 POTENTIAL FOR HARM

HAZARDOUS WASTE DEFINITION Waste can be divided into five categories: Waste can be divided into five categories: Ignitable Ignitable –Liquids with a flash point of 140°F (60°C) or less –Solids that may cause fire through friction or the adsorption of moisture –Oxidizers: Liquids and Solids Corrosive Corrosive –Strong acids and bases with a pH less than or equal to 2.0 or greater than or equal to 12.5 Reactive Reactive –Unstable, reacts violently with water, explosive, or products toxic gases when mixed with water or acid

HAZARDOUS WASTE DEFINITION (continued) Waste categories (continued): Waste categories (continued): Toxic Toxic –Can leach toxic chemicals as determined by a special laboratory test –Listed on EPA’s P-list Non-Hazardous Non-Hazardous –Does not meet the definition of the other four categories A mixture is hazardous waste if any part of the mixture is considered hazardous waste A mixture is hazardous waste if any part of the mixture is considered hazardous waste

HAZARDOUS WASTE DEFINITION (continued) Ways to determine the hazard category for a chemical: See if chemical is listed on: See if chemical is listed on: EPA’s U-List: Hazardous Waste EPA’s U-List: Hazardous Waste EPA’s P-List: Acutely Hazardous Waste EPA’s P-List: Acutely Hazardous Waste Refer to “Hazards Associated with Commonly Collected Chemicals at HIM/NRB” Refer to “Hazards Associated with Commonly Collected Chemicals at HIM/NRB” Material Safety Data Sheet Material Safety Data Sheet NFPA Diamond for Chemical NFPA Diamond for Chemical Conduct a pH Test Conduct a pH Test Call HIM/NRB EH&S Office at Call HIM/NRB EH&S Office at

CONTAINER REQUIREMENTS Hazardous Waste Containers MUST: Be compatible with waste Be compatible with waste Have original label defaced Have original label defaced Remain sealed when not adding waste Remain sealed when not adding waste Stored in secondary containment bin Stored in secondary containment bin Have a completed hazardous waste label Have a completed hazardous waste label Have only one container per waste stream Have only one container per waste stream

LABELING REQUIREMENTS Chemical Waste must be labeled with a tag as the waste is being collected. Waste tags must: 1. Declare “Hazardous Waste” 2. Have contents listed with no abbreviations including chemical abbreviations 3. Have applicable hazards checked off 4. Dated only when full

LABELING REQUIREMENTS What specific problems can you find with this waste label?

SATELLITE ACCUMULATION AREA (SAA) SAAs should be: SAAs should be: In a low traffic area In a low traffic area At or near a point of generation of the waste At or near a point of generation of the waste Away from sinks and floor drains Away from sinks and floor drains NOTE: We recommend placing it in fume hood

SAA (continued) SAA Requirements: All waste must be in secondary containment All waste must be in secondary containment A red SAA sign with the SAA contact information on it A red SAA sign with the SAA contact information on it A telephone in the vicinity A telephone in the vicinity The SAA Must be inspected on a weekly basis The SAA Must be inspected on a weekly basis

SAA CONTACT RESPONSIBILITIES Know the applicable rules and regulations. Refer to the EH&S web page under Waste Disposal tab and Fact Sheets tab Know the applicable rules and regulations. Refer to the EH&S web page under Waste Disposal tab and Fact Sheets tab Work in the laboratory Work in the laboratory Be familiar with: Be familiar with: Characteristics of the waste Characteristics of the waste The operations generating the waste The operations generating the waste Inspect SAA on a weekly basis Inspect SAA on a weekly basis NOTE: REFER TO THE RED SIGN POSTED AT SAA FOR INSTRUCTIONS

WASTE REMOVAL For Full Containers Date label when container becomes full, or no longer used by laboratory Date label when container becomes full, or no longer used by laboratory Go to Hazardous Waste Work Order Webpage. Here is the information: Username: EH&S Password: HazWaste1 Go to Hazardous Waste Work Order Webpage. Here is the information: Username: EH&S Password: HazWaste1 Call to request a chemical waste pickup. Call before noon the day before the pickup. Call to request a chemical waste pickup. Call before noon the day before the pickup. Include name, building, room number, quantity of containers or bottles, and type of waste (ethanol, acetone etc.) Include name, building, room number, quantity of containers or bottles, and type of waste (ethanol, acetone etc.) Waste is picked up on Mondays and Thursdays Waste is picked up on Mondays and Thursdays NOTE: NEVER MARK A CONTAINER UNKNOWN

WASTE REMOVAL (continued) Waste from the SAA is transported to the Main Accumulation Area (MAA) within HIM/NRB Waste from the SAA is transported to the Main Accumulation Area (MAA) within HIM/NRB The hazardous waste subcontractor picks up the hazardous waste from the MAA The hazardous waste subcontractor picks up the hazardous waste from the MAA The waste is transported to an off- site facility for one of the following disposal methods: The waste is transported to an off- site facility for one of the following disposal methods: Fuels blending Fuels blending Incineration Incineration Landfill Landfill

WASTE REMOVAL (continued) The waste hauler WILL NOT accept the following: Biohazardous Waste Biohazardous Waste Infectious Waste Infectious Waste Waste packaged in Red Biohazardous Bags Waste packaged in Red Biohazardous Bags Waste displaying the Biohazardous Symbol Waste displaying the Biohazardous Symbol Radioactive Waste Radioactive Waste Radioactive and Chemical Waste Radioactive and Chemical Waste

WASTE REMOVAL (continued) For chemical and radioactive waste: For chemical and radioactive waste: Please contact Harvard University’s Radiation Safety Office at Please contact Harvard University’s Radiation Safety Office at For biological and chemical waste: For biological and chemical waste: Render the biological component non- infectious (add 10% bleach) Render the biological component non- infectious (add 10% bleach) Dispose of as chemical waste Dispose of as chemical waste

MWRA REQUIREMENTS The Massachusetts Water Resource Authority (MWRA) issued the facility a Sewer Use Discharge Permit to enable the HIM/NRB facility to discharge into Boston’s sanitary sewer. The Massachusetts Water Resource Authority (MWRA) issued the facility a Sewer Use Discharge Permit to enable the HIM/NRB facility to discharge into Boston’s sanitary sewer. In order to ensure compliance with the permit, the following are prohibited from being dumped down the drain: In order to ensure compliance with the permit, the following are prohibited from being dumped down the drain: Volatile Organic Compounds (solvents, formaldehyde, alcohols) Volatile Organic Compounds (solvents, formaldehyde, alcohols) Strong Acids and Bases Strong Acids and Bases Heavy Metals – Mercury-containing materials Heavy Metals – Mercury-containing materials Oils – Fuel, lubricating, cruel Oils – Fuel, lubricating, cruel Waste water with pH lower than 5.5 or higher than 12.0 Waste water with pH lower than 5.5 or higher than 12.0 NOTE: NEVER PUT ANY CHEMICALS DOWN THE DRAIN

SUMMARY OF TOPICS Know the waste in your laboratory’s SAA Conduct weekly inspections Check the labels Ensure that full containers are dated then removed within three (3) days Ensure that there is only one container per waste stream or chemical Ensure containers remain sealed unless adding waste to the container