Welcome to Marquette University’s Hazardous Waste and Emergency Procedures Awareness Training

Why am I here? Handle or generate hazardous materials Formal personnel training program is a requirement for large quantity generators (49 CFR 265.16) To be trained on the proper procedures of accumulating and storing hazardous materials to ensure compliance with the law To prevent personal injury, property damage, or a major spill

Agenda Marquette’s Generator Classification Hazardous Waste Characteristics Globally Harmonized System (GHS) Classification and Labeling of Chemicals Handling Hazardous Materials & Proper Personal Protective Equipment Satellite Accumulation Procedures Spill Response, Clean-Up, Emergency Response and Preparedness

Acronyms EPA = Environmental Protection Agency Determines what is a hazardous waste Governs hazardous waste regulations DOT = Department of Transportation Regulates transportation of hazardous materials RCRA = Resource Conservation & Recovery Act Standard for the disposal of solid and hazardous wastes DNR = Department of Natural Resources Governs over the generators of hazardous waste at the state level OSHA = Occupational Safety and Health Administration Regulates hazardous materials in the workplace PPE = Personal Protective Equipment Last line of defense against hazardous materials

Marquette’s Classification

Three Categories of Generators Very Small Quantity Generator (VSQG) < 220 lbs/month generation or < 2205 lbs total accumulation Small Quantity Generator (SQG) 220 - 2205 lbs/month generation or < 13,230 lbs total accumulation Large Quantity Generator (LQG) > 2205 lbs generation/month or > 13,230 lbs total accumulation Acute Waste >2.2 lbs/month generation or > 2.2 lbs accumulation at any time makes you a LQG

How much is that? 2200 lbs. (1000 kg) is about five 55-gallon drums

Hazardous Waste Determination Characteristic versus Listed Wastes

Hazardous Waste Determination EPA Listed Wastes P Listed: Unused acutely Hazardous Waste U Listed: Unused non-acutely hazardous waste K Listed: Waste from Specific Sources F Listed: Waste from Non- Specific Sources Characteristic Wastes Ignitability Corrosivity Toxicity Reactivity

Ignitable Wastes Flashpoint <140° F, or solids that easily catch fire. Examples: acetone, xylene, and acetonitrile and other solvents Compressed flammable gases, such as propane Flammable solids, such as road flares or carbon .

Corrosive Wastes - pH <2 or >12.5 - Capable of corroding steel at a rate greater than 0.25 inches per year. Examples: nitric acid, aqueous sodium hydroxide, hydrochloric acid. Potassium Tert-butoxide, a flammable solid

Materials that undergo violent change: Reactive Wastes Materials that undergo violent change: - react violently with water or air - capable of detonation - create toxic gases when exposed to pH extremes Examples: sodium metal, extremely dry picric acid, and organic peroxides.

Materials that are poisonous, harmful and potentially deadly Toxic Wastes Materials that are poisonous, harmful and potentially deadly Examples: lead acetate, mercuric chloride, benzene.

Examples of Toxic Contaminants Organics, continued: cresol, 1,4-dichlorobenzene, 1,2-dichloroethane, 1,1-dichloroethylene, 2,4-dinitrotoluene, hexachlorobenzene, hexachlorobutadiene, hexachloroethane, methyl ethyl ketone, nitrobenzene, pentachlorophenol, pyridine, tetrachloroethylene, trichloroethylene, 2,4,5-trichlrophenol, 2,4,6-trichlorophenol, vinyl chloride. Heavy Metals: arsenic, barium, cadmium, chromium, lead, mercury, selenium, silver Pesticides: Chlordane, 2,4-D, Endrin, Lindane, Heptachlor, Methoxychlor, Silvex (2,4,5-TP), Toxaphene. Organics: benzene, carbon tetrachloride, chlorobenzene, chloroform,

Contact Dennis Daye (414) 288-8411 if you have questions about the status of your waste. Hazardous Waste Management can be very confusing and we are here to help you! Steve Sprung, Veolia Environmental Services On campus Wednesday from 1-4 PM

Globally Harmonized System (GHS) & Recognizing Hazardous Materials

What is the GHS? A common and coherent approach to defining and classifying hazards, and communicating information on labels and safety data sheets. (Revision to OSHA’s Hazard Communication Standard 1910.1200)

Globally Harmonized System (GHS) OSHA’s Globally Harmonized System for Classification and Labeling of Chemicals (GHS) Increase international trade Container labeling standardization Chemical classification standardization International Chemical Safety Standard Effective Dates: 12/1/13: All employees must be trained on new label elements and SDS format 6/1/15: Manufacturers and distributors must comply with all modified provisions except that distributors have until 12/1/15 to provide revised labels for all products shipped. 6/1/16: OSHA enforcement starts: Employers must update all labels and HazCom program, provide additional training for workers on newly identified physical or health hazards During transition period, employers can comply with old or new standard as far as labels and SDSs.

Recognizing Hazardous Materials - Read Safety Data Sheet (SDS)

http://cispro.mu.edu/

Container Labeling

National Fire Protection Association (NFPA) Label Colors and numbers are used to communicate the potential hazards of a material. Flammability Hazard Health Hazard Reactivity Hazard Specific Hazards

Chemical Container Labeling 4 = Severe 3 = Serious 2 = Moderate 1 = Slight 0 = Minimal HMIS Label: Hazardous Materials Identification System NFPA Label: National Fire Protection Association Number Health Hazard Fire Hazard Reactivity Hazard PPE 4 Deadly Very Flammable May Detonate Personal Protective Equipment Recommendations 3 Extremely Dangerous Readily Ignitable Shock and Heat May Detonate 2 Hazardous Ignited with Heat Violent Chemical Change 1 Slightly Hazardous Combustible Unstable if Heated Normal Materials Will Not Burn Stable * Chronic Hazard ____________ __________

New Label Requirements GHS Label Workplace Label Updated OSHA GHS Standard Product identifier Signal word Hazard statements Precautionary statements Pictograms Supplier information Supplemental information Current OSHA Standard Material identity Hazard warnings PPE Supplier information

DOT Labels

Brady Label Printer Wehr Life Sciences # 206 Secondary Container Label

Hazardous Material Handling and Proper Personal Protective Equipment

Considerations when Handling Hazardous Materials Use common sense! Think before you act Follow good housekeeping procedures Clean-up after yourself Always wear the proper PPE Know the hazards of the materials you are working with! Create and use chemical specific SOP’s (Safe Operating Procedures)

Controlling Hazards (Hierarchy of Controls) Material Handling and Proper PPE Controlling Hazards (Hierarchy of Controls) Elimination Substitution Engineering Controls Remove the hazard or place a barrier between the worker and the hazard 2. Administrative Controls Limit worker contact with the hazard Training/Procedures, Good Housekeeping 3. PPE LAST RESORT Engineering and administrative controls should be used, but do not completely alleviate the hazard

PPE = Last Resort When PPE is the primary control measure, the hazard is still present in the environment Failure of the PPE or improper usage can expose the worker to the full effect of the hazards present in the environment

Glove Selection Chemical Resistance Guide

Satellite Accumulation Procedures

Satellite Accumulation “A generator may accumulate as much as 55 gallons of hazardous waste…in containers at or near any point of generation…which is under the control of the operator…” Up to 1 quart of acutely hazardous waste (P-coded) can be collected in a satellite accumulation area Your research labs, student labs or other rooms where materials are collected and accumulated are considered to be Satellite Accumulation Areas

Good Management – labeled, dated, contained

Satellite Accumulation Material name must be on label – NO CHEMICAL FORMULAS OR ABBREVIATIONS!!! The container must have the words “hazardous waste” Container Management: Containers must remain closed when not adding waste Must be leak-proof and in good condition Containers must be compatible with contents No corrosive materials in metal containers Store liquid wastes in secondary containers Must be able to hold 110% of the largest containers volume Containers must be moved to storage location within 3 days after being filled Free access to containers must be maintained at all times. The containers must remain closed when waste is not being added or removed The containers must be leak-proof and in good condition The containers must be compatible with contents The containers must be moved to storage location within 3 days after being filled*** The accumulation start date is the day the container is filled – not the day you first add material into the container.

Example of Inadequate Labeling

Example of Inadequate Labeling

Supplies Provided by EH&S Labels & Forms Containers Secondary Containment

11/05/08 Olin Engineering 126 1 1 Jon Pipkorn Toluene Liquid 4 L 2 L Glass 1

Your Responsibilities You must fill out an inventory of material generated or discarded and send it to Dennis State and Federal Regulations State: “The identity and location of all stored hazardous waste shall be known throughout the entire accumulation period.” To maintain documentation of hazardous waste that is currently being stored, in case of an emergency Makes waste shipment easier Aids in determining waste generation rate Helps identify waste minimization opportunities Please fill out sheet for materials to be disposed of on a regular basis Inspect your work area to ensure proper procedures and practices are being followed

Spill Response, Clean-Up, and Emergency Response

Please reference the Marquette University Emergency Procedures Guide and Contingency Plan for further details on what to do in case of an emergency.

Causes of chemical spills are as follows: Causes of a Spill Causes of chemical spills are as follows: Inappropriate handling techniques; Inappropriate storage containers; Damaged storage containers; Uncontrolled access to chemical storage; Lack of chemical-related training; and Lack of supervision.

Spill Prevention Planning Only buy and store amount of material needed Buy the least hazardous materials possible Use non-hazardous materials when possible Minimize traffic in the area Store liquid wastes in secondary containers Regularly inspect containers to ensure their integrity Be aware of evacuation routes and emergency equipment

Managing A Spill What type and size of spills am I capable of managing? You should only be cleaning up small spills (less than 1 gallon) of known materials that you work with on a regular basis after you have had attended a training session given by the EHS department. Small spill clean-up kits are located in the 90-day storage area and in “all” laboratories. Notify the Marquette Police Department (x8-1911) for larger spills, or spills containing reactive or highly toxic materials. Marquette Police will notify the proper authorities.

Spill Kits These spill kits contain everything you need to properly manage a small spill in your labs. These are available from EH&S. Please contact Dennis Daye to place an order.

What to do when an emergency occurs… TAKE CARE OF THE SAFETY OF YOURSELF AND OTHERS! Activate the building’s fire alarm system. If you have bodily contact with material: immediately remove any contaminated clothing flush the area with copious amounts of water Call Marquette Police at 288-1911 Identify yourself and why you are calling Identify the exact location and nature of the emergency Identify any injuries of symptoms involved Identify all hazardous materials involved (if known)

ALWAYS CALL 288-1911 ON CAMPUS TO This is a general awareness training. You are not trained as an emergency responder and should not attempt to manage emergencies. Emergency agencies such as the Fire Department, Police Department and Haz Mat Response Teams will be responsible for situations other than easily contained spills or incidental situations. ALWAYS CALL 288-1911 ON CAMPUS TO REPORT AN EMERGENCY

Training Database

Questions or Suggestions? Feel free to contact Dennis Daye (414) 288-8411 or Steve Sprung steve.sprung@Veolia.com with questions, concerns, or suggestions.

Thank you for participating in Hazardous Waste Generator Requirements Training