1. USC EH&S Hazardous Waste Training

2. 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

3. 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
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4. 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
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5. 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
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6. 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.
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7. 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
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8. 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)
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9. 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
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10. 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
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11. 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.
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12. Labeling Requirements
Must have Federal/State statement…”If found, contact Hazardous Waste Manager at , USC Police at 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
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13. USC Pre-Printed Labels
Belinda Gravel
7-5269
306 Benson
Ethanol
Tetrahydrofuran
Water
LEAVE BLANK
10 L
10L Carboy
6.8
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14. 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.
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15. 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!! .
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16. 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.
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17. 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
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18. 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.
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19. 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

20. 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 for chemical shipping information or to initiate a shipment.
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21. 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
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22. 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
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23. Logging in to the Waste Database
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24. Logging in to the Database
Update personal information if necessary.
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25. 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”
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26. Requesting a lab assignment
Enter the lab that you will be associated with. In the example below Benson 308A was entered.
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27. Requesting a Waste Pickup
Click on Hazardous Waste Disposal Requests Update
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28. Hot Topics Old “Crusty, Dusty & Rusty” chemicals Waste Minimization
failure to make a waste determination
40CFR (solid waste determination)
40CFR (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!
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29. 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
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30. 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.
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31. 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
(803) office
(803) fax
11/28/2018