Hazardous Materials & Hazardous Waste Training

Hazardous Materials & Hazardous Waste Training

September 10, 2008

Drug & Laboratory Disposal, Inc.331 Broad Street

Plainwell, MI 49080

There are many training requirements with which to comply under various

Federal regulations.

EPA, DOT & OSHAare the primary agencies that enforce

specific training requirements related to management of hazardous waste.

Provides a systematic approach to managing hazardous waste

EPA – Environmental Protection

Agency

Regulates hazards during transportation

DOT – Department of Transportation

OSHA –Occupational Safety and Health

Administration

Regulates workplace conditions and practices

EPA Training Requirements

40 CFR 262.34 (d)(5)(iii)Hazardous waste management

RCRA in 1976

Anyone who could cause non-compliance at a facility

Anyone with duties which ensure the facility’s compliance

Annual review of written training plan

EPA Training Requirements

Must include job-specific waste management procedures

Must be completed within 6 months of assignment to the facility

Must have supervision until trained

Training must be reviewed annually

EPA Training Requirements

DOT Training Requirements

49 CFR 172.700; 173.1 (b)Hazardous materials transportation

Employees who directly affect transportation safety

Repeated at least every 3 years

Change in rules requires additional training.

DOT Training Requirements

General awareness

Function-specific training

Security training

Safety training

DOT Training Requirements

Must include test and be kept for 3 years

Training completed within 90 days of employment, during which they may not work with hazardous materials unless under supervision of trained and knowledgeable employee

DOT Training Requirements

OSHA Training Requirements

29 CFR 1910.1200(h)Hazardous chemicals

workplace safety

Any employee who could be exposed to any physical or health hazard

Recognize hazards and protect employees from hazards through proper communication

Establish a written hazardous communication program

OSHA Training Requirements

Must be trained how to work with hazardous chemicals to prevent illnesses, injuries, or death

Must include container management techniques, safe chemical use, proper protective equipment use, and spill response training

OSHA Training Requirements

Labels on incoming containers of hazardous chemicals

Have MSDS readily accessible for each work shift

For waste shipment, have containers labeled

Initial training and whenever new physical or health hazards are introduced

OSHA Training Requirements

Most important; everything hinges on generator knowledge, materials, and processes used.

What is it and is it a hazardous material

Must determine the type of hazard and the degree of hazard

We need to know the physical and chemical properties.

-Physical state (liquid, solid, gas)-Flashpoint or boiling point-Will it kill people (toxicological effect)-What does it do to your skin-Is it reactive to air, water, other chemicals-Is it radioactive

Get information from:

MSDS

Text books

Manufacturer’s data

Analytical results

3 ways to become a hazardous material:

Meets a hazard class definition from 1 – 8

The DOT says so with a “+” entry

Miscellaneous class 9

Hazard class definitions

Hazard class definitions

The DOT says so with a “+” entry

About 50 chemicals from a list of 3000

Must be shipped under this classification

Examples: phenol, magnesium arsenate

Miscellaneous Class 9

If it doesn’t meet a hazard class and meets one of the following;

It has airplane hazards (Crew safety)

It is a hazardous waste (EPA number)

Marine pollutant Separate list by DOT

Elevated temperature material Molten or hot

Forbidden materials

May not legally be offered for transportation or transported

Usually have to meet specific conditions for safety before transportation

Determine the degree of hazard:

PGI indicates greater danger

PGII indicates medium danger

PGIII indicates minor danger

Indicated by packing group, used in packaging the material

Some hazard classes don’t have packing groups. (2, 7)

Not safe to over classify. (responders and employees safety)

Division 3 Packing GroupsPacking Group Flash Point Initial Boiling Point

I   ≤ 35°C (95°F)

II ≤ 23°C (73°F) > 35°C (95°F)

III ≥ 23°C (73°F) but ≤ 60.5°C (141°F) > 35°C (95°F)

Division 6.1 Packing Groups

Packing Group

Oral toxicity LD50 (mg/kg)Dermal toxicity LD50

(mg/kg)

Inhalation toxicity by dusts and mists

LC50 (mg/L)

I ≤ 5 ≤ 40 ≤ 0.5

II > 5 but ≤ 50 > 40 but ≤ 200 > 0.5 but ≤ 2

III solids: > 50 but ≤ 200; liquids: > 50 but ≤ 500 > 200 but ≤ 1000 > 2 but ≤ 10

A material may meet the defining criteria for more than one hazard class but is assigned to only one hazard class.

Lots of chemicals are toxic.

Select from column 2

Be accurate

Be specific (technical names, chemical family, end use, n.o.s. use)

Waste characteristics and waste code numbers

-Characteristic D codes

-F listed solvents

-P & U toxic waste codes

-Act 451 industrial liquid codes

Characteristic D Codes

D001 Ignitable waste code

D002 Corrosive waste code

D003 Reactive waste code

D004 – D011 Toxic heavy metals waste codes

D012 – D043 Toxic organic codes

F Listed Solvents

F001 - Used in degreasing (6 solvents)

F002, F003, F004, F005 - Spent Solvents (28 solvents)

Examples: methanol, xylene, methylene chloride

P & U Toxic Waste Codes

Commercial chemical products – pure

P codes - acutely toxic

U codes – toxic

Examples: nickel cyanide, bromoform

Act 451 Industrial Liquid Codes

Act 451 Part 121 liquid industrial wastes

Not EPA waste codes

Can be DOT shipping name

Examples: Antifreeze, crankcase oil

Act 451 Codes

Mixed Solvents (Solvent Solutions) 007LPharmaceutical 014LAutomotive Oil 017LCoolants and Water Soluble Oils 019LOther Oil 021LPolychlorinated Biphenyls 026LOther Waste 029LAntifreeze 030LStorm Sewer Cleanouts 031LSanitary Sewer Cleanouts 032LX-Ray/Photo Solutions 033LWater Based Cleaning Solutions 034LGrease Trap Wastes 036L

Universal Waste

There are certain hazardous wastes that a business can choose to manage in an alternative manner in place of the more complex hazardous waste regulations.

Advantages of Universal Waste Regulations

- Waste can be accumulated up to one year

- A Hazardous waste manifest is not required

- Volume is not included in determining generator status

- Less labeling is required

Types of Universal Waste

- Batteries

- Electric Lamps

- Electronic components

- Mercury-Containing Devices

- Pesticides

- Pharmaceuticals

Electronic Equipment – Computer Monitors & TVs

CRT’s (cathode ray tubes) in monitors and TV’s have been tested and show lead levels exceeding the regulatory limit of 5.0 mg/L. Some models also contain barium, chromium, or mercury.

Meeting the definition of hazardous waste allows these electronics to be managed as universal waste.

Regulated Medical Waste

Intended to help employees avoid injuries and disease.

Regulated medical waste, n.o.s., 6.2, UN3291, PG II

Waste code possibilities: 029L or N/A

Blood borne Pathogens

Use OSHA’s universal precaution method. Treat all blood as dangerous.

-Blood-soaked bandages-Discarded surgical gloves and instruments -Cultures

-Hepatitis-Tetanus-HIV

Sharps

Can inflict injuries and disease.

-Broken glass

-Lancets

-Needles

-Razor blades

The point of packaging is to make sure that the stuff stays inside the packaging during normal transportation.

Includes temperature changes, handling, vibration caused by rough roads or curves.

The type of packaging you can use

The standards or specifications the packaging has to meet

The rules for filling and closing the package

When different hazardous materials may be placed in the same package

Requirements in column 8 of HM table 172.101

Combination packaging

Single packaging

49 CFR 178.503 Marking of packages

Empty containers

DOT vs. EPA Standards

If empty, package is not subject to hazardous material regulations.

DOT empty containers

Cleaned of residue and purged of vapor

All hazardous markings and labels have been removed or covered

Remaining residue is not a hazardous waste or marine pollutant

EPA empty containers

Must contain less than 1 inch of residue orless than 3% by weight of material

Gas cylinder must equal atmospheric pressure

If contained acutely hazardous waste, container must be triple rinsed or inner liner removed

Must accompany the shipment

Printed legibly in English, no abbreviations

Keep copy for 3 years

Must get copy from TSDF within 45 days. If not, call EPA.

The person signing a hazardous waste manifest is also signing the DOT-required shipper’s certification, certifying that the entire shipment is in full compliance with all applicable DOT regulations.

Anyone who prepares, completes or signs a hazardous waste manifest must have training as required by the DOT’s hazmat employee training standard under 49 CFR 172 subpart H.

Markings identify:

What the material is

Correct emergency response actions

Shipper’s name and address

Special handling precautions

Markings include:

Proper shipping name, UN number, shipper’s name and address

EPA ID number, manifest tracking number

Technical names of hazardous materials and waste codes

“Hazardous Waste” Statement.

Labels identify:

What hazard the material has

Special handling precautions

Labels include:

Diamond shaped hazard class labels

Square precaution labels

U of M – Flint Riverfront

602 Mill Street (810) 766-6762

Flint MI 48503

MID 085 043 891

D001,D002,F003

Waste Flammable Liquid, Corrosive, n.o.s., 3(8), UN2924, PGII

(Methanol, Acetic Acid)

Label Examples: 1- Hazardous Warning Statement 2- Generator Name and Address 3- Generator EPA ID Number 4- Accumulation Start Date 5- EPA Waste Codes 6- Manifest Document Number 7- Proper Shipping Name, Technical Name, Special Hazard Warning (if applicable) and DOT Exemptions (If applicable)

3

2

56

4

7

1

Act 451, Part 121 Regulated Materials(used oil)

U of M – Flint Riverfront 602 Mill Street Flint MI 48503

2

7

The shipper or generator must ensure that placards are provided

Displayed on all four sides

Visible without interference on each side and horizontal placement

Table 1------------------------------------------------------------------------ Placard Category of material (Hazard design class or division number and Placard name section additional description, as reference appropriate) (§ )------------------------------------------------------------------------1.1.............................. EXPLOSIVES 1.1.......... 172.5221.2.............................. EXPLOSIVES 1.2.......... 172.5221.3.............................. EXPLOSIVES 1.3.......... 172.5222.3.............................. POISON GAS.............. 172.5404.3.............................. DANGEROUS WHEN WET...... 172.5485.2 (Organic peroxide, Type B, ORGANIC PEROXIDE........ 172.552 liquid or solid, temperature controlled).6.1 (inhalation hazard, Zone A or POISON INHALATION HAZARD 172.555 B).7 (Radioactive Yellow III label RADIOACTIVE \1\......... 172.556 only).------------------------------------------------------------------------\1\ RADIOACTIVE placard also required for exclusive use shipments of low specific activity material and surface contaminated objects transported in accordance with § 173.427(a) of this subchapter.

Table 2------------------------------------------------------------------------

Placard Category of material (Hazard design class or division number and Placard name section additional description, as reference appropriate) (§ )------------------------------------------------------------------------1.4.............................. EXPLOSIVES 1.4.......... 172.5231.5.............................. EXPLOSIVES 1.5.......... 172.5241.6.............................. EXPLOSIVES 1.6.......... 172.5252.1.............................. FLAMMABLE GAS........... 172.5322.2.............................. NON-FLAMMABLE GAS....... 172.5283................................ FLAMMABLE............... 172.542Combustible liquid............... COMBUSTIBLE............. 172.5444.1.............................. FLAMMABLE SOLID......... 172.5464.2.............................. SPONTANEOUSLY COMBUSTIBLE 172.547.5.1.............................. OXIDIZER................ 172.5505.2 (Other than organic peroxide, ORGANIC PEROXIDE........ 172.552 Type B, liquid or solid, temperature controlled).6.1 (other than inhalation POISON.................. 172.554 hazard, Zone A or B).6.2.............................. (None).................. ...........8................................ CORROSIVE............... 172.5589................................ Class 9 (see § 172.560 172.504(f)(9)).ORM-D............................ (None).................. ...........------------------------------------------------------------------------

Materials handled to prevent damage during loading and unloading.

-This end up-No smoking by classes 1,2,3,4,5.

Segregated and separated to prevent incompatible material from mingling during transportation.

-Incompatibles 4 feet from each other

-Use segregation table

Secured and braced to prevent movement and damage during transportation

-strapped in truck every 10 feet

-watch for load shifting

In transportation:

Protect the general public

Control and clean up releases

Prevent or extinguish fires

Any person or place that creates hazardous waste

Generates 2,200 pounds or more waste per month

Can accumulate on site for 90 days

No limit on amount stored

Must be at least one employee available to respond to emergency

Written plans for handling emergencies

LQG – Large Quantity Generator

Generates 220 to 2,200 pounds of waste per month

May accumulate on site for up to 180 days

Accumulation limit is 13,200 pounds

Must be at least one employee available to respond to emergency

No written emergency plan needed

SQG – Small Quantity Generator

Can generate 220 pounds or less waste per month

Accumulation limit is 2,200 pounds

No plans or reporting required

CESQG – Conditionally Exempt Small Quantity Generator

Mark the accumulation start date on each container

Mark each container with words “hazardous waste”

Have written emergency plan

Keep containers closed and in good condition

Inspect containment area and document

Accumulation

Security Plans EPA

Personnel security

Unauthorized access

En route security

Plan in writing and kept

Security Awareness DOT

Required for all hazmat employees

An awareness of security risks

Recognize possible security threats

Know how to respond

Security Awareness OSHA

Regulates workplace storage of flammable and combustible liquids

Size, amount and place of containers

Personal protective equipment supplied if needed

Safety plans and exit routes

National Fire Protection Association

Based on possible fire situations

Standard system for the identification of hazardous materials

Assists in effective fire and emergency planning

Division rating scale

0, 1 - unlikely to become dangerous2 - depends on the circumstances3, 4 - it is dangerous now

Enforcement and penalties

EPA has authority to inspect facilities

Can require corrective actions to take place

Criminal penalties or fines

FINES & PENALTIES

Summary

Act Sanction Intent Maximum Fines MaximumImprisonment

RCRA(HazardousWaste)

Civil None $32,500/day

Criminal Knowingly $25,000/day (doubled for second offense)

1 year (doubled for second offense)

Knowing imminent endanger-ment to human life

$250,000$1,000,000(organizations)

2 years

Knowing extreme indifference to human life

$250,000$1,000,000(organizations)

5 years

Hazardous Materials & Hazardous Waste Training

September 10, 2008

Drug & Laboratory Disposal, Inc.331 Broad Street

Plainwell, MI 49080