Hazardous Materials & Hazardous Waste TrainingSeptember 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 transportationDOT Department of Transportation
OSHA Occupational Safety and Health AdministrationRegulates workplace conditions and practices
EPA Training Requirements40 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 facilitys compliance
Annual review of written training planEPA 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 annuallyEPA 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 trainingDOT 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 employeeDOT Training Requirements
OSHA Training Requirements29 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 programOSHA 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 trainingOSHA 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 introducedOSHA 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 Manufacturers 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 doesnt 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: PGIindicates greater danger PGIIindicates medium danger PGIIIindicates minor danger
Indicated by packing group, used in packaging the material Some hazard classes dont have packing groups. (2, 7) Not safe to over classify. (responders and employees safety)
Division 3 Packing Groups
Packing GroupFlash PointInitial Boiling PointI 35C (95F)II 23C (73F)> 35C (95F)III 23C (73F) but 60.5C (141F)> 35C (95F)
Division 6.1 Packing Groups
Packing GroupOral toxicity LD50 (mg/kg)Dermal toxicity LD50 (mg/kg)Inhalation toxicity by dusts and mists LC50 (mg/L)I 5 40 0.5II> 5 but 50> 40 but 200> 0.5 but 2IIIsolids: > 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 D001Ignitable waste code D002Corrosive waste code D003Reactive waste code D004 D011Toxic heavy metals waste codes D012 D043Toxic 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)007LPharmaceutical014LAutomotive Oil017LCoolants and Water Soluble Oils019LOther Oil 021LPolychlorinated Biphenyls026LOther Waste029LAntifreeze030LStorm Sewer Cleanouts031LSanitary Sewer Cleanouts032LX-Ray/Photo Solutions033LWater Based Cleaning Solutions034LGrease Trap Wastes036L
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 CRTs (cathode ray tubes) in monitors and TVs 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 OSHAs 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
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 pressureIf 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 shippers 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 DOTs hazmat employee training standard under 49 CFR 172 subpart H.
What the material is
Correct emergency response actions
Shippers name and a