Waste Generator Compliance Guide - fsrqa.comfsrqa.com/esh/docs/Program105.01-WasteGeneratorComplianceG… · Web viewKnowledge of the process or waste (including the use of Material

Waste Management

Compliance Procedure

FISHER SCIENTIFIC

Waste Management Compliance ProceduresProgram 105.01

2000 Park LanePittsburgh, Pennsylvania 15275

Phone 412.490.8300 • Fax 412.490.8930

R E G U L A T O R Y A F F A I R S M A N U A L S E R I E S 1 0 0W A S T E M A N A G E M E N T C O M P L I A N C E P R O C E D U R E P R O G R A M 1 0 5 . 0 1

Table of Contents1 Introduction 1-1

1.1 Purpose 1-11.2 How to Use This Manual 1-1

2 Overview of RCRA 2-12.1 Overview 2-12.2 Applicability to Fisher Scientific 2-12.3 Registration (This section is mandatory) 2-1

3 Waste Identification and Classification 3-13.1 Waste Stream Inventory 3-13.2 Hazardous Waste Classification 3-1

3.2.1 Step 1 - Is the Waste Considered a Solid Waste? 3-23.2.2 Step 2 - Is the Waste Excluded? 3-23.2.3 Step 3 - Is the Waste Listed? 3-33.2.4 Step 4 - Does the Waste Exhibit a Hazardous Characteristic? 3-33.2.5 Step 5 - Is it a Regulated Mixture? 3-5

3.3 Waste Analysis (This section is mandatory) 3-63.4 Generator Status 3-6

3.4.1 Episodic Generators 3-73.5 Spill Material and Damaged Containers 3-73.6 Waste Oil Management 3-73.7 Universal Waste 3-8

3.7.1 Notification 3-83.7.2 Container Management (This section is mandatory) 3-83.7.3 Labeling / Marking (This section is mandatory) 3-83.7.4 Accumulation Time Limits (This section is mandatory)3-93.7.5 Employee Training (This section is mandatory) 3-93.7.6 Off-Site Shipments(This section is mandatory) 3-93.7.7 Tracking Shipments (This section is mandatory) 3-10

3.8 Electronic Waste 3-10

Effective Date: September 1997 Rev. # 3 Mandatory Discretionary Revision Date: September 2004 i


3.9 Aerosol Cans 3-113.10 Solvent Laden Rags 3-113.11 Potentially Biohazardous/Infectious Waste 3-123.12 Special Waste 3-133.13 Tracking Waste Generation 3-13

4 On-Site Requirements 4-14.1 Satellite Accumulation Area 4-14.2 Hazardous Waste Storage Area (This section is mandatory) 4-2

4.2.1 Tank Systems 4-34.2.2 Air Emissions 4-34.2.3 Ignitable Wastes 4-44.2.4 Incompatible Wastes 4-44.2.5 Non-Hazardous Waste 4-44.2.6 Secondary Containment 4-4

4.3 SQG Exemptions/Requirements (This section is mandatory) 4-54.4 Inspection of On Site Storage Areas (This section is mandatory)4-64.5 Empty Container Management 4-6

4.5.1 Reuse of Containers 4-75 Transporting Hazardous Waste 5-1

5.1 Pre-Transport Requirements 5-15.1.1 Packaging 5-15.1.2 Labeling/Marking 5-15.1.3 Placarding 5-2

5.2 Reportable Quantities 5-25.3 Land Disposal Restrictions (LDR) 5-2

6 Uniform Hazardous Waste Manifest 6-16.1 Manifest Requirements (This section is mandatory) 6-1

6.1.1 Manifest Requirements for Distribution Centers 6-16.2 Returned Manifest 6-2

7 Recordkeeping and Reporting 7-17.1 Recordkeeping (This section is mandatory) 7-17.2 Reporting 7-1

7.2.1 Emergency Reports (This section is mandatory) 7-27.2.2 Periodic/Biennial/Annual Reports (This section is mandatory) 7-27.2.3 Exception Reports (This section is mandatory) 7-57.2.4 Recordkeeping System 7-7

8 Training (This section is mandatory) 8-19 Emergency Preparedness and Prevention 9-1

Effective Date: September 1997 Rev. # 3 Mandatory Discretionary Revision Date: September 2004 ii


9.1 Emergency Preparedness Provisions (This section is mandatory)9-19.2 Contingency Plan (This section is mandatory) 9-1

9.2.1 Emergency Coordinator 9-29.2.2 Facility Owner/Operator Responsibilities (This section is mandatory) 9-3

9.3 SQG Requirements (This section is mandatory) 9-410 Waste Minimization 10-1

FormsSee Form Numbers F105.01-F105.19 in Forms Section of Regulatory Affairs

ManualToolsAppendix 1:Appendix 2:Appendix 3: Universal Waste State ComparisonAppendix 4: Aerosol Can ManagementAppendix 5: Hazardous Waste Management Training ProgramAppendix 6: Management of Solvent Contaminated Wipes or RagsAppendix 7: USDO P-listed wastesAppendix 8: State Specific Waste Management RegulationsAppendix 9: Generator Hazardous Waste Report

Effective Date: September 1997 Rev. # 3 Mandatory Discretionary Revision Date: September 2004 iii

1 INTRODUCTION1.1 PurposeThis manual is designed to assist Fisher Scientific facilities in the management of various types of waste: a) hazardous waste in accordance with the Resource Conservation and Recovery Act (RCRA) and associated state regulations, b) universal waste, c) waste oil, d) wipes, e) aerosol cans, f) potentially biohazardous waste, and g) non RCRA waste. The practices established in this manual reflect the federal regulations for waste generators. State specific requirements are found in Appendix 8. Fisher Scientific facilities must use other resources to ensure that they are in compliance with local laws. Contact the Regulatory Affairs Department (see Program 100.01 for a listing) for more information.

This manual is designed to cover the federal requirements for both large and small quantity generators since Fisher Scientific facilities fall into both categories. However, this manual does not provide a comprehensive description of treatment, storage and disposal facility (TSDF) requirements for those facilities with Part B permits as there are no Fisher Sites that have these permits.

The purpose of this manual is to state in plain English the the day-to-day management procedures for meeting federal and state requirements. It is the obligation of the site to be in full compliance with all federal and state regulations dealing with the management of waste.

Although this overall procedures is discretionary (your site specific program must be equivalent and address at least all of the topics discussed herein), there are certain sections that are considered to be mandatory items. Topics addressed in the mandatory sections are highlighted in yellow, and sites that do not follow the procedures in these sections will be considered out of compliance with this Fisher program.

1.2 How to Use This ManualThis manual is designed to be a working reference document used during the daily operations of each facility. It is complemented by hazardous waste training sessions geared to help Fisher Scientific facilities achieve compliance with state and federal hazardous waste regulations.

All personnel with RCRA waste handling responsibilities should familiarize themselves with the requirements in this manual. Each section provides information on the procedures required to manage hazardous waste safely.

This manual also contains a section for:

A contingency plan; and

A waste minimization plan.

If you have any questions, consult the appropriate section of this manual; if the issue still remains unclear, contact the Corporate Regulatory Affairs Department (a listing is provided in Program 100.01).

Effective Date: September 1997 Rev. # 3 Mandatory Discretionary Revision Date: September 2004 1


2 OVERVIEW OF RCRA2.1 OverviewThe Resource Conservation and Recovery Act (RCRA), first enacted in 1976, established the federal regulatory program for hazardous waste management. Under Subtitle C, regulations govern:

Identification of what constitutes hazardous waste;

Management practices for generators, transporters, and treatment, storage and disposal facilities (TSDF); and

Minimum standards for state regulatory programs.

2.2 Applicability to Fisher ScientificAs generators of hazardous waste, Fisher Scientific facilities are subject to the federal RCRA regulations as well as any applicable state regulations.

The federal RCRA regulations can be found in 40 CFR 260-282. The most important section for Fisher facilities is 40 CFR 262 – Standards Applicable to Generators of Hazardous Waste.

Facilities with permits for the treatment, storage, and disposal of hazardous waste are subject to additional requirements (40 CFR 264 and/or 265) as well as their specific permit requirements.

The majority of states (excluding Wyoming and Iowa) have been authorized to administer the RCRA program, and many of them have added more stringent standards to the federal regulations, therefore it is essential to be familiar with your state requirements as well.

2.3 Registration (This section is mandatory)As generators of hazardous waste, all Fisher Scientific facilities must register with the EPA as well as their state regulatory agency. Using Form 8700-12 (the most recent version of the form and instructions are available at http://www.epa.gov/epaoswer/hazwaste/data/form8700/forms.htm), the facility must:

List all the wastes generated on-site; and

List all the hazardous waste activities (i.e., generator, transporter, and treatment, storage, or disposal).

Update the form if any of the information in the last submitted form becomes outdated (e.g. generator status, emergency contact etc) therefore have a copy on file and review it at least yearly.

Upon review of the form, EPA will assign an identification number to each facility. Each time a new waste stream is generated at your facility or the facility information changes, a new form must be


submitted to update the information. This identification number must be used on all correspondence with federal or state agencies, as well as on all labels, manifests, and regulatory reports.

Your facility’s current generator status should be the same as what is listed on Form 8700-12.

The EPA ID number for this facility is: .

Nonhazardous solid wastes are largely regulated by the states. Several states require notification of hazardous and non-hazardous waste generation activities utilizing specific forms or an electronic registration system. See Appendix 8 or contact your State agency to determine notification requirements.


3 WASTE IDENTIFICATION AND CLASSIFICATION3.1 Waste Stream InventoryThe fundamental building block of the hazardous waste management regulations is the characterization of waste streams. At Fisher Scientific, there is a limited range of waste streams to consider for identification.

Wastes at Distribution Facilities Include: Discarded/expired products;

Products damaged in shipment;

Recalled products;

Chemically altered products (discolored or unattached labels, etc.); and

Spills and spill cleanup materials.

Wastes at Manufacturing Facilities Include: Expired products;

Used products (spent solvents);

Wastes from operational activities; and

Spills and spill cleanup materials.

3.2 Hazardous Waste ClassificationAs generators of hazardous waste, all Fisher Scientific facilities are responsible for characterizing their wastes. There is a five-step process to consider in identifying and characterizing waste streams.

Five-Step Waste Classification Process:Step 1 – Is the waste considered a solid waste?

Step 2 – Is the waste excluded?

Step 3 – Is the waste listed?

Step 4 – Does the waste exhibit a hazardous characteristic?

Step 5 – Is it a regulated mixture?


3.2.1 Step 1 - Is the Waste Considered a Solid Waste?A waste may be considered solid regardless of whether the material is physically a solid, liquid, sludge or containerized gas. This is the first step to determine whether your waste classifies as a RCRA regulated waste. If the waste is not considered “solid”, then the regulations do not apply.

Solid waste: Any material being discarded or intended to be discarded that is abandoned, recycled, or considered “inherently waste like.”

The trigger for when a material changes from product to waste is at the point when it is going to be discarded; therefore, it is essential to understand the definition of discarded to classify your waste.

A discarded material is any material that is:

Abandoned: Meaning disposed of, burned, incinerated, accumulated, stored, or treated before disposal.

Recycled: In this context refers to the following four types of recycling activities.

A material is considered a solid waste if it is recycled by being:

Used in a manner constituting disposal (e.g., land application)

Burned for energy recovery or used to produce a fuel

Reclaimed to recover usable products (e.g., lead from spent acid batteries)

Accumulated speculatively (recyclable wastes for which there is no current market)

There are a few exceptions to this rule which apply to the reclamation of sludges and/or by-products exhibiting a hazardous characteristic and commercial chemical products, as well as the speculative accumulation of commercial chemical products. For more information, see 40 CFR 261.2.

Inherently waste like: Refers to a number of materials that the EPA has designated as solid waste regardless of how they are recycled. At the point in time that it is determined a material can no longer be used for its intended purpose, the material becomes a waste. You must then determine whether or not the waste is hazardous and manage it accordingly. If you determine the material to be a hazardous waste, the date generated is the day the material was no longer useable as a product.

If a product falls under any of the above definitions, it is considered a solid waste and, therefore, must be managed in accordance with RCRA. The next step is to determine if the waste meets the regulatory definition of a hazardous waste.

3.2.2 Step 2 - Is the Waste Excluded?EPA has excluded several wastes from classification as a solid waste as well as identified a number of solid wastes as non-hazardous. If you believe your waste stream might be exempt, refer to 40 CFR 261.4 or contact Regulatory Affairs.


Common Fisher Exemptions Include: Domestic sewage;

Industrial wastewater discharges;

Certain reclaimed materials; and

Waste samples for laboratory analysis.

Lab Sample Exemption

Lab samples which are being sent off site for testing and classification are not regulated under RCRA as long as they: are being transported to the lab or back to the collector; are being stored by the collector before transport; or are being stored at the lab.

In order for this exemption to apply, you must ensure that the sample is shipped in compliance with the applicable shipping requirements, such as the DOT (49 CFR) or postal service (39 CFR) requirements. A bill of lading or some other shipping paper will be required.

Once they are returned, however, they must be managed in accordance with the requirements of their waste classification.

3.2.3 Step 3 - Is the Waste Listed?A solid waste is hazardous if it is listed in any of the tables in 40 CFR 261, Subpart D. The first table includes spent solvents or wastes generated from non-specific sources. These are “F” list wastes which would not normally be found in a warehouse unless degreasers are used, but may be found in manufacturing operations (such as F001, solvents used in degreasing).

The second list is wastes generated from specific sources and these are designated as “K” list wastes. These are listed by the industry that generates them. The waste is only hazardous if it is listed under your industry's category. K listed wastes are not found in any Fisher Scientific facilities.

The final list is a series of commercial chemical products and off-specification materials which are considered hazardous when discarded or spilled. These are divided into acute hazardous “P” and toxic “U” lists both of which are found in Fisher facilities. It must be kept in mind that the "P” and “U” listings apply to a chemical substance which is manufactured for commercial or manufacturing use. This substance consists of the pure or technical grade of the chemical, and all formulations in which the chemical is the sole active ingredient. Refer to Appendix 1: Cyanides and Appendix 7: USDO P-listed wastes for use in making listed waste determinations.

3.2.4 Step 4 - Does the Waste Exhibit a Hazardous Characteristic?If a waste is not listed, you must determine whether it exhibits any of the four characteristics described below.

The characteristic can be determined by testing the waste according to methods set forth in 40 CFR 261, Subpart C or by applying your knowledge of the materials or process.

Ignitability EPA Hazard Code: D001


A waste is ignitable if:

It is a liquid (other than an aqueous solution containing less than 24 percent alcohol by volume) and has a flash point less than 140°F as determined by a Pensky Martens Closed Cup Tester or a Setaflash Closed Cup Tester;

It is not a liquid but capable of causing fire through friction, absorption of moisture, or spontaneous chemical changes and when ignited, burns so vigorously and persistently that it creates a hazard;

It is an ignitable, compressed gas; or

It is an oxidizer.

Corrosivity EPA Hazard Code: D002

A corrosive waste is:

An aqueous solution that has a pH less than 2 or greater than 12.5; or

A liquid that corrodes steel at a rate greater than one quarter (1/4) inch per year.

Use Tool T105.01: pH to assist in making a corrosivity waste determination.

Reactivity EPA Hazard Code: D003

A solid waste may be reactive if:

It is normally unstable and readily undergoes violent change without detonating;

It reacts violently with water;

It forms a potentially explosive mixture with water;

It generates toxic gases, fumes, or vapors when mixed with water;

It is a cyanide or sulfide bearing waste which, when exposed to pH conditions between 2 and 12.5, can generate toxic gases, vapors, or fumes;

It is capable of detonating or exploding when subjected to a strong initiating source or if heated under confinement;

It is capable of detonation or explosive decomposition or reaction; or

It is a forbidden explosive.

Toxicity - EPA Hazard Codes: D004 – D043

A waste is toxic if:


A sample of the waste tested by the Toxicity Characteristic Leaching Procedure (TCLP) contains any of the listed contaminants at a concentration equal to or greater than the listed values (Table 1 in 40 CFR 261.24).

Toxic wastes codes range from D004-D043, according to which contaminant is present. Use Tool T105.02: TCLP Calculator for assistance in waste determinations.

3.2.5 Step 5 - Is it a Regulated Mixture?Any material that is composed of a mixture of solid waste and one or more listed wastes is a hazardous waste. If even the smallest amount of a listed waste becomes mixed with the solid waste, the entire waste stream must be handled as a hazardous waste (with the exception of F003 wastes).

If, however, the waste is a hazardous waste solely because of one of the three characteristics, (i.e., ignitability, corrosivity or reactivity) and the resultant mixture no longer exhibits the characteristic, then the mixture may no longer be hazardous. Such a mixture is a hazardous waste only if it, too, exhibits one of the hazardous characteristics.

Spent Solvent Exception

The one exception to the rule for listed wastes is spent solvents. Spent solvents are listed hazardous wastes F001, F002, F003, F004, and F005.

A spent solvent mixture is a hazardous waste if:

The mixture contains at least ten percent of a listed solvent prior to use; or

The mixture contains a total of at least ten percent of any combination of F001, F002, F004, and/or F005 wastes.

F003 waste is treated slightly different:

A mixture of less than 100 percent F003 waste with non listed materials is not a listed hazardous waste, but an "ignitable" waste; and

A mixture of any concentration of F003 waste plus at least ten percent of F001, F002, F004, and/or F005 waste is listed as F003.

Elementary Neutralization

Neutralization is the process whereby an acid or base is added to a corrosive waste to bring the pH into a more neutral range, between 2 and 12.5, thereby rendering it nonhazardous. This is a treatment process which may be conducted on-site without obtaining a RCRA permit. If the waste is hazardous solely due to corrosivity, it may be neutralized in a container, tank, or transport vessel. Once the corrosive waste has been neutralized, it may be managed as a nonhazardous waste.

3.3 Waste Analysis (This section is mandatory)As generators of hazardous waste, Fisher Scientific facilities are required to identify and classify all wastes on site. In many cases, this is a simple process since wastes are still in their original


containers, which show their composition and lot number. Even materials, which are spilled generally, come from clearly labeled containers of commercial products.

However, for wastes of unknown composition, the determination can be made by:

Knowledge of the process or waste (including the use of Material Safety Data Sheets (MSDS) or other published materials).

Waste analysis or testing for ignitability, corrosivity, reactivity, and toxicity in accordance with 40 CFR 261.21-261.24.

Generators are not required to have a formal waste analysis plan but should document their decisions for waste classification, including any waste analysis or testing records. Use Form F105.04: Waste Stream Evaluation and Form F105.05: Hazardous Waste Determination to document waste stream classifications.

3.4 Generator Status Your facility's generator status is determined by how much hazardous waste is generated not how much waste is shipped off-site each month. There are three levels of hazardous waste generators.

Conditionally Exempt Small Quantity Generators (CESQG): Generates no more that 100 kg(220 lbs) of hazardous waste per month

Small Quantity Generators (SQG): Generates greater than 100 kg (220 lbs) but less than 1,000 kg (2,200 lbs) per month

Large Quantity Generators (LQG): Generates greater than or equal to 1000 kg (2,200 lbs) of hazardous waste or 1 kg (2.2 lbs) of acute hazardous waste per month

Regulations become increasingly stringent as waste generation increases. It is essential to know your generator status to determine with which regulations you must comply. Several states including Texas, Pennsylvania and California have additional regulations for each generator status. Use Form F105.01: Federal Hazardous Waste Generator Status Conversions, Status Chart and Log Sheet (facilities in California use Form F105.16) to calculate your generator status each month.

The EPA Form 8700-12 on file for your facility must reflect the generator status that is represented on Form F105.01/F105.16. LQGs may choose not to complete Form F105.01 on a monthly basis; however, such facilities must have LQG designated on their 8700-12 form and they must be meeting all of the requirements of a LQG.

This manual is based on the requirements for LQGs, but SQG exemptions are described in each section and in the state specific waste summaries, provided in Appendix 8.

Note: for Fisher Scientific locations, all CESQGs must meet the storage requirements for SQG (e.g., employee training, records of container inspections, posting of emergency telephone numbers, etc.) but not the timed accumulation for SQG (i.e., 180 days).


Note: Acutely hazardous wastes are listed in 40 CFR 261.33 (e). Those Fisher products identified as acutely hazardous wastes are included in Appendix 7.

3.4.1 Episodic Generators Generators may periodically exceed or fall below their normal generation limits in any given calendar month. If the amount of waste generated in a given month places the generator in a different category, the generator is responsible for complying with all applicable requirements of that category for all waste generated during that calendar month. For example, if a generator produces 660 lb (300 kg) of hazardous waste in March, that waste must be managed in accordance with the small quantity generator regulations; if the same generator produces 3,300 lb (1,500 kg) of hazardous waste in April, that waste must be managed in accordance with the large quantity generator regulations.

Some states require episodic generators to register at the generator level with the more stringent requirements. For example, facilities in Kentucky that may meet the definitions of an SQG in some months and that of an LQG in some months are required to register with the state as an LQG and act accordingly. Check your state requirements or consult Regulatory Affairs.

3.5 Spill Material and Damaged ContainersAll material spilled on site which is a hazardous substance, as well as broken or leaking containers if they contained a hazardous substance, must be treated as a hazardous waste. In addition, spill cleanup materials must be treated as hazardous if they are contaminated with a hazardous waste.

3.6 Waste Oil Management Waste oil is not listed as a federal hazardous waste as long as it has less than 1,000 ppm total halogens and is destined for disposal or recycling. Waste oils that exhibit a hazardous characteristic and are not recyclable must be handled and disposed like any hazardous waste. Some states like Massachusetts do regulate used oil as a state hazardous waste.

Waste oil must be stored in aboveground tanks or containers that comply with 40 CFR 265, Subparts I and J. Containers and tanks must be in good condition (no rusting, deterioration, or structural defects) and must not leak. Containers and tanks must be labeled or marked with the words "used oil."

In the event of a release, the facility should stop and contain the release. The spill should be cleaned up and containers or tanks should be repaired or replaced if necessary to prevent further releases.

The facility should ensure that waste oil is transported by Fisher’s National Waste Contractor. If your facility is unable to use Fisher’s National Waste Contractor, the Waste Oil Questionnaire, Form F105.18, must be completed and submitted to Regulatory Affairs prior to shipment.

3.7 Universal WasteFederal regulated universal waste includes:

batteries (nickel-cadmium and small lead-acid batteries),


agricultural pesticides,

thermostats which can contain as much as 3 grams of liquid mercury, and

fluorescent, high intensity discharge, neon, mercury vapor, high pressure sodium and metal halide lamps which typically contain mercury and lead.

State universal waste regulations may include thermometers, paint-related debris, antifreeze, and aerosol cans. Refer to Appendix 3: Universal Waste State Comparison for more information.

Generators of universal waste are categorized in one of the following ways:

A small quantity handler (SQH) of universal waste accumulates less than 11,000 lbs (5,000 kg) or more (collectively) of universal waste at any time.

A large quantity handler (LQH) of universal waste accumulates 11,000 lbs (5,000 kg) or more (collectively) of universal waste at any time.

The designation as a large quantity handler of universal waste is retained through the end of the calendar year in which 5,000 kilograms or more total of universal waste is accumulated. It can change status in the subsequent year.

3.7.1 NotificationA SQH is not required to notify EPA of universal waste handling activities. A LQH must have sent written notification of universal waste management to the Regional Administrator, and received an EPA identification number, before meeting or exceeding the 5,000 kg storage limit. A LQH of universal waste who has already notified EPA of his hazardous waste management activities and has received an EPA identification number is not required to re- notify under this section.

3.7.2 Container Management (This section is mandatory)Universal wastes must be handled in a way that prevents release of any universal waste or component of a universal waste to the environment, as follows:

Contain any universal waste that shows evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions in a container. The container must be closed, structurally sound, compatible with the contents, and must lack evidence of leakage, spillage or damage that could cause leakage under reasonably foreseeable conditions.

3.7.3 Labeling / Marking (This section is mandatory)Universal waste must be labeled or marked to identify the type of universal waste as specified below along with the date the waste was generated:

Universal waste batteries or their container must be labeled or marked clearly with any one of the following phrases: “Universal Waste—Batteries,” or “Waste Batteries,” or “Used Batteries” + date.

A container, tank, transport vehicle or vessel in which recalled universal waste pesticides are contained must be labeled or marked clearly with: “Universal Waste—Pesticide,” or “Waste Pesticide” +date. Fisher facilities do not typically generate pesticide wastes.


A container, tank, transport vehicle or vessel in which unused pesticide products are contained must be labeled or marked clearly with the label that was on the product when purchased, if still legible; if this is not feasible, the appropriate label as required under the DOT 49 CFR 172; if this is not feasible, another label prescribed or designated by the pesticide collection program; and the words: “Universal Waste--Pesticide,” or “Waste Pesticide”

Universal waste thermostats or their container must be labeled or marked clearly with any one of the following phrases: “Universal Waste—Mercury Thermostats,” or “Waste Mercury Thermostats,” or “Used Thermostats” + date.

Each lamp or container of lamps must be labeled or marked clearly with one of the following phrases: “Universal Waste – Lamps,” or “Waste Lamps,” or “Used Lamps” + date.

3.7.4 Accumulation Time Limits (This section is mandatory)Universal Waste Handlers may accumulate universal waste for no longer than one year from the date the universal waste is generated.

Universal Waste Handlers must be able to demonstrate the length of time that the universal waste has been accumulated from the date it becomes a waste. This can be completed by:

Marking or Labeling Container;

Marking or Labeling Each Lamp or Battery;

Maintaining an Inventory System; or

Maintaining and Labeling (initial accumulation date) a Universal Waste Storage/ Accumulation Area.

3.7.5 Employee Training (This section is mandatory)Universal Waste Handlers must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relative to their responsibilities during normal facility operations and emergencies.

3.7.6 Off-Site Shipments(This section is mandatory)Universal Waste Handlers are prohibited from sending or taking universal waste to a place other than another universal waste handler, a destination facility or a foreign destination. Prior to sending a shipment of universal waste to another universal waste handler, the originating handler must ensure that the receiving handler agrees to receive the shipment.

3.7.7 Tracking Shipments (This section is mandatory)All facilities must keep records of each shipment of universal waste sent from the handler to other facilities. The record may take the form of a log, invoice, manifest, bill of lading or other shipping document. The record for each shipment sent must include the following:

The name and address of the originating universal waste handler, destination facility, or foreign destination to which the waste was sent;


The quantity of each type of waste sent; and

The date of receipt of the shipment of universal waste.

These records must be retained for at least three years from the date the shipment left the facility.

Use Form F105.19: Universal Waste Compliance Checklist to document that these regulatory issues have been addressed and send a copy to Regulatory Affairs in Pittsburgh. The final destination facility is regulated under the hazardous waste regulations, and information concerning this final site must be obtained prior to shipment.

Mercury-containing/fluorescent lamps are handled as Hazardous or Universal waste depending on your state’s requirements. See Appendix 3: Universal Waste State Comparison for more information.

3.8 Electronic Waste Electronic waste is the name given to used cathode ray tubes (CRTs or computer monitors), computers (CPUs), or key boards. The regulatory requirements for the disposal of used computer and electronic equipment is currently being investigated by the United States Environmental Protection Agency (USEPA) and many states. While both the USEPA and many states have begun to evaluate the recycling, reuse, and end-of-life disposal of computer equipment, this material is currently subject to the laws and regulations governing the management of hazardous waste.

A waste classification of this equipment, when discarded, has to be made to determine whether or not it is a hazardous waste. The determination is made by either testing the material or by using knowledge of the material to determine if the equipment meets the definition of hazardous waste. Computer equipment can be divided into two categories:

the cathode ray tube and

all other computer and electrical components.

One of the tests to determine if a waste is hazardous is the Toxicity Characteristics Leachate Procedure (TCLP). Currently, colored CRTs will fail this test due to high levels of lead, which are added to the glass during manufacture to protect the user from radiation emitted inside the CRT. Printed circuit boards also can fail the TCLP test for lead and mercury.

Due to computer equipment upgrades and consolidation of facilities, computer monitors, central processing units, keypads, etc. are being accumulated at various locations.

Normal reuse of CRTs and other computer equipment is exempt from the hazardous waste regulations. Only donations to Goodwill or other non-profit/charitable organizations, which will use this computer equipment, are exempt. Documentation needs to be kept on file of what was sent to Goodwill.

Several recycling outlets for this equipment have been designated in the Fisher’s National Waste Contractor How to Do Business Document that first evaluate the equipment for potential re-use


opportunities prior to sending for recycle. No electronic equipment is to be disposed of via dumpster or landfill. Disposal of the equipment should not occur unless testing has been completed or the manufacturer has been contacted for information as to the lead or mercury content in the CRT. Please contact the Regulatory Affairs Department if you have questions regarding these recycling locations.

3.9 Aerosol Cans Spray cans contain flammable propellants and listed solvents. These spray cans will exhibit the characteristics of ignitibility and reactivity when they are not empty and are therefore hazardous waste. These cans must be managed as is all other hazardous waste generated at your facility. Both manufacturing and logistic operations generate used spray cans from painting, degreasing and lubricating processes. All spray can usage needs to be evaluated to determine if it is truly necessary. If spray can use is necessary, then a waste classification of the material must be determined and documented. Spray can puncturing equipment can be used only if the contents of the cans are not a hazardous waste, if the cans do not exhibit a characteristic of hazardous waste, if the aerosol cans are by regulation “empty”, if the cans are being recycled through a metal recycler, AND if state requirements are met. If any of these conditions cannot be documented, then the aerosol spray can must be managed with the site’s other hazardous waste.

A decision diagram for the management of aerosol spray cans is provided as Appendix 4: Aerosol Can Management. If your site chooses to use the spray can puncturing equipment, then a written operating procedure needs to be developed and reviewed by your site’s ES&H contact.

The simplest action is to collect all aerosol spray cans and make a hazardous waste determination based on the contents of the can and the amount of liquid remaining in the can. Segregate all hazardous and non-hazardous waste aerosol spray cans. Add all hazardous waste spray cans to the other hazardous waste generated on site. Spent aerosol cans need to be placed into an outer container and labeled with the words “hazardous waste” and the date of accumulation.

3.10 Solvent Laden RagsUsed paper or cloth wipes, rags or shop cloths (here after referred to as wipes) are a solid waste when they are thrown out or are recycled. Wipes that become contaminated with certain solvents have the potential to be classified as hazardous waste. A wipe meets the definition of hazardous waste when:

it contains a spent solvent that has served its intended purpose and is no longer useful as a solvent (e.g., acetone) ,

it is mixed with a listed hazardous waste (e.g., F-listed solvents like 1,1,1 trichloroethane) or,

the rag and the solvent meet the characteristic of a hazardous waste (e.g., D001 ignitability through spontaneous combustion or D003 reactivity) then the wipes are hazardous waste.


The management and disposal of these wipes can come under the same rules and regulations that govern the management of hazardous waste. The EPA does allow the individual states to administer their own programs and make decisions on the proper management of solvent contaminated wipes. Therefore interpretations regarding this waste are being made by taking into account regulations of the specific states in which Fisher Scientific generates these types of waste.

Contractors should take all contaminated wipes with them and not be allowed to discard them into Fisher Scientific’s “trash” dumpsters. All maintenance shops need to collect their solvent rags and store them in properly labeled and closed containers. These containers should be labeled as to the contents. For example “shop wipes”, if the wipes are determined to be non hazardous waste, or “hazardous waste “, if the wipes are determined to be hazardous waste. Refer to Appendix 6: Management of Solvent Contaminated Wipes and Rags for more information.

3.11 Potentially Biohazardous/Infectious Waste Potentially biohazardous/potentially infectious waste is waste that is labeled as such or is identified (in a product brochure or Material Safety Data Sheet) as waste material that requires infectious waste treatment. Some examples include:

Diagnostic kit components made from the human blood pool– e.g., Factor Deficient Plasma, Coagulation Control, and Reference Plasmas;

Materials used for the testing of biologicals - serums, antigens, plated/ tube media;

Biohazards/ Infectious waste - cultures and stocks of infectious agents (these items have the biohazard warning on them);

Sharp Waste - needles and Pasteur pipettes (broken, usually means “used” but in New Jersey includes “unused”)

Fisher Logistics, and most manufacturing locations, DO NOT generate Regulated Medical Waste. These sites MAY generate potentially biohazardous, potentially infectious, or truly infectious (DOT 6.2) wastes. There are no federal regulations pertaining to these wastes; each state’s waste regulations (See Appendix 8) must be evaluated regarding storage on-site prior to shipment via Fisher’s National Waste Contractor to Fisher approved disposal facilities, which are included in Fisher’s National Waste Contractor How to Do Business Document. These materials can no longer be sent via mailback containers through the U.S. Postal Service.

A few Fisher Manufacturing locations (e.g., Fisher Diagnostics) CAN generate Regulated Medical Waste. Again, because there are no federal regulations pertaining to Regulated Medical Waste, state regulations must be evaluated. Contact Regulatory Affairs if your facility is involved in the manufacture of biological or diagnostic products that are used in 1) connection with the diagnosis, treatment or immunization of animals or humans; or 2) research pertaining to the provision of medical services; or 3) the provision or testing of biologicals.

Regulated medical waste can either be treated or disposed of in a medical waste incinerator, or treated by autoclaving and then landfilled. Facilities authorized to handle regulated


medical waste for Fisher are included in Fisher’s National Waste Contractor How to Do Business Document.

3.12 Special Waste This is waste that originates at either a distribution center or manufacturing location and is not municipal (paper trash, cardboard), hazardous, potentially infectious/potentially biohazardous, truly infectious, or regulated medical waste. Such items include saline solutions, media plates, and vacutainers, and are only allowed to enter into a landfill or other treatment (waste to energy conversion) if the Fisher location obtains a letter from the treatment/disposal facility. The letter must identify the material being discarded and state that the specific material is permitted to go to that T/D facility. Documentation must accompany the letter that the waste was determined not to be a hazardous waste by virtue of knowledge (MSDS) or testing. Any questions should be directed to Regulatory Affairs.

3.13 Tracking Waste GenerationFisher facilities are required to use Form F105.09 Waste Accumulation Log to document ALL of their wastes AS THEY ARE GENERATED. Blocks have been provided on the spreadsheet so that the waste type can be marked. The Form was created to enable sites to keep a central document, which provides a physical description of each individual waste item that will eventually be shipped from the facility.


4 ON-SITE REQUIREMENTS There are two types of waste accumulation areas at Fisher facilities, which are subject to different requirements:

Satellite Accumulation Area(s); and

Hazardous Waste Storage Area(s).

4.1 Satellite Accumulation Area Satellite areas are located at or near the point of generation under the control of the operator generating the material.

Note: Distribution centers normally will not use satellite accumulation areas as part of their waste management system, unless they have maintenance departments.

The following requirements apply to satellite areas:

must be located at or near the point of generation; and

amount accumulated must not exceed 55 gallons of hazardous waste or one quart of acutely hazardous waste.

Note: The 55-gallon limit is related to the definition for point of generation. If you can claim more than one point of generation, you may be allowed to accumulate two 55-gallon containers. If not, two waste streams may be accumulated but the 55-gallon limit would apply.

Containers and tanks must be labeled as "Hazardous Waste" or with other words that identify the contents of the containers.

Containers must be (40 CFR 265 Subpart I):

- Kept in good condition and leaking containers must be replaced.

- Closed at all times except when waste is being added/removed.

- Made or lined with materials that are compatible with the waste.

Once 55 gallons of hazardous waste or one quart of acutely hazardous waste (listed in 40 CFR 261.33(e)) is accumulated, the container label must be dated and the container moved to the hazardous waste storage area within three days.

Satellite areas should be inspected at least weekly as part of the overall storage area inspections (see subsection 4.4).


4.2 Hazardous Waste Storage Area (This section is mandatory)The Hazardous Waste Storage Area is the central storage location for hazardous waste. A generator can accumulate hazardous waste on site for up to 90 days without becoming subject to RCRA permit standards if:

The waste container is clearly marked with the date accumulation began and labeled with the words "Hazardous Waste."

The waste is stored in containers meeting the requirements of 40 CFR Part 265, Subpart I and J (same container requirements as for satellite areas). Containers must not be opened, handled or stored in a manner which may rupture them.

Emergency preparedness provisions and a contingency plan are in effect at the generating site:

- Spill control equipment should be in close proximity to storage area (including absorbent and empty containers).

- Sufficient aisle space (18 to 30 inches depending on height of stacking) must be maintained to allow unobstructed movement of personnel and emergency equipment (see Section 9 for complete emergency requirements).

- Internal communication or alarm system should be easily accessible. If the hazardous waste area is in a Class 1 Division 2 environment as defined by the Occupational Safety and Health Act (e.g. flammable vaults) then the equipment used in those areas must meet the rating certification for operation in a Class 1 Division 2 location.

- If these communications systems are not in the immediate area where the waste is being stored, then a sign needs to be posted to clearly indicate where the communications devices are located. At the communication devices all emergency telephone numbers must be posted.

- In addition, an air horn shall be available in the hazardous waste areas if there are no communication devices. The air horn will be used by any employee engaged in “hazardous waste handling in the vaults” to notify another employee positioned outside of the vault whose sole function is to access an internal alarm or emergency communication device should a fire, explosion or release occur. Employees with RCRA responsibility shall be trained in this procedure.

All employees involved in handling hazardous waste must be appropriately trained.

Use Form F105.09: Waste Accumulation Log to track waste generation and storage at your facility. Facilities located in California should use Tool T105.03: Gentrak to assist in tracking waste accumulation and to determine the appropriate ship date.


4.2.1 Tank SystemsTank requirements apply to the entire "tank system." The tank system includes the tank itself, the pumps and piping connected to the tank, and the secondary containment system around the tank. The tank must be clearly labeled with the words "Hazardous Waste.'

These requirements are intended to ensure that the tank systems are designed and operated to minimize the impact of the waste on human health and the environment.

The EPA tank system regulations for LQGs may be found in 40 CFR 265 Subpart J. Some state requirements and effective dates may differ. Below is a brief summary of the EPA’s conditions.

Hazardous waste storage tanks which were in existence in July 1986 and did not have impervious secondary containment should have had an integrity assessment by January 12, 1988.

Tanks must be equipped with secondary containment by January 12, 1989, or when the tank is 15 years old, whichever is later. For example, a tank which is five years old in January 1989 wiII not need secondary containment for another 10 years.

Secondary containment for hazardous waste tank systems must be designed to prevent release of hazardous waste to the environment. It must be able to contain 100 percent of the contents of the largest tank in the area plus rainfall, if not located under a roof. Specific design requirements for generator tanks are spelled out in the regulations in 40 CFR 265 Subpart J.

The tank system must be inspected once each operating day for:

- overfill/spill control equipment;

- signs of corrosion or release of waste from the tank, pumps, piping, and secondary containment; and

- monitoring data to ensure that the tank is being operated according to its design.

Fisher sites do not utilize tank systems to store hazardous waste.

4.2.2 Air EmissionsContainers that have a design capacity of equal to or greater than 26 gallons are subject to the Container Level 1 standards as specified in 40 CFR 265.1087(c). A container must be equipped with a cover and closure device that forms a barrier over the container such that there are no visible holes, gaps or other open spaces into the interior of the container.

A container will be equipped with covers and closure devices, as applicable to the container, that are composed of suitable materials to minimize exposure of the hazardous waste to the atmosphere and to maintain the equipment integrity for as long as it is in service.


When quantities or batches of material is added to the container over a period of time, the generator shall ensure that additional material is not added to the container within 15 minutes of the initial batch.

Each cover must be maintained closed except when adding or removing waste. If a defect is identified, first attempts at repair must be made within 24 hours. If repair of a defect cannot be completed within 5 calendar days, then the hazardous waste shall be removed from the container and the container shall not be used to manage hazardous waste until the defect is repaired.

4.2.3 Ignitable Wastes Locate ignitable or reactive wastes at least 50 feet from the facility's property line.

The containers are subject to the air emission requirements found in 40 CFR 265 Subpart CC.

Separate these wastes and protect them from sources of ignition or reaction (e.g., open flames, smoking, cutting and welding, hot surfaces, friction sparks, spontaneous ignition, and radiant heat. "No Smoking" signs must be placed wherever there is a hazard from ignitable/reactive waste (40 CFR 265.17(a)).

4.2.4 Incompatible Wastes Never mix incompatible wastes in the same container and maintain distinct, clearly

marked areas for incompatible wastes separated by a dike, berm wall, or other device.

Do not place hazardous waste in an unwashed container that previously held an incompatible waste or material.

4.2.5 Non-Hazardous WasteNon-hazardous waste is not regulated under RCRA. Label it as non-hazardous waste and keep it separate from the hazardous waste storage area. Non-hazardous waste may be classified as special/industrial waste with state specific storage requirements. Check the State Summaries in Appendix 8 or with and Regulatory Affairs.

4.2.6 Secondary ContainmentAlthough federal regulations do not dictate design standards for a secondary containment system at the generator's hazardous waste storage area, it is recommended that spill containment be provided and that the standards from the RCRA regulations (40 CFR 264.175) are used.

Basic Principles of a Containment System: Underlie the containers with a base which is free of cracks and gaps to contain leaks, spills,

and accumulated precipitation. The base should be constructed of reinforced concrete or other compatible material.

Slope or otherwise design the base so as to drain and remove liquids resulting from leaks, spills, or precipitation unless the containers are elevated or otherwise protected from contact with the accumulated liquids.

Design the containment system to have a capacity of 10 percent of the total volume of the containers or 110 percent of the volume of the largest container, whichever is greater or you


can purchase drum storage “trays”.

Arrange the containers to separate incompatible wastes by a berm, dike, etc., so that in the event of a spill, incompatible wastes will not mix.

Prevent run-on to the containment system by providing weather protection.

Remove spilled or leaked waste and accumulated precipitation from the collection system to prevent overflow. Document any such removal actions. Ensure that pumps used to remove accumulated rainfall or spills are manually operated to prevent inadvertent discharge of contaminated liquid.

Do not install drain lines installed through the walls of dikes or berms. Permanently seal drain lines in existing container storage areas.

4.3 SQG Exemptions/Requirements (This section is mandatory) SQGs may store hazardous waste on site for up to 180 days provided the total amount accumulated never exceeds 6,000 kg (13,200 lbs).

This time limit is extended to 270 days if the generator ships its waste to a TSDF over 200 miles away.

SQGs are subject to all the same storage requirements except one; they do not need a 50-foot buffer zone between the facility boundary and the container storage area for ignitable or reactive wastes.

An additional requirement is the posting of the following information near the telephone/ communication system:

The name and telephone number of the emergency coordinator;

The telephone number of the fire department; and

The location of the fire extinguishers, spill control equipment, and fire alarms.

The tank system regulations for SQGs may be found in 40 CFR 265.201. Below is a brief summary of these conditions.

The tank must be labeled clearly with the words "Hazardous Waste”.

Secondary containment is required if the tank is open-topped (no roof) and two feet of freeboard are not maintained. The secondary containment must have a capacity equal to or greater than the volume of the top two feet of the tank.

There must be a waste feed cutoff system or bypass system on any tank into which waste is fed continuously.

Tank systems must be inspected to ensure proper operations and maintenance.


When the tank is no longer required for hazardous waste storage, all waste and waste residues must be removed from the tank, the discharge control equipment, and the confinement structures. Fisher sites do not store hazardous waste in tanks.

SQG should also use Form F105.09 Waste Accumulation Log to track all waste generation (hazardous, non-hazardous, universal, etc.) and storage at your facility.

The minimum storage requirements for any Fisher generator are for those of a SQG even if the site is a CESQG. The only exception is onsite storage time; as a CESQG you have one year to ship waste off-site.

4.4 Inspection of On Site Storage Areas (This section is mandatory)All storage areas and containers holding hazardous waste must be inspected at least weekly. A container storage area inspection form (Form F105.11) must be completed each time an area is inspected, in order to have a record of the inspection. The same form may be used to inspect the satellite accumulation area; however, the top of the form should identify which area is being inspected. Inspections must be recorded and maintained at the facility.

The inspection form should show what items are checked when conducting the inspections, the name of the inspector, the date and time of inspection, and the findings. Any remedial action taken to correct problems found during the inspection should also be noted on the form. These forms must be kept for three years from the date of the inspection.

Inspectors must be appointed by facility management and must be trained in conducting inspections.

Any time a problem is noted; the inspector must correct the problem or report the condition to someone who can correct the problem. The inspector must footnote any problems and explain the problem on the backside of the inspection form. Any corrective action taken must also be noted on the form when it is completed. All employees are required to notify their supervisors if they notice any problems in the accumulation or storage areas.

The person(s) responsible for inspecting the area is/are ____________________.

4.5 Empty Container ManagementEmpty containers are not subject to hazardous waste regulations providing they meet federal and state definitions of "empty." Empty containers must be managed to ensure that they meet the necessary requirements and are handled appropriately.

A container is empty when:

All waste is removed by common practices, i.e., pumping, pouring, aspirating, and less than one inch of residue remains, or no more than 3 percent remains in a container of 110 gallons or less, or no more than 0.3 percent remains in a container greater than 110 gallons.


For an acutely toxic waste, the container must be triple rinsed or cleaned by another method showing equivalent removal or the inner liner removed. All three rinsates must be collected and handled as a hazardous waste.

A container that has held a gaseous hazardous waste is empty when the pressure approaches atmospheric pressure.

4.5.1 Reuse of Containers Old markings should be removed or obliterated from containers before recycling or disposing of containers. Some containers cannot be reused such as single trip containers (STC) or non reusable containers (NRC) unless special conditions are met.

Prior to reusing drums, please contact the Regulatory Affairs.

A drum that previously contained a hazardous material must be transported in the same manner as required for the hazardous material, unless the drum is "empty." Empty containers being transported for reuse and reconditioning are not subject to manifesting, shipping paper, or placarding requirements for hazardous waste. (49 CFR 173.28)


5 TRANSPORTING HAZARDOUS WASTE5.1 Pre-Transport RequirementsRCRA sets the requirements for container management while waste is being stored on site, but once it is being prepared for off-site shipment, it becomes subject to the Department of Transportation (DOT) requirements for the packaging of hazardous materials (49 CFR, 173, 178, and 179) which specify packaging, labeling, marking, and placarding requirements.

Fisher Scientific has a national contract for the transportation and disposal of hazardous waste. These contractors are familiar with the regulatory requirements, but it is the responsibility of ______________ (site manager) to assure that all wastes are packaged in accordance with DOT requirements prior to off-site shipment.

5.1.1 PackagingDOT specifies packaging requirements in the DOT Hazardous Materials Table (49 CFR 172.101). Materials for which packaging requirements are not given must be securely packaged in strong, tight packages meeting the general container specifications.

5.1.2 Labeling/MarkingEach container of 110 gallons or less must be marked with the following information:

HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency.

Generator's Name ____________________________________

and Address ____________________________________

____________________________________

Manifest Document Number ______________________________

Prior to shipping, the hazardous waste marking/label must contain the following information as specified in 40 CFR 262.32 and 49 CFR 172.304:

Label Information InstructionsDOT shipping name Proper shipping names for hazardous wastes

are given in the DOT Hazardous Materials Table. The name must be preceded by the word "Waste" [Table 172.101]. The designation "RQ" must be added either before or after the shipping name, if the container is carrying a waste in excess of its reportable quantity.

Identification number The UN number designated by DOT.


Label Information InstructionsFacility name and address Self-explanatory.

EPA generator identification number Your EPA ID number (see Section 2).

EPA hazardous waste number The RCRA code for waste identification (see Section 3).

Waste accumulation start date Date on which the material was declared a waste. This is the date when:

Waste is first put into the hazardous waste storage area.

Containers are filled and moved from the satellite accumulation area to the Hazardous Waste Storage Area.

Hazardous waste manifest document number This number should be added when the material is ready for shipping (see Section 7).

5.1.3 Placarding The appropriate placard must be offered to the transporter. This will show the proper DOT shipping number as found in 49 CFR Part 172. 500 Subpart F. Placards must be placed on all transportation vehicles in order to identify the hazard of the materials contained. Only DOT specification placards may be used. Ensure that Fisher’s National Waste Contractor has the proper placards available, as it is a generator's responsibility to make placards available to the transporter.

5.2 Reportable QuantitiesDOT has an appendix to the Hazardous Materials Table, summarizing the reportable quantities (RQ) that the EPA has set for each hazardous substance regulated under CERCLA. All RCRA hazardous wastes are included in the definition of hazardous substances; therefore, each waste number has an assigned RQ.

The RQ is that quantity of a material which, if released into the environment, triggers the reporting requirement specified in the RCRA contingency plan. Under the DOT regulations, the marking on a shipping container must indicate whether it is carrying a hazardous substance in an amount equal to or greater than the RQ for that substance. If the material is equal to or greater than the RQ, you must add the letters "RQ" on the hazardous waste marking/label, either before or after the DOT shipping name. This requirement to indicate reportable quantities, applies to filling out the hazardous waste manifest as well. The manifest requirements are discussed in the next chapter.

5.3 Land Disposal Restrictions (LDR)Before shipment offsite, generators must identify which wastes are subject to land disposal restrictions (LDRs) (40 CFR 268).


Generators must determine if the waste requires treatment prior to land disposal to meet LDRs; must ensure that waste meets LDRs prior to land disposal; and must prepare LDR notifications and certifications. Ensure that all necessary LDRs are completed before Fisher’s National Waste Contractor leaves the facility.

Generator Responsibilities: Determine if LDRs apply by:

o Knowledge of the waste;

o Testing the waste; or

o Testing an extract of the waste

Notify the facility accepting the waste (TSDF) as to its status.

The requirements for notice and certification are described in 40 CFR 268.7 and vary depending on the characterization of the waste. An LDR Notice to File is found as Form F105.06. In general, however, when a waste is prohibited for disposal, the manifest must be accompanied by a notice containing the following information:

LDR Notice: EPA hazardous waste number;

Corresponding treatment standards (40 CFR 268.32 or RCRA Section 3004(d));

Manifest number for the waste shipment; and

Waste analysis data, where available.


6 UNIFORM HAZARDOUS WASTE MANIFEST 6.1 Manifest Requirements (This section is mandatory)Both SQGs and LQGs are required to manifest their hazardous waste when it is shipped off-site to the treatment or disposal facility. A manifest form is required any time hazardous waste is sent offsite for treatment, storage, and disposal. One manifest is required for every truck carrying hazardous waste offsite.

The manifest is the means by which the waste is tracked from "cradle to grave,” that is, from the point of generation to the point of disposal. It is a legally binding document and it is generally uniform across the United States. Generators are required to maintain a copy of the signed manifest on-site and to forward copies to the generator and TSDF states. A final copy is to be returned to the generator to confirm that the waste was received.

Note: Additional copies may be necessary if the state in which the TSDF is located requires a copy from the generator and the TSDF.

Each manifest must be kept on file for three years; manufacturing locations must send a copy to Corporate Regulatory Affairs and distribution operations to the Regional ES&H Manager.

Fisher Scientific has a national contractor for transportation, treatment, and disposal of hazardous waste. The contractor generally fill out the manifest, however, the generator is ultimately responsible for the accuracy of all the information; therefore, it is important to review the manifests to make sure they are accurate and complete. Several states require additional information (i.e., waste codes in Texas) on the manifest. Confirm state specific manifest information requirements with the appropriate environmental agency

When reviewing the manifest, use Tool T105.04: Manifest Review Sheet and the completed manifest template to ensure that all required information is complete.

6.1.1 Manifest Requirements for Distribution Centers Points to keep in mind when manifesting your hazardous waste to ensure that shipments are in compliance with Fisher Scientific Policies and Programs and the Fisher’s National Waste Contractor How to Do Business Document:

NO F-LISTED WASTES—unless the facility has a machine shop, Fisher Logistic facilities do not generate F-listed wastes. Be aware that alcohols in stain solutions do not merit an “F” waste code.

CYANIDE SOLUTIONS ARE D003—Fisher Logistic facilities carry a number of products that contain potassium cyanide or sodium cyanide at low concentrations (e.g., Lyse III solution). Since the cyanide is not in the solution as the sole active ingredient, a P-waste code is not appropriate. However, these solutions are still considered to be hazardous wastes. A D003 waste code is correct; if these solutions came into contact with an acid, toxic gases might be given off.

SEND COPIES:


DISTRIBUTION CENTERS: TO REGIONAL ESH MANAGERS—Copies of manifests should be sent IMMEDIATELY FOLLOWING THE WASTE SHIPMENT to your Regional ES&H Manager. Past practice required manifests to be sent to Park Lane once the signed copy was received from the TSDF. This practice is being modified to increase familiarity with the waste streams generated at the various locations, and to quickly identify and correct any discrepancies.

MANUFACTURING LOCATIONS: CONTINUE TO FORWARD TO PARK LANE

IF YOU SHIP IT, FISHER IS THE GENERATOR—Regardless of whether materials become wastes because they:

expire on the shelf,

are spilled,

are ordered for disposal by a vendor, or

are unwanted by a customer.

Fisher is considered to be the GENERATOR of that waste. We have to ensure it is classified correctly, labeled in the waste area, accounted for on the Generator Status Logs (F105.01 and F105.16) and Waste Accumulation Logs (Form F105.09), and properly coded on the manifest.

6.2 Returned Manifest A copy must be returned to the generator within 45 days. If it is not received by the generator within 35 days, attempts should begin to locate it. If it has not been located within the 45-day limit (60 days for the small quantity generator), an exception report must be submitted to the agency. This report includes a copy of the carbon kept when the waste left the generating facility, and a description of what efforts have been taken to locate the waste.

If another 10 days pass and you have still not received a copy of the manifest, you must file an Exception Report with the EPA Regional Administrator. See subsection 7.2.3 for specific requirements.

SQGs must file a Modified Exception Report if they do not receive a copy of the manifest after 60 days. Use Form F105.13: Container and Manifest Tracking Form to document when the signed manifests are returned.


7 RECORDKEEPING AND REPORTINGEPA and state regulations require generators of hazardous waste to maintain a variety of records for a specific time and to submit reports.

7.1 Recordkeeping (This section is mandatory)Retain the Following Documents for Three (3) Years:

A copy of all manifests;

Copies of test results, waste analysis, or other determinations made in accordance with 40 CFR 262.11 (see Section 3);

Biennial reports;

Exception reports;

Employee training requirements and records (see Section 8);

Inspection forms (see Section 4); and

Copies of LDR certifications and notifications.

Additional Documents to be Maintained On-Site: Contingency plan (see Section 9);

Waste minimization plan (see Section 10);

Facility application for EPA ID number and EPA response;

Emergency contracts and agreements with local hospitals, fire department, contractors, etc.; and

Manifest Tracking Sheet (see Form F105.13).

7.2 Reporting As generators of hazardous waste, Fisher Scientific facilities are required to submit three kinds of reports:

Emergency Reports

Periodic/Biennial/Annual Reports

Exception Reports

A copy of all such reports must be reviewed by Regulatory Affairs in Pittsburgh prior to submission to a government agency. A copy of the final report must also be sent to Corporate Regulatory Affairs.


7.2.1 Emergency Reports (This section is mandatory)All generators must comply with the Contingency Plan and Emergency Procedure requirements, which, in the event of a release, fire, or explosion, stipulate the following:

Immediate notification to the government official designated as the on scene coordinator for that geographical area; or

Immediate notification to the National Response Center at 800/424 8802. The report must include:

- The name, address, and U.S. EPA Identification Number of the generator:

- Date, time, and type of incident (e.g., spill or fire);

- Estimated quantity and disposition of recovered materials, if any;

- The extent of injuries, if any; and

- The possible hazards to human health, or the environment, outside the facility.

In the event of spills, contact the facility supervisor and Corporate Regulatory Affairs in Pittsburgh.

7.2.2 Periodic/Biennial/Annual Reports (This section is mandatory)The EPA requires that large quantity generators (LQG) submit a report every two years (on the even year) by March 1.

Federal hazardous waste regulations define LQG as generating equal to or greater than 2200 pounds of hazardous waste or 2.2 pounds of acutely hazardous waster per month.

The information in this report includes what wastes were generated in the previous year, the quantity of each, and the disposition of the waste. The methods used to minimize the quantity and/or toxicity of hazardous waste generated is also included in this report.

The report must be submitted every even-numbered year. Several states require annual reports to be submitted on March 1 (Texas due date is 1/25 unless filing electronically through the STEERS program).

Small quantity generators (SQG) are often exempt from preparing these reports; however the facility's generator status must be clearly documented to be eligible for this exemption.

Federal regulations define SQG as generating less than 2200 pounds of hazardous waste and 2.2 pounds of acutely hazardous waste per month.

Some states do not exempt SQGS from filing these reports. Refer to 105.01 Appendix 9 that follows for your state’s requirements.


Whether LQG or SQG, when determining if your facility needs to submit a report:

Review your facility's prior year hazardous waste generation rate and accumulation per month by referring to your Hazardous Waste Generation Status Log (Forms F105.01 and F105.16). This generation rate will determine the generator status of your facility during the past year. Pay particular care to the generation and accumulation of acutely hazardous waste. If you exceeded 1 kg/mo. of an acutely hazardous waste (either generated or stored) AT ANY TIME you are a large quantity generator for that year. This must match the generator status identified on the EPA form 8700-12 that is on file for your facility.

Review 105.01 Appendix 9 to determine your state's hazardous waste reporting and waste minimization documentation requirements.

Distribution Centers and Manufacturing Plants: Complete Form 105.14 indicating your generator status for the previous year. Sign the Form and fax it, along with your Hazardous Waste Generator Status Log (Form F105.01 or F105.16) AND EPA Form 8700-12 to Central Office (412.490.8930) no later than the last Wednesday of January. If an annual report is required, it will be prepared for you using software purchased for this task and the data downloads from FISHER’S NATIONAL WASTE CONTRACTOR.

Form F105.17 includes a Waste Minimization Plan template for your use in documenting your waste minimization efforts.


Information that is Included in Biennial/Annual Reports: The EPA ID number, name, and address of the generator;

The calendar year(s) covered by the report;

The EPA ID number, name, and address for each off-site TSDF to which waste was shipped during the year;

The name and EPA ID number of each transporter used during the reporting year;

A description, EPA hazardous waste number, DOT hazard class, and quantity of each hazardous waste shipped offsite. This information must be listed by EPA ID number of each off-site facility to which waste was shipped;

The certification signed by the generator's authorized representative; and

A description of efforts undertaken during the year to reduce the volume and toxicity of the waste generated.

7.2.3 Exception Reports (This section is mandatory)The generator must file an Exception Report with the EPA Regional Office when a manifest has not been returned by the TSDF within 45 days of the waste's acceptance.

A Small Quantity Generator must file a Modified Exception Report if the signed manifest is not received within 60 days after initial transport.

Note: Some states have different reporting periods.

Exception Reports Must Contain: A legible copy of the manifest for which the generator has not received TSDF confirmation;

and

A cover letter signed by an authorized agent of the generator detailing efforts taken to locate the waste and the results of those efforts.

Before filing an exception report, it is important to first determine that the waste arrived and was managed properly at the TSDF. If that is so, and if the failure to receive a TSDF signed copy was a clerical error, obtain a letter to that effect and the manifest form itself, if it can be located. The generator is still required to submit the Exception Report, noting in the cover letter that the shipment arrived and the manifest was lost. In addition, if a facility other than the designated or alternate facility returns the manifest, an Exception Report must be filed.

Federal law requires Exception Reports to be maintained by the generator for three years from the due date of the report.


7.2.4 Recordkeeping System Manifests and signed copies from designated facilities;

Hazardous waste manifests and land ban notifications;

Land disposal restriction certifications;

Exception reports;

Generator status forms;

Hazardous Waste Storage Inspection forms;

Training Documents;

Organizational chart/job descriptions for hazardous waste management personnel;

Standard operating procedures for hazardous waste storage, handling, and disposal;

Notification of hazardous waste activity form;

EPA identification number;

Inventory of hazardous waste;

Waste profiles/test results/waste analyses;

Biennial/annual reports;

Speculative accumulation records;

Training records;

Contingency plan;

Waste minimization/pollution prevention plan;

Notifications of hazardous waste oil fuel marketing or blending activity;

State and/or federal agency inspections;

Notices of violations (NOVs); and

Past audit reports (must be maintained in a confidential file in separate filing cabinet).


8 TRAINING (THIS SECTION IS MANDATORY)The LQG is required to prepare and follow a personnel training program. This program describes the type of training each employee will receive. This may be classroom instruction, on-the-job training, or a combination of both. The program must include instruction that teaches facility personnel hazardous waste management procedures relevant to their position.

The program must instruct the employees to conduct their duties in a way that ensures the facility's compliance with the RCRA regulations. At a minimum, the training must be designed to ensure that facility personnel know how to respond to an emergency.

Personnel must complete the training program within six months after the date of their employment or assignment to the facility. The employees must not work unsupervised until they have been trained. Each employee must participate in an annual review.

Additionally, the LQG must keep certain documents and records regarding personnel training. These include:

the job title and employee name of each position related to hazardous waste management;

a written job description for each of these jobs which includes the requisite skill, education, or other qualifications, and the duties of the person in each position;

a written description of the training given to each person; and

records documenting that the training has been completed by these employees.

Training records must be kept on all current personnel until closure of the facility. Training records on former employees must be kept for at least three years from the date they last worked at the facility. Such records may accompany personnel who move to other positions within the company. All training records are to be stored via the Fisher Trainer on-line training program. Records are automatically stored when training is taken via a session in the on-line library. Group training or hands-on training conducted can also be logged in the system by faxing the attendee sign-in sheet and a copy of the training course outline to Pure Safety at 615-367-3887.

The Fisher Scientific Hazardous Waste Management Written Training Program is included as Appendix 5.

Form F105.07, ESH Record of Training Form, can be used as a training documentation form and Form F105.08 as a RCRA Written Job Position Description Form.


9 EMERGENCY PREPAREDNESS AND PREVENTION9.1 Emergency Preparedness Provisions (This section is mandatory)Generators who store hazardous waste on-site must be maintained and operated to minimize the possibility of a fire, explosion or other accidental release.

Preparedness Provisions Include: The facility must be equipped with:

o An internal communication or alarm system

A radio or telephone readily available to request outside emergency assistance (e.g., local police and fire departments). Since radios or telephones are not allowed in the Flammable Vault, an air horn must be available. In the event of a release of a hazardous waste, the air horn will be sounded so that the Emergency Coordinator can request outside emergency assistance.

o An adequate water supply

o Portable fire extinguishers, fire control equipment, and spill control equipment

The above equipment must be tested and maintained.

All persons involved in waste handling must have immediate access to an alarm system or emergency communications device.

Sufficient aisle space must be maintained to allow unobstructed movement of personnel and equipment in the event of an emergency, if required for emergency response.

The operator must attempt to make emergency arrangements with local police, fire departments, and hospital, as appropriate for the type of waste handled on-site.

9.2 Contingency Plan (This section is mandatory)A contingency plan is the central document of the preparedness and prevention program. It is designed to minimize the hazards to human health and the environment by providing the basic information necessary to respond to hazardous waste emergency incidents. The provisions of the plan must be carried out immediately whenever there is a fire, explosion, or release of hazardous waste or hazardous waste constituents which could threaten human health or the environment.

Contingency Plan Should Include: Description of incident response to fires, explosions and hazardous waste releases.

Description of arrangements agreed to by local police and fire departments, hospitals, contractors, and state and local emergency response teams.

An up-to-date listing of names, addresses, and phone numbers (e.g., office and home) of persons designated as emergency coordinator(s)

Identification of primary coordinators and alternates.

Listing of emergency equipment as mentioned in subsection 9.1

o Fire extinguishing systems

o Spill control equipment


Contingency Plan Should Include:o Communications and alarm system (internal and external)

o Decontamination equipment

Description of the:

o Location of equipment

o Physical description of equipment

o Equipment capabilities

Evacuation plan, including:

o Evacuation signals

o Evacuation routes (primary/secondary)

The LQG must maintain copies of the plan at the facility and submit copies to police departments, fire departments, hospitals, and state and local emergency response teams. (40 CFR 264.53; 265, Subpart D)

The plan must be reviewed and immediately amended whenever:

The facility permit or applicable regulations are revised;

The plan fails in an emergency;

The facility changes in a way that materially increases the potential for incidents or changes the responses necessary for emergencies (e.g., design, construction, operation, maintenance);

The list of emergency coordinators changes; or

The list of emergency equipment changes.

A RCRA Contingency Plan template is presented in Form F105.15.

9.2.1 Emergency CoordinatorA person or persons must be designated as emergency coordinator(s) at each Fisher Scientific facility. At all times, the emergency coordinator must be either on the facility premises or on call (i.e., available to respond to an emergency by reaching the facility within a short period of time) with the responsibility for coordinating all emergency response measures.

In an emergency, the emergency coordinator's responsibilities are as follows:

1. Immediately call or activate facility alarms to notify police, fire departments, medical services (when help is needed), and the Regulatory Affairs Department.

2. Identify the character, exact source, amount, and extent of released material, and assess hazards to human health and the environment.

3. If the assessment indicates that evacuation of local areas may be advisable, the emergency coordinator must immediately notify appropriate local authorities.


4. If the release, fire, or explosion will threaten human health and the environment outside the facility, notify:

Local authorities, if evacuation of the area is required; and

The National Response Center (NRC), which can be reached by calling 800 424 8802. The report to the NRC must include:

Coordinator's name and telephone number

Name and telephone number of facility

Time and type of incident

Name and quantity of material involved

Extent of injuries (if any)

Possible hazards

5. Ensure that fire, explosions, etc., will not spread or recur by:

Stopping processes and operations;

Collecting and containing released waste; or

Removing or isolating containers.

6. Arrange for treatment, storage, or disposal of the recovered waste and any contaminated soil or water and ensure that the facility does not treat, store, or dispose of any waste that may be incompatible with the released material.

7. Ensure that all emergency equipment is cleared and fit for use before operations are resumed.

9.2.2 Facility Owner/Operator Responsibilities (This section is mandatory) Notify the Regional Administrator and appropriate state and local authorities that the

facility is in compliance with 5 and 6 above before operations are assumed in the affected areas of the facility.

Submit a written report to the Regional Administrator within 15 days consisting of the same information as reported to the NRC as well as an estimation of the quantity and disposition of recovered materials.

9.3 SQG Requirements (This section is mandatory)

SQGs are exempt from having a formal contingency plan; however, they are subject to a series of more limited requirements.

The following information must be posted next to the telephone/ communication system:

- Name and telephone number of emergency coordinator;


- Telephone number of local fire department, unless the facility has a direct alarm;

- Location of fire extinguisher, spill control material and fire alarm, where applicable

The generator must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies.

Emergency response procedures include:

- In the event of a fire, call the fire department or attempt to extinguish it using a fire extinguisher.

- In the event of a spill, contain it to the extent possible and clean it up as soon as possible, ensuring that both the hazardous waste and any contaminated materials/soils are collected.

- In the case of a life-threatening release outside the facility or a spill that has reached surface water, the emergency coordinator must notify the National Response Center (800/424-8802) and report the following information:

Name, address, and EPA ID number of the facility;

Date, time, type of incident;

Quantity and type of hazardous waste

Extent of injuries, if any

Estimated quantity and disposition of recovered materials, if any.

Completing the RCRA Contingency Plan, Form F105.15, and posting it near the telephone/communication system would satisfy these requirements.


10 WASTE MINIMIZATIONWhen a generator signs a manifest they make a waste minimization certification. The certification indicates that the large quantity generator has implemented a program to reduce the volume and toxicity of waste to a level deemed economically practical, and has selected a method of treatment to minimize the present and future threat to human health and the environment.

Small quantity generators certify that they have made a good faith effort to minimize their waste generation. A waste minimization program needs to document the progress made to comply with the certification. Additionally, many states have waste minimization or pollution prevention laws/regulations that require state specific plans to be prepared and updated.

As generators of hazardous waste, Fisher Scientific facilities are required to have a waste minimization program to reduce the volume and toxicity of waste generated on-site. The certification statement on each manifest indicates that the generator has a waste minimization program in effect.

The waste minimization program must describe what is being done to reduce the volume and toxicity of waste generated. A report of these efforts must be submitted to the EPA every two years with the Biennial Report, unless your state has other requirements. 40 CFR 262.41 (a) (6)-(7).

Minimization of waste may be achieved by making changes in the process to reduce the quantity of waste or to produce less toxic waste. An aggressive spill prevention program can also help to reduce the amount of hazardous waste generated

The program should include the following elements:

Top management support

Characterization of waste generation and management

Costs

Periodic waste minimization assessments

The program must reduce waste to the degree economically practicable and must ensure selection of a disposal method that minimizes threats to human health and the environment.

SQGs are only required to have "good faith" efforts to minimize waste and select the best waste management method available.

An example waste minimization plan is provided as Form F105.17.


Forms

See Form Numbers F105.01-F105.19 in Forms Section of Regulatory Affairs Manual

Effective Date: September 1997 Rev. # 3 Mandatory Discretionary Revision Date: September 2004

List of Forms

Form F105.01: Federal Hazardous Waste Generator Status Log and Conversion Chart

Form F105.02:

Form F105.3:

Form F105.04: Waste Stream Evaluation

Form F105.05: Hazardous Waste Determination

Form F105.06: Land Disposal Restriction Notice to File

Form F105.07: ESH Record of Training

Form F105.08 Job Description

Form F105.09: Waste Accumulation Log

Form F 105.10:

Form F 105.11: Container Storage Area Inspection

Form F105.12:

Form F105.13: Manifest Tracking Log

Form F105.14: Yearly Hazardous Waste Generator Certification

Form F105.15: RCRA Contingency Plan template

Form F105.16: California Hazardous Waste Generator Status Log and Conversion Chart

Form F105.17: Waste Minimization Plan template

Form F105.18: Waste Oil Questionnaire

Form F105.19: Universal Waste Compliance Checklist


ToolsSee Tool Numbers T105.01-T105.04 in Tools Section of Regulatory Affairs Manual


List of Tools

Tool T105.01: pH Calculator

Tool T105.02: TCLP Calculator

Tool T105.03: Gentrak (California Generators Waste Tracking Spreadsheet)

Tool T105.04: Manifest Review (plastic overlay)


Appendix 1:


Appendix 2:


Appendix 3:Universal Waste State Comparison


Appendix 4:Aerosol Can Management


Appendix 5:Hazardous Waste Management

Training Program


Appendix 6:Management of Solvent Contaminated

Wipes or Rags


Appendix 7:USDO P-listed wastes


Appendix 8: State Specific Waste Management Regulations


Appendix 9: Generator Hazardous Waste Report
