Hazardous Materials Management Policies and Procedures

Transcription

1 Hazardous Materials Management Policies and Procedures Table of Contents I. Purpose... 2 II. Scope... 2 III. Policy... 2 III.A. Methods for Managing Hazardous Materials... 2 III.A.1. Ordering... 2 III.A.2. Use... 3 III.B. Chemical Waste Handling Standard Operating Procedure... 5 III.B.1. Waste Room Maintenance... 7 III.B.2. Removal of Waste from Campus... 7 III.B.3. Waste Management Form Samples... 9 III.C. Radioactive Waste Handling Standard Operating Procedures III.C.1. Radioactive Waste Management Forms IV. Definitions V. Effective Date VI. Policy Management and Responsibilities VII. Approved (or Revised) April 2018 EHS-POL

2 I. Purpose The purpose of this Policy is to properly manage hazardous materials that Albert Einstein College of Medicine (Einstein) must use in such a manner to reduce or eliminate possible hazards to the public, our workers and the environment. II. Scope The policy and the procedures outlined herein apply to all Albert Einstein College of Medicine (Einstein) faculty, staff, and students. III. Policy Albert Einstein College of Medicine (Einstein) uses hazardous materials in teaching, research, building operations, construction and in housekeeping. Proper ordering, use, and disposal of these hazardous materials are needed to ensure that their adverse effects are eliminated. Waste is defined as a product or substance intended for disposal. Hazardous waste, defined by the United States EPA under the Resource Conservation and Recovery Act (RCRA), is a solid, liquid, or gas that is a discarded material and is abandoned, recycled, or otherwise inherently waste like. Types of Hazardous Wastes under RCRA: Chemicals listed in the RCRA regulations Waste that is tested using agency testing methods for certain characteristics or properties for reactivity, flammability, toxicity or corrosivity. Universal wastes Mixed wastes Other types of Hazardous Wastes Covered by other Federal Regulations: Medical Waste such as infectious agents, blood or blood-related products, sharps, laboratory ware Radioactive Waste sealed and unsealed sources of radioactive material Universal Waste such as computer monitors and certain fluorescent light bulbs Asbestos waste generated from renovations or repairs. III.A. III.A.1. Methods for Managing Hazardous Materials Ordering Order what you need. Excessive chemicals become hazardous waste. Encourage the use of non-hazardous materials. o Training o Informational flyers Track ordering o From purchase orders o Departmental inventories o Waste pickups o Incidents 9 April 2018 EHS-POL

3 Government regulations o SARA Title III o Fire Department flammable and explosive limits o Homeland Security Chemicals of Special Interest o Select Agents and Toxins III.A.2. Use Written guidelines to cover ordering, use and disposal o Laboratory- specific guidelines o General guidelines Training and Supervision o Individuals using hazardous materials must be qualified and properly trained and supervised in how to use these materials safely o Training by their education and experience o By Einstein departmental supervisors o By Einstein EH&S Classroom Web-based training Flyers and safety bulletins o Supervision Set right example Observe operations Instruct how to do the operation safely Provide the necessary discipline when needed o Material Safety Data Sheets (MSDS) Maintained by each department using hazardous materials On the Web ( Maintained by Einstein EH&S MSDS Stations around Einstein Proper receipt of hazardous materials o Add receipt date to hazardous materials label o Add item to departmental inventory Proper storage o Special cabinet o Separation o Labeling cabinet o Security Unauthorized use Proper Use o Use according to safety guidelines Adequate ventilation Personal protective equipment Shielding 9 April 2018 EHS-POL

4 o Update inventory o Labeling All items containing hazardous materials must be clearly labeled. This includes secondary storage and waste containers. o Collect waste properly o Have knowledge of what to do in the event of an emergency Proper Disposal o Individuals handling hazardous waste must be trained EH&S training classroom, flyers and on-line training Departmental training o Follow department guidelines o Follow College guidelines o Label waste container Date collection started Name of item collected Department manager s name and telephone extension o Fill out a waste ticket Hazardous chemical disposal Radioactive material disposal o Waste chemicals are brought to our hazardous waste storage room for processing and disposal by our hazardous chemical waste vendor Manifests are kept Since we are a large-scale generator of hazardous chemical waste we have a Contingency Plan in place o Radioactive Waste materials are brought to either our decay-in-storage room or our compaction room. Manifests are kept Contingency Plan is in place Waste Minimization o Chemicals offered to entire department before lab close out o Rechargeable batteries shipped for recycling o Substitute spirit filled, digital or thermocouple thermometers in place of mercury thermometers o Purchase of compress gas cylinders from a manufacturer who will accept the return of the empty or partially-used cylinders. o Treat photographic waste with silver recovery unit o Chlorinated solvent segregation o Recycling waste oil Other Hazardous Waste streams o Medical Waste Packaged at the point of generation in medical waste containers or sharp containers Picked up by Housekeeping and transported to the medical waste storage room Disposed by our medical waste broker Manifests kept for three years o Asbestos waste 9 April 2018 EHS-POL

5 Properly bagged, labeled and sealed by asbestos handlers Disposed by asbestos removal contractors Disposal manifests maintained o Universal Waste Non-green florescent lights picked up by our hazardous chemical vendor Computers and some metals are picked up by a separate disposal company Construction debris Records o Manifests Records for hazardous chemical, radioactive and medical disposal are maintained by Environmental Health and Safety o Training records Maintained by EH&S Maintained by individual supervisors Inspections and Internal audits o Performed by EH&S o Performed by area supervisors Emergency Procedures o Contingency Plan o Emergency Response Guidelines Booklet Wall poster in each department The Department of Environmental Health and Safety assists by picking up and transporting waste to the Hazardous Waste Rooms. Waste is segregated and prepared for off-site disposal by treatment, energy recovery or reclamation. III.B. Chemical Waste Handling Standard Operating Procedure Pickup Request: Environmental Health and Safety (EH&S) receives chemical pickup requests via , Fax, or delivery by laboratory staff directly to the EH&S Office. Administration Receipt of Request: An EH&S secretary gives each individual pickup request a unique number and time stamp indicating the date the request was received and entered into the tracking system. (Attached is an example of a completed, on-line request form.) Technician Processing of Chemical Waste Pickup Form: Waste pickup requests are dropped into the technician s mailbox by the office secretary after receiving a unique number and time stamp. Every pick-up request is tracked in an Excel file by the technician. Below is an illustration of the information that is tracked: 9 April 2018 EHS-POL

6 Room Number (Admin # ) Chanin 416: (M222) Golding G01: (M223) Notes Pickup Date Technician X - Notes 5/27/2011 WPG X - Notes 5/31/2011 WPG/JAN Price 322: (M224) X - Notes 6/2/2011 JAN Location and Labeling of Chemical Waste: Pickup request forms direct the technicians where to go and what chemical waste is to be removed. The party requesting the pickup is responsible for correctly completing and attaching waste labels to the materials slated for removal. (See attached labels.) Transportation of Chemical Waste: Appropriate Personal Protective Equipment (PPE) is worn by the technicians at all times. Waste materials are picked up and transported using the appropriate mechanical device including carts, drum dollies, freight elevators, etc. Each item picked up is inspected by the technician prior to its being moved. At this point, all hazards are identified and addressed to ensure safe handling of waste materials. On a case-by-case basis, usually involving a lab cleanout or highly hazardous material, our waste vendor will pack the chemicals directly from the lab. All chemical waste is transported to one of three chemical waste rooms which are engineered for storage of hazardous materials. Storage of Chemical Waste: Chemical waste is stored in three specially-designed rooms on Campus o Belfer B07 o Price 169 o Kennedy B51A Placement and Segregation of Waste Materials in Storage Room: Placards and instructional signage are placed in the chemical waste rooms to provide clear and specific directions for segregation. Waste materials are segregated according to their hazard class. Incompatible materials are kept separate from one another. Shelved materials are placed into chemical-resistant secondary containment bins and/or trays. Bulk materials need to be placed on spill pallets. Placement of the bins and trays on the shelving units acts as an additional means of segregation through physical separation. 9 April 2018 EHS-POL

7 Tracking Waste: Waste is tracked by a room-specific Excel file. The Excel file keeps a record of each waste bottle s contents, size, quantity, pickup date, pickup location and a description of hazard class. Bottle Content Diaminoben zidine Size Quantity Pickup Date Pickup Location Hazardous Class 500 ml 1 5/31/2011 G 01 Non- Regulated Acetic Acid 1 L 1 5/31/2011 G 01 Corrosive Acid Ammonia 500 ml 2 5/31/2011 G -1 Ammonia Bin III.B.1. Waste Room Maintenance Room Inspections: The chemical waste rooms are inspected weekly. The inspections follow the requirements set for a New York State Large Quantity/Small Quantity Generator. The inspector signs and dates the log book, noting issues, if any issues were found. If an issue is found appropriate, corrective action is taken and logged in the log book. III.B.2. Removal of Waste from Campus Waste is removed from Einstein via our waste disposal vendor at regularly-scheduled times. Waste materials are segregated and manifested following all applicable federal, state, local, and vendor-based laws and regulations. EH&S Site-Specific Guidelines for Waste Vendor: Waste should not be packed until it reaches its ship date. The ship date is dependent upon the generator status of the EPA ID number for the location of the waste (large quantity/small quantity generator). Only full drums should be pulled from Campus. If there is insufficient material of a certain hazard class, it should be left until the ship date is reached or a full drum is produced. Chemical Consolidations: Acceptable materials are poured off into 55-gallon drums in the Belfer, Price, and Kennedy waste rooms. Current consolidations include: o Flammable materials are poured off by our waste vendor during routine lab pack operations o Used oil and Ethidium Bromide gels are consolidated by EH&S technicians when necessary EH&S technicians are responsible for properly rinsing, defacing, and disposing of all containers remaining after chemical consolidation operations. 9 April 2018 EHS-POL

8 Vendor Waste Management: Einstein s waste vendor tracks the waste that leaves our facility to its final disposal. Waste leaving Einstein may be burned, treated, recycled, or buried as prescribed by various laws. Our waste vendor may be called on to provide proof that our waste is being handled and disposed in accordance with all applicable laws and regulations. By contract, our vendor must dispose of all our waste in accordance with the appropriate regulations. Waste Room Supplies: Combustible material such as packing material, etc., is kept to a minimum. A small stockpile of empty bottles is kept in the room in the event EH&S or, in special circumstances, a lab needs a containment vessel. All bottles available for re-use are thoroughly washed. An appropriate number of supplies are kept to allow EH&S to maintain a pack in progress. The supplies include drums of various sizes, bulb tubes and bulb boxes, drum liners, etc. Emergency Contact Numbers: Environmental Health and Safety Office o Main Office: o 24-hour emergency number: ext Chemical Waste Broker o Veolia: April 2018 EHS-POL

9 III.B.3. III.B.3(a) Waste Management Form Samples Hazardous Waste Label 9 April 2018 EHS-POL

10 III.B.3(b) Hazardous Waste Pickup Form 9 April 2018 EHS-POL

11 III.C. Radioactive Waste Handling Standard Operating Procedures Pickup Request: A two-sheet radioactive waste ticket is completed by lab personnel; grant number must be indicated on the form. The initiator of the request submits the form either electronically, by Fax or it is delivered or mailed to the EH&S Office. Regardless of the form s transmission to the Safety Office, one copy of the form must be attached to the waste. Each container of waste must have its own individual ticket. Administration Receipt of Request: The Radiation Secretary enters the information on the form into a database which assigns a unique waste pickup number which is entered onto the form along with the date. Once the pickup is complete, the date of pickup is entered into a database and the pickup form is filed. Interdepartmental Billing for radioactive waste pickup is done once a month. Technician Processing of Radioactive Waste Pickup Form: The form is then placed in the Safety Technician s mailbox. The technician has 3 business days to complete the pickup. Every pickup request is tracked in an Access file by the technician. Location of Radioactive Waste: The pickup request form directs the technicians where to go and what radioactivity is to be removed. Transportation of Radioactive Waste: Appropriate Personal Protective Equipment (PPE) is worn by the technicians at all times. Waste materials are picked up and transported using the appropriate mechanical device including carts, drum dollies, freight elevators, etc. Technician matches the office copy of the waste ticket to the ticket attached to each container. Radiation safety provides replacement yellow 5 gallon and white 10-gallon waste containers for containers that are bagged and labeled. Only if the freight elevators are not available can the technician use the passenger elevators and only if the elevator is empty. If passengers get on the elevator they are to be informed that radioactive waste is being transported. Storage of Radioactive Waste: DSR Belfer C03 Only short-lived isotopes are to be stored in the DSR (<90-day half-life). Segregate waste according to the half-life of the radioisotope. Technician transfers contents into a 30-gallon biohazard box, lined with a pink or red biohazard bag. 9 April 2018 EHS-POL

12 The technician hand ties or uses tape to secure the contents. A clear pouch is placed on the side of the box with a copy of the ticket. A blue label is affixed over the clear pouch which assigns the drum number The technician surveys the drums for initial dose rates and records the information on the label. The technician seals the box with clear tape when it is full. The name of the isotope, the start date, end date and activity are written in the appropriate sections on the label. Ullmann 113 Long-term waste, liquid scintillation vials (LSV) and other liquid waste is mainly stored in this room. Dry Waste: A liner is placed into an empty 55-gallon drum and placed in the compactor. The technician ensures that no LSV or other fluids are mixed in with the dry waste. The technician places a copy of the waste ticked in a clear pouch on the door of the compactor. A blue label is affixed to the compactor which assigns the drum number. Once waste is added to the drum, the technician closes the door and pushes DOWN to compact the contents. When the drum is full, a lid is placed over the drum, the ring is secured, and the bolt is tightened. Liquid Scintillation Vials: A liner is placed in an empty 55-gallon drum. The technician ensures that no dry waste is mixed with the LSV. The technician places a clear pouch on the side of the box and places a copy of the ticket in the pouch. The technician affixes a blue label over the clear pouch which assigns the drum number. Once the waste is added, a lid is placed over the drum, the ring is secured, and the bolt is tightened. Price 165 and Kennedy B52 All radiation waste is stored here regardless of radioisotope half-life. Waste is segregated by type and isotope. The same procedures for long- and short-lived isotopes are followed as appropriate. Disposal of decayed waste (DSR, P-165, K-B52): The waste is held for the required 10 half-lives. If no residual radiation is detected, it may be discarded as medical waste. The outside of the box is checked with a Geiger counter. The technician surveys the waste box for dose rates greater than background. If the technician finds dose rates greater than background, they will return it for longer decay time. The technician completes the Survey Record of Disposed Radioactive Waste from Decay-in-Storage sheet with the required information. (See below.) The technician ensures that there is no radiation tape or stickers among the decayed waste that will be disposed as medical waste. 9 April 2018 EHS-POL

13 The technician affixes a Stericycle label on the appropriate section of the box and writes the current date. The box(es) are transported to the respective loading dock and placed in the room that houses biohazard waste. Disposal of Long-Term Waste (U-113, P-165, K-B53) The technician writes the isotope, start date, end date and activity in the appropriate sections on the blue label when the drum is full. The technician wipes the outside of the drums to be picked up and documents the results. When the inventory meets the room capacity, a pickup date is scheduled with the radioactive waste vendor. The radioactive waste vendor picks up the drums; the waste is segregated and manifested according to federal, state, and local laws and regulations. Inventory and Records: The technician enters the waste pickup and processing information in the appropriate fields in the Radioactive Waste Inventory sheet in the storage room and the Access database. (See below.) No records are to be deleted. Whenever waste is discarded as medical waste or picked up by the waste vendor, the disposal date is entered into the inventory. Emergency Contact Numbers: Radiation Safety Officer (RSO) o Radiation Safety Office ext o Cell Phone Number Radioactive Waste Broker Veolia hour Einstein Emergency Number ext April 2018 EHS-POL

14 III.C.1. III.C.1(a) Radioactive Waste Management Forms Access DB of Radioactive Waste 9 April 2018 EHS-POL

15 III.C.1(b) Radioactive Waste Inventory 9 April 2018 EHS-POL

16 III.C.1(c) Survey of Disposed Radioactive Waste IV. Definitions None. V. Effective Date Effective as of: 9 April April 2018 EHS-POL

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