2.0 LISTED HAZARDOUS WASTES

Transcription

1 SOP Title: S.A.A. Generated Waste-(laboratories) SOP Effective Date: 02/01/2019 Page 1 of 54 Site: 263 Farmington Campus 400 Farmington Avenue 21 South Road EH&S Primary Content Approval Authority: Steven Jacobs, Director of EH&S EH&S Secondary Content Approval Authority: Robert Gottlieb, EH&S Specialist EH&S Document Control Administrator: Elizabeth Pokorski, Administrative Officer 1. PURPOSE & SCOPE Purpose- To define generation of regulated wastes, & the safe management procedures for these wastes at UConn Health s Laboratory Satellite Accumulation Areas (S.A.A. s). Scope- Define roles and responsibilities, basic rules & regulations regarding S.A.A. waste management; incorporating emergency contingency planning application & Personal Protective Equipment (PPE). 2.0 LISTED HAZARDOUS WASTES Wastes that are specifically identified in one of four lists developed by U.S. EPA in the federal hazardous waste regulations [40 CFR through ]. Each hazardous waste listing includes a description of a specific type of waste that EPA considers hazardous enough to warrant regulation. The four groups of listed hazardous wastes are easily identified by the letter that begins their 4-digit EPA waste code (i.e., F, K, U, or P ). See Appendix A, starting on page 13, for LISTED HAZARDOUS WASTE CATAGORIES PER EPA. 3.0 CHARACTERISTIC HAZARDOUS WASTE Subpart C Characteristics of Hazardous Waste General. [Comment: of this chapter sets forth the generator's responsibility to determine whether his waste exhibits one or more of the characteristics identified in this subpart] (a) A solid waste, as defined in 261.2, which is not excluded from regulation as a hazardous waste under 261.4(b), is a hazardous waste if it exhibits any of the characteristics identified in this subpart Characteristic of ignitability. (a) A solid waste exhibits the characteristic of ignitability if a representative sample of the waste has any of the following properties: (1) It is a liquid, other than an aqueous solution containing less than 24 percent alcohol by volume and has flash point less than 60 C (140 F), as determined by a Pensky-Martens Closed Cup Tester, using the test method specified in ASTM Standard D or D (incorporated by reference, see ), or a Setaflash Closed Cup Tester, using the test method specified in ASTM Standard D (incorporated by reference, see ). (2) It is not a liquid and is capable, under standard temperature and pressure, 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. (3) It is an ignitable compressed gas. (D) Using the Bureau of Explosives' Closed Drum Apparatus (see Note 1), there is any explosion of the vapor-air mixture in the drum. (4) It is an oxidizer. An oxidizer for the purpose of this subchapter is a substance such as a chlorate, permanganate, inorganic peroxide, or a nitrate, that yields oxygen readily to stimulate the combustion of organic matter (see Note 4). (i) An organic compound containing the bivalent -O-O- structure and which may be considered a derivative of hydrogen peroxide where one or more of the hydrogen atoms have been replaced by organic radicals must be classed as an organic peroxide unless: (A) The material meets the definition of a Class A explosive or a Class B explosive, as defined in (a)(8), in which case it must be classed as an explosive, (B) The material is forbidden to be offered for transportation according to 49 CFR and 49 CFR , (C) It is determined that the predominant hazard of the material containing an organic peroxide is other than that of an organic peroxide, or (b) A solid waste that exhibits the characteristic of ignitability has the EPA Hazardous Waste Number of D001.

2

3 Characteristic of corrosivity. (a) A solid waste exhibits the characteristic of corrosivity if a representative sample of the waste has either of the following properties: (1) It is aqueous and has a ph less than or equal to 2 or greater than or equal to 12.5, as determined by a ph meter using Method 9040C in Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA Publication SW-846, as incorporated by reference in of this chapter. (2) It is a liquid and corrodes steel (SAE 1020) at a rate greater than 6.35 mm (0.250 inch) per year at a test temperature of 55 C (130 F) as determined by Method 1110A in Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA Publication SW-846, and as incorporated by reference in of this chapter. (b) A solid waste that exhibits the characteristic of corrosivity has the EPA Hazardous Waste Number of D002. [45 FR 33119, May 19, 1980, as amended at 46 FR 35247, July 7, 1981; 55 FR 22684, June 1, 1990; 58 FR 46049, Aug. 31, 1993; 70 FR 34561, June 14, 2005] Characteristic of reactivity. (a) A solid waste exhibits the characteristic of reactivity if a representative sample of the waste has any of the following properties: (1) It is normally unstable and readily undergoes violent change without detonating. (2) It reacts violently with water. (3) It forms potentially explosive mixtures with water. (4) When mixed with water, it generates toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health or the environment. (5) 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 in a quantity sufficient to present a danger to human health or the environment. (6) It is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under confinement. (7) It is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure. (8) It is a forbidden explosive as defined in 49 CFR , or is a Division 1.1, 1.2 or 1.3 explosive as defined in 49 CFR and (b) A solid waste that exhibits the characteristic of reactivity has the EPA Hazardous Waste Number of D003. Are wastes that exhibit any one of the four characteristics listed below? An abbreviated definition is given for each one here. They are fully defined in the federal hazardous waste regulations [40 CFR through ]. Copies of these regulations may be obtained by contacting CT-DEEP or through U.S. EPA s web site at IGNITABILITY: (EPA Waste Code D001) o Aqueous waste solutions with a flash point lower than 140 F, ignitable solids, and materials that are designated by the U.S. DOT as oxidizers. o Alcohols in >24% concentration CORROSIVITY: (EPA Waste Code D002) o Liquid wastes with a ph less than or equal to 2.0, or greater than or equal to 12.5 REACTIVITY: (EPA Waste Code D003) o When mixed with water; or, are capable of exploding at room temperature and pressure or when heated under confinement Materials that are: normally unstable; react violently, explode, or emit toxic fumes. o Cyanide or sulfide bearing wastes o Generates/evolves toxic fumes or ignitable gases through contact with air or water TOXICITY: (EPA Waste Codes, D004-D043) o Materials containing greater than the regulated concentration of any of 40 contaminants listed in the federal hazardous waste regulations [40 CFR ] Toxicity characteristic. (a) A solid waste (except manufactured gas plant waste) exhibits the characteristic of toxicity if, using the Toxicity Characteristic Leaching Procedure, test Method 1311 in Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, EPA Publication SW-846, as incorporated by reference in of this chapter, the extract from a representative sample of the waste contains any of the contaminants listed in table 1 at the concentration equal to or greater than the respective value given in that table. Where the waste contains less than 0.5 percent filterable solids, the waste itself, after filtering using the methodology outlined in Method 1311, is considered to be the extract for the purpose of this section. (b) A solid waste that exhibits the characteristic of toxicity has the EPA Hazardous Waste Number specified in Table 1 which corresponds to the toxic contaminant causing it to be hazardous.

4 Table 1 Maximum Concentration of Contaminants for the Toxicity Characteristic EPA HW No. 1 Contaminant CAS No. 2 Regulatory Level (mg/l) D004 Arsenic D005 Barium D018 Benzene D006 Cadmium D019 Carbon tetrachloride D020 Chlordane D021 Chlorobenzene D022 Chloroform D007 Chromium D023 o-cresol D024 m-cresol D025 p-cresol D026 Cresol D016 2,4-D D027 1,4-Dichlorobenzene D028 1,2-Dichloroethane D029 1,1-Dichloroethylene D030 2,4-Dinitrotoluene D012 Endrin D031 Heptachlor (and its epoxide) D032 Hexachlorobenzene D033 Hexachlorobutadiene D034 Hexachloroethane D008 Lead D013 Lindane D009 Mercury D014 Methoxychlor D035 Methyl ethyl ketone D036 Nitrobenzene D037 Pentachlorophenol D038 Pyridine D010 Selenium D011 Silver D039 Tetrachloroethylene D015 Toxaphene D040 Trichloroethylene D041 2,4,5-Trichlorophenol D042 2,4,6-Trichlorophenol

5 D017 2,4,5-TP (Silvex) D043 Vinyl chloride Hazardous waste number. 2 Chemical abstracts service number. 3 Quantitation limit is greater than the calculated regulatory level. The quantitation limit therefore becomes the regulatory level. 4 If o-, m-, and p-cresol concentrations cannot be differentiated, the total cresol (D026) concentration is used. The regulatory level of total cresol is 200 mg/l. 4.0 OTHER WASTES REGULATED IN CT. There are certain hazardous wastes that do not need to be counted when determining your hazardous waste generator status, per below but are still regulated from a management standpoint. Wastes that are exempt from hazardous waste regulations under 40 CFR 261.4(c) through (f) or 261.6(a)(3). Hazardous wastes that are managed immediately upon generation only in an on-site elementary neutralization unit, wastewater treatment unit, or totally-enclosed treatment facility. Note: these terms are defined in 40 CFR Hazardous wastes that are recycled, without prior storage or accumulation, in hazardous waste recycling units. Hazardous waste residues in empty containers as defined in 40 CFR Universal Wastes that are managed in compliance with RCSA Section 22a-449(c)-113. Used oil that is managed in compliance with RCSA Section 22a-449(c)-119 (unless the used oil is subject to regulation as a hazardous waste because it has been mixed or contaminated with hazardous waste). Spent lead-acid batteries that are managed under RCSA Section 22a-449(c)-106(c) that are hazardous only because they exhibit the toxicity characteristic for waste codes D018 through D CT-REGULATED WASTES-(NON, RCRA) List of Non-RCRA Hazardous Wastes (Connecticut Regulated Wastes) Note: These are wastes which are neither characteristically nor listed RCRA Hazardous Wastes as per 40 CFR 261, but a facility permit is required by CGS Section 22a-454 for a person engaged in the business of storage, treating, disposing or transporting* them. List of Non-RCRA Hazardous Wastes (Connecticut Regulated Wastes) Waste Number Waste Name Description CR01 Waste PCBs Any waste material containing or contaminated by PCBs (Polychlorinated Biphenyls) in concentrations at or above 50 ppm (parts per million). These include, but are not limited to, PCB oils, items and equipment. CR02 Waste Oil Oil or petroleum that is no longer suitable for the services for which it was manufactured due to the presence of impurities or a loss of original properties, and is not miscible in water. These include, but are not limited to, crude oil, fuel oil, lubricating oil, kerosene, diesel fuel, motor oil, non-halogenated oil, and oils that are recovered from oil separators, oil spills or tank bottoms. CR03 Waste Water Soluble Oil Oil or petroleum that is no longer suitable for the services for which it was manufactured, due to the presence of impurities or a loss of original properties and is miscible in water. These include, but are not limited to, cutting oil emulsions or coolants. CR04 Waste Chemical Liquid Any wastes that are liquid, free flowing and/or contain free draining liquids and are toxic, hazardous to handle and/or may cause contamination of ground and/or surface water if improperly managed. These wastes may include, but are not limited to latex and solvent paint wastes, grinding wastes, waste sludges, antifreeze wastes and glycol solutions. CR05* Waste Chemical Solid Any chemical solid or semi-solid from a commercial, industrial, agricultural or community activity. These wastes may include, but are not limited to, grinding dusts, tumbling sludges, scrap plastic and rubber flash, and other ground or chipped waste solid. * Connecticut General Statutes do not require the transporter to be licensed to transport CR05 (Waste Chemical Solid). * Any chemical waste from laboratories not regulated as biomedical or hazardous per EPA. 4.2 UNIVERSAL WASTE MANAGEMENT What are the universal waste labeling and marking requirements? 40 CFR and with modifications under Section 22a- 449(c)-113(a)(2)(I) & (T) of the RCSA and Sections 22a-449(c)-113(c) and (d) of the RCSA; Public Act A generator must follow the labeling and marking requirements as outlined below: 1. Universal waste batteries (each battery) or a container in which the batteries are contained must be labeled or marked clearly with any of the following: "Universal Waste - Battery(ies)" or "Waste Battery(ies), or "Used Battery(ies)".

6 2. Each container in which the thermostats are contained, must be labeled or marked clearly with any one of the following: "Universal Waste - Mercury-Containing Equipment" or "Waste Mercury-Containing Equipment", or "Used Mercury-Containing Equipment". 3. Universal waste lamps (each lamp) or a container or package in which such lamps are contained must be labeled or marked clearly with any of the following: "Universal Waste - Lamp(s)" or "Waste Lamp(s), or "Used Lamp(s)". 4. A container containing recalled universal waste pesticides as covered under these regulations must be labeled or marked clearly with: The label that was on or accompanied the product as sold or distributed; The words "Universal Waste - Pesticide(s)" or "Waste - Pesticide(s)". A container of unused pesticide products as covered under these regulations must be labeled or marked clearly with: The label that was on the product when purchased, if still legible; or, if not feasible, an appropriate label as required under DOT regulations 49 CFR part 172; or, if not feasible, another label prescribed or designated by the pesticide collection program; and The words "Universal Waste - Pesticide(s)" or "Waste Pesticide(s)". 5. All universal wastes must be managed in a way to prevent spills and to maintain recyclability. 6. Accumulation start date (A.S.D.) 1 year from the date first generated. 5.0 SATELLITE ACCUMULATION AREAS (S.A.A. S) 5a. What are Satellite Accumulation Containers? Satellite containers are used for the routine collection of waste from a specific process. (S.A.A.) containers are to be located at or near the process that generates the waste, and that are under the control of the operator of the process generating the waste. (Satellite containers are not subject to the same requirements as regular storage containers, but may instead be managed under a special set of reduced requirements and as follows ;) 5b. What are the Requirements for the Management of Satellite Containers? Although there is no storage time limit for satellite containers, the CT-DEEP strongly recommends that wastes not be stored in satellite areas for any longer than is necessary to facilitate the initial collection of the waste. The longer that wastes are stored in satellite containers, the more likely it is that containers may become damaged or leak, or that a spill may occur. If wastes are generated in very small amounts, it is advisable to use smaller-sized containers, to minimize the length of storage. When this smaller container becomes full, the container can be taken to a fully-regulated storage area, EH&S s new chemical waste storage bldg., and the contents transferred to a full-sized container. 5c. When Does the Storage Time Limit Begin? The time limit begins when the first drop of waste is placed in the container. If the waste is collected in satellite accumulation containers, the time limit starts after the containers are transferred from the satellite accumulation area to a fully-regulated storage area. 5d. Satellite Containers Must be Managed as Follows: The containers must be in good condition. If a container becomes damaged or begins to leak, the waste must be transferred to another container. The containers must be compatible with the waste stored in them (e.g.)-storage of acids in a plain steel drum would not be acceptable. o o The contents within a collection container must also be chemically compatible The generator must use a container made of or lined with materials that will not react with, and are otherwise compatible with, the hazardous waste to be accumulated, so that the ability of the container to contain the waste is not impaired. 5e. Special Standards for Incompatible Wastes Incompatible wastes, or incompatible wastes and materials must not be placed in the same container. Hazardous waste must not be placed in an unwashed container that previously held an incompatible waste or material. A container holding a hazardous waste that is incompatible with any waste or other materials accumulated nearby in other containers must be separated from the other materials or protected from them by any practical means. A container holding hazardous waste must be closed at all times during accumulation, except; o o o When adding, removing, or consolidating waste; or When temporary venting of a container is necessary For the proper operation of equipment, or

7 o To prevent dangerous situations, such as build-up of extreme pressure. 5f. Other S.A.A. Considerations The containers must be marked with the words "hazardous waste" and other words that identify the contents of each container, such as "flammable", "acid", "alkaline", "cyanide", "reactive", "explosive", "halogenated solvent" or the chemical name. o o If marking of containers less than one gallon in size is infeasible, the locker, rack, or other device used to store the container may be marked with this information instead. EH&S asks that 100% of all constituents are identified for all S.A.A. wastes created. EH&S provides hazardous waste containers which meet the regulatory criteria, provide hazardous waste card stock tags which are peel and stick as well as stickers for smaller items. Due to the variety of chemical waste mixtures generated within UCONN Health laboratories, it is essential to the safety of EH&S staff to know what each waste container/mixtures contain. EH&S processes laboratory waste via bulking into larger containers or via lab-packing into drums with chemically compatible wastes. The containers must remain closed, except when adding or removing waste. o o o Hazardous wastes may not be moved from one satellite accumulation area to another. Wastes generated in satellite accumulation areas may only be taken to a fully-regulated storage area, as prescribed in 5b. of this section. S.A.A. collections are not allowed to be stored in chemical fume hoods. The fume hoods are for transferring the wastes only. Other safety based decision making should account for proper S.A.A. set-up and location and ensure that the chosen area is void of other hazards. (e.g.) of improper location for S.A.A. waste solvents would be near next to a non-rated refrigerator/other energized equipment or blocking laboratory emergency egress etc. EH&S provides at no cost to laboratories-the proper collection containers, secondary containment trays and labels. EH&S asks that all S.A.A. waste collection containers be maintained in the provided secondary containment trays. If there are chemically incompatible hazardous wastes, you must segregate these further via usage of a second containment tray and/or via physical separation. Proper use of secondary containment reduces the likelihood of problematic spills. The total amount of waste stored in container(s) within a satellite accumulation area may not exceed 55 gallons of non-acutely hazardous waste, or one quart/2.2 pounds/(1 kilogram) of acutely hazardous waste listed in 40 CFR (e). o o o Once these limits are exceeded, you must date the container(s) and contact EH&S via the waste request form found so to move to a fully-regulated container storage area within 72 hours and managed in compliance with all of the requirements for hazardous waste containers. Place waste pick-up request on form via OVPR EH&S Intranet at The inventory for chemical waste containers has an embedded hyperlink to once completed and is the preferred method of submission and tracking for regulatory auditing purposes. 5g. When Does a S.A.A. Container Meet Pre-Transport Requirements? If you are shipping the hazardous waste in the same container that it is initially accumulated in, you must also comply with the Pre- Transport Requirements. EH&S will determine if a laboratory will utilize a container which will meet the criteria for pre-transport labeling, based on frequency and volumes. Should the container be deemed subject to this standard, EH&S will ensure regulatory alignment through pre-labeled and UN/DOT rated containers for swap and drop service. 5h. How Must Containers Subject to the Pre-Transport Requirements Be Prepared for Shipment Off-Site? Hazardous waste container requirements include Pre-Transport provisions that reference certain U.S. Department of Transportation (DOT) Hazardous Materials regulations. These requirements include: Packaging - The hazardous waste must be packaged in containers that meet U.S. DOT requirements. Labeling - Each container must have the proper DOT label (e.g.) corrosive, flammable liquid, oxidizer, etc. Marking - Each container of 110 gallons or less must be marked with the following words;

8 HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal. If found, contact the nearest public safety authority or the Environmental Protection Agency. Generators name and address: [write in the business name and address] Manifest Document Number: [write in the manifest number] 5i. Other S.A.A. Supplies Provided by EH&S Hazardous Waste labels, tags or stickers-provided by EH&S upon request Non-Hazardous Waste labels, or stickers-provided by EH&S upon request S.A.A. sign-provided by EH&S upon request-(laminated & bright green) o o o Posted at or near the point of waste generation. posted at or near the S.A.A. under the control of the waste generator has the container management rules posted on the sign itself for easy reference The Waste Stream-Disposal Quick sheet, should be mounted near each S.A.A. sign. The sign is available on the EH&S OVPR link; Mixed Non-Halogenated Solvent collection container (if applicable) o o o o Pre-labeled and provided by EH&S upon request or through audit findings Typically <4 Liters & suitable for the collection of flammable liquids (e.g.) a solution of Acetone 25%, Toluene 25%, Ethanol 25%, Isopropanol 25% (e.g.) a solution of Ethanol 25%, in Phosphate Buffer 75% (e.g.) a solution of Xylene <10%, Isopropanol 15%, Coomassie blue 25% and 50% Water Other regulatory considerations besides CT-DEEP/EPA; OSHA for exposure criteria and flammable liquid transfer, NFPA-45 (Fire Marshall) regulations regarding maximum allowable limits of health or physical hazards per work area/fire zone and building level. Mixed Non-Halogenated and Halogenated Solvent collection container (if applicable) o Pre-labeled and provided by EH&S upon request or through audit findings o EH&S prefers segregating halogens and non-halogens where able and due to disposal cost considerations or more importantly-to substitute halogens with less toxic alternate from the experiment if able. o Typically <4 Liters & suitable for the collection of flammable/toxic liquids o (e.g.) a solution of Acetone 25%, Toluene 25%, Methylene Chloride 25%, Phosphate Buffer 25% o Other regulatory considerations besides CT-DEEP/EPA; OSHA for exposure criteria and flammable liquid transfer, NFPA-45 (Fire Marshall) regulations regarding maximum allowable limits of health or physical hazards per work area/fire zone and building level. (e.g.)-methylene Chloride as with many halogens are toxic and have further PPE and exposure requirements for safe handling within the laboratory. o A PPE determination is required to ensure that the appropriate selection is made EH&S offers the Workplace Hazard Assessment form to aid in this process. Mixed Environmentally Hazardous Liquid container-(non-rcra Waste, CT-Regulated Material) (if applicable) o Pre-labeled and provided by EH&S upon request or through audit findings o Typically <5 Gallons & suitable for the collection of NON-EPA regulated aqueous wastes o CT-DEEP regulates with state waste codes of CR02, CR03, CR04 (e.g.) aqueous solutions which are toxic or hazardous to health and or the environment (e.g.) non-hazardous sequencing solutions, histological solutions, or salts and buffers listed under OSHA s GHS as Hazardous, requiring an SDS. Collection must not contain RCRA metals, EPA Listed chemicals, and may not be characteristically hazardous via, Ignitability, Corrosivity, Reactivity and or Toxicity. Mixed Environmentally Hazardous Solids (NON-RCRA Waste, CT-Regulated Material) o Pre-labeled and provided by EH&S upon request or through audit findings o Typically <16 Gallons & suitable for the collection of NON-EPA regulated solid wastes o CT-DEEP regulates with state waste codes of CR05 (e.g.) solid chemicals and their contaminants which are toxic or hazardous to health and or the environment (e.g.) pads, plastics and lab debris contaminated with non-hazardous sequencing solutions, histological solutions, or salts and buffers listed under OSHA s GHS as Hazardous, requiring an SDS. Collection must not contain RCRA metals, EPA Listed chemicals, and may not be characteristically hazardous via, Ignitability, Corrosivity, Reactivity and or Toxicity.

9 No biohazardous material; may not have any bags or items with the Biohazard insignia within the waste, indicating a biohazardous material is present may not contain any infectious or potentially infectious substances Solids such as microscope slides with fixed tissue will be evaluated on a case by case basis due to frequency of generation, volume of discard and the chemicals used in process. 6. OTHER SAFETY CONSIDERATIONS 6a. Fume Hoods For transferring chemical waste into S.A.A. containers Fume hoods are not for; o general storage o storage of chemicals o S.A.A. waste storage o EH&S uses a Volumeter to document sash height flow rates and annually. o EH&S will place a certification sticker on the fume hood with a pass/fail certification. If the fume hood fails, the fume hood shall not be used until the flow rate is re-evaluated and meets minimum OSHA/ANSI and ASHRAE flow requirements. o EH&S will place a work order with Facilities Management-(EOC) to have the hood further inspected. o follow the Chemical Hygiene Plan (CHP) guidance for further detail or contact EH&S for Fume Hood Safety Guidance Document 6b. PPE Principal Investigators have the ultimate responsibility for ensuring the safety of their workers. An LSOP must be created, trained upon and adhered to. A PPE and Workplace Hazard Assessment must be performed, documented and findings should be incorporated into the laboratory s Protocol Standard laboratory PPE is for the wearer/user to don a lab coat, safety glasses, and nitrile gloves with minimum thickness of 4 mil for general laboratory/benchtop work. PPE is however; specific to the task and requires that you reference the SDS and follow the manufacturer s recommendations. For high non-laboratory scale volume or tasks which have greater inherent exposure potential, higher hazard chemicals that are either reactive or acutely hazardous, or for PHS s and select carcinogens, the appropriate level of protection must be applied. o (e.g.) Tyvek lab coats versus standard poly blend with goggles or face shields versus safety glasses, Viton, butyl, neoprene or silver shield gloves versus nitrile. Etc. 6c. Emergency Contact Information, Contingency Planning and Emergency Preparedness Emergency contact information-eh&s provides the Emergency Door Card, which is to be posted at every laboratory door. Emergency contact information shall be posted. Contingency Planning and Emergency Preparedness is captured during New Hire orientation and annual refresher trainings. o EPA requires that Large Quantity Generators LQG s perform annual hazardous waste management training, and there are many requirements within this training regimen to be met and to comply with this federal regulation, such as; o EPA requires that LQG s maintain documents for the job title for each position at the facility related to hazardous waste management, & the name of the employee filling each job. EPA requires a written job description for each position listed, a written description of the type and amount of both introductory and continuing training that will be given to each person filling a position listed under paragraph (a)(7)(iv)(a). EPA requires that records that document training or job experience, required under paragraph (a)(7)(i), (ii) and (iii) has been given to and completed by facility personnel. The Workplace Hazard Assessment (WHA) form is located on the OVPR EH&S Intranet site at 7. DEFINITIONS AND ACRONYMS AND REFERENCES RCSA-Regulations of CT. State Agencies o (RCSA) 22a-449 (c)-102(a)(1) Satellite Accumulation Area (S.A.A.)-the Generator s temporary storage area for process waste generated, prior to collection and disposal through the MAA and then onto final destination.

10 Main Accumulation Area (M.A.A.)-fully regulated hazardous waste storage facility where received S.A.A. waste may store for < 90 days based on the accumulation start dates/receive dates. Environmental Protection Agency- EPA 40 CFR-EPA Code of Federal Regulations o 40 CFR. Part 262 Standards Applicable to Generators of Hazardous Waste EPA s definition of Empty; o (EPA-40 CFR 261.7) all wastes have been removed that can be removed using the practices commonly employed to remove materials from that type of container, e.g., pouring, pumping, and aspirating, and (ii) no more than 2.5 centimeters (one inch) of residue remain on the bottom of the container or inner liner, or (iii) No more than 3 percent by weight of the total capacity of the container remains in the container or inner liner if the container is less than or equal to 119 gallons in size. At or near the point of generation-means that you may not generate a waste in one area and store it in a different area. (aka-the Frisbee rule or threshold rule) Must be the Generator s control-means that the person generating the waste must store it in their controlled SAA. 55 gallons per process-means that no SAA may accumulate more than 55gallons per process/processed waste. Triple rinse-a best management practice for re-use containers in SAA management/collection, by which the first 2 rinses are collected as a waste and the third goes down the drain with copious amounts of water. Caution: (Not suitable for all chemical hazardous wastes) HWCP-Hazardous Waste Contingency Plans UW- Universal Waste DOT/UN- Department of Transportation, United Nations 49 CFR-Department of Transportation Code for Hazardous Materials & Waste Shipments o 49 CFR Subchapter C- HAZMAT Regulations Part Ansel Endicott-Permeation and Degradation Chart for Chemicals 9 th Edition OSHA-Occupational Safety & Health Administration 29 CFR-OSHA Code of Federal Regulations 29 CFR Occupational exposure to Hazardous Chemicals in Laboratories Standard, aka The Laboratory Standard o The Chemical Hygiene Plan aka CHP, is defined in the to specify the mandatory framework requirements necessary to protect laboratory workers from harm due to hazardous chemicals. NFPA-45 National Fire Protection Association, Laboratory Standard Prudent Practices in the Laboratory EH&S-Environmental Health and Safety 8. SAFETY KEY POINTS Employees must have documented training on chemical hazardous waste management and be refreshed on an annual basis. (EH&S will provide initial trainings but then subsequent trainings shall be delivered through SABA) The employee must demonstrate comprehension of the training and this SOP. Generators are responsible for informing EH&S Safety Specialist when new chemicals/raw products will impact the waste collection, prior to creating the waste. Generators are responsible for accurately characterizing their waste streams; which is especially important in collection of mixtures. Generators must appropriately label all waste containers; with the appropriate wording (e.g.) Hazardous 100% or Hazardous 25%, Phosphate Buffer 50%, Acetone 25%. All waste solutions must be written out in English and in full. No unlabeled containers are allowed; this is a violation of RCRA, and creates unknown hazardous waste, which is extremely expensive to characterize and hazardous to handle. SAA s must be maintained in a safe manner, and under the control of the waste s Generator. SAA waste must remain closed unless actively transferring the waste. SAA spills and or residues must be cleaned immediately, collected as hazardous waste in an appropriate container, with the wording hazardous waste and the name of the co-mingled chemicals, and be compatible with the container itself. All constituents must be provided, and chemical formulas are not allowed. PPE must be stocked and readily available.

11 The correct PPE must be selected based on the SDS recommendation. (NOTE: Nitrile gloves are not suitable for all chemicals, and specifically not rated for most chlorinated solvents) Employee Generators should know where the closest safety shower and eyewash is located, as well as fire extinguisher. Generators must have a basic understanding of the chemical properties for the materials that they are working with, which also includes wastes. 9. PROCEDURES Clinical based research & development creates/generates a waste either through the process or purchase or both. Raw materials & or chemicals are used in a process or established in a protocol/procedure; and thusly are known ingredients, with SDS s already reviewed prior to use. Deviation of the raw ingredients must be identified/characterized in how this will impact the collection/generation of waste. Generators are responsible for characterizing their waste streams, and for keeping accurate records of them. It is recommended by EH&S, that protocols and procedures identify and have a description as to the waste products, and collection. Small vials or tubes with compatible/homogenous hazard class wastes may be poured and co-mingled into a larger SAA container & then properly labeled as Hazardous Waste, or properly labeled as Hazardous Waste & placed as is into a secondary container, provided the small tubes/vials will not leak. The container chosen to store Hazardous Waste must be compatible, not leak and stay closed unless actively transferring the waste. All Hazardous wastes & or chemicals that are hazardous but not wastes, must be transferred in your chemical fume hood. Once the first drop of Hazardous Waste is collected, you must label the container with the wording Hazardous Waste, write the name of the chemical constituents in full and in English, and the range in ppm, mg, ml or by % totaling 100% of the volume. Ensure that there are no leaks, spills and evidence of spills. Ensure there are no chemical hazardous residues on the exterior of the container/s. Ensure that the container/s are properly closed, and return from fume hood to you SAA storage containment trays/bins. When the container is full, submit a Chemical Waste Pick-up request via RCRA EMPTY VERSUS DOT EMPTY EPA Definition of Empty; According to 40 CFR 261.7, the EPA allows a container that once held a non-acute/non P-Listed hazardous waste to be considered empty and not subject to hazardous waste regulation when all waste that can be removed has been removed using common practices such as pouring, pumping, and aspirating. The regulations also specify that: No more than 1 inch of residue can remain on the bottom of the container or the inner liner No more than 3 percent (by weight) of the container s total capacity (less than or equal to 119 gallons) can remain in the container; or no more than 0.3 percent (by weight) of the container s total capacity (greater than 119 gallons) can remain in the container A container that held a compressed gas hazardous waste is considered empty when the pressure in the container approaches atmospheric. For containers that held acute hazardous waste, one of the following conditions must be met for it to be considered empty: o o o The container or the inner liner has been triple rinsed using a solvent capable of removing the material The container or inner liner has been cleaned by another method documented in scientific literature or by tests conducted by the generator to achieve equivalent removal The inner liner has been removed For the purposes of hazardous materials transportation, the DOT has a more stringent definition. A container that once held a hazardous material is considered empty when it has been sufficiently cleaned of residue and purged of vapor. According to 49 CFR 171.8, the DOT includes hazardous wastes in the definition of a hazardous material. Consequently, containers that contain less than 1 inch of residue may be considered empty under RCRA but remain regulated by DOT during transportation. DOT Definition of Empty; is more complicated than EPA s definition and applies through the following exemption with conditions met;

12 49 CFR (b)-A close reading of 49 CFR (b) reveals that your empty packaging shipment bulk and non-bulk is not subject to any requirement of the HMR if you are able to meet all 4 of the following provisions, as applicable: First, any hazard communication method that identifies the empty packaging as containing a hazardous material (i.e. marking, labels, placards, etc.) are removed, obliterated, or securely covered in transportation. Second, the empty packaging is either unused, sufficiently cleaned of residue and purged of vapors to remove any potential hazard, or is refilled with a non-hazardous material such that any residue now won t pose a threat. Third, if the empty packaging contains only the residue of an ORM-D Consumer Commodity, a Division 2.2 non-flammable gas described in 49 CFR (b)(2)(iv)(B), or the residue does not meet the definition of a hazardous substance, a hazardous waste, or a marine pollutant. An example of where this last provision might apply is if a shipment is regulated as a hazardous material solely due to it being above the RQ in a single packaging and thus a hazardous substance. If the amount of material in an empty container is below the RQ, then the material is no longer a hazardous substance and no longer subject to the HMR ( ). 49 CFR (c), while not as extensive in the exclusions from the HMR as is paragraph (b), also does not contain as many hoops to jump through. It is most likely the applicable regulation if you ship empty non-bulk packaging s to a drum re-conditioner or back to the material supplier. There are three provisions or which you must be aware. First, it must be a non-bulk packaging as defined at 49 CFR which is a HazMat packaging that is: 119 gallon capacity for a liquid. 119 gallon and 882 pound capacity for a solid. 1,000 gallon water capacity for a gas Second, the residue in the empty packaging may only be a hazardous material covered by Table 2 of 49 CFR and is not a Poison Inhalation Hazard. If the two above provisions are met for your shipment, then it is not subject to the placarding requirements of 49 CFR 172, Subpart F You must also ensure compliance with the US EPA regulations for emptying the container (US EPA refers to it as a container, not a packaging) in order to ensure the residue is no longer a hazardous waste. The applicable US EPA regulations can be found at 40 CFR If you generate any hazardous waste, you may be subject to the training requirements of 40 CFR for any employees who handle hazardous waste or sign a hazardous waste manifest. 11. TABLE OF HAZARDOUS WASTE GENERATOR CATEGORIES Once you have collected all the information required in steps 1 through 3 above, use the table below to figure out your generator category. Each generator category is displayed as a single line in this table. Your generator category is the lowest line on the table for which you meet either of the thresholds in columns two or three of the table. Waste Generator Category Table of Hazardous Waste Generator Categories Amount of Waste Generated Per Calendar Month Amount of Waste Stored On-Site At Any One Time CESQG Conditionally Exempt Small Quantity Generator No More than 100 kilograms* And No More than 1 kilogram* of Acute Hazardous Waste AND No More than 1000 kilograms* And No More than 1 kilogram* of Acute Hazardous Waste SQG Small Quantity Generator Between kilograms* And No More than 1 kilogram* of Acute Hazardous Waste AND No More than 1000 kilograms* And No More than 1 kilogram* of Acute Hazardous Waste LQG Large Quantity Generator 1000 kilograms* or More Or Greater than 1 kilogram* of Acute Hazardous Waste OR More than 1000 kilograms* Or Greater than 1 kilogram* of Acute Hazardous Waste

13 7.3 LQG-(Large Quantity Generator) What is an LQG? An LQG generates the most waste, and is the most highly-regulated type of hazardous waste generator. A generator is an LQG if it meets any of the following conditions: generates 1000 kilograms (2200 pounds) or more of hazardous waste per calendar month; or, accumulates more than 1000 kilograms (2200 pounds) of hazardous waste at any one time; or, generates more than one kilogram (2.2 pounds) of acute hazardous waste per calendar month; or, Accumulates more than one kilogram (2.2 pounds) of acute hazardous waste at any one time. For a typical liquid waste, 1000 kilograms (2200 pounds) equals about five 55-gallon drums. For more dense wastes such as solids and sludges, 1000 kilograms can be much less than five 55-gallon drums.

14 APPENDIX A-LISTED HAZARDOUS WASTE CATAGORIES PER EPA Title 40 - Protection of Environment Volume: 26Date: Original Date: Title: Section Discarded commercial chemical products, off-specification species, container residues, and spill residues thereof. Context: Title 40 - Protection of Environment. CHAPTER I - ENVIRONMENTAL PROTECTION AGENCY (CONTINUED). SUBCHAPTER I - SOLID WASTES (CONTINUED). PART IDENTIFICATION AND LISTING OF HAZARDOUS WASTE. Subpart D - Lists of Hazardous Wastes Discarded commercial chemical products, off-specification species, container residues, and spill residues thereof. The following materials or items are hazardous wastes if and when they are discarded or intended to be discarded as described in 261.2(a)(2)(i), when they are mixed with waste oil or used oil or other material and applied to the land for dust suppression or road treatment, when they are otherwise applied to the land in lieu of their original intended use or when they are contained in products that are applied to the land in lieu of their original intended use, or when, in lieu of their original intended use, they are produced for use as (or as a component of) a fuel, distributed for use as a fuel, or burned as a fuel.(a) Any commercial chemical product, or manufacturing chemical intermediate having the generic name listed in paragraph (e) or (f) of this section.(b) Any off-specification commercial chemical product or manufacturing chemical intermediate which, if it met specifications, would have the generic name listed in paragraph (e) or (f) of this section.(c) Any residue remaining in a container or in an inner liner removed from a container that has held any commercial chemical product or manufacturing chemical intermediate having the generic name listed in paragraphs (e) or (f) of this section, unless the container is empty as defined in 261.7(b) of this chapter. [Comment: Unless the residue is being beneficially used or reused, or legitimately recycled or reclaimed; or being accumulated, stored, transported or treated prior to such use, re-use, recycling or reclamation, EPA considers the residue to be intended for discard, and thus, a hazardous waste. An example of a legitimate re-use of the residue would be where the residue remains in the container and the container is used to hold the same commercial chemical product or manufacturing chemical intermediate it previously held. An example of the discard of the residue would be where the drum is sent to a drum reconditioner who reconditions the drum but discards the residue.](d) Any residue or contaminated soil, water or other debris resulting from the cleanup of a spill into or on any land or water of any commercial chemical product or manufacturing chemical intermediate having the generic name listed in paragraph (e) or (f) of this section, or any residue or contaminated soil, water or other debris resulting from the cleanup of a spill, into or on any land or water, of any offspecification chemical product and manufacturing chemical intermediate which, if it met specifications, would have the generic name listed in paragraph (e) or (f) of this section. [Comment: The phrase commercial chemical product or manufacturing chemical intermediate having the generic name listed in... refers to a chemical substance which is manufactured or formulated for commercial or manufacturing use which consists of the commercially pure grade of the chemical, any technical grades of the chemical that are produced or marketed, and all formulations in which the chemical is the sole active ingredient. It does not refer to a material, such as a manufacturing process waste, that contains any of the substances listed in paragraph (e) or (f). Where a manufacturing process waste is deemed to be a hazardous waste because it contains a substance listed in paragraph (e) or (f), such waste will be listed in either or or will be identified as a hazardous waste by the characteristics set forth in subpart C of this part.](e) The commercial chemical products, manufacturing chemical intermediates or off-specification commercial chemical products or manufacturing chemical intermediates referred to in paragraphs (a) through (d) of this section, are identified as acute hazardous wastes (H) and are subject to the small quantity exclusion defined in 261.5(e). [Comment: For the convenience of the regulated community the primary hazardous properties of these materials have been indicated by the letters T (Toxicity), and R (Reactivity). Absence of a letter indicates that the compound only is listed for acute toxicity. Wastes are first listed in alphabetical order by substance and then listed again in numerical order by Hazardous Waste Number.]These wastes and their corresponding EPA Hazardous Waste Numbers are: Hazardous waste No. Chemical abstracts No. Substance P Acetaldehyde, chloro- P Acetamide, N-(aminothioxomethyl)- P Acetamide, 2-fluoro- P Acetic acid, fluoro-, sodium salt P Acetyl-2-thiourea P Acrolein P Aldicarb P Aldicarb sulfone. P Aldrin P Allyl alcohol P Aluminum phosphide (R,T)

15 P (Aminomethyl)-3-isoxazolol P Aminopyridine P Ammonium picrate (R) P Ammonium vanadate P Argentate(1-), bis(cyano-c)-, potassium P Arsenic acid H 3 AsO 4 P Arsenic oxide As 2 O 3 P Arsenic oxide As 2 O 5 P Arsenic pentoxide P Arsenic trioxide P Arsine, diethyl- P Arsonous dichloride, phenyl- P Aziridine P Aziridine, 2-methyl- P Barium cyanide P Benzenamine, 4-chloro- P Benzenamine, 4-nitro- P Benzene, (chloromethyl)- P ,2-Benzenediol, 4-[1-hydroxy-2-(methylamino)ethyl]-, (R)- P Benzeneethanamine, alpha,alpha-dimethyl- P Benzenethiol P Benzofuranol, 2,3-dihydro-2,2-dimethyl-, methylcarbamate. P P Benzoic acid, 2-hydroxy-, compd. with (3aS-cis)-1,2,3,3a,8,8a-hexahydro-1,3a,8-trimethylpyrrolo[2,3-b]indol-5- yl methylcarbamate ester (1:1). 2H-1-Benzopyran-2-one, 4-hydroxy-3-(3-oxo-1-phenylbutyl)-, & salts, when present at concentrations greater than 0.3% P Benzyl chloride P Beryllium powder P Bromoacetone P Brucine P Butanone, 3,3-dimethyl-1-(methylthio)-, O-[(methylamino)carbonyl] oxime P Calcium cyanide P Calcium cyanide Ca(CN) 2 P Carbamic acid, [(dibutylamino)- thio]methyl-, 2,3-dihydro-2,2-dimethyl- 7-benzofuranyl ester. P Carbamic acid, dimethyl-, 1-[(dimethyl-amino)carbonyl]- 5-methyl-1H- pyrazol-3-yl ester. P Carbamic acid, dimethyl-, 3-methyl-1- (1-methylethyl)-1H- pyrazol-5-yl ester. P Carbamic acid, methyl-, 3-methylphenyl ester. P Carbofuran.