MSOE LMP Training 2011-2013

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This is the Lab Management Plan training presentation prepared for MSOE faculty and staff for 2011-2013

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  • My name is Julie LaRose and I am the Environmental Health and Safety Director for the Milwaukee School of Engineering. I appreciate your participation in MSOE’s Lab Management Plan training.
  • One of my primary goals is to ensure that MSOE sets…With many of the safety and health programs we have implemented in the past year, MSOE has become an institution that others want to emulate.Institutions like Marquette, Medical College, UWM and Madison are watching programs unfold at MSOE and are pursuing a similar path.This is consistent with our mission to be at the forefront of professional educators who recognize….
  • Discuss how MSOE is different than industry
  • Our training outline is ambitious. I would like to review the following:There will be opportunities in the upcoming year for faculty and staff to enroll in additional training which will elaborate on the topics presented here.
  • Acute Waste>2.2 lbs/month generation or > 2.2 lbs accumulation at any time makes you a LQG2200 lbs. (1000 kg) is about five 55-gallon drums
  • Location of CAAsRCRA training is required every year and it is very detailed training.MSOE was at the forefront of environmental health when the university voluntarily opted in to the EPAs New Hazardous Waste Regulation. Some universities are still trying to manage their waste using standards that were designed for industry.
  • For years, the EPA has recognized that universities do not generate hazardous waste in the same manner as industry. Hazardous waste generation in industry is much more predictable, less variable and more easily controlled. The EPA estimates that laboratories will typically account for approximately 75% of the waste generated by a university. Previously, the EPA operated under the assumption that PhDs in the lab were making hazardous waste determinations and waste was being handled in compliance with EPA’s hazardous waste standards. Upon further investigation, it was discovered that students and untrained lab personnel were making these determinations and many of these individuals had no knowledge of hazardous waste standards.The LMP should not only address the handling of unwanted materials, it must also address the safe handling and storage of all chemicals in the labs.
  • Initially, there was confusion about what constituted a lab, MSOE has defined its laboratories – set up its central accumulation areasLaboratory – an area where relatively small quantities of chemicals and other substances are used on a non-production basis for teaching or research and are stored and used in containers that are easily manipulated by one personA primary distinction here at MSOE is the difference between hard and soft labs.A soft lab may meet one of the criteria above, but the lab does not contain chemicals of any kind. As a result, these labs do not need to generate chemical handling or disposal procedures.
  • In some labs, every material is wanted regardless of its age or whether it has long past its shelf life.Labs that stockpile chemicals introduce a variety of issues.These labs do not systematically eliminate unwanted materials. Generally, chemical storage is disorganized, incompatible chemicals are stored next to each other, expired chemicals are maintained for years and an accurate chemical inventory does not exist. The manufacturers of extremely old chemicals may no longer exists so a material safety data sheet may not exist. Often, lab personnel will continually reorder chemicals in stock simply because they can’t find the chemical in storage.Labs that stockpile unwanted materials put the university at risk of becoming a large quantity generator to accommodate the clean out of stockpiles. This forces the university to comply with numerous additional regulatory requirements.We are promoting regular reviews of chemical stocks and the elimination of unwanted materials. We recently requested and were granted small quantity generator status and we want to maintain this status.There are certain chemicals that we attempt to recycle.We try to recycle petroleum-based oils used for lubrication of engines and machinery. This includes centrifuges, diffusion pumps and vacuum pumps used in laborato­ries. Try not toallow cleaning solvents or other materials to be combined with used oils. Uncontaminated instrument and machine oils such as centrifuge, diffusion pump and vacuum pump oils can be recycled.
  • How do we systematically identify unwanted materials on campus?We label the container with a Neon Green Unwanted Material sticker.This sticker must include specific information.
  • We have encountered situations where containers or other wastes are left outside the CAA in the Science Building. This is a bad idea for several reasons. First, storing waste in a means of egress is a bad idea. Second, this hallway is prone to flooding and items left on the ground could become a hazardous waste clean up.
  • Containers that are not labeled appropriately will not be removed from the SAA.We cannot afford mystery containers in the CAA and retroactively figuring out where a container came from is time consuming.
  • Not only of hazardous waste containers, but chemical containers themselvesHazardous waste containers must be compatible with the waste stored –this is particularly true of corrosives.UW-Madison exampleA graduate student sitting as a lab computer was surprised by chemical waste bottle which burst and sprayed nitric acid and glass shards. About 2L of nitric acid waste had been accumulated in a chemical waste bottle which originally held methanol. Over a 12-16 h period, some residual methanol reacted with the nitric acid and created enough CO2 to overpressurize the container.
  • These are some of the issues that will be evaluated during MSOE’s mandatory EPA audit. This audit will be conducted in Spring of 2012.
  • Remove funnel and close container when not adding waste
  • There are specific labeling requirements for working containers.Information from CAMEO chemicalsFlammability is variable – Reactivity is variable Examples vinyl chloride, trichlorobenzene, PCBs, Methylene chloride, chloroform
  • The signage can be acquired by contacting the EHS Department.
  • Media, CDs, Floppy Discs, Hard Drives – all go to Sandy Haro in the Treasurer’s Office (has a contract with Piranha)
  • As you can see, we have great response to our calls to clean out and our clean outs thus far have been very successful.
  • The new standard requires a higher level of training from the hazardous waste handlers down to students.
  • Provides flexibility because there is a recognition that this determination can become complicated and requires extensive knowledge of EPA standards, local WI DNR standards and Milwaukee Metropolitan Sewerage District requirements.For this reason, MSOE has elected to use the hazardous waste chemists of our hazardous waste vendor to make these determinations.
  • EPA hazardous wastes consist of chemical wastes that exhibit the characteristic of corrosivity, ignitability or reactivity or fail the toxicity characteristic leaching procedure (simulates the ability of a compound to leach out of a landfill and enter groundwater.EPA hazardous waste must not be disposed of by certain polluting methods. EPA hazardous wastes must not be disposed: in the normal trash, in the garbage or refuse not in recycling bins, glass receptacles, sharps containers or red bags; by evaporation; by dilution (If EPA hazardous wastes are diluted or combined with a nonhazardous material, the resultant material is still regulated as an EPA hazardous waste. Toxic and ignitiable solvents must NEVER be intentionally evaporated to dispose of themListed Wastes Mismanaged waste streams from certain industrial processes can have a negative impact on human and environmental health, even at low concentrations. So-called "listed wastes" are specific industrial waste streams that appear on one of four lists ("F," "K," "P" or "U") as defined in the Code of Federal Regulations Title 40, Part 261, Subpart "D." "F" List Wastes Wastes on the "F" list are produced during common industrial or manufacturing processes such as degreasing. Because "F" list wastes are not specific to any particular sector of industry, they are also called "non-specific source wastes." Examples from this extensive list include wastewater treatment sludge from certain electroplating operations and spent degreasing solvents such as tetrachloroethylene, trichloroethylene, 1,1,1-trichloroethane and carbon tetrachloride. "K List Wastes "K" list, or source-specific, wastes are waste streams generated by specific industrial sectors, such as ink formulators, petroleum refineries and producers of veterinary pharmaceuticals, explosives, pesticides and inorganic pigments. The Code of Federal Regulations Title 40, Part 261.32 provides a full listing of these wastes. "P" and "U" List Wastes Both "P" and "U" lists involve discarded commercial chemical products, or unused pure or commercial-grade chemical products. Chemicals on the "P" list are fatal or irreversibly damaging to humans and animals at low doses. Those on the "U" list pose a hazard to human or environment health when improperly managed. Compounds appearing on these lists include pesticides and pharmaceuticals. The Code of Federal Regulations Title 40, Part 261.33 defines "P" and "U" list wastes in full. 
  • Ignitable compressed gas DOT list 49 CFR 173.300Oxidizer defined by DOT 49 CFR 173.151
  • PenaltiesIndividuals who improperly ship hazardous materials may be subject to criminal and civil penalties. Fines to the University can range from $250 to $500,000 per violation.Classes of Hazardous MaterialsThe following classes of shipping hazards are defined and regulated.Class 1: Explosives1.1 Explosives with a mass explosion hazard (nitroglycerin/dynamite)1.2 Explosives with a blast/projection hazard1.3 Explosives with a minor blast hazard (rocket propellant, display fireworks)1.4 Explosives with a major fire hazard (consumer fireworks, ammunition)1.5 Blasting agents1.6 Extremely insensitive explosivesClass 2: Compressed Gases2.1 Flammable gases (propane, hydrogen)2.2 Non-flammable gases (helium, nitrogen)2.3 Poison gases (chlorine, phosgene)2Class 3: Flammable Liquids (gasoline, some alcoholic beverages)Class 4: Flammable Solids4.1 Flammable solids (magnesium powder, red phosphorus)4.2 Spontaneously combustible materials (white phosphorus)4.3 Water reactive materials (sodium, potassium)Class 5: Oxidizing Materials5.1 Oxidizers (ammonium nitrate, hydrogen peroxide)5.2 Organic peroxides (benzoyl peroxide)Class 6: Toxic and Infectious Materials6.1 Poisonous liquids or solids (potassium cyanide, mercuric chloride)6.2 Infectious/biohazardous substances (anthrax, HIV)6.3 Liquids and solids with a lower toxicity than those in group 6.1.Class 7: Radioactive Materials7.1-7.3 Radioactive I, II, III (uranium, plutonium, radioactive waste)Class 8: Corrosive Materials (sodium hydroxide, sulfuric acid)Class 9: Miscellaneous Dangerous GoodsMaterials that are hazardous during transportation but do not meet the definition of any of theother hazard classes (dry ice in an airplane).ExceptionsSmall quantity exceptions (49 CFR 173.4 and IATA 2.7) may exist for authorized materials:- 30 mL limit for liquids- 30 g limit for solids
  • Only one LMP is required for the entire campus
  • Sulfuric AcidSodium HydroxideChloroformHydraulic Oil
  • Our training outline is ambitious. I would like to review the following:There will be opportunities in the upcoming year for faculty and staff to enroll in additional training which will elaborate on the topics presented here.
  • MSOE LMP Training 2011-2013

    1. 1. For MSOE Faculty/Staff August 2011
    2. 2. Introduction MSOE strives to set an exemplary standard for occupational safety and environmental health in its laboratories. This commitment places MSOE at the forefront of professional educators who recognize that safety and health must be integrated into all aspects of university operations and curriculum.
    3. 3. Purpose MSOE’s waste streams are:  Highly variable  Generated at multiple points  Numerous  Generated in small volumes – short time frames Hazardous waste management in university settings is challenging for these reasons. To overcome these challenges, MSOE has developed a Lab Management Program (LMP) to govern the handling of unwanted materials (waste) in our facilities. This training program provides a review of regulatory requirements and MSOE’s LMP.
    4. 4. Training Outline Hazardous Waste on Campus – Basic Facts EPA Regulatory Requirements (Subpart K) MSOE’s Lab Management Plan Requirements Hazard Communication Program Emergency Response Program
    5. 5. Basic Facts MSOE: 3 EPA Site IDs  Science/Engineering 429 East State Street (Small Quantity Generator <2200 lbs haz waste/month)  Krueger Hall 820 N Milwaukee Street (Conditionally Exempt Small Quantity Generator <220 lbs. haz waste/month)  Kern Center & Residence Hall Complex 1245 N Broadway (Conditionally Exempt Small Quantity Generator < 220 lbs. haz waste/month) MSOE’s Hazardous Waste Management Firm: Veolia 2010: MSOE shipped 838 lbs. of hazardous waste to certified treatment facilities (flammables, oxidizers, mercury salts and solutions, acids, bases, elemental mercury, aerosols)
    6. 6. Basic Facts MSOE has 3 Central Accumulation Areas for the storage of hazardous waste  Science/Engineering Building  Margaret Loock Residence Hall  Krueger Hall MSOE has 4 individuals trained in EPA’s Resource Conservation and Recovery Act (RCRA) – these are the only individuals who can transport unwanted materials to MSOE’s Central Accumulation Areas Julie LaRose Pete Hanson Eric Homann Tom Barsokine MSOE was one of the first universities in the country to opt into the EPA’s New Hazardous Waste Regulation for Academic Laboratories Rule (Subpart K)
    7. 7. Subpart K: Hazardous Waste Standard for Academic Labs Subpart K establishes criteria for trained professionals to perform hazardous waste determinations of unwanted materials generated by laboratories. Subpart K details container labeling and container management requirements for unwanted materials. Subpart K requires laboratories to develop a Lab Management Plan (LMP) to govern the safe handling, storage and removal of unwanted materials from laboratories. MSOE has elected to require labs to incorporate their chemical hygiene procedures into their LMPs. Subpart K includes incentives for labs to conduct “laboratory clean- outs”
    8. 8. MSOE Definitions Laboratory – an area:  that conducts tests, experiments, or investigations through research or teaching  where nursing practices, artistic endeavors or architectural engineering projects take shape  where chemicals or radioactive materials are used  Any academic or research area where engineering principles are discovered or pursued “Hard” Lab – a lab in which chemicals are allowed “Soft” Lab – a lab in which chemicals are prohibited To maximize faculty, staff, and student awareness of and protection from various safety issues beyond the requirements of Subpart K, MSOE’s LMP is designed to cover as many academic and engineering areas as possible. A “soft” lab prohibits the use of chemicals and therefore need not address Subpart K requirements, but the lab may be required to meet OSHA regulations and/or standards or other “best practice” safety elements. There are some labs that may only need to address the following minimum for training purposes:  Laboratory hours  Statement that chemicals are prohibited  MSOEs emergency planning and evacuation routes for that room
    9. 9. MSOE Lab Management Program KeyRequirements Unwanted Material Labeling Standards Container Standards Training Requirements Removal Frequency of Unwanted Materials Making the Hazardous Waste Determination Laboratory Clean-outs Laboratory Management Plan
    10. 10. Unwanted Material Any chemical, mixture of chemicals, products of experiments or other material from a lab that is no longer needed, wanted or usable in the lab. Issues with stockpiling
    11. 11. Labeling StandardsInformation that must be affixed or attached to the container:  The words “Unwanted Material” or another equally effective term  Sufficient information to alert emergency responders to the contents of the container (e.g. name of the chemical(s) in the container or a descriptive phrase such as “inorganic solvents”)  Sufficient information so “trained professionals” can make a hazardous waste determination  Date unwanted material first started accumulating in the container  Date unwanted container placed in SAA
    12. 12. Satellite Accumulation Areas Satellite Accumulation Area: located in or near each lab where unwanted materials are generated. May be located in a chemical cabinet, under a bench or in a designated, controlled space in the lab. MSOE has designated 19 SAAs. SAAs must be identified in the LMP.
    13. 13. Unwanted Material Label The words Unwanted Materials or equally effective term usedconsistently and written UNWANTED MATERIAL Information toin Part I of the LMP (e.g. alert Emergency Spent Acetone Lab Waste) Responders to the contents of Contents: the container (Flammable) And Information to make a HW S252 Determination SAA Location: 8/1/2010 Indicate SAA Location (in the event there are Date Place in SAA: questions about the material)
    14. 14. Container Standards Performance-based container management standards in order to prevent leaks, spills, emissions to the air, adverse chemical reactions, and to avoid dangerous situations  Containers must be kept in good condition  Containers must be compatible with their contents  Containers must be kept closed  Containers must only contain compatible wastes
    15. 15. Improperly Stored Unwanted Material No MSOE labels No secondary containment No segregation Containers covered with residue
    16. 16. Improperly Stored Unwanted Materials No MSOE labels No secondary containment from hood drain No segregation Container not sealed properly (open funnel)
    17. 17. Working Containers May be open until the end of the procedure or work shift, or until it is full, whichever comes first At end of procedure or work shift, or when it’s full, it must be closed or emptied into a container which is then closed Includes provision for other situations where container cannot be kept closed (e.g when it must be vented to avoid dangerous pressure build-up) – provisions to contain Can be no larger than 2 gallons in size
    18. 18. Unwanted Material Label Working Container The words Unwanted Materials or equally effective term used UNWANTED MATERIALconsistently and written Information toin Part I of the LMP (e.g. Lab Waste) WORKING CONTAINER alert Emergency Responders to Contents: Halogenated Organics the contents of the container (Toxics) And Course: CH222 Lab Tech Information to make a HW II Determination Start Accumulation Date: 8/1/2010 SAA Location: S252
    19. 19. Satellite Accumulation Area Signage
    20. 20. Removal Frequency of Unwanted Materials Unwanted materials must be removed from labs at regularly scheduled intervals (not to exceed 6 months). MSOE has elected to schedule quarterly hazardous waste removals with Veolia. These removals are scheduled for the first week of January, the first week of April, the first week of July and the first week of October. Unwanted materials must be removed from the laboratory within 10 days of exceeding the maximum allowable quantity (55 gallons of waste or 1 quart of acutely hazardous waste) Must date all containers with the date the 55 gallons is exceeded Must date all acutely hazardous waste containers with the date the 1 quart is exceeded MSOE removes “unwanted materials” from each lab as requested by the lab. To request removal, lab personnel file an on-line pick-up request.
    21. 21. Unwanted MaterialRemovalTo Request a Pick-Up,(1) Go to the MSOE intranet site(http://inside.msoe.edu)(2) Look under the Environmental Healthand Safety Department(3) Refer to the Environmental ProtectionSection
    22. 22. Additional Waste Item Pick-Up Requests Universal Wastes  Electronic Waste  Batteries Media, CDs, Floppy Discs  Ni-Cd, metal Hard drives hydride, lithium, alkaline or small sealed lead-acid Laptops, Monitors, Keyboard,  Mercury-containing Mouse equipment (MCE) AV Equipment  Thermostats, barometers, thermometers, press ure relief gauges, temperature gauges, mercury switches (light switches in vehicles)  Pesticides  Aerosol Paint Spray Cans  FIFRA  Unused household  Anti-Freeze  Lamps—lighting devices with a hazardous component  Fluorescent tubes and bulbs, high- intensity discharge  Neon, mercury vapor  High-pressure sodium, metal halide
    23. 23. Central Accumulation Areas MSOE has three EPA Hazardous Waste generator id numbers and has established a Central Accumulation Area (CAA) for each EPA ID number. The CAAs are located:  Room on the ground floor of the Science & Engineering building  Basement of MLH  RPC in Krueger Hall
    24. 24. Training Requirements Training for “trained professionals”  Must be in accordance with the applicable RCRA (hazardous waste) training requirements Training for “laboratory workers” and students:  Must be sufficient for them to understand and implement the requirements of Subpart K, commensurate with their duties  Can be accomplished in a variety of ways (e.g. instruction, electronic/written, on- the-job, etc.) Training must be documented MSOE provides training to faculty via this presentation. Faculty are responsible for providing awareness training to students using the Lab Management Plan Training protocols/documents prepared for each individual lab.
    25. 25. Making the Hazardous Waste Determination  Determining whether an unwanted material is a hazardous waste can become complicated  EPA Standards  WI Department of Natural Resources (DNR) Standards  Milwaukee Metropolitan Sewerage District (MMSD) Discharge Limitations  Subpart K provides some flexibility in where and when the hazardous waste determination is made.  MSOE’s Hazardous Waste Vendor or the MSOE RCRA trained professional will determine whether the unwanted material is a hazardous waste  Before the container is removed from the SAA; or  Within 4 days of the container’s arrival in the CAA.
    26. 26. Hazardous Waste Determination EPA Listed Wastes  Characteristic Wastes  P Listed: Unused Acutely  Ignitability Hazardous Waste  Corrosivity  U Listed: Unused Non-Acutely  Toxicity Hazardous Waste  Reactivity  K Listed: Waste from Specific Sources  F Listed: Waste from Non- Specific SourcesExamples of EPA U Listed Waste on Campus: Acetone, Acetonitrile, Acrylamide, 1- Butanol, Dichloromethane, Ethidium Bromide, Ethyl acetate, Toluene, Xylene
    27. 27. Ignitable WastesA liquid that has a flash point of <140° FFlammable solids, such as road flares or carbon.An ignitable compressed gas (propane) or an oxidizer as defined by the Department of Transportation (DOT)Ignitable materials are represented by a D001 waste code.
    28. 28. Corrosive WastesHave a pH of 2 or less or 12.5 or more.A liquid that corrodes steel at a rate of 6.35 mm or more per year as determined by the National Association of Corrosion Engineers. Potassium Tert-butoxide, a flammable solidExamples: nitric acid, aqueous sodium hydroxide, hydrochloric acid.Corrosive materials are represented by a D002 waste code.
    29. 29. Reactive WastesMaterials that undergo violent change: - react violently with water or air - capable of detonation - create toxic gases when exposed to pH extremesExamples: sodium metal, extremely dry picric acid, and organic peroxides. Reactive materials are represented by a D003 waste code.
    30. 30. Toxic Wastes- Materials that are poisonous, harmful and potentially deadly- Examples: lead acetate, mercuric chloride, benzene.The wastes are represented by codes from D004 – D043. These codes are specific to material types. For example: Mercury has a D009 code, Benzene has D018.
    31. 31. Examples of Toxic ContaminantsHeavy Metals: Organics, continued: arsenic, barium, cadmium, chrom cresol, 1,4-dichlorobenzene, 1,2- ium, copper, lead, mercury, moly dichloroethane, 1,1-dichloroethylene, 2,4- bdenum, nickel, selenium, silver, dinitrotoluene, hexachlorobenzene, hexac zinc hlorobutadiene, hexachloroethane, methy l ethyl ketone, nitrobenzene, pentachlorophenol,Pesticides: Chlordane, 2,4- pyridine, tetrachloroethylene, trichloroeth D, Endrin, Lindane, Heptachlor, Me ylene, 2,4,5-trichlrophenol, 2,4,6- thoxychlor, Silvex (2,4,5- trichlorophenol, vinyl chloride. TP), Toxaphene. • In bold, Milwaukee MetropolitanOrganics: Sewerage District (MMSD) strict benzene, carbon discharge limits. tetrachloride, chlorobenzene, chloro • MMSD also strictly governs the form, discharge of ammonia, cyanide and hexane.
    32. 32. Shipping Hazardous Materials The shipment of hazardous materials and/or dangerous goods must conform to the many regulations stipulated by the US Department of Transportation (DOT: ground transport) and the International Air Transport Association (IATA: air transport). These regulations must be followed by a faculty or staff member wishing to: 1. Ship a research sample for testing. 2. Send hazardous materials to a collaborator in industry or at another university. 3. Return a hazardous material to the manufacturer. 4. Ship a sample packaged in dry ice.
    33. 33. DOT Hazard Classes Consult with MSDS to identify DOT Hazard Class and then contact EHS Department. Department of Transportation (DOT) Hazard Class Diamonds and Placards Containers and trucks are marked with diamonds to inform you of the material’s hazard class Class 1 – Explosives  Class 6 – Toxic Materials and Infectious Substances Class 2 – Gases  Class 7 – Radioactive Materials Class 3 – Flammable Liquids  Class 8 – Corrosive Materials  Class 9 – Miscellaneous Hazardous Class 4 – Flammable Solids Materials Class 5 – Oxidizers and Organic If uncertain whether a material is Peroxides regulated by the DOT as a hazardous material, refer to the MSDS.
    34. 34. DOT Placards
    35. 35. Laboratory Clean-outs Incentive for not keeping materials on-site that will likely never be used Wastes disposed of from lab clean-outs do not have to be counted toward the facility’s generator status 30-day period to sort through and evaluate lab inventory Only one lab clean-out allowed per lab per year The clean-out only pertains to unused chemicals not waste, by- product chemicals MSOE’s EHS Department will organize and document the lab clean-outs. The EHS Department will work cooperatively with the lab techs to conduct the clean outs. Orange clean out labels are available through the EHS Department.
    36. 36. Laboratory Management Plan The goal of the LMP is for the college or university to plan how it is going to implement Subpart K’s performance-based requirements for safely managing unwanted materials generated in laboratories MSOE has a “Master Plan” LMP and each lab has developed an LMP specific to the unwanted materials generated in the lab. The EHS Director is responsible for maintaining and reviewing the Master Plan LMP on an annual basis. Faculty and Staff are responsible for developing individual LMPs that are specific to their labs. The EHS Director serves as a technical resource in the development of these plans. MSOE’s Master LMP and the LMPs of individual labs are located on the EHS Department’s intranet site.
    37. 37. LMP Contents Overview  Part 1: two mandatory elements (enforceable)  1. Describe procedures for container labeling  2. Identify which method will be used for the removal of unwanted materials  Part II: seven mandatory elements (not enforceable)  1. Describe intended best practices for container labeling and management  2. Describe intended best practices for providing training for laboratory workers and students  3. Describe intended best practices for providing training to ensure safe on- site transfers of unwanted materials by trained professionals  4. Describe intended best practices for removing unwanted material from the lab  5. Describe intended best practices for making hazardous waste determinations  6. Describe intended best practices for laboratory clean-outs  7. Describe intended best practices for emergency prevention
    38. 38. Educating Students at MSOE There are Lab Management Plan Training programs for each lab at MSOE Instructors are responsible for reviewing the lab-specific Lab Management Plans with each student prior to using the lab This training must be documented using the LMP training sign-off sheet. Lab Management Plan Training protocols consist of:  General lab rules (e.g. hours, buddy system, clothing requirement, food/drink restrictions. etc.)  Emergency Response Plan  Fire Emergency (evacuation, assembly area, fire extinguishers)  Personal Injury Response (eye wash, emergency shower)  Chemical Spill Response  Hazard Communication or “Right to Know” (potential hazards, MSDSs, chemical labels)  Chemical Handling  Chemical Storage  Chemical Disposal (SAA, trained professionals for transport out of lab)  PPE  Chemical Fume Hoods The Lab Management Plans are posted on the EHS Intranet Site. The LMP Training Sign-Off Sheet is also posted on the EHS Intranet Site.
    39. 39. Subpart K Recordkeeping The following records/documentation is maintained by the EHS Department:  Training records for laboratory workers, students and faculty  Documentation of laboratory clean-out activities, including:  Identity of the lab  The date the clean-out begins  The date the clean-out is completed (cannot be longer than 30 days)  The volume of hazardous waste generated during the clean-out  Campus-wide LMP and lab specific LMPs
    40. 40. Program Summary MSOE identifies items to be discarded from the lab as ‘Unwanted Materials’. MSOE has three EPA hazardous waste generator id numbers (Science & Engineering building, Kern Center/Residence Hall Complex, and Krueger Hall). Each lab can store unwanted materials in its designated area (known as a Satellite Accumulation Area or SAA). Unwanted materials must be labeled with the words “unwanted material” as well as the contents , the SAA location and the date that the container was placed in the SAA. MSOE has three Central Accumulation Areas (Science & Engineering building, MLH, and Krueger Hall). Only ‘Trained Professionals’ are authorized to transport unwanted materials to the CAAs. There are currently four trained professionals at MSOE. Unwanted materials are removed from individual lab SAAs to the CAAs at the request of each lab. The opportunity for unwanted material removal from the campus is scheduled on a quarterly basis. There is an on-line removal request form which must be completed to request pick-up.
    41. 41. General Safety Lab hours policy:  Normal hours for labs are between the hours of 7 am and 10 pm on regular school days. After hours (including weekend and holiday) usage of labs is not allowed without the authorization from the related supervisor and/or instructor. Depending on the lab and/or the activity, the supervisor/instructor may require use of the buddy system to work in the lab during “off” hours.  Working alone should be avoided in “hard” labs. Use of the buddy system is required in the following cases:  When the procedures being conducted are hazardous  When the lab-specific LMP Training plan indicates the buddy system is required for the particular lab  When the instructor and/or the lab-specific LMP Training plan indicates the buddy system is required for a particular activity Food and drink are not allowed in labs. (Exception for “soft” labs where chemicals are prohibited). Note: MSOE is using the term “soft lab” for labs where chemicals are prohibited and the term “hard lab” for labs where chemicals are used/allowed.
    42. 42. Hazard Communication and Safety Each department is required to assess the potential hazards and the appropriate engineering controls and/or personal protective equipment (PPE) for each lab. Students and laboratory workers must be made aware of any potential hazards in the lab (chemical and other hazards). Students and laboratory workers must wear appropriate PPE. Chemicals must be stored by compatibilities. Each lab must have a current inventory of hazardous materials used in the lab. A Material Safety Data Sheet (MSDS) must be available for each chemical used in the lab. MSOE has an on-line MSDS system which is accessible from the MSOE intranet. (https://cisprolive.chemswlive.com/CISPro/login_msds.asp?accessid=686) Every chemical container must be labeled with the contents and hazard warnings (no mystery containers).
    43. 43. Hazardous Materials IdentificationSystem(HMIS) Label Colors, numbers, and letters are used to communicate the potential hazards of a material as well as what kind of protective equipment should be worn. HEALTH 0-4 FLAMMABILITY 0-4 REACTIVITY 0-4
    44. 44. HMIS: Health HazardNumber Rating Word Rating Description of Degree of Danger 0 minimal Little or no damage, even with heavy exposures. 1 slight Irritation or minor injury that can be cured. 2 moderate M ay cause temp. or perm. minor injury or make you unable to function. 3 serious Short exposure may cause serious injury and requires quick medical attention. 4 severe Short exposure may cause death or serious injury.
    45. 45. HMIS: Flammability HazardNumber Rating Word Rating Description of Degree of Danger 0 minimal Does not normally burn even when heated to 1500 deg F 1 slight Will burn but must be heated, FP200°F 2 moderate Must be heated somewhat before burning or may form harmful gases if heated. FP=100°-200°F 3 serious Can be ignited easily, burns rapidly or ignites on exposure to air. FP=<100°F 4 severe Gives off explosive vapors at room temperature (73°F)
    46. 46. HMIS: Reactivity HazardNumber Rating W ord Rating Description of Degree of Danger 0 minimal Usually does not change even during conditions of fire. 1 slight Usually does not change, but may release some energy at high temperatures and pressures. 2 moderate Usually changes easily, may undergo strong changes (not releasing energy suddenly/not exploding) although it may be explosive in water. 3 serious M ay explode but needs a strong start (example - high temperature, pressure, or shock). 4 severe Slight shock, pressure, or temperature may cause an explosion.
    47. 47. Examples of MSOE HMIS Labels
    48. 48. Containers not properly labeled CHCL3
    49. 49. Emergency Response MSOE has developed an Emergency Response Plan (ERP) covering specific types of emergencies (e.g. fire, severe weather, medical, chemical spill, etc.) This plan has been summarized in a emergency procedures flip chart which is provided to faculty and staff and it is posted in every lab. Call Public Safety at 7159 in case of emergency (spill, injury, fire, etc.) Safety equipment is located in individual labs (eye wash, emergency shower, spill response equipment, first aid kit, fire extinguisher, fire blanket)  Note: Not every lab necessarily needs each of the above safety equipment  Note: Lab techs are responsible for testing eye wash operation on a weekly basis• Emergency evacuation procedures and assembly areas should be reviewed with students in the course of the LMP training. Evacuation routes are posted in every lab
    50. 50. Training Program Summary Hazardous Waste on Campus – Basic Facts EPA Regulatory Requirements (Subpart K) MSOE’s Lab Management Plan Requirements Hazard Communication Program Emergency Response Program
    51. 51. ?? Questions ??If you have questions on the information presented, youmay contact: Julie LaRose (MSOE) larose@msoe.edu x7144

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