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For MSOE Faculty/Staff

            August 2011
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.
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.
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
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)
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)
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”
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
MSOE Lab Management Program Key
Requirements
 Unwanted Material Labeling Standards

 Container Standards

 Training Requirements

 Removal Frequency of Unwanted Materials

 Making the Hazardous Waste Determination

 Laboratory Clean-outs

 Laboratory Management Plan
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
Labeling Standards
Information 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
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.
Unwanted Material Label
  The words Unwanted
  Materials or equally
   effective term used
consistently and written          UNWANTED MATERIAL            Information to
in 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)
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
Improperly Stored Unwanted
             Material
 No MSOE labels
 No secondary
  containment
 No segregation
 Containers covered with
  residue
Improperly Stored Unwanted
             Materials
 No MSOE labels
 No secondary
  containment from hood
  drain
 No segregation
 Container not sealed
  properly (open funnel)
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
Unwanted Material Label
                     Working Container
  The words Unwanted
  Materials or equally
   effective term used            UNWANTED MATERIAL
consistently and written                                   Information to
in 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
Satellite Accumulation Area Signage
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.
Unwanted Material
Removal
To Request a Pick-Up,
(1) Go to the MSOE intranet site
(http://inside.msoe.edu)
(2) Look under the Environmental Health
and Safety Department
(3) Refer to the Environmental Protection
Section
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
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
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.
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.
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 Sources



Examples of EPA U Listed Waste on Campus:
  Acetone, Acetonitrile, Acrylamide, 1-
  Butanol, Dichloromethane, Ethidium Bromide, Ethyl
  acetate, Toluene, Xylene
Ignitable Wastes
A liquid that has a flash point of <140° F

Flammable 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.
Corrosive Wastes


Have 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 solid


Examples: nitric acid, aqueous sodium
  hydroxide, hydrochloric acid.


Corrosive materials are represented by a
  D002 waste code.
Reactive Wastes
Materials that undergo violent change:
   - react violently with water or air
   - capable of detonation
   - create toxic gases when exposed to pH extremes

Examples: sodium metal, extremely dry picric acid, and organic peroxides.


                     Reactive materials are represented by a   D003 waste code.
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.
Examples of Toxic Contaminants
Heavy 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 Metropolitan
Organics:                               Sewerage District (MMSD) strict
 benzene, carbon                        discharge limits.
 tetrachloride, chlorobenzene, chloro • MMSD also strictly governs the
 form,                                  discharge of ammonia, cyanide
                                        and hexane.
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.
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.
DOT Placards
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.
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.
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
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.
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
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.
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.
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).
Hazardous Materials Identification
System(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
HMIS: Health Hazard
Number 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.
HMIS: Flammability Hazard
Number 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)
HMIS: Reactivity Hazard
Number 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.
Examples of MSOE HMIS Labels
Containers not properly labeled




              CHCL3
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
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
?? Questions ??
If you have questions on the information presented, you
may contact:
  Julie LaRose (MSOE)
  larose@msoe.edu
  x7144

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MSOE LMP Training 2011-2013

  • 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. 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. 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. 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. 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. 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. 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. MSOE Lab Management Program Key Requirements  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. 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. Labeling Standards Information 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. 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. Unwanted Material Label The words Unwanted Materials or equally effective term used consistently and written UNWANTED MATERIAL Information to in 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. 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. Improperly Stored Unwanted Material  No MSOE labels  No secondary containment  No segregation  Containers covered with residue
  • 16. Improperly Stored Unwanted Materials  No MSOE labels  No secondary containment from hood drain  No segregation  Container not sealed properly (open funnel)
  • 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. Unwanted Material Label Working Container The words Unwanted Materials or equally effective term used UNWANTED MATERIAL consistently and written Information to in 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
  • 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. Unwanted Material Removal To Request a Pick-Up, (1) Go to the MSOE intranet site (http://inside.msoe.edu) (2) Look under the Environmental Health and Safety Department (3) Refer to the Environmental Protection Section
  • 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. 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. 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. 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. 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 Sources Examples of EPA U Listed Waste on Campus: Acetone, Acetonitrile, Acrylamide, 1- Butanol, Dichloromethane, Ethidium Bromide, Ethyl acetate, Toluene, Xylene
  • 27. Ignitable Wastes A liquid that has a flash point of <140° F Flammable 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. Corrosive Wastes Have 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 solid Examples: nitric acid, aqueous sodium hydroxide, hydrochloric acid. Corrosive materials are represented by a D002 waste code.
  • 29. Reactive Wastes Materials that undergo violent change: - react violently with water or air - capable of detonation - create toxic gases when exposed to pH extremes Examples: sodium metal, extremely dry picric acid, and organic peroxides. Reactive materials are represented by a D003 waste code.
  • 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. Examples of Toxic Contaminants Heavy 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 Metropolitan Organics: Sewerage District (MMSD) strict benzene, carbon discharge limits. tetrachloride, chlorobenzene, chloro • MMSD also strictly governs the form, discharge of ammonia, cyanide and hexane.
  • 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. 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.
  • 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. 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. 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. 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. 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. 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. 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. 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. Hazardous Materials Identification System(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. HMIS: Health Hazard Number 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. HMIS: Flammability Hazard Number 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. HMIS: Reactivity Hazard Number 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. Examples of MSOE HMIS Labels
  • 48. Containers not properly labeled CHCL3
  • 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. 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. ?? Questions ?? If you have questions on the information presented, you may contact: Julie LaRose (MSOE) larose@msoe.edu x7144

Editor's Notes

  1. 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.
  2. 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….
  3. Discuss how MSOE is different than industry
  4. 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.
  5. Acute Waste&gt;2.2 lbs/month generation or &gt; 2.2 lbs accumulation at any time makes you a LQG2200 lbs. (1000 kg) is about five 55-gallon drums
  6. 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.
  7. 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.
  8. 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.
  9. 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.
  10. 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.
  11. 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.
  12. 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.
  13. 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.
  14. 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.
  15. Remove funnel and close container when not adding waste
  16. 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
  17. The signage can be acquired by contacting the EHS Department.
  18. Media, CDs, Floppy Discs, Hard Drives – all go to Sandy Haro in the Treasurer’s Office (has a contract with Piranha)
  19. As you can see, we have great response to our calls to clean out and our clean outs thus far have been very successful.
  20. The new standard requires a higher level of training from the hazardous waste handlers down to students.
  21. 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.
  22. 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 &quot;listed wastes&quot; are specific industrial waste streams that appear on one of four lists (&quot;F,&quot; &quot;K,&quot; &quot;P&quot; or &quot;U&quot;) as defined in the Code of Federal Regulations Title 40, Part 261, Subpart &quot;D.&quot; &quot;F&quot; List Wastes Wastes on the &quot;F&quot; list are produced during common industrial or manufacturing processes such as degreasing. Because &quot;F&quot; list wastes are not specific to any particular sector of industry, they are also called &quot;non-specific source wastes.&quot; 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. &quot;K List Wastes &quot;K&quot; 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. &quot;P&quot; and &quot;U&quot; List Wastes Both &quot;P&quot; and &quot;U&quot; lists involve discarded commercial chemical products, or unused pure or commercial-grade chemical products. Chemicals on the &quot;P&quot; list are fatal or irreversibly damaging to humans and animals at low doses. Those on the &quot;U&quot; 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 &quot;P&quot; and &quot;U&quot; list wastes in full. 
  23. Ignitable compressed gas DOT list 49 CFR 173.300Oxidizer defined by DOT 49 CFR 173.151
  24. 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
  25. Only one LMP is required for the entire campus
  26. Sulfuric AcidSodium HydroxideChloroformHydraulic Oil
  27. 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.