1 RCRA Providence VAMC Hazardous Waste Management Program Research Lab Hazardous Waste Training...

1 RCRA

Providence VAMC Hazardous Waste Management

Program

Research LabHazardous Waste Training 2008

2 RCRA

Hazardous Waste Management

Why do we have a HW Program?

It is mandated by EPA, RI Dept. Environmental Management (RIDEM), and VHA

Safety of Patients, Staff, and Students

“Cradle to Grave” responsibility for our waste

3 RCRA


HW Program Elements

1)Employee Hazardous Waste Training

2)Hazardous Waste Identification

3)Hazardous Waste Storage Accumulation Point (AP)

Management Satellite Accumulation Point (SAP)

Management

4)Spill Response Procedures

4 RCRA


EMPLOYEE TRAINING

5 RCRA

Employee Training

HW training is required for personnel managing accumulation (AP) & initial accumulation points (IAP)

Initial HW training should occur within 6 months of a person assigned to a AP/IAP, then annual refresher.

It is NOT Health and Safety Training

It is NOT HAZMAT, HAZWOPER, or HAZCOM training

6 RCRA

Employee Training

HW training will be done by a person trained in hazardous waste management (e.g. VAMC GEMS Coordinator)

Training must include Integrated Contingency Plan Procedures (e.g. Spill

Response Procedures)

Training must include hazardous waste procedures relevant to the position they are employed

7 RCRA


HAZARDOUS WASTE IDENTIFICATION

8 RCRA

Hazardous Waste Identification

Definition of a Hazardous Waste: Contaminated or spent chemicals that can no longer be

used for their intended purpose, outdated or expired chemicals, and chemicals in poor containers (e.g. broken containers, missing labels, etc.).

Acutely toxic chemical listed by name in 40 CFR 261 (e.g. Sodium Azide; U and P Listed)

A chemical listed by name in 40 CFR 261 from a non-specific source (e.g. Methanol Solvent; F Listed)

Determined to exhibit a characteristic that the EPA has identified as making it a hazardous waste (e.g. isopropyl alcohol; D Listed)

Ignitable (<140oF) Corrosive (pH <2, >12) Reactive (water, oxidizer, friction, etc..) Toxic

9 RCRA


Examples of RESEARCH Hazardous WasteMixed Isopropyl Alcohol: (Ignitable, D001)Trans Buffer (Toxic, F003 / Ignitable,

D001)X-Ray Fixer & Rinse-water (Toxic, D011)X-Ray Developer (State Listed R006)Hydrochloric Acid w/ Methanol (Corrosive,

D002 / Ignitable, D001 / Toxic, F003)

10 RCRA


Some wastes may not be “hazardous waste” but must be handled following hazardous waste procedures Chemicals prohibited by the RI

Narragansett Bay Commission for disposal to sanitary sewer

Universal Waste Fluorescent Light Bulbs Rechargeable Batteries

Used Oil

11 RCRA


Universal Waste: A special class of hazardous waste

Batteries: Lead Acid, NiCad, Lithium, Silver Button.

Used lamps (FLB’s, Sodium Lamps, etc.)

Mercury containing items, such as

thermostats, thermometers, BP cuffs, some pressure gauges, some flow meters, etc

12 RCRA

Universal Waste

Universal Waste must be properly labeled

“Universal Waste Batteries” “Universal Waste Lamps”

Universal waste may not be accumulated for more than one year

(Note: Hazardous Waste may not accumulate for more than 89 days)

13 RCRA


HAZARDOUS WASTE STORAGE

14 RCRA

Storage of Hazardous Waste

Initial Accumulation Points (IAP)A storage location at or near the point

of generation where hazardous waste is initially accumulated.

Limits on the amount of waste that can be accumulated at the IAP.

One container, up to 55 gallons per waste stream

No time limit on accumulation

Almost every Service has a SAP manager.

15 RCRA


Initial Accumulation Point Managers Have control over the waste stored in their area Responsible for weekly storage area inspections Responsible for contacting the GEMS

Coordinator if storage areas requires a waste pick-up

Responsible for training employees who place waste in their storage area.

RESEARCH IAP Managers are… Julie Newton Kerry LaPlante C. McGeary

16 RCRA

Initial Accumulation Points

IAP-03, RM 123 Hoods IAP-14, RM 125 Waste Streams

650-047 & 650-103 650-018, 650-019, 650-056

Methanol & DMSO Developer, Fixer , Rinse water

17 RCRA


IAP Requirements 1. Compatible Containers (e.g. Acids in

plastic/glass, Oils in metal containers)

2. Containers must remain closed when not adding waste

18 RCRA


IAP Requirements3. Labeling: All waste containers must

be labeled appropriately with the words “Hazardous Waste”

& “Contents of Container”

GEMS Coordinator can provide labels and containers

19 RCRA


IAP Requirements4. Secondary Containment for

containers (protect floor drains)

20 RCRA


IAP Requirements5. Emergency Contact Information

Posted 6. Have Spill Control Materials

Available

21 RCRA


IAP Requirements7.Weekly Inspections

No leaks No deterioration of containers Containers closed Everything properly labeled Labels face forward No incompatibles stored together Date and time of inspection Observations Corrective actions taken Full name of inspector

(Initials or nicknames not acceptable)

22 RCRA

Example of weekly inspection log

23 RCRA

Accumulation Point Management

Room 135 & 227 – Flammable Storage

SAP containers are brought here when full

ASD placed on container

90 Day Accumulation

More than one container

Proper Segregation

Weekly Inspections

HW labeled completely filled out

24 RCRA


What happens to your waste after it is picked up?We take it to our

Central Accumulation AreaWe conduct field tests

for disposal characterizationWe assign waste codes We keep a weekly inventory

and running inventory of the waste.Waste must be off-site within 90 days.

25 RCRA


Spill Response

Procedures

26 RCRA

Spill Response Procedures

Workers must be familiar will VAMC Integrated Contingency Plan (ICP)

Incidental spill V.S. Non-incidental spill

Report ALL spills to your supervisor, No matter what size it is

27 RCRA

Incidental Spills

Small quantity (e.g. Amount you would use on a lab bench or slight spillage when transferring from one container to another in a shop

Can be cleaned without outside assistance

Always use the appropriate PPE when cleaning up spills

Spill clean-up material is hazardous waste

28 RCRA

Non-Incidental spill

Amount greater than normal use

Outside resources needed due either to quantity or PPE limitations

Notify VA Police (x4999)

Process is identified in EOC Manual and Integrated Contingency Plan

29 RCRA

Incidental Non-Incidental No Env. Exposure Env. exposure


30 RCRA

Major spill


31 RCRA


THE END

Questions??

Contact GEMS Coordinator @ x2637

32 RCRA

Training Certificate

RESEARCH SERVICE VA MEDICAL CENTER

Providence, RI

VA-SPONSORED HAZARDOUS WASTE TRAINING

PROOF OF TRAINING FOR VA EMPLOYEE

I affirm that I have reviewed the mandatory VA Research Hazardous Waste Training: PRINTED NAME DATE SIGNATURE

1 RCRA Providence VAMC Hazardous Waste Management Program Research Lab Hazardous Waste Training...

Documents

Transcript of 1 RCRA Providence VAMC Hazardous Waste Management Program Research Lab Hazardous Waste Training...