R.C.R.A. Handler Training

R.C.R.A.Handler TrainingJay Industries, Inc.EHS DepartmentSeptember 2015Class ObjectivesRCRA, EPA and your jobHazardous waste types and characteristicsHazardous waste containers, labels, storage, handling and disposalManifests and shippingWaste generator types and rulesPPE and emergency responseUniversal waste and recycling

R.C.R.A., the E.P.A.,and other RegulationsWhat is RCRA?Code of Federal Regulations (40CFR 260-282)

Resource Conservation and Recovery Act

RCRA governs waste management for companies

RCRA gives the EPA the authority to regulate waste management

U.S.A. Industrial HistoryUnited States industry was not regulated

Industry generated air pollution and water pollution

R.C.R.A. History1960s=Clean Air Act banned the uncontrolled discharge of airborne pollutants

1970s=Clean Water Act banned the discharge of untreated industrial waste

1976=RCRA caused hazardous waste to be regulated

United States Environmental Protection AgencyThe Mission of the EPA is to protect human health and to safeguard the natural environment-air, water, land, upon which life depends

EPA Enforcement The EPA is the enforcement agency for RCRA

EPA inspectors have the same types of authority as FBI or ATF agents

Ohio also has a State E.P.A.

Both agencies perform general inspections at Jay Industries, issue permits, and respond to specific complaints

E.P.A. Complaint ResponseBoth Federal and Ohio EPA can respond to specific complaints, such as:

Air Emissions from a neighborWater Emissions from finding debris in the storm waterSolid Waste complaints from trash containing items that are Universal or Hazardous Waste

EPA Requires RCRA TrainingAny Large Quantity Generator employee who handles hazardous waste must be trained in the proper techniques

Certain managers must be trained more thoroughly, in order to manage the hazardous waste

Training includes classroom and on-the-job trainingWhat does Cradle to Grave mean in Environmental Management?

CRADLE to GRAVEThe EPA established regulations to govern hazardous materials from birth through death.

Identification Management Labeling Storage Tracking Disposal

There are alsoOSHA and DOT regulationsthat govern hazardous wasteOSHA governs emergency responses to hazardous waste spills and emergencies

DOT governs the transportation of hazardous wastes on public right of waysHazardous Waste Definitions, Types and Characteristics

The Legal Definition of Hazardous WasteA solid waste or combination of solid wastes;Which because of its quantity, concentration, physical, chemical or infectious characteristics;Can cause mortality or serious irreversible or incapacitating illness;Poses a substantial present or potential hazard to human health or the environment;When improperly treated, stored, transported, disposed of or otherwise managed.

Non-legal Definition of Hazardous WasteAnswer some questions:

1.Is it on the list of Hazardous Wastes? Listed Waste

2.Does it exhibit the characteristics of Hazardous Waste? Characteristic WasteThere are Two Main Types of Hazardous WasteListed Wastes=more than 400 chemicals that are on a RCRA list as Hazardous

Characteristic Wastes=the largest category of hazardous waste, containing four primary types

Listed WastesF-list=hazardous waste from nonspecific sources; spent solvents, 28 specific chemicals

K-list=hazardous waste from specific sources and industrial processes which employ chemicals that result in the generation of unstable waste; 100 types

U-list=discarded commercial chemicals, container and spill residues

P-list=any of the above that are categorized as acutely hazardous

Characteristic Waste Types (D list)Corrosive

Ignitable

Reactive

Toxic20CorrosiveAqueous waste that has a pH less than or equal to 2, or greater than or equal to 12.5

Liquid waste that corrodes steel at a rate of greater than 6.35 mm per year

Sulfuric Acid, Nitric Acid

Ignitable Not the same as flammable or combustible

Can be liquid, solid, or gaseous

Not just combustible (wood is combustible), but must burn so vigorously and persistently that it creates a serious hazard

Ignitable properties and examplesA.Flashpoint below 140 degrees F, liquidPaint, solvent, acetone

B.Flammable Solid, ignites via friction, contact with water, or spontaneous combustion. Once it catches fire, it is very difficult to extinguish. Kolene Salt, Magnesium Rods, some plastic pellets

C.Flammable Gas, already in a vapor state and easily ignitable. Acetylene, PropaneIgnitable properties and examplesD.OxidizersThey do not ignite but are reactive and can cause other materials to ignite more easily

They can supply oxygen to a reaction

The reaction can release large amounts of heat and gas or cause an explosion

Some oxidizers can corrode metal and damage living tissueReactives and examplesUnstable and easily undergoes violent change without detonation

Forms potentially violent and explosive reactions with water

When mixed with water, it generates toxic gases and vapors that can present a danger to human health and the environment

It is capable of detonation or explosion if subjected to a strong initiating source of heat or pressure Gunpowder, explosivesToxic WasteThis includes 8 heavy metals, 10 pesticides, and 21 organic compounds

A material that has the ability to harm human health or the environment, or it can cause injury, death or cancerSome questions to ask to determine haz vs. non-haz?Is the material a listed waste? F-K-P-U

If not listed, does it have the properties of a Characteristic Waste? D-listCorrosiveIgnitableReactiveToxic

Is it Universal Waste? Is the waste in an exempted category?Styrene in BMCThe BMC line in Jay Plastics produces Styrene

Styrene is Hazardous Waste and should be handled as such

Spent SolventsSpent solvents used in the painting process are F wastes

F wastes are hazardous wastes and should be handled as such

Generators are responsible for characterizing their waste as Hazardous or non-HazardousBy testing the waste in a labTCLP analysis

Applying their knowledge of the materials used (listed or characteristic components) and manufacturing process in creating the wasteQuestions?Other types of WasteExempted wastesDomestic SewageIndustrial wastewater discharges regulated under Section 4 of the Clean Water ActIrrigation return flowsBy products and special nuclear productsMaterials subjected to in-situ mining techniques which are not removed from the groundPulping liquor re-used in the paper industrySpent sulfuric acid used to produce virgin sulfuric acidSecondary materials that are reclaimed and returned to the original processSmall samples sent to the lab for analysis

Paint SludgeJay Plastics and Broshco produce paint sludge

It is tested annually for an analysis of contents

It is not hazardous waste and is disposed of as solid waste, as long as it has a cake-like consistency

D.O.T. Regulations for Paint Sludge TransportationPaint sludge cannot be transported unless it has a cake-like consistency

It cannot be watery or dripping water

Used PowderKronis produces used powder from its powder coating process

It is tested annually and is not considered hazardous waste

It is solid waste

Water TreatmentBoth Broshco and Kronis produce water that is neutralized and treated

It is tested regularly

It is not hazardous waste

Medical Waste/BiohazardBloodborne Pathogens Personal Protection Equipment

Needles in Sharps containers

Must be labeled as Biohazard Waste

Usually in a red container or bag

Special disposal rules and service

Unknown chemicalsThe EPA and OSHA consider unknown chemicals to be a serious violation

It is your job to prevent unknown chemicalsMaintain legible labelsReview and Rotate chemical stockKeep good inventory and tracking records

Universal Waste DefinedHazardous waste that a generator can manage alternatively, instead of following strict hazardous waste requirements

Generated by businesses in small quantities

Eases regulations

Promotes recyclingUniversal Waste vs. Haz WasteMust be a hazardous waste before it can be a Universal Waste

CheaperEasierIf Universal Waste is not managed by the company as Universal Waste, then it has to be handled as a Hazardous Waste

More ExpensiveMore RegulationsUniversal WasteWhen people throw away this type of waste, it is Household waste

When industry generates this type of waste, it is Universal waste

Electronics, fluorescent bulbs, items containing mercury, batteries, pesticides, other itemsOhio has 4 types of UW:

Lamps, such as incandescent, fluorescent, high intensity discharge, neon, mercury vapor, high pressure sodium, and metal halide lamps.Pesticides that are suspended, recalled or cancelled; or part of waste collection.Mercury Containing Equipment such as thermostats, barometers, temperature and pressure gauges, and switches.Discarded batteries such as nickel-cadmium and lead acid batteries.Hazardous Waste Generator Types

What is a hazardous waste generator?Any person, by site, whose act or process produces hazardous waste, or whose act first causes a hazardous waste to become subject to regulation.Three Classifications of Hazardous Waste GeneratorsLarge Quantity Generator-more than 2200 pounds of hazardous waste per month

Small Quantity Generator between 220 pounds and 2200 pounds of hazardous waste per month

Conditionally Exempt Small Quantity Generator-less than 220 pounds hazardous waste per monthRegulationsThere are more rules on waste sites that generate more waste

Large Quantity Generators have more rules and limits than Small Quantity GeneratorsJay Industries Generator ClassificationsJay PlasticsLarge Quantity Generator2200 pounds per month or more of hazardous waste

Broshco, Sarca, KronisConditionally Exempt Small Quantity Generators or Small Quantity GeneratorLQG Waste RegulationsIdentify hazardous waste;

Obtain an EPA number;

Pack waste in a DOT container with the proper label, markings, and accumulation date;

Store the waste less than 90 days;

More LQG Regulations5.Dispose of all hazardous wastes at EPA permitted treatment, storage and disposal sites;

6.Designate an Emergency Coordinator and make Contingency Plans and a Hazard Prevention Plan;

7.TRAINING for every person that handles Hazardous Waste;

More LQC Regulations8.Manifest all hazardous wastes using uniform haz waste manifest papers;

9.Keep manifests for three years in a safe place (EHS does this);

10.Analyze waste through lab testing and maintain the results for 3 years (EHS does this);

11.Submit a report to EPA every 2 years, with types, quantities, disposal and waste minimization efforts (EHS does this);

SQG RegulationsSame rules as LQG, except:

180 days storage

Must have less than 13, 277 pounds of hazardous waste on site at any time

Waste Treatment or StorageIf a waste generator does not follow the rules for their classification, the EPA can investigate

If they find violations, the EPA can change the generator status to a Waste Treatment or Storage Facility.

Waste Treatment and Storage Facilities have many more rules to follow than generators do!Questions?Hazardous Waste Containers, Labels, and StorageHaz Waste ContainersCan only be used for Hazardous Waste

Clearly marked as Hazardous Waste

Closed when not in use to reduce vapors and to prevent spills if knocked over

Keep the outside barrel as clean as possible

Separate them from other drums or containers

Haz Waste ContainersApproved drum

No structural defects

No rusting steel on drum

Container must be compatible with waste

Packaging Hazardous WasteHazardous Waste must be stored and shipped in approved D.O.T. containers

Jay Industries uses metal drums

Container D.O.T. markingsD.O.T. numbers may be imprinted in the metal portion of the barrel top or painted on the barrel

D.O.T. MarkingsD.O.T. markings may be on a sticker or located on the side of the barrel

Do not paint over D.O.T. markings on the barrel

Hazardous Waste Label

Generator NameAddressEPA Identification Number

When shipped, add:Manifest Tracking number DOT labelPlacard Hazardous Waste Locations and Storage RulesMain Accumulation SiteJay Plastics Paint RoomMust be a clear distinction between product and waste

Waste is kept on the east wall in the paint room

Main Accumulation SiteJay Plastics Paint RoomMust be orderly and neat

Labels must always be visible, readable, and turned where they can be seen immediately

Main Accumulation SiteJay Plastics Paint RoomMust be regularly inspected

The Paint Room Manager inspects the Paint Room and all Satellite Locations WEEKLY.

Inspection records are maintained three years and are subject to EPA inspection

Main Accumulation SiteJay Plastics Paint RoomAll containers must be approved

Labels must filled out properly

Labels must be visible

Main Accumulation SiteJay Plastics Paint RoomContainers and tanks must be closed

Containers must be handled carefully to prevent leaks

Time Limits=90 days maximum storage on site

Label sample in paint roomThe label will already be on the drum from the satellite area

When the barrel is taken to the paint room, put the date on the label

The calendar starts the day the barrel enters the paint room

Satellite Accumulation SitesMust be located at or near the point where the waste is created and collected;

Designed to limit the movement of waste to reduce accidents or spills during the transport of waste to the Main Accumulation Site.Important Satellite RulesNo more than 55 gallons of hazardous waste in each location;

Can have more than one container, but the total cannot exceed 55 gallons;

Must be controlled, monitored and inspected (Paint Room Manger duty)

Have up to 3 days to move the barrel after it is full

Must be stored in approved containers and properly labeledMore Satellite RulesContainers must be closed when not in use

Funnel with flame arrester must be used when adding waste

Funnel must be closed and latched when not in use

More Satellite RulesLabels must be:-clear and neat-legible printing-cannot be damaged-must be visible -must be turned where they can be seenThe start date should not be placed on a Satellite barrel. The calendar begins when the barrel is placed in the Main Accumulation Room.Label Sample at SatelliteThe Haz Waste label on the Satellite barrel should NOT have a date

The calendar does not run in the Satellite area

When a barrel is full, it must be removed to the Main Accumulation area within 72 hours

Instruction SheetsEach satellite area has an instruction sheet, with emergency contacts

The EPA ID number is on the instruction sheet

Put the EPA ID number on the Haz Waste label

Drums must be CLEANTops must be clean and waste free

No drips or splatters

Use spill kits or pigg matts

Use a drip pan under to catch drips and spills

Drip PansUse a drip pan under the spigot of any open chemical, to prevent drips and spills

More Satellite RulesContainers of hazardous materials must be grounded and/or bonded when they are open or in use

This helps prevent fires from static electricity sparks

More satellite rulesReactive or ignitable waste Satellite locations must be at least 50 feet from the property line, in order to reduce the chances of ignition from an outside source, such as welding or cigarettes.

ABSOLUTELY NO SMOKING OR ECIGARETTES ANYWHERE NEAR A MAIN OR SATELLITE ACCUMULATION SITE.EPA ViolationsThe EPA considers these rules so important that they can issue violations against the company if the rules are broken

EACH satellite rule that is broken can constitute ONE EPA violation

Fines for ONE violation begin at $10,000 per violation

Walmart fined 81 MillionWal-Mart pleads guilty in hazardous waste cases, to pay $81 million

Wal-Mart Stores Inc. admitted to improperly handling and disposing of hazardous materials at its stores nationwide, pleading guilty Tuesday to several federal criminal and civil counts and agreeing to pay more than $81 million.

Thee criminal cases from the Justice Department and a civil case brought by the U.S. E.P.A.

The findings -- not training workers to properly deal with and discard hazardous waste, some of which ended up in municipal trash bins or in local sewers.

The satellite drum is full and you need another one. What do you do?No more than 55 gallons at any satellite collection site

Up to three days to have the drum removed and replaced with an empty one

Make sure the new drum is labeled properlyHazardous Waste ManifestsWhat is a manifest?Special shipping papers with mandated information completed

They are a LEGAL document

Creates a chain of custody for tracking of waste

Required by the EPA and DOT

Hazardous Waste ManifestAllows accurate tracking from Cradle to Grave

Creates liability for the GENERATOR

Creates a paper trail documenting that the proper steps are taken with waste

Hazardous Waste ManifestsMust be filled out completely and accurately

Generator must be sure the manifest is complete

Signed copy is sent to the state

Final facility must return a copy to the Generator

Open to EPA inspection upon demand

Hazardous Waste ManifestThe person who signs must have special training

The generator is responsible for keeping the manifest securely for three years

Incorrect or fraudulent manifesting can result in fines and/or jail time!

Hazardous Waste Mistakes and ChallengesHaz Waste MistakesMistakes can lead to E.P.A., O.S.H.A. and other violations

Mistakes can cause fire and explosion hazards

Mistakes waste materials and time

Mistakes cost money

Mistakes are unsafe

Your supplier wants you to send them a waste paint sample?STOP!

Hazardous waste can only be shipped under very strict conditions

Shipping is governed by FAA, EPA, and DOT

Contact your manager or a member of EHS for assistanceTop Haz Waste MistakesNot closing drums of waste

Not keeping training up to date

Pouring haz waste down the drain

Using improper containers

Top Haz Waste MistakesOutdated contingency plans

Incorrect markings on the labels

Improperly filled out Haz Waste Manifests (generator is responsible, not transporter)

Accumulating too much waste at the satellite

Keeping waste on site over legal time limits

Top Haz Waste MistakesMisclassification as hazardous or non hazardous and vice versa

Mishandling of drips and spills

Throwing hazardous waste in the trash

Mixing incompatible wastes togetherPrevent Mistakes to Prevent Problems and ViolationsBe Careful. Slow down and do it right

Keep your work area clean

Use Personal Protective Equipment

Remember the Hazardous Waste rulesQuestions?Personal Protective Equipment and Emergency ResponsePersonal Protective EquipmentThe chemical SDS will tell you what you should wear

SDS information can be obtained in PLEX or on the internal web page

Wear chemical resistant gloves, goggles, aprons, protective clothing, or respiratory protection, when neededPersonal HygieneWash your hands before eating or smoking

Do not eat or drink near Haz Waste

Remove contaminated clothing

Wash thoroughly at the end of the dayWhat IS a Haz Mat Emergency?An incident that the plant cannot handle using its own personnel. Outside resources are needed to stabilize and clean up the situation because there is a potential safety or health hazard.

-Need for outside resources-Threat to health and safetyWhat is NOT a Hazardous Material emergency?The spilled substance can be absorbed, neutralized or controlled by employees in the immediate area or with the help of Maintenance.Jay Plastics Haz Materials Contingency PlanJay Plastics has a written plan which addresses:FireExplosionLarge Scale Spill

The plan can be found under the EHS tab on the home page, under PLANS

Top managers have received training on the planLarge Scale SpillWould require outside assistance in stabilizing and clean-up

Jay Industries would contract any emergency response that it would requireEmergency ResponseNotify others of the spillLimit access to the spill areaLeave the area if the chemicals threaten personal health or safetyUse proper PPE and equipment during clean-upEmergency EquipmentLarge and small spill kitsFire Extinguishers, fire suppression systems, fire alarmsEmergency lighting and Exit lightsFirst Aid and Bloodborne Pathogens kitsEye wash stations and showers

These items are maintained by E.H.S. Dept. and are located throughout the buildingLarge and Small Spill KitsEvery plant has at least one large spill kits

There are small spill kits in all key locations

EHS maintains and inspects the spill kits monthly

Contact EHS if the spill kit is used; they will refill it

Large Spill KitsFor large spillsSocks, pads, snakes and oil dryPersonal Protective EquipmentThe large yellow container can serve as an over pack to contain a leaking 55 gallon drumLocated in key areas

Small Spill KitsFor small spillsPads, socks, and drum leak plugPersonal Protective EquipmentThe yellow buckets can serve as a containerLocated in many key areas

HousekeepingClean up all Hazardous Waste spills immediately

Keep containers closed tightly when not in use

Use drip pans and secondary containment

Keep trash and debris away from flammables

No smoking or sparks nearby

Do you want your work are to look like this?

Know Your ChemicalsRead the label

Use caution and follow the precautions on the SDS

Keep Corrosives away from Flammables

Keep water away from Reactives

Make sure EVERY container containing a chemical is labeled

Questions?Oil ManagementOil managementJay Industries recycles all used oil, used coolant, and used oil filters

Oil must be stored and managed properly to prevent spills

Used oil is recycledUsed oil is sorted by grade

Higher grades of used oil are recycled

Some used oil cannot be recycledIf the used oil has too much water in it, it cannot be recycled

Jay Industries properly disposes of used oil/water combinations

Used Oil must be labeled Used OilThe term Waste Oil should not be used

Waste oil has been contaminated by other chemicals

Waste oil must be disposed of as hazardous waste

Oil must be stored on Secondary ContainmentSecondary containment catches spills and drips

Secondary container must be emptied before it over flows

Used Oil containers must be closed when not in useContainers must be closed when not in use, to prevent accidental spills

Small containers and buckets must also be closed

Used OilOpen buckets are a spill hazard

This bucket is so full of oil that it cannot be moved without spillage!

Used Oil cannot be stored outdoorsIf the container would leak, it could go into the storm water drains or into the ground

Oil damages the water supply

Oil in the drain can result in heavy fines

Clean up oil spills immediately!

Universal Waste and RecyclingOhio has 4 types of Universal WasteLight bulbs that contain heavy metals

Pesticides suspended or recalled

Mercury containing equipment

BatteriesUniversal Waste handling

Must be labeled Universal Waste

Cannot be stored on site more than 365 days

Must be stored to prevent breakage, leaks or spills

The date storage begins should be written on the labelRecyclingJay Industries is committed to an active recycling program

Recycling uses part or all of a product to make a new product

It saves natural resources and puts less solid waste in the landfillLightbulbs are Universal WasteJay Plastics crushes lightbulbs

Crushed bulbs are tested to insure that they are not hazardous

They are properly disposed of when the barrel is fullImproper Lightbulb Mgmt.Not stored to prevent breakage

Not labeled

Not dated

Can break and cause release of toxins, such as Mercury

Correct lightbulb storageLabeled as Universal Waste

Placed in cardboard box and sealed to prevent breakage

Lightbulb Storage TimesDate on the box when storage begins

Must be crushed within 365 days of storage

Lead Acid BatteriesCar and lawn mower batteries; some tow motor or machine batteries

Not subject to hazardous waste regulations

Jay Industries recycles all lead acid batteries

Household batteriesJay Industries recycles all household-type batteries

These are batteries such as 9 volt, AA, AAA, C and D

Battery Recycling BucketsBattery recycling buckets are located in central locations such as tool crib, maintenance, office areas, etc.

Put the date on the bucket when it is put into useUniversal Waste can be stored for 365 days

It must be dated the day that storage begins

Mercury

Switches and ballasts containing Mercury should be sealed in a bag to prevent air leakage

Mercury containing items should be turned in to Maintenance for disposalScrap MetalsJay Industries recycles all scrap metals including steel, copper, aluminum

Scrap metals are exempt from regulation when they are recycled

Scrap Parts are RecycledMetals recycles their scrap parts

Plastics regrinds certain types of scrap parts to make more plastic materials

Why Recycle?

Americans represent 5% of the world population but generate 30% of the worlds wasteWe throw away 4.3 pounds of waste per day per person

Less than 2% of the total waste is U.S. is recycled

Half our daily waste could be recycled-enough to fill a football stadium from top to bottom EVERY day

Most Americans will throw away 90,000 pounds of waste in their lifetime

Why recycle?

Reduces solid wasteSaves natural resourcesPlease do your part.Plastic Bottles

Aluminum Cans

Cardboard recyclingKeeps it out of the landfill

Reduces solid waste

Reduces use of natural resources

Aerosol CansBroshco punctures paint cans and captures the leftover paintThe paint is disposed of as hazardous wasteCans are recycled as scrapEven better, is to eliminate the use of aerosol as much as possible

Office Paper recyclingJay Industries recycles all office paper

Electronics and Ink CartridgesAt home, you can throw your electronics in the trash

At work, electronics are considered Universal Waste

The I.T. Department recycles Jay Industries electronics such as computers and printers

The I.T. Department recycles Jay Industries ink cartridges

Reduce your useEven better than recycling-reduce your use.

Reuse the item

No one knows for sure how long it takes a plastic bottle to decompose.

Use refillable drink bottles and bring your own.

It is cheaper, too!

Better than recycling:Reuse-use it over and over until it is worn out

Reduce-dont buy it

Recycle

R.C.R.A. Managersand Other Resources

RCRA ManagersThere are trained RCRA managers in most plants in Jay Industries

They can answer your questions

If they dont know the answer, they know how to find the answer

EHS has RCRA managers to help with RCRA Management, to file the proper reports and permits, and to interface with the E.P.A.

Jay Industries resources on the internal web pageBloodborne Pathogens Plan and Training

Jay Plastics Contingency Plan

Emergency Action Plans

SWPPP and SPCCC plans (EHS)

Fire Prevention Plan

Questions?Whose job is it?YOURS!

YOU take responsibility for keeping yourselves, your co-workers, and the plant clean and safe

Thank you for attending R.C.R.A. training