Posted on Thu, Jan 14, 2010 @ 08:34 AM
Doug Graham, CHMM Sr. Compliance Advisor & Training Manager
Yes, they’re at it again! Just when you thought you knew how to ship lithium batteries, DOT has thrown in yet another potential rule change.
Currently, there are exceptions for certain “small” lithium metal (primary) and lithium ion (rechargeable) batteries, wherein the DOT allows those batteries to be shipped under a special provision. If the batteries (including those in equipment) meet the requirements described in Special Provision 188 of 49 CFR 172.102, they need not comply with the entire scope of the hazardous materials regulations. DOT defines the maximum size of the batteries applicable to this provision based upon the amount of lithium within each cell and the total within each battery. The batteries that fall within this small-sized range are those we typically find inside cell phones, cameras, and laptop computers, and have power ratings under roughly 100 Watt-hours (Wh).
In a press release on January 8, 2010, the DOT is proposing to remove those exceptions for small lithium batteries, effectively making them fully regulated Class 9 hazardous materials like their medium and large-sized counterparts. The justification for the proposed rule change was explained by House Transportation and Infrastructure Chairman Jim Oberstar this way, "Under existing regulations, a flight crew may not be made aware of a pallet containing thousands of lithium batteries on board the aircraft, yet a five-pound package of flammable paint or dry ice would be subject to the full scope of the regulations. That makes little sense. . .”
To follow these developments regarding lithium battery shipping issues, and other emerging rules regarding DOT hazardous materials, log onto www.phmsa.dot.gov/hazmat . To view the proposed rule change (docket HM-224F) as published in the Federal Register on January 11, 2010, click on the following link: http://edocket.access.gpo.gov/2010/2010-281.htm. So. . . . . .keep your ear to the ground, if history’s any indicator, there’s sure to be more to come.
Posted on Tue, Jan 05, 2010 @ 02:33 PM
Its Biennial Reporting time! The Biennial Report is a mandatory report pursuant to sections 3002 and 3004 of the Resource Conservation and Recovery Act (RCRA). You are required by Federal statue to complete and file a 2009 Hazardous Waste Report if your site is classified as a Large Quantity Generator (LQG) or you or treated, stored, or disposed of hazardous wastes on-site during 2009. Furthermore, some states may impose reporting requirements above and beyond the Federal requirements, such as mandating Small Quantity Generators (SQG) to file. The due date for this reporting year is March 1, 2010 for most states.
Reporting is done on a two-year cycle and the information is collected via the Hazardous Waste Report for the required reporting year. Reports describe each generated hazardous waste, the activity by which they generated the wastes, and the quantity. In addition the reports need to include the management method by which each waste was treated, recycled, or disposed and the quantity managed.
If you are unsure of applicability or are interested in assistance with completing the report, please contact Triumvirate’s consulting group for more information. We have Environmental Consultants ready to answer your questions.
Posted on Wed, Dec 23, 2009 @ 09:43 AM
By Greg Brady, Operations Coordinator
One of the most important, but often overlooked, aspects of chemical management is the proper labeling of chemical containers. In the interest of safety, it is important that all chemicals, used and unused, are clearly labeled and if your facility has a Hazard Communication Plan, it is a requirement. It is crucial in maintaining a safe working environment that the people that are working at your facility are very clear on what they are working with. It is also essential in the event of an emergency response, that the people responding know what materials are in use as well as what materials may have been released. When managing chemicals that are considered hazardous waste, there are four essential requirements for your label:
• Containers must be labeled with the words “HAZARDOUS WASTE”.
• Containers must be labeled with all of the constituents. Constituents must be written clearly and completely without using abbreviations or chemical formulas. It’s also a good idea to use pencil instead of pen so that if the tag gets wet, the constituents can still be read.
• One or more of these four hazard classes must be checked: Ignitable, Corrosive, Reactive or Toxic. Additional information can be included on the tag for informational purposes such as oxidizer, but it is not required.
• Containers must be dated when they are full or no longer in use. Depending on your facility requirements, you must then dispose of the waste within a certain amount of time.
By following these simple guidelines, you can ensure that your facility continues to be a safe place to work while maintaining compliance.
Posted on Mon, Dec 21, 2009 @ 01:07 PM
By Alexa Kaubris, Chemist
With all the rules and regulations, things can get confusing when you have an entire room filled with chemicals. If you’re overwhelmed don’t worry you’re not alone. Here are some helpful hints and reminders when inspecting or reorganizing your MAA in Massachusetts. Don’t forget, not only are there a ton of rules but they change from state to state.
1. Every hazardous waste bottle in the MAA needs a label with a) the words “Hazardous Waste” b) the constituents of the container written in full (no abbreviations or chemical formulas) c) the hazards of the bottle identified (corrosive, ignitable, etc.) d) the date the container was filled in its respective satellite accumulation area (SAA) or the date accumulation began if you fill drums in the MAA.
Do: Make sure you can see this label.
Do: Make sure the container is closed tightly.
Do: Inspect the containers for leaks and cracks.
Do: Make sure the label is on the side of the containers (not on the top).
Hint: It’s always a good idea to label empty drums and containers in the MAA for clarity.
2. These bottles should be segregated out into secondary containment bins so that incompatible chemicals won’t react and an underlying impermeable surface will be ensured.
3. The room itself needs to have an impervious underlying surface, a base that slopes or elevated containers in case of a leak, and run-on needs to be prevented unless containment has excess capacity. Basically, if you have a spill, you need to make sure the other chemicals you are storing in the MAA won’t be sitting in the mess.
Do: Check expansion joints on concrete pads.
Do: Make sure there are no drains in the MAA.
Do: Make sure every hazardous waste container in the MAA is in a designated area for waste. Putting tape on the floor is a quick way to delineate the waste area. Everything else should be stored elsewhere in the MAA.
Hint: For best management practices any material labeled as non-hazardous should be kept separate for the hazardous material.
4. Watch out for aisle spacing! If the waste is not reactive or ignitable all you need is enough room to inspect each row. If the waste is ignitable or reactive you need four feet as required by the NFPA chapter 30.985(3).
Hint: If you’re tight on space, one solution is to make a double row of drums back to back in the middle of the room and then give 4ft to either side. Another is using a pallet to separate containers if you need to stack them.
Fast Facts:
Reactives/Ignitables need to be stored 50 feet from the property line.
The fire department does not like Reactives/Ignitables to be stored in underground rooms like basements (waste or not). The idea behind this being safety of personnel that would have to respond to a fire in a basement when there are limited entrance/exits.
Good luck and have fun! Be sure to take before and after pictures. Make-overs are the best!
Posted on Mon, Dec 14, 2009 @ 08:11 AM
By Doug Graham, Senior Environmental Compliance Advisor
Most
shippers and carriers are now aware of several regulatory changes that
have effectively tightened up the shipping requirements for both
lithium metal and lithium ion batteries. Both the US Department of
Transportation and the International Air Transport Association have
made significant revisions to the rules in both 2008 and 2009.
Packaging Lithium Batteries per updated DOT Regulations
Guidelines for New DOT Regulations Regarding Batteries sent for Recycling
What’s this all about?
Here are a few interesting facts and statistics raised during a
November 19, 2009 hearing of the U.S. House of Representatives
Subcommittee on Railroads, Pipelines and Hazardous materials:
- The Federal Aviation Administration (FAA) gathered
information on 90 hazardous materials incidents occurring from 1991 to
2008. That data indicated that 27 percent of these incidents involved
lithium batteries.
-
The vast majority of those lithium battery incidents (73%) resulted
from either internal or external short-circuiting; 12% from charging or
discharging; and 6% from activation of devices containing lithium
batteries. The balance of the incidents resulted from either
malfunctions or improper handling.
- FAA testing has indicated that current aircraft cargo fire
suppression system would not be capable of suppressing a fire if a
shipment of metal lithium batteries were ignited in flight.
- The National Transportation Safety Board (NTSB) investigated
a February 7, 2006 incident at the Philadelphia International Airport
in which a fire – suspected to have been caused by lithium batteries –
destroyed a United Parcel Service cargo aircraft and most of its cargo.
- That incident lead to the NTSB making five recommendations to the DOT Pipeline and Hazardous Materials Safety Administration.
In light of this increased awareness and dynamic
rule-making environment, offerors and transporters are well-advised to
check and double check the most recent requirements before getting
lithium batteries moving over the road, water, or especially, through
the air.
Posted on Tue, Dec 08, 2009 @ 09:27 AM
By Greg Rosinski, Chemist II
Walking through the laboratories of colleges and universities will result in seeing a lot of unused chemicals that are prior circa 1980. Typically the chemicals are pushed to the back of the chemical storage cabinet until the professor retires. In order to decrease the potential exposure these chemicals could create it is important for the Environmental Health and Safety (EH&S) department to monitor the amount of these chemicals remaining. Recently, a local university had a professor retire from a career of over 50 years of teaching in the same lab. This professor had a refrigerator full of temperature sensitive chemicals that he kept adding to over the years without properly disposing of them. Murphy’s Law played out in this circumstance when a storm happened on the weekend causing a power outage. The school’s generators also were struck causing the refrigerator to shut off, and increase in temperatures beyond the allowable range for the chemicals. The chemicals reacted causing the containers to fail, and spill throughout the refrigerator. On Monday when the professor went to open the refrigerator to start his lab the fumes were nauseating, and forced the EH&S department to call Triumvirate Environmental Inc. to properly dispose of the chemicals. The EH&S then had to make a phone call to have the refrigerator properly decontaminated. The cost to the university in bills and the inconvenience of shutting down the lab has made the EH&S director proactive in disposing of unused chemicals. The result of proper management of aged chemicals has reduced their average spending on disposal, and the occurrence of spills or other incidents. Properly managing chemicals involves spending time in labs, and looking outside of the normal areas. This will help to identify chemicals that are no longer in use. The cost of spills costs more than proactively managing a hazardous waste program. A good place to start looking for temperature sensitive chemicals (not an all inclusive list) is the Department of Transportation (DOT). The DOT’s list can be found in 49 CFR 173.224 for self reactive materials, and 49 CFR 173.225 for organic peroxides. These two types of chemicals are known to become unstable with age.
Posted on Wed, Dec 02, 2009 @ 06:33 AM
By Doug Graham, CHMM
The DOT hazardous materials regulations are a lengthy, complex set of rules with wide-sweeping applicability in many facilities. Investigating all the employees, vendors, materials, and shipment types involving hazmats can be challenging. To make matters worse, shipments may be originating from numerous departments, not necessarily immediately obvious to EH&S staff. Here are a few examples, I’ve heard many times over the years- “I didn’t know the lab was shipping dry ice by air”, “the engineering department has their own FedEx account?”, “Materials Management sent back hazardous chemicals to the supplier in a regular box?”, and my personal favorite- “who authorized him to sign hazardous waste manifests?”.
Here are 10 steps one can take to get a handle on DOT hazardous materials compliance-
1. Identify all potentially-regulated hazardous materials (hazardous wastes, medical /biological wastes, biological products and specimens, dry ice, radioactive materials, and hazardous chemicals (e.g., poisons, corrosives, gases, oxidizers, and flammables) that could potentially be shipped from each department.
2. Identify the modes of transport and carriers and the regulations applicable to each (e.g., 49 CFR for ground and UPS domestic air; IATA for FedEx Express; IMDG for international marine).
3. Identify all employees who have responsibilities related to preparing hazardous materials for transport (“hazmat employees”).
4. Develop training program(s) for those employees addressing general awareness, function-specific, and security issues, including training specific to 49 CFR, IATA, and IMDG, when applicable.
5. Train new hazmat employees within 90 days and retrain every 36 months.
6. Create shipping procedures for regularly-offered hazardous materials, and an auditing system to check shipments prepared by contractors, such as hazardous waste profiles, manifests, and labels prepared by waste vendors.
7. Keep up to date by reviewing regulatory changes on a yearly basis (49 CFR effective each Oct. 1, IATA effective each Jan. 1).
8. Maintain records and administrative programs, including annual registration, security planning, training records, past shipping papers, incident reports, and current regulations.
9. Know when and where to ask for help, e.g., Hazmat hotline, consultants.
10. Self-audit on a regular basis, be prepared for a regulatory or corporate audit, and reinforce through training, review and accountability.
Posted on Fri, Nov 20, 2009 @ 06:57 AM
By Patrick Hallinean, Lab Services Coordinator
The electronic industry’s top manufacturers have dedicated many of their resources to develop more environmentally “friendly” products. If you are unfamiliar with the manufacturing of electronics, which most of us are, an alarming level of brominated and chlorinated compounds are used when producing the many different components used in day-to- day gadgets and doo-dads. Take your iPod or DVD player, for instance; they are loaded with brominated flame retardants (BFRs) and polyvinyl chlorides (PVCs). Such companies as Apple, Sony Ericsson, and Seagate, to name a few, have engineered alternate manufacturing practices that have eliminated these harmful chemicals in many of their products. These halogenated compounds can severely affect human health and the environment by leaching into soil and groundwater, when land filled, and into the air by smelting or burning the tons of discarded obsolete “e-waste”. One may ask, “Aren’t we recycling or re-using a majority of this e-waste”…the answer is no; statistics state that only 15-20% of the 2 million tons discarded in 2005 was recycled. That still leaves an enormous amount of “toxic” waste entering our environment.
So in closing, before you go out and purchase the next new fandangled gadget, or dispose of your old doo-dad, do a little research to see if it’s “green” before you do.
Posted on Tue, Nov 17, 2009 @ 10:38 AM
By Kristina Florentino, Environmental Compliance Specialist
Wide arrays of industries use wipes-including rags, shop towels, disposable wipes and paper towels-are used for cleaning, disinfecting and degreasing. These wipes are considered hazardous waste when discarded if the wipes exhibit a hazardous waste characteristic or are contaminated with a listed solvent (RCRA waste codes F001 through F005). Listed waste mixtures are regulated under the Resource Conservation and Recovery Act (RCRA) under the mixture rule, which states that a mixture composed of any amount of a non-hazardous waste and any amount of a listed hazardous waste is considered a listed hazardous waste. Thus, any amount of a listed waste, no matter how minute, when mixed with a large volume of non-hazardous waste, the resulting mixture will carry the same waste code and regulatory status as the initial waste carried. The rule is applicable regardless of the chemical composition and properties of the resulting mixture.
On October 27, 2009, the EPA published a Notice of Data Availability (NODA) in the federal register, 74 FR55163, seeking comments on a revised risk analysis methodology of an earlier proposed rule relating to solvent contaminated wipes. The Proposed revisions relate to RCRA hazardous waste regulations governing the management of solvent contaminated wipes and would exclude these wipes from the definitions of solid and hazardous waste for solvent-contaminated wipes sent to a laundry or dry cleaner and solvent-contaminated wipes sent to a landfill or combustion facility, provided certain conditions are met. If the rule goes final, states with approved RCRA programs would have to adopt the rule into their own hazardous waste regulations before generators could take advantage of this regulatory relief.
The EPA is currently seeking comment on the proposed rule and the risk analysis used. The comment period is through December 28, 2009.
Posted on Tue, Nov 17, 2009 @ 06:39 AM
By Joseph Shupp, Chemist II
The economic slump that the economy is currently in has forced industries, especially smaller scale companies, to evaluate where they are financially and where they need to be to stay in business. Our industry of hazardous waste management and disposal is heavily driven by meeting regulatory standards. One of the many regulations that we all must follow is having the proper training that we need to do our jobs. Not only must we attend training and receive a certificate, but we also must re-certify on a pre-determined time frame. These trainings are rarely located in our backyard and have numerous cost associated with attending the training. Flights, meals, and hotel rooms are an overhead cost that is tough to cover when your company is cutting budgets and evaluating every penny that is spent.
The solution is to bring the desired training topics to your office. Web seminars and web based training modules are becoming an increasing popular item among companies who need to stay up to date with training regiments, but cannot necessarily afford to send all of there employees to external training centers. These web based programs meet all required regulatory aspects. Some of the trainings include videos and interactive modules to utilize a more hands on approach. In some cases the programs are broken up into sections which allow the trainee to work at there own pace. Upon completion of the modules a test will most likely follow. Once the test is passed a certificate can either be printed directly from the web page or an official certificate is mailed to the person testing. After it is all finished the two basic goals where achieved; training requirements are satisfied, and money has been saved.