Posted on Thu, Jul 08, 2010 @ 06:45 AM
by Steve Todisco, Healthcare Account Manager
For those of you who routinely ship waste off-site for hazardous waste disposal you should be familiar with what the term lab pack means. In order to understand what a lab pack is we should quickly outline the different types of ways that most people typically ship waste off of their site for hazardous or non- hazardous waste disposal. There are typically 3 major types of overall ways to ship waste off-site: Bulk, Non-Bulk, and Lab Pack.
Bulk waste shipping is shipping waste in larger containers that exceed 119 gallons of waste and is usually utilized for shipping in tanks, tanker trucks, and totes.
Non – Bulk waste shipping can include the shipment of a 55 gallon drum of liquid such as oil, or solvents. These containers might look and feel like a bulk container and they are often referred to that way but because they fall under the 119 gallon requirement we can call these non-bulks.
This brings us to the term lab pack. Lab packing is a method of shipping smaller inner containers inside a larger outer container. This allows companies like ours to be more efficient when shipping “like” materials. If you had several smaller containers that all were intact and contained within their own primary container than these items could be placed into a drum that is equal or lesser than 55 gallons and “lab packed”. Other things like packing material would also fall under the requirements of being added to this lab pack drum. Don’t forget that there are specific requirements for the amount of packing material required in each specific size drum per D.O.T regulations.
By shipping “like” things together you will be utilizing shipping names in the regulations like Waste flammable liquids n.o.s or (Not otherwise specified). This means that the shipping name that best fits all of the materials involved isn’t a specific single item like Waste Acetone, or Waste Methanol. Instead it could include “like” items such as methanol, acetone, and Isopropanol all in the same outer container.
Remember that “lab packing” falls under specific rules and exceptions so only highly trained individuals should undertake these tasks. Combining bottles of chemicals in the same outer container can be dangerous if not done correctly.
Posted on Fri, Jun 18, 2010 @ 09:21 AM
By Doug Graham, Senior Compliance Advisor & Training Manager
What makes an EHS specialist qualified and competent? Most employees would agree that training is an essential part of becoming a skilled EHS specialist. In the EH&S world, there are many disciplines that require training, such as the shipping of hazardous materials and the management of hazardous waste. The training is required so that employees tasked with those functions are presented with, and provided an explanation of, specific regulatory requirements which they must meet. But the question becomes, is training enough?
When it comes time to put the knowledge acquired during training to use, can the employee perform the task compliantly? Even further, does the employee continue to be competent if considerable time elapses between tasks or is given new and more challenging tasks? If I'm an employer, I need to know- if I don't, I risk penalties, financial, civil or criminal liability, the reputation of my company or institution, even peoples' lives could be at stake.
It's no secret that employers do not always make an effort to determine if employees are qualified and competent to perform EH&S tasks, usually because they don't see the consequences. . . .right away, that is. (We've heard it- "he's got the certificate, he's good to go"). Concern about competency commonly arises only after a shipment is rejected, a regulatory inspection occurs, a citation is issued, an incident occurs, the environment is contaminated, or a person is injured or killed. It may take considerable time and practice to establish proficiency at mastering the minutiae of a set of regulations to be confident that what he/she is doing is accurate and compliant.
Nowhere in the EH&S world is it more crucial for an employer to determine competency after training, than when offering hazardous materials for transport by aircraft. ValuJet Flight 592 which crashed in the Everglades in 1996- an avoidable tragedy caused by the improper loading of hazardous material, is a stark example. The Federal Aviation Administration (FAA), responsible for enforcement, knows this all too well. In the last 6-7 years enforcement has been vigorous. Enforcement actions against employers have resulted from discovery of non-compliant shipments at air terminals, incidents, and what's becoming ever more frequent, from unannounced inspections of employers triggered merely by offering hazardous materials by air. FAA is very concerned with the qualifications and competence of employees tasked with preparing shipments. One FAA inspector recently, during an onsite inspection, required the employer to assess the competency of each hazmat employee and certify that those previously-trained individuals were qualified, even suggesting an additional employer's signature be added to the original training certificate already signed by the instructor.
So, the lesson to be learned here is, employers should look at EH&S tasks carefully, assess the risks associated with non-compliance, and not only train those employees, but follow-up and have another person with the training, knowledge and experience assess their competency through evaluation of actual job duties. . . only then should they be qualified.
Posted on Thu, Jun 17, 2010 @ 09:57 AM
By Sandy Perry, Director of Water Management and Wastewater Services
If you have a wastewater treatment system then you probably (hopefully) have a discharge permit, for which you must have submitted an application to one regulatory agency or another. I’ve found that the section of the application that seems to be the most difficult and takes the most time is where you must list the quantities of wastewater generated from each potential source. This is primarily because few facilities have flow meters on all water use sources.
Ideally, you want to be able to account for the entire volume of water used in a twelve month period. Identifying and quantifying all water uses and the outputs of this water to match the incoming water is typically a challenge. Why? Because it is difficult at best to estimate the amounts evaporated, the boiler blow down quantity, lab sink contributions, or discharges from scrubbers, production operations where some of the water may be consumed in the product or wastes collected for offsite disposal, non-contact cooling (which is clean water and should not go to sewer discharge), RODI reject water, etc.
The best plan is to gather together key people from Facilities, Production, Research, and EH&S to assist in identifying all of the inputs. Piping diagrams are great, but I’ve found that few are kept up to date with piping changes made over the years. Use a white board to begin creating a water mass balance flow diagram and label each box with each water use activity and all of the outputs from each water use source. So for instance, if you have incoming water to your steam boilers, there should be at least two arrows from that box labeled as outputs – evaporation and boiler blow down.
Comparing the total water consumed to the either estimated or metered outputs, you may find that it doesn’t add up. Then you need to review your estimates – what are you missing? What have you double counted? Are your flow meters calibrated? How reliable are they? You may determine the need for additional meters and daily or weekly water use logs. Most regulatory agencies think this is a pretty important aspect of your permit so it’s a good idea to work towards a no more than 1-5% differential between incoming and outgoing water sources. Good luck!
Posted on Tue, Jun 08, 2010 @ 01:58 PM
By, Ashley Cole, Chemist II
Looking for a simple rubric to assist you in determining your status as a generator of hazardous waste?
Just remember this number.
2.2
VSQG's
If you generate less than 220 pounds of D, U, F or K listed Hazardous Waste in a one month period and NO P-listed materials, then you are a Very Small Quantity (VSQG). If this is the case, the legal requirements you must adhere to are the easiest to comply with.
VSQG's do not have a time limit for storage of waste materials, do not need an EPA ID#, and do not need to keep manifest records. VSQG's must still identify and dispose of Hazardous waste in a State Permitted Hazardous Waste or solid waste disposal facility.
SQG's
If you generate more than 220 but less than 2200 pounds of D, U, F or K listed Hazardous Waste and no more than 2.2 pounds of P-listed materials in a one month period, then you are a Small Quantity Generator (SQG). Remember, no more than 2.2 pounds or acutely hazardous waste can be generated and stored in both the SAA's and the MAA. Requirements for SQG's are more stringent than VSQG's but significantly less than for LQG's.
SQG's must identify and properly label Hazardous Waste, store it in the MAA for no more than 180 days, obtain an EPA ID#, utilize manifests for shipping hazardous waste and maintain records for at least three years.
LQG's
If you generate greater than 2200 pounds of D, U, F or K listed Hazardous Waste and more than 2.2 pounds of P-listed materials in a one month period, then you are a Large Quantity Generator (LQG). If this is the case, you must comply with the most stringent code of conduct.
LQG's may store materials in the MAA for no more than 90 days, have an established employee training program, have a formalized written contingency plan for emergencies and spills, submit biennial reports to EPA as well as comply with SQG requirements above.
It is up to each generator to properly assess and track their status. Practicing waste minimization in the laboratory and including your EH + S team in the purchasing process, are both great ways to reduce the potential of accidentally knocking yourself up the 2.2 ladder.
*Please remember that this is a partial list of requirements and that each State Department of Environmental Protection has a greater than or equal to clause when it comes to complying with 40 CFR 261. Check with your local government for further regulatory information.
Posted on Fri, May 21, 2010 @ 01:00 AM
By Courtney Drayer, Technical Services Representative
Keeping track of manifest return copies can be a hassle especially if you ship waste frequently. If you have not received a signed return copy of your manifest by 35 days from the time of shipment (per 40 CFR part 262.42), it is time to call your friendly TSR to request it. You can track when it is time to call your TSR by using the following four column spreadsheet:
The magic happens in the status column. Logically, what we want to know is "IF the manifest is older than 35 days AND I have not received a return copy THEN I should call my Technical Services Representative to ask for it." You also want to know that "IF the manifest is older than 35 days AND I have received a return copy THEN I am in compliance." And finally you'll want to know "IF the manifest is younger than 35 days AND I have received my return copy or I have not received my return copy THEN I am in compliance". We can say all that in excel using the following formula in column D;
=IF(AND((TODAY()-B2>35), C2="N"), "Call your TSR", "Compliant")
Now all you have to do is enter your manifest #, the shipment date, and whether or not you have your return copy and the spreadsheet will tell you the rest! Since we have used the "TODAY()" function in the formula, the spreadsheet will automatically update every time you open the file so you don't need to keep track of the dates anymore!
If all this still sounds like more data entry than you have time for, you can use Triumvirate's ADVISE software to track manifest compliance.
Your manifests will automatically appear in
ADVISE with red, yellow and green dots showing you the compliance status of each one. You can also scan in and upload your manifest copies (generator’s copy and returned copy) and save them in the program.
ADVISE can be accessed from anywhere you have an internet connection.
So, if an inspector shows up for a paperwork review at one of your sites, you can show them all of your manifests from all of your sites from the comfort of your desk!
Now that’s easy.
Posted on Tue, May 04, 2010 @ 08:31 AM
By Greg Rosinski, Chemist II
It is not an every day occurrence where flood waters close down a Publicly Owned Treatment Works (POTW); however, it is possible. In order to be ready for such an event safety plans should be established to help alleviate some of stress associated with this type of emergency. The goal of this plan should involve working with a disposal company that can provide the proper amount of tanker trucks to maintain levels of waste water discharge as to not slow down a facilities production. A list of aspects the plan should consist of, but not limited to include the following:
- Proper waste water analysis to help obtain facility approval
- Volume of Waste Water needing to be disposed of per day
- Method of transfer to trucks
- Proper equipment for process including
- Secondary containment for tanker truck
- Spill Kits
- Device to aid in raising transfer hoses to the tanker truck
- Lighting if project should occur during the night
- Proper personal protection gear
- How to staff the project, and the length of time each it will require staffing.
- Organizational plan for truck staging
- A estimate of the total cost for budgeting purposes
Preparing for an event like this allows a facility to limit the different situations that could slow down or stop the manufacturing of their product. It also helps the local community focus on re-establishing order that was lost due to flooding.
Posted on Mon, Mar 29, 2010 @ 03:15 PM
By Greg Rosinski, Chemist II
A vast majority of society has made a committed move towards "Green Existence". Helpful tips to remember or that should be posted in offices or homes to help save energy and emissions are the following:
- Make sure to turn off your computer at the end of a work day. This helps to reduce energy consumption, save money, decreases the effects on global warming, and move towards personal stewardship of natural resources used to keep a computer on.
- A laboratory containing a Variable Air Volume (VAV) Fume hood should instruct lab personnel to make sure they completely shut the fume at the end of each use. Leaving a VAV fume hood open causes the air exhausted into the fume hood to leave the fume hood increasing the amount of energy used, money wasted, and impact on natural resources. Closing just one VAV fume hood in a laboratory after every use over the course of a year results in an energy saving approximately the same as the energy used by 3 houses in a year.
- Laboratory personnel should move towards using washable containers for lab use. Even though most plastic equipment is recyclable it still creates wasted energy to recycle the material. To help preserve the natural resources used in recycling simply use glass beakers, measuring devices, and other lab equipment. This applies to eating meals at work as well. Bring in containers from home that can be washed or use washable dishware from the cafeteria.
- Try to remember the impact of wasted water, electricity, or gas on the environment when working in laboratory. The earth is already experiencing shortages in the majority of natural resources, and most of our time in life is spent at work. That is why we must make a committed decision to decreasing unused natural resources on a daily basis.
All though there are other areas to help move towards a "Green Existence" the above topics are several helpful tips. These tips should be post in work places or circulated throughout the workplace to increase general awareness.
Posted on Mon, Mar 29, 2010 @ 11:54 AM
By Doug Graham, CHMM Sr. Compliance Advisor & Training Manager
The U.S. Department of Transportation (DOT) is modifying current security plan requirements applicable to shippers and carriers of hazardous material.
Based on an evaluation of the security threats associated with specific types and quantities of hazardous materials, the final rule narrows the list of materials subject to security plan requirements. The final rule also clarifies certain requirements related to security plan components, training, and documentation.
In a qualitative risk evaluation, DOT considered the following factors when deciding how the new security planning requirements would better address actual terrorism threats: (1) Physical and chemical properties of the material or class of materials and how those properties could contribute to a security incident; (2) quantities shipped and mode of transport; (3) past terrorist use; (4) potential use; and (5) availability.
In this "new look" at which materials pose significant risk, DOT explained that , "One of the most significant security vulnerabilities involves the potential for an individual or group to take control of a conveyance containing a high-risk material and move it to a site where the material could cause maximum physical or psychological damage. For some hazardous materials, the primary security threat involves theft or highjacking of raw materials for use in developing explosive devices or weapons".
So, based upon this fresh analysis and the need for clarification to the original rule, the following is a summary of the regulatory changes to the security planning rule that are slated to go into effect on October 1 of 2010:
- Firstly, the list of materials being either offered or transported, which would trigger the requirement for developing a security plan has changed. The list, found in 49 CFR 172.800(b) currently identifies seven categories, including placardable quantities. The new list identifies sixteen very specific categories of hazardous materials, most of which have threshold quantities.
- Secondly, the required components of a written security plan under 49 CFR 172.802 have been clarified and expanded. Hi-lights include:
- clarification that the plan must address risks associated only to those materials identified in 172.800(b);
- there must be a senior management official identified who is responsible for development and implementation of the plan;
- the plan must identify security duties for each position or department responsible for implementing all or part of the plan;
- the plan must describe the process for notifying employees when plan elements are to be implemented; and
- the plan must be in writing, retained (paper or electronic), available to employees responsible for implementing it, updated as necessary, reviewed annually, and made available to the DOT for inspection, upon request.
- And lastly, the security training requirements under 172.704 have been clarified.
In summary, it is anticipated that many employers who currently require security plans solely due to offering placardable quantities of common hazardous material will no longer need them. Additionally, those who will still require security plans under the new rule will need to make major revisions to their plans, procedures, and recordkeeping.
To see the complete revised rule change as published in the March 9, 2010 Federal Register, go to: http://edocket.access.gpo.gov/2010/2010-4778.htm
Posted on Tue, Mar 23, 2010 @ 06:36 AM
The importance of proper sample collection.
By Sandy Perry, Director of Water Management and Wastewater Services
Whether you discharge to the sewer or directly to a water body, the importance of collecting truly representative samples of your treated wastewater cannot be overstated. So what does "representative" mean? It means that:
- your wastewater treatment system is operating properly,
- you've selected a day to sample that is typical of your daily operations,
- your composite sampling equipment is set up to take flow proportioned samples properly,
- your flow meter is sized appropriately for your flow rates and is calibrated at least annually, and finally,
- the sampling equipment and collection containers are clean!!
To my last point, the last thing you want is a cross-contaminated sample. If you think about it, there are actually quite a few opportunities for contamination. And with metals limits in parts per billion, it doesn't take much to tip the lab results over the limit.
Dischargers should check with their sampling contractor regarding their procedures to prevent sample contamination. Do they change the pump tubing or just rinse it out between yours and another client's sampling? Do they acid wash and rinse the collection container? And how does he or she appear when they are onsite to setup and collect the samples - is their appearance neat and clothing clean? Even dirty hands and dust/dirt on clothing can be a potential source of contamination.
Did you know that in some areas of the country, dischargers are subject to limits in parts per trillion (Maine and the Great Lake areas' mercury limits are in ug/L) and must perform "clean sampling"? The U.S. EPA's Clean Sampling guidance includes using non-metal sampling equipment, and wearing tyvek suits and gloves, and even warns against breathing near the sample (ex. mercury in dental fillings).
You might also check with your contractor to find out if they perform periodic equipment or field blanks as part of their Quality Control program? Do they have a Quality Control Program? Non-compliance is not a pleasant situation to be in and can lead to enforcement actions including fines and penalties. Don't take a chance, make sure that your samples are being collected properly to ensure that your data is "representative" of your discharge.
Posted on Thu, Mar 18, 2010 @ 01:50 PM
By Sandy Perry, Director of Water Management and Wastewater ServicesHow do companies in Massachusetts know which regulations apply to their wastewater sewer discharge? It's interesting how much separation there is between a local authority, such as the Massachusetts Water Resource Authority, and the state authority, the MassDEP. Unfortunately the lack of outreach by either entity typically results in something being missed with respect to compliance.
In fact, no matter which sewer authority a facility in Massachusetts discharges to, wastewater treatment system plans and descriptions must be submitted to the MassDEP along with a staffing plan. Also, facilities are required to have an Operations & Maintenance Manual specific to their system. And depending on the volume discharged, you may need a MassDEP permit as well.
On the other hand, the MWRA (and most local authorities) are most concerned about the characteristics of the wastewater being discharged. They care only that it meets compliance with the sewer use ordinance, local limits, and/or specific permit limits. That is because they have a biological treatment system to protect and their own discharge limits to meet. In most instances you will be required to apply for a discharge permit. However, some of the smaller communities and sewer authorities may not require a permit if your discharge volume is low or you have no chemicals of concern in use.
So my best advice is to do your due diligence before starting up or relocating. Companies need to look into their regulatory obligations prior to moving and understand just what is required. And those already in operation, to be on the safe side, check to make sure that you have made the proper submittals to the MassDEP and/or local sewer authority. (A final word of caution - don't assume that the contractor that installed your treatment system took care of this for you.)