By Amanda Mendonza, Technical Services Representative
So you finally got your RCRA and DOT training and you’re ready to start shipping waste. You learned about appropriate container labeling and how to properly fill out your uniform hazardous waste manifest. One important part of your training should have been making sure your chemical waste is contained in a “specification” packaging for the material you are shipping. If you are shipping a DOT-regulated hazardous material, then your drum will have to be “UN-specification” (that’s UN as in United Nations). This means that the drum has been tested to international standards of integrity, such as drop and pressure testing. You can check whether your drum is UN-specification by the UN test marking located on the side or top of the drum. It will have a series of codes in the following configuration:
1H1/Y1.8/150/05/USA/M824 /1.1 mm
Here is how you decode the series:
1H1: Is a packaging identification code designating the container type, material of construction, and in some cases, a characteristic. In this case the notation is saying this is a closed top plastic drum.
Y: Indicates which of the three performance standards has been met which tells the filler which packing group materials (PG I, II, or III) are allowed. X = OK for PG I, II, or III, Y= OK for PG II or III, Z = PG III only
1.8: Designates the maximum specific gravity of the liquid chemical suitable for this drum. In this case, the notation is saying this drum is able to withstand the weight of a liquid with a density up to 1.8 g/cm3. Non- leak proof containers will have a maximum gross mass in kilograms at this spot in the marking.
150: Is the hydrostatic pressure test in kPa. Non-leak proof containers will have an “S” at this spot in the marking. Shippers must select materials with vapor pressures that are not too high- the pressure test marking is used as part of that calculation (see 49 CFR 173.24a(b)(4) for how to calculate).
05: 2005 Production year
USA: Manufactured in the U.S.
M824: This spot is used to indicate, either by name and address, or by the use of a symbol, what party performed the UN- protocol testing.
1.1 mm: On many drums, the minimum thickness of the material of construction is indicated in millimeters (this is required in some cases for the container to be eligible for reuse).
On reconditioned drums, you may also see an abbreviated version of the full series, such as: 1H2/Y25/S
And remember, all UN-specification drums come with a set of closure instructions by the manufacturer to which you much precisely follow and retain a copy of for a period of 1 year after a package is offered for transport.
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.
By Bob Shuman, National Healthcare Director
Many hospital organizations today are struggling internally with the dilemma of meeting the regulatory standards for the management, collection and disposal of pharmaceutical waste. This predicament is further complicated with both the uncertainty of the direction E.P.A. is headed with its adoption of its proposed universal waste rule, as well as the harsh reality that many pharmaceuticals developed post-RCRA are far more dangerous to human beings, wildlife and the environment than those currently regulated (and enforced).
Given the latter issue related to those post-RCRA pharmaceuticals, the conundrum arises as to "how much" of the pharmaceutical band-width a hospital should be prepared to collect to achieve both compliance with applicable regulations, and, to also adopt the "socially responsible" position that promotes the preservation of our waterways and drinking water.
To be sure, hospitals are faced with the quandary of where they each feel they should place themselves along the pharmaceutical collection continuum. This decision is not a simple one; it brings to bear questions related to cost, training, time and resource allocation, to name just a few considerations.
In the end, there is no "one" best solution; however, each hospital must take the plunge into the water soon, no matter how cold it may be, at first.