Posted on Wed, Jul 14, 2010 @ 08:01 AM
Written By Matt Bauer, Marketing Intern
The EPA recently added over 3,500 chemical facilities and 6,000 chemicals of the Toxic Substances Control Act (TSCA) to their public internet database rightly named, Envirofacts. The TSCA rule was originally mandated in 1976 in order to give the EPA authority over industrial firms to require reporting and record keeping of certain hazardous chemicals. Now, the EPA is focused on helping the general public to better understand this regulation and how it affects their surrounding environment. Envirofacts is aimed to allow users to access information about the Environmental, Health & Safety hazards which may affect the air, water and land, from a single source. This reference tool collects information from state and federal forms that are mandated by the TSCA rule, and compiles them in an easy to use database. Information includes, the facility name, location, granted permits, as well as tools to analyze the data.
The site is further broken down into the following categories for simplified searches: Air Permits/Releases, Water Permits/Releases, Land Use, Waste Management, Toxics (Reports and Hazards,) Radiation, Facilities Information, Compliance History, Mapping, and Brownfield Development. The EPA intends to continue adding more information in the coming months.
Posted on Mon, Jun 28, 2010 @ 09:41 AM
By Meagan Collins, Environmental Compliance Specialist
As security and safety measures rise, it is very likely that local, state, and federal organizations will be stricter about enforcing environmental regulations and policies. Organizations of particular interest include the EPA, OSHA, and local fire departments.
When an audit or inspection is performed, it is extremely helpful to have a current inventory of chemicals available. Pertinent information about each chemical onsite should include location, quantity, CAS number, and hazard class where applicable. Having an accurate chemical inventory is important for safety and regulatory compliance, including reporting hazardous chemicals in Tier I and Tier II forms mentioned in 40 CFR. This issue is of high importance to Environmental Health and Safety (EH&S) departments of higher education institutions.
ChemTracker is a web-based chemical inventory database hosted by Stanford University, started in the mid-1980s. After Stanford experienced success with the system, other higher education institutions expressed an interest in accessing the program. Both EH&S departments as well as individual labs find ChemTracker helpful with maintaining chemical stocks and in meeting compliance standards. Higher education institutions that use ChemTracker include MIT, Cornell, and the CUNY system.
The integrity of information in ChemTracker is the result of years of research as well as trial and error by Stanford University. Inventory in ChemTracker is linked to the ChemTracker Reference Database, also maintained by Stanford University. The ChemTracker Reference Database contains over 11,000 unique chemicals as well as 49,000 chemical synonyms.
The process begins when a lab’s chemical inventory is entered in ChemTracker. From there, it is easy to change, modify, and delete stock. Inventory is linked to a “chemical owner” who can make changes, and modify stock for purchasing purposes. Likewise, lab managers and EH&S find that links for MSDS information and hazard classes to be very useful. Reports can be run using parameters such as chemical owner, room, or department to get a summary report by hazard class. Once the initial inventory is set up, maintaining an accurate chemical inventory database is as easy as clicking a mouse.
Sources:
- Gibbs, L.M. “ChemTracker Consortium – The higher education collaboration for chemical inventory management and regulatory reporting”. Chemical Health and Safety. Volume 12, Issue 5, September-October 2005, pages 9-14.
- http://med.stanford.edu/somsafety/messageboard/archives/chemical_inventory_updates/index.html, Accessed June 2, 2010.
- http://www.epa.gov/oem/content/epcra/index.htm, Accessed June 10, 2010.
Posted on Fri, May 21, 2010 @ 01:32 PM
By Dave Williamson, Higher Education Account Manager
If the new Academic Lab Rule known as Subpart K is effective in your state and your institution is an eligible academic entity with laboratories, then you have the choice of opting into Subpart K. If you decide to opt in, your laboratory hazardous waste will fall under a new set of regulations. Before opting in make sure you have support from your institution's administration.
Many institutions have a couple EPA ID numbers for different parts of the campus. Under Subpart K each separate EPA ID has the option to opt in. It would make the job for the EH&S staff challenging to operate under different regulations for each EPA ID number, but it can be done.
A Lab Management Plan is required for institutions that adopt the academic lab. You must develop this in two parts. The first part is where you select options available to you under the rule. The second part is where you develop your own site specific best management practices for managing your laboratory hazardous waste in accordance with Subpart K.
One of the main benefits for opting in is the chance to reduce your generator status. Subpart K allows one lab clean out per year which does not count against your generator status. However, the waste still has to be reported.
Posted on Thu, Apr 29, 2010 @ 09:58 AM
By Greg Rosinski, Chemist II
In a society saturated with ideas of waste minimization, it is important to take a moment to reflect on what is best for the environment and those around us. Chemicals are being depleted at a rate faster than can be manufactured. An example of this seen throughout manufacturing industries is Acetonitrile. A major reason for the shortage is the relatively low boiling point, and its use ubiquitous properties in solutions. An extreme shortage of this particular chemical started in 2008 when the Chinese government decided to shut down one of the biggest manufacturers of this chemical during the Olympics in Beijing.
To help save the supplies of chemicals, it is necessary to find alternatives to disposal that are better for the environment and anyone involved with the process. A good place to start is to determine if the chemical needing disposal has reached its expiration date. Manufacturers of chemicals, like the food industry, place an expiration use date on each bottle of chemical designating when the chemical no longer will perform as intended. If a site has chemicals ready for disposal due to site mandated expiration dates than a program should be instituted to find a way to reuse the chemicals or donate them to a site in need of those chemicals. Chemical reuse between laboratories helps to use as much of the chemical as was purchased, and will help to reduce disposal fees. By emptying a bottle of chemicals the bottle can be triple rinsed, and then recycled saving on disposal costs.
It is important to make sure that there is an environmental specialist involved with this process so that chemicals that are harmful to the person or environment are properly handled. It also ensures safety and compliance is up held in recycling containers.
Posted on Tue, Mar 16, 2010 @ 12:24 PM
By Lawrence Hren, Onsite Support Services Coordinator
In my recent experience with EPA inspections focused toward laboratory and hazardous waste management, it has become apparent that preparation for a surprise inspection is every bit as important as properly responding to an inspection. While this is by no means an all-inclusive guide to successfully handling an EPA inspection, the following should serve as an outline of key points to consider prior to and during an inspection:
- Is your emergency contact information accurate and up to date?
- This may be one of the first things an inspector delves into upon arrival at your facility. Additionally, it is important to test your primary and secondary methods of acquiring an MSDS in the event of an emergency. For example: if you have identified that MSDS's will be obtained via the internet in the event of an emergency, you should also be sure that you are familiar with an alternative method such as calling an emergency MSDS hotline and that an MSDS can be faxed to your facility on short order.
- Is your Main Accumulation Area (MAA) well maintained, in compliance, and is your weekly MAA inspection log complete and up to date?
- Proper MAA maintenance is intrinsically linked to running a top notch Haz-Waste management program at your facility. Deficiencies during this portion of an EPA inspection will most likely lead to a higher level of scrutiny during the remainder of the inspection. Be sure that you are completely in compliance with MAA regulations and that the space is as clean and organized as possible. Don't forget to make sure all emergency contact info is conspicuously posted and a phone is located inside of or very close by the MAA
- Weekly MAA inspection logs are to be kept on file for 3 years. It is crucial that there are no gaps in the records. Be sure to take into account long weekends and holiday schedules. If you can present a simple SOP geared towards accommodating for such circumstances, all the better!
- How well are your laboratories maintained? Are training records kept on file and readily available?
- Once inside the lab, an inspector will most likely ‘interview' lab staff. Questions will focus on waste management, safety procedures, and chemical compatibility issues in your chemical storage cabinets.
- RCRA is all about records. Be sure that all laboratory training records and lab SOPs are available.
- Out of date, unusable, or excessive amounts of chemicals should not be stored in the lab. Chemical storage/labeling issues raise a red flag, and are viewed as an indicator of poor lab practices
The main thing to keep in mind during an inspection is to remain calm and answer all questions honestly and to the best of your ability. Never try to down-play compliance issues as a means to dissuade the inspector from looking into them. Dedication to running an exemplary program goes a long way.
Posted on Mon, Mar 15, 2010 @ 06:32 AM
By Dave Williamson, Account Manager
So your college or university always has that one yearly lab pack to clean up your science classrooms right? Pretty typical in the higher education world for mid to small size programs. Do you recall how much the total weight of the last hazardous waste shipment was? According to COMAR 26.13.02.05, no more than 220 pounds of hazardous waste or 2.2 pounds of acute hazardous waste is permitted to be accumulated on-site at one time for small quantity generators. This goes for the entire campus, not just the labs in the science buildings. If your institution falls under this deadline then congratulations you are a small quantity generator.
For those that are over the weight limit, you are a large quantity generator. With this status comes some more chores for the EH&S department. The Maryland Department of Environment insists that all Large Quantity Generators have a contingency plan, inspection records, training records and must complete a bi-annual report every two years. Also, large quantity generator must ship every 90 days (or 180 days if special conditions are met.)
Posted on Mon, Dec 14, 2009 @ 06:29 AM
By Jason Atwood, Field Service Manager
In recent months, public scrutiny surrounding the presence of PCBs in materials commonly used in public school building construction prior to 1978 has been mounting. Media coverage and an onslaught of resulting attention have forced this issue to the forefront of public health and safety concerns pertaining to our environment. Typically - this focus has been aimed at the presence of the contaminated caulking itself: in window glazing/caulking, interior and exterior joint compounds, in Univent construction, paints, etc.
While building inspections and intensive sampling plans will certainly illustrate the cause of concern (I.E. The presence of PCB contaminated material is the crux of the issue), the true effect may not become evident without a stringentair monitoring / sampling plan. PCBs do not become an immediate hazard until they are ingested into the human body, be it through consumption, absorption or inhalation.
The latter may be the issue of greatest concern in the context of classroom hazards. PCBs have the ability to volatilize - that is tiny particles of the material can vaporize from the solid state and become airborne, a process that is expedited with the presence of heat. Window caulking and glazing subject to extended exposure to the sun, PCB ballast material that may leak inside of fluorescent lighting and PCB containing material within or immediately around HVAC systems all pose a significant risk for volatilization. Once airborne, PCB particles mix with other sources of airborne dust and can be directly inhaled, or can deposit on horizontal surfaces and then be ingested or absorbed.
To ensure your school department engages in a robust and encompassing risk assessment plan, it is imperative that they focus not only on potentially impacted materials, but also on the byproducts of those materials in the form of airborne PCB concentrations and associated surface dusts. The EPA has established guidelines for acceptable PCB concentrations for both of these medias, taking into account all potential sources of human ingestions of PCBs and how those risks align with the risks outlined herein. These guidelines can be found here.
As with all environmental concerns, effective assessment is essential in the development of a risk management plan. PCBs in building materials, air, dusts, and soil are all manageable risks that can mitigated through effective remediation efforts. As public scrutiny surrounding this issue has intensified, so also has our ability in the environmental services industry to protect families from future exposure and the resulting detrimental health effects.
Posted on Thu, Dec 10, 2009 @ 11:07 AM
By Kristina Florentino, Environmental Compliance Specialist
An emerging environmental health issue is information published by the Environmental Protection Agency (US EPA) that caulk containing polychlorinated biphenyls (PCB) was used in many nonresidential buildings, including schools, throughout the 1950s through the 1970s. PCBs are man-made toxic chemicals that persist in the environment and bioaccumulate in animals and humans. Exposure to PCBs can affect the immune system, reproductive system, nervous system, and endocrine system and is potentially cancer-causing. Caulk is used in construction to seal gaps to make windows, door frames, masonry and joints in buildings watertight or airtight. Before the prohibition of PCBs in all U.S.-manufactured products in 1977, caulk was prepared with PCBs due to the flexibility and other valuable properties of the compound such as persistence and low reactivity. Buildings that were constructed or renovated during this period could contain caulking with elevated levels of these hazardous compounds.
Until recently, testing was seldom conducted for PCB levels and there have been few studies to determine the environmental exposures to building occupants, remediation or construction workers, or related environmental contamination. The material will evidently deteriorate and leach PCBs into nearby soil, concrete pads, bricks, mortar, storm drains and potentially volatilize. Studies have shown a correlation between PCBs in caulking and elevated levels of PCBs in indoor air and dust, in addition to ambient soil surrounding the buildings. The deteriorating caulk has the highest potential for creating dust exposing occupants via inhalation. In addition to inhalation from PCBs in the air or dust, dermal exposure may occur when a person comes in contact with the caulk, surrounding porous materials, or PCB-contaminated soil adjacent to buildings.
The US EPA recommends indoor air monitoring to determine if PCB levels exceed the suggested public health levels. If testing reveals PCB levels above these levels, the potential sources of PCBs need to be identified. Typically testing of samples of caulk, dust, and soil is performed. If elevated air levels of PCBs are found, it is also recommended that the ventilation system be evaluated to determine if it is contaminated with PCBs, since it may have been contaminated before other sources of PCBs were removed from the building and may be contributing to elevated air levels. Contaminated ventilation systems need to be decontaminated along with removal of any sources of PCBs that are found to avoid recontamination of the system.
EPA is currently researching PCB exposure related to contaminated caulk and looking into methods for mitigating exposure and potential risks associated with PCBs in caulk. In addition to the risk posed by PCBs caulk can also contain as much as 20 percent asbestos, requiring additional management during sampling and disposal.
Resources: MA DEP PCB Q&A, US EPA, Target Indoor Air Levels published by the EPA
Herrick, R. F., Lefkowitz, D. J., & Weymouth, G. A. (2007). Soil Contamination from PCB-Containing Buildings. Environmental Health Perspectives , 115 (2), 173-175.
Look for future consulting blogs about environmental health and safety, and industrial hygiene topics including mercury, lead and heavy metals. Please contact Triumvirate’s consulting group for more information. We have Environmental Engineers and Consultants ready to answer your questions.
More PCB Remediation Blogs!
Posted on Wed, Dec 02, 2009 @ 10:18 AM
By Steve Todisco, Senior 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 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.
If you have any questions, please feel free to contact us here at Triumvirate.
Posted on Wed, Nov 11, 2009 @ 10:14 AM
By Kevin Poulin, Account Manager
Developing a waste minimization program can be difficult to maintain without a strong strategic plan to guide the process. I have spent countless meetings generating several plausible ideas, but without a specific course of action to follow, it was hard to achieve success. Through my experiences I have learned valuable lessons in the art of developing the tools and systems that are needed to build and maintain a waste minimization program that generates real results and cost savings year after year.
My colleagues and I have come up with four key components to follow in order to create and maintain a successful program.
1. Know your waste
2. Lab/Facility Assessment
3. Prioritize
4. Budget/Implementation
The first step, know your waste, refers to getting to know your program inside and out. Ask the who, where, when, what, how, and why questions. Some examples of these questions are…
– Who generates waste on campus?
– Where the waste is stored (i.e. SAA/90-Day Storage Area)?
– When are waste determinations made?
– What waste streams are collected?
– How is it collected and processed on campus?
– How many labor hours does it take to complete these activities?
– Why are certain wastes collected and not put in the drain or trash can?
Once you obtain this information create a flow chart to see the bird’s eyes view of how your waste was collected, transported, packaged, and disposed.
The biggest problem with waste minimization is the planning and organization of usable data and metrics so managers can effectively delegate. Instead of just tossing around ideas, take a more systematic approach by answering the following questions; What opportunities exist?, What is the total expected campus savings?, Which opportunities have highest ROI?, What is the feasibility of implementing these opportunities? These questions will help you assess the lab or facility generating the waste for the likelihood of implementing and maintaining the new process or behavior.
Next it is crucial to start prioritizing. This will allow you to take all the data and questions you answered and see if the program will work. To do this first determine how much of an impact it will have. Make sure to keep in mind the capabilities of your lab/facility, the likelihood of this being implemented, and the impact of the goal overall. Be sure to look at the operational impacts, the EHS compliance impacts, the cost/feasibility to reduce these impacts.
Finally, it is vital to examine your budget before you start to implement the program. Some changes may require some capital money, but if the ROI is there, obtaining money will be easier.
To do this, work with Departmental Purchasing groups, use return on investment models, the costs to implement don’t necessarily have to come from EH&S if another department is going to reap the benefit.
It may be easiest for you to start by focusing your energy on your department, to obtain easy successes, and implement behavioral changes. Then you can target the next opportunity with the biggest ROI and share your recent successes. Taking the time to do these steps will help to create a waste minimization program that produces real results and cost savings for years to come.