Posted on Mon, Dec 14, 2009 @ 06:29 AM
By Jason Atwood, Field Service Manager
In
recent months, public scrutiny surrounding the presence of PCB's 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 stringent
air 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.
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.
Posted on Fri, Oct 23, 2009 @ 07:06 AM
Bret Skinner, Technical Specialist
In this day and age, there are many regulatory agencies that demand the proper labeling of commercially available chemicals and their containers. In particular, the OSHA HAZCOM standard requires that hazardous chemicals be marked with the chemical names and also a universal method to communicate the hazards involved with such a chemical. This communication is usually achieved with symbols or a universal scale such as the Hazardous Materials Identification System (HMIS), or the NFPA 704 diamond which uses a scale of 1-4 to communicate the severity of a chemical’s health hazards, flammability and reactivity. However, what labeling requirements are there for solutions prepared or repacked in secondary containers by laboratory personnel?
OSHA HAZCOM has no specific standard for the labeling of secondary containers, however many letters of interpretation have stated that these containers have the same labeling requirements as commercial chemical containers. What does this mean? The common laboratory practices of labeling prepared chemical solutions with lab tape or marker may only comply with HAZCOM if it accomplishes the demands of the standard in that: the labeling identifies the chemicals in the container, and that the labeling effectively communicates the hazards of the chemical. Common chemical abbreviations seen every day in the laboratory setting such as “NaOH” or “HCl” may not comply with the standard. Although these abbreviations communicate both the chemical and its hazards to trained laboratory personnel, would custodial staff or a firefighter necessarily know what these items were? Also, would custodial personnel know how to initiate a proper response to an emergency involving these chemicals? If the answer is not “Absolutely” then one has not met their HAZCOM requirements.
So what can be done? It is often not practical to get every person in every lab to properly label every chemical container every time. Therefore EH&S departments must help develop systems that will aid laboratory personnel to accomplish the HAZCOM standards as easily as possible so that they may continue to do their job: research.
Some easy solutions to aid with proper labeling of secondary chemical containers:
• Purchase commercially available secondary containers that meet the OHSA standard (see attached photo).
• Work with personnel in order to learn what chemical preparations are in use in their laboratory. Make a list, and create preprinted labels that meet the standard and are easy to use. One could even create a database of the labels and attach it to a website for easy access.
• Ask your chemical manufacturers for extra labels that meet the standards and apply them to secondary containers.
• Training, training, training! Usually, everyone is willing to help with these safety issues. Giving personnel correct knowledge of the standards can make these very intelligent people into valuable safety tools.
NFPA 704 diamond for Sodium Hydroxide (NaOH)
Wash Bottles with NFPA Diamonds.
Posted on Wed, Oct 07, 2009 @ 10:01 AM
By Ian Lanza, Life Sciences Operations Coordinator
The Institute of Hazardous Material Managers (IHMM) CHMM and CHMP certification has received international accreditation from the American National Standards Institute (ANSI) under ANSI/ISO/IEC 17024, the international standard for personnel certification programs. This accreditation is a huge step for the IHMM. It recognizes the skills and abilities of professionals holding IHMM certifications. IHMM certified professionals have the skills and abilities to implement policies, practices, procedures for the management of hazardous materials to protect humans and the environmental from the potential dangers and risks of hazardous materials.
Posted on Mon, Oct 05, 2009 @ 10:09 AM
By Gregory Rosinski, Chemist II
Unlike other industries where there is a relatively fixed staff dealing with chemicals universities/colleges have a continuous turnover rate of students and teacher assistants dealing with the chemicals onsite. The problem is that it places a huge burden of training and retraining students so that everyone is on the same page. A good checklist for laboratory supervisor’s and staff at these institutions to consider when training is to keep it simple to allow for easier remembrance. Below is a quick check list to help prepare students in case of a spill:
• Who is the emergency contact
• What number to call if the event of a spill
• What spilled, the size, location, anyone injured
• Know the…
-Location of the Material and Data Safety Sheet (MSDS) and how to use it.
-Location of spill supplies and how to use them.
• Decide if the amount is more than allowed to be personally cleaned up according to University policy
• When in doubt, call for help!
• If involved with a spill learn from what went wrong, and what went right.
To help reduce spills in Universities:
• Make sure containers are properly secured
• Segregate incompatible chemicals
• Keep track of unused chemicals for proper disposal
• Maintain a complete awareness of the surroundings
• Keep chemicals in secondary containment whenever possible
Posted on Thu, Oct 01, 2009 @ 06:21 AM
By Gregory Rosinski, Chemist II
It is understood by most that maintaining hazardous waste helps to eliminate immediate or long term exposure to harmful chemicals. However, the confusion comes into play with whether it is our responsibility at home to help manage these wastes or turn a blind eye while throwing them into the trash. As of right now it is difficult for anyone to truly manage household hazardous waste. This is where it is up to personal ownership to take control. It is often hard with the economy in tougher times to go the extra mile, and not throw all trash together. It is still necessary to help reduce the exposure of unused waste by disposing of it properly. When buying chemicals for use in the home it is important to consider source reduction. A short list of waste reduction is below:
• Using substitute products with less potential hazardous components
• Buying small quantities
• Using products up before purchasing new products
• Checking for products that can be disposed of at home
The most common Household Hazardous Waste chemicals are:
o Oil-based paint
o Mercury containing devices (thermometers, thermostats, fluorescent bulbs)
o Fertilizer and Pool Chemicals
o Automotive Fluids
State officials have made disposal easier for households by setting up transfer facilities or landfills with collections areas for household waste. In the state of Rhode Island at apartment complexes there are now containers set up for household hazardous waste. The benefit of knowing what to do with these products is lessening the chance of contamination to the environment that could ultimately affect the immediate person or those around them.
Posted on Wed, Sep 30, 2009 @ 08:55 AM
Sean Reagan, Corporate Director of Higher Education
Long awaited guidance from EPA Headquarters on the issue of PCB-laden building caulking material provides us with a great deal to digest. Although the EPA states that the presence of PCBs should not be cause for alarm -effectively managing this complex issue is cause for alarm for many school administrators and facility managers. Here's a first pass on the highlights of this guidance:
1. EPA was careful to not use "must" or "shall" language and maintained "may" and "should" language in this guidance. Testing (caulk sampling or indoor air) is still not required however, indoor air testing in schools is strongly recommended to determine if their is an immediate exposure risk to children in schools.
2. EPA acknowledges the growing amounts of evidence of the presence of levels of PCBs in caulk used in older buildings (1950-1978) - generally not concerned YET about newer buildings (but this may still be a problem).
3. IMMEDIATE MITIGATION STEPS - The released guidance are steps building owners and school administrators should take to minimize potential exposure. Immediate steps include cleaning air ducts, improving ventilation, clean frequently-reduce dust, wash children's hands frequently, among a few other common sense steps.
4. INDOOR AIR TESTING - Beyond immediate steps, EPA recommends testing to determine if PCB levels in the air exceed EPA's suggested public health levels. If testing reveals PCB levels above these levels, schools should be especially vigilant in implementing and monitoring practices to minimize exposures. If a second test after immediate steps taken do not lower indoor levels - schools should (not required) take steps to remove peeling caulk. In short - it is believed that if you fail the second air test you will be remediating the PCB Caulk and contact building materials under the direction of the Regional PCB Coordinator.
5. PCB INDOOR AIR THRESHOLDS - EPA published Public Health Levels of PCBs in School Indoor Air (ng/m3) - indoor air concentrations below these levels are believed to keep total exposure below EPA reference dose (in other words - "safe").
6. ADDITIONAL RESEARCH - EPA states that they need more time to complete research on questions related to the magnitude of unresolved scientific questions such as the link between the concentrations of PCBs in caulk and PCBs in the air or dust. More to come on this......some schools may be recruited to participate in these studies to include methods to mitigate exposures to PCB caulk including encapsulation of the caulking as well as contact material (wood, brick, concrete).
7. SCHOOLS and CONTRACTORS INFO KIT - Guidance contains useful communication and information tools for school administrators, teachers students as well as contractor who may come in contact with caulking.
Posted on Fri, Sep 25, 2009 @ 10:11 AM
By Mike Benson, Senior Higher-ed Account Manager
Times are tough. Everyone is looking for opportunities to recycle more often and to save money. Have you ever asked yourself; how do those solvent recyclers work and which solvents are the easiest to get lab researchers to buy into? The answer is Acetone.
Acetone is a widely-used laboratory solvent most-commonly used to clean and dry glassware. The process of drying glassware is performed in virtually every chemistry laboratory. And because quality and potential impurities are not quite as vital, it is easier for laboratory researchers to buy into the concept of reusing a recycled product in their labs.
Acetone is quite costly both from the purchase of new solvent, and from the needed collection and disposal of the waste solvent. Acetone recycling, however, is quite easy, virtually automatic, and extremely cost effective. The recovery of acetone is usually close to 100%, and the purity of the recovered acetone is typically greater than 99.9 %. Non-volatile contaminants are reduced by > 109-times.
Besides acetone, the same recycler can be used to separate and recover other solvents from most solvent wastes. As with acetone, the percentage of solvents that are recovered is very high and the recovered-solvents usually are highly pure. Virtually every solvent, with boiling points from 0°C to 300°C, can be recycled successfully.
If you’d like to talk about starting a demo at your school, give me a call. I can walk you through the steps on how to get this done.
Mike Benson, CHMM 617-592-731