Posted on Fri, Mar 12, 2010 @ 09:22 AM
By Joe Caliri, Account Manager
Earlier this month the Boston Globe published a story about 9 truck-size shipping containers filled with old televisions from a Massachusetts recycling firm, that were seized by local port officials. These containers were initially sent to Indonesia for “re-use” or “recycle”, which in theory seems to be a globally sustainable resource exchange practice.
“E-waste” (electronic), categorized as a regulated or universal waste by the EPA, consists of everything from televisions, computer scrap, batteries, and in some cases mercury containing devices. The issue at hand with the export of this material overseas is that this E-waste contains toxins, that when not processed properly, pose serious health risks to humans.
This E-waste is certainly picked for all of the re-usable metals and components from countries that lack these natural resources, and yield far higher value overseas than here domestically. The horrific downside of this practice is that the process of recycling is sometimes nothing more than manual dismantle, without any personal protective equipment or regard for potential environmental impacts. Recently, 60 Minutes’-“The Wasteland” actually investigated one of these E-scrap towns in China which resembled what could be described as a post-apocalyptic environment, with a constant toxic fog and extremely contaminated water.
Ultimately these 9 containers were turned back by the Indonesian government on a tip from a U.S. based environmental group (BASEL), seized by the local port authority, and investigated by the U.S. EPA. The United States has not ratified the Basel Convention treaty, a 172-nation pact to prevent the transfer of hazardous waste from developed countries to less-developed ones.
Posted on Fri, Mar 12, 2010 @ 09:16 AM
By Dave Williamson, Account ManagerSo 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 Tue, Feb 16, 2010 @ 09:52 AM
By Amanda Mendonza, Technical Services Representative
Shipping routine waste streams has a habit of becoming just that...routine. However, many lab experiments and industrial processes change frequently. This could mean adding and eliminating chemical constituents to achieve a new outcome or product. It's possible the manufacturing line or HPLC the waste comes off of is the same, so the name of the waste or the generation might not change. This does not necessarily mean the waste composition has remained the same. It is very important to review your waste profiles and maintain accurate waste description.
You can keep your profiles current by holding an annual profile review where either you alone or you and your waste vendor address the generation of each active profile on record. If you are a Connecticut facility then you are actually required by your state to submit specific documentation describing your waste generation and composition. It is very important to keep on record all of your hard copy profile forms and any supporting analytical. These will act as an eternal record of all waste amendments or general activity. Compiling a binder with current/active profiles stored toward the front or in a completely separate binder from legacy profile information will be most efficient for referencing.
When completing your profile review here are some questions to keep in mind:
• Is the profile active (meaning is the generating process still in operation)?
• Has the generation process been altered since the last review/initial generation?
• Have any new chemical constituents been added? Have any been removed or replaced?
• Will any RCRA codes need to be added or removed?
• Will analytical be required to compile and accurate waste profile?
• Have the above amendments altered the shipping information?
• Should the profile be amended or inactivated and recreated?
Maintaining current and accurate waste profiles is a measure in safety as well as a cost-efficient practice. Per your hazardous communication to your employees, you want to make sure you are making all workers aware of all potential hazards at any given moment. This is difficult to achieve if you are not consistently reviewing your waste streams. Inaccurate profiles will also increase costs when disposal facilities discover changes to waste compositions for you. This leads to off-specifications and full waste rejections which will in turn result in additional shipping and processing fees. Keeping your waste profiles current and accurate is an important part of running a successful environmental management system.
Posted on Mon, Dec 14, 2009 @ 07:57 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.
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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 Mon, Dec 14, 2009 @ 07:43 AM
By Rick Foote, Senior Environmental Compliance Advisor
All batteries are subject to requirements in the DOT Hazardous Materials Regulations.
This is because they have two types of hazards:
(1) The chemicals or other materials contained in the battery, and
(2) The electrical potential of the battery.
All batteries must be packaged for transportation in the following manner:
Lithium Batteries-The terminals must either be taped or placed in a plastic bag to ensure no contact between battery terminals
Wet Batteries (electrolyte/alkaline)-These
types of batteries must be packed alone and not with any other
materials. The terminals must be protected to ensure they do not come
in contact with other batteries. The exposed terminals can be protected
with non-conductive caps, or non-conductive tape.
Sodium Batteries-These
types of batteries must be secured to prevent shifting while in a
vehicle. They also must have adequate ventilation and separation
between batteries to ensure they do not overheat. Additionally, if
there is other freight on the vehicle the batteries must be stored no
less than 1.6 feet away.
Dry batteries (alkaline, nickel
cadmium (NiCad), nickel metal hydride (NiMH) and silver-zinc batteries)
- These types of batteries are not covered under the Hazardous
Materials regulations as long as they follow these requirements:
- Packaged as to prevent the buildup of heat.
- This can be accomplished by one of the following methods:
- Taping the terminals and ensuring that the container is compatible with the batteries.
- Placing the batteries in a plastic bag
- Separating the batteries individually
Posted on Mon, Dec 07, 2009 @ 01:18 PM
By Craig Sasse, Senior Engineer LSP
The manufacturing sector has unique circumstances that complicate ending production and leaving a facility. Managing costs, timing and liabilities associated with retiring assets, vacating space and transfer of assets is always a concern. Unidentified and unanticipated conditions, updates to regulations and a regulator’s expectations can lead to a chaotic situation. Common concerns for transitions, renovations and vacating production areas include:
• Lease obligations, due-diligence considerations and real estate transfer regulations;
• Closure of RCRA hazardous waste storage areas;
• State and federal permit modifications or terminations;
• Decontamination of equipment (prior to disposal or transfer);
• Decontamination of facility work areas; and
• Adequate and appropriate documentation for regulators, owners, lenders and buyers.
Triumvirate’s professionals offer practiced regulatory compliance, efficient assessment, effective decontamination and thorough documentation. Our consultants and field service personnel have years of experience managing and performing industrial closure on a wide variety of facilities.
Posted on Wed, Dec 02, 2009 @ 10:38 AM
By Mike Farrell, Disposal Coordinator
Black Friday…Cyber Monday..We’re being inundated with news and flyers advertising the best deals that are worth stampeding a WalMart for. Also out there are all the black market rip off products available from overseas, everything from DVD’s to household cleaners. Make sure you’re getting what you pay for.
If you’re a manufacturer make sure you’re doing your part to keep returned or damaged goods and off-spec products off the shelves and damaging your brand name. Triumvirate helps clients destroy, and when possible, responsibly recycle all kinds of consumer products and trade secret raw materials. We can manage a wide range of materials through various technologies such as shredding, waste to energy incineration and even ethanol recovery of that awful fragrance Grandma sent you from last Christmas.
Happy Holidays!
Posted on Wed, Dec 02, 2009 @ 10:03 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 18, 2009 @ 01:54 PM
Our Industrial Insights Newsletter for Q3 is now available for download. In this issue:
Common Compliance Issues and Associated Fines
by Meghan Sunyar, Technical Services Representative
Aboveground Storage Tanks. . . Things You Should Know
by Doug Graham, CHMM, Senior Environmental Compliance Advisor & Trainer
Strengthening your EH&S During a Recession
by Amanda Mendonza, CHMM, Technical Services Representative
Click here to download your copy!
Posted on Tue, Nov 10, 2009 @ 12:10 PM
By Daniel Roohan, Chemist
Most companies are trying to reduce the amount of waste they produce to limit disposal costs. One great way to reduce cost while also helping the environment is to use reconditioned drums. Using reconditioned drums is cheaper than using new drums and reduces the amount of drums being discarded as well as the amount of drums which need to be manufactured.
The reconditioning process is regulated to ensure that all drums being reused meet high standards and are devoid of contamination. An example of the process for reconditioning a 55 gallon closed head steel drum is as follows. Interiors are thoroughly cleaned and treated for corrosion resistance. If residue remains or corrosion is evident the drum is rejected or flushed with acid to completely remove rust. Drum lips are mechanically resealed and reshaped and dents are removed by use of internal pressure. Drums are abrasive blasted to remove any coatings they may have and prepare them for repainting. The drums are vacuum tested for leaks and all closures are checked for damage and fitted with new gaskets. Once this has been completed drums are repainted and stamped with the appropriate DOT ID number as well as the date the drum passed inspection.
This reconditioning process is different for each type of container, but the goal is always to restore the container to a standard accepted by the DOT for the storage and transport of products and waste. Reconditioning also saves money, reduces waste, and conserves resources.