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.
Posted on Wed, Oct 07, 2009 @ 09:56 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 Wed, Sep 30, 2009 @ 06:35 AM
By Todd Kato, Industrial Account Manager
There are many treatment technologies and disposal facilities across North America that treat a wide variety of wastes generated in the research and manufacturing workplace for medical device companies. I am often asked for my opinion to offer a summary on these options.
Medical Device manufacturers usually generate similar wastes from one company to another. These consist of halogenated and non-halogenated flammable solvents, wastewaters from cleaning medical devices and parts, IPA wipes, unused devices, and non-RCRA materials from production. The options for disposal consist of recycling, RCRA incineration, non-RCRA incineration, fuels blending, wastewater treatment, and stabilization and landfill.
Sometimes sifting through these options can be an arduous task between environmental compliance and budget. If you are unsure of your options, always seek out an environmental professional to assist you. A good starting point is to look at the options per waste stream.
Halogenated and Non-Halogenated Solvents – you can select recycling, fuels blending, or RCRA incineration. Generally, fuel blending offers a lower price over incineration and the material is reused in the cement kiln industry. Incineration is higher in price, but offers ultimate destruction. Recycling options exist for materials that are predominantly one solvent and provide beneficial reuse for the material.
Wastewaters from Cleaning Medical Devices – these materials may be RCRA hazardous or non-RCRA depending on the pH of the wastewater and any potential heavy metal constituents. Either way, wastewater treatment, stabilization and landfill, or incineration (if there is any organic content) are your options.
IPA Wipes – shredding for fuels blending or incineration are the main options.
Unused Medical Devices – this is a very broad category and the devices may be high in metal content or may not contain much metal content. I mention the metal content because your incinerators may or may not accept the material based on the amount of metal they have to burn in their kiln. Incineration or Landfill are your options.
Non-RCRA Materials – this is also a very broad category, but generally consist of non-metal materials that a non-RCRA incinerator can provide ultimate destruction at an affordable price.
Triumvirate Environmental works with many medical device companies and has done the research and due diligence on each of their wastestreams and the appropriate disposal facilities. Contact us today to assist with this task!
Posted on Tue, Sep 22, 2009 @ 11:55 AM
By Dave Williamson, Industrial Account Manager 
One man's garbage is another's gold. Everyday companies are continually trying to become "greener" and everyday someone is shipping sodium hydroxide as hazardous waste for disposal. Want to look like a hero in your EH&S program by reducing your hazardous waste? Of course who doesn't? In many cases sodium hydroxide can be re-used in a process as a substitute to a commercial chemical product.
The best case scenario for re-use is unused sodium hydroxide. However, let's say it is spent with a ph over 12.5. After a few tests are run to see quality standard a determination can be made. Or it could even be solid sodium hydroxide. As long as it is water soluble it can be re-used. When can it not be recycled? Sodium hydroxide can not be recycled when it has high metals content or organic contaminants.
When transported it will still be considered a hazardous material but not a hazardous waste. The proper shipping name would be Sodium Hydroxide for recycling. When it comes time to do your next bi-annual report there will be no need to report this and it will show that your company shipped less hazardous waste. That might be worth mentioning come your next yearly evaluation.