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Too much to do and not enough time!

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By Ron Souza, Environmental Compliance Advisor

Do you find yourself overwhelmed with what you have to do? Do you miss deadlines? Are you stressed out and feeling like you have too much to do and not enough time?

Making good use of your time management at work can reduce your stress, build your confidence, and increase your value to your company.

Here are 5 Time Management strategies you can implement today.

1. Know your job role and how your performance is measured

a. Do you know what your job responsibilities are? Do you have a job scope? If you are contracting and have specialist expertise, do you know the expectations the company has of you?
b. Having a clear idea of what needs to be done can help you avoid wasting time and do those activities that are most important to your job.

2. Manage Interruptions

Between your mobile phone(s) ringing, dozens of messages on your email and a work colleague asking you a question - how are you ever going to complete that important project? Interruptions cost you time and productivity.
a. Plan for interruptions - understand that you will be interrupted when you plan your day.
b. Block time off each day to read emails and return phone calls.

3. Keep focused on important and urgent activities

a. Keep a "To do list" which helps you prioritize those important tasks.
b. Spend the majority of the day doing those tasks.

4. Be specific about actions in your "To do list"

a. Do not lump multiple action into a "group action"
b. Instead of "train employees on Radiation Safety" the "To do list" should list a specific next action item - such as "book meeting room for radiation safety training" or "prepare draft of presentation for radiation safety training."

5. Do it now and beat procrastination

a. Divide and conquer. Breaking the task into smaller bite-sized pieces is an effective way to manage an overwhelming project.
b. Jump in. By simply jumping into the game, you will get a better idea of what you need to do. Take a break when your concentration starts to wander.
c. Get organized. By having a place for everything, and everything in its place, you can be more organized.

Inspection Preparedness

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By Ian Lanza, Life Sciences Operations Coordinator

Being prepared for a state or federal environmental agency inspection can mean the difference between passing with flying colors and non-compliance. Often state and federal inspectors do not give prior notice of an inspection, or very short notice (a day or two). Today is the time to prepare your facility for an inspection!

You should have an Inspection Plan to which key institutional stakeholders have been trained. Having a plan where key stakeholders know how to immediately respond to a surprise inspection is vital. Key stakeholders include:

• The receptionist
• EH&S staff
• Department managers
• Hazardous waste generators

Receptionist
Upon arrival, the receptionist should be prepared to accept the inspector into the facility and calmly notify the other key stakeholders of the inspection. Do not allow the inspector beyond the front lobby until the EH&S manager has arrived onsite.


EH&S
Generally, the EH&S staff will accompany the inspector throughout the facility. Greet the inspector and bring him/ her to a conference room to gain a clear understanding of the purpose and objective of the inspection. Do not offer any other details which are not specifically asked for.


Department Managers
Department Managers should be notified that their areas will be inspected for environmental compliance by a state or federal agency. Employees working in these areas should be respectful and honest with any regulatory figure. I have often found that employees tend to be on their best behavior when they know there is an inspection as well.


Hazardous Waste Generators
Any employee who generates or manages hazardous waste will probably be interviewed by the inspector at the point of waste generation or collection. This is why it is important for responsible employees to have a comprehensive understanding of their role and obligations because the inspector will test them. If the inspector finds a compliance issue, the responsible employee should not get defensive, but should acknowledge the issue and correct it immediately.


Being prepared for regulatory inspections can mean the difference between passing and failing the audit. You should bring together all applicable stakeholders, train them on their role and responsibilities, and get them prepared for a surprise inspection.

 

Manifest Management: Three- Folder System

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By Ian Lanza, Life Sciences Operations Coordinator

The Resource Conservation and Restoration Act (RCRA) requires hazardous waste generators to retain hazardous waste manifests for up to three years. Generators are responsible for retaining the Generator's Copy of the federal hazardous waste manifests, as well as a returned copy from the treatment, storage or disposal facility within 45 days of the signing and shipping of the hazardous waste from the generator's site.

The three-folder system to hazardous waste manifest management is an easy way for all hazardous waste generators to manage their hazardous waste manifests. In a filing cabinet, setup three folders for your hazardous waste manifests. Upon shipping waste from your facility, place the ‘Generator's Copy' in the first folder. The second folder is a limbo folder. Many states require that manifest copies be sent to the state environmental agencies. I use this folder for copies that require further actions to comply with specific state requirements. Once the TSDF copy has been received and I have complied with applicable state copies I staple the TSDF return copy to the Generator's copy with any packing slips or LDRs and file in the third folder. I keep manifest in the third folder for three years. After three years, I move the manifests to an archived folder.

If a manifest stays in the first folder for over 38 days you must contact the TSDF to track down your return copy from the TSDF. The three-folder manifest management system is a simple way to track and file hazardous waste manifests and ensure RCRA compliance.

What to do the next time you need to move your lab to the other side of town

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By Kim Parker, Life Sciences Account Manager

If you are responsible for managing labs for a life science company that rents their space, then you know that sometimes "business is good" is a synonym for "it's moving day". It may be your first big lab move or you may be a HPLC schlepping, biosafety cabinet certifying, chemical packing, lease signing, permit obtaining guru! No matter how experienced you are, it can be stressful, expensive, and time consuming! Here are a few tips that may help you better prepare for the next big move:

  1. Read your lease agreement carefully. You should make sure you fully understand the landlord's expectations for decommissioning the space. Some leases may read broom clean, while others may require you to meet ANSI decommissioning standards or other specific requirements. You should be prepared to provide the landlord with a thorough report documenting decommissioning procedures that meet their standards. When choosing a new facility, you should read the new lease in full and obtain documentation of the decommissioning performed by previous tenants. You may be responsible for some equipment as well, such as boilers or emergency generators. Make sure you know who is responsible for maintaining air permits and performing maintenance on equipment.
  2. Make a list of permits - know in advance the permits you will need to obtain and terminate and how long this process will take. If your operations are not changing from one site to the next, then this will be easier. In some cases a simple change of address will suffice. Examples of common permits, registrations and certifications you may need include:
    • Flammable Storage Permit
    • rDNA Permit
    • EPA ID registration and RCRA generator status
    • Local POTW/wastewater permits
    • DEA and controlled substance permits (federal and state)
    • Radioactive materials license
    • Tax free alcohol application
    • Emergency generator registration
    • Boiler Registration
    • Fume hood and Biosafety Cabinet Certifications
    • And the list goes on....
  3. Create a written plan. You should develop a realistic schedule that includes timelines with specific assigned tasks and all involved parties. Once this plan is in place, you should hold periodic progress meetings to make sure everyone is on the same page.
  4. Get a second opinion. Find a consultant or someone in the industry you trust and have them QC your plan. A second set of eyes never hurts.
  5. Choose your vendors wisely. In any lab move, there are many deadlines and new contractors involved. Even when "business is good", you still need to get the job done on time and meet your budget. By selecting the right vendor, you'llbe able to streamline activities that would otherwise bevery costly and mismanaged. Communication is critical. Talk upfront about your schedule and how each vendor will communicate with you.

Follow these five tips and you're off to a good start! Good luck.

 


Retaining Top Talent

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By Denise Hutchins, Executive Director of Life Sciences

Retaining top talent allows you and your organization to build its people power at all levels and conduct succession planning. It is the key to success and growth at all levels.


There are several different forms of recognition to help with retention; here are a few I suggest:


IT'S ‘THE LITTLE THINGS':
Employees want to be recognized; in the thousands of employment surveys taken, ‘recognition' is always the #1 thing lacking in an employee's job. Saying ‘thank you' or sending a handwritten thank you note can go a long way in showing an employee that you appreciate their work. Many times, extravagant is not necessary or as memorable as a smaller token of appreciation. Don't forget to execute on doing the little things for your people. The little things can make all the difference.


TRAINING & PROJECTS:
Training outside a person's specialty is always a good way to express long-term commitment to that employee. Plus, project assignments off the beaten path of what the person would generally manage allows for personal and professional development, stretching of that person's skill sets, new challenges, and sources of inspiration.


NETWORKING:
Creating networking opportunities is a good way to expose your top talent to new ideas and thought leaders. Take a colleague to an interesting symposium or after-hours event. Helping a colleague reach the next level shows you care and are invested in that person's career growth.


OVER COMMUNICATE:
Communicating corporate strategy and direction as well as career path potential with your employees is critical to retention. Communication is always key but even more so during these turbulent times. When there is not enough communication, people will draw their own conclusions.


Please share with me what you and your company are doing to retain your top talent. We are considering hosting an event for us to share the best ideas we receive.

Two Life Sciences organizations have already been inspected by the MA DEP since the beginning of 2010. Is your company next?

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By Andy Joy, Life Sciences Account Manager

During the past three weeks, the MADEP has dropped in on two LQG's for an unannounced audit. So the question I have for you is; are you prepared? Now, everyone should be prepared and well aware that the DEP (and other local/state/federal agencies) can and will stop without any lead time at your facility for an inspection.

Here are some things to think about: are my emergency generator's permitted (if needed); do I have a wastewater discharge permit, do my colleagues have the pertinent training for their job description, are my authorized signee's for manifests up to date on their trainings, do we have sufficient records of hazardous waste manifests, is the hazardous waste under 90 day accumulation, did I complete the Tier II Report, the Biennial Report, is all my waste properly labeled, is my flammable permit/license up to date, do I have an SPCC Plan?

These are questions that we need to think about on a daily basis regardless of the initiative by the DEP; but now apparently more than ever. The more prepared and organized you are, usually the easier the inspection.

So, I ask you, what else can you think of that Large Quantity Generators should think of and be prepared for?

Familiar with a lab pack?

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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.

Secondary or Repackaged Container Labeling in the Laboratory

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By 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 OHSA 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.

Loading Dock Spill Kits

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By Gregory Rosinski, Chemist II

1 Field Service Crew

1 Tanker Truck

30 Bags of Speedy Dry

25 Spill Pigs

5 Bags of Oil Spill Pads

15 x 55 gallon Steel Drums

165 Total Hours of Remediation

1 Truck for Transportation of Waste

11 Hours of Pouring Rain

1 Delivery truck with a bad gas cap causing the spill -------- “Priceless”

At Life Science accounts supply trucks constantly come in and out of loading docks and accidents can happen. The greatest amount of planning against spills still eventually will result in a leak from an automotive vehicle causing gas or oil spills. A tool that will help to contain and prevent massive spills of oil mixing with rain is to always have a fully supplied spill kit at every loading dock. It only takes a minimal amount of oil or gas mixed with rain water to encompass a big area costing a lot more than if there was someone ready with supplies to prevent the spread of material. A spill kit containing the following should be a minimum at every loading dock or parking garage to contain and clean spills from vehicles:

Oil Spill Pads

Speedy Dry

Small Broom

Small Dustpan

Hazardous Waste Collection Bags

Oil Spill Booms

Drain Covers

Safety Gloves

This list of supplies is the minimum, but if kept in a DOT shippable drum allows for the collected material to be ready for shipping.

Emergency Response in Life Sciences

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By Bart Nielsen, Environmental Compliance Specialist

Emergency response in the Life Sciences is a critical safety issue. The collection of chemical, biological, and radioactive materials in research facilities can make emergency preparedness a daunting task.

Safety managers must begin by inventorying and evaluating all of the hazardous materials onsite, then identify the what types of hazards the materials pose to employees and the environment. From there, safety managers must develop systems for the facility and its employees to safely and swiftly respsond to any type of emergency. The number one goal is to eliminate or minize harm to employees and the environment from an emergency.

The cleanup is usually one the most difficult aspects of emergency response. Depending on the size and content of the spilled material, employees may need extensive training from qualified trainings to repsond. Also, additional exposure monitoring and personal protective equipment is often required when cleaning up hazardous material spills.

Here’s a story…

If you’ve ever had to clean up elemental mercury you know that it isn’t that easy to contain. On top of that, it poses a significant respiratory hazard so you should be wearing a mask with an air tank (in most cases).

During a routine job I happened upon a scientist trying to dismantle a barometer that was 6 feet tall and full of mercury. Just as I was about to ask him how he planned on removing the mercury he released a pin at the base and out it poured (I estimate ½ gallon).

I’ve never seen such large pools of mercury all over the floor. Needless to say, I had him evacuate the area.

His first response to me was, “I’ll get the mercury spill kit.”

To which I replied, “Even if you had a spill kit for that much mercury, you don’t have the proper protective equipment.”

His response, “I’ll just hold my breath.”

What do you think I said next???

What challenges or additional safety issues have you encountered when cleaning up a hazardous material spill?

Question: Would you like to share an emergency response experience?

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