Environmental Health & Safety Compliance Blog

Bacteria: What is it good for?

Posted by Mark Campanale on May 4, 2011 8:49:00 AM


Sanitary wastewater treatment, of course!

Maybe you never once thought about wastewater systems or perhaps you said, “Just dump that; it’ll go to the wastewater treatment facility anyway.” In terms of wastewater treatment, an educated and conscientious public helps keep recreational and drinking water supplies free of contamination. Let’s find out what happens in the sanitary system we use and take for granted every day, and why we should think twice before sending something down the drain.

Wastewater from homes and businesses travels through pipes to larger sewers below ground. The sewers are accessible for inspections and maintenance through manholes, and lead to a publicly-owned treatment works (POTW) facility, which is designed to treat primarily one thing: human waste.

Of course, many other wastes enter the system including “untreatables” such as dental floss, chewing gum, hygiene products, and children’s toys, to name a few. Accidents happen but placing as much untreatable waste as possible into household garbage ultimately saves resources and sewer bill costs because those items must be screened at the POTW entrance (called the headworks) then hauled away.

As repulsive as human waste is to humans, it is nothing less than the most delectable feast to many bacteria. These bacteria, known collectively as activated sludge (are you getting hungry?), are the heart stomach of the POTW.

Under tightly-controlled conditions, sludge digests wastewater organic matter. When the smorgasbord is complete, liquid and sludge solids are separated. Liquid continues through a final disinfection (reaching near drinking water quality) before discharge to a nearby river, lake, or ocean. The dewatered solids are often sold as fertilizer. Other byproducts such as methane gas are produced and can be reclaimed as renewable resources to power the POTW.

Despite my simplification of POTWs, their true complexities are proven by regulations that require designs licensed by professional engineers, permits approved by government agencies, and systems operated by experienced and certified personnel.

Ask if your local POTW offers tours and you can see how much happens “behind the scenes” to keep our waters safe.

Now that you have a basic understanding of sanitary wastewater treatment, will you think twice about what you dump, flush, or rinse down the drain? What do you think happens to other potentially harmful “stuff” that gets into the system? Check back here for more insight.

EH&S Compliance Program Review vs. Compliance Audit

Posted by Mark Campanale on Mar 21, 2011 8:00:00 AM

What’s the difference, and when you should do one or the other

Sandy Perry EHS Compliance Expertby Sandra J. Perry, Environmental Health & Safety Consultant

The primary difference between a Compliance Program Review and a Compliance Audit is that a compliance audit identifies potential non-compliance specific to onsite activities and programs, related to hazardous waste management, air emissions, wastewater treatment, hazardous materials management, safety practices etc. The program review is a bird’s eye view of the EH&S programs that are currently in place in order to assess the strengths or weaknesses of the current programs.

It is prudent to conduct a comprehensive third-party compliance audit at least every one to two years.  A fresh look at day-to-day activities and compliance management systems can take care of that “can’t see the forest for the trees” situation that happens to us all after awhile.

A program review on the other hand is more of a higher level look at the systems and programs that are in place, designed to keep you in compliance. Conducted similar to a compliance audit, each EH&S program area by media – Clean Air Act, Clean Water Act, RCRA, DOT, Radiation Control, NIH, etc. is compared to current applicable regulatory requirements.  This is also an excellent means of assessing staffing and organizational structure.  It may tell you that you need to go to the President for additional staffing or consider outsourcing specific program areas.


Understanding “UN” Markings

Posted by Rebecca McDaniel on Sep 1, 2010 7:35:00 AM

By Amanda Mendonza, Technical Services Representative

So you finally got your RCRA and DOT training and you’re ready to start shipping waste. You learned about appropriate container labeling and how to properly fill out your uniform hazardous waste manifest. One important part of your training should have been making sure your chemical waste is contained in a “specification” packaging for the material you are shipping. If you are shipping a DOT-regulated hazardous material, then your drum will have to be “UN-specification” (that’s UN as in United Nations). This means that the drum has been tested to international standards of integrity, such as drop and pressure testing. You can check whether your drum is UN-specification by the UN test marking located on the side or top of the drum. It will have a series of codes in the following configuration:

describe the image1H1/Y1.8/150/05/USA/M824 /1.1 mm


Here is how you decode the series:

1H1: Is a packaging identification code designating the container type, material of construction, and in some cases, a characteristic. In this case the notation is saying this is a closed top plastic drum.

Y: Indicates which of the three performance standards has been met which tells the filler which packing group materials (PG I, II, or III) are allowed. X = OK for PG I, II, or III, Y= OK for PG II or III, Z = PG III only

1.8: Designates the maximum specific gravity of the liquid chemical suitable for this drum. In this case, the notation is saying this drum is able to withstand the weight of a liquid with a density up to 1.8 g/cm3. Non- leak proof containers will have a maximum gross mass in kilograms at this spot in the marking.

150: Is the hydrostatic pressure test in kPa. Non-leak proof containers will have an “S” at this spot in the marking. Shippers must select materials with vapor pressures that are not too high- the pressure test marking is used as part of that calculation (see 49 CFR 173.24a(b)(4) for how to calculate).

05: 2005 Production year

USA: Manufactured in the U.S.

M824: This spot is used to indicate, either by name and address, or by the use of a symbol, what party performed the UN- protocol testing.

1.1 mm: On many drums, the minimum thickness of the material of construction is indicated in millimeters (this is required in some cases for the container to be eligible for reuse).

On reconditioned drums, you may also see an abbreviated version of the full series, such as: 1H2/Y25/S

And remember, all UN-specification drums come with a set of closure instructions by the manufacturer to which you much precisely follow and retain a copy of for a period of 1 year after a package is offered for transport.

Tags: DOT

Excel for EH&S Specialists: manifest tracking

Posted by Mark Campanale on May 21, 2010 2:00:00 AM

By Courtney Drayer, Technical Services Representative

Keeping track of manifest return copies can be a hassle especially if you ship waste frequently. If you have not received a signed return copy of your manifest by 35 days from the time of shipment (per 40 CFR part 262.42), it is time to call your friendly TSR to request it. You can track when it is time to call your TSR by using the following four column spreadsheet:

TSR Manifest Sample








The magic happens in the status column. Logically, what we want to know is "IF the manifest is older than 35 days AND I have not received a return copy THEN I should call my Technical Services Representative to ask for it." You also want to know that "IF the manifest is older than 35 days AND I have received a return copy THEN I am in compliance." And finally you'll want to know "IF the manifest is younger than 35 days AND I have received my return copy or I have not received my return copy THEN I am in compliance". We can say all that in excel using the following formula in column D;

=IF(AND((TODAY()-B2>35), C2="N"), "Call your TSR", "Compliant")

Now all you have to do is enter your manifest #, the shipment date, and whether or not you have your return copy and the spreadsheet will tell you the rest! Since we have used the "TODAY()" function in the formula, the spreadsheet will automatically update every time you open the file so you don't need to keep track of the dates anymore!

If all this still sounds like more data entry than you have time for, you can use Triumvirate's ADVISE software to track manifest compliance.

Advise Manifest Sample





Your manifests will automatically appear in ADVISE with red, yellow and green dots showing you the compliance status of each one. You can also scan in and upload your manifest copies (generator’s copy and returned copy) and save them in the program.  ADVISE can be accessed from anywhere you have an internet connection.  So, if an inspector shows up for a paperwork review at one of your sites, you can show them all of your manifests from all of your sites from the comfort of your desk!  Now that’s easy.

EH&S Tips: Quick Green Moments

Posted by Rebecca McDaniel on Mar 29, 2010 4:15:00 PM

By Greg Rosinski, Chemist II

A vast majority of society has made a committed move towards "Green Existence". Helpful tips to remember or that should be posted in offices or homes to help save energy and emissions are the following:

  • Make sure to turn off your computer at the end of a work day. This helps to reduce energy consumption, save money, decreases the effects on global warming, and move towards personal stewardship of natural resources used to keep a computer on.
  • A laboratory containing a Variable Air Volume (VAV) Fume hood should instruct lab personnel to make sure they completely shut the fume at the end of each use. Leaving a VAV fume hood open causes the air exhausted into the fume hood to leave the fume hood increasing the amount of energy used, money wasted, and impact on natural resources. Closing just one VAV fume hood in a laboratory after every use over the course of a year results in an energy saving approximately the same as the energy used by 3 houses in a year. 
  • Laboratory personnel should move towards using washable containers for lab use. Even though most plastic equipment is recyclable it still creates wasted energy to recycle the material. To help preserve the natural resources used in recycling simply use glass beakers, measuring devices, and other lab equipment. This applies to eating meals at work as well. Bring in containers from home that can be washed or use washable dishware from the cafeteria. 
  • Try to remember the impact of wasted water, electricity, or gas on the environment when working in laboratory. The earth is already experiencing shortages in the majority of natural resources, and most of our time in life is spent at work. That is why we must make a committed decision to decreasing unused natural resources on a daily basis.

All though there are other areas to help move towards a "Green Existence" the above topics are several helpful tips. These tips should be post in work places or circulated throughout the workplace to increase general awareness.

Tags: Environment

Changes to DOT HazMat Services Security

Posted by Rebecca McDaniel on Mar 29, 2010 12:54:00 PM

By Doug Graham, CHMM Sr. Compliance Advisor & Training Manager

The U.S. Department of Transportation (DOT) is modifying current security plan requirements applicable to shippers and carriers of hazardous material.

Based on an evaluation of the security threats associated with specific types and quantities of hazardous materials, the final rule narrows the list of materials subject to security plan requirements. The final rule also clarifies certain requirements related to security plan components, training, and documentation.

In a qualitative risk evaluation, DOT considered the following factors when deciding how the new security planning requirements would better address actual terrorism threats: (1) Physical and chemical properties of the material or class of materials and how those properties could contribute to a security incident; (2) quantities shipped and mode of transport; (3) past terrorist use; (4) potential use; and (5) availability.

In this "new look" at which materials pose significant risk, DOT explained that , "One of the most significant security vulnerabilities involves the potential for an individual or group to take control of a conveyance containing a high-risk material and move it to a site where the material could cause maximum physical or psychological damage. For some hazardous materials, the primary security threat involves theft or highjacking of raw materials for use in developing explosive devices or weapons".

So, based upon this fresh analysis and the need for clarification to the original rule, the following is a summary of the regulatory changes to the security planning rule that are slated to go into effect on October 1 of 2010:

  • Firstly, the list of materials being either offered or transported, which would trigger the requirement for developing a security plan has changed. The list, found in 49 CFR 172.800(b) currently identifies seven categories, including placardable quantities. The new list identifies sixteen very specific categories of hazardous materials, most of which have threshold quantities.
  • Secondly, the required components of a written security plan under 49 CFR 172.802 have been clarified and expanded. Hi-lights include:
  1. clarification that the plan must address risks associated only to those materials identified in 172.800(b);
  2. there must be a senior management official identified who is responsible for development and implementation of the plan;
  3. the plan must identify security duties for each position or department responsible for implementing all or part of the plan;
  4. the plan must describe the process for notifying employees when plan elements are to be implemented; and
  5. the plan must be in writing, retained (paper or electronic), available to employees responsible for implementing it, updated as necessary, reviewed annually, and made available to the DOT for inspection, upon request.
  • And lastly, the security training requirements under 172.704 have been clarified.

In summary, it is anticipated that many employers who currently require security plans solely due to offering placardable quantities of common hazardous material will no longer need them. Additionally, those who will still require security plans under the new rule will need to make major revisions to their plans, procedures, and recordkeeping.

To see the complete revised rule change as published in the March 9, 2010 Federal Register, go to: http://edocket.access.gpo.gov/2010/2010-4778.htm

Tags: DOT, 49 CFR

Main Accumulation Area Compliance: Time for a Refresh?

Posted by Rebecca McDaniel on Dec 21, 2009 2:07:00 PM

By Alexa Kaubris, Chemist

With all the rules and regulations, things can get confusing when you have an entire room filled with chemicals. If you’re overwhelmed don’t worry you’re not alone. Here are some helpful hints and reminders when inspecting or reorganizing your MAA in Massachusetts. Don’t forget, not only are there a ton of rules but they change from state to state.

1. Every hazardous waste bottle in the MAA needs a label with a) the words “Hazardous Waste” b) the constituents of the container written in full (no abbreviations or chemical formulas) c) the hazards of the bottle identified (corrosive, ignitable, etc.) d) the date the container was filled in its respective satellite accumulation area (SAA) or the date accumulation began if you fill drums in the MAA.

Do: Make sure you can see this label.

Do: Make sure the container is closed tightly.

Do: Inspect the containers for leaks and cracks.

Do: Make sure the label is on the side of the containers (not on the top).

Hint: It’s always a good idea to label empty drums and containers in the MAA for clarity.

2. These bottles should be segregated out into secondary containment bins so that incompatible chemicals won’t react and an underlying impermeable surface will be ensured.

3. The room itself needs to have an impervious underlying surface, a base that slopes or elevated containers in case of a leak, and run-on needs to be prevented unless containment has excess capacity. Basically, if you have a spill, you need to make sure the other chemicals you are storing in the MAA won’t be sitting in the mess.

Do: Check expansion joints on concrete pads.

Do: Make sure there are no drains in the MAA.

Do: Make sure every hazardous waste container in the MAA is in a designated area for waste. Putting tape on the floor is a quick way to delineate the waste area. Everything else should be stored elsewhere in the MAA.

Hint: For best management practices any material labeled as non-hazardous should be kept separate for the hazardous material.

4. Watch out for aisle spacing! If the waste is not reactive or ignitable all you need is enough room to inspect each row. If the waste is ignitable or reactive you need four feet as required by the NFPA chapter 30.985(3).

Hint: If you’re tight on space, one solution is to make a double row of drums back to back in the middle of the room and then give 4ft to either side. Another is using a pallet to separate containers if you need to stack them.

Fast Facts: Reactives/Ignitables need to be stored 50 feet from the property line. The fire department does not like Reactives/Ignitables to be stored in underground rooms like basements (waste or not). The idea behind this being safety of personnel that would have to respond to a fire in a basement when there are limited entrance/exits.

Good luck and have fun! Be sure to take before and after pictures. Make-overs are the best!

Tags: Hazardous, MAA, Main Accumulation Area, Compliance

Proactive Chemical Management

Posted by Rebecca McDaniel on Dec 8, 2009 10:27:00 AM

By Greg Rosinski, Chemist II

Walking through the laboratories of colleges and universities will result in seeing a lot of unused chemicals that are prior circa 1980. Typically the chemicals are pushed to the back of the chemical storage cabinet until the professor retires. In order to decrease the potential exposure these chemicals could create it is important for the Environmental Health and Safety (EH&S) department to monitor the amount of these chemicals remaining. Recently, a local university had a professor retire from a career of over 50 years of teaching in the same lab. This professor had a refrigerator full of temperature sensitive chemicals that he kept adding to over the years without properly disposing of them. Murphy’s Law played out in this circumstance when a storm happened on the weekend causing a power outage. The school’s generators also were struck causing the refrigerator to shut off, and increase in temperatures beyond the allowable range for the chemicals. The chemicals reacted causing the containers to fail, and spill throughout the refrigerator. On Monday when the professor went to open the refrigerator to start his lab the fumes were nauseating, and forced the EH&S department to call Triumvirate Environmental Inc. to properly dispose of the chemicals. The EH&S then had to make a phone call to have the refrigerator properly decontaminated. The cost to the university in bills and the inconvenience of shutting down the lab has made the EH&S director proactive in disposing of unused chemicals. The result of proper management of aged chemicals has reduced their average spending on disposal, and the occurrence of spills or other incidents. Properly managing chemicals involves spending time in labs, and looking outside of the normal areas. This will help to identify chemicals that are no longer in use. The cost of spills costs more than proactively managing a hazardous waste program. A good place to start looking for temperature sensitive chemicals (not an all inclusive list) is the Department of Transportation (DOT). The DOT’s list can be found in 49 CFR 173.224 for self reactive materials, and 49 CFR 173.225 for organic peroxides. These two types of chemicals are known to become unstable with age.

Tags: Environmental Health and Safety, EHS, DOT, Department of Transportation, Chemicals, 49 CFR, Chemical Management

EH&S News: EPA Exclusion of Rags and Wipes

Posted by Rebecca McDaniel on Nov 17, 2009 11:38:00 AM

By Kristina Florentino, Environmental Compliance Specialist

Wide arrays of industries use wipes-including rags, shop towels, disposable wipes and paper towels-are used for cleaning, disinfecting and degreasing. These wipes are considered hazardous waste when discarded if the wipes exhibit a hazardous waste characteristic or are contaminated with a listed solvent (RCRA waste codes F001 through F005). Listed waste mixtures are regulated under the Resource Conservation and Recovery Act (RCRA) under the mixture rule, which states that a mixture composed of any amount of a non-hazardous waste and any amount of a listed hazardous waste is considered a listed hazardous waste. Thus, any amount of a listed waste, no matter how minute, when mixed with a large volume of non-hazardous waste, the resulting mixture will carry the same waste code and regulatory status as the initial waste carried. The rule is applicable regardless of the chemical composition and properties of the resulting mixture.

On October 27, 2009, the EPA published a Notice of Data Availability (NODA) in the federal register, 74 FR55163, seeking comments on a revised risk analysis methodology of an earlier proposed rule relating to solvent contaminated wipes. The Proposed revisions relate to RCRA hazardous waste regulations governing the management of solvent contaminated wipes and would exclude these wipes from the definitions of solid and hazardous waste for solvent-contaminated wipes sent to a laundry or dry cleaner and solvent-contaminated wipes sent to a landfill or combustion facility, provided certain conditions are met. If the rule goes final, states with approved RCRA programs would have to adopt the rule into their own hazardous waste regulations before generators could take advantage of this regulatory relief.

The EPA is currently seeking comment on the proposed rule and the risk analysis used. The comment period is through December 28, 2009.

Tags: EPA, Non-Hazardous Waste

Disposal of Laboratory Waste: Tips for Labeling

Posted by Rebecca McDaniel on Oct 26, 2009 8:32:00 AM

By Kate Carpenter, TRS, Triumvirate Environmental Somerville

One of the most common deficiencies identified during lab inspections are related to container labeling.  Whether it is an environmental agency or the local Fire Department auditing you, they will want chemicals properly identified and the implications of this are very important for maintaining safety and compliance and also for avoiding fines.  Having all containers of virgin chemicals labeled so they are easily identified is important, but there are even stricter regulations for managing hazardous waste containers.

When labeling waste, there are specific requirements you must follow depending upon what state you are in.  In Massachusetts, any hazardous waste accumulating in a Satellite Accumulation Area must be labeled with a hazardous waste label with the full chemical names written (no abbreviations), and have the hazards identified (ignitable, corrosive, toxic or reactive).   When the container is full and it is brought into the Main Accumulation Area, there must be a date added onto the label.  The date is important for tracking how long the waste has accumulated on-site (to ensure compliance with maximum accumulation time requirements).   Since hazardous waste container labeling rules vary significantly from state to state, it is important to check your specific state hazardous waste regulations, or check with your friendly environmental advisor!

Tags: Environment, Inspections, Hazardous Waste Regulations