Environmental Health & Safety Compliance Blog

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

Meeting metal limits in wastewater discharge permits

Posted by Rebecca McDaniel on Mar 23, 2010 7:36:00 AM

 The importance of proper sample collection.

By Sandy Perry, Director of Water Management and Wastewater Services

Whether you discharge to the sewer or directly to a water body, the importance of collecting truly representative samples of your treated wastewater cannot be overstated. So what does "representative" mean? It means that:

  1. your wastewater treatment system is operating properly,
  2. you've selected a day to sample that is typical of your daily operations,
  3. your composite sampling equipment is set up to take flow proportioned samples properly,
  4. your flow meter is sized appropriately for your flow rates and is calibrated at least annually, and finally,
  5. the sampling equipment and collection containers are clean!!

To my last point, the last thing you want is a cross-contaminated sample. If you think about it, there are actually quite a few opportunities for contamination. And with metals limits in parts per billion, it doesn't take much to tip the lab results over the limit.

Dischargers should check with their sampling contractor regarding their procedures to prevent sample contamination. Do they change the pump tubing or just rinse it out between yours and another client's sampling? Do they acid wash and rinse the collection container? And how does he or she appear when they are onsite to setup and collect the samples - is their appearance neat and clothing clean? Even dirty hands and dust/dirt on clothing can be a potential source of contamination.

Did you know that in some areas of the country, dischargers are subject to limits in parts per trillion (Maine and the Great Lake areas' mercury limits are in ug/L) and must perform "clean sampling"? The U.S. EPA's Clean Sampling guidance includes using non-metal sampling equipment, and wearing tyvek suits and gloves, and even warns against breathing near the sample (ex. mercury in dental fillings).

You might also check with your contractor to find out if they perform periodic equipment or field blanks as part of their Quality Control program? Do they have a Quality Control Program? Non-compliance is not a pleasant situation to be in and can lead to enforcement actions including fines and penalties. Don't take a chance, make sure that your samples are being collected properly to ensure that your data is "representative" of your discharge.

Tags: EPA, Compliance, Wastewater

Information gap…MWRA versus MassDEP…beware wastewater dischargers

Posted by Rebecca McDaniel on Mar 18, 2010 2:50:00 PM

By Sandy Perry, Director of Water Management and Wastewater Services

How do companies in Massachusetts know which regulations apply to their wastewater sewer discharge? It's interesting how much separation there is between a local authority, such as the Massachusetts Water Resource Authority, and the state authority, the MassDEP. Unfortunately the lack of outreach by either entity typically results in something being missed with respect to compliance.

In fact, no matter which sewer authority a facility in Massachusetts discharges to, wastewater treatment system plans and descriptions must be submitted to the MassDEP along with a staffing plan. Also, facilities are required to have an Operations & Maintenance Manual specific to their system. And depending on the volume discharged, you may need a MassDEP permit as well.

On the other hand, the MWRA (and most local authorities) are most concerned about the characteristics of the wastewater being discharged. They care only that it meets compliance with the sewer use ordinance, local limits, and/or specific permit limits. That is because they have a biological treatment system to protect and their own discharge limits to meet. In most instances you will be required to apply for a discharge permit. However, some of the smaller communities and sewer authorities may not require a permit if your discharge volume is low or you have no chemicals of concern in use.

So my best advice is to do your due diligence before starting up or relocating. Companies need to look into their regulatory obligations prior to moving and understand just what is required. And those already in operation, to be on the safe side, check to make sure that you have made the proper submittals to the MassDEP and/or local sewer authority. (A final word of caution - don't assume that the contractor that installed your treatment system took care of this for you.)

Tags: Wastewater Treatment, Wastewater

Regulatory Compliance: New Rules for Lithium Batteries

Posted by Rebecca McDaniel on Jan 14, 2010 9:34:00 AM

Doug Graham, CHMM Sr. Compliance Advisor & Training Manager

Yes, they’re at it again! Just when you thought you knew how to ship lithium batteries, DOT has thrown in yet another potential rule change.

Currently, there are exceptions for certain “small” lithium metal (primary) and lithium ion (rechargeable) batteries, wherein the DOT allows those batteries to be shipped under a special provision. If the batteries (including those in equipment) meet the requirements described in Special Provision 188 of 49 CFR 172.102, they need not comply with the entire scope of the hazardous materials regulations. DOT defines the maximum size of the batteries applicable to this provision based upon the amount of lithium within each cell and the total within each battery. The batteries that fall within this small-sized range are those we typically find inside cell phones, cameras, and laptop computers, and have power ratings under roughly 100 Watt-hours (Wh).

In a press release on January 8, 2010, the DOT is proposing to remove those exceptions for small lithium batteries, effectively making them fully regulated Class 9 hazardous materials like their medium and large-sized counterparts. The justification for the proposed rule change was explained by House Transportation and Infrastructure Chairman Jim Oberstar this way, "Under existing regulations, a flight crew may not be made aware of a pallet containing thousands of lithium batteries on board the aircraft, yet a five-pound package of flammable paint or dry ice would be subject to the full scope of the regulations. That makes little sense. . .”

To follow these developments regarding lithium battery shipping issues, and other emerging rules regarding DOT hazardous materials, log onto www.phmsa.dot.gov/hazmat . To view the proposed rule change (docket HM-224F) as published in the Federal Register on January 11, 2010, click on the following link: http://edocket.access.gpo.gov/2010/2010-281.htm. So. . . . . .keep your ear to the ground, if history’s any indicator, there’s sure to be more to come.

Tags: Hazardous Materials, DOT, Lithium Batteries, Training, Regulations, PHMSA, Trainings


Posted by Rebecca McDaniel on Jan 5, 2010 3:33:00 PM

Its Biennial Reporting time! The Biennial Report is a mandatory report pursuant to sections 3002 and 3004 of the Resource Conservation and Recovery Act (RCRA). You are required by Federal statue to complete and file a 2009 Hazardous Waste Report if your site is classified as a Large Quantity Generator (LQG) or you or treated, stored, or disposed of hazardous wastes on-site during 2009. Furthermore, some states may impose reporting requirements above and beyond the Federal requirements, such as mandating Small Quantity Generators (SQG) to file. The due date for this reporting year is March 1, 2010 for most states.

Reporting is done on a two-year cycle and the information is collected via the Hazardous Waste Report for the required reporting year. Reports describe each generated hazardous waste, the activity by which they generated the wastes, and the quantity. In addition the reports need to include the management method by which each waste was treated, recycled, or disposed and the quantity managed.

If you are unsure of applicability or are interested in assistance with completing the report, please contact Triumvirate’s consulting group for more information. We have Environmental Consultants ready to answer your questions.

Do I Really Need to Label Everything?

Posted by Rebecca McDaniel on Dec 23, 2009 10:43:00 AM

By Greg Brady, Operations Coordinator

One of the most important, but often overlooked, aspects of chemical management is the proper labeling of chemical containers. In the interest of safety, it is important that all chemicals, used and unused, are clearly labeled and if your facility has a Hazard Communication Plan, it is a requirement. It is crucial in maintaining a safe working environment that the people that are working at your facility are very clear on what they are working with. It is also essential in the event of an emergency response, that the people responding know what materials are in use as well as what materials may have been released. When managing chemicals that are considered hazardous waste, there are four essential requirements for your label:

• Containers must be labeled with the words “HAZARDOUS WASTE”.

• Containers must be labeled with all of the constituents. Constituents must be written clearly and completely without using abbreviations or chemical formulas. It’s also a good idea to use pencil instead of pen so that if the tag gets wet, the constituents can still be read.

• One or more of these four hazard classes must be checked: Ignitable, Corrosive, Reactive or Toxic. Additional information can be included on the tag for informational purposes such as oxidizer, but it is not required.

• Containers must be dated when they are full or no longer in use. Depending on your facility requirements, you must then dispose of the waste within a certain amount of time.

By following these simple guidelines, you can ensure that your facility continues to be a safe place to work while maintaining compliance.

Tags: Emergency Response, Safety, Compliance, Chemical Management

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

Lithium Battery EH&S Safety Concerns

Posted by Rebecca McDaniel on Dec 14, 2009 9:11:00 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.
  • 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.

Tags: Hazardous Materials, DOT, IATA, Lithium Batteries

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