Date: Sat, 31 Mar 2007 06:43:36 -0400
Reply-To: Ralph Stuart <rstuart**At_Symbol_Here**UVM.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Ralph Stuart <rstuart**At_Symbol_Here**UVM.EDU>
Subject: Re: [CSHEMA-L] University of Washington Hazardouse Waste Incident

On March 8, I posted a press report on a hazardous waste situation at  
the University of Washington. Here is a statement from the Director  
of the Environmental Health and Safety that clarifies some of the  
points left dangling in the newspaper story.

- Ralph

	From: 	  kav**At_Symbol_Here**U.WASHINGTON.EDU
	Subject: 	Re: [CSHEMA-L] University of Washington Hazardouse Waste  
Incident
	Date: 	March 30, 2007 9:23:15 PM EDT (CA)
	To: 	  CSHEMA-L**At_Symbol_Here**LISTS.UMN.EDU

Over the past several weeks there have been many comments about the
University of Washington and its hazardous waste program because of an
extremely unfortunate incident involving one of our faculty members.
While I can't reveal the full story or the final outcome of the  
incident,
there are a couple of things that I do need to say.

First, the UW has a well established and excellent hazardous chemical
waste management program. We safely manage approximately 200 tons of
chemical hazardous waste each year from over 3500 chemical use areas. We
have a successful, award winning pollution prevention program and are
leaders in recycling hazardous materials.  We have developed both in
person and on-line training for University employees. We work closely  
with
a University Chemical Hazards Advisory Committee (CHAC) that is  
chaired by
a faculty member and has other faculty members in attendance. A  
number of
our hazardous waste and chemical hazard issues are reviewed by that  
group.
The University had inspections by the regulatory authorities in the last
two years and had no major regulatory violations.

  I am extremely proud of the staff in EH&S who make it all  
possible.  In
the case under review they have done absolutely everything right and are
held in the highest respect by the regulating community.  As a  
director, I
could not ask for a better team.

Second, the routine hazardous waste disposal is paid for by the central
budget, not by the researchers.  There are two situations where the
laboratory or department is asked to pay for certain costs before  
disposal
occurs.  One is the identification of "unknown" chemicals found in a
laboratory; we usually charge approximately $80 per unknown to cover the
costs of the analysis. The other is the management of outdated peroxide
forming chemicals that are too dangerous for the laboratory staff to
manage.  A visit from a contractor to stabilize the chemicals costs  
about
$5000 and involves the coordination of the UW Police Department and the
Seattle Fire Department and requires a City of Seattle Reactive
Stabilization permit. We work closely with the researcher/laboratory
manager in preparing for these visits. We try to help the labs and
minimize costs by keeping a list of these chemicals found in  
laboratories
throughout the campus and scheduling the contractor to come once or  
twice
a year to stabilize all the chemicals on the list.  This coordinated
effort usually decreases the cost to less than $500 per container,
depending on the number of containers being handled. This approach has
been in place for many years and ordinarily works well.

Lastly, the UW has a long standing Peroxide Management Protocol that
allows researchers to test for and stabilize peroxides themselves, if it
can be done safely. This guidance is posted on our website at
http://www.ehs.washington.edu/form/epo/peroxideguidelines.pdf. In most
cases the peroxide forming chemicals are tested, found to have peroxide
concentrations less than 10 ppm, and once stablized are disposed of
through the regular hazardous waste management stream at no charge.  But
if the chemical does not meet the safety criteria (i.e. is very old,  
shows
signs of deterioration, has evaporated or has visible crystals present),
it is determined that the chemical cannot be safely tested and  
treated by
the researcher.  In such a situation, the contractor is scheduled to  
test
and stabilize the chemicals as described above.

In the recent instance, EH&S was working with the Lab Manager on the
proper management of 5 containers of outdated ethers.  When the  
materials
were discovered missing, the University self-reported the situation  
to the
Washington State Department of Ecology and EPA. This is consistent with
the long standing commitment to compliance that exemplifies the  
University
of Washington.

For now, that's about all I can say, but I hope I have answered some of
your questions about our program and this incident.

Feel free to give me a call.


Karen VanDusen, Director
Environmental Health and Safety
University of Washington
206-616-4146

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