Date: Tue, 19 Jun 2007 17:14:25 -0400
Reply-To: "Young, Jennifer" <Jennifer.Young**At_Symbol_Here**TARGACEPT.COM>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: "Young, Jennifer" <Jennifer.Young**At_Symbol_Here**TARGACEPT.COM>
Subject: "open" sharps containers
I could use some help about how to respond to a DENR inspection
violation regarding an open sharps container.  We were cited for
violating 40 CFR 262.34(c)(1)(I) and 265.173(a), which states "that a
container holding hazardous waste must always be closed during storage,
except when it is necessary to add or remove waste."  I understand that,
but a sharps container is designed such that once it is closed, it
cannot be reopened.  Only the small flap for adding sharps was open, but
is has to be open.  It would be quite a danger for the chemists to have
to try to pry open the container when they had a syringe to dispose of.
(This is a large, 7 gallon bucket-type container, with a flat lid that
is hinged and a flap that leaves an open space for adding the
syringes/needles, not the small wall-hanging or tabletop kind.)  How
does one keep the waste container closed when it is designed to be open
like that?  How do I respond?  Any advice you could give would be great.
Jennifer A. Young, Ph.D.
Targacept, Inc.
336 480-2182

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