Jennifer: I think the regulation goes on to state that the container must be closed so that if the container is upended, no waste will leak out (or words to that effect). Will waste leak out of the sharps container if the container is upended? If no waste leaks out, then I think you could argue that the performance of the container meets the regulation. I'm curious, though - are the sharps contaminated with hazardous materials? If you're disposing as hazardous waste, that would be the assumption but I just wanted to make sure.
Debbie ------------------------ Debbie Decker EH&S UCDavis (530)754-7964 FAX (530)752-4527 dmdecker**At_Symbol_Here**ucdavis.edu Co-Conspirator to Make the World A Better Place -- Visit www.HeroicStories.com and join the conspiracy Birkett's hypothesis: "Any chemical reaction that proceeds smoothly under normal conditions, can proceed violently in the presence of an idiot." -----Original Message----- From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of Young, Jennifer Sent: Tuesday, June 19, 2007 2:14 PM To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU Subject: [DCHAS-L] "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 Jennifer.Young**At_Symbol_Here**Targacept.com
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