Since I know for a fact that regulators refuse to define "closed container" (I have asked) the simplest answer is to find a different container that can be closed when not "adding or removing waste". Below are links for a couple of possible options. You may have to buy a couple of different types to determine if they can be temporarily "closed" as they promote in their descriptions. Good Luck. http://www.plastiproducts.com/text/detailpage.tmpl?command=showpage&sn=45403&sku=Mouth&cart=118234920576732&location=1 http://www.hopkinsmedicalproducts.com/product.jsp?path=-1|1047&id=1054 https://www1.vaxserve.com/index.cfm?event=getProductDetail&product_id=2457&cat_id=42 http://www.americancorporateservices.com/index.php/fuseaction/products.details/catid/13875/id/13876.php Words of Wisdom: Never Over-estimate the power of common-sense & logic when placed in the hands of a regulator or Govt. official that can $fine$ you. Robert Blomberg Talley Defense Systems, Inc. Environmental Quality Specialist Phone: 480-898-2433 Fax: 480-898-2410 Cell: 480-226-0607 REMEMBER - ALWAYS BE SAFE! This transmission may contain information that is privileged, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or use of the information contained herein (including any reliance thereon) is STRICTLY PROHIBITED. If you received this transmission in error, please immediately contact the sender and destroy the material in its entirety, whether in electronic or hard copy format. >>> "Young, Jennifer"
6/20/2007 6:04 AM >>> The flap is large enough that yes, the sharps might spill out if it is turned over. And yes, they are contaminated with hazardous waste--a number of P-listed chemicals are dispensed by syringe and then the syringe and needle (with only barely a residue of chemical) are placed in the sharps container. No liquid waste is present. But if you close the flap, you cannot open it again. I have a picture of one, but cannot post it. If you click the link, you can see the picture, it is the large container in the back with the hinged flap. http://www.labsafety.com/search/sharps/9543/ We're using Biohazard sharps containers, then removing the Biohazard label and affixing a HazWaste label instead. They are listed as meeting OSHA standards, but not anything about RCRA. If anyone knows of a source for chemical waste sharps, that would be great. -----Original Message----- From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of Debbie Decker Sent: Tuesday, June 19, 2007 8:12 PM To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU Subject: Re: [DCHAS-L] "open" sharps containers 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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