Date: Wed, 20 Jun 2007 09:28:24 -0700
Reply-To: Robert Blomberg <RBlomberg**At_Symbol_Here**TALLEYDS.COM>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Robert Blomberg <RBlomberg**At_Symbol_Here**TALLEYDS.COM>
Subject: Re: "open" sharps containers
Comments: To: Jennifer Young
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.|1047&id=1054
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


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>>> "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.

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


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 Decker
EH&S UCDavis
FAX (530)752-4527
Co-Conspirator to Make the World A
Better Place -- Visit and join the conspiracy

Birkett's hypothesis: "Any chemical reaction that proceeds smoothly
under normal conditions, can proceed violently in the presence of an

-----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

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