Jennifer, That DENR inspector may have been way off base. I was a RCRA for years and have logged more than 500 hazardous waste inspections. Those regulations - 40 CFR 262.34(c)(1)(I) and 265.173(a) - apply to hazardous waste. Other than the physical hazards you call "sharps", what was the residue that gave this waste it's hazardous characteristic, i.e., the EPA-defined hazardous waste codes? If there are no hazardous waste codes that apply to this waste, then 40 CFR 262.34(c)(1)(I) and 265.173(a) are totally irrelevant. If you don't know the answer to that question, then you should have been cited with 40 CFR 262.11 (c)(2) instead - failure to make a hazardous waste determination. Eric Eric J. Clark, MS, CCHO, CHMM Chemical Terrorism Coordinator Laboratory Response Network Oregon State Public Health Laboratory 1717 SW 10th Ave Portland, OR 97201 (503) 229-5592 Fax: (503) 229-5682 https://lrn.hr.state.or.us/home/h_contactus.cfm >>> "Young, Jennifer"
06/19/2007 2:14:25 PM >>> 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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