Good point. That citation might be non-enforceable by that agency if it's not what they do. When I did hazardous waste inspections, my focus was all RCRA. However, from time to time I'd see something egregious that would come under the category of "Other Areas of Concern" such as a welding station located right next to a solvent storage area, or an un-guarded drive belt. I'd include those non-RCRA things in my report so that if, for example, the place burned to the ground a week later, the probable cause would have already come to the attention of the facility owner prior to the fire. Although these items were non-enforceable by my agency, we'd mention it (a) as a legitimate safety concern (b) to clear the inspector of any implied neglegence and (c) to keep the agency from being blamed for something like that in the press. >>> "Diane Amell"
06/21/2007 8:46:01 AM >>> Part of the issue may be that the sharps container requirement under OSHA only applies to waste materials contaminated with blood or "other potentially infectious materials" under the Bloodborne Pathogens standard. (Or, as it is known in MN environmental agencies, "infectious waste".) While it sounds like a good idea to me on the behalf of your employees to use the sharps container for safety purposes, we do not require it. This may be why the inspector raised his or her objections. My experience, at least in Minnesota, is that environmental agency employees specialize in one area and are usually not familiar with other environmental areas, much less OSHA regulations. - Diane Amell, MNOSHA >>> "Young, Jennifer" 6/20/2007 8:04 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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