Date: Thu, 28 Oct 2010 21:33:22 -0400
Reply-To: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
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From: ILPI <info**At_Symbol_Here**ILPI.COM>
Subject: Re: Lab safety showers
In-Reply-To: <00f101cb76ea$b2dfb020$189f1060$**At_Symbol_Here**edu>

Excellent.  With that lead from Mary, I was able to look up where shower water is apparently exempted:  http ://

Sec. 261.3  Definition of hazardous waste.
however, the following mixtures of solid wastes and hazardous wastes listed in subpart D of this part are not hazardous wastes (except by application of paragraph (a)(2)(i) or (ii) of this section) if the generator can demonstrate that the mixture consists of wastewater the discharge of which is subject to regulation under either section 402 or section 307(b) of the Clean Water Act (including wastewater at facilities which have eliminated the discharge of wastewater) and;

   (D) A discarded commercial chemical product, or chemical intermediate listed in Sec. 261.33, arising from de minimis losses of these materials from manufacturing operations in which these materials are used as raw materials or are produced in the manufacturing process. 
For purposes of this paragraph (a)(2)(iv)(D), ``de minimis'' losses include those from normal material handling operations (e.g., spills from the unloading or transfer of materials from bins or other containers, leaks from pipes, valves or other devices used to transfer materials); minor leaks of process equipment, storage tanks or containers; leaks from well maintained pump packings and seals; sample purgings; relief device discharges; discharges from safety showers and rinsing and cleaning of personal safety equipment; and rinsate from empty containers or from containers that are rendered empty by that rinsing; or

    (E) Wastewater resulting from laboratory operations containing toxic (T) wastes listed in subpart D of this part, Provided, That the annualized average flow of laboratory wastewater does not exceed one percent of total wastewater flow into the headworks of the facility's 
wastewater treatment or pre-treatment system or provided the wastes, combined annualized average concentration does not exceed one part per million in the headworks of the facility's wastewater treatment or pre-treatment facility. Toxic (T) wastes used in laboratories that are 
demonstrated not to be discharged to wastewater are not to be included in this calculation; or.....


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On Oct 28, 2010, at 5:54 PM, Mary Cavanaugh wrote:

I don=92t have time to dig it up right now, but there is an EPA letter of interpretation that says that runoff from an emergency drench shower is not hazardous waste.  So containment is only necessary if your local POTW is requiring it. 
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU]  ;On Behalf Of Alan Hall
Sent: Thursday, October 28, 2010 3:15 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject:& nbsp;Re: [DCHAS-L] Lab safety showers
I agree with Rob Torecki,
This is a senseless regulation that would do much more harm than good, and presents a slip-and-fall hazard full time, not just when the emergency shower is in use.
I also agree with how dilute most chemical splashes would be by the time you dilute them with 15 minutes **At_Symbol_Here** 20 gallons/minute = 300 gallons of water.
Alan H. Hall, M.D.

Date: Thu, 28 Oct 2010 14:55:20 -0400
From: info**At_Symbol_Here**ILPI.COM
Subject: Re: [DCHAS-L] Lab safety showers
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU

Wow, thanks for sharing.  That one is a poster child for Bad Regulations.
1. Let's say the berm encompasses a 4' x 4' area around the shower.  That's 16 square feet, one inch high, for a volume of 1.33 cubic feet = 10 gallons.  Under ANSI Z358, showers must put out at least 20 gallons per minute.  And that shower is likely to flow for 5, if not 15 minutes.  So the berm is essentially useless.
Now, if the reg is calling for a berm that say, stretches across an entire hallway or doorway - heck, or just around the drain itself, that might work by flooding the rest of the building, as all it does is make the floor drain non-functional.  Plugging the floor drain permanently is an easier solution.
2. The amount of hazardous material on a victim is going to be so exceedingly small and so diluted in the drains that it boggles the mind.  Seriously - you get what, 10 mL of concentrated acid on you and that washes down the drain with 100 gallons of water?   Yeesh.  And if the stuff was so nasty toxic that it is a hazard even that dilue, this city review department thinks it's better to spread the hazmat all over the building and down a couple floors onto various objects and people than it is to send it down the drain.
3. When you're blinded by something and trying to find a shower on foot or on a wheelchair, even that 1" sloped bump is a barrier.  And no doubt a trip hazard the rest of time no matter how well it's marked with floor tape.
Rob Toreki
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S afety Emporium - Lab & Safety Supplies featuring brand names
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Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012
On Oct 28, 2010, at 2:31 PM, Betsy Shelton wrote:

I am currently involved in construction of two new laboratories and was instructed by the city commercial building review department to include a 1" high curb around the shower area to keep hazmat from entering the floor drain in the event of a spill.  Also, the curb has to be sloped on both sides to allow accessibility.

Best regards,

Betsy Shelton

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