Date: Tue, 2 Nov 2010 13:16:24 -0700
Reply-To: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: "Alnajjar, Mikhail S" <ms.alnajjar**At_Symbol_Here**PNL.GOV>
Subject: Re: FW: Lab safety showers
In-Reply-To: <AANLkTin0GymZWxE-po2Yny-6PtgfnmyxcEX_ZaO=jDqR**At_Symbol_Here**>

To be honest with all those who are interested in this topic , the berm idea does not make any sense considering the rare events where showers are used.  As it was mentioned, the hazardous materials are so diluted tha t it is not logical to flood the floor (building) for the sake of preventing tra ce amounts of hazardous materials from going down the drain.   

Thanks … M.A

From: DCHAS-L Discu ssion List [mailto:DCHAS-L**At_Symbol_Here**] On Behalf Of Alan McCartney
Sent: Tuesday, November 02, 2010 10:50 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] FW: Lab safety showers

I might be mistaken, bu t the placement of the berm, will violate the life safety code (and rleated buldi ng codes) regarding smooth, trip free walking surfaces. I believe this limitat ion is 1/8". 

On top of this, this triping hazard will directly compound & negatively affect the worker's compensation exposure for the associated employees.

I would think that the this trumps the local water / sewer inspectors reque st.


On Mon, Nov 1, 2010 at 9:18 AM, Williams, Mark <Mark.Williams**At_Symbol_Here**> wrote:

Thank you for the citation, Rob!

Mary, if you run acr oss the letter of interpretation sometime in the future, would you post it here for us?




From: ILPI [mailto: info**At_Symbol_Here**ILPI.COM]
Sent: Thursday, October 28, 2010 9:33 PM

Subject: Re: Lab safety showers


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


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 waste s (except by application of paragraph (a)(2)(i) or (ii) of this section) if t he generator can demonstrate that the mixture consists of wastewater the disch arge 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 eliminat ed 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 operat ions 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 materia ls from bins or other containers, leaks from pipes, valves or other devices us ed 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 emp ty containers or from containers that are rendered empty by that rinsing; or


    (E) Wastewate r 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-trea tment system or provided the wastes, combined annualized average concentration do es 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 discharge d to wastewater are not to be included in this calculation; or.....< /o:p>




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

I don’t 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

Subject: 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 whe n the emergency shower is in use.
I also agree with how dilute most chemical splashes would be by the time yo u dilute them with 15 minutes **At_Symbol_Here** 20 gallons/minute = 300 gallons of wat er.
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

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 gallo ns.  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 hallw ay or doorway - heck, or just around the drain itself, that might work by floo ding 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.  Seriousl y - you get what, 10 mL of concentrated acid on you and that washes down the dr ain with 100 gallons of water?   Yeesh.  And if the stuff was so nast y toxic that it is a hazard even that dilue, this city review department thin ks it's better to spread the hazmat all over the building and down a couple fl oors onto various objects and people than it is to send it down the drain.< /o:p>


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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you know and trust.  Visit us at

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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 f loor drain in the event of a spill.  Also, the curb has to be sloped on bot h sides to allow accessibility.


Best regards,

Betsy Shelton
retrosynthesi s**At_Symbol_Here**


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