Date: Tue, 2 Nov 2010 16:56:13 -0400
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: Margaret Rakas <mrakas**At_Symbol_Here**SMITH.EDU>
Subject: Re: FW: Lab safety showers
In-Reply-To: <2AF7FC1106E2C841A71E5EE896E4897A017BD2F853A2**At_Symbol_Here**>

Of course you are correct t hat it doesn't make sense.  But I just left a meeting where a ve ry upset project manager INSISTED eyewashes cannot be plumbed due to the possibility of contamination (the engineer told him it was code... 1;  This makes even less sense, but as I will spend a good amoun t of time in the next day or two trying to determine WHICH code, and whether it is superseded by another, etc etc I would like to suggest that CHAS find some way to officially work with the code-setters, at least on lab-related issues.  

My personal opinion only 4; not business or legal advice, and may not reflect the opinion of m y employer...


> >> "Alnajjar, Mikhail S" <ms.alnajjar**At_Symbol_Here**PNL.GOV> 11/2/2010 4:16 PM >>>

To be honest with all those who are intere sted in this topic, the berm idea does not make any sense considering the rare events where showers are used.  As it was mentioned 4; the hazardous materials are so diluted that it is not logical to flood the floor (building) for the sake of preventing trace amounts of hazardous materials from going down the drain.   


Thanks … M.A


From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here** #93; On Behalf Of Alan McCartney
Sent: Tuesday, November 02& #44; 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, but the placement of the berm, will violate the life safety code (and rleated bulding codes) regardin g smooth, trip free walking surfaces. I believe this limitation is 1/ 8". 

On top of this, this triping hazard will direct ly compound & negatively affect the worker's compensation exposur e for the associated employees.

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


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

Thank you for the citati on, Rob!

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





Mark Williams

Teledyne Energy Systems Inc.

38 Loveton Cr

Sparks MD 21152


mark.williams**At_Symbol_Here**< o p="#DEFAULT">


From: ILPI [mailto:info**At_Symbol_Here**ILPI.COM]
Sent: Thursday, October 28& #44; 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: m


Sec. 261.3  Definition of hazardous w aste.


however, the following mixtures of soli d wastes and hazardous wastes listed in subpart D of this part are not ha zardous wastes & #40;except by application of paragraph (a)(2)(i) or (ii) of this section) if the generator can demonstrate tha t the mixture consists of wastewater the discharge of which is subject to regulation under either section 402 or section 307(b) of the Cle an Water Act (including wastewater at facilities which have eliminate d the discharge of wastewater) and;



   (D) A discarded comme rcial chemical product, or chemical intermediate listed in Sec. 261.3 3, arising from de minimis losses of these materials from manufacturi ng operations in which these materials are used as raw materials or are p roduced 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., sp ills from the unloading or transfer of materials from bins or other conta iners, 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 s afety showers and rinsing and cleaning of personal safety equipment;< /b> and rinsate from empty containers or from containers that are re ndered 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 a verage 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 o r provided the wastes, combined annualized average concentration does not exceed one part per million in the headworks of the facility's w astewater treatment or pre-treatment facility. Toxic (T) wastes u sed in laboratories that are 

demonstrated not to be discharged to wastewate r 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’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 containme nt is only necessary if your local POTW is requiring it. 


From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UV M.EDU] On Behalf Of Alan Hall
Sent: Thursday 4; 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, a nd presents a slip-and-fall hazard full time, not just when the emergency shower is in use.
I also agree with how dilute mos t 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: 60;info**At_Symbol_Here**ILPI.COMSubject: Re: [DCHAS-L] Lab safety showers

Wow, thanks for sharing.  That one i s 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, o ne inch high, for a volume of 1.33 cubic feet = 10 gallons. & #160;Under ANSI Z358, showers must put out at least 20 gallons per mi nute.  And that shower is likely to flow for 5, if not 15 mi nutes.  So the berm is essentially useless.


Now, if the reg is calling for a berm that sa y, 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 i s going to be so exceedingly small and so diluted in the drains that it b oggles the mind.  Seriously - you get what, 10 mL of concent rated acid on you and that washes down the drain with 100 gallons of wate r?   Yeesh.  And if the stuff was so nasty toxi c that it is a hazard even that dilue, this city review department th inks 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 dow n the drain.


3. When you're blinded by something and tryin g to find a shower on foot or on a wheelchair, even that 1" slop ed bump is a barrier.  And no doubt a trip hazard the rest of ti me no matter how well it's marked with floor tape.< /o>


Rob Toreki


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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 de partment to include a 1" high curb around the shower area to keep ha zmat from entering the floor drain in the event of a spill.  Als o, the curb has to be sloped on both sides to allow accessibility.


Best regards,

Betsy Shelton
512.636 .1905
retrosynthesis**At_Symbol_Here** < /p>


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