Date: Tue, 2 Nov 2010 17:31:25 -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: ILPI <info**At_Symbol_Here**ILPI.COM>
Subject: Re: FW: Lab safety showers
t think any private code trumps the Feds. Except where private
codes are incorporated by reference.
manager might get away with not installing plumbed eye washes or drench
hoses, as you can use portable units that will supply the required flow,
but there is no way you can avoid plumbing a shower - 20 gallons per
minute for 15 minutes would require a huge
On Nov 2,
2010, at 4:56 PM, Margaret Rakas wrote:
Of course you are correct that it doesn't make
sense. But I just left a meeting where a very upset project
manager INSISTED eyewashes cannot be plumbed due to the possibility of
contamination (the engineer told him it was code...) This makes
even less sense, but as I will spend a good amount 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day or two trying to determine WHICH code, and whether it is superseded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.
personal opinion only, not business or legal advice, and may not reflect
the opinion of my employer...
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 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 =85 M.A
I might be mistaken, but
the placement of the berm, will violate the life safety code (and
rleated bulding codes) regarding smooth, trip free walking surfaces. I
believe this limitation is 1/8".
On top of this, this
triping hazard will directly compound & negatively affect the
worker's compensation exposure for the associated employees.
would think that the this trumps the local water / sewer inspectors
Thank you for the citation,
Mary, if you run across the letter of
interpretation sometime in the future, would you post it here for
Teledyne Energy Systems
Subject: Re: Lab safety
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
(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)
(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
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
(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
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.....
Safety Emporium - Lab & Safety
Supplies featuring brand names
Fax: (856) 553-6154, PO Box 1003,
Blackwood, NJ 08012
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.
Subject: Re: [DCHAS-L]
Lab safety showers
I agree with Rob
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.
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
Alan H. Hall, M.D.
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
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
- Lab & Safety Supplies featuring brand names
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
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