DCHAS-L Archives Feb 17 2011 - Re: [NAOSMM] Expiration dates of chemicals/regulations

--0-829485659-1297977095=:55116 All, =C2=A0 Not sure where I read it - maybe Lab Standard, RCRA or some other EPA rule, Prudent Practices, Chemical Health & Safety, not really sure=C2=A0(could b e a best practice recommendation) - something like chemicals should only be stored for a year, then dispose or waste out. =C2=A0 I know in OSHAland, whatever the manufacturer recommends, you follow, wheth er it makes sense or not. =C2=A0 I advise my clients during inspections to replace any chemicals older than a year. That helps eliminate the inherently waste-like, speculative accumul ation, etc=C2=A0practices EPA folks like to cite. =C2=A0 My personal best practice advice. Bill Parks CHST, CHMP, CEHT, LSP, RPIH CHEMPHYXX......is now LinkedIn 630/380-4032 **Providing sound Industrial Hygiene, Occupational Health and Safety, Envir onmental Health & IAQ, Environmental Science, and Laboratory support servic es and solutions** --- On Thu, 2/17/11, Rita Kay Calhoun wrote: From: Rita Kay Calhoun Subject: Re: [DCHAS-L] [NAOSMM] Expiration dates of chemicals/regulations To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU Date: Thursday, February 17, 2011, 2:25 PM But what regulation requires that you get rid of a chemical that you haven =E2=80=99t used in a year or more?=C2=A0=C2=A0 There=E2=80=99s a difference between a suggestion and a regulation isn=E2=80=99t there?=C2=A0 In academ ia, especially in small schools, upper level courses may not be taught ever y year.=C2=A0 Also, according to who is teaching the chemicals needed might change.=C2=A0 To pay to dispose of, and then to purchase again in four or five years a perfectly stable chemical is wasteful, and usually we have to watch how we spend =C2=A0our money.=C2=A0 =C2=A0We also often need small am ounts of a variety of compounds for unknowns. =C2=A0 Kay =C2=A0 From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of Ki m Auletta Sent: Thursday, February 17, 2011 2:25 PM To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU Subject: Re: [DCHAS-L] [NAOSMM] Expiration dates of chemicals/regulations =C2=A0 Our state Haz Waste inspectors call this "inherently waste -like" and love to cite us for it. The researchers always argue they might need it some day . Guess who looses? Kim Auletta Lab Safety Specialist EH&S =C2=A0 =C2=A0Z=6200 Stony Brook University kauletta**At_Symbol_Here**notes.cc.sunysb.edu 631-632-3032 FAX: 631-632-9683 EH&S Web site: http://www.stonybrook.edu/ehs/lab/ Remember to wash your hands! From: Jeff Your To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU Date: 02/17/2011 02:11 PM Subject: Re: [DCHAS-L] [NAOSMM] Expiration dates of chemicals/regulations Sent by: DCHAS-L Discussion List =C2=A0 As regards old containers sitting on the shelf, I have heard many 'opinions ' that regulators will offer. =C2=A0 If the bottle is expired, is there a good reason for keeping it? =C2=A0Is i t actively in use for research or instructional purposes? If the bottle looks old and you cannot document its regular circulation, th en some instectors use the 'white glove' test. =C2=A0If I can wipe dust off the top of the container, it's probably not being used and hasn't been for some time. =C2=A0Now the question becomes, Why are you keeping it? =C2=A0R CRA has a term for this: speculative accumulation. See article below. =C2=A0While spec.accum. specifically addresses certain h azardous wastes which could be recycled, it has also been applied to the si tuation of holding on to lots of old chemicals with no stated present or fu ture purposes other than 'just in case we may need it some day'. So, have a real good idea what is being actively used in your teaching labs . =C2=A0Get rid of anything you can justify will not be used within the nex t year, expired or not. =C2=A0This is an iterative process as profs will pu t up resistance to throwing away 'perfectly good' reagents from the 1950's. =C2=A0Weed regularly and a little at a time. http://www.lion.com/newsletter/archives/2009/vol10issue47.asp Speculative accumulation happens. Keeping in mind that the term "speculative accumulation=" is defined only for the purpose of determining if a material is a solid waste [40 CFR 261.2(c)], the EPA=E2=80=99s definition, at section 40 CFR 261.1(c )(8) starts simply with "A material is =E2=80=98accumulated specula tively=E2=80=99 if it is accumulated before being recycled.=" But if we continue reading, we find that you may claim your recycling as le gitimate, and your accumulation as NOT speculative, if you meet two conditi ons: 1. =C2=A0 =C2=A0 =C2=A0 =C2=A0A feasible means of recycling the material ex ists, and 2. =C2=A0 =C2=A0 =C2=A0 =C2=A0At least 75% of the material on-hand on Janua ry 1 is recycled by the end of the year. Remember to document everything! In any enforcement action, the burden of p roof is on the generator to show that the waste is excluded and being legit imately recycled. [40 CFR 261.2(f)] That is, it is up to you to prove to th e regulators that the material is not being speculatively accumulated. On the other hand, if you stockpile hazardous secondary material, make no a rrangements to recycle it, all the while claiming that it will be recycled later, the EPA will ask you to prove that the recycling is legitimate, feas ible, and actually happening. If you cannot do this, then you are " accumulating speculatively.=" What happens next is, the waste will b e reclassified as solid, and possibly as hazardous, waste, and you will get to know your local agency very well. As always, state regulations may vary. Not every authorized state program p ermits every recycling relief, and your state may have particular standards for documenting your recycling activities. -- Jeffrey A. Your, M.B.A.,C.S.M.M. Science Buyer; Central Scientific Stores and Laboratory Support Services =C2=A0 John Carroll University =C2=A0 20700 North Park Blvd. =C2=A0 =C2=A0 =C2=A0 =C2=A0 =C2=A0 University Hts, Ohio 44118-4578 =C2=A0 =C2=A0 216.397.4244 vox =C2=A0 =C2=A0 =C2=A0216.397.1803 fax =C2=A0216.496.7594 ce ll ---- Original message ---- Date: Thu, 17 Feb 2011 09:58:23 -0800 From: Teresa Arnold Subject: [NAOSMM] Expiration dates of chemicals/regulations To: dchas-l , NAOSMM I had a question come to me from a High School, who is being dinged by a re gulatory person. I don't have a definitive answer/source. =C2=A0 Can you he lp? One major question I have is the idea of "shelf life=". =C2=A0As a che mist, I know that some chemicals degrade over time. =C2=A0But the ones that create a hazard upon d egrading are few and far between. =C2=A0What are the rules about shelf life particul arly for inherited old chemicals? =C2=A0What actions are required and what are merel y suggested? Thanks! Teresa Arnold George Fox University Biology-Chemistry Lab Coordinator tarnold**At_Symbol_Here**georgefox.edu 503-554-2724 Fax: 503-554-3884 414 N. Meridian St. =C2=A0#6144 Newberg, OR =C2=A097132 --0-829485659-1297977095=:55116

All,

Not sure where I read it - maybe Lab Standard, RCRA or some other EPA rule, Prudent Practices, Chemical Health & Safety, not really sure ;(could be a best practice recommendation) - something like chemicals shoul d only be stored for a year, then dispose or waste out.

I know in OSHAland, whatever the manufacturer recommends, you follow, whether it makes sense or not.

I advise my clients during inspections to replace any chemicals older than a year. That helps eliminate the inherently waste-like, speculative ac cumulation, etc practices EPA folks like to cite.

My personal best practice advice.

Bill Parks
CHST, CHMP, CEH T, LSP, RPIH
CHEMPHYXX......is now LinkedIn
630/380-4032

**Pro viding sound Industrial Hygiene, Occupational Health and Safety, Environmen tal Health & IAQ, Environmental Science, and Laboratory support service s and solutions**

--- On Thu, 2/17/11, Rita Kay Calhoun <r. calhoun**At_Symbol_Here**MOREHEADSTATE.EDU> wrote:

From: Rita Kay Calhoun <r.calhoun**At_Symbol_Here**MOREHEADSTAT E.EDU>
Subject: Re: [DCHAS-L] [NAOSMM] Expiration dates of chemicals/ regulations
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Date: Thursday, February 17, 201 1, 2:25 PM

But what regulation requires that y ou get rid of a chemical that you haven=E2=80=99t used in a year or more? There=E2=80=99s a difference between a suggestion and a regulati on isn=E2=80=99t there? In academia, especially in small schools, upp er level courses may not be taught every year. Also, according to who is teaching the chemicals needed might change. To pay to dispose of, and then to purchase again in four or five years a perfectly stable chemic al is wasteful, and usually we have to watch how we spend our money.& nbsp; We also often need small amounts of a variety of compounds for unknowns.

Kay

From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of Kim Auletta
Sent: Thursday, February 17, 2011 2:25 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L ] [NAOSMM] Expiration dates of chemicals/regulations

Our state Haz Waste inspect ors call this "inherently waste -like" and love to cite us for it. The rese archers always argue they might need it some day. Guess who looses?

Kim Aule tta
Lab Safety Specialist
EH&S Z=6200
Stony Bro ok University
kauletta**At_Symbol_Here**notes.cc.sunysb.edu
631-632-3032
FAX: 631-6 32-9683
EH&S Web site: http://www.stonybrook.edu/ehs/lab/

Remember to wa sh your hands!

From:

Jeff Your <jyour**At_Symbol_Here**JCU.EDU>

To:

DCHAS-L**At_Symbol_Here**LIST.UVM.EDU

Date:

02/17/2011 02:11 PM

Subject:

Re: [DCHAS-L] [NAOSMM] Expiration dates of chemicals/regu lations

Sent by:

DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>

As regards old containers sitt ing on the shelf, I have heard many 'opinions' that regulators will offer.
If the bottle is expired, is there a good reason for keeping it? ;Is it actively in use for research or instructional purposes?

If the bottle looks old and you cannot document its regular circulatio n, then some instectors use the 'white glove' test. If I can wipe dus t off the top of the container, it's probably not being used and hasn't bee n for some time. Now the question becomes, Why are you keeping it? RCRA has a term for this: speculative accumulation.

See article below. While spec.accum. specifically addresses cert ain hazardous wastes which could be recycled, it has also been applied to t he situation of holding on to lots of old chemicals with no stated present or future purposes other than 'just in case we may need it some day'.

So, have a real good idea what is being actively used in your teaching labs. Get rid of anything you can justify will not be used within th e next year, expired or not. This is an iterative process as profs wi ll put up resistance to throwing away 'perfectly good' reagents from the 19 50's. Weed regularly and a little at a time.

http://www.lion.com/newsletter/archives/ 2009/vol10issue47.asp

Speculative accumulation happens.

Keeping in mind that the term "speculative accumulation=E2=80 =9D is defined only for the purpose of determining if a material is a solid waste [40 CFR 261.2(c)], the EPA=E2=80=99s definition, at section 40 CFR 2 61.1(c)(8) starts simply with "A material is =E2=80=98accumulated s peculatively=E2=80=99 if it is accumulated before being recycled.="

But if we continue reading, we find that you may claim your recycling as legitimate, and your accumulation as NOT speculative, if you meet two co nditions:
1. A feasible means of recycling the materi al exists, and
2. At least 75% of the material on-han d on January 1 is recycled by the end of the year.

Remember to document everything! In any enforcement action, the burden of proof is on the generator to show that the waste is excluded and being legitimately recycled. [40 CFR 261.2(f)] That is, it is up to you to prove to the regulators that the material is not being speculatively accumulated.

On the other hand, if you stockpile hazardous secondary material, make no arrangements to recycle it, all the while claiming that it will be recy cled later, the EPA will ask you to prove that the recycling is legitimate, feasible, and actually happening. If you cannot do this, then you are =E2 =80=9Caccumulating speculatively.=" What happens next is, the waste will be reclassified as solid, and possibly as hazardous, waste, and you wi ll get to know your local agency very well.

As always, state regulations may vary. Not every authorized state prog ram permits every recycling relief, and your state may have particular stan dards for documenting your recycling activities.

--
Jeffrey A. Your, M.B.A.,C.S.M.M.
Scien ce Buyer; Central Scientific
Stores and Laboratory Support Serv ices
John Carroll University
20700 No rth Park Blvd.
University Ht s, Ohio 44118-4578

216.397.4244 vox 216.397.1803 fax 216.496.7594 cell

---- Original message ----
Date: Thu, 17 Feb 2011 09:58:23 - 0800
From: Teresa Arnold <tarnold**At_Symbol_Here**georgefox.edu>
Subj ect: [NAOSMM] Expiration dates of chemicals/regulations
To: d chas-l <dchas-l**At_Symbol_Here**list.uvm.edu>, NAOSMM <naosmm**At_Symbol_Here**mailman.rice.edu>

I had a question come to me from a High School, who is being di nged by a regulatory person. I don't have a definitive answer/source. Can you help?
One major
question I have is the idea of "shelf life=". As a chemist, I know that some
chemicals degrade over time. ;But the ones that create a hazard upon degrading
are few and far betwee n. What are the rules about shelf life particularly for
inherited old chemicals? What actions are required and what are merely
sugge sted?

Thanks!
Teresa Arnold

George Fox University

Biology-Chemistr y Lab Coordinator

tar nold**At_Symbol_Here**georgefox.edu

503-554-2724
Fax: 503-554-3884

414 N. Meridian St. #6144
Newberg, OR 97132

--0-829485659-1297977095=:55116--

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