From: Monona Rossol <actsnyc**At_Symbol_Here**>
Subject: Re: [DCHAS-L] Pressure release requirements on laboratory waste containers?
Date: Wed, 27 Jan 2016 08:32:08 -0500
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 1528348bf10-3b0d-15b**At_Symbol_Here**
In-Reply-To <024601d15894$f5485f20$dfd91d60$**At_Symbol_Here**>

Bruce.  Thanks so much.  This is a simple and elegant way to do this and it will be in all my reports from this time on.  And while the inquiry was about solvents, another issue for art and theater is collection of water based paint waste that contains regulated metal-containing pigments and dyes.  The biocides in these acrylic and other types of plastic emulsion materials fail with dilution, mold and bacteria establish quickly and can build up pressure as well.   And with a cap like this the odor should be reduced.  

Monona Rossol, M.S., M.F.A., Industrial Hygienist
President:  Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
181 Thompson St., #23
New York, NY 10012     212-777-0062


-----Original Message-----
From: Bruce Van Scoy <bvanscoy**At_Symbol_Here**TWC.COM>
Sent: Tue, Jan 26, 2016 7:46 pm
Subject: Re: [DCHAS-L] Pressure release requirements on laboratory waste containers?

Thanks Kyle!  I had not heard of Circumvent caps previously.  Well done, BruceV
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**] On Behalf Of Kyle J. Angjelo
Sent: Tuesday, January 26, 2016 12:59 PM
Subject: Re: [DCHAS-L] Pressure release requirements on laboratory waste containers?
Dear Nancy,
                Simply leaving the lid off in terms of waste is a non-compliance with respect to RCRA Act 40 CFR 265.173(a).  If it's unprocessed solvents it is most likely a non-compliance with your state's version of International Fire Code.  Having pressure relief valves which will frequently vent with liquids with high vapor pressure may also pose an issue with some of what's outlined in your institution's chemical hygiene plan and in terms of best practice when controlling chemical vapors. 
                I worked in an organosilanes industry plant before I stopped my bench work and moved to safety.  Pressure relief valves and caps should be rated with high enough of a pressure relief where common "volatile" chemicals won't naturally trigger release anyway.  Pressure relief caps should be rated at a pressure below (but not too far below) the pressure where concern for the condition of the container becomes pertinent.  We had plenty of wastes that we were worried about building pressure and rupturing; we had no pure solvents that had high enough of a vapor pressure where we were worried about over-pressurization or "frozen" caps (even in the summer). 
                Princeton EHS has purchased Circumvent caps for wastes that may spontaneously build pressure.  They comply with RCRA which require containers to be closed and also with International Fire Code NJ Edition 2006 in keeping our stock containers closed.  You can buy sizes that fit standard 2.5L and 4L amber glass solvent bottles.  The link is below.
Best Regards,
Kyle Angjelo
Chemical Program Manager
Princeton University EHS
262 Alexander St.
Princeton, NJ 08544
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Richardson, Nancy A
Sent: Tuesday, January 26, 2016 12:45 PM
Subject: [DCHAS-L] Pressure release requirements on laboratory waste containers?
A colleague asked me if there were ever requirements for pressure release valves on lab waste collection containers particularly for very volatile liquids.
In absence of a pressure release valve, some wonder if one can simply "leave the lid off" which seems to be a problem from many perspectives.
If there are any best practices that can be sited or regulations, I would be interested. 

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