From: Jeff Tenney <jtenney46**At_Symbol_Here**ATT.NET>
Subject: Re: [DCHAS-L] flammable hazardous waste
Date: Wed, 18 Dec 2019 08:01:53 -0500
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: 201912181301.xBID1sQ9032491**At_Symbol_Here**

Usually the line coming out of the HPLC is grounded back to the instrument to prevent a static charge from building up and as long as the line touches the container you should be safe from there being a static charge to be generated. It maybe be helpful to just bond the waste line to the plastic container as a way that would help easy the "fire guy" concerns.


Above is a letter of understanding issued by OSHA. The last paragraph is the what you may want to use.



Sent from Mail for Windows 10


From: Melissa Ballard
Sent: Wednesday, December 18, 2019 6:43 AM
Subject: [DCHAS-L] flammable hazardous waste


I would appreciate your feedback on my situation. We have recently replaced our single satellite accumulation container that was a 5-gallon metal drum to 2 separate plastic (UN approved) translucent "drums". This was at the suggestion of one of the environmental coordinators at the site. Now the other environmental coordinator & the "fire guy" are saying this is unacceptable because we cannot ground the plastic containers. We only use glass beakers or flasks to pour waste into these containers or it is waste going directly into a container from a HPLC (essentially a closed system).


Is this really a "fire risk"?  I recognize that there may be a small potential for static to build in a plastic container, but we are not really "transferring or dispensing" from these containers in the traditional sense. The original starting materials are purchased in plastic 4L containers or glass containers which cannot be grounded when pouring out of either. I am having a hard time understanding the push to go back to a metal container just so we can ground it. I will add that the plastic gives us the ability to see the volume of liquid in the container so we will not over-fill it.


Thoughts on how to handle this? The plastic containers meet the requirements for the waste as per NFPA/DOT so it is just a question of fire risk.


Thanks for your input!




Industrial Hygienist / Industrial Hygiene Chemist




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