From: Richard Palluzi <000006c59248530b-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
Subject: Re: [DCHAS-L] flammable hazardous waste
Date: Wed, 18 Dec 2019 08:44:16 -0500
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: 001f01d5b5a9$3dce2c00$b96a8400$**At_Symbol_Here**verizon.net
In-Reply-To


A common tactic to ground plastic containers is to simply place a metal (conductive) rod or bar inside the container and ground it. Then you just need to train people to make any pours onto the bar.

 

You can also do a calculation based on the material to determine the potential static build up. Most times you need to transfer at least about a liter of hydrocarbon to build up any appreciable charge. However, this is dependent on a lot of factors and most organizations are reluctant to give too much weight to this type calculation due to the many potentials for someone doing something that was never considered in the analysis. And, of course, some liquids and some situations can develop a higher charge with much lower rates.

 

Richard Palluzi

PE, CSP

 

Pilot plant and laboratory consulting, safety, design,reviews, and training

www.linkedin.com/in/richardppalluzillc/

 

Richard P Palluzi LLC

72 Summit Drive

Basking Ridge, NJ 07920

rpalluzi**At_Symbol_Here**verizon.net

908-285-3782

 

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> On Behalf Of Harold Ingmire
Sent: Wednesday, December 18, 2019 7:36 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] flammable hazardous waste

 

I found this OSHA link https://www.osha.gov/laws-regs/standardinterpretations/1999-03-29 This may be of some help, but note it is dated.

 

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> On Behalf Of Melissa Ballard
Sent: Wednesday, December 18, 2019 6:27 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
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!

 

 

Melissa BALLARD - MSPH, CIH, CSP, CCHO

Industrial Hygienist / Industrial Hygiene Chemist

melissa.ballard**At_Symbol_Here**michelin.com

 

 

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