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Previous by Date: Subject: Re: [DCHAS-L] Waste storage question Date: Thursday, August 5, 2021 at 3:10:47 PM Author: pzavon**At_Symbol_Here**ROCHESTER.RR.COM |
Next by Date: Subject: Re: [DCHAS-L] Waste storage question Date: Thu, 5 Aug 2021 15:37:36 -0600 Author: Jan Windhorst |
Failure to perform appropriate Hazardous Waste Determinations is the #1 current EPA RCRA violation (40 CFR 262.11). As the waste generator, the EPA wants you to KNOW what your material is, and so as Peter has indicated does the
DOT.
This would classify as flammable (primary hazard), toxic (subsidiary hazard) as DOT Hazard Classes are: 3 & 6.1 per 49 CFR 172.101. If all else fails, put a drop on a ‘watch glass’ and see if it ignites and/or do a RCRA Flash Point determination.
Even if the waste vendor drafts a waste information profile, it is the responsibility of the waste generator to ensure accuracy and completeness.
Patrick
Patrick Ryan, CIH, CSP, CHMM
Hazardous Materials Manager
Montana State University
406/570-9140
Patrick.ryan6**At_Symbol_Here**montana.edu
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
On Behalf Of pzavon**At_Symbol_Here**ROCHESTER.RR.COM
Sent: Thursday, August 5, 2021 1:11 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Waste storage question
I used to spend a good deal of time on hazardous materials shipping, although not in connection with lab waste. While "just in case" or "err on the side of caution" is a good thing to do in many circumstances, if you are assessing this
mixture for transportation, classifying as flammable (or other hazard) just in case is as contrary to regulations as failing to classify a hazardous material. The DOT wants you, and thus the trucker, to KNOW, one way or the other. In that context Rachel's
suggestion of having your waste vendor profile the stuff is a good one.
Peter Zavon, MS, CIH
Penfield, NY
PZAVON**At_Symbol_Here**Rochester.rr.com
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
On Behalf Of Rachel Harrington
Sent: Thursday, August 5, 2021 1:55 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Waste storage question
If you want to you could have your waste vendor profile the waste for you, this is actually an important regulatory element, characterizing your waste stream. There would be a charge for
this but in the end you will be confident in how you handle it and will have identified all the associated waste characteristics of which there may be more than just flammable as mentioned by another member.
Regards,
Rachel Harrington, MPH
Get
Outlook for iOS
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> on behalf of Ralph Stuart <ralph.stuart**At_Symbol_Here**KEENE.EDU>
Sent: Thursday, August 5, 2021 12:38:27 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Subject: Re: [DCHAS-L] Waste storage question
> I prefer to use the Fisher web site to look up safety and SDS information, as everything is clear and easy to understand.
Thanks for sharing that resource. I note that the Fisher SDS states that "Chemical waste generators must determine whether a discarded chemical is classified as a hazardous waste.” Someone else shared a link to a 2016 EPA document that describes the regulatory
process for the classification of waste solvents, assuming perfect information is available for the mixture. This guidance is at
https://www.epa.gov/sites/default/files/2016-09/documents/version_2_-_solvent_guidance_final_508_compliant_090116.pdf
Unfortunately, we don’t have enough specific information available for this waste mixture to use the EPA’s resource. So we will be erring on the side of caution and assuming it is flammable.
Thanks to everyone for sharing their thoughts on this question.
- Ralph
Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859
ralph.stuart**At_Symbol_Here**keene.edu
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