DCHAS-L Discussion List Archive
Date: Thu, 17 Feb 2011 14:24:44 -0500
Reply-To: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Kim Auletta <kauletta**At_Symbol_Here**NOTES.CC.SUNYSB.EDU>
Subject: Re: [NAOSMM] Expiration dates of chemicals/regulations
In-Reply-To: <20110217135433.ECF93902**At_Symbol_Here**mirapoint.jcu.edu>
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 Z=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
As regards old containers sitting 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 circulation,
then some instectors use the 'white glove' test. If I can wipe dust off
the top of the container, it's probably not being used and hasn't been 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 certain
hazardous wastes which could be recycled, it has also been applied to the
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 the
next year, expired or not. This is an iterative process as profs will put
up resistance to throwing away 'perfectly good' reagents from the 1950'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" is defined only
for the purpose of determining if a material is a solid waste [40 CFR
261.2(c)], the EPA’s definition, at section 40 CFR 261.1(c)(8) starts
simply with "A material is ‘accumulated speculatively’ 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
conditions:
1. A feasible means of recycling the material exists, and
2. At least 75% of the material on-hand 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
recycled 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 "accumulating speculatively." What happens next is, the waste will
be 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
permits 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
John Carroll University
20700 North Park Blvd.
University Hts, 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
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
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 between. What are the rules about shelf life particularly
for
inherited old chemicals? What actions are required and what are merely
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. #6144
Newberg, OR 97132
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