James, Goody, If you can show me where there is a state rule that says colleges and universities must comply with a some sort of Texas hazard communication and where I can get a copy of that program, I'll be thrilled to inform a couple of schools who tell me they don't have to do squat.

Monona

-----Original Message-----
From: James Kaufman <jim**At_Symbol_Here**LABSAFETY.ORG>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Tue, Feb 18, 2020 2:57 pm
Subject: Re: [DCHAS-L] Chemical Waste Handling

However, Texas does have its own hazard communication standard.

PS. "There's more to lab safety than just labs!"

James A. Kaufman, Ph.D.

Founder/President Emeritus
The Laboratory Safety Institute (LSI)
A Nonprofit Educational Organization for Safety in Science, Industry, and Education

192 Worcester Street, Natick, MA 01760-2252
508-647-1900 Fax: 508-647-0062
Cell: 508-574-6264 Res: 781-237-1335
Skype: labsafe; 508-401-7406

jim**At_Symbol_Here**labsafety.org www.labsafety.org

Teach, Learn, and Practice Science Safely

On Tue, Feb 18, 2020 at 2:43 PM Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**lists.princeton.edu> wrote:

Excellent work, Yaritza. EPA rules all apply to schools in Texas. But Texas state and municipal schools are exempt from the OSHA regulations. So training about hazcom, SDS, etc., is up to individual schools, and some have chosen not to have any of the usual OSHA written programs. It also sounds like the advice Pam got about storing in the hood means that the training of the facilities people is not working too well.

Monona

-----Original Message-----
From: Yaritza Brinker <YBrinker**At_Symbol_Here**FELE.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Tue, Feb 18, 2020 1:24 pm
Subject: Re: [DCHAS-L] Chemical Waste Handling

Hi Pam,

Federal regulations do require waste containers to be kept closed when not pouring into them. This may be inconvenient, but does prevent "waste treatment by evaporation" which is prohibited by the EPA. However, "tightly closed" may be an issue for some experiments if the waste generates gas overnight and can cause an explosion (saw the aftermath as an undergrad). So, it is prudent to use secondary containers. Better yet, include a step in the experiment to reduce the hazard level of the "soon to be declared waste" (which is allowed) to eliminate the risk of over pressurizing the waste container.

I looked around your school's website a bit. Federal Regulations encourage the use of Integrated Contingency Plans (ICP). It appears your institution has chosen to also include the CHP, RSP, Bio Safety, and other plans into their ICP. Your institution has chosen to use a separate webpage for each section of their ICP and also for each section of the CHP. Thus, at first glance it looks like you don't have a CHP. However, when you start to look you do find the required sections. PLEASE NOTE that I'm not commenting on the quality of each section as I have really not read thru them.

Your ICP main page is located at - http://www.lonestar.edu/Environment-health-safety.htm

Your generator status section is - http://www.lonestar.edu/16717.htm#responsibilities

This page has a summary, including who is responsible for training you- your Facilities Department- http://www.lonestar.edu/16749.htm

Interestingly enough, your institution's policy specifically says not to store waste in hoods. Judging by the wording, most of it looks almost verbatim from the regulations. Thus, I wonder if the don't store waste in hoods is an extension of the heuristic "don't store stuff in active hoods". I would gather the information already suggested by others to justify your current arrangement. I would also make the argument that hazardous wastes (i.e. acid, organic solvents) do pose a respiratory hazard. Therefore, it is common to denote a hood as the Satellite Containment Area.. Please do a bit of homework on Satellite Containment Areas as these are supposed to be denoted in your plan and are the responsibility of the "local" researcher/CHO/stock room manager.

In addition to the resources others have pointed out, I also suggest the following EPA resources available for download at https://www.epa.gov/nscep

Environmental Management Guide For Small Laboratories

EPA Enforcement Alert: Mismanagement of Laboratory Waste Creates Risk of Serious Injury

Management Of Hazardous Wastes From Educational Institutions Report To Congress (This is a critical review of bad practices found in the 80's. It is not explicit, but it does allude to storage of waste inside cabinets as a bad practice.)

Hope this helps!

Yaritza Brinker

260.827.5402

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