Section D.7 University of South Carolina Safety Program Guide RELOCATING HAZARDOUS MATERIALS This guide contains safety guidelines and reference information for the physical relocation of hazardous materials and is primarily written for laboratory relocations. These guidelines are based on established policies and procedures drawn from the USC Safety guide. The concept for this guide was taken from the University of California at Berkeley’s and The University of Georgia’s relocation guide. Planning and preparing for your move is the prefect time to update your chemical and equipment inventories, clean out unusable and outdated materials, repair or discard broken equipment and ensure that a safe work environment is created in your new location. The time you spend preparing and organizing may save you time and money by avoiding preventable accidents and fines. If you have questions before, during, or after your move call Environmental Heath & Safety (EHS) at 777-5269. You can also ask for an EHS staff member (e.g., Patty Hamilton, 777-5269, hamilton@sc.edu) to work with you during the move process. Many informational resources can be found on the EHS web site at http://ehs.sc.edu, including online training for laboratory safety, fire safety, extinguisher use, etc. Any suggestions, additions or clarifications of the information contained in this document may be directed to the Environmental Health and Safety Office at 777-5269. Planning Your Move Who to notify of the move during the initial planning stages In the planning stages the following groups should be notified as early as possible: Environmental Health & Safety, 777-5269; Facilities Management, 777-4217; The appropriate building supervisor for your facility. Chemicals may not be moved off campus without prior review by EHS. Please contact EHS for more information. Who will move your hazardous materials and how If the move is within the same building or to an adjacent building, you can move properly packaged chemicals and hazardous materials using a good hand-truck, dolly or cart. EHS should be consulted during the packing process and prior to moves. Facilities movers can be contracted to move furniture and heavy equipment. EHS-G-D7 Page 1 Destroy Previous Revisions Date: 04/23/08 Approval: BH Prior planning for a safe moving process should start several months before the move. By taking the following pro-active steps, potential difficulties associated with the move can be anticipated in advance: Survey existing chemicals and equipment in your laboratory, Evaluate your new relocation site. You should only move items that will be of use at the new laboratory. A move is a perfect time to eliminate expired and unused chemicals. Prepare to dispose of opened container of chemicals that are no longer needed in your laboratory, unusable chemicals, and waste chemicals. Prepare these chemicals for disposal as soon as possible because it may take 3 to 4 weeks for the Hazardous Material Manager to pick up the chemicals after the initial request. If complete lab clean out or decontamination is required, the Hazardous Materials Manager should be contacted at 777-28399 as soon as possible. Arrange the transfer of any unserviceable or unwanted equipment to surplus. Please get in touch with USC Inventory Control at 777-3114. Schedule equipment repair before you move so that the equipment can be in working order during the move. Check all equipment for chemical or radioactive contamination. Assess whether the equipment needs decontamination before moving and/or recertification after moving (e.g., pathogenic work in a biological safety cabinet, radioactive contamination of liquid scintillation counters, gas chromatographs or centrifuges, or refrigerators with an accumulation of contaminated ice). If complete decontamination of instruments is required, the Hazardous Materials Manager should be contacted at 777-28399 as soon as possible. Survey the entire laboratory space to ensure that all chemicals are addressed prior to the move. Radioisotopes Prior to moving radioactive materials to other on campus locations, your radiation license needs to be amended to add the new location(s) and delete the old location(s). A request for an amendment form should be sent to the Radiation Safety Office (Dr. Daniel Zurosky, 777-5269, dzurosky@gwm.sc.edu). NO MOVE OF RADIOACTIVE MATERIALS CAN TAKE PLACE WITHOUT PRIOR LICENSING CHANGES AND A CHECK-OUT INSPECTION. Contact the Radiation Safety Office at 7-5269 to arrange a check out inspection. To move materials off campus, arrangements must be made through the Radiation Safety Office. Evaluating the New Facility Plan where you will place large items. Determine if there are enough electrical outlets and, if not, where new electrical outlets should be located. Extension cords and power strips are not substitutes for properly wired receptacles. Submit appropriate work orders to initiate these renovations. EHS-G-D7 Page 2 Destroy Previous Revisions Date: 04/23/08 Approval: BH If hazardous chemicals are to be used, make sure there is a safety shower and eyewash in the laboratory where the chemicals will be used. Plan a storage area for your chemicals. Plan a designated area for collecting unwanted hazardous materials until pick-up by Hazardous Materials management. Set aside a safety restraint area (i.e., chains) for gas cylinders. If assistance in evaluating a new laboratory is required, contact Patty Hamilton (777-5269, hamilton@sc.edu). The Laboratory Standard section (http://ehs.sc.edu/guides/LAB_GUI.HTM) of the University of South Carolina Safety Program Guide contains a laboratory safety checklist that can be downloaded for your use. Update your laboratory chemical hygiene plan to reflect changes in location, personnel, equipment, inventory, and safety procedures. A sample chemical hygiene is available at the USC Health & Safety web site (http://ehs.sc.edu/forms.htm). Supplies for Packing and Transporting Laboratory Equipment and Chemicals Prior to the move, check to see if you have all the supplies and equipment you need to pack. At a minimum, you will need: Boxes, absorbent materials (newspaper, vermiculite, etc), magic markers, a gas cylinder cart, hand truck, bungee chords, packing tape, proper personnel protective equipment for the chemicals being packed, proper spill cleanup materials in the event of a bottle breaking or spill. Planning Checklist Contacts USC Environmental Health & Safety has been notified of the impending move of hazardous chemicals. USC Facilities moving crew (or commercial movers) have been contacted to move large items. Biological Safety Officer has notified with regards to biological hazards. Radiation Safety Officer has been notified with regards to radioisotopes, x-ray machines, and lasers. Evaluating what will and will not be moved There are no hazardous chemicals stored that may be forgotten or missed during the packing and moving. All unneeded or expired chemicals have been disposed of properly. EHS-G-D7 Page 3 Destroy Previous Revisions Date: 04/23/08 Approval: BH Chemicals destined for waste have been tagged, inventoried, and the hazardous waste manager has been contacted for disposal. All chemicals have been properly labeled as to their contents and primary hazard(s). No equipment or furniture is contaminated by chemical, biological, or radiological hazards. All unwanted equipment has been scheduled for surplus pickup prior to the move. Special handling arrangements have been made for heavy equipment, equipment containing hazardous materials and delicate equipment. Regulators of all gas cylinders have been removed, the cylinder valves closed, and all cylinders tightly capped. Moving Supplies for Packing Appropriate spill kits are available and accessible. Potential hazards must be identified before the move and suitable spill kits acquired. Proper personal protective equipment is available, accessible, and personnel trained in appropriate use. All packing supplies (boxes, absorbent, markers, carts, hand trucks, tape, bungee chords, etc.) are acquired. The New Laboratory Emergency eyewash and showers are working and accessible within 25 feet (or 3 seconds) of the lab work area. Fire extinguishers are inspected, fully charged, mounted near doorways, unobstructed. Flammable storage cabinets are available for the storage of flammable volumes in excess of 10 gallons. All fume hoods are working properly and have been certified for use by appropriate inspectors. Areas are designated and equipment available to secure compressed gas cylinders. Sufficient numbers of electrical outlets are available. Outlets or breakers to outlets within 6 feet of a water source are ground faultinterrupted. Preparing Your Move Dangerous situations can arise if boxes are dropped and incompatible chemicals interact. Since compatibility requirements are similar for moving and storing chemicals, packing chemicals for the move is a good time to lay the groundwork for segregated storage in your new lab. Laboratory safety officers at EHS are available upon appointment or request to advise you in properly segregating chemicals for packaging and information is EHS-G-D7 Page 4 Destroy Previous Revisions Date: 04/23/08 Approval: BH available at the EHS web site (http://ehs.sc.edu/Lab Safety/chemstorage.html). No chemicals or radioactive materials are to be left behind in the old laboratory once the move is complete! The use of personal vehicles is prohibited for moving hazardous materials. Use of personal vehicles for hazardous chemicals may invalidate any auto or personal insurance. Preparing for Packing Wear personal protective equipment appropriate for the materials being handled (splash goggles, lab coat, gloves, closed-toed shoes, apron, etc.) when packing. Information concerning selection of gloves for various chemicals is provided on the EHS web site (http://ehs.sc.edu/Lab Safety/gloves.htm). Label chemical containers with the full chemical names and appropriate hazard warnings. Make sure that containers are not likely to leak in transport. Replace all containers in that are in poor condition (e.g., damaged containers, containers that are chemically corroded or contaminated). Using damaged containers is one of the major causes of accidental spills. Move only labeled and non-leaky containers to your new location. Make sure all caps and lids are in good condition and closed. Secure glass stoppers to their containers with tape and provide secondary containment for the containers. Packing Your Chemicals Use sturdy boxes or deep trays to pack chemicals. Cushion the containers to prevent breakage and contain spills using compatible absorbent materials. Newspaper is often a good cushion since it is absorbent and does not react with most chemicals, but it is not recommended for oxidizers or organic peroxides. Pack boxes so they can be completely closed and taped shut. Boxes should be light enough to be picked up by one person. Do not allow bottlenecks or stems to protrude from the boxes. Boxes that cannot be stacked are not suitable for transport. Boxes must be places in upright position (mark each container or box with an "up-arrow" to indicate proper orientation). Keep boxes of incompatible chemicals separated from one another before and during transportation. Label each box as you pack it. EHS recommends taping a list of chemical contents to the box. This will make unpacking easier and keep the box from being misplaced. Labels all boxes according to general hazard class (e.g., radioactive, flammable solid, acid, base, etc.). Refrigerated materials need not be boxed together, but should be separated into their hazard classes or handled according to their special requirements. Special Materials Equipment Containing Mercury EHS-G-D7 Page 5 Destroy Previous Revisions Date: 04/23/08 Approval: BH Take extra precautions to keep the mercury from spilling or leaking during to move. Use secondary containment if possible. Mercury spills can be difficult and expensive to clean up. Radioactive Materials Radioactive materials need to be properly packaged and labeled for moves involving motor vehicles. Arrangements should be made through the Radiation Safety Office (Dr. Daniel Zurosky, 777-5269, dzurosky@gwm.sc.edu) for packaging and transporting radioisotopes. No radioactive materials are to be left behind once the move is complete. Be sure that your new location is properly licensed prior to your move. Biological Materials The University Biosafety Officer (Mark Robbins, 777-4042, mrobbins@gwm.sc.edu) must contacted prior to the relocation of any biologically hazardous materials. Biohazardous materials must be properly packaged prior to the move. Consult with the Biosafety Officer regarding proper preparations. Biosafety Cabinets Disinfect work surfaces of biosafety cabinets prior to the move. Cabinets used for work involving pathogenic organisms may require decontamination prior to being moved. All biological safety cabinets should be tested and certified for air flow and filter integrity after being moved. Note: biosafety cabinets have a specially designed HEPA filter system and should not be confused with a chemical fume hood. For further information and appointments for certification, consult with the campus BioSafety Officer at 7-5269. Gas Cylinders Close the cylinder valve, remove the gauge and regulator, and secure the valve cap before moving a cylinder. Never move a cylinder by rolling it across the floor. Transport cylinders on a wheeled cart, carefully securing them with a chain in an upright position. If needed, secure an appropriate cylinder label with packaging tape to prevent it from falling off. Never drop cylinders or bang them against anything. Inventory Update your chemical inventory as you pack. If you do not have a written inventory, create one as you pack. Make an inventory sheet that includes chemical name, manufacturer, and quantity. Add the location of each chemical to your inventory after moving to the new lab. EHS-G-D7 Page 6 Destroy Previous Revisions Date: 04/23/08 Approval: BH Check containers for expiration date and signs of corrosion or crystallization; if such degradation has occurred, arrange for disposal of the materials through Hazardous Materials Management. Keep an extra copy of the inventory in a safe location outside the lab (e.g., department office) for reference in emergencies. Mark each box with the location of origin and the location to where it is to be transported. Use an ID system so that the box can be matched with the inventory should they become separated. Unwanted Equipment and Chemicals Equipment Recycle, salvage or dispose of unwanted equipment when possible. Old refrigerators must be emptied, decontaminated and labeled "FOR LAB USE ONLY". Strap latching refrigerators shut before moving them. Decontaminated equipment may be transferred to Surplus. Liquid scintillation counters and gas chromatographs or other equipment transferred to surplus must have any radioactive sources removed prior to transport. A contamination survey must be performed in all licensed laboratories. The Radiation Safety Officer (Dr. Daniel Zurosky, 777-5269, dzurosky@gwm.sc.edu) must be notified of the intent to transfer or dispose of any radioactive materials. Chemicals Label and identify hazards of all known chemicals and compounds. Put new labels on containers with illegible or deteriorating labels. To surplus unopened bottles of chemicals, call the Hazardous Materials Manager at 7-5269. For disposal, contact the Hazardous Materials Management at 7-5269. Follow the requirement s for labeling, inventory and tagging waste as outlined in the USC Health and Safety Guide (http://ehs.sc.edu/guides/CWAST_GU.HTM). Gas Cylinders Empty cylinders should be labeled empty. Call the supplier for pick up. Because of the high cost of disposal of most toxic gases, these gases should be returned to the vendor whenever possible. Contact the vendor for guidelines on preparing the cylinder for return. Contact EHS at 7-5269 if you have a cylinder with unknown contents or if the manufacturer will not take the cylinder back. Radioactive Waste EHS-G-D7 Page 7 Destroy Previous Revisions Date: 04/23/08 Approval: BH Unwanted radioactive waste should be packaged, prepared for disposal, and stored according to the Radiation Safety Manual. If you have any questions regarding radiation safety, call the Radiation Safety Office at 7-5269. If you need radioactive waste picked up or information on waste packaging, call EHS 7-5269. Disposal into the Common Trash Be careful about what you put in the trash. Dispose of only non-hazardous materials in the trash. Some non-hazardous items that may go into the trash include sugars, some salts, powdered detergents, protein mixes, etc. Place broken glass in an appropriate broken glass waster container such as a sturdy box so as to prevent custodians from being injured. Seal broken glass in a puncture-resistant container. Place a "Broken Glass" label on these containers. Do not place clean or contaminated hypodermic needles or syringes in the common trash. Place them in a "Sharps" container and contact the University BioSafety Officer for proper disposal. Fully decontaminate empty chemical bottles, remove the caps, and fully deface the label prior to disposal in the trash. DO NOT dispose of biological waste, hazardous waste, radioactive waste or containers labeled with the international biohazard or radioactive symbol or the words "medical waste, biohazard, infectious or sharps waste" in the regular trash. Handling Hazardous Materials During the Move Most chemical spills and accidents that happen during chemical packaging and transport are preventable. Taking the following precautions can help to avoid mishaps. Keep from knocking bottles against each other by using plenty of packing material. Don’t lift container or bottles by the cap. Don’t try to save trips by stacking boxes too high on carts. Don’t lift too much at one time. When you lift boxes, support them from underneath. Don’t lift them up by the sides or the box bottoms may split open. Use the elevator when carrying containers not the stairs. See laboratory safety and HazCom training modules on the USC EHS web site at http://ehs.ec.edu. Back Injury Prevention EHS-G-D7 Page 8 Destroy Previous Revisions Date: 04/23/08 Approval: BH Although you may not be moving your lab contents personally, you will be packing boxes, moving items out of the way, and stretching over and around objects. To prevent back strain: Do not twist while you lift, carry or deposit a load. Twisting when reaching, lifting or depositing an object is the main cause of back injuries. Make certain that you are facing the object squarely, whether it’s a book on a shelf, a reagent bottle or a box. Do not lift or lower an object above shoulder height. Use a ladder or step stool to position yourself so that high objects are below shoulder height. Ask someone to help you so you can safely hand down the objects. Do not stretch to pick up or deposit an object. If you must stretch to reach an object in front of you, support your upper body weight by leaning on a desk or table. Keep the object you are lifting as close as possible to your body to prevent back strain. Even a light object lifted at arm’s length can strain you neck and back, particularly if it is done repeatedly. Lift with your leg muscles, not with your back. As you lift, keep the load as close to the body as possible. Keep your back straight as you lift, bending at the knees instead. See online training module on the USC EHS web site (http://ehs.sc.edu/training/safety_training.htm). Who Should be Handling Hazardous Materials? All personnel handling the hazardous chemicals must be trained in the proper handling and spill clean-up of the specific hazardous materials being moved. NO facilities management movers or custodial workers shall move any hazardous materials. PRIVATE VEHICLE USE FOR MOVING HAZARDOUS MATERIALS (CHEMICAL, BIOLOGICAL AND RADIOACTIVE) IS PROHIBITED. Special training, placarding, vehicle requirements, and insurance are needed to transport many types of hazardous materials on public roads. If the move is within the building to an adjacent building, you can handle the hazardous materials using a hand-truck, dolly or cart. As noted above, gas cylinders are to be moved on special gas cylinder carts. Hazardous Materials in Laboratory Equipment Some laboratory items may contain materials or chemicals that are potentially harmful to human health or the environment. Preparing this equipment for transport requires special handling. Care must also be taken to avoid damaging or disturbing asbestos-containing materials. Facilities management will inspect items suspected of containing asbestos. If necessary to disturb asbestos-containing materials, contact the USC Asbestos Coordinator at 7-9155 before beginning work. Fragile components or components containing materials that may spill if inverted (e.g., a 2-foot glass manometer) must be specially EHS-G-D7 Page 9 Destroy Previous Revisions Date: 04/23/08 Approval: BH secured with double containment or emptied. Any instrument or piece of unsealed equipment containing significant quantities of a hazardous material in liquid form must be drained prior to move. Report any items you suspect may contain PCB’s to EHS. The following equipment should be given particular attention during your move: Acid: Large batteries, power supplies Solvents: Degreasing equipment PCBs: High voltage systems, power supplies, immersion oils, Capacitors, Transformers, Hydraulic fluids Asbestos: Autoclaves, Ovens, Furnaces, Gloves, Curtains, Incubators Radioactive Materials: Gas chromatographs, Liquid scintillation detectors Mercury: Manometer, Thermometer, Barometers Compressed Gases: Internal cylinders, Ampoules, Canisters Carcinogenic dyes: Laser Systems Moving into the New Location Chemical Storage Plan for Laboratories Incompatible materials need to be segregated and stored separately in compatible groups. Hazard classification information helps in identifying storage groups; however, be aware that there are many materials in the same basic class that have specific incompatibilities. Laboratory safety officers at EHS are available upon appointment or request to advise you in properly segregating chemicals for packaging and information is available at the EHS web site (http://ehs.sc.edu/Lab Safety/chemstorage.html). Biohazard Storage Biohazard users must update the BioSafety Office with regards to the new location. Contact the campus Biosafety Officer (Mark Robbins, 777-4042, mrobbins@gwm.sc.edu) with this information. An inspection may be scheduled once the new lab has been set up. Access doors to regulated areas containing biohazard or carcinogens must be posted with warning signs. Contact the Biosafety Officer if you need a warning sign or are not certain about the type of sign required. EHS-G-D7 Page 10 Destroy Previous Revisions Date: 04/23/08 Approval: BH Radioactive Material Storage All areas where radioisotopes are to be used should be delineated. All storage areas of materials and waste must be labeled with a "Radioactive Materials" sticker or sign. Radiation Safety Staff (Dr. Daniel Zurosky, 777-5269, dzurosky@gwm.sc.edu) will go through the new lab to assist in setting up for radioactive material use, x-ray use and shielding requirements, and laser set-ups. Decommissioning the Old Facility Once the old facility is moved out of, the following must be done: Check the entire facility for containers of chemicals. Chemicals or wastes are NOT to be left behind in the old facility one the move has taken place. Any remaining containers must be moved to the new laboratory. All work surfaces are to be decontaminated. Areas of heavy discoloration or contamination should be left until safety officers from EHS can examine them. All bench coveringing must be taken up and properly disposed of. Yellow "Caution" door signs are to be taken down and discarded. Radiation symbols on all signs must be defaced prior to disposal. All radioactive materials tape, notices, and symbols must be removed. Extensive swipe and Geiger testing must be conducted to assure that there is no residual contamination. Radiation Safety Staff (Dr. Daniel Zurosky, 777-5269, dzurosky@gwm.sc.edu) will perform additional exit wipes after move is completed. All storage areas outside the laboratory (including attics and basements) are to be examined for chemicals and property belonging to the facility. Any property found should be either moved or labeled with the name and new address of the principle investigator. Once the Move-in is Complete New Area Checklist Once you are moved into the facility, you can use this checklist to assure that no problems exist and that your facility is ready for use. Emergency Equipment Emergency eyewash and showers are working and accessible within 25 feet (or 3 seconds) of the lab work area. EHS-G-D7 Page 11 Date: 04/23/08 Destroy Previous Revisions Approval: BH Fire extinguishers are inspected, fully charged, mounted near doorways, unobstructed. Appropriate spill kits are available and accessible. Properly filled out yellow hazard identification sign on all entrances. Chemical Storage Flammable substances are stored in proper flammable storage cabinets (volumes in excess of 10 gallons). Chemicals are segregated hazard class Corrosive materials are stored in low cabinets/shelves below waist level. Liquids have secondary containment. Area designated for collecting waste chemicals for Hazardous Waste Management to pickup. Radioactive Material Storage The materials are properly stored. Radioactive labels are properly posted on cabinets, hoods and refrigerators where material is located. The laboratory is properly labeled (i.e., "RADIOACTIVE MATERIALS") The required notices are posted. General Laboratory Conditions Hazardous work areas are posted with hazard and warning information? (e.g., biohazards, carcinogens, radiation, lasers, UV light) All fume hoods are working properly and have been certified for use by appropriate inspectors. Biological safety cabinets have been re-certified for proper operation. Compressed gas cylinders are properly secured and labeled. Proper disposal containers are available for materials such as sharps, needles, broken glass, etc. There is a minimum of 24-inch clearance in the aisle. There is a minimum of 36-inch clearance in passageways. Heavy items are stored on low shelves. All toxic gases are stored in a mechanically ventilated area such as a toxic gas cabinet or fume hood. Outlets or breakers to outlets within 6 feet of a water source are ground faultinterrupted. Roles and Responsibilities Department EHS-G-D7 Page 12 Destroy Previous Revisions Date: 04/23/08 Approval: BH • • • Identify all departmental activities that could result in the generation of hazardous waste Be aware of University policies and procedures for proper relocation of hazardous materials Distribute information on proper relocation of hazardous materials to all applicable parties Supervisors • Ensure that all individuals involved in activities that relocate hazardous materials understand and follow policies and procedures EHS • • Provide technical advice on proper relocation of hazardous materials Provide training Individual • • Follow established practices for proper relocation of hazardous materials Properly dispose of all wastes at the conclusion of a project and before leaving the University For More Information • Contact EHS at 777-5269 EHS-G-D7 Page 13 Destroy Previous Revisions Date: 04/23/08 Approval: BH