Hazardous Materials &
Hazardous Waste
Training
September 10, 2008
Drug & Laboratory Disposal, Inc.
331 Broad Street
Plainwell, MI 49080
There are many training requirements
with which to comply under various
Federal regulations.
EPA, DOT & OSHA
are the primary agencies that enforce
specific training requirements related to
management of hazardous waste.
EPA –
Environmental Protection
Agency
Provides a systematic approach
to managing hazardous waste
DOT –
Department of Transportation
Regulates hazards during
transportation
OSHA –
Occupational Safety and Health
Administration
Regulates workplace
conditions and practices
EPA Training Requirements
40 CFR 262.34 (d)(5)(iii)
Hazardous waste management
RCRA in 1976
EPA Training Requirements
Anyone who could cause non-compliance at a
facility
Anyone with duties which ensure the facility’s
compliance
Annual review of written training plan
EPA Training Requirements
Must include job-specific waste management
procedures
Must be completed within 6 months of assignment
to the facility
Must have supervision until trained
Training must be reviewed annually
DOT Training Requirements
49 CFR 172.700; 173.1 (b)
Hazardous materials transportation
DOT Training Requirements
Employees who directly affect transportation
safety
Repeated at least every 3 years
Change in rules requires additional training.
DOT Training Requirements
General awareness
Function-specific training
Security training
Safety training
DOT Training Requirements
Must include test and be kept for 3 years
Training completed within 90 days of employment,
during which they may not work with hazardous
materials unless under supervision of trained and
knowledgeable employee
OSHA Training Requirements
29 CFR 1910.1200(h)
Hazardous chemicals
workplace safety
OSHA Training Requirements
Any employee who could be exposed to any physical
or health hazard
Recognize hazards and protect employees from
hazards through proper communication
Establish a written hazardous communication
program
OSHA Training Requirements
Must be trained how to work with hazardous
chemicals to prevent illnesses, injuries, or death
Must include container management techniques, safe
chemical use, proper protective equipment use, and
spill response training
OSHA Training Requirements
Labels on incoming containers of hazardous
chemicals
Have MSDS readily accessible for each work shift
For waste shipment, have containers labeled
Initial training and whenever new physical or health
hazards are introduced
Most important; everything hinges on generator
knowledge, materials, and processes used.
What is it and is it a hazardous material
Must determine the type of hazard and the degree of
hazard
We need to know the physical and chemical
properties.
-Physical state (liquid, solid, gas)
-Flashpoint or boiling point
-Will it kill people (toxicological effect)
-What does it do to your skin
-Is it reactive to air, water, other chemicals
-Is it radioactive
Get information from:
MSDS
Text books
Manufacturer’s data
Analytical results
3 ways to become a hazardous material:
Meets a hazard class definition from 1 – 8
The DOT says so with a “+” entry
Miscellaneous class 9
Hazard class definitions
Hazard class definitions
The DOT says so with a “+” entry
About 50 chemicals from a list of 3000
Must be shipped under this classification
Examples: phenol, magnesium arsenate
Miscellaneous Class 9
If it doesn’t meet a hazard class and meets one of the
following;
It has airplane hazards (Crew safety)
It is a hazardous waste (EPA number)
Marine pollutant
Separate list by DOT
Elevated temperature material
Molten or hot
Forbidden materials
May not legally be offered for transportation or
transported
Usually have to meet specific conditions for safety
before transportation
Determine the degree of hazard:
PGI
indicates greater danger
PGII
indicates medium danger
PGIII
indicates minor danger
Indicated by packing group, used in packaging the
material
Some hazard classes don’t have packing groups.
(2, 7)
Not safe to over classify. (responders and
employees safety)
Division 3 Packing Groups
Packing Group
Flash Point
Initial Boiling Point
≤ 35°C (95°F)
I
II
≤ 23°C (73°F)
> 35°C (95°F)
III
≥ 23°C (73°F) but ≤ 60.5°C (141°F)
> 35°C (95°F)
Division 6.1 Packing Groups
Oral toxicity LD50 (mg/kg)
Dermal toxicity LD50
(mg/kg)
Inhalation toxicity
by dusts and mists
LC50 (mg/L)
I
≤5
≤ 40
≤ 0.5
II
> 5 but ≤ 50
> 40 but ≤ 200
> 0.5 but ≤ 2
III
solids: > 50 but ≤ 200; liquids: > 50 but ≤ 500
> 200 but ≤ 1000
> 2 but ≤ 10
Packing
Group
A material may meet the defining criteria for more
than one hazard class but is assigned to only one
hazard class.
Lots of chemicals are toxic.
Select from column 2
Be accurate
Be specific (technical names, chemical family, end
use, n.o.s. use)
Waste characteristics and waste code
numbers
-Characteristic D codes
-F listed solvents
-P & U toxic waste codes
-Act 451 industrial liquid codes
Characteristic D Codes
D001
Ignitable waste code
D002
Corrosive waste code
D003
Reactive waste code
D004 – D011
Toxic heavy metals waste codes
D012 – D043
Toxic organic codes
F Listed Solvents
F001 - Used in degreasing (6 solvents)
F002, F003, F004, F005 - Spent Solvents (28
solvents)
Examples: methanol, xylene, methylene chloride
P & U Toxic Waste Codes
Commercial chemical products – pure
P codes - acutely toxic
U codes – toxic
Examples: nickel cyanide, bromoform
Act 451 Industrial Liquid Codes
Act 451 Part 121 liquid industrial wastes
Not EPA waste codes
Can be DOT shipping name
Examples: Antifreeze, crankcase oil
Act 451 Codes
Mixed Solvents (Solvent Solutions)
Pharmaceutical
Automotive Oil
Coolants and Water Soluble Oils
Other Oil
Polychlorinated Biphenyls
Other Waste
Antifreeze
Storm Sewer Cleanouts
Sanitary Sewer Cleanouts
X-Ray/Photo Solutions
Water Based Cleaning Solutions
Grease Trap Wastes
007L
014L
017L
019L
021L
026L
029L
030L
031L
032L
033L
034L
036L
Universal Waste
There are certain hazardous wastes that a business
can choose to manage in an alternative manner in
place of the more complex hazardous waste
regulations.
Advantages of Universal Waste Regulations
-
Waste can be accumulated up to one year
-
A Hazardous waste manifest is not required
-
Volume is not included in determining generator status
-
Less labeling is required
Types of Universal Waste
-
Batteries
-
Electric Lamps
-
Electronic components
-
Mercury-Containing Devices
-
Pesticides
-
Pharmaceuticals
Electronic Equipment – Computer Monitors & TVs
CRT’s (cathode ray tubes) in monitors and TV’s have
been tested and show lead levels exceeding the
regulatory limit
of 5.0 mg/L. Some models also contain barium,
chromium, or mercury.
Meeting the definition of hazardous waste allows these
electronics to be managed as universal waste.
Regulated Medical Waste
Intended to help employees avoid injuries and disease.
Regulated medical waste, n.o.s., 6.2, UN3291, PG II
Waste code possibilities: 029L or N/A
Blood borne Pathogens
Use OSHA’s universal precaution method. Treat all
blood as dangerous.
-Blood-soaked bandages
-Discarded surgical gloves and instruments
-Cultures
-Hepatitis
-Tetanus
-HIV
Sharps
Can inflict injuries and disease.
-Broken glass
-Lancets
-Needles
-Razor blades
The point of packaging is to make sure that the stuff
stays inside the packaging during normal
transportation.
Includes temperature changes, handling, vibration
caused by rough roads or curves.
The type of packaging you can use
The standards or specifications the packaging has to
meet
The rules for filling and closing the package
When different hazardous materials may be placed in
the same package
Requirements in column 8 of HM table
172.101
Combination packaging
Single packaging
49 CFR 178.503
Marking of packages
Empty containers
DOT vs. EPA Standards
If empty, package is not subject to hazardous
material regulations.
DOT empty containers
Cleaned of residue and purged of vapor
All hazardous markings and labels have been
removed or covered
Remaining residue is not a hazardous waste or
marine pollutant
EPA empty containers
Must contain less than 1 inch of residue or
less than 3% by weight of material
Gas cylinder must equal atmospheric pressure
If contained acutely hazardous waste, container
must be triple rinsed or inner liner removed
Must accompany the shipment
Printed legibly in English, no abbreviations
Keep copy for 3 years
Must get copy from TSDF within 45 days.
If not, call EPA.
The person signing a hazardous waste manifest is
also signing the DOT-required shipper’s
certification, certifying that the entire shipment is in
full compliance with all applicable DOT regulations.
Anyone who prepares, completes or signs a
hazardous waste manifest must have training as
required by the DOT’s hazmat employee training
standard under 49 CFR 172 subpart H.
Markings identify:
What the material is
Correct emergency response actions
Shipper’s name and address
Special handling precautions
Markings include:
Proper shipping name, UN number, shipper’s name
and address
EPA ID number, manifest tracking number
Technical names of hazardous materials and waste
codes
“Hazardous Waste” Statement.
Labels identify:
What hazard the material has
Special handling precautions
Labels include:
Diamond shaped hazard class labels
Square precaution labels
Label Examples:
1- Hazardous Warning Statement
2- Generator Name and Address
3- Generator EPA ID Number
4- Accumulation Start Date
5- EPA Waste Codes
6- Manifest Document Number
7- Proper Shipping Name, Technical Name, Special Hazard Warning (if applicable) and DOT
Exemptions (If applicable)
1
2
U of M – Flint Riverfront
602 Mill Street
(810) 766-6762
Flint
Act 451, Part 121 Regulated Materials
(used oil)
7
MI
3
MID 085 043 891
4
U of M – Flint Riverfront
602 Mill Street
Flint
2
MI
48503
48503
6
D001,D002,F003
Waste Flammable Liquid, Corrosive, n.o.s., 3(8), UN2924, PGII
(Methanol, Acetic Acid)
7
5
The shipper or generator must ensure that placards
are provided
Displayed on all four sides
Visible without interference on each side and
horizontal placement
Table 1
-----------------------------------------------------------------------Placard
Category of material (Hazard
design
class or division number and
Placard name
section
additional description, as
reference
appropriate)
(§ )
-----------------------------------------------------------------------1.1.............................. EXPLOSIVES 1.1..........
172.522
1.2.............................. EXPLOSIVES 1.2..........
172.522
1.3.............................. EXPLOSIVES 1.3..........
172.522
2.3.............................. POISON GAS..............
172.540
4.3.............................. DANGEROUS WHEN WET......
172.548
5.2 (Organic peroxide, Type B,
ORGANIC PEROXIDE........
172.552
liquid or solid, temperature
controlled).
6.1 (inhalation hazard, Zone A or POISON INHALATION HAZARD
172.555
B).
7 (Radioactive Yellow III label
RADIOACTIVE \1\.........
172.556
only).
-----------------------------------------------------------------------\1\ RADIOACTIVE placard also required for exclusive use shipments of low
specific activity material and surface contaminated objects
transported in accordance with § 173.427(a) of this subchapter.
Table 2
-----------------------------------------------------------------------Placard
Category of material (Hazard
design
class or division number and
Placard name
section
additional description, as
reference
appropriate)
(§ )
-----------------------------------------------------------------------1.4.............................. EXPLOSIVES 1.4..........
172.523
1.5.............................. EXPLOSIVES 1.5..........
172.524
1.6.............................. EXPLOSIVES 1.6..........
172.525
2.1.............................. FLAMMABLE GAS...........
172.532
2.2.............................. NON-FLAMMABLE GAS.......
172.528
3................................ FLAMMABLE...............
172.542
Combustible liquid............... COMBUSTIBLE.............
172.544
4.1.............................. FLAMMABLE SOLID.........
172.546
4.2.............................. SPONTANEOUSLY COMBUSTIBLE
172.547.
5.1.............................. OXIDIZER................
172.550
5.2 (Other than organic peroxide, ORGANIC PEROXIDE........
172.552
Type B, liquid or solid, temperature controlled).
6.1 (other than inhalation
POISON..................
172.554
hazard, Zone A or B).
6.2.............................. (None).................. ...........
8................................ CORROSIVE...............
172.558
9................................ Class 9 (see §
172.560
172.504(f)(9)).
ORM-D............................ (None).................. ...........
------------------------------------------------------------------------
Materials handled to prevent damage during
loading and unloading.
-This end up
-No smoking by classes 1,2,3,4,5.
Segregated and separated to prevent incompatible
material from mingling during transportation.
-Incompatibles 4 feet from each other
-Use segregation table
Secured and braced to prevent movement and
damage during transportation
-strapped in truck every 10 feet
-watch for load shifting
In transportation:
Protect the general public
Control and clean up releases
Prevent or extinguish fires
Any person or place that creates
hazardous waste
LQG – Large Quantity Generator
Generates 2,200 pounds or more waste per month
Can accumulate on site for 90 days
No limit on amount stored
Must be at least one employee available to respond
to emergency
Written plans for handling emergencies
SQG – Small Quantity Generator
Generates 220 to 2,200 pounds of waste per month
May accumulate on site for up to 180 days
Accumulation limit is 13,200 pounds
Must be at least one employee available to respond
to emergency
No written emergency plan needed
CESQG – Conditionally Exempt Small
Quantity Generator
Can generate 220 pounds or less waste per month
Accumulation limit is 2,200 pounds
No plans or reporting required
Accumulation
Mark the accumulation start date on each container
Mark each container with words “hazardous waste”
Have written emergency plan
Keep containers closed and in good condition
Inspect containment area and document
Security Plans
Personnel security
Unauthorized access
En route security
Plan in writing and kept
EPA
Security Awareness
DOT
Required for all hazmat employees
An awareness of security risks
Recognize possible security threats
Know how to respond
Security Awareness
OSHA
Regulates workplace storage of flammable and
combustible liquids
Size, amount and place of containers
Personal protective equipment supplied if needed
Safety plans and exit routes
National Fire Protection Association
Based on possible fire situations
Standard system for the identification of hazardous
materials
Assists in effective fire and emergency planning
Division rating scale
0, 1 - unlikely to become dangerous
2
- depends on the circumstances
3, 4 - it is dangerous now
Enforcement and penalties
EPA has authority to inspect facilities
Can require corrective actions to take place
Criminal penalties or fines
FINES & PENALTIES
Summary
Act
Sanction
Intent
RCRA
Civil
None
(Hazardous
Criminal Knowingly
Waste)
Maximum Fines
Maximum
Imprisonment
$32,500/day
$25,000/day (doubled for
second offense)
1 year (doubled
for second
offense)
$250,000
$1,000,000(organizations)
2 years
Knowing
$250,000
extreme
$1,000,000(organizations)
indifference
to human life
5 years
Knowing
imminent
endangerment to
human life
Hazardous Materials &
Hazardous Waste
Training
September 10, 2008
Drug & Laboratory Disposal, Inc.
331 Broad Street
Plainwell, MI 49080