Jennifer:
I think the regulation goes on to state that the container must be
closed so that if the container is upended, no waste will leak out (or
words to that effect). Will waste leak out of the sharps container if
the container is upended? If no waste leaks out, then I think you could
argue that the performance of the container meets the regulation.
I'm curious, though - are the sharps contaminated with hazardous
materials? If you're disposing as hazardous waste, that would be the
assumption but I just wanted to make sure.
Debbie
------------------------
Debbie Decker
EH&S UCDavis
(530)754-7964
FAX (530)752-4527
dmdecker**At_Symbol_Here**ucdavis.edu
Co-Conspirator to Make the World A
Better Place -- Visit www.HeroicStories.com and join the conspiracy
Birkett's hypothesis: "Any chemical reaction
that proceeds smoothly under normal conditions,
can proceed violently in the presence of an idiot."
-----Original Message-----
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of
Young, Jennifer
Sent: Tuesday, June 19, 2007 2:14 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: [DCHAS-L] "open" sharps containers
I could use some help about how to respond to a DENR inspection
violation regarding an open sharps container. We were cited for
violating 40 CFR 262.34(c)(1)(I) and 265.173(a), which states "that a
container holding hazardous waste must always be closed during storage,
except when it is necessary to add or remove waste." I understand that,
but a sharps container is designed such that once it is closed, it
cannot be reopened. Only the small flap for adding sharps was open, but
is has to be open. It would be quite a danger for the chemists to have
to try to pry open the container when they had a syringe to dispose of.
(This is a large, 7 gallon bucket-type container, with a flat lid that
is hinged and a flap that leaves an open space for adding the
syringes/needles, not the small wall-hanging or tabletop kind.) How
does one keep the waste container closed when it is designed to be open
like that? How do I respond? Any advice you could give would be great.
Jennifer A. Young, Ph.D.
Targacept, Inc.
336 480-2182
Jennifer.Young**At_Symbol_Here**Targacept.com
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