Good point.  That citation might be non-enforceable by that agency if
it's not what they do.  When I did hazardous waste inspections, my focus
was all RCRA.  However, from time to time I'd see something egregious
that would come under the category of "Other Areas of Concern" such as a
welding station located right next to a solvent storage area, or an
un-guarded drive belt.  I'd include those non-RCRA things in my report
so that if, for example, the place burned to the ground a week later,
the probable cause would have already come to the attention of the
facility owner prior to the fire.  Although these items were
non-enforceable by my agency, we'd mention it (a) as a legitimate safety
concern (b) to clear the inspector of any implied neglegence and (c) to
keep the agency from being blamed for something like that in the press. 
 

>>> "Diane Amell"  06/21/2007 8:46:01 AM >>>
Part of the issue may be that the sharps container requirement under
OSHA only applies to waste materials contaminated with blood or "other
potentially infectious materials" under the Bloodborne Pathogens
standard. (Or, as it is known in MN environmental agencies,
"infectious
waste".)
 
While it sounds like a good idea to me on the behalf of your employees
to use the sharps container for safety purposes, we do not require it.
This may be why the inspector raised his or her objections. My
experience, at least in Minnesota, is that environmental agency
employees specialize in one area and are usually not familiar with
other
environmental areas, much less OSHA regulations. 
 
- Diane Amell, MNOSHA

>>> "Young, Jennifer"  6/20/2007 8:04 AM
>>>

The flap is large enough that yes, the sharps might spill out if it is
turned over.  And yes, they are contaminated with hazardous waste--a
number of P-listed chemicals are dispensed by syringe and then the
syringe and needle (with only barely a residue of chemical) are placed
in the sharps container.  No liquid waste is present.  But if you
close
the flap, you cannot open it again.  I have a picture of one, but
cannot
post it.  If you click the link, you can see the picture, it is the
large container in the back with the hinged flap.

http://www.labsafety.com/search/sharps/9543/ 

We're using Biohazard sharps containers, then removing the Biohazard
label and affixing a HazWaste label instead. They are listed as
meeting
OSHA standards, but not anything about RCRA.  If anyone knows of a
source for chemical waste sharps, that would be great.

-----Original Message-----
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf
Of
Debbie Decker
Sent: Tuesday, June 19, 2007 8:12 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU 
Subject: Re: [DCHAS-L] "open" sharps containers

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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