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Subject: Re: shower berm
Date: Fri, 29 Oct 2010 09:43:02 -0400
Author: Don Abramowitz
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Subject: Re: Lab safety showers
Date: Fri, 29 Oct 2010 10:48:12 -0400
Author: Kristi Ohr
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Date: Fri, 29 Oct 2010 09:39:29 -0500
Reply-To: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Janet Baum <baum.janet**At_Symbol_Here**GMAIL.COM>
Subject: Re: Lab safety showers
In-Reply-To: <6695C7F4-697A-4611-A049-07E430636D42**At_Symbol_Here**ilpi.com>
Rob, Thank you for this EPA reference!
Janet Baum
On Thu, Oct 28, 2010 at 8:33 PM, ILPI wrote:
> Excellent. With that lead from Mary, I was able to look up where shower
> water is apparently exempted:
> http://edocket.access.gpo.gov/cfr_2005/julqtr/40cfr261.3.htm
>
> Sec. 261.3 Definition of hazardous waste.
> (snip)
> *however, the following mixtures of solid wastes and hazardous wastes
> listed in subpart D of this part are not hazardous waste*s (except by
> application of paragraph (a)(2)(i) or (ii) of this section) if the genera
tor
> can demonstrate that the mixture consists of wastewater the discharge of
> which is subject to regulation under either section 402 or section 307(b)
of
> the Clean Water Act (including wastewater at facilities which have
> eliminated the discharge of wastewater) and;
> (snip)
>
> (D) A discarded commercial chemical product, or chemical intermediate
> listed in Sec. 261.33, arising from de minimis losses of these materials
> from manufacturing operations in which these materials are used as raw
> materials or are produced in the manufacturing process.
> For purposes of this paragraph (a)(2)(iv)(D), ``de minimis'' losses inclu
de
> those from normal material handling operations (e.g., spills from the
> unloading or transfer of materials from bins or other containers, leaks f
rom
> pipes, valves or other devices used to transfer materials); minor leaks o
f
> process equipment, storage tanks or containers; leaks from well maintaine
d
> pump packings and seals; sample purgings; relief device discharges; *disc
harges
> from safety showers and rinsing and cleaning of personal safety equipment
;
> * and rinsate from empty containers or from containers that are rendered
> empty by that rinsing; or
>
> (E) Wastewater resulting from laboratory operations containing toxic
> (T) wastes listed in subpart D of this part, Provided, That the annualize
d
> average flow of laboratory wastewater does not exceed one percent of tota
l
> wastewater flow into the headworks of the facility's
> wastewater treatment or pre-treatment system or provided the wastes,
> combined annualized average concentration does not exceed one part per
> million in the headworks of the facility's wastewater treatment or
> pre-treatment facility. Toxic (T) wastes used in laboratories that are
> demonstrated not to be discharged to wastewater are not to be included in
> this calculation; or.....
>
> Rob
>
> =======================
=========================
======
> Safety Emporium - Lab & Safety Supplies featuring brand names
> you know and trust. Visit us at http://www.SafetyEmporium.com
> esales**At_Symbol_Here**safetyemporium.com or toll-free: (866) 326-5412
> Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012
>
>
>
> On Oct 28, 2010, at 5:54 PM, Mary Cavanaugh wrote:
>
> I don=92t have time to dig it up right now, but there is an EPA letter of
> interpretation that says that runoff from an emergency drench shower is n
ot
> hazardous waste. So containment is only necessary if your local POTW is
> requiring it.
>
> From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On
> Behalf Of Alan Hall
> Sent: Thursday, October 28, 2010 3:15 PM
> To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
> Subject: Re: [DCHAS-L] Lab safety showers
>
> I agree with Rob Torecki,
>
> This is a senseless regulation that would do much more harm than
> good, and presents a slip-and-fall hazard full time, not just when the
> emergency shower is in use.
>
> I also agree with how dilute most chemical splashes would be by the time
> you dilute them with 15 minutes **At_Symbol_Here** 20 gallons/minute = 300 gallons of wa
ter.
>
> Alan
> Alan H. Hall, M.D.
>
>
> Date: Thu, 28 Oct 2010 14:55:20 -0400
> From: info**At_Symbol_Here**ILPI.COM
> Subject: Re: [DCHAS-L] Lab safety showers
> To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
> Wow, thanks for sharing. That one is a poster child for Bad Regulations.
>
> 1. Let's say the berm encompasses a 4' x 4' area around the shower. That
's
> 16 square feet, one inch high, for a volume of 1.33 cubic feet = 10 gal
lons.
> Under ANSI Z358, showers must put out at least 20 gallons per minute. A
nd
> that shower is likely to flow for 5, if not 15 minutes. So the berm is
> essentially useless.
>
> Now, if the reg is calling for a berm that say, stretches across an entir
e
> hallway or doorway - heck, or just around the drain itself, that might wo
rk
> by flooding the rest of the building, as all it does is make the floor dr
ain
> non-functional. Plugging the floor drain permanently is an easier soluti
on.
>
> 2. The amount of hazardous material on a victim is going to be so
> exceedingly small and so diluted in the drains that it boggles the mind.
> Seriously - you get what, 10 mL of concentrated acid on you and that was
hes
> down the drain with 100 gallons of water? Yeesh. And if the stuff was
so
> nasty toxic that it is a hazard even that dilue, this city review departm
ent
> thinks it's better to spread the hazmat all over the building and down a
> couple floors onto various objects and people than it is to send it down
the
> drain.
>
> 3. When you're blinded by something and trying to find a shower on foot o
r
> on a wheelchair, even that 1" sloped bump is a barrier. And no doubt a t
rip
> hazard the rest of time no matter how well it's marked with floor tape.
>
> Rob Toreki
>
> =======================
=========================
======
> Safety Emporium - Lab & Safety Supplies featuring brand names
> you know and trust. Visit us at http://www.SafetyEmporium.com
> esales**At_Symbol_Here**safetyemporium.com or toll-free: (866) 326-5412
> Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012
>
>
> On Oct 28, 2010, at 2:31 PM, Betsy Shelton wrote:
>
>
> I am currently involved in construction of two new laboratories and was
> instructed by the city commercial building review department to include a
1"
> high curb around the shower area to keep hazmat from entering the floor
> drain in the event of a spill. Also, the curb has to be sloped on both
> sides to allow accessibility.
>
> --
> Best regards,
>
> Betsy Shelton
> 512.636.1905
> retrosynthesis**At_Symbol_Here**gmail.com
>
>
>
>
Rob, Thank you for this EPA reference!
Janet Baum
On Thu, Oct 28, 2010 at 8:33 PM, ILPI
<info**At_Symbol_Here**ilpi.com>
wrote:
Sec. 261.3
=A0Definition of hazardous waste.
(snip)
however, the following mixtures of solid wastes an
d hazardous wastes listed in subpart D of this part are not hazardous waste
s (except by application of paragraph (a)(2)(i) or (ii) of this section
) if the generator can demonstrate that the mixture consists of wastewater
the discharge of which is subject to regulation under either section 402 or
section 307(b) of the Clean Water Act (including wastewater at facilities
which have eliminated the discharge of wastewater) and;
(snip)
=A0=A0 (D) A discarded commercial chem
ical product, or chemical intermediate listed in Sec. 261.33, arising from
de minimis losses of these materials from manufacturing operations in which
these materials are used as raw materials or are produced in the manufactu
ring process.=A0
For purposes of this paragraph (a)(2)(iv)(D), ``de minimis'' l
osses include those from normal material handling operations (e.g., spills
from the unloading or transfer of materials from bins or other containers,
leaks from pipes, valves or other devices used to transfer materials); mino
r leaks of process equipment, storage tanks or containers; leaks from well
maintained pump packings and seals; sample purgings; relief device discharg
es; discharges from safety showers and rinsing and cleaning of personal
safety equipment; and rinsate from empty containers or from containers
that are rendered empty by that rinsing; or
=A0=A0 =A0(E) Wastewater resulting from laboratory oper
ations containing toxic (T) wastes listed in subpart D of this part, Provid
ed, That the annualized average flow of laboratory wastewater does not exce
ed one percent of total wastewater flow into the headworks of the facility&
#39;s=A0
wastewater treatment or pre-treatment system or provided the wastes, c
ombined annualized average concentration does not exceed one part per milli
on in the headworks of the facility's wastewater treatment or pre-treat
ment facility. Toxic (T) wastes used in laboratories that are=A0
demonstrated not to be discharged to wastewater are not to be included
in this calculation; or.....
Rob
=A0=A0========
=========================
=====================
S
afety Emporium - Lab & Safety Supplies featuring brand names
Fax: (856)
553-6154, PO Box 1003, Blackwood, NJ 08012
O
n Oct 28, 2010, at 5:54 PM, Mary Cavanaugh wrote:
I do
n=92t have time to dig it up right now, but there is an EPA letter of inter
pretation that says that runoff from an emergency drench shower is not haza
rdous waste.=A0 So containment is only necessary if your local POTW is requ
iring it.=A0
=A0
=A0
I agree with Rob Torecki,
=A0
This is a senseless regulation tha
t would do much more harm than good,=A0and=A0presents a slip-and-fall hazar
d full time, not just when the emergency shower is in use.
=A0
I also agree with how dilute most chemical splashes would be by the
time you dilute them with 15 minutes **At_Symbol_Here** 20 gallons/minute = 300=A0gallons
of water.
=A0
Alan
Alan H. Hall, M.D.
=A0
Date: Thu, 28 Oct 2010 14:55:20 -0400
From:=A0info**At_Symbol_Here**ILPI.COM
Subject: Re: [D
CHAS-L] Lab safety showers
To:=A0DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Wow, thanks for sharing. =A0That one is a poster child for Bad Re
gulations.
1. Let's say t
he berm encompasses a 4' x 4' area around the shower. =A0That's
16 square feet, one inch high, for a volume of 1.33 cubic feet = 10 gall
ons. =A0Under ANSI Z358, showers must put out at least 20 gallons per minut
e. =A0And that shower is likely to flow for 5, if not 15 minutes. =A0So the
berm is essentially useless.
Now, if the reg is calling for a b
erm that say, stretches across an entire hallway or doorway - heck, or just
around the drain itself, that might work by flooding the rest of the build
ing, as all it does is make the floor drain non-functional. =A0Plugging the
floor drain permanently is an easier solution.
2. The amount of hazardous materia
l on a victim is going to be so exceedingly small and so diluted in the dra
ins that it boggles the mind. =A0Seriously - you get what, 10 mL of concent
rated acid on you and that washes down the drain with 100 gallons of water?
=A0 Yeesh. =A0And if the stuff was so nasty toxic that it is a hazard even
that dilue, this city review department thinks it's better to spread t
he hazmat all over the building and down a couple floors onto various objec
ts and people than it is to send it down the drain.
3. When you're blinded by some
thing and trying to find a shower on foot or on a wheelchair, even that 1&q
uot; sloped bump is a barrier. =A0And no doubt a trip hazard the rest of ti
me no matter how well it's marked with floor tape.
=A0
=A0========================
=========================
=====
Safety Emporium - Lab & Safety Sup
plies featuring brand names
Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012
On Oct 28, 2010, at 2:31
PM, Betsy Shelton wrote:
=A0
I am currently involved in construction o
f two new laboratories and was instructed by the city commercial building r
eview department to include a 1" high curb around the shower area to k
eep hazmat from entering the floor drain in the event of a spill.=A0 Also,
the curb has to be sloped on both sides to allow accessibility.
--=A0
Best regards,
Betsy Shelton
512.636.1905
retrosynthesis**At_Symbol_Here**gmail
.com
=A0
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