DCHAS-L Archives Nov 02 2010 - Re: FW: Lab safety showers

Dear Alan, You are correct with regard to the building codes. Berms in corridors are not allowed; they are trip hazards. The exception would be i f the safety shower were in an alcove to one side of the corridor and egress pathway. I have seen institutions and agencies install regular shower basins in alcoves for the safety showers. However, even those basins are inadequate to contain the volume of water emitted by safety showers, so you still have a mess to clean up. Janet Baum, AIA, DCHAS On Tue, Nov 2, 2010 at 12:50 PM, Alan McCartney wrot e: > I might be mistaken, but the placement of the berm, will violate the life > safety code (and rleated bulding codes) regarding smooth, trip free walki ng > surfaces. I believe this limitation is 1/8". > > On top of this, this triping hazard will directly compound & negatively > affect the worker's compensation exposure for the associated employees. > > I would think that the this trumps the local water / sewer inspectors > request. > > Alan > > On Mon, Nov 1, 2010 at 9:18 AM, Williams, Mark < > Mark.Williams**At_Symbol_Here**teledynees.com> wrote: > >> Thank you for the citation, Rob! >> >> Mary, if you run across the letter of interpretation sometime in the >> future, would you post it here for us? >> >> Thanks >> >> >> >> >> >> >> >> Mark Williams >> >> Teledyne Energy Systems Inc. >> >> 38 Loveton Cr >> >> Sparks MD 21152 >> >> 410-472-7733 >> >> mark.williams**At_Symbol_Here**teledynees.com >> >> >> ------------------------------ >> >> *From:* ILPI [mailto:info**At_Symbol_Here**ILPI.COM] >> *Sent:* Thursday, October 28, 2010 9:33 PM >> >> *Subject:* Re: Lab safety showers >> >> >> >> 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 gener ator >> 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 >> include those from normal material handling operations (e.g., spills fro m >> the unloading or transfer of materials from bins or other containers, le aks >> from pipes, valves or other devices used to transfer materials); minor l eaks >> of process equipment, storage tanks or containers; leaks from well >> maintained pump packings and seals; sample purgings; relief device >> discharges; *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 >> >> >> >> (E) Wastewater resulting from laboratory operations containing toxic >> (T) wastes listed in subpart D of this part, Provided, That the annualiz ed >> average flow of laboratory wastewater does not exceed one percent of tot al >> 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 i n >> 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 not >> 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 w ater. >> >> 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 >> gallons. Under ANSI Z358, showers must put out at least 20 gallons per >> minute. And 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 enti re >> hallway or doorway - heck, or just around the drain itself, that might w ork >> by flooding the rest of the building, as all it does is make the floor d rain >> non-functional. Plugging the floor drain permanently is an easier solut ion. >> >> >> >> 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 wa shes >> 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 depart ment >> 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 or >> on a wheelchair, even that 1" sloped bump is a barrier. And no doubt a trip >> 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 >> >> >> >> >> >> ______________________________________________________________________ >> This e-mail has been scanned by MCI Managed Email Content Service, using >> Skeptic(tm) technology powered by MessageLabs. For more information on M CI's >> Managed Email Content Service, visit http://www.mci.com. >> ______________________________________________________________________ >> > >

Dear Alan, You are correct with regard to the building codes. =A0Berms in c orridors are not allowed; they are trip hazards. =A0The exception would be if the safety shower were in an alcove to one side of the corridor and egre ss pathway. =A0I have seen institutions and agencies install regular shower basins in alcoves for the safety showers. =A0However, even those basins ar e inadequate to contain the volume of water emitted by safety showers, so y ou still have a mess to clean up.

Janet Baum, AIA, DCHAS

On Tue, Nov 2, 2010 at 12:50 PM, Alan McCartney <firesafeguy**At_Symbol_Here**gmail.com> wrot e:

I might be mistaken, but the placement of t he berm, will violate the life safety code (and rleated bulding codes) rega rding smooth, trip free walking surfaces. I believe this limitation is 1/8& quot;.=A0
On top of this, this triping hazard will directly compound & negati vely affect the worker's compensation exposure for the associated emplo yees.
I would think that the this trumps the local water / sewer inspectors r equest.

Alan

On Mon, Nov 1, 2010 a t 9:18 AM, Williams, Mark <Mark.Williams**At_Symbol_Here**teledynees.com> wrote:

Thank you for the citation, Rob!

Mary , if you run across the letter of interpretation sometime in the future, would you post it here for us?

Thanks

=A0

=A0

=A0

Mark Williams

Teledyne Energy Syst ems Inc.

38 Loveton Cr

Sparks MD 21152

410-472-7733

mark.williams**At_Symbol_Here**teledynees.com< /a>

=A0

From: ILPI [mailto:inf o**At_Symbol_Here**ILPI.COM]
Sent: Thursday, October 28, 2010 9:33 PM

Subject: Re: Lab safety show ers

=A0

Excellent. =A0With that lead from Mary, I was able to look up where shower water is apparently exempted: =A0http://edocket.access.gpo.gov/cfr_2005/julqtr/40cfr261.3.htm

=A0

Sec. 261.3 =A0Definition of hazardous waste.

(snip)

however, the following mix tures of solid wastes and hazardous wastes listed in subpart D of this part are not hazard ous wastes (except by application of paragraph (a)(2)(i) or (ii) of this section) if t he generator can demonstrate that the mixture consists of wastewater the disch arge 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 eliminat ed the discharge of wastewater) and;

(snip)

=A0

=A0=A0 (D) A discarded commercial chemical pro duct, 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.=A0

For purposes of this paragraph (a)(2)(iv)(D), ``de minimis'' losses 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 =A0(E) Wastewater resulting from labora tory operations containing toxic (T) wastes listed in subpart D of this part, Provided, That the annualized average flow of laboratory wastewater does no t exceed one percent of total wastewater flow into the headworks of the facility's=A0

wastewater treatment or pre-treatment system o r 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=A0

demonstrated not to be discharged to wastewate r are not to be included in this calculation; or.....

=A0

Rob

=A0

=A0=A0=========== ========================= ==================

Safety Emporium - Lab & Safety Supp lies featuring brand names

you know and trust. =A0Visit us at http://www.SafetyEm porium.com

esales**At_Symbol_Here**safetyemporium.com =A0or toll-free: (866) 326-5412

Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012

=A0

=A0

=A0

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 not hazardous waste.=A0 So containment is only necessary if your local POTW is requiring it.=A0

=A0

From:=A0DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU]=A0On Behalf Of=A0Alan Hall
Sent:=A0Thursday, October 28, 2010 3:15 PM

To:=A0DCHAS-L**At_Symbol_Here**LIS T.UVM.EDU
Subject:=A0Re: [DCHAS-L] Lab safety showers

=A0

I agree with Rob Torecki,
=A0
This is a senseless regulation that would do much more harm than good,=A0and=A0presents a slip-and-fall hazard 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 yo u 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: [DCHAS-L] Lab safety showers

To:=A0DCHAS-L**At_Symbol_Here**LIS T.UVM.EDU

Wow, thanks for sharing. =A0That one is a poster child for Bad Regulations.

=A0

1. Let's say the 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 fee t = 10 gallons. =A0Under ANSI Z358, showers must put out at least 20 gallons per minute. =A0And that shower is likely to flow for 5, if not 15 minutes. =A0So the berm is essentially useless.

=A0

Now, if the reg is calling for a berm that say, stretc hes across an entire hallway or doorway - heck, or just around the drain itself, that mig ht work by flooding the rest of the building, as all it does is make the floor drain non-functional. =A0Plugging the floor drain permanently is an easier solution.

=A0

2. The amount of hazardous material on a victim is goi ng to be so exceedingly small and so diluted in the drains that it boggles the mind. =A0Seriously - you get what, 10 mL of concentrated 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 rev iew department thinks it's better to spread the hazmat all over the buildin g and down a couple floors onto various objects and people than it is to send it down the drain.

=A0

3. When you're blinded by something and trying to find a shower on foot or on a wheelchair, even that 1" sloped bump is a barrier. =A0And no doubt a trip hazard the rest of time no matter how well it's marked wit h floor tape.

=A0

Rob Toreki

=A0

=A0=A0================ ========================= =============

Safety Emporium - Lab & Safety Supplies featuring brand names

you know and trust. =A0Visit us at=A0http://www.SafetyEmporium.com

esales**At_Symbol_Here**safetyemporium.com=A0=A0or toll-free: (866) 326-5412

Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012

=A0

=A0

On Oct 28, 2010, at 2:31 PM, Betsy Shelton wrote:

=A0

I am currently involved in construction of two new laboratories and was instruct ed 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.=A0 Also, the curb has to be sloped on both sides to allow accessibility.
--=A0

Best regards,
Betsy Shelton
512.636.1905
retrosynthesi s**At_Symbol_Here**gmail.com

=A0

______________________________________________________________________
This e-mail has been scanned by MCI Managed Email Content Service, using Skeptic(tm) technology powered by MessageLabs. For more information on MCI& #39;s Managed Email Content Service, visit http://www.mci.com.
______________________________________________________________________

About This Archive \|	DCHAS-L 2010 Index \|	DCHAS-L Yearly Index
Search All Posts: Advanced Search Disclaimer