To be honest with all those who are interested in this topic
, the
berm idea does not make any sense considering the rare events where showers
are
used. As it was mentioned, the hazardous materials are so diluted tha
t it
is not logical to flood the floor (building) for the sake of preventing tra
ce
amounts of hazardous materials from going down the drain.
Thanks … M.A
From: DCHAS-L Discu
ssion
List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of Alan McCartney
Sent: Tuesday, November 02, 2010 10:50 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] FW: Lab safety showers
I might be mistaken, bu
t the
placement of the berm, will violate the life safety code (and rleated buldi
ng
codes) regarding smooth, trip free walking surfaces. I believe this limitat
ion
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 reque
st.
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 acr
oss
the letter of interpretation sometime in the future, would you post it here
for
us?
Thanks
Sec. 261.3 Definition of
hazardous waste.
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 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;
(D) A discarded
commercial chemical product, or chemical intermediate listed in Sec. 261.33
,
arising from de minimis losses of these materials from manufacturing operat
ions
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 from the unloading or transfer of materia
ls
from bins or other containers, leaks from pipes, valves or other devices us
ed
to transfer materials); minor leaks 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 emp
ty
containers or from containers that are rendered empty by that rinsing; or
(E) Wastewate
r
resulting from laboratory operations containing toxic (T) wastes listed in
subpart D of this part, Provided, That the annualized average flow of
laboratory wastewater does not exceed one percent of total wastewater flow
into
the headworks of the facility's
wastewater treatment or pre-trea
tment
system or provided the wastes, combined annualized average concentration do
es 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 discharge
d to
wastewater are not to be included in this calculation; or.....<
/o:p>
=========================
=========================
====
Safety Empor
ium -
Lab & Safety Supplies featuring brand names
Fax: (856)
553-6154, PO Box 1003, Blackwood, NJ 08012
On
Oct 28, 2010, at 5:54 PM, Mary Cavanaugh wrote:
I
don’t 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.
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 whe
n
the emergency shower is in use.
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 gallons of wat
er.
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
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 gallo
ns.
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 entire hallw
ay
or doorway - heck, or just around the drain itself, that might work by floo
ding
the rest of the building, as all it does is make the floor drain
non-functional. Plugging the floor drain permanently is an easier
solution.
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. Seriousl
y -
you get what, 10 mL of concentrated acid on you and that washes down the dr
ain
with 100 gallons of water? Yeesh. And if the stuff was so nast
y
toxic that it is a hazard even that dilue, this city review department thin
ks
it's better to spread the hazmat all over the building and down a couple fl
oors
onto various objects and people than it is to send it down the drain.<
/o:p>
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
.
==================
=========================
===========
Safety
Emporium - Lab & Safety Supplies featuring brand names
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 f
loor
drain in the event of a spill. Also, the curb has to be sloped on bot
h
sides to allow accessibility.
--
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