Check out Safety Emporium for your N95, N99, and face shield needs.
Date: Thu, 17 Feb 2011 11:59:26 -0800
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: Teresa Arnold <tarnold**At_Symbol_Here**GEORGEFOX.EDU>
Subject: Re: [NAOSMM] Expiration dates of chemicals/regulations
In-Reply-To: <OF6AD99116.58AC6C52-ON8525783A.006A881C-8525783A.006AA30F**At_Symbol_Here**notes.cc.sunysb.edu>
--90e6ba6e82d8b50b0c049c7fd50d
So true!
Teresa Arnold
Biology-Chemistry Lab Coordinator
tarnold**At_Symbol_Here**georgefox.edu
503-554-2724
Fax: 503-554-3884
414 N. Meridian St. #6144
Newberg, OR 97132
On Thu, Feb 17, 2011 at 11:24 AM, Kim Auletta
wrote:
> Our state Haz Waste inspectors call this "inherently waste -like" and lov
e
> to cite us for it. The researchers always argue they might need it some d
ay.
> Guess who looses?
>
> Kim Auletta
> Lab Safety Specialist
> EH&S Z=6200
> Stony Brook University
> kauletta**At_Symbol_Here**notes.cc.sunysb.edu
> 631-632-3032
> FAX: 631-632-9683
> EH&S Web site: http://www.stonybrook.edu/ehs/lab/
>
> Remember to wash your hands!
>
>
> From: Jeff Your To:
> DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
> Date: 02/17/2011 02:11 PM Subject: Re: [DCHAS-L] [NAOSMM] Expiration date
s
> of chemicals/regulations Sent by: DCHAS-L Discussion List <
> DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
> ------------------------------
>
>
>
> As regards old containers sitting on the shelf, I have heard many
> 'opinions' that regulators will offer.
>
> If the bottle is expired, is there a good reason for keeping it? Is it
> actively in use for research or instructional purposes?
>
> If the bottle looks old and you cannot document its regular circulation,
> then some instectors use the 'white glove' test. If I can wipe dust off
the
> top of the container, it's probably not being used and hasn't been for so
me
> time. Now the question becomes, Why are you keeping it? RCRA has a term
> for this: speculative accumulation.
>
> See article below. While spec.accum. specifically addresses certain
> hazardous wastes which could be recycled, it has also been applied to the
> situation of holding on to lots of old chemicals with no stated present o
r
> future purposes other than 'just in case we may need it some day'.
>
> So, have a real good idea what is being actively used in your teaching
> labs. Get rid of anything you can justify will not be used within the ne
xt
> year, expired or not. This is an iterative process as profs will put up
> resistance to throwing away 'perfectly good' reagents from the 1950's. W
eed
> regularly and a little at a time.
>
> *http://www.lion.com/newsletter/archives/2009/vol10issue47.asp*
>
> Speculative accumulation happens.
>
> Keeping in mind that the term =93speculative accumulation=94 is defined o
nly
> for the purpose of determining if a material is a solid waste [40 CFR
> 261.2(c)], the EPA=92s definition, at section 40 CFR 261.1(c)(8) starts s
imply
> with =93A material is =91accumulated speculatively=92 if it is accumulate
d before
> being recycled.=94
>
> But if we continue reading, we find that you may claim your recycling as
> legitimate, and your accumulation as NOT speculative, if you meet two
> conditions:
> 1. A feasible means of recycling the material exists, and
> 2. At least 75% of the material on-hand on January 1 is recycled b
y
> the end of the year.
>
> Remember to document everything! In any enforcement action, the burden of
> proof is on the generator to show that the waste is excluded and being
> legitimately recycled. [40 CFR 261.2(f)] That is, it is up to you to prov
e
> to the regulators that the material is not being speculatively accumulate
d.
>
> On the other hand, if you stockpile hazardous secondary material, make no
> arrangements to recycle it, all the while claiming that it will be recycl
ed
> later, the EPA will ask you to prove that the recycling is legitimate,
> feasible, and actually happening. If you cannot do this, then you are
> =93accumulating speculatively.=94 What happens next is, the waste will be
> reclassified as solid, and possibly as hazardous, waste, and you will get
to
> know your local agency very well.
>
> As always, state regulations may vary. Not every authorized state program
> permits every recycling relief, and your state may have particular standa
rds
> for documenting your recycling activities.
>
>
> --
> Jeffrey A. Your, M.B.A.,C.S.M.M.
> Science Buyer; Central Scientific
> Stores and Laboratory Support Services
> John Carroll University
> 20700 North Park Blvd.
> University Hts, Ohio 44118-4578
>
> 216.397.4244 vox 216.397.1803 fax 216.496.7594 cell
>
>
>
> ---- Original message ----
> *Date:* Thu, 17 Feb 2011 09:58:23 -0800*
> From:* Teresa Arnold *
> Subject:* [NAOSMM] Expiration dates of chemicals/regulations*
> To:* dchas-l , NAOSMM
>
>
> I had a question come to me from a High School, who is being dinged by a
> regulatory person. I don't have a definitive answer/source. Can you hel
p?
>
> One major
> question I have is the idea of =93shelf life=94. As a chemist, I know th
at
> some
> chemicals degrade over time. But the ones that create a hazard upon
> degrading
> are few and far between. What are the rules about shelf life particularl
y
> for
> inherited old chemicals? What actions are required and what are merely
> suggested?
>
> Thanks!
>
> Teresa Arnold
>
> George Fox University
>
> Biology-Chemistry Lab Coordinator
> *
> **tarnold**At_Symbol_Here**georgefox.edu*
>
> 503-554-2724
> Fax: 503-554-3884
>
> 414 N. Meridian St. #6144
> Newberg, OR 97132
>
>
>
--90e6ba6e82d8b50b0c049c7fd50d
So true!
Teresa Arnold
Biology-Chemistry Lab Coordinator
tarnold**At_Symbol_Here**georgefox.edu
503-554-2724
F
ax: 503-554-3884
414 N. Meridian St.=A0 #6144
Newberg, OR=A0 9713
2
On Thu, Feb 17, 2011 at 11:24 AM, Kim Au
letta
<kauletta**At_Symbol_Here**notes.cc.sunysb.edu> wrote:
Our state Haz Waste inspectors call th
is
"inherently waste -like" and love to cite us for it. The research
ers
always argue they might need it some day. Guess who looses?
Kim Auletta
Lab Safety Specialist
EH&S =A0 =A0Z=6200
Stony Brook University
kauletta**At_Symbol_Here**
notes.cc.sunysb.edu
631-632-3032
FAX: 631-632-9683
EH&S Web site: http://www.stonybrook.
edu/ehs/lab/
Remember to wash your hands!
| From:
| Jeff Your <jyour**At_Symbol_Here**JCU.EDU>
|
| To:
| |
| Date:
| 02/17/2011 02:11 PM
|
| Subject:
| Re: [DCHAS-L] [NAOSMM] Expira
tion dates
of chemicals/regulations
|
| Sent by:
| DCHAS-L Discussion List <<
a href="mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU" target="_blank">DCHAS-L**At_Symbol_Here**LIST.UVM.E
DU> |
As regards old containers sitting on the shelf, I have
heard many 'opinions' that regulators will offer. =A0
If the bottle is expired, i
s there a good reason for keeping
it? =A0Is it actively in use for research or instructional purposes?
If the bottle looks old and
you cannot document its regular
circulation, then some instectors use the 'white glove' test. =A0If
I can wipe dust off the top of the container, it's probably not being u
sed
and hasn't been for some time. =A0Now the question becomes, Why are
you keeping it? =A0RCRA has a term for this: speculative accumulation.
See article below. =A0While
spec.accum. specifically
addresses certain hazardous wastes which could be recycled, it has also
been applied to the situation of holding on to lots of old chemicals with
no stated present or future purposes other than 'just in case we may ne
ed
it some day'.
So, have a real good idea w
hat is being actively used in
your teaching labs. =A0Get rid of anything you can justify will not
be used within the next year, expired or not. =A0This is an iterative
process as profs will put up resistance to throwing away 'perfectly goo
d'
reagents from the 1950's. =A0Weed regularly and a little at a time.
Speculative accumulation happens.
Keeping in mind that the term
=93speculative accumulation=94
is defined only for the purpose of determining if a material is a solid
waste [40 CFR 261.2(c)], the EPA=92s definition, at section 40 CFR 261.1(c)
(8)
starts simply with =93A material is =91accumulated speculatively=92 if it
is accumulated before being recycled.=94
But if we continue reading,
we find that you may claim
your recycling as legitimate, and your accumulation as NOT speculative,
if you meet two conditions:
1. =A0 =A0 =A0 =A0A
feasible means of recycling the material exists, and
2. =A0 =A0 =A0 =A0At
least 75% of the material on-hand on January 1 is recycled by the end of
the year.
Remember to document everything! In any enforcement act
ion,
the burden of proof is on the generator to show that the waste is excluded
and being legitimately recycled. [40 CFR 261.2(f)] That is, it is up to
you to prove to the regulators that the material is not being speculatively
accumulated.
On the other hand, if you stockpile hazardous secon
dary
material, make no arrangements to recycle it, all the while claiming that
it will be recycled later, the EPA will ask you to prove that the recycling
is legitimate, feasible, and actually happening. If you cannot do this,
then you are =93accumulating speculatively.=94 What happens next is, the
waste will be reclassified as solid, and possibly as hazardous, waste,
and you will get to know your local agency very well.
As always, state regulations may vary. Not every au
thorized
state program permits every recycling relief, and your state may have parti
cular
standards for documenting your recycling activities.
--
Jeffrey A. Your, M.B.A.,C.S.M.M.
Science Buyer; Central Scientific
Stores and Laboratory Support Services =A0
John Carroll University =A0
20700 North Park Blvd. =A0 =A0 =A0 =A0 =A0
University Hts, Ohio 44118-4578 =A0
216.397.4244 vox =A0 =A0 =A0216.397.1803 fax =A0216.496.7594
cell
---- Original message ----
Date: Thu, 17 Feb 2011 09:58:23 -0800
From: Teresa Arnold <tarnold**At_Symbol_Here**georgefox.edu>
Subject: [NAOSMM] Expiration dates of chemicals/regulations
To: dchas-l <dchas-l**At_Symbol_Here**list.uvm.edu>, NAOSMM <naosmm**At_Symbol_Here**mailman.rice.edu>
I had a question come to me from a High School, who is being dinged by
a regulatory person. I don't have a definitive answer/source. =A0 Can
you help?
One major
question I have is the idea of =93shelf life=94. =A0As a chemist, I know
that some
chemicals degrade over time. =A0But the ones that create a hazard upon
degrading
are few and far between. =A0What are the rules about shelf life particularl
y
for
inherited old chemicals? =A0What actions are required and what are merely
suggested?
Thanks!
Teresa Arnold
George Fox University
Biology-Chemistry Lab Coordinator
tarnold**At_Symbol_Here**georgefox.edu
503-554-2724
Fax: 503-554-3884
414 N. Meridian St. =A0#6144
Newberg, OR =A097132
--90e6ba6e82d8b50b0c049c7fd50d--
Previous post | Top of Page | Next post