Date: Thu, 17 Feb 2011 13:11:35 -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: bill parks <misterbill21225**At_Symbol_Here**YAHOO.COM>
Subject: Re: [NAOSMM] Expiration dates of chemicals/regulations
In-Reply-To: <FF70A3D197478C4A8E079799AD76FBEC06F406252F**At_Symbol_Here**gimli.morehead-st.edu>

--0-829485659-1297977095=:55116

All,
=C2=A0
Not sure where I read it - maybe Lab Standard, RCRA or some other EPA rule,
 Prudent Practices, Chemical Health & Safety, not really sure=C2=A0(could b
e a best practice recommendation) - something like chemicals should only be
 stored for a year, then dispose or waste out. 
=C2=A0
I know in OSHAland, whatever the manufacturer recommends, you follow, wheth
er it makes sense or not.
=C2=A0
I advise my clients during inspections to replace any chemicals older than 
a year. That helps eliminate the inherently waste-like, speculative accumul
ation, etc=C2=A0practices EPA folks like to cite.
=C2=A0
My personal best practice advice.

Bill Parks
CHST, CHMP, CEHT, LSP, RPIH
CHEMPHYXX......is now LinkedIn
630/380-4032

**Providing sound Industrial Hygiene, Occupational Health and Safety, Envir
onmental Health & IAQ, Environmental Science, and Laboratory support servic
es and solutions**

--- On Thu, 2/17/11, Rita Kay Calhoun  wrote:

From: Rita Kay Calhoun 
Subject: Re: [DCHAS-L] [NAOSMM] Expiration dates of chemicals/regulations
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Date: Thursday, February 17, 2011, 2:25 PM





But what regulation requires that you get rid of a chemical that you haven
=E2=80=99t used in a year or more?=C2=A0=C2=A0 There=E2=80=99s a difference
 between a suggestion and a regulation isn=E2=80=99t there?=C2=A0 In academ
ia, especially in small schools, upper level courses may not be taught ever
y year.=C2=A0 Also, according to who is teaching the chemicals needed might
 change.=C2=A0 To pay to dispose of, and then to purchase again in four or 
five years a perfectly stable chemical is wasteful, and usually we have to 
watch how we spend =C2=A0our money.=C2=A0 =C2=A0We also often need small am
ounts of a variety of compounds for unknowns.
=C2=A0
Kay
=C2=A0

From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of Ki
m Auletta
Sent: Thursday, February 17, 2011 2:25 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] [NAOSMM] Expiration dates of chemicals/regulations
=C2=A0
Our state Haz Waste inspectors call this "inherently waste -like" and love 
to cite us for it. The researchers always argue they might need it some day
. Guess who looses? 

Kim Auletta
Lab Safety Specialist
EH&S =C2=A0 =C2=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  

To: 

DCHAS-L**At_Symbol_Here**LIST.UVM.EDU 

Date: 

02/17/2011 02:11 PM 

Subject: 

Re: [DCHAS-L] [NAOSMM] Expiration dates of chemicals/regulations 

Sent by: 

DCHAS-L Discussion List 
=C2=A0




As regards old containers sitting on the shelf, I have heard many 'opinions
' that regulators will offer. =C2=A0 
If the bottle is expired, is there a good reason for keeping it? =C2=A0Is i
t actively in use for research or instructional purposes? 
If the bottle looks old and you cannot document its regular circulation, th
en some instectors use the 'white glove' test. =C2=A0If I can wipe dust off
 the top of the container, it's probably not being used and hasn't been for
 some time. =C2=A0Now the question becomes, Why are you keeping it? =C2=A0R
CRA has a term for this: speculative accumulation. 
See article below. =C2=A0While spec.accum. specifically addresses certain h
azardous wastes which could be recycled, it has also been applied to the si
tuation of holding on to lots of old chemicals with no stated present or fu
ture 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
. =C2=A0Get rid of anything you can justify will not be used within the nex
t year, expired or not. =C2=A0This is an iterative process as profs will pu
t up resistance to throwing away 'perfectly good' reagents from the 1950's.
 =C2=A0Weed 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 "speculative accumulation=" is
 defined only for the purpose of determining if a material is a solid waste
 [40 CFR 261.2(c)], the EPA=E2=80=99s definition, at section 40 CFR 261.1(c
)(8) starts simply with "A material is =E2=80=98accumulated specula
tively=E2=80=99 if it is accumulated before being recycled.=" 
But if we continue reading, we find that you may claim your recycling as le
gitimate, and your accumulation as NOT speculative, if you meet two conditi
ons: 
1. =C2=A0 =C2=A0 =C2=A0 =C2=A0A feasible means of recycling the material ex
ists, and 
2. =C2=A0 =C2=A0 =C2=A0 =C2=A0At least 75% of the material on-hand on Janua
ry 1 is recycled by the end of the year. 
Remember to document everything! In any enforcement action, the burden of p
roof is on the generator to show that the waste is excluded and being legit
imately recycled. [40 CFR 261.2(f)] That is, it is up to you to prove to th
e regulators that the material is not being speculatively accumulated. 
On the other hand, if you stockpile hazardous secondary material, make no a
rrangements 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, feas
ible, and actually happening. If you cannot do this, then you are "
accumulating speculatively.=" What happens next is, the waste will b
e 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 p
ermits every recycling relief, and your state may have particular 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 =C2=A0
John Carroll University =C2=A0
20700 North Park Blvd. =C2=A0 =C2=A0 =C2=A0 =C2=A0 =C2=A0
University Hts, Ohio 44118-4578 =C2=A0 =C2=A0

216.397.4244 vox =C2=A0 =C2=A0 =C2=A0216.397.1803 fax =C2=A0216.496.7594 ce
ll


---- 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 re
gulatory person. I don't have a definitive answer/source. =C2=A0 Can you he
lp?

One major
question I have is the idea of "shelf life=". =C2=A0As a che
mist, I know that some
chemicals degrade over time. =C2=A0But the ones that create a hazard upon d
egrading
are few and far between. =C2=A0What are the rules about shelf life particul
arly for
inherited old chemicals? =C2=A0What actions are required and what are merel
y
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. =C2=A0#6144
Newberg, OR =C2=A097132 

      
--0-829485659-1297977095=:55116

All,
 
Not sure where I read it - maybe Lab Standard, RCRA or some other EPA rule, Prudent Practices, Chemical Health & Safety, not really sure  ;(could be a best practice recommendation) - something like chemicals shoul d only be stored for a year, then dispose or waste out.
 
I know in OSHAland, whatever the manufacturer recommends, you follow, whether it makes sense or not.
 
I advise my clients during inspections to replace any chemicals older than a year. That helps eliminate the inherently waste-like, speculative ac cumulation, etc practices EPA folks like to cite.
 
My personal best practice advice.

Bill Parks
CHST, CHMP, CEH T, LSP, RPIH
CHEMPHYXX......is now LinkedIn
630/380-4032

**Pro viding sound Industrial Hygiene, Occupational Health and Safety, Environmen tal Health & IAQ, Environmental Science, and Laboratory support service s and solutions**

--- On Thu, 2/17/11, Rita Kay Calhoun <r. calhoun**At_Symbol_Here**MOREHEADSTATE.EDU> wrote:

From: Rita Kay Calhoun <r.calhoun**At_Symbol_Here**MOREHEADSTAT E.EDU>
Subject: Re: [DCHAS-L] [NAOSMM] Expiration dates of chemicals/ regulations
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Date: Thursday, February 17, 201 1, 2:25 PM

But what regulation requires that y ou get rid of a chemical that you haven=E2=80=99t used in a year or more?   There=E2=80=99s a difference between a suggestion and a regulati on isn=E2=80=99t there?  In academia, especially in small schools, upp er level courses may not be taught every year.  Also, according to who is teaching the chemicals needed might change.  To pay to dispose of, and then to purchase again in four or five years a perfectly stable chemic al is wasteful, and usually we have to watch how we spend  our money.& nbsp;  We also often need small amounts of a variety of compounds for unknowns.

 

Kay

 

From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of Kim Auletta
Sent: Thursday, February 17, 2011 2:25 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L ] [NAOSMM] Expiration dates of chemicals/regulations

 

Our state Haz Waste inspect ors call this "inherently waste -like" and love to cite us for it. The rese archers always argue they might need it some day. Guess who looses?

Kim Aule tta
Lab Safety Specialist
EH&S    Z=6200
Stony Bro ok University
kauletta**At_Symbol_Here**notes.cc.sunysb.edu
631-632-3032
FAX: 631-6 32-9683
EH&S Web site:
http://www.stonybrook.edu/ehs/lab/

Remember to wa sh your hands!


From:

Jeff Your <jyour**At_Symbol_Here**JCU.EDU>

To:

DCHAS-L**At_Symbol_Here**LIST.UVM.EDU

Date:

02/17/2011 02:11 PM

Subject:

Re: [DCHAS-L] [NAOSMM] Expiration dates of chemicals/regu lations

Sent by:

DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>

 





As regards old containers sitt ing 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 circulatio n, then some instectors use the 'white glove' test.  If I can wipe dus t off the top of the container, it's probably not being used and hasn't bee n for some 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 cert ain hazardous wastes which could be recycled, it has also been applied to t he situation of holding on to lots of old chemicals with no stated present or 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 th e next year, expired or not.  This is an iterative process as profs wi ll put up resistance to throwing away 'perfectly good' reagents from the 19 50's.  Weed regularly and a little at a time.
Speculative accumulation happens.
Keeping in mind that the term "speculative accumulation=E2=80 =9D is defined only for the purpose of determining if a material is a solid waste [40 CFR 261.2(c)], the EPA=E2=80=99s definition, at section 40 CFR 2 61.1(c)(8) starts simply with "A material is =E2=80=98accumulated s peculatively=E2=80=99 if it is accumulated before being recycled.="
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 co nditions:
1.        A feasible means of recycling the materi al exists, and
2.        At least 75% of the material on-han d on January 1 is recycled by 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 prove to the regulators that the material is not being speculatively accumulated.
On the other hand, if you stockpile hazardous secondary material, make no arrangements to recycle it, all the while claiming that it will be recy cled 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 =E2 =80=9Caccumulating speculatively.=" What happens next is, the waste will be reclassified as solid, and possibly as hazardous, waste, and you wi ll get to know your local agency very well.
As always, state regulations may vary. Not every authorized state prog ram permits every recycling relief, and your state may have particular stan dards for documenting your recycling activities.


--
Jeffrey A. Your, M.B.A.,C.S.M.M.
Scien ce Buyer; Central Scientific
Stores and Laboratory Support Serv ices  
John Carroll University  
20700 No rth Park Blvd.          
University Ht s, 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 <tarnold**At_Symbol_Here**georgefox.edu>
Subj ect:
[NAOSMM] Expiration dates of chemicals/regulations
To:
d chas-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 di nged by a regulatory person. I don't have a definitive answer/source.   Can you help?
One major
question I have is the idea of "shelf life=".  As a chemist, I know that some
chemicals degrade over time.   ;But the ones that create a hazard upon degrading
are few and far betwee n.  What are the rules about shelf life particularly for
inherited old chemicals?  What actions are required and what are merely
sugge sted?


Thanks!
Teresa Arnold

George Fox University

Biology-Chemistr y Lab Coordinator

tar nold**At_Symbol_Here**georgefox.edu

503-554-2724
Fax: 503-554-3884

414 N. Meridian St.  #6144
Newberg, OR  97132


--0-829485659-1297977095=:55116--

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