As I understand it, static buildup occurs as a result of pumping and not as a result of pouring. This is because the static is created by the friction of the fluid against the tubbing/pipe/pump interior.. You are not going to create static by slowly pouring from a 4L container nor by pouring into a waste drum.

OSHA requires the grounding of containers when the transfer is done by pumping. Your HPLC machine is pumping. Thus, the kit recommended would be a good addition.

That said many of us (myself included) choose to "loose" this argument and end-up grounding everything on sight.. Not a bad thing to concede this particular battle to win the war.

Regarding how to ground a plastic drum- https://www.osha.gov/laws-regs/standardinterpretations/1986-10-06. I'm thinking (please others pipe in if I'm wrong) that you could use a metal funnel with a flame arrester and ground to it. Most hazmat waste drum funnels come with self-closing lids (req to meet the closed container clause). Some funnels also have over-fill prevention, which could have solved your initial problem.

Here's a bit nobody has brought up- flammable materials stored in plastic drums and/or totes have fire suppression requirements that are not necessarily the same if storing the same liquid in metal drums. I don't know much about the ins and outs of this particular clause, but you should look into it if you haven't already. Maybe someone in the list can shed some light?

Thank you,

Yaritza Brinker

260.827.5402

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> On Behalf Of ILPI Support
Sent: Wednesday, December 18, 2019 8:52 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] flammable hazardous waste

** External Email **

Justrite makes a line of of HPLC direct-to-waste systems. Disclaimer: my company is a Justrite distributor. We haven=E2=80™t added these to our own web site yet but you can find examples here:

https://www.justrite.com/safety-cans-and-containers/laboratory-hplc-disposal-containers.html

https://www.justrite.com/quick-disconnect-disposal-safety-can-polypropylene-fittings-for-3-8-tubing-5-gal-poly-white.html

https://www.justrite.com/disposal-can-with-faucet-quick-disconnect-s-s-fittings-for-1-4-tubing-5-gallon-poly-white.html

Those are list prices. Never pay list.

Best wishes,

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 Dec 18, 2019, at 6:26 AM, Melissa Ballard <melissa.ballard**At_Symbol_Here**MICHELIN.COM> wrote:

I would appreciate your feedback on my situation. We have recently replaced our single satellite accumulation container that was a 5-gallon metal drum to 2 separate plastic (UN approved) translucent "drums". This was at the suggestion of one of the environmental coordinators at the site. Now the other environmental coordinator & the "fire guy" are saying this is unacceptable because we cannot ground the plastic containers. We only use glass beakers or flasks to pour waste into these containers or it is waste going directly into a container from a HPLC (essentially a closed system).

Is this really a "fire risk"? I recognize that there may be a small potential for static to build in a plastic container, but we are not really "transferring or dispensing" from these containers in the traditional sense. The original starting materials are purchased in plastic 4L containers or glass containers which cannot be grounded when pouring out of either. I am having a hard time understanding the push to go back to a metal container just so we can ground it. I will add that the plastic gives us the ability to see the volume of liquid in the container so we will not over-fill it.

Thoughts on how to handle this? The plastic containers meet the requirements for the waste as per NFPA/DOT so it is just a question of fire risk.

Thanks for your input!

Melissa BALLARD - MSPH, CIH, CSP, CCHO

Industrial Hygienist / Industrial Hygiene Chemist

melissa.ballard**At_Symbol_Here**michelin.com

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