Rob, Pamela says there is no CHO and Waste Management is under Emergency Response. I think you can't even talk about OSHA rules as an option.
My advice to Pamela is to go to her own school's web page and search for any kind of information on safety from emergency plans to lab safety. Most of the UT system state schools have adopted the fed OSHA regulations. I even know one Texas UT art department with an exemplary program. And on my recommendation, they hired a professor with a bit of safety background in addition to being a good artist to help keep people on the straight and narrow.
But Pamela may confirm that her school is like (or is one of) two schools in her area I worked at that had no operating OSHA programs nor any intention of having such programs in the future. In one of these, a previous facilities safety person had provided a one page right to know set of rules to the art schools web page in 2011, but no one had done any labeling or training when I was there. And it was not really official so there was no enforcement.
Pamela is being asked to do things that are not good practice. And she is operating without a safety program. Just because it is "legal" in Texas, does not make it safe or right for her or for the students. There comes a point where choices must be made.
However, Pamela's question is about a process that also falls under EPA's jurisdiction. All Texas schools are under EPA's authority. In addition, Texas schools are very liability conscious in that tort reform state. So I will tell Pamela what I would do were I standing in her high top boots.
1) Contact the manufacturer of the hoods by email or letter (anyway to get a written response) and ask them if the cabinets under their hoods are the proper place to store hazardous waste along with the other chemical storage there. If you reach the right person and get a resounding "no," you have a legal issue with which to open a discussion with administrators about using equipment in ways other than the manufacturer recommends.
2) EPA has a confidential whistleblower reporting program. You clearly have no Satellite Accumulation Area or any of the other bells and whistles for waste handling. And I betcha a years salary I could find a bunch more issues if I looked. If I were Pamela, I'd be quietly cultivating some EPA regulators plus a plan B for a job somewhere else.
But that's only what I would do. Pamela may not to embark on a life like mine where she will hear regularly: "Oh god, she's here. What does she want NOW!"
Monona
-----Original Message-----
From: ILPI Support <info**At_Symbol_Here**ILPI.COM>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Sent: Thu, Feb 13, 2020 4:57 am
Subject: Re: [DCHAS-L] Chemical Waste Handling
I assume your employer is in Texas? Is your employer private or the state? Texas is under federal OSHA jurisdiction which covers most private sector workers within the state. State and local government workers are not covered by federal OSHA.
If you are covered by federal OHA then you need a Chemical Hygiene Plan (CHP), which requires a Chemical Hygiene Officer (CHO).
I=E2=80™m sure others on the list can speak to Texas requirements at state schools.
Best wishes,
Rob Toreki
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Can some one lead me to resources on how waste is collected and handled in teaching labs. There is some debate going on at my school. We do not have a chemical hygiene officer. Chemical waste falls under the Emergency Response Manager. She did not like our use of carboys with safety funnels, (labeled separated into aqueous, acid, organic and halogenated organic) in hoods and asked that we keep waste in closed containers in the cabinets beneath the hoods. I can see problems with this but do not know where to go for authoritative background.
Thanks
Pamela Auburn, PhD
2041 Branard
Houston TX 77098
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