Hi Pam,
Federal regulations do require waste containers to be kept closed when not pouring into them. This may be inconvenient, but does prevent "waste treatment by evaporation" which is prohibited by the EPA. However, "tightly closed" may be an
issue for some experiments if the waste generates gas overnight and can cause an explosion (saw the aftermath as an undergrad). So, it is prudent to use secondary containers. Better yet, include a step in the experiment to reduce the hazard level of the "soon
to be declared waste" (which is allowed) to eliminate the risk of over pressurizing the waste container.
I looked around your school's website a bit. Federal Regulations encourage the use of Integrated Contingency Plans (ICP). It appears your institution has chosen to also include the CHP, RSP, Bio Safety, and other plans into their ICP. Your
institution has chosen to use a separate webpage for each section of their ICP and also for each section of the CHP. Thus, at first glance it looks like you don't have a CHP. However, when you start to look you do find the required sections. PLEASE NOTE that
I'm not commenting on the quality of each section as I have really not read thru them.
Interestingly enough, your institution's policy specifically says not to store waste in hoods. Judging by the wording, most of it looks almost verbatim from the regulations. Thus, I wonder if the don't store waste in hoods is an extension
of the heuristic "don't store stuff in active hoods". I would gather the information already suggested by others to justify your current arrangement. I would also make the argument that hazardous wastes (i.e. acid, organic solvents) do pose a respiratory hazard.
Therefore, it is common to denote a hood as the Satellite Containment Area.. Please do a bit of homework on Satellite Containment Areas as these are supposed to be denoted in your plan and are the responsibility of the "local" researcher/CHO/stock room manager.
In addition to the resources others have pointed out, I also suggest the following EPA resources available for download at
https://www.epa.gov/nscep
Environmental Management Guide For Small Laboratories
EPA Enforcement Alert: Mismanagement of Laboratory Waste Creates Risk of Serious Injury
Management Of Hazardous Wastes From Educational Institutions Report To Congress (This is a critical review of bad practices found in the 80's. It is not explicit, but it does allude to
storage of waste inside cabinets as a bad practice.)
Hope this helps!
Yaritza Brinker
260..827.5402
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
On Behalf Of Pam Auburn
Sent: Thursday, February 13, 2020 5:58 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Chemical Waste Handling
Lone Star College was founded in 1973 and offers Associate Degrees, Workforce Certificates and Transfer Credits.
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Guide Background This Chemical Hygiene Guide provides a set of guidelines designed to protect the health and safety of faculty, staff and students in LSCS laboratories.
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2041 Branard
Houston TX 77098
Good James. That's the first question and why I advised Pamela to get on her own schools website and look for information about safety
programs. It will be there. Monona
Pamela,
Do you work at a public or private institution?
James A. Kaufman, Ph.D.
Founder, LSI
508-574-6264
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.
2041 Branard
Houston TX 77098
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