From: Jeffrey Lewin <jclewin**At_Symbol_Here**MTU.EDU>
Subject: Re: [DCHAS-L] Haz Waste Characterization Records
Date: Tue, 9 Feb 2021 07:30:02 -0500
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID: CAEwQnqjG6_b8NtAxJaDWfqPtzEeienO-py_Uq4wMEFU2+vWjvg**At_Symbol_Here**mail.gmail.com
In-Reply-To <729687058.330183.1612840105407**At_Symbol_Here**connect.xfinity.com>


Note that once you've determined you are collecting hazardous waste there are specific rules (in Michigan, which has adopted the EPA Generator Improvement Rules) for managing the waste containers including, what is commonly called the "4 L's of hazardous waste." They including Labeling (MUST have the words ``hazardous waste" plus either the contents OR EPA codes plus hazards in the container (words, GHS symbols, DOT symbols, etc.), Lids (must be closed when not adding or removing wastes - NO funnels sitting in the bottle), Location (near the "point of generation; some of my peers indicate their regulators want the container literally next to the point of generation (i.e. multiple containers), some allow a common container in the lab; most don't allow you to move that container to another room) and Leaks (container must be compatible with contents; leaking containers must be replaced; some some of my peer's regulators require (rather than suggest) secondary containment).

Note it is my understanding that the labeling requirements differ under Subpart K

I've summarized the above rules here.

Jeff

,

On Tue, Feb 9, 2021 at 5:50 AM JAMES PORTER <porterjb**At_Symbol_Here**comcast.net> wrote:
Very nice work! Thanks for sharing. Be well...Best, Jim
On 02/08/2021 8:50 PM Meg Osterby <megosterby**At_Symbol_Here**gmail.com> wrote:
When I was still in charge of chemistry labs while teaching at Western Technical College in LaCrosse, WI, I found that since WI is not a state where OSHA regs are generally followed in schools, the bottom line was I had to provide the information and segregation of the waste that the waste hauler required. They followed OSHA and DOT and WISDOT rules. My labs were all semi-micro, and we were a small school. So I kept two jugs going, with vapor locking funnel lids (I forget the brand name). One jug got all organic, not water soluble waste, except if it contained either Benedict's reagent or Biuret's reagent, both principally copper (II) sulfate. The waste recycling facility that the hauler delivered my waste to, wanted the copper sulfate separate.
For each jug, there was a signing sheet. Each student dumping their waste wrote in the sheet what they put in, including the various solvent rinses prior to washing. So an organic jug entry might read: Josey Student, 2mL acetone (rinse) today's date,. Next line, Josey Student, 2mL linolenic acid plus drops K2Cr2O7 solution.
I'd stand by the jug and help the first groups get it written correctly, then all the other lab groups could copy the first entry.
I found it rather silly, but that's what the folks who took it away wanted, and failure to comply could result in a fine and them refusing to take it away without a costly assay. So, I made the sheets for the students to sign, I helped them know what to write, and I used it as teachable moments about doing the right thing even though it is annoying. We literally could have dumped every test tube down the sink legally because we were such a small school and I filled 1 4-Liter jug of organic waste a year, and 1 of the copper (II) sulfate waste every two years. But our local water treatment plant did nothing to remove the dissolved or organics that went down our drains, and after treatment the water is returned to the Mississippi River, so it gave me the opportunity to talk about being "green" even when not required to because it's the right thing to do for our Planet, and for the local habitats and environment.
Hope everyone is staying warm. Supposed to go down to -14 Fahrenheit here tonight, and that's by the river. Where I am, up in the bluffs, it will be colder.

Meg Osterby

On Mon, Feb 8, 2021, 11:21 AM Monique Wilhelm < mwilhelm**At_Symbol_Here**umich..edu> wrote:
Hello Everyone,

I work in academia and most of teh haz waste taht I generate are
mixtures that come from our courses. Because they all follow the same
set procedure and are using known chemicals, I know the contents and
teh hazards prior to the wste benign generated and therefore it is
very unusual for me to have to do any actual tests to characterize the
waste prior to shipping it out.

I have been determine the hazards of our waste based on the materials
we supply them for the experiment and even use the 49 CFR to include
the hazard class for most of the chemicals in these mixtures of the
bottle label.

Our new EHS person wants us to start logging each waste bottle monthly
on a form similar to the one here
https://www.michigan.gov/documents/deq/Optional_Waste_Characterization_Record_Form_460914_7.pdf

Does anyone else do this or have any guidance for streamlining this process?

Thank you,
_________________________________________________________
Monique Wilhelm
Lab Manager
CAS, Department of Chemistry & Biochemistry | The University of Michigan-Flint
303 E. Kearsley St | Room 572 MSB | Flint, MI | 48502-1950
NEW EMAIL ADDRESS: mwilhelm**At_Symbol_Here**umich.edu

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--
Jeff Lewin
Director of Chemical Laboratory Operations
Research Integrity Office
Laboratory Operations
205 Lakeshore Center
Michigan Technological University

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