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Previous by Date: Subject: Re: [DCHAS-L] Prescription Safety Glasses Suggestions Date: Friday, August 6, 2021 at 8:44:37 AM Author: Elizabeth Miller <lizannmiller2**At_Symbol_Here**GMAIL.COM> |
Next by Date: Subject: [DCHAS-L] Job Posting: CHO/RSO for Carleton College, Minnesota Date: Fri, 6 Aug 2021 13:14:03 -0500 Author: Patrick A Ceas |
Ralph,
The original question (*below) was asking how to classify waste DCM/Hexanes in storage and I answered that question accurately and with a regulatory citation. (a legitimate waste storage question; answered accurately)
"This would classify as flammable (primary hazard), toxic (subsidiary hazard) as DOT Hazard Classes are: 3 & 6.1 per 49 CFR 172.101. "
*We have an organic research lab that is producing solvent waste mixtures that are about 50% DCM and 50% hexanes and ethyl acetate. Does anyone know where I might find information for this mixture that might tell us whether this should be stored as flammable waste or non-flammable?
Thanks for any information on this.
- Ralph*
The classification I provided (for the benefit of the Listserv) would enable correct labeling and storage of described waste materials. (a legitimate waste storage question; answered accurately) This correct classification and labeling/storage is part of the waste determination process. The usefulness of my answers to lab workers enables lab workers to accurately classify/label/store their waste.
The utility of knowing the top current EPA RCRA violations for PIs/lab workers/their host institutions is this knowledge enables them to evaluate conditions and processes in their labs and to benchmark their lab operations against an external metric. At the same time, this process can reduce institutional risk, prevent potential lab mishaps, regulatory citations, and/or bad press. Disagreements over "appropriate Hazardous Waste Determinations‰?? is an excellent reason for developing a deeper understanding of regulatory requirements and related regional EPA citation and inspection histories. The original question was about waste storage; which falls in the EPA domain.
Top 3 EPA RCRA Violations:
1. Hazardous Waste Determinations
2. Container Labeling
3. Training
PR
-----Original Message----- >> Failure to perform appropriate Hazardous Waste Determinations is the #1 current EPA RCRA violation (40 CFR 262.11). Thanks for pointing this out, but I‰??m not sure that is useful information to share with lab workers when addressing their legitimate waste storage questions. I would also note that many EPA staff people disagree what "appropriate Hazardous Waste Determinations‰?? are in specific lab situations, not to mention the differences between state level regulators‰?? interpretations of this in 48 out of the 50 states. - Ralph Ralph Stuart, CIH, CCHO ralph.stuart**At_Symbol_Here**keene.edu --- ---
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From: ACS Division of Chemical Health and Safety
Sent: Friday, August 6, 2021 5:38 AM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Waste storage question (DCM & Hexanes / EPA Waste Determination)
Environmental Safety Manager
Keene State College
603 358-2859
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