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Disclaimer i
Disclaimer
This Manual represents a good faith effort to compile and accurately explain Federal Safety and
Environmental Laws of relevance to optical labs. It has been revised from the original OLA
document to reflect changes in OSHA and EPA regulations. Due to the complexity of and
frequent changes in the law in this area, the publisher, The Vision Council Lab Division does not
warrant the completeness or accuracy of the materials herein and expressly disclaims any and all
liability arising from use of this Manual. This Manual does not constitute, and is not a substitute
for, legal advice for each individual operation. This Manual does not cover state and local laws.
The Appendix hereto does include contacts for state OSHA and EPA Offices for additional
information. It is the responsibility of the user to ensure that they are in compliance with all
federal, state and local laws that apply to their company.
Copyright 2005, revised 2019, Vision Council Lab Division. Members of The Vision Council (TVC) Lab Division
may use, print copies of, and make electronic copies of this Manual, solely for use within their company, and not for
sale or other distribution outside of their company. No other person or company may print, copy in any media, or
distribute in any media any portion of this Manual without the express written consent of Vision Council Lab
Division.
Preface ii
Preface
Environmental compliance and employee safety are two essential responsibilities of the 21st
century optical laboratory manager. Unmanaged, these issues could place a lab at risk of heavy
government fines as well as increased costs of operation. This manual is designed to assist the
optical laboratory manager to address common concerns using chemicals in their facility.
The risk of fines from the Occupational Safety & Health Administration (OSHA) and the
Environmental Protection Agency (EPA) is existent, even if it has never had a government
inspection. Ignoring the safety and environmental aspects of business could increase costs and
increase the risk of employee injuries relating to chemical use. This manual is based on Federal
EPA and OSHA regulations. Some states and local areas may have additional requirements.
Following OSHA and EPA regulations is like paying taxes, it is something that takes time and
money, but it is part of doing business.
Proper management of waste and chemicals should contribute to making the lab more efficient
and profitable. If large quantities of waste are generated from lab processes, it affects the cost of
operations because more chemicals are purchased than necessary. Using the least amount of
chemicals to create the most amount of product is just good business.
A lab manager’s responsibilities are growing, and the realization that there is another “required
program” may be overwhelming. The best way to develop a program is to prioritize and
implement one step at a time. Setting annual goals and tracking their progress is important. EPA
and OSHA compliance is a management function, and it is a very achievable responsibility. This
manual gives a road map to avoid the common mistakes that are often made and to build the
foundation of an OSHA and EPA Program. Having this basic knowledge will make it much
easier to comply with these regulations. Lab management may want professional assistance with
a program, but much of the work can be done by existing resources. This manual is the first step
on a journey that is not difficult to complete, but will help protect the environment, safeguard
your employees and help an optical laboratory to become a better corporate citizen.
Remember: Ignorance of the law is not an excuse. The government contends that as a manager,
you knew or should have known regulations affecting your operation. Maintenance checklists
Table of Contents
Disclaimer .................................................................................................................................... i
Preface ......................................................................................................................................... ii
Section 1 Hazard Communication ............................................................................................... 1
1. Optical Laboratory Hazard Communication ................................................................... 1
Executive Summary ........................................................................................................ 1
Hazard Communication Standard ............................................................................................... 2
Guide to Globally Harmonized System .......................................................................... 4
Hazard Communication Standard Compliance ............................................................... 4
STEP I: Understand The Purpose Of The Globally Harmonized (GHS) Hazard
Communication Standard.................................................................................................... 4
STEP II: Read And Understand The Hazard Communication Standard ............................ 4
STEP III: Assign Responsibility ......................................................................................... 4
STEP IV: Prepare An Inventory List Of Chemicals In The Workplace ............................. 5
STEP V: Ensure That Containers Are Properly Labeled .................................................... 5
STEP VI: Obtain Safety Data Sheets For All Chemical Sunstances .................................. 7
STEP VII: Develop And Implement A Written Hazard Communication Program ............ 8
STEP VIII: Make Safety Data Sheets Available To All Workers ...................................... 9
STEP IX: Hazard Communication Employee Information And Training .......................... 9
STEP X: Establish Procedure To Maintain A Hazard Communication Program ............ 11
STEP XI: Evaluating Program Effectiveness ................................................................... 11
Sample Of A Written Hazard Communication Program .......................................................... 12
Hazard Communication Program ................................................................................. 12
1. Company Policy ............................................................................................................ 12
2. Container Labeling........................................................................................................ 12
3. Safety Data Sheets (SDS) ............................................................................................. 13
4. Employee Information and Training ............................................................................. 13
5. Hazards of Non-Routine Tasks ..................................................................................... 13
6. Informing Other Employers/Contractors ...................................................................... 14
7. List of Hazardous Chemicals ........................................................................................ 14
8. Chemicals in Unlabeled Pipes ...................................................................................... 14
9. Program Availability ..................................................................................................... 14
Frequently Asked Hazard Communication Questions ...................................................... 15
What is the application of a Hazard Communication Program to an office
environment?............................................................................................................. 15
Is a Safety Data Sheet (SDS) required for a non-hazardous chemical? .................... 15
What are the requirements and limits to using a generic SDS? ................................ 15
What are the requirements for refresher training or retraining a new hire? .............. 15
Can the SDS be stored on a computer to meet the accessibility requirements of the
Hazard Communication Program? ............................................................................ 16
SECTIONS OF AN SDS AND THEIR SIGNIFICANCE ........................................... 16
Summary ....................................................................................................................... 17
Section 2 Chemical Safety in The Optical Laboratory ............................................................. 19
Executive Summary ...................................................................................................... 19
What Are Hazardous Substances? ............................................................................ 19
How Do Hazardous Substances Affect Employees? ................................................ 19
How To Know If Hazardous Substances Are A Risk In The Workplace? ............... 20
What Needs To Be Done To Protect Employees? .................................................... 20
Practical Solutions To Reduce Risks Of Hazardous Substances .............................. 20
General Safe Work Practices When Working With Solvents ................................... 21
Review The Safety Precautions In The Safety Data Sheet ........................................... 21
How Solvents Can Enter The Body .............................................................................. 22
Basic Safe Working Methods For All Solvents ............................................................ 22
What Is “Flash Point”?.............................................................................................. 23
The NFPA Diamond ................................................................................................. 24
NFPA Rating And Label Codes For Solvents .................................................................. 24
Solvent Safety Checklist ................................................................................................... 24
Chemical Spill And Cleanup Procedures .......................................................................... 26
Section 3 Optical Laboratory Environmental Management ...................................................... 35
Executive Summary ...................................................................................................... 35
Background ................................................................................................................... 35
Typical Laboratory Waste And Treatment Options ...................................................... 66
Optical Laboratory ............................................................................................................ 70
Waste Disposal Matrix .................................................................................................. 70
Summary ....................................................................................................................... 78
Disclaimer ..................................................................................................................... 78
List of Tables
Table 1: Acronym Definitions ...................................................................................................... i
Table 2: Basic Elements of the HazCom Program ...................................................................... 2
Table 3: Potentially Hazardous Chemicals Present in Typical Labs .......................................... 3
Table 4: Hazardous Optical Lab Waste ..................................................................................... 40
Table 5: Characteristic Laboratory Waste ................................................................................. 43
Table 6: Characteristic Laboratory Waste ................................................................................. 45
Table 7: Finishing Operations/Surfacing Operations ................................................................ 71
List of Figures
Figure 1: A container label that is not legible enough to identify the contents ........................... 5
Figure 2: A container with unknown contents is a violation of the OSHA Hazard
Communications Standard for labeling ....................................................................................... 6
Figure 3: Gasoline stored in an improper container. The container label does not identify the
contents and hazard level. ........................................................................................................... 6
Figure 4: This SDS binder is kept in the lab for reference by employees who work with
chemicals as is required by the HCS ........................................................................................... 9
Figure 5: Many of the containers storing hazardous materials do not have the respective SDS
that are required by the Hazardous Communication Standard .................................................. 21
Figure 6: National Fire Protection Association hazardous material label that identifies the
health, fire hazard and reactivity of a chemical ........................................................................ 24
Figure 7: Large quantities of flammable liquids must be stored in an appropriate storage
building or locker. Check with your local fire department regarding how to store flammable
liquids to reduce the likelihood of a fire or chemical release. ................................................... 25
Figure 8: Plunger that can be used to dispense a flammable liquid. This reduces the amount of
hazardous liquids that are being used in an operation. .............................................................. 26
Figure 9: An absorbent material being used to clean up and contain a chemical spill. ............ 27
Figure 10: Example of a well-equipped chemical spill kit ........................................................ 27
Figure 11: Absorbent sock used to contain chemical spills ...................................................... 30
Figure 12: An eyewash station located adjacent to a tinting unit in the lab .............................. 31
Figure 13: A spill blocker mat that is used to prevent a chemical spill from entering a storm
drain ........................................................................................................................................... 32
Figure 14: Waste from 55-gallon drums being pumped into a tanker truck for removal to a
waste disposal site ..................................................................................................................... 36
Figure 15: Lab waste being stored and waiting for proper disposal due to not being permitted
to dispose of the production waste into the sewer system, by order of the local sanitation
district ........................................................................................................................................ 39
Figure 16: An example of a hazardous waste label used to identify the contents. This type of
label is an EPA requirement for waste waiting for disposal. .................................................... 41
Figure 17: A hazardous waste storage area with a secondary containment system placed
around the drum to prevent hazardous waste from releasing if there is a leak. Drums must be
sealed when chemicals are not being added. ............................................................................. 42
Figure 18: Low melting point alloy (LMPA) blocking system ................................................. 44
Figure 19: Lens protective tape cover with a lead-based alloy. This type of waste must be
disposed of as hazardous waste. ................................................................................................ 46
Figure 20: Example of a warning sign for handling chemicals ................................................. 47
Figure 21: Unidentified waste that might be hazardous. This is an example of a violation of the
Hazard Communications Standard and EPA regulations for identification of waste. .............. 52
Figure 22: Low-melting-point alloy reclaim tank. Notice the loose alloy surrounding the tank.
The water and sludge are hazardous waste (HW) produced by the tank when a lead-based alloy
is used. ....................................................................................................................................... 57
Figure 23: This is an example of a treatment unit for AR-coating waste. Caustic liquid waste is
combined with water in the clear plastic tank. The pH of the waste is adjusted with 5%
Hydrochloric Acid to make it suitable for sewer disposal. A local permit was obtained to
discharge treated waste in the sewer system. ............................................................................ 59
Figure 24: An automatic pH meter used to check the pH level of caustic waste prior to its
discharge into the sewer system. The lab has a permit from the local sewer system authority to
discharge pH-adjusted waste. .................................................................................................... 59
Figure 25: Dispensing pump for hydrochloric acid designed to mix with caustic waste for a pH
neutralization process. The pump will adjust the hazardous caustic waste close to a neutral pH,
which is suitable for sewer disposal. ......................................................................................... 60
Figure 26: A waste drum used to collect unserviceable tinting chemicals. Note the two
environmental violations: (1) The top of the drum has been left open when not in use (2) The
drum has no label identifying its contents. It should be labeled as non-hazardous tinting waste.
................................................................................................................................................... 64
Figure 27: A wastewater evaporation system that can be used to reduce waste volume from
most water-based materials, including tints and reclaim tank water. The residue waste can be
hazardous or non-hazardous, depending on the material being evaporated. ............................. 65
Figure 28: Lens surfacing equipment produces large volumes of non-hazardous waste, which
should be treated prior to disposal or, a permit for sewer disposal can be obtained from local
authorities, depending on local regulations. .............................................................................. 66
Figure 29: An automatic cleaning centrifuge used to process production waste from lens
generators .................................................................................................................................. 68
viii
Table 1: ACRONYM Definitions
AR Anti-Reflective (Coating)
AUL Authorized Use List
CESQG Conditionally Exempt Small Quantity Generators
CFR Code of Federal Regulations
DMV Department of Motor Vehicles
DOT Department of Transportation
EPA Environmental Protection Agency
GHS Globally Harmonized System
HAZCOM Hazard Communication
HAZ-MAT Hazardous Materials
HAZWOPER Hazardous Waste Operations and Emergency
Response
HCP Hazard Communication Program
HCS Hazard Communication Standard
HID High-Intensity Discharge
HW Hazardous Waste
ID Identification
IRIS Incident Reporting Information System
LMPA Low Melting Point Alloy
LQG Large Quantity Generators
MSDS Material Safety Data Sheet (has been replaced by
SDS)
NFPA National Fire Protection Association
NRC National Response Center
OLA Optical Laboratories Association
OSHA Occupational Safety and Health Administration
PPE Personal Protection Equipment
RCRA Resource Conservation and Recovery Act
SDS Safety Data Sheet
SOP Standard Operating Procedure
SQG Small Quantity Generators
SRP Standard Report Form
TDD Telecommunications Device for the Deaf
TSDF Treatment, Storage and Disposal Facility
1
Section 1 Hazard Communication
1. Optical Laboratory Hazard Communication
Executive Summary
If an optical laboratory uses chemicals, it is very likely that federal regulations require a Hazard
Communication (HAZCOM) Program. Nearly all optical laboratories fall under this requirement.
In 2012 the Occupational Safety & Health Administration (OSHA) revised the Hazard
Communication Standard (HCS), by incorporating requirements of the Globally Harmonized
System. Employers must update their HAZCOM programs, including employee training, Safety
Data Sheets and container labeling, to comply with the revised OSHA GHS standard by 2015
Occupational Safety & Health Administration (OSHA) revised the Hazard Communication
Standard (HCS), by incorporating requirements of the Globally Harmonized System. Employers
must update their HACOM programs, including employee training, Safety Data Sheets and
container labeling, to comply with the revised OSHA GHS standard by 2015.
OSHA HAZCOM is based on a simple concept, that employees have both a need and a right to
know the hazards and identities of the chemicals they may be exposed to in the workplace. They
must also know what protective measures are available to prevent adverse health effects from
occurring. When employees are trained about the chemicals they use, they can take steps to
reduce exposures, substitute less hazardous materials, and establish proper work practices. These
efforts will help prevent the occurrence of work-related illnesses and injuries caused by
chemicals.
Before a new chemical is introduced in the lab, it is a good practice to review the Safety Data
Sheets (SDS), formerly Material Safety Data Sheet (MSDS), for potential chemical hazards.
Employees must be aware of any dangers when using the chemical and must take appropriate
safety precautions. If the chemical presents a health or safety hazard, a less hazardous chemical
should be considered as a replacement. A trained person familiar with the HCS should be
responsible to make the determination if a chemical should be included in the HAZCOM
Program, and to review all orders for new chemicals prior to the chemical being ordered. The
chemical hazards to employees and any concerns relating to disposal of waste should be
evaluated as part of the ordering process.
Common household items such as glass cleaner, whiteout and non-hazardous chemicals used in
the same quantities and manner as home use do not have to be included in the HAZCOM
Program It is the employer’s responsibility to review the chemicals to make the determination if
a chemical presents any hazards to employees and to comply with the requirements of the
standard to protect them. It is recommended to include all chemicals that present hazards to
employees in the HAZCOM Program.
Source: OSHA Publication 3104 and 3111
NOTE: Segments reprinted with permission of Oklahoma State University Environmental
Health and Safety Department.
2
Table 2: Basic Elements of the HazCom Program
1. A written hazard communication program.
2. Labeling of containers of chemicals for contents and chemical hazards.
3. Maintaining Safety Data Sheets (SDS) for all hazardous chemicals.
4. Providing information and training to employees on chemical hazards in the
workplace.
Hazard Communication Standard
In order to ensure chemical safety in the workplace, information about the identities and hazards
of the chemicals must be available and understandable to workers. OSHA’s Hazard
Communication Standard (HCS) requires the development and dissemination of such
information.
Chemical manufacturers and importers are required to evaluate the hazards of the chemicals they
produce or import, and prepare labels and safety data sheets to convey the hazard information to
their downstream customers.
All employers with hazardous chemicals in their workplaces must have labels and Safety Data
Sheets for their exposed workers, and train them to handle the chemicals appropriately.
Hazard Communication Standard:
• Hazard Classification: Provides specific criteria for classification of health and physical
hazards, as well as classification of mixtures.
• Labels: Chemical manufacturers and importers are required to provide a label that
includes a harmonized signal word, pictogram, and hazard statement for each hazard
class and category. Precautionary statements must also be provided.
• Safety Data Sheets: Have a specified 16-section format.
• Information and Training: Employers are required to train workers on labels, elements,
and Safety Data Sheet format to facilitate recognition and understanding.
The following table identifies some types of potentially hazardous chemicals that may be present
in a typical lab.
3
Table 3: Potentially Hazardous Chemicals Present in Typical Labs
Characteristic Laboratory Waste Examples
ACETONE
ACIDS
ALCOHOL
AR STRIPPER
CATALYSTS (e.g., USED FOR SLAB-OFF
LENSES)
CAUSTICS
FIBERGLASSTM
FUELS
GASOLINE
GREASES
INKS
LENS COATING MATERIAL
LENS TANK CLEANER
LENS TINTS
LIQUID RESIN
LOW MELTING-POINT ALLOY (LMPA)
(CONTAINING LEAD and CADMIUM)
NEUTRALIZER
PAINTS
PESTICIDES
SOLDER
SOLVENTS
SOME CLEANING AGENTS
SOME JANITORIAL SUPPLIES
4
Guide to Globally Harmonized System
Hazard Communication Standard Compliance
STEP I: Understand The Purpose Of The Globally Harmonized (GHS) Hazard Communication Standard
The GHS Hazard Communication Standard (HCS),
https://www.osha.gov/lawsregs/regulations/standardnumber/1910/1910.1200, establishes the
requirements to assure that the hazards are evaluated for all chemicals imported into, produced,
or used in U.S. workplaces, and that the resultant hazard information and associated protective
measures are transmitted to employees working with these chemicals. Chemical manufacturers
and importers must communicate the hazard information they learn from their evaluations to the
user of the chemical by the means of labels on the containers and a Safety Data Sheet (SDS) for
each chemical. The program ensures that all employers receive the information they need to
inform and train their employees properly. It also provides necessary hazard information to
employees, so they can participate in, and support, the protective measures in place at their
workplaces.
STEP II: Read And Understand The Hazard Communication Standard
The standard itself is long and some parts are technical, but the basic concepts are simple. In fact,
the requirements reflect what many employers have been doing for years. Many lab managers
may find that they already largely comply with many of the provisions and will simply have to
modify existing programs somewhat. A lab that is operating in a state that requires an OSHA-
approved State Plan, must comply with the state requirements, which may be different than those
of the Federal rule. Many of the State Plan States have had hazard communication or “right-to-
know” laws prior to the Federal rule. Employers in State Plan States should contact their state
OSHA Offices for more information regarding applicable requirements.
STEP III: Assign Responsibility
Hazard communication will be a continuing program in a lab. Compliance with HCS is not a
“one shot deal.” In order to have a successful program, lab management must assign
responsibility for both the initial and ongoing activities that have to be undertaken to comply
with the rule. In some cases, these activities may be part of current job assignments. For
example, Department Supervisors are frequently responsible for on-the-job training sessions.
Early identification of the responsible employees and their involvement in developing an action
plan will result in a more effective program. Involving affected employees also will enhance the
evaluation of the quality of a program. For any safety and health program, success depends upon
commitment at every level of the organization. This is particularly true for a Hazard
Communication Program where success requires a change in behavior when working with
chemicals. This will occur only if employers understand the program and are committed to its
success, and if the people presenting the information motivate employees.
5
STEP IV: Prepare An Inventory List Of Chemicals In The Workplace
Creating an Authorized Use List (AUL) of chemicals, including the name, manufacturer and
maximum amount allowed for each chemical, will be a component of a lab’s compliance with
the standard. Having control of what chemicals are in the lab may save money by not ordering
unnecessary chemicals and not storing excess quantities of chemicals that could create a safety
hazard and storage problems. A manager should walk around the workplace, read all container
labels, and list the identity of all materials that may be hazardous, including the work area where
the product is used and the manufacturer’s product name, location, telephone number. It is
critical to include hazardous chemicals that are generated in the work operation, but are not in a
container. Check with the purchasing department to ensure that all hazardous chemicals, before
being purchased, are included on the AUL. Purchasing new chemicals should not be approved
unless they are on the lab’s AUL. See Figure 1 below.
Figure 1: A container label that is not legible enough to identify the contents
STEP V: Ensure That Containers Are Properly Labeled
The primary information to be obtained from an OSHA-required label is the identity of the
material and appropriate hazard warnings. The identity is any term that appears on the label, the
SDS, and the list of chemicals, thus linking these three sources of information. The identity used
by the supplier may be a common or trade name or a chemical name. The hazard warning is a
brief statement of the hazardous effects of the chemical (e.g., “flammable,” “causes lung
damage”). Labels frequently contain other information, such as precautionary measures (e.g., “do
not use near open flame”), but this information is provided voluntarily and is not required by the
rule. Labels must be legible and prominently displayed. There are no specific requirements for
size or color. See Figure 2 and Figure 3 below.
6
Figure 2: A container with unknown contents is a violation of the OSHA Hazard Communications Standard for
labeling
Figure 3: Gasoline stored in an improper container. The container label does not identify the contents and
hazard level.
7
In terms of labeling systems, a lab may choose to use the labels provided by the suppliers on the
containers. These will generally be text labels, and do not usually include numerical rating
systems or symbols that require special training. The most important thing to remember is that
this is a continuing program and all containers of all chemicals must always be labeled.
Therefore, it is important to designate someone to be responsible for ensuring that the labels are
maintained as required on the containers in the lab, and that newly purchased materials are
checked for labels prior to use.
STEP VI: Obtain Safety Data Sheets For All Chemical Substances
Chemical manufacturers and importers are required to obtain or develop a Safety Data Sheet
(SDS) for each hazardous chemical they produce or import. Distributors are responsible for
ensuring that their customers are provided a copy of these documents. Employers must have an
SDS for each hazardous chemical used that could result in an employee being exposed to a
chemical hazard. An example of an article that would not be included in your Hazard
Communication Program would be a sealed toner cartridge for a printer or copier. An SDS is not
required for a toner cartridge, since the chemicals are contained in the sealed cartridge, and under
normal use, the employee is not exposed to any chemical hazards.
The SDS must be in English but chemical hazard information must also be communicated to
non-English speaking employees in languages they understand.
The lab is entitled to receive an SDS from their suppliers to include all of the information
required under the HCS. If an SDS is not received automatically, it should be requested. All SDS
must be current to comply with GHS requirements. If an SDS is obviously inadequate, for
example, created before 2012, or has blank spaces that are not completed, an appropriately
completed one should be requested. If a request for a data sheet or for a corrected data sheet does
not produce the information needed, contact the local OSHA Area Office for assistance in
obtaining the SDS. Make sure the SDS is available to all employees or designated
representatives during their work shift and is available during an OSHA inspection. Employees
should know where the SDS is located for the chemicals they use and how to use the SDS if
asked by the inspector. Employees should know to ask their supervisor if they do not understand
any information contained on the Safety Data Sheet.
NOTE: Vision Council Lab Division members have access to an online library of SDS specific
to optical laboratories. Go to https://www.thevisioncouncil.org/members/optical-lab-resources
and click on the SDS Library Online.
8
STEP VII: Develop And Implement A Written Hazard Communication Program
The OSHA Hazard Communication Standard (HCS) requires all workplaces where employees
are exposed to hazardous chemicals to develop and implement a written Hazard Communication
Program. While this plan does not have to be lengthy, the Standard requires that the program:
1. be written;
2. describe how the facility will comply with the Standard;
3. deal with plans for labeling and other forms of warning;
4. describe how the SDS will be obtained for each hazardous chemical used in the work
area;
5. describe how the SDS will be made available in the workplace;
6. describe how information and training will be provided to employees;
7. include an inventory of all toxic chemicals known to be present in the workplace,
cross-referenced to the SDS file;
8. explain how workers will be informed of hazards connected with non-routine jobs,
such as dealing with accidental spills and leaks;
9. explain how workers will be informed of hazards associated with chemicals contained
in unlabeled pipes and contain information on how contract employers will be
informed about hazards their employees may encounter while working in the facility.
A sample Hazard Communication Program plan is included in this section. (A sample plan is
also included on page 12 as a separate document that may be customized to individual needs and
specifications.) Preparation of the plan is not just a paper exercise; all elements must be
implemented in the workplace to comply with the rule. The only work operations that do not
have to comply with the written plan requirements are those where employees only handle
chemicals in sealed containers. The plan is intended to be a “blueprint” for implementing the
program and to ensure all aspects of the requirements have been addressed.
The sample program included will be helpful, however, it is important to remember that the
written program has to reflect what is occurring in the workplace. Therefore, if a generic
program is used, it must be adapted to address the chemicals and procedures used in the specific
laboratory. For example, the written plan must list the chemicals present at the site and indicate
where written materials will be made available to employees. It may also indicate who is
responsible for the various aspects of the program. If OSHA inspects a workplace for compliance
with the HCS, the OSHA compliance officer will ask to see the written plan at the outset of the
inspection.
The written program should provide enough details about the employer’s plans in this area to
assess whether or not a good faith effort is being made to train employees. OSHA does not
expect that every worker will be able to recite all the information about each chemical in the
workplace. In general, the most important aspects of training under the HCS are to ensure that
employees are aware that they are exposed to hazardous chemicals, that they know how to read
and use labels and an SDS, and that, as a consequence of learning this information, they are
following the appropriate protective measures established by the employer. OSHA compliance
9
officers talk to employees to determine if they have received training, if they know they are
exposed to hazardous chemicals, and if they know where to obtain substance-specific
information on a label and on an SDS.
STEP VIII: Make Safety Data Sheets Available To All Workers
Safety Data Sheets must be readily accessible to employees when they are in their work areas.
This may be accomplished in many different ways. You must decide what is appropriate for your
particular workplace. Some employers keep the SDS in a binder in a central location; others,
particularly in workplaces with large numbers of chemicals, computerize the information and
provide access through terminals. As long as all employees can get to the information when they
need it, any approach may be used. See Figure 4 below.
Figure 4: This SDS binder is kept in the lab for reference by employees who work with chemicals as is required
by the HCS
NOTE: Vision Council Lab Division members have access to an online library of SDS specific
to optical laboratories. Go to https://www.thevisioncouncil.org/members/optical-lab-resources ,
scroll down and click on SDS Library Online. If you have a chemical for which there is no up to
date SDS in the Library, contact Michael Vitale at [email protected] for assistance.
STEP IX: Hazard Communication Employee Information And Training
Each employee who may be “exposed” to hazardous chemicals when working, must be provided
information and be trained prior to initial assignment to work with a hazardous chemical, and
whenever the hazard changes. Training must be provided in the same language as other
employee training and instructions. While there is no federal OSHA annual training requirement,
some states do require annual training. “Exposure” or “exposed” under the rule means that an
employee is subjected to a hazardous chemical in the course of employment through any route of
entry (inhalation, ingestion, skin contact, or absorption) and includes potential (e.g., accidental or
possible) exposure. Information and training may be done either by individual chemical, or by
categories of hazards (such as flammability or carcinogenicity). If there are only a few chemicals
in the workplace, then it may be appropriate to discuss each one individually. Where there are a
large number of chemicals, or the chemicals change frequently, it will probably be best to train
generally based on the hazard categories (e.g., flammable liquids, corrosive materials,
carcinogens). Employees will have access to the substance specific information on the labels and
on the SDS.
Employers must ensure, however, that employees are made aware under which hazard category a
chemical is classified. Information and training are a critical part of the HAZCOM program.
10
Workers obtain information regarding hazards and protective measures through written labels
and Safety Data Sheets. It is through effective information and training, however, that workers
will learn to read and understand such information, determine how to acquire and use it in their
own work area, and understand the risks of exposure to the chemical as well as the ways to
protect themselves. A properly conducted training program will ensure comprehension and
understanding. It is not sufficient to either just read material to the workers or simply give them
the material to read.
Training Requirements in OSHA Standards and Training Guidelines (OSHA 2254) contains
voluntary training guidelines prepared by OSHA’s Training Institute. It is available by mail,
telephone and online:
Superintendent of Documents
Government Printing Office
P.O. Box 371954
Pittsburgh, PA 15250-7954
(202) 512-1800 or (866) 512-1800
Order online from
http://bookstore.gpo.gov or download a PDF from
http://www.osha.gov/Publications/osha2254.pdf
Valuable information can be found at the OSHA Office of Training and Education web site:
http://www.osha.gov/fso/ote/training/trainingresources.html
This information is available to sensory impaired individuals upon request. Voice phone:
(202) 219-8615; Telecommunications Device for the Deaf (TDD) message referral phone:
(800) 326-2577.
The standard does not require employers to maintain records of employee training, but it is
advised that employers do so (note that some states require documentation of training).
Documentation of training helps track what training has been completed and demonstrates a
good faith effort to comply with the standard. The use of an outline of what is presented
should be included in a safety program. This may help monitor the program to ensure that all
employees have been trained appropriately. Regardless of the method relied upon, however,
the employer is always ultimately responsible for ensuring that employees are adequately
trained. If the compliance officer finds that the training is deficient, the employer will be cited
for the deficiency regardless of who actually provided the training on behalf of the employer.
11
While this program does not have to be extensive, the OSHA performance standard specifies that
employees must receive information on the:
➢ provisions of the Hazard Communication Standard;
➢ types of operations in their work areas where hazardous chemicals are present;
➢ location and the availability of the written HazCom Program, list(s) of hazardous
chemicals and SDS;
➢ employee training sessions that describe methods which employees can use to detect the
presence or release of toxic chemicals in the workplace;
➢ physical and health hazards associated with the chemicals in their work area;
➢ specific measures to protect themselves from the hazards in their work areas;
➢ specific components of the Hazard Communication Program (HCP) including
explanations of the labeling system used in the lab and the methods employees can use to
obtain hazardous chemical information.
STEP X: Establish Procedure To Maintain A Hazard Communication Program
For employers using hazardous chemicals, the most important aspect of the written program
relating to the SDS is to ensure that someone is responsible for obtaining and maintaining the
SDS for every hazardous chemical in the workplace. The list of hazardous chemicals, required to
be maintained as part of the written program, will serve as an inventory. As new chemicals are
purchased, the list should be updated. Many companies have found it convenient to include on
their purchase order the name and address of the person designated in their company to receive
the SDS. SDS that are outdated (created prior to 2012) or for chemicals no longer used should be
archived for 30 years to protect the employer in case hazards not known at the time the SDS for
products, such as asbestos, was created become future issues.
STEP XI: Evaluating Program Effectiveness
The employer is always ultimately responsible for ensuring the company is in compliance with
the Hazard Communication Standard. Examples of items that are used to measure effectiveness
include:
1. Ask the employee about their knowledge of the Hazard Communication Program.
2. Are all containers properly labeled?
3. Is the Authorized Use List (AUL) up to date?
4. Does the written program reflect what is actually done in the workplace?
5. Are employees following safety procedures that are contained in the SDS?
6. Has employee training in HAZCOM been completed?
12
Sample Of A Written Hazard Communication Program
NOTE: The following sample Hazard Communication Program is based on the requirements of
HAZCOM 2012 at 29 CFR 1910.1200. The intent of this sample is to provide an easy-to-use
format that can be modified to address the specific situation in your workplace. You are free to
use whatever format you choose to develop your program — there is no requirement to follow
this example. However, if you use this or any other sample program, you must customize it to
your specific workplace, otherwise you will not be in compliance with the HAZCOM 2012.
Hazard Communication Program
1. Company Policy
To ensure that information about the dangers of all hazardous chemicals used by [INSERT
NAME OF COMPANY] is known by all affected workers, the following hazard
communication program has been implemented. Under this program, workers will be informed
of the requirements of the OSHA Hazard Communication Standard as revised by GHS
(HAZCOM 2012), the operations where exposure to hazardous chemicals may occur, and how
workers can access this program, as well as labels and SDS.
This program applies to any chemical which is known to be present in the workplace in such a
manner that workers may be exposed under normal conditions of use or in a foreseeable
emergency. All work areas that involve potential exposure to chemicals are part of the hazard
communication program. Copies of the hazard communication program are available in the
[INSERT LOCATION] for review by any interested worker.
[INSERT NAME OF RESPONSIBLE PERSON AND/OR POSITION] is the program
coordinator, with overall responsibility for the program, including reviewing and updating this
plan as necessary.
NOTE: Where names are used to identify the responsible person(s), the written plan must be
updated whenever there are any personnel changes.
2. Container Labeling
[INSERT NAME OF RESPONSIBLE PERSON AND/OR POSITION] will verify that all
containers received for use will be clearly labeled in accord with the requirements of HazCom
2012, including a product identifier, pictogram, hazard statement, signal word, and precautionary
statements, as well as the supplier’s contact information (name, address and phone number).
The [INSERT NAME OF RESPONSIBLE PERSON AND/OR POSITION] in each work
area will ensure that all secondary containers are labeled with the original supplier’s label or with
an alternative workplace label. For help with labeling, see [INSERT NAME OF
RESPONSIBLE PERSON AND/OR POSITION].
On the following individual stationary process containers, we are using [INSERT
DESCRIPTION OF LABELING SYSTEM USED] rather than a label to convey the required
information: (LIST CONTAINERS HERE).
We are using an in-house labeling system (DESCRIBE ANY IN-HOUSE SYSTEM WHICH
CONVEYS REQUIRED WORKPLACE LABEL INFORMATION).
The [INSERT NAME OF RESPONSIBLE PERSON AND/OR POSITION] will review the
13
company labeling procedures every (PROVIDE A TIME PERIOD) and will update labels as
required.
3. Safety Data Sheets (SDS)
[INSERT NAME OF RESPONSIBLE PERSON AND/OR POSITION] is responsible for
establishing and monitoring the company SDS program. The procedure below will be followed
when an SDS is not received at the time of initial shipment: (DESCRIBE PROCEDURE TO
BE FOLLOWED HERE).
Copies of SDS for all hazardous chemicals to which workers are exposed or are potentially
exposed will be kept in [IDENTIFY LOCATION]. Workers can access SDS by [INSERT
PROCEDURE FOR ACCESS].
NOTE: If alternatives to paper copies of SDS are used, describe the format used and how
workers can access the SDS.
SDS will be readily available to all workers in each work area during each work shift. If an SDS
is not available, contact [INSERT NAME OF RESPONSIBLE PERSON AND/OR
POSITION].
When revised SDS are received, the following procedures will be followed to replace old SDS:
(DESCRIBE PROCEDURES).
[INSERT NAME OF RESPONSIBLE PERSON AND/OR POSITION] is responsible for
reviewing the SDS received for safety and health implications and for initiating any needed
changes in workplace practices.
4. Employee Information and Training
[INSERT NAME OF RESPONSIBLE PERSON AND/OR POSITION] is responsible for
employee information and training.
Every worker who will be potentially exposed to hazardous chemicals will receive initial training
on the Hazard Communication standard and this program before starting work.
The training program for new workers is as follows: [INSERT DESCRIPTION OF HOW THE
TRAINING WILL BE PRESENTED AND WHAT IS INCLUDED].
Prior to introducing a new chemical hazard into any work area, each worker in that work area
will be given information and training as outlined above for the new chemical hazard. The
training format will be as follows:
(DESCRIBE TRAINING FORMAT, SUCH AS AUDIOVISUALS, INTERACTIVE
COMPUTER PROGRAMS, CLASSROOM INSTRUCTION, ETC.)
5. Hazards of Non-Routine Tasks
Periodically, workers are required to perform non-routine tasks that are hazardous. Examples of
non-routine tasks are confined space entry, tank cleaning, and painting reactor vessels. Prior to
starting work on such projects, each affected worker will be given information by [INSERT
NAME OF RESPONSIBLE PERSON AND/OR POSITION] about the hazardous chemicals
he or she may encounter during such activity. This information will include specific chemical
hazards, protective and safety measures the worker should use, and steps the company is taking
14
to reduce the hazards, including ventilation, respirators, the presence of another worker (buddy
systems), and emergency procedures.
6. Informing Other Employers/Contractors
It is the responsibility of (Name of responsible person and/or position) to provide other
employers and contractors with information about hazardous chemicals that their workers may
be exposed to on this work site, and suggested precautions for workers. It is the responsibility of
[INSERT NAME OF RESPONSIBLE PERSON AND/OR POSITION] to obtain information
about hazardous chemicals used by other employers to which our workers may be exposed.
Other employers and contractors will be provided with SDS for hazardous chemicals generated
by this company’s operations in the following manner: (DESCRIBE COMPANY POLICY
HERE).
In addition to providing a copy of an SDS to other employers, other employers will be informed
of necessary precautionary measures to protect workers exposed to operations performed by this
company.
Also, other employers will be informed of the hazard labels used by the company. If alternative
workplace labeling systems are used, the other employers will be provided with information to
understand the labels used for hazardous chemicals to which their workers may have exposure.
7. List of Hazardous Chemicals
A list of all known hazardous chemicals in the workplace is attached to this program. This list
includes the name of each chemical, and the work area(s) in which each of the chemicals is used.
Further information on each chemical may be obtained from the SDS, located in (IDENTIFY
LOCATION). When new chemicals are received, this list is updated within (x) days of
introduction into the workplace. To ensure that any new chemical is added in a timely manner,
the following procedures shall be followed: (IDENTIFY PROCEDURES TO BE
FOLLOWED).
The hazardous chemical inventory is compiled and maintained by [INSERT NAME OF
RESPONSIBLE PERSON AND/OR POSITION AND TELEPHONE NUMBER].
8. Chemicals in Unlabeled Pipes
Work activities may be performed by workers in areas where chemicals are transferred through
unlabeled pipes. Prior to starting work in these areas, the worker shall be informed by (NAME
OF RESPONSIBLE PERSON AND/OR POSITION) about the identity and hazards of the
chemicals in the pipe, as well as required precautionary measures required to be followed.
9. Program Availability
A copy of this program will be made available upon request to workers, their designated
representatives and OSHA.
15
Frequently Asked Hazard Communication Questions
Source: OSHA website (www.osha.gov)
Any questions regarding compliance with the Hazard Communication Standard should be
referred to the local Occupational Safety and Health Administration (OSHA) Area Office for
assistance. In addition, each OSHA Regional Office has a Hazard Communication Coordinator
who can answer questions. Free consultation services are also available to assist employers, and
information regarding these services can be obtained through the OSHA Area and Regional
Offices as well.
What is the application of a Hazard Communication Program to an office environment?
Office workers who encounter hazardous chemicals only in isolated instances are not covered by
the rule. OSHA considers most office products (such as pens, pencils, adhesive tape) to be
exempt under the provisions of the rule, either as articles or as consumer products. An example is
toner for copiers or printers. OSHA has previously stated that intermittent or occasional use of a
copying machine does not result in coverage under the rule. However, if an employee handles
the chemicals to service the machine, or operates it for long periods of time, then the program
would have to be applied.
Is a Safety Data Sheet (SDS) required for a non-hazardous chemical?
An SDS that represents non-hazardous chemicals are not covered by the HCS. Paragraph 29
CFR 1910.1200(g)(8) of the standard requires that “the employer shall maintain in the workplace
copies of the required SDS for each hazardous chemical and shall ensure that they are readily
accessible during each work shift to employees when they are in their work area(s).” OSHA does
not require nor encourage employers to maintain an SDS for non-hazardous chemicals.
Consequently, an employer is free to discard an SDS for non-hazardous chemicals.
What are the requirements and limits to using a generic SDS?
The requirements for an SDS are found in paragraph (g) of 29 CFR 1910.1200. An SDS must be
developed for hazardous chemicals used in the workplace and must list the hazardous chemicals
that are found in a product in quantities of 1% or greater, or 0.1% or greater if the chemical is a
carcinogen. The SDS does not have to list the amount of the hazardous chemical that occurs in
the product.
Therefore, a single generic SDS can be developed for the various combinations of chemicals, as
long as the hazards of the various mixtures are the same. This generic SDS must meet all of the
minimum requirements found in 29 CFR 1910.1200(g), including the name, address and
telephone number of the responsible party preparing or distributing the SDS who can provide
additional information.
What are the requirements for refresher training or retraining a new hire?
Additional training is to be done whenever a new physical or health hazard is introduced into the
work area, not a new chemical. For example, if a new solvent is brought into the workplace, and
it has hazards similar to existing chemicals for which training has already been conducted, then
no new training is required. As with initial training, and in keeping with the intent of the
standard, the employer must make employees specifically aware of the hazard category (i.e.,
corrosive, irritant, etc.) of the solvent. The substance-specific data sheet must still be available,
and the product must be properly labeled. If the newly introduced solvent is a suspected
16
carcinogen, and there has never been a carcinogenic hazard in the workplace before, then new
training for carcinogenic hazards must be conducted for employees in those work areas where
employees will be exposed.
Some states require the employer to retrain each employee annually. Check your local
requirements. The employer is responsible for ensuring that their employees are adequately
trained and are equipped with the knowledge and information necessary to conduct their jobs
safely. It is likely that additional training will be needed since employees must know the
specifics of their new employers’ programs such as where the SDS are located, details of the
employer’s in-plant labeling system, and the hazards of new chemicals to which they will be
exposed.
Can the SDS be stored on a computer to meet the accessibility requirements of the Hazard Communication Program?
If the employee’s work area includes the area where the SDS can be obtained, then maintaining
SDS on a computer would be in compliance, as long as each employee is able to access the SDS.
The Vision Council has recently made this type of program available to member labs. The Vision
Council may be contacted regarding the details.
SECTIONS OF AN SDS AND THEIR SIGNIFICANCE
OSHA specifies the information to be included on an SDS but does not prescribe the precise
format for an SDS. The SDS must be in English and must include at least the following
information. The GHS required format for an SDS is:
Section 1, Identification;
Section 2, Hazard(s) identification;
Section 3, Composition/information on ingredients;
Section 4, First-aid measures;
Section 5, Fire-fighting measures;
Section 6, Accidental release measures;
Section 7, Handling and storage;
Section 8, Exposure controls/personal protection;
Section 9, Physical and chemical properties;
Section 10, Stability and reactivity;
Section 11, Toxicological information;
Section 12, Ecological information;
Section 13, Disposal considerations;
Section 14, Transport information;
Section 15, Regulatory information; and
Section 16, Other information, including date of preparation or last revision.
17
Summary
The most common OSHA violation is lack of an effective Hazard Communication Program. It is
vital that business and work procedures follow this requirement. Having effective control of
chemicals in the workplace will save the businesses money and will also protect employees.
Most optical businesses are often confused or overwhelmed by the number of regulations with
which they must comply. Complying with the Hazard Communication (HAZCOM) Program is a
common problem. The standard HAZCOM Program is designed to make employees informed of
the chemical risks in the workplace. OSHA expects a properly implemented HAZCOM Program,
and employees often will be interviewed during an inspection to determine the HAZCOM
program effectiveness.
The key of the HAZCOM program is the Safety Data Sheet (SDS). It is detailed chemical
information provided by the chemical manufacturer or distributor. It describes the chemical
hazards and precautions for each specific chemical. Employers must maintain a current,
complete, and accurate SDS for each hazardous chemical that is used in their business.
OSHA’s expectations of compliance with HAZCOM requirements are more complicated than it
might appear. As required by the standard, employers must develop plans, programs, and
training. Implementation of each of these HAZCOM requirements must be apparent. Records of
training, Safety Data Sheets, and container labeling will show that a company is trying to
comply. However, inspectors are using more sophisticated criteria in judging the effectiveness of
HAZCOM programs. OSHA expects a properly implemented HAZCOM program to reduce
injuries or employee risks from chemical exposure.
Employees will often be interviewed by OSHA to determine HAZCOM Program effectiveness.
Employees should be able to explain how labeling conveys the hazards posed by chemicals in
containers. They must not only know that labels are required, but also must be able to show what
the label indicates about the hazard – for example: flammable, irritant, carcinogen. A basic
understanding of how chemicals can be injurious should be evident. Employees should
understand how to select and use protective equipment (gloves, goggles, respirators, etc.) to
safeguard themselves from the specific chemical hazards.
During OSHA inspections, hazard communication citations have ranked in the top ten citations
handed out by OSHA. Lack of a written program has been the number one violation. One fallacy
about the HAZCOM Program is that some companies do not have to comply because they do not
have any hazardous chemicals. Nearly all chemicals have some hazards associated with their use.
It is recommended that a written program should be in place if a business has potentially
hazardous chemicals in the work areas.
A successful HAZCOM program will reduce the actual and potential injuries from chemicals
used by employees. The program must be regularly evaluated to ensure that it is up to date. The
written program, training records, and SDS files should be reviewed at least once per year.
Conducting an annual inventory of all chemicals used in business is a good method to identify
unnecessary chemicals.
19
Section 2 Chemical Safety in The Optical Laboratory
Executive Summary
Source: National Occupational Health and Safety Commission. Copyright Commonwealth of
Australia [Reproduced with permission.]
Optical laboratories have hazardous substances in their operations. Under OSHA regulations, all
employees must be protected from chemicals hazards. This section is designed to be a guide to help
to identify chemical hazards at work as well as suggest possible methods to safeguard employees.
This chapter also includes procedures for chemical spill management. The safe use of chemicals is a
vital part of any safety program. The best approach is to eliminate the hazardous chemical or use a
non-hazardous one, but if that is not possible, an effective chemical safety program is vital.
What Are Hazardous Substances?
Hazardous substances are chemicals and other substances that can affect health, causing illness or
disease. They may be solvents, pesticides, paints, adhesives, petroleum products, heavy metals, or
any other substance that is hazardous to health and is used or produced at work. Hazardous
substances come in many forms: liquids, solids, vapors, gases, fumes or dusts. What identifies a
substance used in the workplace as hazardous?
To be classified as a hazardous substance, the ingredients of the substance must be present in
concentrations that are known to cause health effects. Where this is the case, the substance must be
labeled appropriately to ensure that users know it is hazardous. It must also be accompanied by a
Safety Data Sheet (SDS) setting out health effects, what to do in an emergency, and instructions for
safe use and storage. The easiest way to determine if a substance is hazardous is to look on the label
and note the words “hazardous,” “warning,” “poison,” “dangerous poison,” “harmful” or “corrosive”
or other advice about specific health effects. Employers must make the SDS for a hazardous
substance readily accessible to all employees and ensure there is a hazardous substances list.
How Do Hazardous Substances Affect Employees?
Hazardous substances can get into the body in different ways. The most common ways are:
➢ Breathing in the substance (inhalation);
➢ Absorption through the skin (dermal);
➢ Accidental swallowing (ingestion), e.g., by eating or smoking with contaminated hands.
Health effects may be acute, a short-term illness (usually from high level exposure), or chronic, often
resulting in a long-term illness (usually low-level exposure). Chronic effects may not occur for many
years. They are hard to predict in advance, and when they do occur, it may be hard to identify what
caused them. An example of a chronic effect is lead poisoning from the improper handling of a lead
based Low Melting Point Alloy (LMPA).
20
How To Know If Hazardous Substances Are A Risk In The Workplace?
To know whether there is a risk of exposure, it is necessary to make an assessment of hazardous
substances in the workplace.
In order to do this:
➢ Identify hazardous substances – read the label.
➢ Review information about hazardous substances – read the SDS and make sure all instructions
are being followed.
➢ Identify any risks of exposure by taking into account factors such as how often exposure
occurs, for how long, and at what level. It may be necessary to have a professional measure
the air concentration of hazardous substances in the workplace.
What Needs To Be Done To Protect Employees?
Employers must take action to prevent exposure to hazardous substances at work; or if that is not
practicable, to ensure that exposure is adequately controlled to minimize risks to health. Employees
have the responsibility to work safely using the control methods provided. To ensure employees can
work safely, they have the right to be provided with information and training on any hazardous
substances to which they may be exposed. This should include advice about health hazards, reading
labels on containers, and how to access the SDS as well as emergency procedures and first aid.
Practical Solutions To Reduce Risks Of Hazardous Substances
There are a number of practical actions that can be instituted to reduce the risks when working with
hazardous substances. Below are suggested actions, with the ones that are generally the most
effective listed first.
• Elimination: Removal of a hazardous substance that is not essential – for example, cleaning
lenses with the use of an ultrasonic cleaner and a non-hazardous cleaner instead of using a
hazardous cleaner.
• Substitution: Using a less hazardous substance, or a less hazardous form or process – for
example, using a wax blocking system rather than a lead-alloy blocking system.
• Isolation: Separating hazardous substances from the people using them by distance or barrier
– for example, locating operators in a separate, air-conditioned, control room away from
hazardous fumes.
• Engineering Controls: Using machinery, equipment or processes which minimize workplace
contaminates by containing or removing hazardous substances – for example, using local
exhaust ventilation to remove hazardous vapors caused by neutralizers used in a tinting
operation.
• Safe Work Practices: Having procedures for how to do the job safely – for example,
requiring authorization to operate systems and restricting access to hazardous areas.
• Personal Protection Equipment (PPE): Protective equipment – for example, respirators,
gloves, or eye protection – must be suitable for the type of substance used and properly fitted
to the worker. The equipment must comply with OSHA Standards. PPE should only be used
to provide extra protection, or where other control measures are not practicable – for example,
during maintenance or emergency operations.
21
• Monitoring and Health Surveillance: For some hazardous substances, it may be necessary
to monitor the amount of a substance in the workplace environment. Where monitoring
shows exposure approaching unsafe levels, immediate action should be taken to reduce the
level of use.
Chemical safety in the lab should not be overlooked. Employees usually are concerned about the
chemicals they are exposed to at work. Worker compensation cases and OSHA fines have resulted
from employees being injured by chemicals. It is a wise decision to safeguard staff and the
environment before working with chemicals in the lab. See Figure 5 below as an example of
noncompliant chemical storage.
Figure 5: Many of the containers storing hazardous materials do not have the respective SDS that are required by
the Hazardous Communication Standard
General Safe Work Practices When Working With Solvents
Source: Hazard Evaluation System and Information Service
Department of Health Services, State of California,
1515 Clay St., Suite 1901, Oakland, CA 94612
[Reproduced with permission.]
Review The Safety Precautions In The Safety Data Sheet
Always review the SDS prior to using any solvent and take appropriate safety precautions.
22
How Solvents Can Enter The Body
• Breathing: Solvents that have evaporated into the air can be inhaled. Many solvents
evaporate very quickly, which forms invisible vapors. When sprayed, they can also form
visible or invisible mist. When breathing vapors or mist, lungs easily absorb the solvent into
the bloodstream. This is a common way for solvents to get into the body.
• Skin Absorption: Liquid solvents can go into the body right through the skin. The solvents
are then carried throughout the body in the bloodstream. Some solvents go through skin very
quickly, and others absorb more slowly.
• Swallowing: Sometimes people accidentally drink a solvent. This can happen easily, e.g.,
when someone has poured solvent into a drink container. Starting a siphon by sucking solvent
though a tube also results in accidental swallowing.
Basic Safe Working Methods For All Solvents
• Get the Right Chemical: Start by using the safest solvent available for the job. There
may be a water-based or solvent-free substitute. Perhaps there is use a less toxic or less
flammable solvent to use.
• Keep Solvents Off Skin and Clothes: Change clothes if they get wet with solvent.
(Solvent-soaked clothing can seriously overexpose the wearer.) Wash solvent-
contaminated clothes with soap or detergent. Use solvent-resistant gloves, aprons, or
goggles if needed to prevent contact. Don’t wash hands with solvents. Instead use a
waterless cleaner, soaps, oils, detergents – use anything but solvent. No solvent is safe for
hand washing.
• Use Less: Use the smallest amount of solvent that will get the job done.
• Cover Containers When Not in Use: When working with solvents, it is important to
keep solvent-soaked rags and waste solvent in a closed container, clean up spills right
away and follow basic safe work methods for flammable and combustible solvents that are
included with the warning label attached to the container.
• Containers and Storage: Use containers that are specially designed for flammable
solvents. If more than a few pints of flammable solvents are in the lab, safety storage
cabinets should be used. It is also prudent to keep them in a separate room, away from
combustible materials.
• Ground and Bond Metal Containers: When transferring flammable solvents, preventing
static electricity sparks is vital. This can be done by connecting containers to each other
and to an electrical ground using clamps, wires, or direct metal-to-metal contact.
• Keep These Substances Away from Flammable Solvents: Chlorine gas, chromic acid,
compressed air, compressed oxygen, nitric acid, peroxides, sulfuric acid, and any
chemicals labeled “oxidizer,” such as potassium nitrate. Oxidizers are chemicals that add
oxygen, which can start fires or make fires burn faster. Oxidizers should never be used or
stored near flammable solvents, or near other flammable materials.
23
• Fire Dangers of Solvents: Many solvents are highly flammable, and substantial property
damage result from solvent fires. Flammable solvents must be stored away from heat and
flame.
• Solvent Dangers to the Skin, Eyes and Lungs: Most solvents dissolve skin oils, causing
skin irritation and damage. Unless indicated on the container label, solvents should never
be used for to wash hands. Solvent vapors and liquids can severely damage eyes,
especially if contact lenses are worn. Breathing solvents is hard to avoid because many
evaporate quickly into the air. Solvents can cause nose and throat irritations, damage lung
tissue and enter the bloodstream through the lungs.
• Keep Only Small Amounts in the Work Area: Additional safe work practices regarding
solvents include keeping only enough solvent for one day in the work area. Keeping larger
amounts in a separate fireproof storage area, and understanding the fire hazards of
solvents are important. Flammable solvents are dangerous and can catch fire at ordinary
room temperature, and all it takes is a spark or heat source touching the vapor.
Combustible solvents can catch fire too, but only if they are warmer than 100° (degrees)
F. It’s actually the vapor that burns. Sparks and heat must be strictly controlled wherever
invisible vapors may be found. Usually heavy concentrations of vapors are found next to
the surface of the liquid solvent. But with poor ventilation conditions, concentrated vapors
can be found far from the liquid and a fire can start where invisible vapors exist.
What Is “Flash Point”?
The “flash point” is the lowest temperature at which a solvent gives off enough vapor to start burning
when a heat source is present. Each solvent has a different flash point; low flash points are more
dangerous. Flammable solvents have flash points of less than 100° (degrees) F.
24
The NFPA Diamond
The National Fire Protection Association (NFPA) “Diamond” is a chemical warning symbol that is
in the shape of a diamond and is comprised of four smaller diamonds that contain numerals. The
respective definitions of hazards are rated/defined in color-coded text and are assigned on a scale of
0 to 4, with 0 as least dangerous and 4 as the greatest danger. Health hazards are rated in the left-side
text (blue). Fire hazards are rated in the right-side text (red). Reactivity hazards are rated in the lower-
right-side text (yellow). Specific hazards are rated in the lower-left-side text (white). Specific hazards
are comprised of acronym definitions and do not use a numerical scale. See Figure 6 below.
Figure 6: National Fire Protection Association hazardous material label that identifies the health, fire hazard and
reactivity of a chemical
NFPA Rating And Label Codes For Solvents
The following scale definitions apply to fire hazards:
0 = not flammable; will not burn.
1 = combustible liquid; can catch fire if heated above 200° (degrees) F.
2 = flammable liquid; can ignite at ordinary room temperatures [100° (degrees) F or lower] but
does not exceed 200° (degrees) F.
3 = highly flammable; ignites below 100° (degrees) F.
4 = explosive; can catch fire below 73° (degrees) F.
Solvent Safety Checklist
SOLVENT SELECTION
Use the safest chemicals that can do the job.
25
Training
1. The employer trains workers and requires workers to use safe work practices.
2. Workers learn how to work safely before starting a new assignment or facing a new hazard.
3. Workers know the chemical ingredients of the products they use.
4. Workers know the fire hazards and health hazards of the chemicals they use.
5. Workers know safe work methods and emergency procedures (fire, spill, first aid) for the
specific chemicals they use. Safety Data Sheets (SDS) are kept onsite and are available to
workers using chemicals. Workers must report both unsafe conditions and work-related
injuries and illnesses to their supervisor.
Containers
Each container has a label showing the chemical name and hazard warnings. See Figure 7 below. If
chemicals must be transferred from the original containers, the new containers are labeled with the
chemical name and hazard warnings.
Figure 7: Large quantities of flammable liquids must be stored in an appropriate storage building or locker. Check
with your local fire department regarding how to store flammable liquids to reduce the likelihood of a fire or
chemical release.
Only approved containers are used for flammable solvents. Containers are closed or covered when
not in use. Incompatible chemicals are stored separately from each other. Only small amounts of
flammable solvents are kept in the work area (enough for one day only). See Figure 8 below.
26
Figure 8: Plunger that can be used to dispense a flammable liquid. This reduces the amount of hazardous liquids
that are being used in an operation.
Gloves And Safety Goggles
Gloves, goggles, or other protective clothing are needed to keep solvents away from skin, eyes and
clothing. They should be made of a material that prevents chemicals from seeping through. They
should be replaced before they become worn out, cracked, soaked through or spongy.
Air Contamination
If solvents are being used in work areas, employees may be breathing unsafe air:
1. The employer must test the air in these areas.
2. Workers must be given the test results.
3. If ventilation is used (fans, ducts, hoods) it must be tested and maintained within the last year.
Chemical Spill And Cleanup Procedures
Copyright: University of South Carolina Safety Program Guide and New Pig Corporation
www.newpig.com. (Reproduced with permission.)
Introduction
Despite best efforts to practice safe work procedures, accidents resulting in the release of chemicals
might occur. For this reason, it is essential that laboratory personnel have a spill response plan that
includes appropriate procedures and materials to adequately contain and cleanup a spill. The
following procedures should be used as a guide to help employees design an effective spill control
plan for their laboratory.
Individuals should be familiar with the properties and hazards of the materials with which they work.
In the event of a chemical spill, the individual(s) who caused the spill is (are) responsible for prompt
and proper cleanup. Improper cleanup of a chemical spill may result in injury, illness, fire, a release
to the environment, or property damage. Planning for chemical spills is essential. Before beginning
work with chemicals, one should be sure that he or she has adequate training for cleaning up small
spills, and that the appropriate types and amounts of spill cleanup materials and personal protective
equipment are immediately available. See Figure 9 below.
27
Figure 9: An absorbent material being used to clean up and contain a chemical spill.
Chemical spills might be simple or small and simply require wiping up the chemical or it might be a
55-gallon drum of hazardous chemicals that could endanger staff and the environment. It is important
that to conduct a risk assessment of the situation and have staff trained in cleanup techniques, along
with the proper supplies on hand to conduct spill cleanup. See Figure 10 below. If a spill of a
dangerous substance occurs, it is important to have an arrangement with the local fire department that
has a spill cleanup team to contain the chemicals. The protection of people should be foremost in the
planning process. Other important considerations are the protection of both the environment and the
lab facilities.
Figure 10: Example of a well-equipped chemical spill kit
28
To prevent spills of hazardous chemicals, and to control releases of hazardous waste from drums and
other containers, the Resource Conservation and Recovery Act (RCRA) requires that “A container
holding hazardous waste must always be closed during storage, except when it is necessary to add or
remove waste” [40 CFR 264.173 (a)].
It is important that to have a relationship with the local fire department, and for them to tour the lab
and made recommendations on the proper storage of chemicals. The recommendations should be in
writing to document that a company is following proper procedures. Employees must be trained on
what to do in an emergency. The local fire department hazardous material response office is a great
resource for this information. Another element of planning is notification of state and government
agencies when a spill occurs that leaves a building or enters a storm drain. It is prudent to have a spill
plan in place and have employees trained on both how to safely cleanup spills and whom to notify.
Failure to notify appropriate agencies when a spill occurs could result in heavy fines. The prompt
action to cleanup a chemical spill and to report it will reduce the likelihood of fines. It is
recommended that labs seek professional environmental guidance regarding all chemicals that are
used, and to have a plan in place in the event of a hazardous material spill.
Employees who may come in contact with hazardous materials should read the SDS prior to working
with the material so that they become familiar with the material’s potential hazards and proper
cleanup procedures. If an emergency occurs, precious time might be lost while looking at the
reference material prior to attempting the cleaning of a chemical spill.
29
Scope And Application
Laboratory workers are neither expected, nor allowed, to clean up chemical spills other than their
own. Personnel that have been trained and equipped to clean spills will make the proper notifications.
Employees working in labs should be aware that required safety training for lab workers includes
emergency response training. The OSHA Hazard Communication Standard and the OSHA Standard
for Hazardous Waste Operations and Emergency Response (HAZWOPER) mandate such training.
Emergency training applies to building evacuation procedures during fires and explosions,
recognition of system alarms, and appropriate action in the event of spills of hazardous materials in
the lab. Lab workers must receive training to distinguish between the types of spills they can handle
on their own and those spills that are classified as “Major.” Major spills dictate the need for outside
help.
Lab workers are qualified to clean up spills that are “incidental and/or minor.” OSHA states an
incidental spill is a spill that does not pose a significant safety or health hazard to employees in the
immediate vicinity nor does it have the potential to become an emergency within a short time frame
(the period that constitutes a short time is not defined). Lab workers can handle incidental spills
because they are expected to be familiar with the hazards of the chemicals they normally handle. If
the spill exceeds the scope of the lab workers’ experience, training and willingness to respond, the
workers must be able to determine that the spill cannot be dealt with internally.
Emergency assistance is provided by an outside agency such as the local fire department spill
response team. Large spills require the involvement of individuals outside the lab. Spills in this
category are those that have truly become emergency situations. In that situation, workers are
overwhelmed, and the proper response is above their level of training. Their response capability is
compromised by the magnitude of the incident.
Planning For A Spill
Preventive Actions to Prepare for Spills
➢ Assess the need for spill-control materials.
➢ Provide adequate spill-control materials.
➢ Ensure individuals receive appropriate training.
➢ Develop and periodically review (at least annually) spill response plans.
➢ Ensure spill-control materials are replenished after use.
➢ Investigate the cause of any spill; provide necessary follow up, including steps to minimize
the likelihood of spills.
30
Sample Contents of a Spill Containment Kit
➢ Absorbent Pads, 18" x 18"
➢ Absorbent Pillows
➢ Absorbent Spill Containment Dikes/Socks
➢ 3" x 4" (See Figure 11 below.)
➢ Nitrile Gloves of Different Sizes
➢ Splash-Proof Goggles
➢ Tyvek® Coveralls, XL
➢ Floor-Stand Spill Sign
➢ HAZ-MAT Disposal Bags,
➢ Spill Response Pocket Guide
➢ DOT Emergency Response Guidebook
➢ Labels
Figure 11: Absorbent sock used to contain chemical spills
Individuals should:
➢ Become familiar with the hazards of chemical products before using them.
➢ Use preventive measures to minimize the likelihood of spills, such as using secondary
containers when transporting chemicals and placing absorbent materials on work surfaces.
➢ Receive training, as needed.
➢ Assess the need for spill-control materials.
➢ Assist in developing spill response plans.
➢ Clean up small spills properly.
➢ Report all spills to the supervisor or principal investigator.
31
Figure 12: An eyewash station located adjacent to a tinting unit in the lab
Workers should know where eye-wash stations are located throughout the facility. See Figure 12
above.
General Guidelines For Cleaning Up Chemical Spills
1. Immediately alert others in the area and the supervisor, and evacuate the area, if necessary.
2. Have emergency numbers posted in the event of a fire or medical attention is needed.
3. Attend to any persons who may be contaminated. Contaminated clothing must be removed
immediately, and the skin flushed with water for no less than fifteen minutes. Clothing must
be laundered before reuse.
4. If a volatile, flammable material is spilled, immediately warn others in the area, control
sources of ignition, and ventilate the area.
5. Put on personal protective equipment, as appropriate to the hazards. Refer to the SDS or other
references available in the laboratory for information.
6. If the spill is substantial and if there has been a release into the environment, or if assistance
is needed, contact the National Spill Response Center and appropriate state agency.
7. Consider the need for respiratory protection. The use of a respirator or self-contained
breathing apparatus requires specialized training and medical surveillance. Never enter a
contaminated atmosphere without protection or use a respirator without training.
8. Protect floor drains or other means for environmental release. Spill socks and absorbents may
be placed around drains, as needed. See Figure 13 below.
32
Figure 13: A spill blocker mat that is used to prevent a chemical spill from entering a storm drain
1. Loose spill control materials should be distributed over the entire spill area, working from the
outside circling to the center. This reduces the chance of splash or spreading of the spilled
chemical.
2. PolyZorb™ products and their equivalent will handle hydrofluoric acid. Many neutralizers for
acids and bases have a color change indicator to show when neutralization is complete.
3. When the spilled materials have been absorbed, use a brush and scoop (spark-resistant if
flammable materials are involved) to place materials in an appropriate container. Polyethylene
bags may be used for small spills. Five-gallon pails or 20-gallon drums with polyethylene
liners may be appropriate for larger spills.
4. Complete a hazardous waste tag, identifying the material as “Spill Debris involving XYZ
Chemical” and affix the sticker to the container or bag. Remember the use of an absorbent
material does not alter the chemical properties of the chemical. Contact the hazardous waste
contractor for advice on storage and packaging for disposal.
5. Place the container in a hooded or other properly-ventilated area until the next chemical waste
pick-up occurs.
6. Decontaminate surfaces involved in the spill using a mild detergent and water, as appropriate.
NOTE: Optical labs must decide whether they will train and equip employees to respond to chemical
spills or call 911.
Reporting Spills
It is strongly recommended to report ALL chemical spills that leave a building or enter a sewer
system or storm drain. Failure to do so could result in criminal and civil penalties. Spills should be
reported to the National Response Center (NRC). The NRC is the sole federal point of contact for
reporting oil and chemical spills. Spills should be reported via the toll-free number: 1-800-424-8802
or use 202-267-2675 if there is no “800” access. The website http://www.nrc.uscg.mil/nrchp.html
has additional information on reporting requirements and procedures.
The NRC maintains a 24-hour per day, 7 days per week, 365 days per year Operations Center at
which all information received by the toll-free number is entered directly into an on-line database
system, and is electronically disseminated as part of the National Response System (NRS). Once
33
contacted, the NRC Duty Officer will guide the caller through a series of detailed questions based on
the Standard Report Form (SRF) to gather as much information as possible concerning the spill or
release. The information is immediately entered into the Incident Reporting Information System
(IRIS) and based on several pre-established criteria, including material involved, mode of
transportation, injuries, damage and fatalities, a select federal agency notification will take place
within 15 minutes of receipt. When any of the following incidents occur, the responsible party should
immediately contact the NRC at their toll-free number: 1-800-424-8802. Anyone who sees or
discovers an oil spill or a release of chemicals and who is not the responsible party, should contact
the NRC with all available information.
What Information Does The NRC Need?
CALLER IDENTITY
➢ Caller’s name, address and phone number.
➢ The name, address and phone number of the responsible party, if known.
NOTE: Anonymous calls are accepted.
WHAT HAPPENED
➢ What type of material was released?
➢ How much was released?
WHERE IT HAPPENED
➢ City, county and state
➢ Location, i.e., nearest street corner or landmark.
WHEN IT HAPPENED
➢ At what time it happened
➢ At what time it was discovered
WHY IT HAPPENED
➢ How did it happen?
➢ What caused the discharge?
What if the caller does not have all of the above listed information? The NRC still wants and needs
the information. It might be providing the NRC with the first indication that a major incident has
occurred. For a complete and detailed list of the information that is collected, review the online report
forms.
35
Section 3 Optical Laboratory Environmental Management
Executive Summary
Background
Optical laboratories are required by law to manage waste in compliance with Environmental
Protection Agency (EPA), state, and local environmental regulations. An effective environmental
program will not only greatly reduce a company’s liability of fines from the EPA, but will also
contribute to improving production efficiencies. The penalties under US environmental laws
could result in up to $75,000 per day per violation. In some cases, criminal penalties could result.
The types of waste that are typically produced by optical labs include:
• Non-Hazardous Waste: (Non-Regulated Waste) Industrial process waste not
considered a hazardous waste under federal environmental laws. This waste could be
suitable for sewer disposal if approved by the local sewer district.
• Hazardous Waste: By-product of many industrial processes that can pose a
substantial or potential hazard to human health or the environment when improperly
managed. Possesses at least one of four characteristics (ignitability, corrosively,
reactivity or toxicity; or appears on special EPA lists). Any substance or mixture of
substances having properties capable of producing adverse effects on the health or
safety of a human being.
Unnecessary waste from lab processes generally adds to the cost of doing business. It is too easy
for optical labs to use the most convenient method of disposal, an open drain to either a sewer
system or storm drain. In most instances, it is illegal to discharge industrial waste in the local
sewer system unless a permit is obtained from the local sanitary sewer district. Even if a
chemical is non-hazardous or it is labeled biodegradable, it is not automatically suitable or legal
for sewer disposal. Typical optical laboratories’ non-hazardous waste including tinting waste,
lens polish, and liquid coolants are generally not suitable for untreated disposal in the sewer
system. Many local sanitation districts do not allow the sewer disposal of untreated tinting,
polishing, and liquid coolant waste.
36
Figure 14: Waste from 55-gallon drums being pumped into a tanker truck for removal to a waste disposal site
Hazardous waste (HW) could include some types of low-melting point alloy contaminated waste,
solvents, and some cleaners. Hazardous waste must be disposed using a licensed HW contractor.
It is not allowed in sewer systems without specialized treatment and sewer permitting. Hazardous
waste disposal costs are high and are also a liability concern to labs. It is much better to reduce
and eliminate hazardous waste rather than pay for disposal and risk substantial EPA fines.
Always use a reputable hazardous waste contractor that has local experience to provide guidance
in hazardous waste disposal. Once a lab generates hazardous waste it becomes the lab’s
responsibility forever, even if it is given to a contractor for disposal. The EPA calls it “cradle to
grave” waste liability. See Figure 14 above.
Overview Of Waste Management Issues
Each local sanitation district regulates the types and concentration of waste that may be
processed in their sewer system following federal standards. Localities must always meet
minimum federal waste discharge standards, but they may have stricter standards. Sewage
treatment systems are generally not designed to process waste produced by many industrial
operations, including optical labs. Before they issue a permit to a facility, many sewer districts
require pretreatment of industrial waste prior to sewer discharge. A lab manager might ask,
“Why haven’t I been notified of this problem?” Every area of the country has different
regulations and levels of enforcement of sanitation laws. Some parts of the country are stricter
than others regarding their enforcement and monitoring. The unmistakable trend is that optical
businesses are being held accountable for their waste disposal practices. A lab should not wait
until it is charged with a violation before addressing this issue. Waiting to act in crisis mode can
cause significant cost and business disruption.
37
Many sanitation districts monitor sewer disposal at the manholes outside commercial
establishments to detect illegal dumping. Sewer monitoring is done to monitor waste discharge to
ensure it meets the standards for heavy metal, pH and other standards established by the district.
The sampling is done to determine if a violation has occurred. When this happens the lab usually
receives a warning letter or could be fined by the district. If hazardous waste is being improperly
disposed of, the state environmental enforcement department is usually called. The EPA also
receives tips from employees of labs relating to real or perceived violations.
Sometimes tips are motivated by revenge from disgruntled employees. Any lab is only a phone
call away from an EPA inspection and possible heavy fines if they are in violation of
environmental laws. Once a lab is caught illegally dumping, the sewer district soon realizes there
may be other optical labs in the area that could be producing similar waste. They usually send
warning letters out to those labs or start more aggressive monitoring of their operations. Being in
compliance is the best insurance against environmental fines.
Environmental compliance is generally not easy or inexpensive, but if a lab plans to stay in
business for the long term, getting started addressing these requirements is the best approach to
protect a business from EPA enforcement actions. Ignoring the problem and/or waiting until
being under an enforcement action by environmental authorities is not a wise decision. If a lab is
not where it should be in an environmental program, management should develop a plan, budget
for environmental compliance, and make a top executive commitment to start dealing with
environmental management issues now. If environmental compliance seems to be expensive,
consider the possibility of $50,000 per violation per day EPA fines, and legal expenses.
Compliance costs are inexpensive compared to EPA penalties, so putting a lab at risk by
violating environmental laws is not a good business decision.
NOTE: Individuals who knowingly dispose of hazardous waste improperly can be held
responsible and are subject to fines up to $75,000 and/or 1 (one) year in prison.
With the demands on our environment, the proper management, recycling, and disposal of lab
waste will become even more important in the future. Businesses must plan for the future to
survive, and environmental concerns are part of that planning. It is not just the law; it is also the
right thing to do as a good corporate citizen.
Getting An Environmental Program Started
Managing a lab is a complex undertaking and complying with broad environmental laws makes
the job even more difficult. Environmental compliance is a cost of doing business and ignoring
these issues could expose a business to significant legal penalties. It is important to work with
local waste disposal contractors or environmental consultants that have specific expertise in the
management of optical lab waste. Using appropriate legal assistance is prudent when dealing
with regulators. Environmental laws are extremely complex, and this chapter is not intended as a
comprehensive guide to ensure compliance with every environmental law, but to provide a
summary of key points to assist in working with environmental professionals to develop a
program that meets a specific situation.
Typical Step’s For Setting Up A Lab’s Environmental Program
1. Collect information about applicable environmental laws and how they apply to the lab.
38
This manual is a good starting point on EPA and OSHA topics. Discretely obtain a copy
of local sewer regulations from the local sewer district and become familiar with the
regulations and how they apply to the lab. Using an attorney to contact the regulatory
agencies on the lab’s behalf is prudent to reduce a lab’s exposure to fines for past or
present environmental violations.
2. Develop a budget for environmental programs for the company. Address hazardous waste
management first, since this type of waste has the greatest liability.
3. Develop an Authorized Use List (AUL) of Chemicals used in the lab along with current
Safety Data Sheets (SDS) on those chemicals. Limit the chemicals in the lab to only
chemicals that are essential to the lab’s operation. No new chemicals should be brought
into the lab unless the manager responsible for the safety and environmental program has
approved the SDS. The sewer district usually requests to see the SDS for chemicals that
will be disposed of in their sewer system before granting a disposal permit.
4. Conduct a waste analysis to determine what waste is suitable for sewer disposal and what
waste has to be treated prior to disposal. This will give the basic information needed to
help develop a waste management plan for the laboratory. One effective method is to
group all similar waste together, such as polish waste or tint department waste and
conduct an analysis with assistance from a local environmental testing lab. The lab
analysis will determine if the waste meets local sewer discharge limitations, or if the
waste have to be pretreated prior to sewer discharge.
5. Have limited contact with environmental agencies until the lab is in compliance with the
laws they enforce. Once government agencies get involved, the lab may be fined for past
violations. Many states have offices to assist businesses on environmental compliance,
and that will not take enforcement actions but will require the lab to comply with
deficient areas that are identified. This is an option that should be considered after legal
consultation to take into account any liability issues.
6. Classify the waste that are generated by the lab as being either hazardous or non-
hazardous. Never combine hazardous and non-hazardous waste without written approval
from a state or local agency. A local certified environmental testing lab would help by
recommending the type of tests needed to classify all waste. Combining similar waste,
such as all coolants, should make disposal and treatment easier and less costly.
7. If pretreatment of waste prior to discharge is necessary, install the necessary treatment
equipment.
8. If necessary, obtain the required sewer discharge permits.
9. Train lab staff on waste management procedures.
39
10. Disposal of hazardous waste should be through a licensed waste contractor. Ensure
conformity with hazardous waste storage requirements. See Figure 15 below.
11. Monitor compliance of the program by analysis of industrial waste being discharged into
the sewer system.
When a lab produces hazardous waste, it is vital that to have the proper information and take the
necessary steps to comply with EPA requirements regarding hazardous waste disposal and
management. There are significant criminal and civil penalties for violating environmental laws,
even if only a small quantity of hazardous waste is involved.
These laws are not to be taken lightly, since the potential exists for an EPA or state
environmental agency to inspect a lab at any time. A phone call to the EPA, or a waste sampling
by regulatory authorities at the sewer pipe outside the lab, could result in an inspection and
violations with the potential of business disruptions and substantial fines.
Figure 15: Lab waste being stored and waiting for proper disposal due to not being permitted to dispose of the
production waste into the sewer system, by order of the local sanitation district
This section is designed as an overview of federal hazardous waste management procedures.
State and local environmental agencies may have additional regulations.
It is the lab’s responsibility to properly classify waste as either hazardous or non-hazardous and
dispose of it properly. The SDS and laboratory analysis will help to determine if waste is either
hazardous or non-hazardous and how to manage it correctly. Examples of hazardous optical lab
waste include:
40
Table 4: Hazardous Optical Lab Waste
Laboratory Waste Examples
ACETONE
ACIDS
ALCOHOL
AR STRIPPER
CATALYSTS (e.g., USED FOR SLAB-OFF LENSES)
CAUSTICS
FIBERGLASSTM
FUELS
GASOLINE
GREASES
INKS
LENS COATING MATERIAL
LENS TANK CLEANER
LIQUID RESIN
LOW MELTING-POINT ALLOY (LMPA)
(CONTAINING LEAD and CADMIUM)
PAINTS
PESTICIDES
SOLDERS
SOLVENTS
SOME CLEANING AGENTS
SOME JANITORIAL SUPPLIES
Assigning an employee who has had proper training as a Hazardous Waste Coordinator is a
helpful management control to maintain compliance. The training must be performed annually,
and it must meet all requirements of the Resource Conservation and Recovery Act (RCRA). A
Hazardous Waste Coordinator’s duties include, but are not limited to:
41
1. ensuring production waste is properly labeled, stored and is inspected weekly, and results
are documented. (See Figure 16 below.)
2. keeping records of hazardous waste generated and analyzing lab waste;
3. maintaining hazardous waste manifests and reports;
4. conducting employee hazardous waste training;
5. coordinating proper disposal of waste;
6. ordering waste cleanup supplies.
Figure 16: An example of a hazardous waste label used to identify the contents. This type of
label is an EPA requirement for waste waiting for disposal. NOTE:. The label shown in figure 16
is not appropriate for shipping hazardous waste. Prior to shipment, containers must have
proper EPA and DOT labels affixed. See below.
42
There are 2 (two) primary options regarding hazardous waste management in a lab. The choices
are either treatment or disposal. Obtaining approval for hazardous waste treatment is sometimes
complex and expensive and might not be the best course of action. The best strategy regarding
hazardous waste is substitution of a non-hazardous materials for hazardous materials. For
example: replace a blocker that uses a lead-based alloy with a wax blocking system, or switch to
a non-lead alloy that is available from many optical lab suppliers. See Figure 17 below.
Figure 17: A hazardous waste storage area with a secondary containment system placed around the drum to
prevent hazardous waste from releasing if there is a leak. Drums must be sealed when chemicals are not being
added.
A lab that generates hazardous waste, should have a written Standard Operating Procedure
(SOP), that employees follow to help prevent violations. However, an SOP is only effective if
workers are trained to follow it and the procedures are enforced.
What Is Hazardous Waste?
Waste is a solid, liquid or compressed gaseous material that is no longer used, but is stored until
there is enough to treat or dispose. Certain waste can cause serious problems if not handled and
disposed of carefully. Such waste could cause death or serious irreversible, incapacitating
illnesses, and/or damage or pollute the land, water or air. The Environmental Protection Agency
(EPA) and various states’ Departments of Environmental Quality have classified hazardous
waste into two categories:
➢ Characteristic waste
➢ Listed waste
Answers to specific questions regarding Federal hazard waste regulations are available by calling
the Resource Conservation and Recovery Act (RCRA) Call Center (Washington, DC area) at
(800) 424-9346 or TDD 800-553-7672.
43
Characteristic Waste
Characteristic waste is comprised of materials that may be hazardous if they contain one or more
of the following type of waste:
• Ignitable waste: easily flammable with a flash point lower than 60° (degrees) C/140°
(degrees) F.
• Corrosive waste: pH less than 2 (two) or greater than 12.5.
• Reactive waste: unstable or undergoes rapid or violent chemical reaction with water
or other materials and releases toxic gases.
• Toxic waste: if an extract from the waste is tested and found to contain a high
concentration of heavy metals or specific organic compounds that could be released
into ground water.
Table 5: Characteristic Laboratory Waste
Characteristic Lab Waste Examples
ACETONE
ACIDS
ALCOHOL
AR STRIPPER
CATALYSTS (e.g., USED FOR SLAB-OFF LENSES)
CAUSTICS
FUELS
GASOLINE
LENS COATING MATERIAL
LENS TANK CLEANER
LOW MELTING-POINT ALLOY (LMPA) (CONTAINING LEAD and CADMIUM)
PAINTS
PESTICIDES
SOLDERS
SOLVENTS
SOME JANITORIAL SUPPLIES
44
EPA Listed Waste
The EPA identifies approximately 500 chemicals and hazardous waste by technical name in 4
(four) different lists. If the name of the waste material generated by an operation appears in any
one of these 4 (four) lists, the waste must be considered as hazardous. To obtain a copy of the
Listed Waste, contact the state government environmental department, if available, or the EPA at
www.epa.gov. Optical labs following standard operations do not commonly produce this class of
waste.
Hazardous Waste Determination
Deciding which waste are hazardous and which are non-hazardous can present some difficulties.
It is the responsibility of the generator of the waste to make the determination if the waste is
hazardous. The Safety Data Sheet is a good starting point for information for determining if a
waste is hazardous. Management of hazardous waste is generally not a “do it yourself
proposition” due the complexity of federal law and specific local regulations. Dealing with an
experienced waste disposal contractor is the first line of defense to avoid violations.
The contractor will help develop a program to classify, store and dispose of hazardous waste.
Prices could vary greatly between contractors, so obtaining quotes and references will help find a
contractor that will best meet the needs of the local lab. A local environmental testing lab may
also be of assistance to recommend what testing is required to classify waste. Another place to
turn for support is a state environmental assistance center. Many states have environmental
offices to provide guidance on determining what waste could be considered hazardous. These
assistance programs may also recommend how to properly manage waste. In many states, this is
a free service and is separate from the environmental enforcement office. As previously
discussed, consultation with an attorney when working with government officials is always
advisable. See Figure 18 below.
Figure 18: Low melting point alloy (LMPA) blocking system
45
Typical Characteristic Optical Waste
Table 6: Characteristic Laboratory Waste
Characteristic Optical Hazardous Waste
ACETONE
ACID AND CAUSTIC
ALLOY WASTEWATER CONTAINING LEAD
LIQUID RESINS
LOW-MELTING-POINT ALLOY (LMPA)
CONTAINING LEAD
SLUDGE FROM ALLOY RECLAIM TANKS
SOLVENTS
SOME LENS-COATING SPRAYS
Reducing Hazardous Waste
➢ Substitute non-hazardous chemicals for hazardous ones.
➢ Review SDS for all new chemicals and try to use non-hazardous materials.
➢ Conduct a cost-benefit analysis of hazardous materials (HM) and use HM only when
necessary.
➢ Do not combine hazardous waste with non-hazardous waste. The EPA will classify the
entire amount of waste as hazardous and require an analysis of the waste before disposal.
See Figure 19 below.
➢ Keep the smallest amount of HM as possible on hand in the lab.
➢ Use a lead-free alloy or a wax-blocking system.
46
Figure 19: Lens protective tape cover with a lead-based alloy. This type of waste must be disposed of as
hazardous waste.
Responsibilities Of Optical Labs That Produce Hazardous Waste
All laboratories have the following responsibilities in regard to hazardous waste in their
workplace:
➢ select chemicals carefully;
➢ become familiar with individual workplace hazards;
➢ manage and dispose of all hazardous waste in compliance with all mandated regulations.
The SDS will help provide this information.
Responsibilities of a hazardous-waste generator include:
➢ properly identify, segregate, collect and label all hazardous waste;
➢ ensure all employees involved in managing hazardous waste are trained in the
requirements of the Resource Conservation and Recovery Act (RCRA);
➢ contact a licensed waste-disposal contractor to provide proper containers and guidance to
comply with hazardous waste regulations;
➢ ensure the hazardous-waste containers are always kept closed except when adding or
removing waste from the container;
➢ label and store hazardous waste containers in a safe location that is not exposed to
weather;
➢ ensure different waste streams from operations are not being mixed together unless
approved by the disposal contractor;
➢ initiate a meaningful waste-minimization plan through substitution, reduction, purchase
control and/or recycling;
47
➢ prevent spills and waste entering the sewer system by sealing floor drains near waste
storage areas. See Figure 20 below.
Figure 20: Example of a warning sign for handling chemicals
Hazardous Waste Laws
The law that regulates hazardous waste in the United States is the Resource Conservation and
Recovery Act (RCRA). This law restructured waste management practices nationwide. The
RCRA achieves three primary goals to:
1. protect human health and the environment;
2. reduce waste, conserve energy and natural resources;
3. reduce or eliminate generation of hazardous waste as expeditiously as possible.
These regulations specify that hazardous waste can be legally disposed of at EPA approved
disposal facilities. Any company that produces hazardous waste material is classified as a
“hazardous waste generator.” Hazardous waste generators have direct control over how
efficiently hazardous waste are managed within their workplaces.
Each hazardous waste generator should develop standard operating procedures for their work
processes that comply with all applicable regulatory requirements to identify and temporarily
store hazardous waste. This can help protect from regulatory actions by the EPA and/or state
environmental departments. There are substantial fines or prison sentences imposed against
48
persons handling and/or disposing of hazardous waste improperly. Even very small amounts of
hazardous waste not disposed of in accordance with regulations could place a business at risk. A
reputable contractor will assist in achieving compliance with these regulations.
Generator Categories
What are “generator categories”? When waste is hazardous, it must be managed according to
appropriate Federal regulations. A lab’s generator category determines which requirements must
be followed to manage hazardous waste.
The first step in this process is to measure the amount of hazardous waste produced per month.
The EPA defines three categories of hazardous waste generators based on the amount of
hazardous waste a worksite produces monthly. The categories are:
1. CONDITIONALLY EXEMPT SMALL QUANTITY GENERATORS (CESQG)
generate less than 220 lbs. (100 kg) of HW monthly
2. SMALL QUANTITY GENERATORS (SQG) generate between 220 lbs. (100 kg) and
2,200 lbs. (1,000 kg) of HW monthly
3. LARGE QUANTITY GENERATORS (LQG); generate more than 2,200 lbs. (1,000
kg) of HW monthly
Most optical laboratories that produce hazardous waste are classified as Conditionally Exempt
Small Quantity Generators (CESQG); some may be Small Quantity Generators (SQG). Each
category of generator must comply with the hazardous waste rules specific to that category. This
manual is intended primarily for labs that generate a small quantity of hazardous waste (SQG
and CESQG), to help them learn about regulations that apply to their operations.
Depending on the size of a lab and the amount of waste that is generated, a lab might be
regulated under different rules at different times. If, for example, less than 220 lbs (100 kg) of
hazardous waste are generated during the month of June, this would be considered a CESQG for
June, and June waste would be subject to the hazardous waste management requirements for
CESQG. If, in July, between 220 and 2,200 lbs (100 kg to 1,000 kg) of hazardous waste are
generated, a lab’s generator status would change, and it would be considered an SQG for July.
July waste would then be subject to the management requirements for SQG. If the waste
generated during June and July are mixed, the entire mixture would be subject to the more
stringent SQG standards. In many cases, small businesses that fall into different generator
categories at different times choose to satisfy the more stringent requirements to simplify
compliance.
Much hazardous waste is comprised of liquids and is measured in gallons, not pounds. In order
to measure liquid waste, convert pounds to gallons. Determine the density of the liquid. A rough
guide is 30 gallons (about half of a 55-gallon drum) of waste with a density similar to water
weighs about 220 pounds (100 kg) i.e., 300 gallons of waste with a density similar to water
weighs about 2,200 lbs (1,000 kg).
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Conditional Exempt Small Quantity Generators (CESQG)
If a lab generates no more than 220 lbs. (100 kg) of hazardous waste per month, it is a
Conditionally Exempt Small Quantity Generator (CESQG). A lab must comply with three basic
waste-management requirements to remain exempt from the full hazardous-waste regulations
that apply to generators of larger quantities (SQG and LQG). The requirements are:
1. Identify all hazardous waste that is generated.
2. More than 2,200 lbs. (1,000 kg) of hazardous waste may not be stored onsite at any
time.
3. Ensure delivery of hazardous waste to an offsite treatment or disposal facility that is
licensed or registered by a state that manages municipal or industrial solid waste.
It is advisable to call the appropriate state agency to verify that the Treatment, Storage and
Disposal Facility (TSDF) selected has all the necessary permits, etc. It is recommended that such
a call be documented in the lab’s records. Document the name of the person spoken to, as well as
what was said.
The onsite storage requirements of CESQG stipulate that a business may not store more than
2,200 lbs. (1,000 kg) of hazardous waste onsite at any time. The state director or the regional
EPA administrator may grant limited extensions. If these limits are exceeded, a special EPA
permit is required.
State Requirements For CESQG
Some states have additional requirements for CESQG. For example, some states require CESQG
to follow some of the SQG requirements such as obtaining an EPA identification number or
complying with storage standards.
Lab managers should check with their respective state environmental agency for the applicable
regulations at each location.
Contact with state regulators is essential since, in almost every state, the EPA has delegated
authority to the states to implement and enforce major portions of the hazardous waste
management programs. In order to receive authorization from EPA, states’ hazardous waste
management regulations must be at least as stringent as EPA’s hazardous waste regulations. The
state authorization process is ongoing and can be difficult to track. Laboratory management
should check with their states to understand the hazardous waste requirements in their area and
what parts of the environmental laws are enforced by state authorities and what portions EPA
enforces.
Small Quantity Generators (SQG)
If a laboratory generates between 220 lbs. (100 kg) and 2,200 lbs. (1,000 kg) of hazardous waste
per month, it is an SQG. In addition to the requirements listed above for CESQG, it must obtain
and use an EPA identification number. The EPA and state environmental agencies use these 12-
character identification numbers to monitor and track hazardous waste activities. The
identification number will need to be used when waste is sent offsite to be managed.
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To obtain an EPA identification number, call or write the state hazardous waste management
agency or the Hazardous Waste Division of the EPA regional office and ask for a copy of the
EPA Form 8700-12, “Notification of Hazardous Waste Activity.” The EPA will send a booklet
that contains the form with instructions for completion, along with portion(s) of the regulation(s)
that will help identify waste. State agencies will also send the appropriate form to complete.
Each site will receive its own EPA identification number.
Accumulating Hazardous Waste
Accumulating hazardous waste can pose a threat to human health and the environment. It may
only be kept for a short time without a permit. Before shipping the waste for disposal or
recycling, the generator of the waste is responsible for its safe management, which includes safe
storage, safe treatment, preventing accidents, and responding to emergencies in accordance with
Federal regulations.
An SQG can accumulate no more than 13,228 lbs. (6,000 kg) of hazardous waste onsite for up to
180 days without a permit. Waste may be accumulated in this amount for up to 270 days if it
must be transported more than 200 miles away for recovery, treatment or disposal. To avoid
having to register as a shipper of hazardous materials, it is best to limit the quantity of hazardous
waste in a single shipment to 2 (two) 55-gallon drums or less of each waste type (flammable,
corrosive, reactive and toxic).
Waste generated in small amounts throughout a facility may be stored in satellite accumulation
areas located at or near the point of generation of the waste. The total amount of waste that may
be accumulated at a satellite area is limited to 55 gallons. Once this quantity has been exceeded,
regulations allow three days to transfer the waste to the designated 180-day (or 270-day) storage
area. An SQG location must accumulate waste in tanks or containers, such as 55-gallon drums.
State environmental assistance offices have specific requirements for their areas. By definition,
CESQG accumulates less than 55 gallons of waste each month.
NOTE: Hazardous waste is considered a hazardous material under USDOT Hazardous Materials
Shipping Regulations. Companies that ship a “placardable quantity” of any hazardous waste
material must register as a HAZMAT Shipper. For flammable liquids the placardable quantity is
1,000 lbs., or approximately 2-1/2 55-gallon drums. The fee to register as a Hazmat Shipper is
$2,000 per year.
The storage tanks and containers used to accumulate hazardous waste must be managed
according to the EPA requirements summarized below.
For containers:
➢ Label each container with the words “HAZARDOUS WASTE” and what type of waste
is in the container, along with the date that the waste drum was filled.
➢ Use a container made of, or lined with, a material that is compatible with the hazardous
waste to be stored. (This will prevent the waste from reacting with or corroding the
container.)
➢ Keep all containers holding hazardous waste closed during storage, except when adding
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or removing waste.
➢ Do not open, handle or store (e.g., stack) containers in a way that might rupture them,
cause them to leak or otherwise fail.
➢ Inspect areas where containers are stored at least weekly and document results of the
inspection.
➢ Look for leaks and/or deterioration caused by corrosion or other factors.
➢ Maintain the containers in good condition. If a container leaks, put the hazardous waste in
another container, or contain it in some other way that complies with EPA regulations.
➢ Do not mix incompatible waste or materials unless precautions are taken to prevent
certain hazards.
➢ Have spill cleanup supplies available and block floor drains and storm drains to prevent
chemicals entering the environment.
Management Of Hazardous Waste Onsite
Some labs accumulate hazardous waste onsite for a short period of time and then ship it offsite to
a Treatment, Storage or Disposal Facility (TSDF). It is good practice never to mix waste without
obtaining the waste disposal contractor’s approval. Mixing waste could create an unsafe work
environment and lead to complex and expensive cleanups and disposal. Several points to
remember when managing waste at a lab include:
➢ DO NOT MIX NON-HAZARDOUS WASTE WITH HAZARDOUS WASTE. Once
a non-hazardous waste is mixed with a listed hazardous waste, the whole batch becomes
hazardous. Mixing waste can also make recycling very difficult, if not impossible. A
typical example of mixing waste would be putting non-hazardous cleaning agents in a
container of used hazardous solvents.
➢ CHANGE MATERIALS, PROCESSES OR BOTH. Businesses can save money and
increase efficiency by replacing a material or a process with another that produces less
waste or non-hazardous waste. For example, a lead-free alloy could be used in place of an
alloy with lead content. Check the SDS for the ingredients of the alloy to see if it contains
lead. If a lead-based alloy is used and then, when possible, switch to a lead-free alloy, the
new alloy could have contamination with lead residue left on the equipment. The cost of
lead-free alloy could be many times more than alloy that contains lead, and this should be
considered before the material is purchased. Lab analysis of waste is recommended to
ensure that the waste from processes are free of any hazardous material. Reviewing the
SDS of chemicals for hazardous materials before they are purchased will help prevent
hazardous material from being introduced into the lab.
➢ RECYCLE AND REUSE MANUFACTURING MATERIALS. Many companies
routinely put useful material back into production use rather than disposing of it. This is
commonly done with low melting point alloy. Alloy reclaim water may be both filtered
and reused or evaporated. The residue or used filters from these treatment processes are
considered hazardous waste if they contain lead. In addition, some companies have taken
waste minimization actions such as using fewer chemicals to do the same job. Do not put
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unfiltered alloy reclaim tank water to drains.
➢ SAFELY STORE HAZARDOUS PRODUCTS AND CONTAINERS. Avoid creating
more hazardous waste by preventing spills or leaks. Store hazardous chemicals and waste
containers in secure areas and inspect them weekly for proper labeling and container
integrity to prevent spills. Maintain a log of the weekly inspection results for three years.
If leaks or spills occur, materials used to clean them also become hazardous waste.
➢ MAKE A GOOD FAITH EFFORT. SQG facilities do not have to document their
waste minimization activities or create a waste minimization plan. However, SQG
facilities do need to certify on their manifests that they have made a good faith effort to
minimize waste generation when they send waste offsite.
➢ ELIMINATE UNKNOWN WASTE. Hazardous waste management regulations
specifically prohibit transportation, storage, and disposal of unknown waste materials.
For this reason, and for the safety of the contractor and staff, the Hazardous Waste
Contractor will not accept unknowns. The generation of unknown waste can be
prevented, if proper management practices are in place at a laboratory or workplace.
Having unlabeled barrels of waste would result in a costly environmental violation.
Should a lab need assistance in properly identifying unknowns, the hazardous waste
contractor may be able to be a guide in the proper direction. All barrels should always be
labeled as to the contents of the barrel. See Figure 21 below.
Figure 21: Unidentified waste that might be hazardous. This is an example of a violation of the Hazard
Communications Standard and EPA regulations for identification of waste.
Hazardous Waste Manifests
The Hazardous Waste (HW) Manifest System is a set of forms, reports, and procedures designed
to seamlessly track hazardous waste from the time it leaves the generator until it reaches the
offsite waste management facility that will store, treat, or dispose of the HW. The system allows
the waste generator to verify that its waste has been properly delivered and that no waste has
been lost or unaccounted for in the process. The key component of this system is the Uniform
Hazardous Waste Manifest, which is a multi-part form prepared by most generators that transport
hazardous waste for offsite treatment, recycling, storage, or disposal. Both the U.S. Department
of Transportation (DOT) and the EPA require the manifest to ship waste.
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When completed, the manifest contains information on the type and quantity of the waste being
transported, instructions for handling the waste, and signatures of all parties involved in the
offsite treatments, recycling, storage, or disposal process. Each party must retain a copy of the
manifest. This process ensures critical accountability in the transportation and disposal process.
Once the waste reaches its destination, the receiving facility returns a signed copy of the manifest
to the generator, confirming that the waste has been received. The generator must maintain both
copies for three years plus the current year.
Labeling Waste Shipments
All hazardous waste must be properly labeled prior to shipment as to the contents and specific
hazards of the waste such as flammable. The Hazardous Waste Disposal Contractor will provide
specific guidance and proper labels for shipment of the waste. Most small businesses use a
commercial transporter to ship hazardous waste. These transporters can advise on specific
requirements for placarding, labeling, marking, and packaging; however, the originator of the
hazardous waste remains responsible for compliance.
Federal regulations allow transporting hazardous waste to a designated treatment facility
provided that the means of transport is in compliance with Department of Transportation rules.
Some states, however, do not allow this practice. Check with the state hazardous waste
management agency regarding applicable regulations.
Record Keeping
Hazardous Waste Generators are required to maintain records to document proper disposal of
hazardous waste. A hazardous waste disposal contractor, or EPA regional offices included in the
appendix, will provide additional information, if requested, about meeting these requirements.
The primary information that must be included in record keeping is:
1. Copies of all hazardous waste manifests and the signed copy of the manifest returned
by the disposal facility.
2. Copies of lab analysis of disposed lab waste.
3. Annual reports submitted to the EPA and state environmental office on waste
generated during the calendar year.
4. Training records of hazardous waste training provided to all employees who handle or
come in contact with hazardous waste.
5. Additional state record keeping requirements may apply in any locality.
Universal Waste Rule
The Universal Waste Rule was written to streamline environmental regulations for waste
generated by large numbers of businesses in relatively small quantities. It is designed to reduce
the amount of hazardous waste disposed of in municipal solid waste, encourage the recycling and
proper disposal of certain common hazardous waste, and reduce the regulatory burden for
businesses that generate these wastes. Universal waste are items commonly thrown into the trash
by households and small businesses.
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Although handlers of universal waste can meet less stringent standards for storing, transporting,
and collecting the waste, handlers must still comply with the full hazardous waste requirements
for final recycling, treatment or disposal. By providing a waste management structure that
removes the waste from municipal landfills and incinerators, the rule ensures stronger safeguards
for public health and the environment.
Materials are continually added to the universal waste list:
See www.epa.gov/epaoswer/hazwaste/id/univwast.htm for the latest information.
Examples of universal waste include:
➢ Batteries such as nickel-cadmium (Ni-Cd), lithium, and small sealed lead-acid batteries,
which are found in many common items, including electronic equipment, cell phones,
portable computers, and emergency backup lighting.
➢ Lamps, which typically contain mercury and sometimes lead, and are found in businesses
and households. Examples include fluorescent, high-intensity discharge (HID), neon,
mercury vapor, high-pressure sodium, and metal halide lamps.
Preventing Accidents
Whenever hazardous waste is stored onsite, the potential risks from fires, spills or other accidents
must be minimized. Although the EPA does not require CESQG or SQG to have a written
contingency plan, managers must be prepared for an emergency at every facility.
IF A CHEMICAL EMERGENCY IS SUSPECTED, IMMEDIATELY CALL 911 AND
THE NATIONAL RESPONSE CENTER (NRC) AT 800-424-8802.
In the event of a fire, explosion, or other release of hazardous waste that could threaten human
health outside the facility, or if a spill may have reached surface water, call the National
Response Center to report the emergency. The Response Center will evaluate the situation and
help make appropriate emergency decisions. In many cases, it will be determined that the
problem was not a true emergency, but it is better to call if there is any uncertainty. Serious
penalties exist for failing to report waste spills that enter the environment.
Onsite Hazardous Waste Treatment
The EPA and many states provide several regulatory exclusions that allow generators to treat
hazardous waste without a permit. Some of these treatment exclusions may be useful in
furthering waste reduction efforts. Treating hazardous waste onsite in ways other than provided
for in the regulatory exclusions, subjects generators to extremely high fines (e.g., up to $75,000
per day) and possible criminal penalties (i.e., time in prison). Before treating hazardous waste
onsite, generators must be absolutely sure that the treatment they are considering is
allowed without a RCRA or state/local permit. In addition, generators must ensure that they
have proper procedures, equipment and skilled employees to conduct treatment safely and
effectively onsite.
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HW Management Issues For Typical Optical Lab Waste
Many optical labs produce hazardous waste during their operations, but with good planning the
waste should be of limited quantity. This will reduce disposal costs and EPA liability dealing
with this issue. The Safety Data Sheet is a good source of information to determine if a material
will produce hazardous waste. The SDS sometimes provides detailed information regarding
disposal of the material. If the material has changed due to contamination with another material,
lab analysis could be required to determine the proper disposal method. If the information
regarding waste disposal procedures on the SDS is vague, it would be prudent to call the supplier
and request written recommendations for waste disposal. It is important to remember that the
responsibility for disposal of waste is on the generator of the waste not the chemical
manufacturer. It would be difficult to discuss every hazardous waste that could be found in a lab,
so this discussion will be limited to some commonly found optical laboratory waste such as:
➢ Low Melting Point Alloy (LMPA);
➢ Solvent;
➢ Acid;
➢ Caustic
Low Melting Point Alloy Waste (117°F ALLOY)
Low Melting Point Alloy (LMPA) has been used in optical labs for decades, but many optical
laboratory workers and managers are not aware of its hazards. The most common alloy still in
use in many labs is the 117° (degrees) F alloy. Some labs use the 145° (degrees) F alloy in their
operations. This alloy might contain lead or cadmium depending on the supplier. The 117°
(degrees) F alloy generally contains approximately 22% lead and 5% cadmium. Both metals
present a significant hazard to employee safety and the environment, if not managed properly.
Lead contamination concerns are a national priority. It is becoming increasing more important to
eliminate lead contamination from the environment. Use of this material creates considerable
liability for laboratory management. The chief disadvantage to using 145° (degrees) F alloy is
the increased cost and potential for distortion of thin lenses. The cost of managing the hazardous
waste from 117° (degrees) F alloy could make using it more expensive than the no-lead alloy.
The reduction of EPA liability and improvement in worker safety makes switching to a no-lead
alloy preferable.
LMPA Management Issues
Lab managers have significant responsibilities regarding OSHA and EPA regulations when using
a material that contains lead. The following are areas of concern when lead and cadmium are
used in a lab:
Hazard Communication Standard
Employees must be informed of the hazards of chemicals and substances that they come in
contact with at work. This requirement is discussed in detail in Section 1 of this manual.
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Personal Protective Equipment
When employees work with LMPA, they should wear disposable latex gloves. If a splash hazard
exists while pouring liquid alloy, splash proof safety goggles should be worn.
Employee Training
Employees must be trained on safe work practices while working with alloy. Lab policies
regarding the safe use and disposal of this material should be developed. Safety policies, to be
effective, must be enforced. Safety training should be documented with a signed roster including
a course outline. The review of the SDS sheets and should be included in the training.
Work Area Posting
The area, such as around reclaim tanks and blockers, should have a sign informing employees
that this is a lead work area and eating, smoking, and drinking is prohibited. Before pregnant
employees work with lead, their doctor should be consulted.
Sanitation Issues
It should be a lab’s safety policy that employees wash their hands after working with alloy before
eating, drinking or smoking, and these activities should be prohibited in areas where this material
is being used. Wearing disposable gloves and aprons helps to prevent alloy from getting on
employees’ work clothes and possible lead exposure to their families by bringing lead
contaminated clothing home to be washed. Alloy contaminated protective equipment should be
managed as hazardous waste unless the lab can document there is no lead or cadmium present.
Environmental Concerns
Lead and cadmium create significant environmental concerns. In many areas, if lab waste has 5
(five) parts per million or more of these substances, it is considered a hazardous waste. Also, it is
a common practice for local sewer districts to monitor waste discharges by businesses. Two
primary metals that are monitored in waste discharge are lead and cadmium. Remember that
disposal of a hazardous waste such as lead contaminated alloy wastewater in the sewer system is
not legal and could expose the company and individual managers to significant fines.
PROTECTIVE TAPE
When protective tape is contaminated with a lead based alloy, it would be considered a
hazardous waste, not suitable to be disposed of in regular lab trash.
RECLAIMED ALLOY WASTE MANAGEMENT AND TREATMENT
Typically, all alloy waste may be combined in one 55-gallon drum for disposal with the
hazardous waste contractor’s approval. Waste reduction of reclaim water by filtration and
recycling of the water will reduce the volume and cost of waste from this process.
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Figure 22: Low-melting-point alloy reclaim tank. Notice the loose alloy surrounding the tank. The water and
sludge are hazardous waste (HW) produced by the tank when a lead-based alloy is used. The tank must be
labeled with appropriate HAZCOM warning labels.
Substitutes For 117°F Alloy
Lead and cadmium free alloy is a highly effective material in the surfacing of ophthalmic lenses.
Several options are available to limit or eliminate lead and cadmium in an optical lab. The use of
145° (degrees) F low-lead alloy may be an option for using existing equipment. The use of alloy
material with no lead and cadmium content is a logical choice to address safety and
environmental concerns. This will limit employee exposure to lead and hazardous waste disposal
concerns. Waste generated from use of a “lead-free alloy” must still be tested prior to disposal.
Safety and environmental concerns should be considered prior to bringing in any chemical or
other material into a lab. The high cost of 145° (degrees) F alloy is a disadvantage.
LMPA Reclaim Tank Waste
The alloy-reclaim tank operation that collects/melts alloy for reuse by the lens blockers will
usually produce hazardous waste from the lead contamination of the reclaim water and
residue/dirt remaining in the bottom of the tank. Both of these materials should be considered a
hazardous waste if they contain lead. A lab could face substantial fines for dumping lead
contaminated waste into the sewer system. Several waste management options are available that
will reduce the volume produced from this operation. These options include evaporation and
recycling the reclaim water for reuse. The Universal Photonics “Lead Removal System” is a
commonly used treatment method designed for recycling alloy wastewater. This method will
reduce the volume of liquid waste, but the solids that remain must be disposed of as a hazardous
waste through a licensed contractor. The solid residue from the filters would also be considered a
hazardous waste unless it is recycled by the supplier. See Figure 22 above.
If a lab uses a lead-free alloy, an environmental testing lab can provide the information to take
the proper action to dispose of the waste generated by this alloy. Even if the alloy does not
contain lead and cadmium, the waste might not be suitable for sewer disposal. The local sewer
district is the final authority to determine what waste is suitable to be disposed of into the sewer
system. The other metals such as indium contained in “lead free alloy” might not be allowed to
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be disposed of in the sewer. Many so-called “lead-free alloys” could also contain a small amount
of lead. The content of the alloy may be verified by a simple lab test. When working with a local
sewer district regarding obtaining a waste disposal permit, it is prudent to also work with an
environmental consulting firm or environmental contractor with local experience.
Solid waste that is determined to be non-hazardous should be suitable to be disposed of with
normal lab trash. Checking with the local trash hauler is wise. If a lead-based alloy is used, the
hazardous waste, both liquid and solid, must be placed in a hazardous waste collection container
and disposal arranged through a licensed contractor. The drum must be labeled with the contents
of the container. The amount of hazardous waste that is allowed to be stored at a lab is generally
limited to no more than 55 gallons. An EPA permit may also be required to store waste awaiting
disposal. A hazardous waste contractor should be able to provide specific guidance regarding the
regulations of storing hazardous waste. A good technique is to filter and reuse the reclaim tank
wastewater. Avoid allowing alloy to get into sink drains to prevent lead and cadmium from
entering the sewer system. Sealing all floor drains in production areas will help prevent chemical
spills from getting into the sewer system that could result in a violation.
EPA Lead Reporting
A limited number of labs that use a large quantity of low melting point alloy (LMPA) containing
lead are subject to EPA lead reporting regulations. If the worksite meets the following
requirements, the facility is subject to EPA lead reporting regulations.
➢ There are at least 10 (ten) employees;
➢ The facility falls under a Standard Industrial Classification (SIC) code of 20-39. The lab’s
SIC code is 3851, and the North American Industry Classification System (NAICS) code
is 339115;
➢ The facility manufactures, processes or otherwise uses 100 pounds or more of lead, or
100 pounds or more of a lead compound in a calendar year.
The standard for reporting requirements is based on how much lead or lead compound is used in
a calendar year. The discharge amount is irrelevant to the 100-pound-use threshold. Merely
storing lead, as opposed to the use of lead, does not count towards the 100-pound threshold.
Reused lead or lead compound is not counted twice.
Treatment Of Acid Waste From AR Coating
Some labs use acid as part of the cleaning process in their anti-reflective (AR) lens coating
process. See Figure 23 below. Treatment of this acid waste is an issue for such labs. An option is
to treat the waste onsite for sewer disposal. The local sewer district has to grant approval for
neutralized waste to be discharged into the sewer system. Generally, they will require periodic
monitoring of the waste produced from a lab to ensure that it has been properly treated and
complies with discharge limitations.
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Figure 23: This is an example of a treatment unit for AR-coating waste. Caustic liquid waste is combined with
water in the clear plastic tank. The pH of the waste is adjusted with 5% Hydrochloric Acid to make it suitable
for sewer disposal. A local permit was obtained to discharge treated waste in the sewer system.
The EPA’s exclusions that allow generators to treat hazardous waste onsite without a permit are
described as using “elementary neutralization.” The EPA and most state authorities allow
elementary neutralization, i.e., pH adjustment of hazardous waste. Elementary neutralization
units (as defined in 40 CFR 260.10) may be used to neutralize D002 (corrosive) waste without
requiring any permit based on the Resource Conservation and Recovery Act (RCRA). See
Figures 24 and 25 below.
Figure 24: An automatic pH meter used to check the pH level of caustic waste prior to its discharge into the
sewer system. The lab has a permit from the local sewer system authority to discharge pH-adjusted waste.
Important points to remember are:
➢ elementary neutralization only refers to pH adjustment;
➢ neutralized waste should only be discharged down a drain if the waste meets all
60
applicable sewer discharge regulations and if written approval has been obtained from the
local sewer district;
➢ check with the state environmental office to determine whether additional regulations are
applicable;
➢ seek professional environmental assistance when developing a waste treatment system.
(Many states provide free technical assistance to small businesses having hazardous
waste issues.)
Figure 25: Dispensing pump for hydrochloric acid designed to mix with caustic waste for a pH neutralization
process. The pump will adjust the hazardous caustic waste close to a neutral pH, which is suitable for sewer
disposal.
Solvent Use In Labs
The use of solvents in labs should be limited in most cases. The prudent use of solvents, in many
instances, could result in no waste being generated at all. The use of a plunger dispensing
container designed for flammable liquids, that dispenses only the quantity of solvent needed,
works well in most small applications. If a special application produces liquid solvent waste that
does not evaporate, it must be managed as a hazardous waste. The storage of used solvents has
fire protection concerns. The local fire department should be consulted when storing flammable
liquids other than small containers of flammables in the lab.
Cleaning solvents must be properly classified as either a hazardous or non-hazardous waste. The
SDS will assist in making this determination. There are also many non-hazardous cleaning
solvents that could be suitable for sewer disposal if they are not contaminated with a hazardous
material. It is important to remember that the local sewer district approves the discharge of the
waste into their sewer system. If a solvent is hazardous, it is generally not acceptable to dispose
of it by using evaporation into the atmosphere. Regulations under the Federal Clean Air Act
generally do not permit evaporation of a hazardous waste as a treatment option. Environmental
regulations are complex and using professional assistance would be advisable if solvent waste is
produced as part of a production process. If a lab produces hazardous solvent waste, it should be
collected in a non-flammable container and a determination made regarding the proper disposal
method. Decisions should be based on the SDS, lab analysis of the waste, and professional
assistance if necessary. It is illegal to dispose of flammable solvents in the sewer system. This
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applies to even small quantities of hazardous waste.
Used cleaning cloths that contain flammable material such as alcohol as part of a production
process should be stored in a hazardous waste container until they may be disposed of properly.
If the solvents are part of a production process, such as cleaning the markings off progressive
lenses, the used solvents may be evaporated as part of the process. Solvent soaked rags should be
stored in an appropriate closed flammable container and kept away from any ignition sources.
Examples of locations where flammable materials should not be stored are near furnaces and
portable heaters. It is wise to have the local fire prevention inspector evaluate the lab for fire
hazards. Some states and localities have very strict air emission standards that go beyond Federal
regulations and should also be considered.
If a lab produces cleaning rags that contain a hazardous solvent, in most cases, they would have
to be handled and disposed of through a hazardous waste contractor. If there are questions
regarding disposal of even small amounts of hazardous waste, it would be advisable to first
review the SDS of the material planned for disposal, and then call the state environmental agency
for specific guidance. It is advisable to document conversations with a memo of what was
discussed when speaking with state and local environmental agencies.
Alkali or Caustic Waste
An alkali or base is any chemical substance that has a pH above 7. They may cause severe burns
to the skin. An alkali turns litmus paper blue and has a pH value from above 7 to 14. Some AR
coating operations produce this type of waste. Using personnel protective equipment, including
splash proof goggles, rubber gloves and an apron is appropriate when working with materials
with high pH values.
This waste may be neutralized in many cases to make it suitable for sewer disposal using a mild
acid such as hydrochloric acid, but there are many precautions that must be taken, and
professional assistance may be needed to prevent injuries to employees, damage to equipment,
and environmental violations. There could be a dangerous chemical reaction when mixing an
acid with a base, so only qualified individuals should develop treatment methods for a lab using
this type of system. A secondary containment system around the acid drum to contain the acid in
the event of a spill is recommended. A waste contractor can provide recommendations in this
area.
Alkali waste, once properly neutralized to near a pH value of 7, could be suitable for sewer
disposal depending on local rules. As with any industrial waste, written approval or permits must
be obtained prior to discharging the waste in the sewer system. A written operating procedure for
employees, as well as ensuring employees are trained in these procedures, will help prevent
injuries and violations.
Choosing Reliable Waste Disposal Services
Hazardous waste generators have “cradle to grave” responsibility for the waste they produce. In
other words, generators (a company that produces hazardous waste) face a potential liability if
their waste were to cause a problem during any stage of the management process. Selecting a
reliable hazardous waste transporter and treatment, storage, and disposal facility (TSDF) is very
62
important in order to minimize future liability. Quality of service should be a primary concern. It
is essential to obtain information about the transporter, such as regulatory status, safety records,
customer satisfaction, compliance assistance and waste stream capabilities, before selecting a
service that will meet all of a lab’s needs. Selecting a disposal service on price alone could place
a lab and lab management at great financial and criminal risk. The producer of waste is forever
responsible for the waste generated, and improper actions of a contractor could be very costly. A
hazardous waste disposal contractor should be able to provide the following services:
➢ provide consultation and technical information, if requested, on hazardous waste and
their appropriate disposal methods;
➢ supply containers to collect different types of hazardous waste;
➢ furnish hazardous waste shipping manifests and labels to properly identify hazardous
waste
➢ pick up properly identified and packaged hazardous waste from work areas for proper
disposal;
➢ assist in developing a waste minimization plan;
➢ monitor the amount of hazardous waste generated from each laboratory and workplace;
➢ assist in developing an emergency response plan, adequate for each work site, in the
event of an accident or a chemical spill;
➢ act as a liaison between the lab and regulators, such as the EPA, if necessary.
The following gives an overview of the necessary criteria and some guidance on how to evaluate
hazardous waste services. The Hazardous Waste Contractor should be able to provide the
following information:
➢ EPA/state ID number;
➢ hazardous waste transporter registration with the state;
➢ hazardous waste transporter registration with U.S. Department of Transportation;
➢ hazardous waste endorsement from the Department of Motor Vehicles (DMV);
➢ if applicable, registration in the destination state for interstate transport;
➢ compliance with the manifest system, providing a signed copy of the waste manifest for
waste that is being shipped.
It is also important to ask the contractor for this information:
➢ a list of customers in the area with similar waste streams that they are servicing;
➢ points of contact at several other accounts for inquiries regarding their experience and
satisfaction with a specific transporter.
It is worthwhile to visit the disposal site. Things to look for are:
➢ cleanliness,
➢ well-maintained equipment and vehicles,
➢ properly contained storage areas,
63
➢ supervision of operations,
➢ safety precautions,
➢ presence and accessibility of safety and emergency response equipment,
➢ control points and spill containment possibilities,
➢ security and record keeping processes.
Since responsibility for waste stays with the generator even after the waste reaches a disposal
facility, it is important to select the waste disposal contractor carefully.
Hazardous Waste Tip
For questions about Federal hazardous waste regulations, contact the RCRA Call Center at
800-424-9346. For the hearing impaired, call TDD 800-553-7672 or visit website
https://www.epa.gov/home/epa-hotlines. The Call Center provides free technical assistance. Any
information shared will not be used for any other purpose.
Non-Regulated Waste
A waste that is not classified as hazardous, but could still be unsuitable for sewer disposal, is
known as non-regulated waste. This waste, in many cases, has to be pre-treated to meet sewer
discharge standards, depending on local rules. Some localities allow direct sewer discharge of
this material, while other areas do not allow it without treatment and permits. Non-regulated
waste is less expensive to dispose of than hazardous waste and the disposal regulations are less
stringent than for hazardous waste. This class of waste is not regulated by EPA hazardous waste
regulations. Local sewer districts and other Federal regulations control the disposal of this class
of waste. If the waste exceeds sewer discharge limits for specific materials (lead, cadmium, pH,
total suspended solids for example), pretreatment could be required before it is discharged into
the sewer system. Examples of typical Non-Regulated Waste include:
➢ Oil and water ophthalmic coolants
➢ Lens tints, UV, neutralizer
➢ Plastic and glass polish materials
➢ Many cleaning detergents
➢ Used lens fining water
Many liquid non-waste streams may be disposed of directly into the sewer system or with normal
solid waste in the dumpster, depending on local sewer discharge limitations or waste disposal
restrictions. A prudent course of action is to review the industrial waste discharge requirements
for the local area and conduct a lab analysis of waste by a local environmental testing lab. If
necessary, take the required steps to come into compliance, such as treatment of waste prior to
sewer discharge.
Checking with the company that picks up solid waste, regarding the disposal of dry-cut plastics
(CR-39, high index, polycarbonate, etc.) and solid plastic sludge from the centrifuges will help
64
avoid issues with the solid waste hauler. They might require special handling, such as double
bagging of dry-cut plastics. An example of how this may become a problem is when a dumpster
is being dumped into a trash truck, a plastic bag breaks open and covers the truck and
surrounding areas with a white plastic powder. The trash hauler might consider this a hazardous
waste and call the EPA to investigate. Also, the truck would be covered with a white power that
would create clean-up issues and ill will. Good communication is the key when working with the
trash hauler to avoid problems regarding waste disposal. Documentation of action taken and key
conversations with disposal companies could help protect the lab in the event of regulatory
action.
Treatment Of Tinting Waste
Most tinting materials are classified as a non-hazardous waste. Even if the material is non-
hazardous, in many cases, it is still not suitable for sewer disposal. The local sewer district will
review the SDS and a determination will be made by them if the material may be disposed of in
the sewer system. As previously discussed, it is strongly recommended to seek appropriate legal
advice when dealing with government officials. If it is not permitted to dispose of the waste in
the sewer system, there is the option of combining all tinting waste in a drum and disposing of it
as a non-regulated waste through a licensed contractor. The drum should be labeled as “Non-
Hazardous Tinting Waste.” This could cost up to $500 disposal per drum.
Figure 26: A waste drum used to collect unserviceable tinting chemicals. Note the two environmental
violations: (1) The top of the drum has been left open when not in use (2) The drum has no label identifying its
contents. It should be labeled as non-hazardous tinting waste.
The use of a wastewater evaporator, produced by many different companies, is a cost-effective
method to dispose of waste. Any residue may be disposed of with the solid trash, but always
check with the local waste hauler to make sure that this material may be included with the trash.
Wastewater evaporators generally cost less than $10,000 installed, and they only produce water
vapor. If more than 25 gallons of tinting waste and tint rinse water is generated weekly, the cost
of purchasing an evaporator is a practical alternative to disposing of it as non-regulated waste.
See Figure 26 above and Figure 27 below.
65
Figure 27: A wastewater evaporation system that can be used to reduce waste volume from most
water-based materials, including tints and reclaim tank water. The residue waste can be
hazardous or non-hazardous, depending on the material being evaporated.
66
Typical Laboratory Waste And Treatment Options
NOTE: This section is for informational purposes to assist in the development of an
environmental program. This material is not designed as a complete compliance program, but
rather to add information to improve existing environmental procedures. Check with local and
state environmental agencies for specific guidance. Although most waste streams are similar in
optical laboratories, an analysis for each chemical and residual waste should to be assessed. State
and local environmental regulations will vary and should be consulted to ensure environmental
compliance. Legal counsel, experienced in environmental matters, should be consulted prior to
contacting environmental regulators.
Lens Polish
Polish, water and coolants are vital to a laboratory’s production system, and how they are
managed will affect the bottom line. Today, smart laboratory managers realize that filtration in
their surfacing processes improves quality and saves money. Polish waste is normally classified
as a non-hazardous waste unless it is contaminated by lead and/or cadmium, if alloy is being
used. Some local wastewater regulations do not allow any process waste to be discharged to
sewers. Check your local requirements.
Effective filtration equipment designed for optical laboratories is a necessity to stay competitive
and work with many newer lens materials. Most laboratories use hundreds of gallons of lens
polish annually. Labs pay over $20.00 per gallon for polish and must dispose of it when it
becomes contaminated from the plastics or other foreign material produced from the polishing
operation. Contaminated plastic polish contributes to poor lens quality and increases the scrap
rate. A lab must be able to produce consistently high-quality lenses with low or no rejects to stay
profitable. Optical lens polish is a high-cost fluid that is a key part of surfacing lenses. Two good
rules are to buy high quality polish, and to filter and chill it to extend polish life. Once the polish
becomes contaminated, it generally results in rejects and machine down time to change the
polish. See Figure 28 below.
Figure 28: Lens surfacing equipment produces large volumes of non-hazardous waste, which should be
treated prior to disposal or, a permit for sewer disposal can be obtained from local authorities, depending on
local regulations.
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Chiller System
The installation of a chiller, or refrigeration system, in production operations including finers,
polishers, and generators, is important to reduce liquid temperature to approximately 65°
(degrees) F. The chiller will remove excessive heat produced during these operations to help
prevent slippage, aberrations, and deblocking of the lenses.
Filtration In Ophthalmic Production
The filtration of lens polish, and the types of filters used have changed greatly over the past
several years. Some filtration systems use bag filters that have limited polish life because they
remove the polishing medium as well as the contamination. Bag filters are not as effective as
newer technology and are ineffective and time consuming in polishing operations. The next
generation filters were pleated paper filters. These filters were more effective in removing
contaminates but could not be cleaned and reused.
The newest filter technology that is cost effective and easy to use, is the reusable nylon filter that
can be cleaned. This filter is held in a stainless-steel slotted basket that catches the heavy waste
such as blocking material and is part of a polish chilling system. These filtration units are
designed to handle as many as ten polishers.
Wet Cut Edger And Generator Coolant
Coolant is a fluid that is taken for granted in most labs. Some labs like to run water in their
edgers and generators, send it to the drain, and do not add coolant. This could be in violation of
local sewer disposal regulations, since a large amount of plastics is being emptied into the sewer
system which is not treatable by local sewage plants. An edger is the price of a nice car. It would
be unthinkable to spend $25,000 on a car, and then put tap water in the radiator, even if it is not
in a freezing climate. Anti-freeze is especially designed to protect a car’s cooling system. Using
a quality coolant will protect both edgers and generators and will have many benefits, including
extending wheel/blade life, lubrication, keeping the equipment cleaner, preventing corrosion, and
the reduction of foaming. Water-based coolants have fewer environmental concerns. Coolant
should have an antibacterial agent to inhibit bacterial growth in the coolant lines. Otherwise there
could be line blockages, as well as skin infections for employees.
Coolant is a fluid that is difficult to keep clean because of the high plastic content. Some
filtration units will work in a low volume lab, but the filters clog quickly as production increases.
The use of a centrifuge system is the best option for high volume labs. Centrifuges are widely
used in wholesale labs for both edger and generator coolant management. The self-cleaning
centrifuge system, with a chilling system, provides excellent service in the wholesale lab
environment. Centrifuges also come in manual cleaning models, but lab managers will have to
consider machine down time and the labor required to clean the unit, to make an appropriate
choice for their lab. The coolant could last up to two months, but coolant levels must be
maintained, a defoamer used, and coolant levels checked regularly.
An effective arrangement recycles edger coolant in a closed loop system with a chiller to
maintain the temperature at around 65° (degrees) F. The coolant should be checked reguarly to
prevent foaming and coolant line blockages. Many wholesale laboratories are using centrifuge
systems to recycle and clean edger coolant.
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Lens Fining Water
Another large expense for surfacing labs is the labor cost and down time required to change
plastic fining water when it becomes contaminated with plastics removed from the lenses during
fining. Some optical laboratories change this water as often as two times each day when it
becomes contaminated during the fining process. Changing filters and frequently changing water
is a labor-intensive operation. The reject rate in fining is also a problem when there is not clean,
cool water in the finers. After installation of a filtration system, substantial production time can
be saved from when no longer changing fining water, bag filters and cleaning plastics deposited
on finers.
Efficient filtration allows the water to be changed weekly or at even longer intervals, instead of
twice each day. Also, good filtration equipment saves thousands of gallons of water usage each
year, which results in lowered utility bills. Generally, sewer system regulations will not permit
plastic waste from edgers and generators to be discharged into the drain without a waste
discharge permit. This is because the waste has a high amount of suspended solids. See Figure
29 below.
Figure 29: An automatic cleaning centrifuge used to process production waste from lens generators
Waste Sewer Discharge Permitting
Most industrial waste is subject to waste permitting if it is disposed of in the sewer system. It is
the responsibility of the waste generator to ensure that any industrial waste meets the discharge
limitations of designated components. Waste has to meet waste discharge limitations for the
specific locality where the lab is located. The following are examples of waste characteristics
that are commonly monitored by sewer districts:
• Lead and Cadmium – found in some types of low-melting point alloy
• pH – the closer the waste is to 7 or neutral, the more suitable it will be for sewer
discharge
• Suspended Solids – polish, fining water, coolants, waste from edgers and generating
69
lenses
• Excessive Quantities of Petroleum Products – any nonbiodegradable cutting oil,
petroleum oil, refined petroleum products or products of mineral oil origin, in amounts
that could interfere with effective wastewater treatment or contribute to violations of
wastewater discharge permit limitations
• Corrosive Materials – any wastewater having a pH level less than 5.0 or greater than
11.0, or with other corrosive characteristics that might cause damage to pipes, pumps,
and other equipment or create a hazard for maintenance workers, would generally not be
suitable for sewer discharge
• Colorful Waste – waste from tinting operations
• Flammable Mixture – any liquid, solid or gas that might cause a fire or explosion. These
are hazardous waste. Waste containing constituents of specific concern are gasoline,
diesel fuel, kerosene, alcohol, acetone and ketones.
• Toxic Pollutants and Hazardous Substances – any wastewater containing toxic
pollutants or hazardous material
Dealing With Regulators
Many sanitation districts monitor sewer disposal at the manholes outside commercial
establishments to detect illegal dumping. Any optical lab in the U.S. is only a phone call away
from an EPA inspection. Once a lab is caught illegally dumping, the district inspectors soon
realize there may be other optical labs generating the same type of waste products. Warning
letters are usually sent out to those labs, but the regulatory agencies may also start more
aggressive monitoring of their operations.
The best defense when dealing with regulators is to have a waste management program that is in
compliance and is well documented. The procedures are similar to an OSHA inspection, but the
penalties are much higher and even time in prison is possible for violators. Since the penalties
are so high, it is vital to have an environmental attorney to consult with on these issues. Always
tell the truth, but do not volunteer information. Have documentation on waste analysis available,
if requested. Environmental procedures should be a part of work instructions for lab operations.
Waste Treatment For Optical Labs
The challenges of the treatment of optical waste have been a learning experience, and there has
been much trial and error to find a system that works and is cost effective. In some areas, much
lab waste could be able to be disposed of down the drain; but without a permit from the local
sewer district, a lab could be in violation of the law. An effective treatment method uses a
combination of waste treatment technologies that could be installed in most laboratories for less
than $20,000. This might appear to be a lot of money to treat waste that have previously been
poured down the drain, but when comparing the fines a lab could face, waste treatment costs are
a bargain.
There is a technology that uses a special clay material to treat waste which has proven to be a
positive solution for some labs. The waste treatment equipment that uses a special clay is
70
generally effective to treat coolants and polish waste from lab processes. The clay mixes with the
waste and removes suspended solids, plastic, and other chemicals. It will treat nearly all non-
hazardous waste from lab production processes, including polish, coolants, and fining water. An
environmental company can determine what is the best clay mixture for specific waste. The costs
to treat waste are pennies a gallon. The treated waste is suitable, in nearly all cases, to be
disposed of in the sewer system after the local sewer district reviews the lab analysis results.
There are companies that produce this clay treatment technology. Ringwood Environmental
Inc., www.ringwoodenvironmental.com, is an example source of this type of equipment. Also,
it is important to remember that the clay treatment technology should not be used to treat tinting
chemicals and hazardous waste.
Optical Laboratory
Waste Disposal Matrix
NOTE: The table below is for informational purposes only and is based on examples of typical
waste streams at optical labs. The information is not intended to be legal advice. The treatment
and disposal of waste is dependent on the specific chemicals that comprise the waste. Many
localities require a wastewater discharge permit and analysis before optical waste is discharged
into the sewer system. Always obtain approval from the local sewer district before discharging
either untreated or treated waste from all industrial processes. Professional guidance regarding
environmental compliance in a particular area is recommended. Review the respective Safety
Data Sheets for recommendations regarding specific chemicals used in lab operations.
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Table 7: Finishing Operations/Surfacing Operations
Waste Stream Typical Classification:
Hazardous/ Non-Hazardous
Common Waste Treatment/Options
Waste Characteristics Comments
Edger Waste
Wet Cut Plastic
Non-Hazardous Centrifuge, Filtration High-suspended solids
are a problem and
contains coolant
Centrifuges are very
effective in high capacity
operations to keep
coolant clean.
Centrifuged waste could
be suitable for sewer
disposal. Include a
chiller to remove heat
produced during the
edging process. Waste
analysis is
recommended to
determine is this waste
is suitable for sewer
disposal. Untreated
plastic waste in labs
have clogged sewer
lines.
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Table 7: Finishing Operations/Surfacing Operations, Continued
Waste Stream Typical Classification:
Hazardous/ Non-Hazardous
Common Waste Treatment/Options
Waste Characteristics Comments
Tinting Material:
• UV
• Tints
• Neutralizer
• Heat Transfer
Fluids
Non-Hazardous Could be suitable for
direct sewer disposal
if allowed by the local
sewer district. Tinting
material may be
evaporated or
disposed of through a
disposal contractor if
sewer disposal is not
permitted.
Review the SDS for
waste disposal
recommendations for
the specific chemicals
used. Dissolved tint
solids, could be
difficult to treat by
sewage treatment
plants. Some sewer
districts will not allow
tinted wastes in their
sewer systems.
Tinting materials vary widely in chemical characteristics. If tinting waste is to be disposed of in the sewer system, conduct a lab analysis to ensure it is suitable for sewer disposal and obtain permission from the local sewer district.
Surfacing Fining
Water
Non-Hazardous Direct sewer
discharge waste
treatment if required
by the local sewer
district. Treatment
systems using a clay
to treat this type of
waste has proven
effective
High suspended
plastic solids and
foaming could be a
problem
Use filtration and chiller
to extend water life. This
will also result in fewer
lens rejects.
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Table 7: Finishing Operations/Surfacing Operations, Continued
Waste Stream Typical Classification:
Hazardous/ Non-Hazardous
Common Waste Treatment/Options
Waste Characteristics Comments
Lens Polish Non-Hazardous Sewer disposal is an
option, if a permit is
obtained. If sewer
disposal is not
authorized, treat this
waste for disposal.
Treatment systems using
clay to treat this type of
waste have proven
effective
High in suspended solids
with Aluminum Oxide and
other chemicals.
Polish should be filtered
and reused to extend its
life. Installation of a
chiller system will
remove heat produced
during the polishing
operation.
Low Melting
Point Alloy
Reclaim Water (containing lead and cadmium)
Hazardous Waste Dispose and store in
compliance with
hazardous waste
regulations. Reclaim
water may be filtered
cleaned and reused to
extend its life. The sludge
and used treatment
filters are hazardous
waste if the reclaim water
is filtered for reuse.
Contact the company
providing the alloy for
possible recycling
Alloys could contain high
levels of lead and
cadmium that would
classify the waste as
hazardous.
Review the SDS to
determine if the alloy
contains lead or
cadmium. Verifying the
lead and cadmium levels
in waste by laboratory
analysis will assist in
determining if the waste
is hazardous or
nonhazardous.
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Table 7: Finishing Operations/Surfacing Operations, Continued
Waste Stream Typical Classification:
Hazardous/ Non-Hazardous
Common Waste Treatment/Options
Waste Characteristics Comments
Low Melting
Point Reclaim
Tank Sludge (containing lead and cadmium)
Hazardous Waste Dispose through a
hazardous waste
contractor or recycling
company. Do not place in
regular trash
Hazardous waste
treatment is not an option.
Lead is a high priority
pollutant with the EPA.
adding 100 lbs. of lead
(approximately 400 lbs
alloy) in any year is
reportable to EPA
Unusable/expired
Low Melting
Point Alloy (containing lead and cadmium)
Hazardous Waste Turn in to a metal recycling
company or dispose of as a
hazardous waste through a
licensed contractor.
Contains lead and cadmium Ensure compliance with all
hazardous waste disposal
regulations
Wax Blocking
Compound
Non-Hazardous Disposed with normal trash
when cold/hard.
Contains non-hazardous
material
Review the SDS for specific
information
Lead Free Low
Melting Point
Depending on
specific alloy it
could be
classified as
either a
Hazardous or
Non-Hazardous
Waste
Comply with disposal
recommendations
explained in the SDS.
Conduct lab testing to
determine if the alloy
contains lead or cadmium to
determine disposal method
of waste material.
Some so-called lead-free
alloys contain small levels
of lead.
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Table 7: Finishing Operations/Surfacing Operations, Continued
Waste Stream Typical Classification:
Hazardous/ Non-Hazardous
Common Waste Treatment/Options
Waste Characteristics Comments
Flammable
Liquid Waste (e.g., acetone, alcohol)
Hazardous Waste Keep minimum amount of
flammable materials on
hand. Treatment of
flammable waste by
burning and evaporation
is usually not acceptable
as a treatment option.
Store in proper
flameproof containers.
Store in a proper location
away from open flames
and heaters. Only use
what is necessary in a
production process.
Substitute non-
flammable materials
when possible
Generator
Coolant
Non-Hazardous Use a centrifuge to
extend the coolant life.
Direct sewer disposal is
an option in some areas.
If direct discharge is not
possible, use a
pretreatment system
prior to discharge.
Treatment systems using
clay to treat this type of
waste have proven
effective.
Contains plastic solids
and coolant. The use of
non-hazardous water
based coolant is
preferable
The use of a chiller
system, in high
production labs, is
needed to remove heat
produced during the
generating process
Solid Plastic and
Glass Waste
Non-Hazardous Normally disposed as
regular trash if the waste
does not contain
hazardous materials
Plastic waste from edger
and generator tanks and
waste from centrifuge
systems are generally
suitable to be disposed as
regular trash.
Do not dispose of liquid
wastes in dumpsters or
on the ground.
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Table 7: Finishing Operations/Surfacing Operations, Continued
Waste Stream Typical Classification:
Hazardous/ Non-Hazardous
Common Waste Treatment/Options
Waste Characteristics Comments
Caustic Cleaning
Solutions for AR
Operations
Non-Hazardous The pH could be adjusted
to make it suitable for
sewer disposal. This
could be a hazardous
operation. Dispose of as
a hazardous waste if it is
not treated for sewer
disposal.
Presents a safety hazard
of burns to skin and eyes.
Wearing splash proof
goggles, latex gloves and
other protective
equipment is necessary
See Section 2 on
Hazardous Waste
Management for detailed
information. Request
professional assistance
to set-up a treatment
system. Treated waste
must have a local permit
for disposal in the sewer
system
UV Cured
Scratch-
Resistant
Coating
Refer to the SDS
for waste
classification.
May be disposed with
normal trash if in a solid
state if the material is
non- hazardous. Review
the SDS for information
on proper disposal
requirements.
May contain solvents and
other hazardous material.
Use of a UV coating
system that produces no
waste should be
considered.
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Table 7: Finishing Operations/Surfacing Operations, Continued
Waste Stream Typical Classification: Hazardous/ Non-Hazardous
Common Waste Treatment/Options
Waste Characteristics Comments
Acid Cleaning for
AR Operations
Hazardous Waste The pH could be adjusted
with a base material to
make it suitable for
sewer disposal. This
could be a hazardous
operation.
Hazardous material that is
not suitable for sewer
disposal without having
the pH adjusted near
neutral. Generally, a
waste discharge permit
will be required
Use of technical
assistance to develop a
waste neutralization
process for the specific
acid waste is prudent.
Note: AR Stripper may
contain hydrofluoric
acid. Safe work
practices should be
included in the
procedure including
gloves and goggles.
Glass Chemical
Hardening
Chemicals
Hazardous Waste Check the SDS and
licensed hazardous
waste disposal company
for disposal procedures.
Contain potassium, or
sodium nitrate, oxidizers
which may intensify fire
Keep hot hardening
chemicals away from
plastic lenses and water.
Make sure chemicals are
cold before disposal.
Check gloves and
aprons and make sure
they do not contain
asbestos.
78
Summary
After review of this brief summary of EPA regulations, it should be clear that it is in a lab’s best
interest to eliminate hazardous waste whenever possible. This will limit environmental liability,
reduce costs and protect employees from working with hazardous material. Optical technology has
advanced greatly over the past several years and systems are available for fabricating eyewear that
will reduce or eliminate hazardous waste in a lab. Lab purchasing agents should make it known to
suppliers that the safety and environmental characteristics of their products will be considered as part
of the purchasing decision. This will be an incentive for the suppliers to incorporate these features
into their products. It is always prudent to review the SDS for disposal options of chemical waste. A
lab analysis and professional environmental assistance could be necessary to determine proper
disposal of waste produced by any production processes.
Disclaimer
This document is designed as an overview of the federal requirements for hazardous waste
management and is not designed to be legal advice. Many states have their own hazardous waste
regulations based on the federal regulations. In some of these states, the requirements are the same as
the federal standards. Other states, however, have developed more stringent requirements than the
federal program. If this is the case, a lab must comply with the state regulations. Review of waste
management practices by an environmental professional knowledgeable of state and local regulations
is recommended. For the address or phone number for state agencies, contact the RCRA Call Center
at 800-424-9346. Many states have programs designed to assist businesses to comply with
environmental regulations. In most cases, this is a free service. Consultation with your attorney is
prudent before arranging such a visit to avoid any regulatory action as a result of the visit.