The Sentinel EventThe Sentinel Event

During a routine annual hazardous waste During a routine annual hazardous waste management inspection by the management inspection by the Hazardous Waste Section of NC DENR, Hazardous Waste Section of NC DENR, violations in laboratory practices were violations in laboratory practices were identified, citations were issued, and an identified, citations were issued, and an administrative penalty was assessed.administrative penalty was assessed. As part of the Consent Order, Duke As part of the Consent Order, Duke agreed to develop a laboratory agreed to develop a laboratory chemical waste management practice.chemical waste management practice.

The Sentinel EventThe Sentinel EventDuring the inspection, the following violations were During the inspection, the following violations were

noted:noted: Duke failed to make waste determinations for waste Duke failed to make waste determinations for waste

generated in some labs.generated in some labs. Waste was stored in a defective container and not Waste was stored in a defective container and not

transferred to a container in good condition.transferred to a container in good condition. Certain wastes were not properly marked with the words Certain wastes were not properly marked with the words

“Hazardous Waste” or “Waste Chemical”.“Hazardous Waste” or “Waste Chemical”. Wastes were stored in open containers.Wastes were stored in open containers.

This informational presentation will familiarize you with the This informational presentation will familiarize you with the requirements of the Laboratory Chemical Waste requirements of the Laboratory Chemical Waste Management Practice. Once you have read through the Management Practice. Once you have read through the practice, please contact OESO EP with any question you practice, please contact OESO EP with any question you may have.may have.

Laboratory Chemical Waste Laboratory Chemical Waste Management PracticesManagement Practices

Occupational and Environmental Occupational and Environmental Safety OfficeSafety Office

Environmental Programs DivisionEnvironmental Programs Division

Purpose / BackgroundPurpose / Background

Research, teaching and clinical Research, teaching and clinical laboratories produce a variety of waste laboratories produce a variety of waste chemicals that may be subject to chemicals that may be subject to regulatory management standards. regulatory management standards.

If improperly managed in the laboratory, If improperly managed in the laboratory, waste chemicals could pose a risk to waste chemicals could pose a risk to human health and the environment.human health and the environment.

Purpose / Background Purpose / Background

Laboratory chemical wastes are Laboratory chemical wastes are regulatedregulated by the Environmental Protection Agency by the Environmental Protection Agency and the North Carolina Department of and the North Carolina Department of Environment and Natural ResourcesEnvironment and Natural Resources

The Occupational and Environmental The Occupational and Environmental Safety office is tasked with ensuring that Safety office is tasked with ensuring that all laboratories understand and comply all laboratories understand and comply with these regulationswith these regulations

ScopeScope

This practice applies to This practice applies to allall teaching, teaching, research, and clinical laboratories research, and clinical laboratories at Duke University, Duke at Duke University, Duke University Medical Center, and University Medical Center, and Duke University Health SystemsDuke University Health Systems

ProceduresProcedures

Any laboratory that will generate waste Any laboratory that will generate waste chemicals chemicals mustmust obtain a generator ID by obtain a generator ID by registering with the Occupational and registering with the Occupational and Environmental Safety Office Environmental Environmental Safety Office Environmental Programs Division (OESO EP) prior to beginning Programs Division (OESO EP) prior to beginning processes that will generate chemical wasteprocesses that will generate chemical waste

Waste chemicals generated in a laboratory Waste chemicals generated in a laboratory mustmust be managed in accordance with the following be managed in accordance with the following proceduresprocedures

Collection of Waste ChemicalsCollection of Waste Chemicals

Waste chemicals collected either during Waste chemicals collected either during the operation of a process or otherwise the operation of a process or otherwise accumulated in the laboratory accumulated in the laboratory must must be be placed into containers that are in good placed into containers that are in good condition, compatible with the contents, condition, compatible with the contents, and able to contain the contents without and able to contain the contents without leaking.leaking.

Container Labeling and MarkingContainer Labeling and Marking

Container ContentsContainer ContentsContainers used to collect waste chemicals Containers used to collect waste chemicals

mustmust be clearly marked with the words be clearly marked with the words “Waste (name of chemical)” “Waste (name of chemical)”

Containers Containers mustmust be marked or labeled at the be marked or labeled at the time waste is first placed in the containertime waste is first placed in the container

OESO EP will provide pre-printed labels for OESO EP will provide pre-printed labels for laboratorieslaboratories

Container Labeling and MarkingContainer Labeling and Marking

Waste Collection DatesWaste Collection DatesContainers Containers mustmust have an “open date” listed have an “open date” listed

on the container label, and when full or no on the container label, and when full or no longer being filled, a “fill date”.longer being filled, a “fill date”.

The “open date” is the earliest date that waste The “open date” is the earliest date that waste is placed in the container whereas the “fill is placed in the container whereas the “fill date” is the date that the container is filled and date” is the date that the container is filled and will no longer be used to accumulate waste.will no longer be used to accumulate waste.

Container Labeling and MarkingContainer Labeling and Marking

Unused, unwanted, or unopened Unused, unwanted, or unopened chemicals that are to be discarded chemicals that are to be discarded mustmust be labeled with the words “Waste (name of be labeled with the words “Waste (name of chemical) and the date that they were chemical) and the date that they were determined to be unwanted or unusable.determined to be unwanted or unusable.

Container Labeling and MarkingContainer Labeling and Marking

Small or odd shaped containers that are Small or odd shaped containers that are difficult to place a label on difficult to place a label on mustmust be placed be placed in a larger sealed container and labeled on in a larger sealed container and labeled on the outside. (zip-lock bags, plastic the outside. (zip-lock bags, plastic containers, etc.)containers, etc.)

Unknown ChemicalsUnknown Chemicals

Containers holding chemicals that cannot Containers holding chemicals that cannot be identified by chemical name, chemical be identified by chemical name, chemical constituents, or process generating the constituents, or process generating the waste waste mustmust be labeled as “Waste be labeled as “Waste Unknown” with the date that they are Unknown” with the date that they are considered to be no longer needed.considered to be no longer needed.

Removal of Unknown ChemicalsRemoval of Unknown Chemicals

Chemicals identified by the laboratory as Chemicals identified by the laboratory as an unknown an unknown mustmust be removed from the be removed from the laboratory no later than 30 days after laboratory no later than 30 days after being designated as no longer needed.being designated as no longer needed.

Container ManagementContainer Management

Waste containers Waste containers mustmust be compatible with be compatible with their contents.their contents.

Waste containers must be kept closed Waste containers must be kept closed except when adding or removing wastes.except when adding or removing wastes.

Waste containers should be kept clean Waste containers should be kept clean with no visible contamination on the with no visible contamination on the outside of the container.outside of the container.

Waste labels and markings Waste labels and markings mustmust be be readable and not defaced.readable and not defaced.

Container ManagementContainer Management

Areas where waste chemicals are accumulated Areas where waste chemicals are accumulated mustmust have secondary containment sufficient to have secondary containment sufficient to collect any incidental spills from container collect any incidental spills from container failure.failure.

Waste containers should not be overfilled. Full Waste containers should not be overfilled. Full containers must have at least a 10% headspace containers must have at least a 10% headspace to allow for expansion.to allow for expansion.

Filled waste containers Filled waste containers mustmust be stored in a be stored in a secure area under the control of the operatorsecure area under the control of the operator

Improper labeling and storage of a waste chemicalImproper labeling and storage of a waste chemical

Open when not in use/funnel left in container

Unlabeled container

No secondary containment

Correct labeling and storage of a waste chemicalCorrect labeling and storage of a waste chemical

Container ManagementContainer Management

Wastes collected during processes:Wastes collected during processes:Wastes that are collected as part of a Wastes that are collected as part of a

continuous process (such as HPLC wastes) continuous process (such as HPLC wastes) mustmust be collected via tubes that are fed be collected via tubes that are fed through a cap or other container closure to through a cap or other container closure to insure that the container is kept closed. This insure that the container is kept closed. This closure closure mustmust be a positive closing lid. be a positive closing lid. Parrafilm and similar closures will not be Parrafilm and similar closures will not be acceptable. acceptable.

Improper labeling and storage of a HPLC waste Improper labeling and storage of a HPLC waste chemicalchemical

Open Container

Unlabeled container

No secondary containment

Correct labeling and storage of a HPLC waste chemicalCorrect labeling and storage of a HPLC waste chemical

Container ManagementContainer Management

Containers used to collect waste Containers used to collect waste chemicals on a frequent, routine basis chemicals on a frequent, routine basis mustmust be closed when a procedure or be closed when a procedure or experiment has been completed.experiment has been completed.

EXAMPLEEXAMPLE: Containers used to collect acetone : Containers used to collect acetone washes must be kept closed except when actively washes must be kept closed except when actively adding or removing wastes from the container.adding or removing wastes from the container.

Laboratory Shutdowns or Laboratory Shutdowns or CloseoutsCloseouts

Whenever a laboratory is shut down or Whenever a laboratory is shut down or closed out the principal investigator closed out the principal investigator mustmust insure that all waste chemicals are insure that all waste chemicals are properly identified and labeled so that they properly identified and labeled so that they can be removed.can be removed.

Laboratory closeout procedures can be Laboratory closeout procedures can be found in section 5 of the Laboratory Safety found in section 5 of the Laboratory Safety Manual at: Manual at: http://www.safety.duke.edu/SafetyManuals/LabManual/index.htmhttp://www.safety.duke.edu/SafetyManuals/LabManual/index.htm

Roles and ResponsibilitiesRoles and Responsibilities

Principal Investigators, Laboratory Principal Investigators, Laboratory DirectorsDirectorsPrincipal Investigators or Laboratory Directors Principal Investigators or Laboratory Directors

are responsible for insuring that these are responsible for insuring that these practices are implemented in the laboratory. practices are implemented in the laboratory. They may choose to assign or designate a They may choose to assign or designate a laboratory waste manager to implement this laboratory waste manager to implement this practicepractice

Roles and ResponsibilitiesRoles and Responsibilities

Laboratory Waste ManagerLaboratory Waste ManagerLaboratory waste managers are responsible Laboratory waste managers are responsible

for insuring that all processes generating for insuring that all processes generating chemical wastes comply with these practices chemical wastes comply with these practices on a day to day basis.on a day to day basis.

Roles and ResponsibilitiesRoles and Responsibilities

OESO EPOESO EPOESO EP will provide support and oversight OESO EP will provide support and oversight

to the laboratories through education, training, to the laboratories through education, training, routine assessments of laboratory routine assessments of laboratory performance, and timely removal of chemical performance, and timely removal of chemical wastes from the laboratory.wastes from the laboratory.

Chemical WasteChemical Waste How do we get waste picked up?How do we get waste picked up?

First you must determine - Are you or your First you must determine - Are you or your group registered generators? group registered generators?

If no, call 684-2794, ask for chemical waste personnel If no, call 684-2794, ask for chemical waste personnel and request set up as a generator. You will receive a and request set up as a generator. You will receive a packet of information containing your generator ID packet of information containing your generator ID number, labels, barcode labels, and a waste pick up number, labels, barcode labels, and a waste pick up request form.request form.

If yes, If yes, Place one barcode label on the waste container.Place one barcode label on the waste container. Place the matching barcode label on the pick up Place the matching barcode label on the pick up

request form.request form. Fill out the chemical description and container size that Fill out the chemical description and container size that

corresponds to that barcode number.corresponds to that barcode number. Repeat the above steps for additional waste containers.Repeat the above steps for additional waste containers.

Chemical WasteChemical Waste Fax (684-2422) or email Fax (684-2422) or email

(env.programs@mc.duke.edu) the completed form (env.programs@mc.duke.edu) the completed form to OESO EP.to OESO EP.

Once OESO EP receives a request, it will be entered into Once OESO EP receives a request, it will be entered into our database and the waste will be picked up within 5 our database and the waste will be picked up within 5 business days. business days.

A member of OESO EP will contact your lab if there is a A member of OESO EP will contact your lab if there is a problem with the pick up request.problem with the pick up request.

A summary of the waste pick up A summary of the waste pick up process can be found at process can be found at OESO EP OESO EP General Guidance for Chemical Waste General Guidance for Chemical Waste PickupsPickups..

Questions / ConcernsQuestions / ConcernsA copy of the Laboratory Chemical Waste A copy of the Laboratory Chemical Waste Management Practice can be found Management Practice can be found herehere..

Any other inquiries:Any other inquiries:

Environmental Programs DivisionEnvironmental Programs DivisionBox 3914Box 3914684-2794684-2794

env.progs@mc.duke.eduenv.progs@mc.duke.eduwww.safety.duke.eduwww.safety.duke.edu