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By Jeffrey C. Camplin
February 2006 -
Material Handling Article Use Policy
Hazardous material management is a rising priority in many institutional and commercial facilities. As federal scrutiny grows along with public awareness of the potential problems these materials present, the pressure grows on managers to better understand the hazardous waste their operations generate.
The regulatory environment also is heating up. Under federal and state environmental regulations, all wastes generated from a facility must be evaluated to see if they are hazardous. Each state also has specific regulations on handling and disposing of hazardous waste.
A manager’s ability to comply with hazardous waste regulations depends on an understanding of what constitutes a hazardous waste.
For a waste to be deemed hazardous, the U.S. Environmental Protection Agency (EPA) must list it under the Resource Conservation and Recovery Act (RCRA) regulations — i.e., listed wastes. If a waste does not appear on one of these lists, it still might be a hazardous waste if it has one or more of the following characteristics:
The toxicity characteristic leaching procedure (TCLP) is a standard test used to determine the toxicity of a solid waste. The test is based on the ability of a waste to leach specific metals and chemicals. If the leachate contains more than the regulatory level for a specific chemical, the material is considered a hazardous waste.
The EPA lists a waste because it has been shown to be harmful to health and the environment when not managed properly. The EPA regulations — 40 CFR Part 261 — list more than 400 hazardous wastes. But even if a waste is not found on any of these federal lists, it still might be on a state hazardous waste list, which managers can review at www.epa.gov/epawaste/laws-regs/state/index.htm.
As of August 2005, mercury-containing equipment is a new universal waste category. Mercury is used in several types of instruments, including switches, barometers, meters, temperature gauges, pressure gauges, and sprinkler-system contacts. Among the common types of mercury-containing waste are these:
For more common hazardous wastes, see the accompanying article below.
Universal waste regulations have streamlined hazardous waste management standards for the federal universal wastes, including batteries, pesticides, thermostats and lamps. Universal waste regulations govern the collection and management of these widely generated materials. The regulations facilitate the environmentally sound collection, and they increase the proper recycling or treatment of universal wastes.
They facilitate programs developed to reduce the quantity of these wastes in municipal solid waste landfills or combustors. They also ensure that universal wastes subject go to appropriate treatment or recycling facilities.
States can modify the universal waste rule and add additional universal waste in individual state regulations, so managers should check with the state for the exact applicable regulations. To review state-specific universal waste regulations, managers can access the web site of the U.S. Environmental Protection Agency (EPA) www.epa.gov/epaoswer/hazwaste/id/univwast/uwsum.htm.
Small and large facilities that generate hazardous wastes in the universal waste categories can use the more streamlined requirements under the universal waste rule.
The universal waste rule eases the regulatory burden on facilities that generate these wastes. Facilities that produce less than 100 kilograms — 220 pounds — of universal wastes per month can handle their universal wastes under the universal waste regulations or as a conditionally exempt small quantity generator.
Hazardous waste management begins with proper material labeling. New technologies allow managers to easily print compliant labels, including warnings and symbols from their computers. Manufactur-ers also have introduced advances in areas of spill control and fire protection.
Special considerations for hazardous wastes include ensuring adequate ventilation through the use of hoods or localized exhaust systems. Managers also should be sure to ground and bond containers during transfer of flammable liquids to prevent static sparking.
Employees should not smoke, eat or drink in waste storage areas, and they should not mix incompatible chemicals or store incompatible chemicals together unless a separate, secondary containment is provided.
Managers also need to remember that many chemicals are hazardous in more than one manner. For example, concentrated hydrogen peroxide is toxic, corrosive, flammable, and reactive, and it is a strong oxidizer. Employees should read the material safety data sheet (MSDS) for hazard information on all chemicals used in a facility.
Finally, managers will find significant developments in the tools used in handling and transporting hazardous wastes. These developments include transportation carts with built-in secondary spill control, various sizes of spill-control funnels, and spill kits specifically designed for vehicles and shop areas.
The easiest and most cost-effective way of managing any waste is to avoid generating it in the first place. Managers can decrease the amount of hazardous waste their organizations produce by developing a few good habits. These procedures generally save organizations money, and they prevent accidents and waste. To help reduce the amount of waste an organization generates, managers can consider the following practices:
Hazardous wastes require careful management within a facility. Identifying hazardous waste streams, minimizing or eliminating these streams, and proper labeling and handling of these materials will allow managers to address hazardous wastes in a safe, efficient and economical manner.
Jeffery C. Camplin, CSP, CPEA is president of Camplin Environmental Services Inc. in Rosemont, Ill. He is the administrator of the environmental practice specialty of the American Society of Safety Engineers, where he provides environmental support to its 30,000 safety professional members.
Institutional and commercial facilities generate a host of common hazardous wastes. The activities listed below often generate hazardous wastes, but some activities taking place in facilities generate hazardous wastes that are not listed here.
Among the activities are these:
— Jeffrey C. Camplin