Regulatory Affairs ManualSeries 100
Waste Management Compliance Procedure Program 105.01
Appendix 5:
Fisher Scientific
1999-2000
Table of Contents
Section 1
Purpose4
Program Goal4
Course Objectives5
Management Policy6
Outline7
Section 2
Introduction/Overview11
General Information12
Regulations14
Recordkeeping15
Reporting16
Determining If a Waste Is Hazardous16
Material Safety Data Sheets17
Types of Generators18
Inspections18
On-Site Management Requirements19
Container Inspection19
Waste Segregation19
Non-Hazardous20
“Empty” Containers20
Labeling, Marking and Use of Placards20
EPA Markings20
DOT labels, markings, placards21
DOT Hazardous Materials Table21
Transporting Hazardous Waste22
Reportable Quantities22
Land Disposal Restriction22
Manifests23
Prevention & Preparedness24
Protecting Your Health & Safety24
Personal Protective Equipment24
Procedures & Compliance26
Procedures26
Emergency Procedures27
Training27
Who needs trained and to what level27
Types of training28
Training Obligations29
Small Quantity Generators29
Administration29
Conclusion29
Section 3
Updating Written plan30
Appendices
Appendix A
Traps Trainer’s Fall Into
Pre-test
Answer sheet for Pre-test
Post-test
Answer sheet for Post-test
Appendix B
Generator Compliance Training Outline
Instructor’s Manual (Power Point)
Participant’s Manual (Hand out)
Appendix C
Example Job Classification and Training Recommendation
Training Documentation Form (for files)
Job Description Sample and Form (for files)
Appendix D
Instructional Materials
Sample MSDS
Sample Manifest
Sample Hazardous Materials labels
Sample Placards
MSDS Employee Information
SECTION 1
Forward
Sickness, injuries, and death can result when employees mishandle or improperly handle hazardous wastes. All employees who work with hazardous wastes are required to be provided with training (presently employed and recently hired at Fisher Scientific).
The instructor’s manual was developed to permit Fisher Scientific to conduct a Hazardous Waste Management Training Program that complies with both the law and Fisher Scientific’s policies. The skills and knowledge which this training provides to our employees will ensure that they can handle hazardous waste properly without the risk of injury, illness, and/or incident.
Purpose of Training on Hazardous Waste Management
The specifically trained employees at Fisher Scientific are the only individuals who should handle hazardous waste. If the waste is not handled and disposed of properly there may be disastrous consequences. The employees may be injured or killed, the community may be affected, and the environment may be irreversibly damaged.
The training program will assist the employee to better understand the risks of working with hazardous waste. The ways to protect themselves from illness, injury, damage to the environment, and what to do in the event of a leak or spill. Additionally, the employee will understand the laws regulating hazardous wastes and the management of hazardous waste.
Goals of Hazardous Waste Management Training Program
The goal of this training program is to explain the basic regulations and precautions governing hazardous waste management, why it is important to follow these regulations for both the company and the employee, how to follow the regulations, and who is affected by each regulation.
This training program has been designed to cover the information and skills necessary to ensure that employees know how to identify hazards, follow the proper protocol for handling those hazards, and the most appropriate way of protecting themselves from the hazards.
Objectives of Hazardous Waste Training Program
The objectives of this training program are to train participants in the following:
Recognizing the laws and regulations involved in hazardous waste management with 100% accuracy
Being able to identify hazardous waste by utilizing MSDSs, labels, manifests,
DOT (labels, markings, placards, and hazardous materials table) with 100% accuracy
Handling the hazardous wastes in a safe and effective manner (personal protective
equipment) with 100% accuracy
Trainees will be able to follow precautions with 100% accuracy
Trainees will be able to review the paperwork needed to assure that the hazardous waste arrives at its assigned destination with 100% accuracy
SEE POLICY 105 - WASTE MANAGEMENT POLICY
Hazardous Waste Management Outline
A.Purpose
The purpose of this program is to establish Hazardous Waste Management procedures to prevent unintended releases, illness or injuries which may occur when an employee is handling hazardous waste. It is to be utilized to ensure that only trained employees handle hazardous waste, and that these employees are aware of the hazards that the wastes may contain and how he/she can best protect themselves, their co-workers, and the environment.
B.Responsibility
The responsibility of each level of management has been outlined in the “Waste Management Policy” (Policy 105). Additionally, once trained (as indicated by the “Record of ESH Training” forms) all employees (new and veteran) are responsible to attend all training and updating of training, also they are responsible to be aware of the hazards (by reading the labels, MSDS, and all additional information) and protect themselves to the best of their capability.
C.Welcome
Welcome the new employees. Introduction of instructors, what the training is covering that day and why. Attempt to create comfort with training material, also understanding the importance of safety training particularly training in Hazardous Waste Management.
D.Introduction
An explanation of what will be contained in Hazardous Waste Management training and why it should be important to you as an employee. At this point the actual training will begin. The entire presentation will be on PowerPoint and can be provided on overheads. All the trainees will be given a booklet to follow along and take notes when necessary.
E.RecordKeeping
Why it is important that records are stringently kept is covered here. How long and what particular records need to be kept. Reporting procedures are also covered in this segment.
F.Determining if a Waste is Hazardous
Explain the two ways a waste is determined to be a hazardous waste. Gives the characteristics of hazardous waste in accordance with the EPA. Describe what the listed wastes are. Reveals what is contained on an MSDS, also what is on a manifest and how to use both, in addition DOT markings, labels, and placards. Also the DOT’s hazardous materials table and it’s implications are included.
G.Types of Generators
A clarification on the different type of generators and how they are classified: Large Quantity Generators, Small Quantity Generators, and Conditionally Exempt Small Quantity Generators. The inspection requirements that are to be followed, the inspection schedule, and the records are included in this section.
H.On-site Management
It is at this point that the on-site accumulation of hazardous waste is discussed; both the Satellite Accumulation Area and the Hazardous Waste Storage Area. The inspection of containers. The importance of waste segregation due to incompatibles is explained. The procedures dealing with non-hazardous waste, and “Empty” containers are explained.
I.Transportation
The DOT requirements must be implemented once a waste is being prepared for off-site shipment (labeling, marking, and container standards). What are reportable quantities and when do they apply to a shipment or spill. Finally, land disposal restrictions are examined in this section.
J.Prevention and Preparedness
Everything from generators to contingency plans are covered here including a contingency plan review, and the responsibilities of the emergency coordinator. Additionally, it explains the best way to protect yourself and your co-workers especially with the use of personal protective equipment. Procedures and emergency procedures are included.
K. Employee Information and Training
Who, why, when, and to what extent should the employees at our facilities be trained in Hazardous Waste Disposal? Those questions and many more are covered in the training session of our program.
L.Conclusion
An overview of training the employees received today.
SECTION 2
Introduction
Training is the key to the employee’s success and safety while dealing with hazardous wastes. This is a very serious issue. The employee’s undivided attention is required so that they may learn as much of the presentation material as they can. They need to be aware of what hazardous wastes they may come into contact with, and how to protect themselves and the environment. The environment and the employee’s good health, may depend on how much they learn from Fisher Scientific’s training program.
We are aware of the importance of following safety precautions when we work with hazardous chemicals. But we may not realize that safety is just as important with hazardous substances that are no longer used or are produced by our work. These discarded materials may be considered hazardous wastes, and the way we handle and dispose of them can affect the health and well-being of many people.
Improper disposal of hazardous waste can create terrible long-lasting problems. These problems may affect the employee in ways they never imagined. For example, if hazardous waste is not disposed of properly it can get into the water table and affect the drinking water for their town. We have all heard or read about the Love Canal and other hazardous waste sites that take numerous years and millions of dollars to clean up. Over time, wastes often leak into the soil and water around sites. That creates a great health risk for people who live, work, play, and attend school on or near these sites. You and your children may be playing or living on contaminated soil causing health problems and future health problems you will not be aware of until it is too late. In some places the health problems were recognized to be so great people had to evacuate the homes they grew up in which held all their memories, because someone did not consider the consequences that dumping hazardous wastes would have on future generations.
Unfortunately, the hazardous waste sites we hear about were often created at a time when no one knew about the hazards of the substances they dumped. Even where hazards were known, it was believed that the wastes were safe in containers at the dump sites. At the time there were no laws restricting where waste was dumped. These hazardous wastes are now leaking into the environment, because the containers have deteriorated over time.
Today, there are no longer any excuses for careless hazardous waste dumping. We now know which wastes are hazardous and how to dispose of them without causing health risks or environmental problems. There are now laws that exist and are enforced to make sure that hazardous waste disposal is handled in a manner which will protect us and others and will not create new hazards. In this training program we will be learning about the laws and procedures we must follow to assure that hazardous waste is managed and disposed of properly and that it is handled carefully at every stage to assure its safe arrival at its final destination.
Overview
The hazardous waste regulations (Resource Conservation and Recovery Act and subsequent amendments- RCRA) require that all personnel handling hazardous waste receive classroom or on-the-job training. The training program must teach facility personnel hazardous waste management procedures. In addition, as part of the training for those individuals who are emergency responders, a review of the facility’s RCRA Contingency Plan and Chemical Spill Response Plan is required.
General Information
What is waste?
Something left over-something we no longer need and throw away. We throw most waste in the trash, and it goes to a landfill or is burned in an incinerator. However, it is dangerous and illegal to dispose of hazardous waste in this manner.
What is hazardous waste?
A waste that may cause or significantly contribute to serious illness, death, or that may pose a substantial threat to human health or the environment.
How is hazardous waste regulated?
It is regulated by the Environmental Protection Agency (EPA) the state or other governing authorities, which only allows disposal at specific sites that have special permits. These sites are designed specifically to dispose of hazardous waste in ways that will not harm people or the environment.
What properties does the EPA feel are needed to consider something a hazardous waste? (one or more are needed)
A hazardous waste:
- Contains any of several hundred chemicals specifically listed by EPA as toxic or acutely toxic
- Results from a process listed by EPA as generating hazardous waste. For
example, EPA lists a number of spent solvents as hazardous waste
- Is corrosive, it can burn the eyes, skin, or body tissue on contact. Corrosives can also corrode standard containers
- Is ignitable, it can catch fire or explode easily when exposed to heat or a spark
- Is reactive, it can catch fire, explode, or give off dangerous vapors if it comes in contact with air, water, or certain other substances
- Is toxic (poisonous), it can cause illness. Some substances are toxic if inhaled (inhalation), some if they get on the skin (absorption), and some if they are swallowed (ingestion). Some substances maybe toxic on the first exposure (acute); others cause health problems as a result of repeated exposures. Sometimes the effects show up immediately - for instance, nausea or rash; other health problems may not show up for years (chronic). Often these long-term effects are very serious - for example, organ damage, cancer or even death.
Why is hazardous waste disposal so carefully regulated?
Wastes which the EPA considers hazardous really can pose great risks to human health and the environment.
You can never, under any circumstances, dispose of hazardous waste along with the regular trash. That is as important at home as in the workplace. If, for instance, you use refinishing products or change the oil in your car, you are creating hazardous wastes. By tossing these wastes down a drain or throwing them out with your trash, you can poison the ground where you dump them or under the landfill where your trash goes. These poisons may also eventually seep into underground drinking water, putting an entire community at risk.
To help alleviate the preceding problems, many communities have special hazardous waste collection days. Trained people wearing protective equipment collect homeowners’ waste and place it in special containers for proper disposal. In addition, many local gas stations will take your used motor oil for recycling.
What are the most common forms of safe and proper disposal for hazardous waste?
Incineration: Hazardous waste can only be burned in special incinerators.
- These incinerators burn hotter than those used for other trash and hold the materials longer (i.e. more efficiently)
- They also clean any contaminated air or water produced by the burning process.
- Operators of these incinerators must prove they do all of this safely to receive and maintain an EPA permit.
Landfills: These are not the same landfills utilized for normal trash.
- They have liners and other protections against the spread of contamination.
- Often viewed as temporary resting places for the hazardous wastes.
- No container is likely to be able to hold waste safely forever.
Recycling: Hazardous wastes, like other forms of trash, can sometimes be recycled and reused again for other purposes.
- Due to cost and complexity of proper hazardous waste disposal, more and more companies are seeking ways to recycle their waste.
- However, recycling has to meet strict standards designed to assure that the wastes do not find their way into the environment.
Others: Scientists are working on better and safer ways to dispose of hazardous waste.
- Including experiments with bacteria that “eat” the wastes.
- Must take every precaution to assure that our disposal methods do not cause a fire or other incidents or create a risk to the environment or to human health.
Regulations
The key federal hazardous waste law is the EPA’s Resource Conservation and Recovery Act (RCRA). RCRA regulates the generation, treatment, transportation, and disposal of hazardous waste. In addition, when any hazardous material, including waste, is transported, it has to meet rules issued by the Department of Transportation (DOT).
Many of these legal requirements are the responsibility of employers, not individual workers. For example, RCRA requires employers to identify, handle, store, treat, and dispose of hazardous wastes safely and correctly. Companies must have a plan for responding to hazardous waste fires, explosions, and spills. RCRA requires employers to train everyone who works around hazardous waste to:
- Understand and follow general hazardous waste regulations
- Know how to work safely with hazardous wastes
- Know what to do in an emergency
DOT has two key regulations designed to assure safety when hazardous wastes are moved from one place to another. These rules mesh with international standards to reduce confusion when wastes move from country to country. The DOT regulations:
- Establish classifications and packing groups for hazardous waste
- Require use of special labels, markings, and placards
- Set out training requirements for anyone who is involved in any way with hazardous materials handling and transport
Operating Procedures
TheFisher Scientific Waste Management Compliance Guide (Program 105.01) describes the requirements for generators to be in compliance with applicable RCRA regulations. Throughout this training, references will be made to acquaint the employee with those sections of the manual.
RecordKeeping
Many records and documents need to be kept on file for numerous years. For instance, a copy of all manifests, copies of test results, waste analysis, or other determinations in accordance to 40 CFR 262.11 must be kept on file for three years. Additionally, biennial reports and exception reports must also be kept for three years. However, land ban forms (LBF) must be kept for a period of five years.
Other documents that must be maintained on site include: inspection forms, contingency plan, waste minimization plan, facility application for EPA identification number and the EPA response, emergency contracts and agreements with local hospitals, fire departments, contractors, and manifest tracking sheets.