Environmental Energy Technologies Division Old Chemical Disposal Self-Assessment
Environmental Energy Technologies Division
2012 Self-Assessment Project 2
A Self-Assessment of the EETD Old Chemical Disposal Project
July 9, 2012
Approved by:
______
Ashok Gadgil, Division Director Date
Introduction
This self-assessment report describes an old chemical disposal project conducted in 9 EETD lab areas and what improvements can be made for future implementation. Over a number of years, various chemicals have accumulated in EETD lab areas. These old chemical containers take up valuable lab space. They can also present unnecessary potential fire and health hazards in the workplace. The quantities of old chemical containers that require proper disposal can present a very time consuming task for lab owners in order to prepare required labels and paperwork. Some chemical containers are also inherited when a lab researcher retires and vacates a lab space. EHS Division’s Waste Management Group initiated a process to streamline the collection and disposal of old chemicals that had previously been successful in another division. EETD took steps to use the same process for the 9 EETD lab areas. As a result, 558 chemical containers were removed and properly disposed.
Requirements
Hazardous materials storage and hazardous waste disposal requirements are described in the following documents:
- LBNL Chemical Hygiene and Safety Plan- “Chemical Procurement, Transportation, and Inventory”
- LBNL Pub-3093- “Waste Generator Requirements”
Hazardous materials are stored in designated hazardous materials storage cabinets. Liquid chemicals are secondarily contained for potential spills. They are also segregated by hazard class for chemical compatibility. Each hazardous materials container is assigned a bar code and entered into LBNL’s Chemical Management System (CMS) for inventory tracking.
When a hazardous material is no longer wanted, it is identified as hazardous waste with the attachment of a completed “hazardous waste” label and is then placed into a designated “Satellite Accumulation Area” (SAA) located inside each lab area. Hazardous wastes may be stored for up to 275 days in a SAA before they must be picked-up and properly disposed by the LBNL Waste Management Group. Each SAA is inspected by the EETD Safety Manager on a quarterly basis. This also includes spot checks of chemical storage cabinets and fume hoods.
All EETD personnel who handle hazardous materials in the wet lab areas must complete EHS0348 “Chemical Hygiene and Safety” training. This ensures employees are aware of hazardous materials hazards, use of personal protective equipment, and chemical storage requirements. EETD personnel who place hazardous wastes into the SAA must also complete EHS0604 “Hazardous Waste Generator” training. This ensures employees are aware of hazardous waste labeling, packaging, and waste requisition requirements.
Methodology
The following methodology was used to conduct this old chemical disposal project self assessment:
1. Nine EETD lab areas were identified as areas that needed assistance in removing unwanted chemicals. The Principal Investigators (PI) in charge of these lab areas were contacted by the EETD Safety Manager to gain support in identifying old chemicals that needed removal. The EETD lab areas included in this project were:
· Building 62 Room 218 (J. Kerr)
· Building 62 Room 320 (T. Richardson)
· Building 64 Room 115 (H. Goudy)
· Building 70 Room 108 (R. Kostecki)
· Building 70 Room 218/299 (V. Battaglia)
· Building 70 Room 226 (G. Liu)
· Building 70 Room 249 (S. Mao)
· Building 70 Room 269 (S. Chang/G. Liu)
· Building 70 Room 293 (D. Lucas)
2. A team consisting of Ron Scholtz (EETD Safety Manager), Dan Best (EHS Division Industrial Hygienist), and Howard Hansen (EHS Division Waste Generator Assistant) met with each lab area PI and old chemicals were pulled from lab area storage cabinets. An orange “dot” sticker was affixed to each container for identification. The old chemicals were then logged on to a spreadsheet. The spreadsheet contained information regarding the chemical name, Chemical Abstract System (CAS) number, hazard class, LBNL Chemical Management System (CMS) bar code number, container size, and contents amount.
3. Each spreadsheet was submitted to Howard Hansen of the Waste Management Group for evaluation and compilation.
4. LBNL Waste Management Group’s Operation Team staff collected the chemicals from each lab and transferred them to the centralized staging area at the Hazardous Waste Handling Facility on the day of shipment. The Waste Management Group’s hazardous waste disposal subcontractor was tasked with segregating and packaging the chemicals per applicable Department of Transportation (DOT) requirements and approved waste disposal profiles for final disposal at approved and permitted Treatment Storage and Disposal Facilities (TSDF).
The scope of this project only applied to the following:
1. Old chemicals in their original primary containers with intact identification labels.
The following materials were excluded from the scope of this project:
1. Radioactive, bio hazardous, or compressed gas cylinders.
2. Containers that had contents that could not be identified and are considered “unknown”.
3. Waste streams normally generated by laboratory research activities were not collected as part of this project. This includes mixed solvent wastes, mixed acid wastes, contaminated gloves/wipes, spent pump oil, etc.
The following LBNL personnel participated in this project:
· Ron Scholtz- EETD Division Safety Manager
· Dan Best- EHS Division Industrial Hygienist
· Howard Hansen- Waste Management Group Generator Assistant
· Roshan Shadlou- Hazardous Waste Handling Facility Operations Team Leader
· Nancy Rothermich- Waste Management Group Leader
· Mark Lasartemay- Waste Management Group Generator Assistant
Summary of Findings, Observations and Noteworthy Practices
Old Chemical Collection
A total of 558 chemical containers were collected from the 9 EETD lab areas over a several month period. These are summarized in Attachment 1 of this self-assessment report. The old chemicals were inventoried and organized by a team consisting of Ron Scholtz, Dan Best, and Howard Hansen. The following is a summary of some the observations made during this portion of the project:
Noteworthy Practices:
- The process of identifying and logging the various containers was greatly streamlined by having more than one person working in a lab area at a time. This resulted in a “buddy system” to ensure this non-routine activity was performed safely.
- The PIs were very supportive in identifying old chemicals. The number of containers identified was much greater than originally anticipated. Other lab areas have already expressed an interest in similar assistance.
- There were a number of containers that were difficult to identify due to a lack of a label, aging or poor labeling practices. It took further investigation by the team to figure out what was in the container. In some cases, the contents could not be identified, remained an “unknown” and could not be disposed as part of this project.
Suggestions:
- Individual spreadsheets were used for tracking old chemicals in each lab area. Some spreadsheets also included tabs based on the different hazard classes. This made tracking of the different spreadsheets difficult and created confusion for the team. In the future, a single spreadsheet for all lab areas and hazard classes should be used. Tabs and other information logging formats that can allow chemicals to be overlooked should be avoided.
- There is a need for additional assistance in removing inherited sample containers containing unknown liquids as well as assistance in removing some old lecture-size gas cylinders.
Findings:
- Several very old containers of peroxide forming chemicals were identified. These are potentially reactive chemicals with a limited shelf life. Some containers had a start date indicated but were a number of years old. Other containers did not have a start date indicated and/or the required “Peroxide Former” warning label affixed. The labeling and testing requirements for storage of peroxide forming chemicals must be further emphasized to the lab area users. (Corrective Action Tracking System Item #9162)
- Discrepancies between the actual inventories and the CMS system were noted. Some containers did not have a CMS bar code label affixed and therefore were not entered into the lab area chemical inventory. In addition, a larger number of containers that had CMS bar code labels affixed were not found in the CMS system inventory or had already been given a “disposed” status. An evaluation of each lab area needs to be performed to determine the level of compliance with the Chemical Management System. If the CMS system is used properly, unwanted chemicals could simply have their bar codes scanned and an inventory spreadsheet quickly generated. (Corrrective Action Tracking System Item #9165)
Lab Area Principal Investigator Survey
A Goggle Documents “Old Chemical Disposal Project” survey was sent to all 9 EETD Principal Investigators who had lab areas involved in this project. There were a total of 8 responses. The lines of inquiry asked in the survey are summarized as follows:
1. What would you have done with your old chemicals if this project were not implemented? Please explain.
2. Were any old chemicals collected inherited from previous lab owners? If yes, approximately what percentage of the total was inherited?
3. How often do you normally clean out your chemical storage areas of unwanted chemicals? Please explain.
4. What did you like about this special disposal project? Please explain.
5. What would you like to see improved on future chemical disposal projects? Please explain.
6. If there were another unwanted chemical disposal project, would you be interested in participating again?
7. Do you have any unknown chemicals or samples that require disposal? If yes, approximately how many containers?
8. If you were to participate in the future, would you be willing to complete a spreadsheet summarizing each chemical container requiring disposal?
9. Are there any other comments about this special disposal project that you would like to add?
The survey results can be summarized as follows:
Noteworthy Practices:
- We received very positive feedback that this project was helpful to the researchers. It gave them an incentive to remove old chemicals from their areas with little time spent or direct cost incurred.
- Survey respondents indicated that anywhere from 50-100% of the unwanted chemicals disposed were inherited or “donated” from previous researchers.
- A number of the survey respondents indicated they never or very infrequently perform chemical inventory clean-outs. The main reason given was the amount of time needed in order to label and complete the requisition for each item. The amount of effort needed seems very important.
- Almost all respondents stated that if we did not provide this service, they probably would have kept most of the containers because “there was a chance we may need one of them some day”.
- All 8 of the respondents indicated that they have or will have additional unwanted chemicals for disposal in the future. Some also expressed a need for assistance with disposing some unknown samples.
Suggestions:
- The EETD Safety Manager needs to develop and emphasize chemical disposal requirements for retiring PIs who are vacating lab spaces. The process should ensure that unwanted chemicals are not left behind for another researcher to “inherit”.
- Additional EETD lab areas require similar disposal efforts. In addition, several chemical storage closets contain some old chemicals left by previous researchers.
- Old chemical clean-outs of all EETD lab spaces should be offered on at least an annual basis to ensure that inventories are kept at the levels actually needed.
Findings:
- A follow-up EETD chemical clean-out is needed to address lab and storage areas not included in this self-assessment project. (Corrective Action Tracking System Item #9167)
Waste Management Group Feedback
A post-project meeting was held with all project participants in order to identify what worked and what needed improvement. The results of this meeting are as follows:
Noteworthy Practices:
- It was much more efficient having the Waste Management Group pick-up the containers from each lab area and transferring them to a centralized location such as the Hazardous Waste Handling Facility for consolidation rather than having the waste disposal subcontractor pack the chemicals directly inside each lab.
- It was essential that a representative from EETD be present to assist the Waste Management Group when entering labs to pick-up the old chemical containers.
Suggestions:
- Future old chemical disposal campaigns need to be planned with a 3-month time frame in mind. The first month is given for collection and inventory of old chemicals with a definite cut-off date established for submittal of a single spreadsheet for each division. The second month is needed for review and correction of the submitted spreadsheets. The third month is needed for scheduling and organizing the disposal subcontractor.
- The multiple submittals of spreadsheets to the Waste Management Group created some confusion. In addition, some information on the spreadsheets was not clear, incomplete, or misspelled. A single spreadsheet listing all old chemicals for all lab areas should be submitted only once to the Waste Management Group just prior to the cut-off date.
- A firm cut-off date needs to be established for submittals of unwanted chemical lists to the Waste Management Group. No last minute additions to the list can be allowed. Any chemicals picked-up that are not on the submitted list will be returned.
- It would be helpful if the Waste Management Group’s Operation Staff can visit the affected laboratories a few days in advance of the transfer to have time to familiarize themselves with the location of the chemicals and possibly perform an inventory check of what needs to be picked-up. Having a division representative present during this process is also extremely helpful.
- The old chemical containers were originally segregated into containment trays inside each lab area and left separate from the other chemicals that will remain for use. It took three months to organize each lab, review each log sheet submitted, and have the waste disposal vendor organize their effort. As a result, the trays of unwanted chemicals remained in the labs for longer than originally planned by EETD. In the future, the old chemical containers should be clearly identified, but left in their original storage location until just before pick-up.
- Organize an old chemical disposal campaign on a regular basis. However, there needs to be enough containers in each campaign to make the project cost effective for the disposal subcontractor. Current subcontractor pricing is based on a fixed cost per pound based on net waste weight (only the primary container weight). The cutoff point that has been suggested by the subcontractor based on current pricing is 700 pounds. Coordination among all divisions will help in reaching this minimum.