Chemical Waste Compliance Inspection Follow-Up
In the Summer Edition of Lab Notes, we discussed the findings of a June 4th chemical waste compliance inspection conducted on campus by the Indiana Department of Environmental Management (IDEM).
The inspection brought to light a number of compliance deficiencies – most notably in campus laboratories and most notably involving unlabeled waste dump containers or waste containers left open after having had waste added.
In response to the inspection findings, EHS initiated the following corrective measures:
Mandatory refresher training for all staff in the various campus departments found to be out of compliance.
Weekly compliance inspections for all of the departmental labs involved (83 laboratories in total).
Referral to the Laboratory Safety Committee for consideration. Subsequently, all 83 laboratories were placed on a 6 month probation period and were subject to monthly compliance inspections. Laboratories found with any chemical waste violations were issued a laboratory safety grade of an “F” with an automatic referral to the Department Chair and the School Dean.
Inadequately labeled wastes which could not readily be identified by lab staff (due to the lack of labeling) were submitted for analysis by a contract laboratory. The charges for the laboratory analysis were referred back to the campus department which produced the waste. In one instance, the laboratory charges were in excess of $2,000.00.
Concurrent with these activities, EHS submitted a formal response to IDEM detailing the specific corrective measures undertaken by the University as well as initiatives to prevent similar violations in the future. On September 13th, IDEM forwarded a response to the University indicating that the corrective measures were sufficient to return the campus to a state of compliance.
Countless hours have been devoted over the past 6 months by EHS and the various departments involved addressing the concerns noted during the inspection. Unfortunately, the story does not end with IDEM’s response of September 13th.
Due to the fact that this summer’s inspection resulted in the issuance in a formal Violation Letter, the campus has in effect been put on notice. Similar infractions in the future – regardless of the location (not just in laboratories previously cited for violations) - could readily result in additional enforcement actions by IDEM up to and including the issuance of monetary fines against the offending laboratories.
As discussed previously, campus labs can easily maintain an appropriate level of compliance by following four simple steps:
- Know what chemical wastes are being produced in the lab and where the wastes are located at all times.
- Ensure that each waste container is labeled prior to adding any chemical waste to the container.
- Ensure that all chemical waste containers are closed when not actively being filled.
- Refer any chemical wastes to EHS for final disposal as soon as the container is full by means of our on-line manifest form available at: http://ehs.iupui.edu/waste-manifest.asp
For additional information, please review the summer edition of Lab Notes available here. Please contact Amanda Stinnett at 8-3328 or Kevin Mouser at 4-4351 with any chemical waste question or concern.