The Indiana Department of Environmental Management conducted a routine hazardous waste inspection on campus on June 14, 2013. A number of campus laboratories were found to have all too common compliance problems which ultimately led the agency to issue a formal Violation Letter to the campus – the first in nearly 25 years of similar inspections on campus. Your lab can avoid being the next to be cited by following these four simple steps in managing your chemical wastes:
Know what your chemical waste are and where they are currently located.
Ensure that the waste container is labeled prior to adding any chemical waste to the container.
Ensure that your chemical waste containers are closed when not actively being filled.
Refer your chemical waste to EHS for final disposal as soon as the container is full.
How much may it be worth to your lab to ensure that these four steps are strictly followed? The Violation Letter very plainly states: “Failure to . . . verify a return to compliance at this facility will result . . . in civil penalties of up to $25,000 a day for each violation. . .”
An unlabeled dump jug sitting in the fume hood without a cap in place could ultimately result in $50,000 a day in fines and penalties – fines and penalties that, by University policy, are the responsibility of the department(s) involved in the citation.
In an effort to enhance compliance on campus, EHS also recommends that all containers of biohazard/infectious waste be kept covered when not actively being filled.
Lastly, EHS recommends that other waste receptacles maintained on lab benches or in chemical fume hoods which receive waste which is not biologically or chemically contaminated – waste destined to be discarded with the lab’s other general refuse – be labeled simply as “Trash” to avoid any confusion as to the content of the waste containers.
While conducting recent compliance inspections in the SL Building, EHS encountered the following arrangement in a chemical fume hood in room 209 which is one of the best illustrations noted to date of how to manage chemical wastes in a lab. (Please click on image for a larger view.)
Referring back to the four steps of compliance, it is easy to see how this lab provides for the highest degree of protection of lab personnel as well as the environment.
A specific area has been designated in the fume hood for the lab’s chemical wastes – as defined by the plastic tray. The lab staff knows exactly what chemical wastes are currently being generated in the lab and where the wastes are to be found.
Each container of chemical waste has been appropriately labeled – complete with the name of the chemical waste and a complete listing of constituents.
Each container is closed when not actively being filled – including the plastic bag of pipet tips as noted in the upper right hand corner. While several of the dump jugs have dedicated funnels, the lids have been placed back on the container and the funnels simply set on top for future use.
The staff know that their final responsibility is to request that EHS remove the waste as soon as any of the containers are filled by completing an EHS manifest form available at: http://ehs.iupui.edu/waste-manifest.asp
EHS would like to also acknowledge labs found to be in compliance the day of the inspection – especially labs in the Medical Science, Medical Research, and the R2, R3 and R4 Buildings. EHS extends a special word of acknowledgement to Lindsay Hammack in SL 209 for her initiative in coordinating chemical waste disposal in SL 209 and to Rose Richardson in the Medical Sciences Building who is always on our list of labs to visit during compliance inspections due to her fastidious record keeping and attention to detail in managing the chemical waste in her area.