MEC&F Expert Engineers : PROPER LABELING AND MANAGEMENT REQUIRED FOR RE-USED CONTAINERS/CHEMICAL WASTE MANAGEMENT

Monday, March 16, 2015

PROPER LABELING AND MANAGEMENT REQUIRED FOR RE-USED CONTAINERS/CHEMICAL WASTE MANAGEMENT







Re-using and repurposing a container is an acceptable practice provided the container is of an appropriate material and configuration and properly prepared for it new contents. This preparation includes correct labeling. 

Discussion: 

A worker was refilling squeeze bottles of methanol for use in a laboratory. While pouring from a manufacturer’s large amber bottle expected to contain pure methanol, the employee immediately noticed that the contents were a bright fluorescent pink (figure 1), and did not match the characteristics of methanol.
A review of the bottle providing this liquid showed some faint scratch marks over the original product labeling (figure 2), but nothing definitive was added to indicate what the new contents were. 

Analysis: 

A review of the source bottle indicated that it originated in a nearby facility, and individuals relocated this bottle, along with several unopened bottles, in an attempt to reuse chemicals when the directorate initiated a lab cleanout initiative. 

Further review of past operations in the original building indicated that the pink color was a result of adding a laser dye to a solvent. The attempted relabeling of the amber (source) bottle was inadequate to communicate the contents to the new owner(s). 

Nothing indicated the presence of a laser dye, some of which are toxic or even carcinogenic. Furthermore, the relabeling would probably be insufficient for use within the lab by knowledgeable individuals.


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Chemical Waste Management 


Chemical waste may include:


  • old and/or expired chemicals,
  • chemical waste solutions, or
  • debris contaminated with chemicals


UVM is committed to managing its chemical waste in a way that prevents release to the environment. This means that sink disposal of hazardous chemicals at UVM must be pre-approved.

Chemical liquids or solutions disposed of down a UVM drain go directly to Burlington's wastewater treatment facility and eventually discharged into Lake Champlain. To protect this area resource, laboratory personnel are prohibited from disposing of the following materials down any UVM drain.

Sink or drain disposal of any chemical solutions must be pre-approved by Risk Management & Safety by submitting this online Sink Disposal Request Form.


Sink Disposal

If you are generating a waste solution that you believe can go down a lab drain but it is NOT listed on the Materials Allowed for Disposal, you must submit an online Sink Disposal Request form.  Please be sure to indicate 100% of the  constituents in the solution, even if the solvent is water.

Per the Environmental Protection Agency (EPA) and Burlington Public Works Department, laboratory personnel are PROHIBITED from disposing of the following materials down any UVM drain:


  • Flammable Liquids (flash point equal to or less than 140 deg F), reactive or explosive materials;
  • Liquids having a pH equal to or less than 5.0, or greater than or equal to 9.5 or other corrosive property capable of causing damage to wastewater facilities;
  • Highly viscous materials (e.g. oils) capable of causing an obstruction in the wastewater system;
  • Radioactive materials;
  • Materials that have or create a strong odor (e.g: hydrogen sulfide, carbon disulfide, ammonia, trichloroethylene, sulfur dioxide, formaldehyde, chlorine, bromine or pyridine);
  • Wastewater capable of significantly raising the temperature of the system;
  • Grease or oils according to the following
  • petroleum > 15 mg/L,
  • animal or vegetable > 100 mg/L,
  • non-emulsified or "floatable" oils or grease; or
  • Pharmaceuticals or endocrine disruptors.


It is acceptable to discharge non-hazardous aqueous salt and sugar solutions down the drain, but please err on the side of caution. If you have specific questions about whether a solution is suitable for sink disposal, email safety@uvm.edu before you dispose of it down any UVM drain.

Collect solvents used to clean glassware
Solvents used to rinse clean glassware (acetone, ethanol, Nochromix, etc) are required to be collected as hazardous waste and disposed of through UVM's waste disposal procedures.

Disposal via evaporation is prohibited
Evaporation of hazardous materials in a chemical fume hood for the purpose of disposal is prohibited.
Fume hoods are used to control exposure to vapors during experimental processes and may increase the evaporation rate of some of the chemicals being used. To minimize the potential for air pollution as a result of fume hood use:


  • Close caps tightly when not in use, 
  • Never store chemicals, including wastes, in the fume hood. Clutter and extra materials stored on the fume hood work surface prevents proper movement of airflow and can cause laboratory accidents.


Waste Container Choice Matters
Container Material

Choose the proper waste container. The container material, type of cap and size of the container matters. Take a moment to consider the following:


  • Are the waste chemicals compatible with the container material?
  • Are the waste chemicals that are going to be mixed together compatible (will not react with each other)?
  • Have you checked with Safety staff to make sure that the waste you are combining can be collected together in one waste container and easily disposed?
  • Should 2 different waste containers be used instead for the types of waste streams being generated?
  • Is the waste required to be collected in a specific size or type of container (e.g. with a vented cap, a 1-gal vs. a 5-gal waste container)?


Email safety staff if you are unsure about how to collect waste in your area.

Use common sense. If hydrochloric acid was originally shipped from a distributor in a glass container (or a glass container coated with plastic), a glass container (or a glass container coated with plastic) may be the safest choice in which to store a waste hydrochloric acid solution.



30% hydrogen peroxide solution is shipped from a distributor in a container with a vented cap. Be sure to purchase and store waste solutions of this material at varying concentrations in a pressure-relieving container with a vented cap.  


Improperly choosing a waste container can increase the risk of the waste container degrading, leaking, or building up unnecessary pressure, leading to a potential lab injury. 

Do's and Don'ts of Waste Container Choices





  • Chemical waste containers should be leak-proof.
  • Never use empty household or food-grade containers (e.g.plastic milk jugs or juice containers). 
  • Never use open beakers to collect waste.
  • Waste containers should be free of contamination.
  • Waste containers must have a screw-top cap that fits. No snap-on caps or glass stoppers.
  • Caps must be securely closed when not in use.   
  • Never store waste chemicals that are corrosive in a metal container. Never use a metal can as a secondary containment bin for corrosive chemicals.   



Re-use of stock chemical containers to collect waste

If you re-use a stock chemical container to collect waste, be sure that 1) the container has been triple rinsed, 2) chemicals being added are compatible with chemicals that the container originally, and 3) place a yellow laboratory waste accumulation container label on the container once a drop of waste is added.
Clearly label any reused containers as "EMPTY" until you start using them.

Never rinse and re-use an acutely toxic or reactive chemical container                                   as a waste container.  

Any empty chemical container that held acutely toxic or reactive material, such as sodium azide, osmium tetroxide or cyanides, is required to be tagged for waste disposal (see list of acutely hazardous chemicals).  


Double labeling causes confusion!    
Never place an orange or green label AND a lab waste accumulation label on a container. Use one or the other. Consult with Safety staff  if you need assistance with chemical or waste labeling.    


Properly Size Your Waste Container

Think about how much waste you will generate within a specific time frame.
For example, if you estimate that a lab procedure you are conducting will only generate 1-gallon of a specific waste stream over a one year period of time, then a 1-gallon waste container may be too large of a choice because lab waste is required to be picked up for disposal from UVM labs every six (6) months. On the other hand, if you estimate that a procedure will generate 500 mls of a specific waste stream in one week and you have hundreds of samples to run, perhaps a larger waste container makes sense so you only have to have two waste pickups per year.

Safety staff are always available to help make these kinds of waste descisions.

UVM Chemsource Sells Some Waste Containers

UVM Chemsource only sells 1-gallon amber glass waste containers and 5-gallon (20 liters) plastic containers for liquid or solid waste collection.  

Waste containers cannot be returned to users.  5-gal waste container customers pay for the initial delivery of a 5-gallon waste container to help cover our cost. From then on, 5-gallon waste containers are swapped out at no additional charge.



Labs that need to collect lab waste in volumes larger than 5 gallons (20-liters) should contact Safety staff before doing so. 

If your lab needs smaller waste containers, please contact a contracted UVM preferred vendor, such a VWR or Thermo-Fischer Scientific, to purchase the appropriate size waste containers for your needs.


Label Waste Containers Properly   


UVM's laboratory safety program requires that laboratory waste that will accumulate over a period of time be labeled with a Laboratory Waste Accumulation Container label.  This is a requirement of UVM's Laboratory Safety Program and is clearly noted on the monthly Laboratory Self-Inspection Checklist. 

Clearly and completely filled out laboratory waste accumulation labels ensure that laboratory staff, Safety staff, custodians, Physical Plant personnel and emergency responders can identify containers of waste and any chemical hazards easily.  

Waste labeling at UVM is a two-part procedure:


  1. Fill out and place a yellow Laboratory Waste Accumulation Container label on any container that is being used to collect waste over time. This label must be filled out and placed on the waste container as soon as one drop of liquid (or solid contaminated debris) is added to the container. 
  2. Once a waste container is full OR 6-months from the waste accumulation start date, it is required that a white Laboratory Waste Tag be filled out and entered online. Be sure to hang the tag on the waste container itself. Entering the lab waste tag online notifies UVM lab waste technicians that there is a waste container(s) ready for pickup and proper disposal.


If you are not following this procedure, it may cause an accident and your lab and waste are out of compliance with UVM's Laboratory Safety Program.  Please review the details about this procedure below. Waste accumulation labels and laboratory waste tags are available from several locations on campus.


Laboratory Waste Accumulation Container label
The Laboratory Waste Accumulation Container label must be filled out completely. As part of the required UVM monthly laboratory self-inspection, visibly inspect waste container labels.
If the information written on a waste label is unreadable (has faded over time or chemicals have dripped on to the label), replace it!  A properly filled out laboratory waste accumulation label includes:


  • Full English names to list all of the contents,
  • The date that the waste began being collected
  • Circles around the appropriate hazard(s) of the contents


Waste container labels must be visible and readable at all times. 




Laboratory Waste Tag

Once a waste container is full OR the date on the container is approaching a 6-month time frame, fill out a white muti-part Laboratory Waste Tag.  



List all chemical contents in English (no formulas) and estimated percentages.

Waste tags are uniquely numbered. NEVER MAKE UP A TAG NUMBER.  After manually filling out a waste tag,


  • Enter the waste tag online
  • Attach the tag to the waste container with tape or the string, and
  • Place the containers into a properly labeled storage cabinet with other compatible chemicals.  (Do not store waste in a chemical fume hood unless odors are being emitted).



Waste technicians pick up laboratory waste for disposal 2x per week on main campus. Waste from off-campus buildings is picked up on the 2nd and 4th Thursday of each month. Off campus locations include Colchester Research Facility, Rubenstein Laboratories, Proctor Maple Research Facility, UVM Horticulture Education & Research Center, etc.

Waste accumulation container labels and laboratory waste tags are available from several locations on campus or by contacting safety@uvm.edu.


Lab Cleanouts / Lab Decommissioning

It is recommended that labs review all of their chemicals in storage and conduct a cleanout of old and unused chemicals once per year.

If a lab has more than 15 or 20 waste containers ready for disposal at one time, please contact  Safety staff  to set up a time for us to meet with you so we can assist with the proper segregation, tagging and disposal of the waste.  In these cases, EACH container need not be tagged individually.  Please meet with your Laboratory Safety Coordinator before conducting any chemical cleanout.

Lab Decomissioning

When renovating, relocating or closing a lab at UVM, it is the responsibility of the Principal Investigator to make sure that the lab is decommissioned properly. A Laboratory Clearance Checklist must be completed. Please review UVM's Lab Decommissioning Procedure.


Segregate and Store Waste Properly
Key Requirements:


  • Waste containers must be securely closed when not in use. 
  • All liquid laboratory wastes must be stored in secondary containment in case the primary container fails.
  • Never leave a funnel in a waste container unless the funnel itself is designed to be a secure lid.
  • Avoid or minimize the storage of waste materials inside a chemical fume hood to preserve space for working safely and to allow for proper airflow within the fume hood.   
  • Flammable waste should be stored within a flammable safety cabinet and must count towards the fire code storage limits for the lab.
  • Do not store waste containers on the floor.  In some cases, larger, non-glass containers of waste may be stored on the floor inside of a secondary containment bin. Never block aisles and/or egress and do not create a tripping hazard. 




Chemical waste storage cabinets

Store chemical waste by hazard with other compatible chemicals in a properly labeled chemical storage cabinet. Never store waste in a chemical fume hood unless odors are being emitted (e.g. phenol, chloroform).

Cabinets used for multiple waste containers that are labeled "Chemical Waste Storage" must have smaller secondary containment bins inside to separate incompatible chemicals. Please see the Chemical Storage Guide.

Prevent leaks

Leave 2 inches of empty space at the top of waste containers - never overfill.
Waste containers must be inspected at least monthly, per the self inspection checklist, to assure that no degradation of the container or its contents has occurred.

A leaking container must be either packed in a secondary container, or its contents transferred to another container.


Specific Wastes 


Unknown Chemicals

"Unknowns" are chemicals that are found in the lab either with an illegible label or no label at all. We cannot guess at what these wastes are. There is a strict and expensive protocol that Safety staff are required to follow in order to manage this type of waste. Please inspect your chemicals monthly as required by the Lab Safety Program to eliminate or minimize unknown chemicals in your lab.

Chemically-contaminated sharps

Sharps contaminated with hazardous chemicals must be collected in a puncture proof container such as a sharps box and labeled clearly with a yellow waste accumulation container label. Be sure to list all of the chemicals that have been in contact with the sharps, circle the hazard(s), and write the date in which accumulation of the sharps began. Fill out and enter a waste tag online when the sharps container is 2/3 full; do not overfill. Do not place chemically-contaminated sharps in a biohazard box.

Containers of acutely toxic or reactive chemicals 

Containers of acutely toxic or reactive chemicals must be securely closed and tagged for hazardous waste disposal. Never re-use these containers to collect waste.

Contaminated debris: broken glassware, gloves, pipettes, etc.

Debris that is contaminated with hazardous chemicals should be collected in a clear bag or in a cardboard box lined with a clear plastic bag and tagged as chemical waste for disposal. Never use a red biohazard bag to collect chemically contaminated glassware or debris.

Glassware contaminated with infectious material should be placed in a puncture-proof container and then placed in a biohazard box. For information about biological waste please follow this link to the biowaste management page.

Glassware contaminated with radioactive contaminants should be decontaminated and Radiation Safety staff should be notified.  For information pertaining to radioactive waste management follow this link to the Radiation Safety Office (RSO) website.

Mixed waste

Waste that is contaminated with both biological material and chemicals should be tagged as a laboratory waste. Provide specific information on the tag or in the comments box on the online tag entry page.


Pump Oil, Contaminated Rags


Used oil, and oil-contaminated rags or debris, is regulated in Vermont. This means used oil and oil-contaminated debris must be collected, labeled and disposed of as hazardous waste. Used oil may include:


  • vehicle crankcase oils, transmission fluids and power steering fluids;
  • hydraulic, compressor and straight cutting oils;
  • tramp oil and oil drained from evaporators.


The best container for collecting rags contaminated with used oils (motor oil, linseed oil) or solvents (thinners, paints) is a metal can with a self-closing lid.  A self-closing lid on the waste collection container can prevent these types of rags from spontaneous combustion or a spark.


Chemical Spills: Contaminated Spill Debris   

  


Chemical spills of 2-liters or less can be cleaned up by lab personnel using the Chemical Spill Kit that is provided by Risk Management & Safety to every lab on campus.  

Debris, such as contaminated gloves, cardboard, bench pads, glassware, etc should be collected in a CLEAR plastic bag and tagged immediately with a laboratory waste tag. Safety staff are always available to consult with lab personnel about a spill or to assist or perform the spill cleanup itself. Page Safety staff by calling UVM Service Operations at 656-2560, press 1 to speak to dispatcher.


Batteries, lightbulbs, mercury thermometers, old lab equipment with hazardous components



Please refer to the UVM Recycling Guide for details about how these and other items are collected on campus.

Assorted batteries are collected throughout campus in brown battery buckets or in E-waste (electronic waste) containers scattered around campus by UVM Recycling. Enter a lab waste tag online when your brown battery bucket is full; the description on the tag can be "assorted batteries"; please estimate the amount in "lbs". Larger lead acid batteries should also be tagged for waste disposal.

Burned out fluorescent lights, compact lightbulbs, UV lightbulbs, etc are considered Universal Waste in the State of Vermont and should be removed from the fixture and carefully placed back inside of the cardboard box that they came in to prevent breakage. Email safety@uvm.edu or call 656-5408 for intact lightbulb pickup. 

Broken lightbulbs are considered hazardous waste and should be collected in a clear bag that can be sealed inside of a cardboard box. Fill out a lab waste tag and enter tag online for pickup.

Mercury Thermometers can be swapped out by Safety staff for FREE. Be sure to check that new lab equipment does not have a mercury thermometer inside.  Please specify whether you would like a partial or total thermometer. 

Old laboratory equipment needs to be checked out by UVM ITS to have hazardous components removed before the equipment can be safely disposed of as scrap metal or E-waste. Labs are required to use the Surplus Disposal Form that is required before disposing of old lab equipment.