Hazardous Waste Disposal

            When it comes to Hazardous Chemical Waste Storage and Disposal on Ohio University’s campus, there’s a process that must be followed. Generally there are two situations in which chemicals are required to be picked up on OU’s campus. The first being hazardous laboratory chemical waste and the other being unwanted chemicals.

            Storage of the hazardous laboratory chemical waste may sound like a lengthy process, but in fact in only involves a small number of steps. The first step is to identify the waste stream, which is done by determining if the chemical is hazardous or non-hazardous as defined by the E.P.A. This can usually be determined by looking at the MSDS or SDS for the chemical.  Selecting a container for waste collection does this and ensuring the waste does not weaken or destroy the container. The container must also have a sealable lid. This container is then placed in a secondary containment device, such as a tray or dish to collect spills. This secondary container must be able to contain the volume of the primary container. The next crucial step is to prevent the mix of hazardous and non-hazardous wastes.

Steps 4, 5, and 6 are the steps that require the hazardous material to be placed in the primary and secondary containment, labeled correctly with the provided hazardous waste labels, then correctly placed in a location for the EHS Hazardous Materials Manager or his student workers (myself and one other) to be picked up and moved to the Hazardous Waste Storage Area. Steps 8 and 9 are the steps taken to have the Hazardous Materials Manager or his student workers to come and pick up the chemical waste. During Step 8, a Chemical Waste Disposal form will have to be filled out and sent directly to the HMM, or through the campus mail to Hazardous Materials Manager, EHS, University Service Center. Step 9 is done to help the Hazardous Materials Manager identify the characteristics of the waste for proper storage and eventual pickup by a contractor for disposal. If there were to be any problems during the steps, the person with the waste is given the number for the Hazardous Materials Manager for assistance.

            So then what happens when the chemical is unwanted? The same process takes place. Identify the hazards in the chemical by using the MSDS or SDS, label the chemical correctly, fill out a Chemical Waste Disposal form and send it in, and then finally the Hazardous Materials Manager will come and pick up the chemical. If the chemical is a hazardous waste, it will be placed in the correct storage area on campus and stored there until a contractor comes and picks up the chemical to be disposed of properly. If the chemical is not a hazardous waste, it will be disposed of based on the physical state of the chemical. Liquids will be poured down the sink with copious amounts of water to dilute it and solids will be thrown away in the trash and go to the landfill.  

https://www.ohio.edu/riskandsafety/ehs/environmental/hazmat/chemical.htm

Hazards in the Laboratory

            When people hear the words ‘laboratory hazards,’ the most commonly thought of thing are chemical hazards due to the core belief that every lab has dangerous chemicals in it. This maybe the case for a lot of labs, but chemical hazards aren’t the only dangers found in laboratories. There are three other hazards to look out for in laboratories, and they are physical hazards, biological hazards, and electrical hazards. Other hazards that can be found in labs can include mechanical hazards and radiation hazards, but these are found in more high-end laboratories.

            Chemical hazards are usually found in most labs, and as a result, OSHA has developed two different standards to handle chemical hazards in the lab. The first standard, which is known as the Hazard Communication standard or 29 CFR 1910.1200 and the second is known as the OSHA Lab Standard or 29 CFR 1910.1450. The main focus of 29 CFR 1910.1200 or Hazard Communication is to make sure that any hazards of all chemicals produced or imported are evaluated and all details regarding their hazards are transmitted to employers and employees.  This is done through the Safety Data Sheet or SDS. The HCS requires all chemical manufacturers, distributors, or importers to provide the Safety Data Sheets to communicate the hazards of hazardous chemical products. By June 1, 2015, new SDSs will be required to be in a unified format, include section numbers, headings, and associated information listed in order given by the HCS. The second standard is 29 CFR 1910.1450 or the OSHA Lab Standard, which supersedes any previous OSHA standard related to lab safety, meaning identifying hazards, determination of employee exposure, and the development of a chemical hygiene plan.

            Biological hazards include things like microbes, recombinant organisms, and vectors. Biological agents introduced to experimental animals are also considered a biological hazard. When dealing with biological hazards, there are many key ways to keep exposure to a minimum and reduce the chance of infection, injury, or even death. These will include warning signs, separated working areas in the lab, PPE, safety cabinets, decontamination areas, and the biosafety levels.

            Physical hazards will include things like electrical safety hazards, ergonomic hazards, sharp objects, and even housekeeping issues. Lab operations can result in workers assuming continued or even repetitive postures that can result in injuries to the eyes, back, hands, and neck. Pain is a good indicator that something is wrong and a posture change should be encouraged. Sharps containers are found all over laboratories and following some safety rules can reduce the chance of injuries and infections. Sharps containers should be puncture-proof and prevent leaks. The containers themselves should clearly labeled as sharps containers, never have their covers removed or have the contents transferred to another container. When the container becomes three-fourths full, it should be replaced with an empty container. Finally, housekeeping issues can prevent things like slips, trips, and falls in the lab. Safe and organized storage areas are a great place to start with. Material storage shouldn’t be creating hazards in the lab either. Bags, containers, and bundles should be stacked, blocked, and limited in height so that they are in a stable condition and can’t slide or fall.

            The last main hazard in laboratories comes from electrical hazards. Electrical hazards can be incredibly life threatening and are found way too often in labs. All outlets in a wet location should be equipped with ground-fault circuit interrupters to prevent accidental electrocutions. GFCIs are designed to trip and break the circuit when a small amount of the circuit begins to flow to ground. Wet locations are often located within six feet of a sink, faucet, and any other source of water or outlets located outdoors or in areas that get washed down frequently. Another common electrical hazard is the use of extension cables. These should not be used instead of permanent wiring. If an extension cord has to be used, make sure that the cord insulation is in good condition and never repair cracks, breaks, cuts or tears with tape. Either discard the extension cord or shorten it by installing a new plug end. Make sure not to run extension cords through doors or windows where they can become pinched or cut, and always be aware of any potential tripping hazards that the cords can create. Never remove the grounding pin from an extension cord as well and never use extension cords in series, just use the right length of cord for the job.

https://www.osha.gov/Publications/HazComm_QuickCard_SafetyData.html

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10106

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=10099

http://www.labmanager.com/lab-health-and-safety/2011/09/laboratory-hazards-and-risks#.Vspjcceih-g

http://www.safety.uwa.edu.au/topics/biological/hazards

OSHA Lab Standard vs. Other OSHA Standards

The main purpose of the OSHA Laboratory Safety is to supersede and build upon already existing OSHA standards. The primary being the General Duty Clause, which requires an employer to provide it’s workers with a safe work environment free from recognized hazards that are likely to cause injury or death. It also requires employees to comply with occupational safety and health standards and all rules issued that are applicable to their own actions and conduct. The OSHA Lab Standard also covers many other OSHA regulations that covered Hazardous Substances, Protection of Other Personnel In Laboratories, Hazard Communication, Resource Conservation and Recovery, and Definition of a Generator under RCRA.

Regarding “particularly hazardous substances’, you are talking about substances including select carcinogens, reproductive toxins, and substances with a high degree of acute toxicity. In order for a chemical to be classified as a carcinogen, it needs to meet of the following criterion; 1) regulated by OSHA as a carcinogen, 2) listed as ‘known to be a carcinogen’ in the Annual Report on Carcinogens published by the National Toxicology Program or NTP, 3) listed under Group 1 or ‘carcinogenic to humans’ by the International Agency for Research on Cancer, or finally 4) listed in either Group 2A or 2B by IARC or under he category ‘reasonably anticipated to be carcinogens’ by NTP in some cases.

A reproductive toxin is defined as chemicals that affect reproductive capabilities, including chromosomal damage or mutations and effects on fetuses. Chemicals with a high degree of toxicity also require special provisions for worker health. ‘Select carcinogens’, although are specifically identified through reference to other publications, ‘reproductive toxins’ and chemicals with a ‘high degree of acute toxicity’ are not specified further, which has made it more difficult to apply these categories. Some institutions have chosen to adopt the OSHA Hazard Communication Standard definition of ‘highly toxic’, or an LD₅₀ < 50 mg/kg oral dose as a workable definition of  ‘high degree of acute toxicity’. There is little to no agreement on how to determine reproductive toxins.

When handling or working with carcinogens, reproductive toxins, and substances that have a high degree of acute toxicity, consider the use of designated areas, containment devices, special handling of contaminated waste, and decontamination procedures. The OSHA requirement is for evaluation, assessment, and implementation of these special controls when appropriate.

The Resource Conservation and Recovery Act, or RCRA. RCRA was enacted by congress in 1976to address the problem of waste disposal and reduction. Subtitle C of RCRA established a system for controlling hazardous waste from generation to disposal. This is referred to as the ‘cradle to grave’ system. The cradle, however, is the point at which the hazardous material first becomes a ‘hazardous waste’, not when it is first received a laboratory. Under RCRA, the Environmental Protection Agency is given great responsibility in promulgating detailed regulations governing the generation, transport, treatment, storage, and disposal of hazardous waste. RCRA and EPA regulations were written with a focus on industrial-scale generation of hazardous waste, but, with very limited exceptions, they also apply to laboratories that use chemicals.

Ethics

            When reading ‘The Lawyer Who Became DuPont’s Worst Nightmare’ article, six different levels of ethics can be found; personal, community, professional, state, federal, and corporation. Of the six levels of ethics, ethics at the corporate level were broke the most.

            For some background information, DuPont has been using a chemical commonly known as C8, or scientifically as Perflourooctanoic acid or PFOA, and PFOA was originally made by 3M. DuPont started purchasing PFOA from 3M in 1951 for use in manufacturing Teflon. PFOA was originally created by 3M four years earlier. PFOA was yet to be classified by the federal government as a hazardous substance, so how to dispose of the chemical came from 3M. One of DuPont’s first breaking of the corporate ethical code was by not following 3M’s directions of how to dispose of PFOA. It was recommended that PFOA was to be incinerated or sent to chemical-waste storage facilities. DuPont’s own directions were that it was not to be flushed into surface water or sewers.

However, over the decades that followed, hundreds of thousands of pounds of PFOA powder was disposed of through outflow pipes into Ohio River while sludge containing PFOA was dumped into digestion ponds, which seeped into the ground and into the water table. This water table supplied water to communities across Parkersburg, Vienna, Little Hocking and Lubek, totaling more than 100,000 people.

The next notable breakage of the corporate ethics was the secret conduction of medical studies for more four decades. Starting in 1961, DuPont researches found that the compound could increase the size of livers in rats and rabbits. During the 1970s, they discovered high concentrations of PFOA in the blood of factory workers at their Washington Works plant. In 1981, 3M found that ingestion of PFOA in rats lead to birth defects. DuPont wanted to test children that were born to workers in the Teflon division and found two cases of birth defects in the seven children that were born. In all three incidents, DuPont did not share their findings.

Another instance in when DuPont broke corporate ethics was during the ‘90s when DuPont knew that PFOA caused cancerous testicular, pancreatic and liver tumors in lab animals. As a result, they began looking for an alternative to PFOA. In 1993, they sent out an interoffice memo that detailed how they believe that they were able to successfully find an alternative to PFOA. However, corporate headquarters decided against it as products manufactured with PFOA were an important part of DuPont’s business, bringing in over $1 billion in revenue.

              Another major breakage, and probably the largest one was back in August of 2000. Rob Billot, who was the lawyer pursuing this case, sent his findings to Christie Whitman, administrator of the E.P.A., and John Ashcroft, the United States attorney general. To protect themselves and their interests, DuPont reacted immediately and issued a gag order against Billet to prevent his findings in the Tennant case from reaching the government. For a company to do that required a lot of guts realizing how bad it looks to the public and had a small chance of success. Luckily for Billot , a federal court denied the gag order and his letter went to the attorney general and the heads of the E.P.A.  

                                   Picture of the article talking about Billot's 'Famous Letter'

                                     Picture showing the structure of Perfluorooctanoic acid