Hazardous Materials &

Hazardous Waste
Training
September 10, 2008

Drug & Laboratory Disposal, Inc.

331 Broad Street
Plainwell, MI 49080
 There are many training requirements
with which to comply under various
Federal regulations.

EPA, DOT & OSHA

are the primary agencies that enforce
specific training requirements related to
management of hazardous waste.
 EPA
Environmental Protection
Agency
Provides a systematic approach
to managing hazardous waste
 DOT
Department of Transportation

Regulates hazards during

transportation
 OSHA
Occupational Safety and Health
Administration

Regulates workplace
conditions and practices
EPA Training Requirements

40 CFR 262.34 (d)(5)(iii)

Hazardous waste management
RCRA in 1976
 EPA Training Requirements
Anyone who could cause non-compliance at a
facility

Anyone with duties which ensure the facilitys

compliance

Annual review of written training plan

 EPA Training Requirements
Must include job-specific waste management
procedures

Must be completed within 6 months of assignment

to the facility

Must have supervision until trained

Training must be reviewed annually

DOT Training Requirements

49 CFR 172.700; 173.1 (b)

Hazardous materials transportation
 DOT Training Requirements
Employees who directly affect transportation
safety

Repeated at least every 3 years

Change in rules requires additional training.

 DOT Training Requirements
General awareness

Function-specific training

Security training

Safety training
 DOT Training Requirements
Must include test and be kept for 3 years

Training completed within 90 days of employment,

during which they may not work with hazardous
materials unless under supervision of trained and
knowledgeable employee
OSHA Training Requirements

29 CFR 1910.1200(h)
Hazardous chemicals
workplace safety
OSHA Training Requirements
Any employee who could be exposed to any physical
or health hazard

Recognize hazards and protect employees from

hazards through proper communication

Establish a written hazardous communication

program
OSHA Training Requirements
Must be trained how to work with hazardous
chemicals to prevent illnesses, injuries, or death

Must include container management techniques, safe

chemical use, proper protective equipment use, and
spill response training
OSHA Training Requirements
Labels on incoming containers of hazardous
chemicals

Have MSDS readily accessible for each work shift

For waste shipment, have containers labeled

Initial training and whenever new physical or health

hazards are introduced
Most important; everything hinges on generator
knowledge, materials, and processes used.

What is it and is it a hazardous material

Must determine the type of hazard and the degree of

hazard
We need to know the physical and chemical
properties.

-Physical state (liquid, solid, gas)

-Flashpoint or boiling point
-Will it kill people (toxicological effect)
-What does it do to your skin
-Is it reactive to air, water, other chemicals
-Is it radioactive
Get information from:

MSDS

Text books

Manufacturers data

Analytical results
3 ways to become a hazardous material:

Meets a hazard class definition from 1 8

The DOT says so with a + entry

Miscellaneous class 9
Hazard class definitions
Hazard class definitions
The DOT says so with a + entry

About 50 chemicals from a list of 3000

Must be shipped under this classification

Examples: phenol, magnesium arsenate

Miscellaneous Class 9
If it doesnt meet a hazard class and meets one of the
following;
It has airplane hazards (Crew safety)
It is a hazardous waste (EPA number)
Marine pollutant
Separate list by DOT

Elevated temperature material

Molten or hot
Forbidden materials

May not legally be offered for transportation or

transported

Usually have to meet specific conditions for safety

before transportation
Determine the degree of hazard:

PGI indicates greater danger

PGII indicates medium danger

PGIII indicates minor danger

Indicated by packing group, used in packaging the
material

Some hazard classes dont have packing groups.

(2, 7)

Not safe to over classify. (responders and

employees safety)
Division 3 Packing Groups
Packing Group Flash Point Initial Boiling Point
I 35C (95F)
II 23C (73F) > 35C (95F)
III 23C (73F) but 60.5C (141F) > 35C (95F)
Division 6.1 Packing Groups
Inhalation toxicity
Packing Dermal toxicity LD50
Oral toxicity LD50 (mg/kg) by dusts and mists
Group (mg/kg)
LC50 (mg/L)
I 5 40 0.5
II > 5 but 50 > 40 but 200 > 0.5 but 2

III solids: > 50 but 200; liquids: > 50 but 500 > 200 but 1000 > 2 but 10
A material may meet the defining criteria for more
than one hazard class but is assigned to only one
hazard class.

Lots of chemicals are toxic.

Select from column 2

Be accurate

Be specific (technical names, chemical family, end

use, n.o.s. use)
Waste characteristics and waste code
numbers

-Characteristic D codes

-F listed solvents

-P & U toxic waste codes

-Act 451 industrial liquid codes

Characteristic D Codes

D001 Ignitable waste code

D002 Corrosive waste code

D003 Reactive waste code

D004 D011 Toxic heavy metals waste codes

D012 D043 Toxic organic codes

F Listed Solvents

F001 - Used in degreasing (6 solvents)

F002, F003, F004, F005 - Spent Solvents (28

solvents)

Examples: methanol, xylene, methylene chloride

P & U Toxic Waste Codes

Commercial chemical products pure

P codes - acutely toxic

U codes toxic

Examples: nickel cyanide, bromoform

Act 451 Industrial Liquid Codes

Act 451 Part 121 liquid industrial wastes

Not EPA waste codes

Can be DOT shipping name

Examples: Antifreeze, crankcase oil

Act 451 Codes
Mixed Solvents (Solvent Solutions) 007L
Pharmaceutical 014L
Automotive Oil 017L
Coolants and Water Soluble Oils 019L
Other Oil 021L
Polychlorinated Biphenyls 026L
Other Waste 029L
Antifreeze 030L
Storm Sewer Cleanouts 031L
Sanitary Sewer Cleanouts 032L
X-Ray/Photo Solutions 033L
Water Based Cleaning Solutions 034L
Grease Trap Wastes 036L
Universal Waste

There are certain hazardous wastes that a business

can choose to manage in an alternative manner in
place of the more complex hazardous waste
regulations.
Advantages of Universal Waste Regulations
- Waste can be accumulated up to one year

- A Hazardous waste manifest is not required

- Volume is not included in determining generator status

- Less labeling is required

Types of Universal Waste

- Batteries

- Electric Lamps

- Electronic components

- Mercury-Containing Devices

- Pesticides

- Pharmaceuticals
Electronic Equipment Computer Monitors & TVs
CRTs (cathode ray tubes) in monitors and TVs have
been tested and show lead levels exceeding the
regulatory limit
of 5.0 mg/L. Some models also contain barium,
chromium, or mercury.

Meeting the definition of hazardous waste allows these

electronics to be managed as universal waste.
Regulated Medical Waste

Intended to help employees avoid injuries and disease.

Regulated medical waste, n.o.s., 6.2, UN3291, PG II

Waste code possibilities: 029L or N/A

Blood borne Pathogens
Use OSHAs universal precaution method. Treat all
blood as dangerous.

-Blood-soaked bandages
-Discarded surgical gloves and instruments
-Cultures

-Hepatitis
-Tetanus
-HIV
Sharps
Can inflict injuries and disease.

-Broken glass

-Lancets

-Needles

-Razor blades
The point of packaging is to make sure that the stuff
stays inside the packaging during normal
transportation.

Includes temperature changes, handling, vibration

caused by rough roads or curves.
The type of packaging you can use

The standards or specifications the packaging has to

meet

The rules for filling and closing the package

When different hazardous materials may be placed in

the same package
Requirements in column 8 of HM table
172.101

Combination packaging

Single packaging
49 CFR 178.503
Marking of packages
Empty containers

DOT vs. EPA Standards

If empty, package is not subject to hazardous

material regulations.
DOT empty containers

Cleaned of residue and purged of vapor

All hazardous markings and labels have been

removed or covered

Remaining residue is not a hazardous waste or

marine pollutant
EPA empty containers

Must contain less than 1 inch of residue or

less than 3% by weight of material

Gas cylinder must equal atmospheric pressure

If contained acutely hazardous waste, container

must be triple rinsed or inner liner removed
Must accompany the shipment

Printed legibly in English, no abbreviations

Keep copy for 3 years

Must get copy from TSDF within 45 days.

If not, call EPA.
The person signing a hazardous waste manifest is
also signing the DOT-required shippers
certification, certifying that the entire shipment is in
full compliance with all applicable DOT regulations.
Anyone who prepares, completes or signs a
hazardous waste manifest must have training as
required by the DOTs hazmat employee training
standard under 49 CFR 172 subpart H.
Markings identify:

What the material is

Correct emergency response actions

Shippers name and address

Special handling precautions

Markings include:

Proper shipping name, UN number, shippers name

and address

EPA ID number, manifest tracking number

Technical names of hazardous materials and waste

codes

Hazardous Waste Statement.

Labels identify:

What hazard the material has

Special handling precautions

Labels include:

Diamond shaped hazard class labels

Square precaution labels

Label Examples:
1- Hazardous Warning Statement
2- Generator Name and Address
3- Generator EPA ID Number
4- Accumulation Start Date
5- EPA Waste Codes
6- Manifest Document Number
7- Proper Shipping Name, Technical Name, Special Hazard Warning (if applicable) and DOT
Exemptions (If applicable)

1
U of M Flint Riverfront 2
602 Mill Street (810) 766-6762
Flint MI 48503

7 3
Act 451, Part 121 Regulated Materials

6
(used oil)
MID 085 043 891

4 D001,D002,F003 5
U of M Flint Riverfront
602 Mill Street
Waste Flammable Liquid, Corrosive, n.o.s., 3(8), UN2924, PGII

2
Flint MI 48503
(Methanol, Acetic Acid)

7
The shipper or generator must ensure that placards
are provided

Displayed on all four sides

Visible without interference on each side and

horizontal placement
Table 1
------------------------------------------------------------------------
Placard
Category of material (Hazard design
class or division number and Placard name section
additional description, as reference
appropriate) ( )
------------------------------------------------------------------------
1.1.............................. EXPLOSIVES 1.1.......... 172.522
1.2.............................. EXPLOSIVES 1.2.......... 172.522
1.3.............................. EXPLOSIVES 1.3.......... 172.522
2.3.............................. POISON GAS.............. 172.540
4.3.............................. DANGEROUS WHEN WET...... 172.548
5.2 (Organic peroxide, Type B, ORGANIC PEROXIDE........ 172.552
liquid or solid, temperature
controlled).
6.1 (inhalation hazard, Zone A or POISON INHALATION HAZARD 172.555
B).
7 (Radioactive Yellow III label RADIOACTIVE \1\......... 172.556
only).
------------------------------------------------------------------------
\1\ RADIOACTIVE placard also required for exclusive use shipments of low
specific activity material and surface contaminated objects
transported in accordance with 173.427(a) of this subchapter.
Table 2
------------------------------------------------------------------------

Placard
Category of material (Hazard design
class or division number and Placard name section
additional description, as reference
appropriate) ( )
------------------------------------------------------------------------
1.4.............................. EXPLOSIVES 1.4.......... 172.523
1.5.............................. EXPLOSIVES 1.5.......... 172.524
1.6.............................. EXPLOSIVES 1.6.......... 172.525
2.1.............................. FLAMMABLE GAS........... 172.532
2.2.............................. NON-FLAMMABLE GAS....... 172.528
3................................ FLAMMABLE............... 172.542
Combustible liquid............... COMBUSTIBLE............. 172.544
4.1.............................. FLAMMABLE SOLID......... 172.546
4.2.............................. SPONTANEOUSLY COMBUSTIBLE 172.547.
5.1.............................. OXIDIZER................ 172.550
5.2 (Other than organic peroxide, ORGANIC PEROXIDE........ 172.552
Type B, liquid or solid, temperature controlled).
6.1 (other than inhalation POISON.................. 172.554
hazard, Zone A or B).
6.2.............................. (None).................. ...........
8................................ CORROSIVE............... 172.558
9................................ Class 9 (see 172.560
172.504(f)(9)).
ORM-D............................ (None).................. ...........
------------------------------------------------------------------------
Materials handled to prevent damage during
loading and unloading.

-This end up
-No smoking by classes 1,2,3,4,5.
Segregated and separated to prevent incompatible
material from mingling during transportation.

-Incompatibles 4 feet from each other

-Use segregation table

Secured and braced to prevent movement and
damage during transportation

-strapped in truck every 10 feet

-watch for load shifting

In transportation:

Protect the general public

Control and clean up releases

Prevent or extinguish fires

Any person or place that creates
hazardous waste
LQG Large Quantity Generator

Generates 2,200 pounds or more waste per month

Can accumulate on site for 90 days

No limit on amount stored

Must be at least one employee available to respond

to emergency

Written plans for handling emergencies

SQG Small Quantity Generator

Generates 220 to 2,200 pounds of waste per month

May accumulate on site for up to 180 days

Accumulation limit is 13,200 pounds

Must be at least one employee available to respond

to emergency

No written emergency plan needed

CESQG Conditionally Exempt Small
Quantity Generator
Can generate 220 pounds or less waste per month

Accumulation limit is 2,200 pounds

No plans or reporting required

Accumulation

Mark the accumulation start date on each container

Mark each container with words hazardous waste

Have written emergency plan

Keep containers closed and in good condition

Inspect containment area and document

Security Plans EPA

Personnel security

Unauthorized access

En route security

Plan in writing and kept

Security Awareness DOT

Required for all hazmat employees

An awareness of security risks

Recognize possible security threats

Know how to respond

Security Awareness OSHA

Regulates workplace storage of flammable and

combustible liquids

Size, amount and place of containers

Personal protective equipment supplied if needed

Safety plans and exit routes

National Fire Protection Association

Based on possible fire situations

Standard system for the identification of hazardous

materials

Assists in effective fire and emergency planning

Division rating scale

0, 1 - unlikely to become dangerous

2 - depends on the circumstances
3, 4 - it is dangerous now
Enforcement and penalties

EPA has authority to inspect facilities

Can require corrective actions to take place

Criminal penalties or fines

 FINES & PENALTIES
Summary
Act Sanction Intent Maximum Fines Maximum
Imprisonment
RCRA Civil None $32,500/day
(Hazardous
Waste) Criminal Knowingly $25,000/day (doubled for 1 year (doubled
second offense) for second
offense)
Knowing $250,000 2 years
imminent $1,000,000(organizations)
endanger-
ment to
human life
Knowing $250,000 5 years
extreme $1,000,000(organizations)
indifference
to human life
 Hazardous Materials &
Hazardous Waste
Training
September 10, 2008

Drug & Laboratory Disposal, Inc.

331 Broad Street
Plainwell, MI 49080