Frequently Asked Questions for the EPA Region 2 RCRA Audit
1. What is hazardous waste / How do I know if I am generating hazardous waste?
A waste is considered a hazardous waste if it is flammable, corrosive, reactive, or toxic or if it is on either of two lists (U List or P List) of specific chemical substances developed by the USEPA. Some examples of hazardous waste are spent solvents and effluents from analytical instruments, spent phenol chloroform from extractions, ethidium bromide gels, histology waste, and any old, outdated, or expired chemical reagents. See page 26 of the 2003 Health and Safety Manual. If you are uncertain whether or not you are generating or hoarding hazardous waste, please contact EH&S (212-305-6780).
2.What is mixed waste?
Mixed waste is hazardous waste that contains a combination of chemical-biological, chemical-radioactive or biological-radioactive waste For hazardous waste containing radioactive materials, contact the Radiation Safety Office (212-305-0303).
3. What are “inherently waste-like” chemicals?
Chemicals are considered inherently waste-like if they are old, outdated, and appear as though they have not been used in years.
4. Where can I get information on CUMC hazardous waste handling procedures?
You can obtain hazardous waste procedures from the 2003 Health and Safety Manual (hard copy or electronic version , the Emergency Procedure Wall Guide, and from the back of the hazardous waste labels.
5. What is a satellite accumulation area?
A satellite accumulation area is a designated location in your lab where hazardous waste is collected and safely stored until removal by EH&S.
6. Can I store my hazardous waste on the floor?
Provided it is kept in a secondary container away from high traffic areas and does not block means of egress, waste can be stored on the floor. While floor storage of hazardous waste is not the preferred method, it can be stored accordingly.
7. Can I dispose of small quantities of hazardous waste down the drain?
No. There is a ‘no drain disposal’ policy at CUMC. Do NOT dispose of any hazardous waste down the drain.
8. If our laboratory occupies more than one room on the same floor, can I take hazardous waste generated in my lab to the other lab?
No. All hazardous waste must be collected and remain at the place where it was generated until it is removed from your laboratory by EH&S personnel.
9. What should I do to have my hazardous waste removed from my lab?
You must fill out the chemical waste disposal form (see Lab Safety & Chemical Hygiene Plan, Attachment IX) and fax it to EH&S (212-795-5847). You can also send your request by completing the electronic version of the Hazardous waste Form and submit it online.
10. How do I get rid of old chemicals left behind in my lab by the previous investigator?
For unwanted chemicals, you must fill out the chemical waste disposal form (see LSCHP, attachment IX; or the electronic version ) and fax it to EH&S (212-795-5847).
11. How do I dispose of radioactive waste?
Contact the Radiation Safety Office 212-305-0303.
12. How can I meet the requirements of properly labeling my hazardous waste?
Once a chemical is designated as a hazardous waste, the words HAZARDOUS WASTE must be written on the bottle in addition to the proper chemical name. Also, a waste classification determination must be made. To simplify procedures, EH&S provides preprinted waste labels – just print the chemical name, check the appropriate waste class box, and affix the label to your hazardous waste container. Do not use any abbreviations or chemical structures to identify the hazardous waste constituents.
Example:
If you generate ethanol, your container must read “ethanol” NOT EtOH and the “flammable” box must be checked.
If you generate formaldehyde, your container must read “formaldehyde” NOT HCHO and the “toxic” box must be checked.
If you are unsure of how to properly label your waste, call EH&S at 212-305-6780.
13. Which color applies to my location? Waste labels are color- coded.
Black Building (BB)
Physcians and Surgeons (P&S)
Vanderbilt Clinic (VC)
Presbyterian Hospital
>
Babies Hospital
Eye Institute
Milstein |
Pink
|
Neurological Institute
Hammer Health Sciences (HHSC)
Kolb Psychiatric Institute Annex
Mailman School of Public Health (Bldg. 722) |
Green
|
Russ Berrie Pavillion
Lasker BioScience Park
Audubon II |
Orange
|
State Psychiatric Institute
|
Blue
|
14. How do I get additional waste labels?
You can obtain waste labels by:
Checking the appropriate box on the Hazardous Waste Pick up form
E-mailing your lab safety officer or EH&S at ehs@columbia.edu
Calling EH&S at 212-305-6780.
15. Is it acceptable practice to label my waste “organic solvents” if all the waste solvents are compatible organic solvents?
No. While it is acceptable to collect compatible solvents together, each constituent must be listed on the label, which must contain the words HAZARDOUS WASTE.
16. I seem to always be adding to my hazardous waste storage container, can I leave it uncapped or with a funnel in the top?
No. Hazardous waste containers must be capped when they are not being filled. Laboratory supply companies sell funnels with caps that are suitable for this purpose. Contact your lab supply vendor or EH&S for more information.
17. How do I handle materials cleaned up from a manageable spill?
Materials cleaned up from a manageable spill involving a hazardous material must be handled as a hazardous waste. Therefore it must be collected, labeled and stored in the same manner as your other hazardous waste.
18. How often do I need hazardous waste training?
Within 30 days of initial hire and every three years thereafter. Training is conducted on a monthly basis (see EH&S website for training schedule) or it can be customized for your lab. Three-year refresher training can be done online via Rascal at https://www.rascal.columbia.edu/ .
19. How do I get rid of my mercury thermometers?
CUMC is striving for a mercury free pictures/environment and as part of our mercury free program, EH&S will exchange your mercury thermometer for a mercury-free one at no cost. If the use of mercury is compulsory, you must have a mercury spill kit in your lab.
20. When should I contact EH&S for waste removal?
<
Contact EH&S by faxing your removal request to 212-795-5847 when your waste container is 90% full.
21. How should I handle light bulbs from tissue culture hoods?
Contact Facilities Operations at 212-305-7367 for the removal of the fluorescent or UV bulbs from your tissue culture hood.
22. How do I handle pump oil, batteries, monitors and glass bottles?
Pump oil: Submit a hazardous waste pick up form for removal.
Batteries: Place batteries in battery recycling receptacles located in the hallways of every building.
Video monitors and glass bottles: Contact Facilities Operations at 212-305-7367 for removal.
23. How do I discard empty glass containers?
For containers that previously held acutely toxic substances, contact EH&S. For all other glass containers, deface the label by putting an ‘X’ through the label and then place container in a strong cardboard box labeled “Empty Glass Bottles/Containers” and have Facilities Operations (212-305-3753) remove it.
24. How do I get more wall guides and Health & Safety Manuals?
Contact EH&S at 212-305-6780.
25. Where can I get information on issues not addressed above?
You can obtain information on all lab safety issues by checking our website, http://www.ehs.columbia.edu/index.html, or by calling the EH&S office at 212-305-6780.
|
