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TABLE OF CONTENTS
INTRODUCTION I. DOES YOUR SCHOOL GENEKATE HAZARDOUS' W.;STE?
What Is A Hazardous WasGe? Listed Wastes Types of Waste by Characteristic Acutely Hazardous Wastes Waste Streams Commonly Geuerated by Schools -
11. DETERMINING YOUR CLASSIFICATION Very Small Quantity 'Generator
Small Quantity Generator Large Quantity Generator
111. REGULATIONS FOR VERI? SMALL QUANTITYSGENERATORS Regis tration Self-Transport Option Treatment /Disposal Options Record-keeping Accumulatlon Time Limits
IV. REGULATIONS FOR SMALL QUANTITY GENERATORS Summary of Steps to be Taken Accumularion Time Limits Obtaining an EPA Identification Number Shipping Hazardous Waste Off-Site Choosing a Transporter and Treatment Facility Preparing Wastes for Shipment Completing the Manifest
v. MANAGING HAZARDOUS WASTE ON PREMISES Accumulation Area Standards Container Standards Satellite Accumulation Emergency Preparation and Response
Equipment Prepare Your Employees Notify Local Authorities Emergency Coordinator Emergency Res pons e
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VI. A HAZARDOUS WASTE MANAGEMENT PROGRAM FOR SCHOOLS Purchasing Strategies
Inventory
Storage Waste Reduction "Milk Run" Transporter Service Other Applicable Regulations f o r Schools
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APPENDICES APPENDIX A - FEDERAL h STATE CONTACTS FOR ASSISTANCE APPENDIX B - GUIDE TO DETERMINING STATUS h REGULATORY
REQUIREMENTS APPENDIX C - HAZARDOUS WASTE CODES APPENDIX D - REGULATIONS APPLICABLE TO SCHOOLS APPENDIX E - REFERENCES
INTRODUCTION
The purpose of this handbook is to help educators and adminis- trators who are responsible for safe and proper disposal of hazardous waste in school systems to better understand and comply with federal and state regulations. The handbook will also help in designing a program for safe and environmentally sound management of hazardous substances.
In 1976, Congress passed the Resource Conservation and Recovery Act (RCRA), which directed the U. S. Environmental Protection Agency (EPA) to develop and implement a program to protect human health and the environment from improper hazardous waste management practices. The program is designed to control the management of hazardous waste from its generation to its ultimate disposal - from l'cradle-to-grave.tt or accumulating over 1,000 kilograms (2,200 pounds) of hazardous waste a month, the potential for environmental and health problems resulting from mismanaging even small quantities of hazardous waste became apparent. As a result of amendments to RCRA, new federal requirements were established that would bring small quantity generators of hazardous waste into the regulatory system. €PA regulations for small quantity generators became effective September 2 2 , 1986.
Although EPA first focused on large companies, those generating
Massachusetts, on the other hand, has regulated small quantity generators since 1983. Massachusetts is authorized by EPA to enforce its state hazardous waste regulations in lieu of federal enforcement within the state. State regulations may be more stringent but not less stringent than EPA's rules. In defining and Pegulating small quantity generators, Massachusetts Law has been stricter than federal law, in keeping with the principle that a densely populated, heavily industrialized state must take extra measures beyond the. minimum national standards. The extra measures are also to acknowledge the proportionally greater number Of small generators in Massachusetts than in other areas of the nation.
Chapter 21C of the Massachusetts General Laws authorizes the Depart- ment of Environmental Quality Engineering (DEQE) "to protect Public health, safety, and welfare and the environment, by comprehensively regulating the generation, storage, collection, transport, treatment, disposal, use, reuse and recycling of hazardous waste in Massachusetts." These regulations, codified as 310 CMR 30.000 (Code of Massachusetts Regulations), have been in effect since 1983.
New regulatory amendments were developed in Massachusetts with the goals of further strengthening, clarifying and extending the hazardous waste management regulations and ensuring that Massachusetts
maintains its authority to administer the hazardous waste program.
Environmental laws can be confusing. Those responsible for hazardous materials or hazardous waste would be well advised to learn as much as
possible about the regulations that affect them. While most educators are aware that many activities in their institutions involve the use of hazardous materials- chemicals in science laboratories and photographic studios, paints and solvents in art departments, and even cleaning supplies and pesticides in maintenance departments, to name a few - many may not realize that these,same activities produce hazardous wastes that make the schools subject to hazardous waste regulations.
As educators and administrators, it is your responsibility to know your legal obligation under the Hazardous Waste Regulations. You are liable for your hazardous waste and any damage it creates even after it leaves your site and is taken away by a transporter to a treatment, storage or disposal facility. You can be required 'to contribute to the costs of cleaning up any contamination resulting from your wastes wherever they are.
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The cost of waste disposal and liability coverage is escalating. Landfilling of many hazardous wastes is now banned. There are few commercial hazardous waste disposal facilities, and their capacity is limited.
Reducing the amount of your hazardous waste may be the most economical and environmentally sound approach to meeting your requirements. Substituting non-hazardous for hazardous products, modifying your process, segregatinq non-hazardous from hazardous waste streams, recyclinR your waste and better housekeepinK should be key considerations for you.
This handbook provides guidelines for the proper handling and disposal of hazardous waste in accordance with current regulations. However, it is not a substitute for the complete set of Hazardous Waste Regulations, 310 CMR 30.000, which is available for a small charge at the State House Bookstore. You can have it sent to you by 'calling 617-727-2834.
I. DOES YOUR SCHOOL GENERATE HAZARDOUS WASTE?
WWAT IS A HAZARDOUS WASTE? A waste is a solid, liquid or contained gaseous material that you .
no longer use, and either cecycle, throw away or accumulate until you have e n o w to dispose of'. A waste is considered hazardous if it has certain properties that could pose dangers to human health and the environment after it is discarded. These wastes are currently regulated by federal and state publid health and environmental. safety laws. The Department of Environmental Quality Engineering (DEQE) is the state regulatory agency that is responsible for regulating hazardous waste in the Commonwealth.
There are two ways in which a waste may be classified as a hazardous waste for regulations:
(1) LISTED WASTES - Your waste is regulated as a hazardous waste if it appears on any one of the four lists of toxic hazardous wastes or contains a contaminant in concentrations listed in Table 30.125 contained in the Massachusetts regulations 310 CMR 30.125-136. The regulations list over 400 hazardous wastes and are classified by EPA Waste Codes ?Df, v F f , ?MI, IK*, ? U t , ?PC. (See AppendixC.)
(2) CHARACTERISTICS OF HAZARDOUS WASTE - If a waste does not appear on the toxic hazardous waste lists mentioned above, it is regulated as a hazardous waste if it has one or more of the following character- istics: (310 CMR 30.120-125) A. IGNITABLE [DOOl] - It is flammable with a flash point of
60°C/1400F or less, such as solvents or solvent mixtures con- taining alcohols, ethyl ether, petroleum ether, benzene. Solids that may cause fire through friction or the absorption of moisture, such as sodium potassium metal, carbon powder, elemental phosphorus, and metal dusts.
Oxidizers, liquids and solids, such as chlorates, nitrates, peroxide and oxidizing acids.
.
B. CORROSIVE [DOO2] - It is aqueous or corrodes steel. (pH62.0 or 112.5) Examples are: Strong acids and bases, such as hydrochloric acid, nitric acid (40% or less), sulfuric acid, ammonium hydroxide, and sodium hydroxide,
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C.
D.
- REACTIVE [DO031 - It is unstable or undergoes rapid or violent chemical reaction with water or other materials. Friction or heat may cause explosion. A cyanide or sulfide bearing waste which when exposed to a pH between '2.0 and 12.5 can generate toxic gases. Any waste when mixed with water produces toxic gases. Danger: Opening or physically shocking old cans of picric acid or ether may cause explosions.
TABLE 310 CMR 30.125 - An aqueous chemical solution containing more than the concentration of the specified contaminants listed below:
Arsenic, 5.0 mg/l or more [DO041 Barium, 100.0 mg/l or more [DO051 Cadmium, 1.0 mg/l or more [DO061 Selenium, 1.0 mg/l or more [Dolo]
Lead, 5.0 mg/l or more [DO081 Silver, 5.0 mg/l or more [Doll]
Chromium, 5.0 mg/l or more [DO071 Mercury, 0.2 mg/l or more [DO091
ACUTELY HAZARDOUS WASTES - Wastes are considered to be lIacutely hazardous" if they are on the list of acutely hazardous wastes. (See 310 CMR 30.136.) These wastes are extremely toxic and are regulated more strictly tban other hazardous wastes. Acutely hazardous wastes, for example, may result from the use of certain pesticides or cyanide compounds. They also include dioxin-containing wastes. Wastes that appear in Appendix C beginning with lPC are considered acutely hazardous.
VAST€ OIL - Waste oil is regulated somewhat differently from other hazardous waste.. Call DEQE for details..
WHO CAN HELP IDENTIFY YOUR WASTES? For assistance in identifying your wastes, you may contact the
Massachusetts Department of Environmental Quality Engineering (DEQE), Division of Hazardous Waste, Compliance Assistance Office, 617-292-5898. This office can also provide you with a list of testing laboratories and hazardous waste facilities and transporters who may assist you in
identifying your waste.
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EPA WASTE NUMBERS FOR WASTE STREAMS COMMONLY GENERATED BY SCHOOLS
Many school departments carry on activities that generate hazardous wastes. Some of the more common types of wastes are listed below with their EPA Waste Numbers. See Appendix c for a further listing. complete listing,see 310 CMR 30.120-136.
TYPE OF WASTE Laboratories (Jr . H i g h , High and VocationallTechnical Schools) Solvents, solvent mixtures containing alcohols, ethyl ether, petroleum ether, benzene; sodium pQtassium metal, carbon powder, elemental phosphorua, metal dusts; oxidizers, liquid and solid, such as chlorates, nitrates, peroxide or nitric acid (30.122) Strong acids and bases (pH ~2.0 ora 12.51, such as hydro- chloric acid, nitric acid, ammonium hydroxide, or sodium hydroxide (30.123) A cyanide or sulfide bearing waste, which when exposed to a pH between 2.0 and 12.5, can generate toxic gases (30.124) Some spent solvents are F wastes
Auto Repair Shops (Vocational/Technical Schools) Parts Cleaners* Mineral spirits (petroleum naphtha) Immersion cleaner, cold parts or carburetor cleaner (a solvent blend)
*Even if this is recycled, it is considered a waste when shipped off site. Waste Oil and Grease Paint Wastes Paint thinners Paint wastes containing lead, nickel, or
chromium concentrations may be toxic (classification is based on a laboratory test)
Rust Removers
Antifreeze
Strong acid or alkaline solutions
Although not currently listed as a regulated hazardous waste, it is a special liquid waste and DEQE recommends shipping it as a hazardous waste
Machine Shops (Industrial Arts, Vocational/Technical Schools) Petroleum Naphtha (Mineral Spirits)* 'Even if this is recycled? it is considered a waste wnen it is shipped off site. Spent solvents used in degreasing, such as trichloroethylene, methylene chloride, l,l,l,- trichloroethane, carbon tetrachloride and chlorinated hydrocarbons, and sludges from the recovery of these solvents in degreasing
Spent solvent used as cold parts cleaner, typically used for cleaning carburetors
For a
EPA WASTE NUMBER
DOOl
DO02
DO03
DOOl
F002
MA01
DO01
DO08 ,DO07
DO02
MA99
DOOl
Fool
FOOZ
TYPE OF WASTE Graphic Arts, Photography, Printinq (High Schools,
Spent Solvents Used turpentine, mineral spirits, waste ethyl alcohol', isopropanol carbon tetrachloride, 1,1,1 trichlorethane,dichloromethane, methylene chloride; trichloroethylene waste ethyl benzene
Containers with more than one.inch of residue Ink or Paint Wastes with heavy metals
(may be toxic in certain concentrations) Ink with chromium of 5 mg/ or more Ink with lead of 5 mg/l or more
Containing silver (5 mg/l or more)
Vocational/Technical Schools
. Paint Wastes
Spent Photographic Wastes
Waste Ink or Ignitable Wastes Strong Acid or Alkaline Wastes Etch and Acid Plating Bath Wastes
Strong alkaline or acid solutions ~ 2 p H or112.5 pH gtrong acid solutions with chromium
To determine which code is applicable, refer to Massachusetts regulations 310 CMR 30.000.
Electroplating Wastes with Cyanides
Woodworking (High Schools, Vocational/Technical Schools) All of the wastes produced below are classified as ignitable:
Petroleum Distillates, Mineral Spirits, Used Paint, Varnish, Enamel and Shellac Remover,Sludge and Turpentine, Pigments, Alcohol, Paint Wastes and Thinners, Nitrocellulose (Gun 'Cotton) overspray residue, Polyurethane, Lacquer that will not be used
EPA WASTE NUMBER
l- ' Do01
EO01
. . F003 . .
DOG1 . . 1- -
DO07 DO08
DO11 DOOl DO02
DO02 DO07 F007-F012
Maintenance (All Schools)
Paint Wastes with any of the following ingredients: Ethylene Dichloride, Benzene (benzol ) , Toluene (toluol , Ethyl Benzene, Chlorobenzene, Methyl Ethyl Ketone (MEK) Methyl Isobutyl Ketone
Methylene Chloride Carbon Tetrachloride Trichlorotrifluorethane Toluene Xylene (xylol), Acetone Kerosene (fuel oil #l), Mineral Spirits (naptha)
Spent Solvents (cleaning or degreasing agents
DOOl
DOOl
F002 FOOl FOOl or F002 F005 F003 DOOl
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TYPE OF WASTE
Maintenance (All Schools ) ( Cont ' d . Strong Acid/Alkaline Wastes (corrosives)
Ammonium Hydroxide, Hydrobromic Acid, Hydrochloric Acid, Hydrofluoric Acid, Nitric Acid, Phosphoric Acid,.Potassium Hydroxide, Sodium Hydroxide; Sulfuric Acid
Waste Oil (gear or engine oil) Lawn Care Products
You will need to check your Material Safety Data Sheets (MSDS) for chemical names and propeties. The lists of regulated wastes (see Appendix C) are divided into two groups:
. discarded commercial chemical products acutely hazardous wastes (P group)
(U group 1
Empty Bags or Inner Liiers of bags containing residues of acutely
Debris from Clean-up of a spill of U group or P group wastes
hazardous waste
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11. DETERMINING YOUR GENERATOR CLASSIFICATION (310 CMR 30.351, 30.353) +
Two activities determine your generator category: rate at which you Renerate and how much you store (accumulate).
You are a VERY SMALL QUANTITY GENERATOR (VSQG) if you meet the following conditions and register with DEQE:
Generate any amount of non-acutely hazardous waste up to 100 kgs per month; Accumulate up to 600 kgs (about three 55 gallon drt!w) of non- acutely hazardous waste at any time; and Generate or accumulate no amount of acutely hazardous waste or any residue, soil, debris or linerdbags that are contaminated with acutely hazardous waste.
You are a SMALL QUANTITY GENERATOR (SQG) if you: *
ff
1
* *
Generate up to 1000 kgs or 2200 pounds (lbs) (about five 55 gallon drums) of non-acutely hazardous waste per month; Accumulate less than 2000 kgs of non-acutely hazardous waste in
containers at any one time, or 6000 kgs in tanks. If both tanks and containers are used, then the amount accumulated in containers may not exceed 2000 kgs, and the total accumulation may not exceed 6000 kgs ;
Generate less than 1 kg or 2.2 lbs of acutely hazardous waste per month; Accumulate less than 1 kg of acutely hazardous waste at any time; Generate less than 100 kgs or 220 lbs in a month of any residue, contaminated soil, water, or other debris from the clean-up of
a spill of acutely hazardous waste; and Generate less than 10 kgs or 22 lbs in a month of inner liners/ paper bags containing residue of' acutely hazardous waste.
You are a LARGE QUANTITY GENERATOR (LQG) if.you exceed any of the above. For a more detailed definition of a Large Quantity Generator and description of requirements, which are more strict than those for SQG, see the regulations 310 CMR 30.000.
*(See Appendix B - Guide to Determining Status and Regulatory Requirements)
CATEGORIES OF HAZARDOUS WASTE GENERATORS
tC3 KEY: (H = 1 barrel z about 200 kilograms of hazardous waste
which is about 55 gallons 100 kgs
- VERY SMALL QUANTITY GENERATORS
(220 lbs or approximately 25 gallons) a month of hazardous waste, and no acutely hazardous waste, you are eligible to register as a Very Small Quantity Generator (see page 6 for the generation and accumulation limits). To qualify as a VSQG you must notify DEQE on a designated form of the following:
If you generate less than 100 kgs
types and quantities of hazardous waste you generate
nhow you plan to recycle, treat or dispose of your waste
the name and location of any fa- cility or generator receiving your waste
See pages 8 and 9 for a summary of the options available to you.
SMALL QUANTITY GENERATORS
and less than 1000 kg (between 220 and 2200 lbs or between 1 and five 55 gallon drums) of haz- ardous waste and less than 1 kg of acutely hazardous waste in any month,,you are a Small Quantity Generator and are required to:
II Comply with the 1986 rules
If you generate more than 100
for managing hazardous waste, including the accumulation, treatment, storage and dis- posal requirements described in this handbook.
LARGE QUANTITY GENERATORS If you generate 1000 kg (about
2,200 Ibs or 300 gallons) or more
kg of acutely hazardous waste in any month, you are a Large Quantity Generator, an6 the federal and state hazardous waste laws 'require
. o f hazardous waste, or more than 1
you to: fi Comply with applicable hazardous waste management rules. (See 310 CMR 30.000)
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111. REGULATIONS FOR VERY SMALL QUANTITY GENERATORS (310 CMR 30.353)
Registration If you produce less than 100 kgs (220 lbs or approximately 25
gallons) a month of hazardous waste, and no acutely hazardous waste, you are eligible $0 register as a Very Small Quantity Generator. To qualify, however, you must notify DEQE on a designated form (see Figure 1) of the following: (Contact DEQE 617-292-5898)
Types and quantities of hazardous waste you generate How you plan to recycle,.treat or dispose of your waste
* The name and location of any facility or generator receiving your waste. IF YOU DO NOT REGISTER A S A VSQG, THEN YOJ ARE SUBJECT TO ALL THE SQG REGULATIONS, INCLUDING NOTIFICATION AND MANIFEST REQUIREMENTS.
- NOTE:
Self-Transport Option
As a registered VSQG, you may transport your own hazardous waste under the following conditions:
* *
*
* *
*
You transport only the waste that you generate on your premises You do not transport more than 200 kgs (446 lbs or about 55 gallons) at one time Your waste must be in containers that are: - no larger than 55 gallons in volume - compatible with the waste - tightly sealed - labeled as "HAZARDOUS WASTE". - labeled with the name of the waste and the type of - tightly secured to the vehicle transporting the waste You do not transport incompatible wastes in the same shipment In the event of a spill or leak of hazardous waste that may threaten human health or the environment, you notify your DEQE Regional office or the State Police (617-566-4500) and the National Response Center (1-800-424-8802), as described on page 19. You must have a copy of your VSQG registration with DEQE as evidence of the manifest exemption You must be in compliance with the federal Department of Transportation (617-494-2770) and hate Department of Public Safety (617-566-4500) requirements. You must have a permit from the Department of Public Safety to transport more than 21 gallons of flammable wastes (This is an important exception to the 55-gallon limit.)
hazard (e.g., ignitable)
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FIGURE 1
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PLPASL P R I N T on TYPE
DEQE REfXSIRATION HASSACHUSRTS VERY SMALL QuAKnn HAZARDOJS UASTE (iENERATOR
waa-iwo
N A Y I OF COMPANY U A M E Olr OUNER OR O P I R A T O R -
MA I L INC Aooness sriser C I T Y OR TORN I I P
XEltFiE5K-WURT UA-H- 6-
T ' P W s L I L
&I lons per month or recycling
H.A. . . . . . . . . . . I D (complete i f already assigned)
Hazardous Waste Disposal, storage, treatment &/or recycling Generated (check) prior t 0 t=ZlmXIt (Name company 6 address where waste I s taken
or type of treatment on site of generation) W A S T E OIL -
_I SOLVLNT
A e i m OR A L K A L I - O T H E R : (name)
I I CERTIFY UNDER PENALTY OF LAW that I have personally examined and am familiar with the information submitted In thu document and ail attachments and that. based on my inquiry of those individuals immediately responsible for obtaining the information. I believe that the information is true. accurate. and complete. I am aware hat there are significant pendtict for submitting fake infonna- tion. including possible fines and impricnrlmcnt.
D A T L 5 I GNED P R I N T N A M E
. .
a
Treatment/Disposal Options
As a registered VSQG you have the following options for handling your waste:
You may recycle or trieat the waste genera-ted on your site, provided the process you describe in your registration is acceptable to DEQE You may transport your waste to another generator who is in compliance with the regulations and who will count your waste as part of their genqration You may transport your waste in your own vehicle to a licensed treatment, storage or disposal facility, or permitted recycling facility, or You may use a licensed transporter and manifest form.
L
Record-keepinq If you are not using a licensed transporter but are transporting
YOUP own wastes, you do not need an €PA ID number or manifest form. You must, however, keep a record of the type and quantity, as well as the date, method of transport and treatment/disposal of your waste. You will need proof of the receipt of the waste by the facility or generator.
. .
If you use a licensed transporter to ship your waste off-site, you need an EPA ID number and must use and retain the manifest (as described on pages 13-15 for SQGs.)
You must keep receipts or manifests of waste shipped and records of waste analysis for at least 3 years, or for the duration of any enforcement action by DEQE.
Accumulation Time Limits You may accumulate up to 600 kgs (165 gallons or approximately
three 55 gallon drums) of hazardous waste in cantainers that meet .
the standards on page 16, with no time limit.
IV. REGULATIONS FOR SMALL QUANTITY GENERATORS (310 CMR 30.351) .If in one month's time you produce 100 kga or more (220 lbs or
approximately 25 gallons), but less than 1000 kgs of non-acutely hazardous waste as listed in Appendix B, you are.considered a Small Quantity Generator (SQG).
WHAT STEPS MUST BE TAKEN TO COMPLY WITH THE LAW?
After you have identified your hazardous wastes and determined
Use a licensed hazardous waste transporter and treatment,
Use a uniform hazardous waste manifest as a shipping document.
your generator status, to comply with the law you are required to:
Obtain an EPA Identification Number.
storage, or disposal facility.
This may be obtained through a licensed transporter or manifest printer. (See p. 13.)
and the hazards associated with it and the date when accumu- lation began in each container.
* Accumulate your waste by category in separate containers which are tightly sealed and provide appropriate aisle space accord- ing to National Fire Protection Association code for.container storage of ignitable or reactive waste.
Label your waste as hazardous waste, describing the waste
Observe time limits on accumulation of hazardous waste. * Comply with requirements governing emergency procedures, prevention and response.
Obtaining An EPA Identification Number (310 CMR 30.303) Massachusetts requires that any-school or business which generates,
transports, treats, stores, uses, or disposes of hazardous waste must notify the Federal government and the Commonwealth of Massachusetts of its activity.
To obtain your U.S. EPA Identification Number, call or write the Massachusetts Department of Environmental Quality Engineering (DEQE), 617-292-5898, or the EPA regional office (see Appendix A),and ask for a copy of Notification of Hazardous Waste Activity. You will receive the form with general instructions as to how to complete it. Figure 2 provides
a sample copy to show you the kind of information"required. The information requested covers your school site ("installation")
and your hazardous wastes. The school must operate as one site, meaning that all hazardous waste activities at the same address must be coordinated.
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1 I I I I I I I I I I I I I I I I I I I I I I I 1 I I I ii I I II I I ti I r j 1TiITliTj
1.
II.
111.
N.
C i or Town a t e Do-
PRINCIPAL ACI'M'IY 4 digit SIC number Description
V. INnALlATlON CONTACI' rime" Name Ih. h a , Qrrrodr) * I1 I i I I I I I I 1 I I I I I I 1 I I I T m i 1TI"l
VI. OWNERSHIP
f and U codas - Harrrdous Uartts f r a C o n - S k l f l c Sources. See 30.131.
U codes - Uarardous Uastcs from Specific Sourcrr. kt 30.132.
U codes - Comercia1 thtrcical Product Hazardous t!astes. See 30.133.
11171 11111 11171
P codes - Acutely Hazardous Uastcs. See 30.136.
c COMMENTS
,. CERTIFICATION
- To complete Item VI1 of the form, you need to identify your hazardous waste by the EPA hazardous waste number. Appendix B contains waste types and their EPA hwrdous waste numebrs. If you cannot match YOUP wastes with those listed, seek help from one of the sources listed in Appendix A.
i
Complete one copy of the form for each school address where you generate or handle hazardous wastes. Each site or location will receive its own U.S. EPA Identification Number and will stay with that site or location. If you move to another location, you must notify EPA or the state of your new location and submit a new form.
The ttprincipal activity" at the site is assigned a four-digit Standard Industrial Classification --wSICn-- which best fits your installation, e.g., Jr. High, High and Vocational/Technical Schools - 8221, Colleges and Universities - 8211.
The completed form must be certified and signed by the authorized representative of your installation. An **authorized representative" is a person responsible for the overall operation, for example, plant superintendent or central coordinator.
After completion of the Notification of Hazardous Waste Activity Form, send it to:
EPA Region I Waste Management Division MA Waste Management Branch
John F. Kennedy Federal Building Boston, MA 02203
HRR - CAUS
YOUP number will be mailed to you within a few months. If you need to dispose of hazardous waste while you are waiting for a permanent ID number, you can obtain a temporary number over the phone by calling
D E W at 1-800-343-3420, The temporary number is good for one month, or 30 days, if you have just a one-time collection or a spill. It is good fop six months, or 180 days, if you have applied for a permanent number.
Your identification number is specific to your location, not your
hazardous waste. There is no charge for either the temporary or permanent ID -
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Shipping Hazardous Waste Off-Site ( 310 CMR 30 - 304 , 30- 305 ) . waste off-site. You must (1) choose a hauler and facility which have EPA Identification Numbers, (2) package and label your wastes for shipping, and (3 ) prepare a hazard- vpste manifaat-
(.. #.
There are three steps that must be carried out to ship your hazardous
(1) Choosing a hauler and facility - Carefully choosing a hauler and designating a waste managaamt facil ity is -important- Although a .-
- hauler must be licensed to handle your wastes, you are still held -- -
. responsible for assuring that waste is disposed of properly. The waste
management facility will be the final destination of your hazardous waste for treatment, storage,*or disposal
Some transporters are authorized to assist small quantity generators and are identified on the list provided by DEQE. A list of licensed transporters and Massachusetts treatment, storage or disposal facilities (TSD) is available from DEQE by calling 617-292-5882. Note that prices vary among the transporters, and-it is advisable to check out more than one.
( 2 ) Labelling your hazardous wastes for shipment - All hazardous waste must be transported in containers that are labeled with the
words llHAZARDOUS WASTE", the name of the waste (e-g., waste oil, acetone), type of hazard(s1 (e.g., ignitable, toxic, dangerous when wet), generator's name, address and EPA ID Number, in compliance with the federal regulations administered by the Department of Transportation.
Your hauler should be able to assist you. If you need additional
,information, you may wish to consult the requirements for packaging and labelling hazardous wabtes found in the Department of Transportation (DOT)
regulations (49 CFR Part 172). (3) Preparing a hazardous waste manifest (310 CMR 30.310) Massachusetts and federal law require that DEQE track hazardous
wastes which are generated, stored, treated, used or disposed of in the Commonwealth from "cradle to grave". A computerized system traces each waste shipment by a special shippinB document called a MANIFEST from its point of generation to its final destination. To comply with
the regulations, it is necessary to:
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Obtain a hazardous waste manifest - For a shipment of waste destined for disposal in Massachusetts, a Massachusetts manifest form with a pre-printed MA document number is required. (See Figure 3 . ) For shipments within New England, either the MA form or the destination state's form (ME, CT, NH, VT, RI) can be used. If the waste is being shipped to a state outside of New England., that state may require a different manifest.
obtain manifests in bulk from the following printers: Many transporters will provide a manifest, but you can also
* Certified Business Forms, Inc e , Newton, MA (617-969-055U) Moore Business Forms, Inc . , Wellesley , MA ( 617-431-6405 1 Unified Data Products, Nashua, NH (603-889-2192)
Your waste must also be shipped in accordance with federal transportation regulations, (CFR Title 49, Part 100-1771, which can be obtained at the JFK Federal Building Bookstore in Boston ( 617-223-6071 1 the description of waste required in Line 11 of the manifest, Your transporter or facility will also be able to provide this informatioi e
Bart 172.101, Hazardous Materials Table , provides
* Complete the manifest - The most'common problems in completing the manifest are clerical. For clarity, as this is a multiple carbonless copy form of 8 pages, typinK is strongly recommended. The generator should check for legibility of all copies before transferring the manifest to the transporter at the time of '
shipment. The generator must ensure that all information is complete and accurate. Make sure that you can answer correctly the following questions:
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- Is your federal identification number correctly Stated? - Have you checked the identification number of your trans- porter and receiving facility? Do they each hold a valid hazardous waste license? To do this, call DEQE (6171292-55761 or refer to your list of licensed transporters and Massachusetts treatment, storage or disposal facilities.
e ,
- Is there to be a second transporter? The generator has the responsibility to select this transporter and to complete Line 7, including Blocks E and F. Line 18 will be completed by the second transporter. Can you certify that you have a program to reduce the volume and toxicity of waste generated? This is a national requirement of all generators and is intended to encourage good management practice. Large quantity generators are required to report how they are reducing waste in their annual report. Can you certify that the contents of this shipment are fully and accurately described, packed, marked and labeled? The waste number in Block 1 should correspond with the waste codes listed in your Notification of Hazardous Waste Activity Form. Are there any special handling instructions? The generator can list an alternative receiving facility in Line 15. If more than four wastes are included in a single shipment, a second pre-numbered manifest must be used. When more than two transporters are used for one shipment, an 8-part Massachusetts Continuation Sheet, numbered to match the first manifest, should be used.
.
Use and distributethe manifest - Instructions regarding the use and distribution of the manifest copies are stated on the back of the manifest. The generator retains Copies 6, 7 and 8 at the time of shipment. Copy 6 should be mailed to the manifest office of the state in which the destination facility is located. If it is in
Massachusetts, both copies 6 and 7 should be mailed to: I
DEQEI DHW Manifest Section 1 Winter Street Boston, MA 02108
.. Copy 3, signed by the hauler and designated facility, is returned to the generator by the receiving facility when the shipment arrives.
-14- .
.I
I?
6 e e
a C 0 i z 01 E
0.
0 P) cn (D 0 c -
,
EPA form 8700-22 (Rev 4-85 Previous addition is obsolete)
C O P Y > % : D E S T I N A T I O N S T A T E - R A I L E D B Y T S D F
New federal regulations require that you keep Copy 3 and Copy 8, as well as any records of tests and analyses done of your hazardous waste, for at least 3 years, and for the duration of any enforcement action. If a signed manifest copy from the destination facility
is not received within 35 days, the generator must investi- gate and fi'le an Exception Report with the DEQE Enforcement Section within 45 days of shipment, if Copy 3 has still not been received.
Time Limits on Accumuiation (310 CMR 30.351 ( 5 ) 1 As a Small Quantity Generator, you may accumulate up to 2000 kgs
(4400 lbs) in drums, or 6000 kgs in tanks, for as long as 180 days before you are required to ship your waste. If both tanks and containers are used, then the amount accumulated in containers may not exceed 2000 kgs, and the total accumulation may not exceed 6000 kgs. The 180 day clock does not start until after 100 kgs are,accumulated if the containers are redated at that time.
.
NOTE: Large Quantity Generators have a 90 day accumulation time limit, and no volume limit.
c
-15-
,V. REQUIREMENTS FOR MANAGING HAZARDOUS WASTE ON PREMISES
A. ACCUMULATION AREA STANDARDS (3lQ CMR 30.351 (8 )
conditions for both containirs and tanks: Your accumulation or storage area must meet the following
. * Q
*
#
Above-ground tanks and containers must be on a surface which does not have any cracks or gaps and is impervious to the hazardous wastes being stored. Area must be secured,against unauthorized entry. Area must be clearly marked (e.g., by a visible line or" tape, or by a fence) and be separate from any points of generation.
Area must be posted with a sign: "HAZARDOUS WASTE" in capital letters at least one inch high. Each such sign shall meet the guidelines set forth in the National Fire Protection Association's Code No. 704. An outdoor area must have secondary containment, such as a berm or dike, which will hold any spill or leaks at: - either 10% of the total possible contained volume of the containers and above-ground tanks, or
- 110% of the volume of the largest container or above- ground tanks, whichever is larger.
Any spillage must be promptly removed. (In general, if the hazardous waste being stpred has no free liquids, no pad or berm is required, provided that the accumulation area is sloped, or the containers are elevated.)
B. STANDARDS FOR CONTAINERS OR TANKS !310 CMR 30.680) Each container must be clearly and visibly labeled throughout the period of accumulation with the following: - the words ttHAZARDOUS WASTEtt - the name of the waste (e.g., waste oil, acetone) - the type of hazard(s) Ce.g., ignitable, toxic,
- date on which the accumulation began dangerous when wet)
* Each container must be in good condition. * Wastes of different types must be segregated. For example, this includes not mixing waste oil or used fuel oil with other wastes. Be careful not to put incompatible wastes in the same container or put wastes i n unwashed containers that previously held incompatible wastes.
* Separate containers of incompatible wastes by a berm, dike or similar structure. Each container holding hazardous wastes must be safely closed throughout the period of accumulation, except when the waste is being added or removed.
-1 6-
I- C.),
Containers holding ignitads or reactive wastes must be at . least 15 meters (50 ft.) from the property line, or if this
is not practical, you must be in compliance with all local ordinances ard by-laws.
any leaking or deterioration of your containers. You must have enough aisle space between your containers to allow for inspections.
Inspect your accumulation area at least once a week for
C. SATELLITE ACCUMULATION (310 CiR 30.351 (4) ) The Satellite Accumulation provision applies to SQGq and LQGs.
It offers additional flexibility by allowing you to accumulate up to 55 gallons of hazardous waste, or one quart of acutely hazardous waste, at each point where you generate your waste if you meet the following conditions:
* The waste must be generated from a process at the location of the satellite accumulation.
* Each satellite accumulation area can have only one container in use at a time. Each satellite accumulation area must be managed by the person who is directly responsible for the process pro-
- ducing the waste. Within 3 days of when the container is full, the waste must
The container must also be labelled per 310 CMR 30.682 (no be moved to the main designated accumulatiop area.
date required).
D. EMERGENCY PREPARATION AND RESPONSE (310 CMR 30.351 ( 9 ) )
A Small Quantity Generator shall comply with the following require- ments governing emergency procedures, prevention, and response: Equipment
To minimize the risk of fire, explosion, or release of hazardous wastes that may contaminate the environment,.you are required to have on site, and immediately accessible to your hazardous waste handling area, the following (unless the hazards posed by your wastes do not require one of them):
an alarm or communication system which can provide emergency
a telephone, two-way radio or other device which can summon
* portable fire extinguishers and/or fire control equipment
instruction to employees
police, fire or emergency response teams
(e.g., foam, inert gas), and spill control/decontamination e quipmen t
or water sprays, or foam-producing equipment adequate supply and pressure of water, automatic sprinklers
-1 7-
All your equipment must be periodically tested and properly maintained so it will work during an emergency. Prepare Your Employees
the waste handling and emergency procedures that Piay be needed for each of their jobs. An employee must have immediate access to alarm or com- munication devices, either directly or through another employee, whenever hazardous waste is being handled. If your operation is at any time being handled by a sing14 employee, that person must have im-
You must thoroughly familiarize each of your employees with all
mediate access to a telephone or two-way radio. For easy movement of employees and emergency equipment, you must
maintain adequate aisle space in the area of hazardous waste handling. Mark all exits clearly,
Notify Local Authorities
You must make every reasonable attempt to carry out the following arrangements in regards to the waste you produce:
* Familiarize your police department, fire department, local boards of health, and any emergency response teams with the hazardous nature of your waste; the layout of your site, in- cluding entrances and evacuation routes, and the location where your employees usually work.
and the types of injuries that could result from any accidents.
Obtain agreements with emergency response teams and contractors, and local boards of health. If more than one police and/or fire department might respond to an emergency, make an agreement with the department which will have primary emergency authority and specify others as support .
If any of the above refuse to make agreements with you, you must maintain on file a signed copy of a letter which demonstrates you made the attempt to make such arrangements.
* Familiarize local hospitals with the hazards of your waste
Emergency Coordinator You must designate at least one employee to be on call (or on
the premises) at all times. This person is the emergency coordinator and is responsible for coordinating all emergency response measures.
-18-
EmerRency Response
,
generation area the followipg: You must have posted next to each telephone near your waste
name (s 1 and telephone number ( 8 ) of your emergency coordinator ( s * location(s) of the fire control equipment and any fire alarms telephone number of the fire department, or if there is a direct alarm system,linstructions on how to use it evacuation routes, where applicable
If any of the following emergencies occur: Fire - attempt to extinguish the fire and/or call the fire department Spill or leak - contain the flow as quickly as possible and as soon as is practical clean up the waste and any soil or other materials which may have become contaminated with waste
explosion of hazardous waste that may threaten human health or the environment - call the appropriate DEQE Regional Office, or - call the State Police (617/566-4500) if the incident occurs after 5 pa., or on a day that DEQE is. closed, and
- call The National Response Center's 24-hour toll-free number
?
* A release (spill or leak) or threat of release, fire or
(1-800-424-8802)
VI. A HAZARDOUS WASTE MANAGEMENT PROGRAM FOR SCHOOLS
The following pages may apply to your science labs, art studios,
vocational ahops, maintenance and other departments. To ensure compliance with hazardous waste regulations, the school must operate as one site, meaning that all hazardous waste activities at the same address must be coordinated.
The Department of Envi,ronmental Quality Engineering ( DEQE) recommends that each school establish a hazardous waste management program that:
identifies all sources and types of hazardous waste at
* calculates the total volume of hazardous waste generated
establishes routine storage, disposal and record keeping
designates a central coordinator
the school h
monthly
procedures, as well as emergency plans
It is important to point out, however, that reducing the amount of hazardous waste generated may be the most effective approach, both
economically and environmentally, to dealing with 'the problem of hazard- ous waste disposal. Some strategies for accomplishing waste reduction and economical transport of those wastes that cannot be avoided are discussed below.
Purchasing Stratenies As recently as 1985, it was estimated that 40% of hazardous
wastes from laboratories consisted of unused chemicals. These unused chemicals represented inventory against which two costs were assessed - the initial purchase price and the charge for proper disposal 0 but for which no value was actually received.
' Many experimenters, wanting llfreshtf chemicals for their projects,
open new containers rather than take supplies from the remainder in a
previously opened one. Containers with only a smiil amount of contents removed accumulate until their contents deteriorate and become waste for disposal. This mode of operation negates all the economic advantages of bulk purchasing. Rather, it adds unnecessary cost and more risk of accident and injury.
Under these circumstances, purchasing chemicals in small-volume Units is better - more economical - especially if the SMll-VOhlme units can be tailored to experimental needs.
-20-
--
Inventory
A good inventory of often not cost effective create storage and waste
all chemicals is important to maintain. It is to take advantage of a sale of chemicals and problems later. Purchase only what is needed.
Combine orders with all departments to reduce duplication. An up-to-date inventory will help prevent excessive purchases.
The chemical inventory system should also indicate proper storage, whether the substance appears on the Massachusetts Substance List under the Right-to-Know Law, whether any waste is a hazardous waste, and any other information that you may wish to include, such as NFPA Codes, whether the substance is a carcinogen, etc.
Storage
r
Chemical companies are now required to provide certain safety information on labels. Most labels will give proper storage instructions and color codes.
Color codes vary among companies, but there are five general categories for storage: (See Figure 4.)
1. Flammable hazard - red 2. Health or toxic hazard - usually blue 3. Reactive hazard - yellow 4. Corrosive hazard - white 5. General storage - orange, green or gray
.
others of its class. A striped label generally means the chemical is not compatible with
Such storage information can be helpful in providing information on .hazardous waste storage. .
Hazardous Waste StoraRe
Although regulations provide characteristics for wastes and waste codes, storage should conform to DOT, NFPA, and general safe storage techniques as recommended by chemical companies. Material Safety Data Sheets (MSDS) may be helpful in providing storage Znformation but are not always accurate. For example, Potassium Nitrate is an oxidizer and is therefore an ignitable hazardous waste (D001). Petroleum Ether is also an ignitable hazardous waste (D001). Certainly, 'oxidizers should never be stored wi$h ignitable materials. Hazardous waste codes and characteristics are not necessarily good indicators of proper storage.
-21-
FIGURE 4
2, DANCER: Uquid~~ opot be moderately herfad before ienium n=u -CUT or ~ o i i d ~ thrrt gits off n-18 V I L ~ ~ .
ated before igr; f t ion
4. EXTXEPE DANGEZi: Erplosipc at room temperature,
3. SEVERE HAZARD: Short exposure could cause serioua injury,
2. MODlERBTE EAZJUD: btense or
3, SEVERE DANGER: Mar be erplosive if shocked, heated under confinement, or mixed w i t h water.
chemical change or react violently w i t h water.
heated or mixed with hater.
--• 1. SLIGHT HBZAKD- Hay cause
0. No particula health effect,
2 - L: Protective equipment
irritation o r minor injury,
l e SLIGHT DAN-* react if --e
required. 0. Stable and not reactive with water,
= oxu>IzEIEIs COB = c o m v ACID = ACIDS $T = U S E N O W B T E B
ALE - ALKALIS e - RUUTXON HAZARD
m
Waste Reduction
Waste reduction not only makes sense for environmental and personal safety, but it makes economic sense as well. There are considerable savings to be gained from waste reduction in two areas: (1) Less generation of waste means less cost for waste removal. (2) Less generation
of waste also means more efficient usage of chemical stocks. Thus, purchas- ings costs are also less. Waste Reduction Methods:
1. Reducing amounts of raw materials needed by using the minimum amount of hazardous materials which will accomplish the task. Do not make extra solution but try to make and use just what is required for results. Frequently, amounts of chemicals in
laboratory experiments can be reduced by half or more aithout affecting the results. Hazardous solvent usage can be reduced by substituting non-toxic substances.
2. By having students work in pairs, waste generation is halved. Thus, the cost of removal is halved.
3 - The use of micro scale quantities of materials is very cost effective, but the initial cost of the glassware is expensive.
4. In some cases, products of one laboratory experfimentcan be used as raw material for another experiment. Thus, the products of an experiment may not necessarily be a waste as defined in 30.010.
5. Exchanging unwanted chemicals may be beneficial but poses a number of problems, such as the liability of transporting hazardous materials, danger from using contaminated chemicals, and finding someone willing to accept your unwanted chemicals. Within the same establishment it may be easier to exchange chemicals. Surplus acetic acid from chemistry laboratories can be used by photography for stop baths. There are a number of cherricals which can be exchanged in this way.
6. Substituting non-hazardous chemicals or less hazardous chemicals whenever possible can contribute to safety as well as to waste reduction. It is important to select laboratory manuals that call for less hazardous chemicals and for chemicals in smaller amounts e
-22-
nMilk-Runtt Transport Services
Licensed hazardous waste disposal facilities are often great
distances from sites of generation. Consequently, transportation costs can become more burdensome than disposal costs, especially for small quantity generators. Recognizing the need to supply an affordable service that would encourage and support conscientious efforts to comply with accumulation and disposal regulations, some transporters offer *'milk-runw services to their SQG customers.
In a milk-run program, small quantity generators with similar wastes for disposal are scheduled for pick-up in such a way that the transporter can make one liswingn through a given geographical area, stop to load hazardous waste shipments at several locations, then continue on to one disposal facility where all shipments are received. While each individual generator continues to bear the full disposal cost for his waste, transportation costs are shared between milk-run participants on a pro- rated basis.
Ability to participate in this kind of a cost-saving program depends on the kind of waste you have to dispose of and the number of other generators with that kind of waste in a geographical proximity that makes the program economical for the transporter also. Transporters will insist on strict adherence to rules by all who qualify for participation so that no regulatory discrepancies jeopardize this joint transportation-disposal arrangement. Rules about segregation of waste, proper packaging, labelling and marking, and accurate manifests must be obeyed. Usually, assistance is available .from the organizing transporter.
+
To find out which transporters to contact for additional information about milk-run programs, consult the Massachusetts Hazardous Waste
Transporters List, available from DEQE, 1 Winter Street, bSton, MA 02108. Waste Authorization Key number 3 identifies the transporters in your region servicing small quantity generators.
-23-
Other Applicable Remlations for Schools
It behooves educators and administrators responsible for the safe and proper disposal of hazardous waste t o understand and fully
comply with federal and state regulations. In addition to Hazardous Waste Regulations 310 CMR 30.000,
environmental regulations tqat are applicable to schools are codified in Department of Transportation (DOT) regulations , . National Fire Protqction Association regulations, three sets of Right-to-Know regula-
tions, the community Right-to-Know requirements of the amended Federal Superfund (SARA Title In), the worker Right-to-Know provisions ad- ministered by OSHA, Clean Water Act requirements, the Federal Superfund, Occupattonal Health and Safety standards, and municipal and local standards. (See Appendix D) .
For more information or assistance in understanding your particular situation.relevant to these regulations, contact DEQE
- .. ..
Compliance staff at 617-292-5898.
-24-
P Pr
\
/ -
P' bi I
- - APPENDIX A
FEDERAL HAZARDOUS WASTE CONTACTS FOR ASSISTANCE
EPA REGION 1 . Waste Management Division -MA Waste Management Branch
JFK Federal Building HRR - C A W
RCRA/Superfund Hotline
National Response Center 1-800-424-9346
1-800-424-8802
BOstm. MA. 02203 Department o f Transportation
617-573-5740 617-494-2770
STATE HAZARDOUS WASTE CONTACTS FOR ASSISTANCE *
DEQE MAIN OFFICE Division- of Hazardous Waste 1 Winter Street Boston 02108
617-292-5898
DEQE REGIONAL OFFICES
Metro BostodNortheast 5 Commonwealth Avenue Woburn 01801 617-935-2160
Cent r a1 75 Grove Street Worcester 01605 617-792-7653
Southeast Lakeville Hospital Lakeville 02346 617-947-1231
Western P.O. Box 2410 Springfield 01101 413-785-5327
For more information: -Notification Form, EPA ID No., Waste Identification, List of Certified Testing Laboratories (DEW)
List of licensed transporters (DEQE) Manifests: .
Certified Business Forms, Inc. Newton Moore Business Forms, Wellesley Unified Data Products, Nashua, NH
State Police
Department of Public Safety
MASSACHUSETTS HAZARDOUS WASTE REGULATIONS ( 310 CMR 30.000 State Book Store, State House
617-292-5898
617-292-5822
617-969-0550 617-431-6405 603-889-2192 617-566-4500 617-566-4500
617-727-2834
4PPENDIX B BUIDE TO DRERIIIIIYG STATUS Aw) REGUUTORI REqUlRolUrTS
Dcflnlt lans: bnrcrs lanr :
--e
Regulatory Kiloyraas/ K I lograms Gal Ions Status Mwith (met r l c 1 (varies by substance) VsqS sqs LW
= l&glstrat lon Is requlred
less than 100 IO0 25 - 27 150 - 165
IO00 o r more 1000 250 - 270 2000 500 - 550 6000 1500 - 1650
100-999 600
[Exception:. Qlde does not apply t o acutely hazardous waste.)
i i
No l ln i t No l lnit
L l i m i t ti0 l i m i t
No l i m i t No l i m i t
a 0 0 2ouo
6000 2000
6000 2000
600 1 6CO I
.i ------ L--- .- UUQLE:
Your business produces 10 gallons of solvent and 500 gallocis o f waste o i l each ronth. To determine"your EPF Status atid the standards by wliich you mist manage your Iraste:
Yes" j i Yes i Yes I
1. Translate your galloits o f each type of waste t o a "Rcqufatory Status": I O gals. less than 100 kllograms = VW of hazardous waste
500 gals. = amre than I.OOC kllograms = LQG o f waste oil 2. Flnd your appropriate I lne. looking a t Column 1. (Line 3) 3. Read across Line 3 t o determlne:
your EPA Status = VSQG. wlilch w i l l be entered on l i n e V l l l nf the Application fo r €PA Ident i f icat ion Number. (Colunn 2) the length c f time you can accumulate your solvent (unlimited). the raxi tnum amcuitt you caii accuinulale a t any one tim (600 kgs) lColuain 3) and your waste o i l (you rust ship wfttifn 90 days and you have no liniit i r i the volume you CJII accunulate. (Co1un.n 4 ) You rus t Panlfest your waste o i l but you may self-transport your solveut i f YOU rcc1istc.r a 5 a VW. You are required lo m e t the accumulation area staridards and eaergency preparatioli requireiierits. (Colunm 6)
(Colun 5)
NOTE:
- If both hazardous waste and waste o i l are accuarrlclted, the t o ta l waste wliicli can be accun.ulated a t ariy one t i m e m y not exceed 6.000 kilograms for SQG's. or 600 kilograms fo r VSfJG'r.
- If an Sqc uses botli tanks and containers, Llie t o ta l waste which can be accunulilted a1 any one t ime may riot exceed 6.000 kilograms and w y not exceed 2.000 k i l og ram i n contaiiiers.
APPENDIX C
wn ................ Poo2,--, #H7.."..-..". WSB ,... Po68.-.-....
Pool, .-....-.
#)02....", ,. Po03.,.-. PO70.,- wo* .a_.....- Poos ..-...... WQB."..........". m 7 ...... " ........ moa ..... "......... #)09 ....-._. - PllS.. - w10 ...-...... w 1 1 ................ w 1 1." ......-. ma..., ......-. PO- ..... ..." ...... PO24 ...........,... PO77... "..""..." Po28 .I.............. w12 ................ W14 ......... ._ W15 ............... PO16 ................ PO17 ............... PO18 ................ PO21 ................ Pl23 ........... ~-. P103 .............. PO22 I...." ...-.. PO=.., ......-.-.
mi2 ....__..._
m i 2 .-.....-
w i 3 ...............
WZB ...._..._...
MA01
MA02
MA03
k.9#.hyd.. dlloro. Acotumde, N . ( F ) . Acotumde, 2.flwfo. Aae Kd. fiuor~., sobum rrrn Acmmdn .cia N-[(nwmyrar-
3 - ( . l o h . - k . w y r ~ ) 4 ~
1 -kmr+2-mK*ru krokn AlQcua A" wvc .Icoho( Alu"MlosP(ud. %&n"Otnylk3-MurOlor
Am" pcnto (R) A m " n n r d . t a Amona .ad
krwuc (v) one. krwuc p.ntOmd0
kun. Aardm
8 . m m . cbloro- Brp.nuM.. 44uirO. B.rrmn. (Chlcnxmlhyo- 13-8 .m. (~dm1. 4 4 Ihydrory.~.(momg.
8 .mwmOl 8.m mw. 8ofyIlwm dust Bb(chlorom0myt) o t tw 8fumoueton. erucnm c.lcnun cyHnd. cunomn.. OCtlChkm- cMunnndQI.(.noK .od CMOn krJlld. CMOn elsulflaa
bunoylkyl-. n w q ..1.r
md 8". whn o" a c o n c " m s Qutw U l M 0.3%
krrnr ( t q oad.
~ n m r
e-
Mno).myll-
HAZARDOUS
Nan-Specific Sources
Waste Oil
Wastes Containing PCB'sA 50 ppm
A mixture of spent solvents listed'under two or more . of the F001-FO05 codes. See p. of this list.
c
[Comment: For the convenience of the regu- lated community, the primary hazardous properties of these materials have been indicated by the letters T (Toxicity), R (Reactivity), I (Ignitability) and C (Corrosivity). Absence of a letter indicates that the compound is only listed for toxicity.]
Acutely Hazardous Wastes
H- wuto No. I
JASTE CODES
Hazardous Wastes Which Are Discard- ed Commercial Chemical Products O r Off-Specific Batches of Commercial Chemical Products o r Spilled Resi- dues of Either
These wastes and their correspond- ing EPA Hazardous Waste Numbers are:
-3-
HUWQouS w8StO NO.
0234 ....... -.... u021 ............... u202 ........ ....... U120 ..... .. ._... UO22 .u022-..... ...I... U197 .....-... uon .........I.... w50 .... I- ..... uo85 .....I.....
...............
U021 .-........... U O n .... .. ......... uog 1 ............... U095 .... -...- .... U024 ............... W27 .... ... ........ u 2 u ...-....... U028 .....I........ U246 ....... ..".... U225 .........._... UWO ............... U172 ._........ u12a ...-. U035.....--..
U031 .-........ u159 ....-- UlgO .-......- W53 ...-...... U074 ..........-.. u031 .....-.. u136 * . U032 --- una ..: ............ U178- U178..-- U l n........., U219 .....-- Uo07 . - U215-. u156 ............... UW3 .--..-.. u211 ..-.... uo33 ......- ". uo34....-....... uo35 I..-.. UW6 .....-....... uo26 ............... U037," -......... uo39 ..........,. U M l .... ........... uo*2 .......... I... uou ...........-. M46 .....-........ UM7 .--. uo40 .........I .... w 9 ......... .. .... u032 .... I......... uoso ....-.- U05 1 .....-........ uos2 .....I.. ". U052 ....-..-.., u053 .....-...... U055 ....... .. ...... U248 ............... U197 ............... uo56 ............... UOS7 ............." U130 ............... UOSB ............... U240 .............. .] uo59 ...............I
SUI)SUK.
Bontono. 1.3.5-"8+ (A.n ~onzleino 1.2-a.noro-. 1. l-dloxld. B.mo(i.kllluorm 8.nm[rlpyrw 3.4d.moWr.m p8cnrrwuncM B.ruocncMond. (C.R.T) 1.2.8mpnMMmrm 2 2 . ~ (1.T)
~-
( 1 , 1 * ~ ) 4 . 4 ' ~ (l.l'-6iprrmvr).*.#-. 3.3'drhW* (1.1 '-8iWHyr)J,4'd~. 3.3d1mo1hoy- (1,1'-Blpnmvt)-r,*.amm. 3.3.amemy1- B b ( l t h " 0 y ) momno B u ( 2 w ) .(h.r
6 W d " y I - m ) duulMo
B"o cyuwd. Bromotorm
Bi2lmylh.yl) ph".
i.saul.dmr. 1.1.2.3.4.cr~~~~- l g u u r u " . N W B u t w r ad. 6(8o (2u1 l~ rw tnp l )u l - 14ut~0I(I) 2-6utMoM(I.T) 2-Buurom p"da (R,T) 2 - B ~ t w 2 - h W ~ . 1.44chbm- (1.T) n-8uyl .Ichohol (I) c.ca6yllccrad klaum chromrt. csrbunc rad, .mvr osw Cubunr .ad -, a h y ~ esta cubur*d.. CMUnd.. "YcKnboSo. cuburrb.. Uwo. cubunay( chlond.. dinwmyl. cubonc rerd. -1) dt Cuaonocnondrc ' .oa lrrmyl m.r (1.T) CarBon oy(luond0 (R,T) CMOn u(I1chlond. cuboyr fiuond. ( R . 7 auoml Quonmk#l OlladM.. tlckncr) at- cNao#nzw v 1-2- 2chkramy( vmyi o m olraorwm C h l a 0 r " y l m.ayl 0- bou-m.m oChlomphrnor c C h l ~ 1 o l u d l M . hydrocnr-0 QvomK: a d dawn cbywlla h o s o t e cf..o)r c f o t o n ~ e w o Cu" (I) Qan0g.n bmmde 1 .-u- Qcm" (I)
Q u o o m s o w n
Duvlomyon
.ad
W M X M O l l O (I) 1 . 3 ~ l l C h e n 0 , lt3.4.5.5-h0~a- ChIm
2.444. saiu am m1.n
-4-
uO60...,,. Uodl.,.,., U142 ..._........ lJo62"..."-.". U133 .....- u221 ......I_
uO63 ......-. UO63 ...-..._ uo(y ....-........ u064 ............... W66 ....... .. .... .. UWQ ............... UO62 ............... W70 ....._....._. W71 .....- UO72 -........... WM .......-.... w74 ......__.
000 DOT o.UenlOtooCt.nyc)r(F 1 .3.--2H-
~ t . ( c . a l - P o n u l 8 f l - 2 - Di.ll.1. Dumcn (RT) Du" ~ l & n l u l l n m c o M 1 . 2 5 . 6 W o n z ~ ~ ~
~ n r [ u l ~ . n
Dtbucyl m8l.u
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Hazardous wastes from non-apccific aourcea.
Spent Solvents
APPENDIX D
REGULATIONS APPLICABLE TO SCHOOLS
hssacfiusetts Reuulations:
t~hss8chusetts Department of Environmental Quality Engineering Hazardous Waste Regulations (310 CMR 30.00) Right-to-Know Regulations ( 310 CMR 33 . 0 0 )
hsSt&ChUSettS Department of Public Health . .
Right-to-Know Regulations (105 CMR 670)
Massachusetts Department of Labor and Industry Right-to-Know Regulations (441 CMR 21.000)
Federal Reuulations:
Department of Transportation (40 CFR 262, 263, and 265); and (49 CFR Parts 173, 178 and 179)
Occupational Safety and Health Administration Hazard Communication Standard (29 CFR Part 1910.1200) Occupational Safety and Health Act, general industry health standards (29 CFR 1910) Proposed Rule: Occupational Exposure to Toxic Substances in Laboratories (to be codified at 29 CFR Part 1910.1450)
Environmental Protection Agency:
Superfund Amendments and Reauthorization Act (SARA) Title 111 (Emergency Planning and Community Right-to-Know Regulations) (42 U.S.C. @ 6901 et seq.) Clean Water Act (administered JDintly with Massachusetts DEQE) (33 U.S.C. 1251) Comprehensive Environmental Response, Compensation and Liability Act (Superfund) (42 U.S.C. @ 6901 et seq.)
National Fire Protection Associations: National Fire Protection Act Code 45
APPENDIX E
Allen, Ralph O., "Waste Disposa? in the Laboratory: .Teaching Responsibility and Safety," Journal of Chemical Education, Volume 60 Number 3, March 1985.
American Chemical Society, "Safety in Academic Laboratories," 1985.
Bayer, Richard, "Lab Safety as Collateral Duty in Small Colleges," Journal of Chemical Education, Volume 60 Number 10, October 1984.
Carlson, Kenneth, "Pire!," The Science Teacher, November 1985.
Coble, Charles R., and Paul B. Hounshell, "A Framework for Evaluating," - The
Environmental Protection Agency, Office of Solid Waste and Emergency Response, "Problems Associated with Management of Hazardous Wastes from Educational Institutions," Draft Report to Congress, Washington, D.C., September 30, 1987.
Science Teacher, 'May 1980.
Fawcett, Howard H., "The OSHA Hazard Commnvlication Standard or "Right-to- Know," Journal of Chemical Education, March 1986.
Fischer, Kenneth E., "Contracts to Dispose of Laboratory Waste," Journal of Chemical Education, Volume 62 Number 4, April 1985.
Gallagher, Barbara, "The ACS Chemical Health and Safety Referral Service," Journal of Chemical Education, July 1984.
Hanson, David, "Academic Labs Face Compliance with Emergency Planning Rules," C & EN, May 13, 1987.
Harmel, Coleman, "Safe Storage of Chemicals," Chem Safety, 1984
' Howard, Brian, "Laboratory Safety: More Important than Ever," July 1985.
Kasnoff, Craig, "Handle With Care,'! Campus Voice, Fall 1987.
Koeingsberg, J., "Avoiding Hazards in the Laboratory: Detecting and Correcting Problems," American Laboratory, July 1986.
Nagel, Miriam C., "Caution! Flammable Volatile Liquid," Journal of Chemical Education, Volume 62 Number 3, March 1985.
National Association of College and University Business Officers, "Hazardous Waste Management at Educational Institutions," Washington, 1987.
Pesta, Shelly, and James A. Kaufman, "Laboratory Safety in Academic Institutions," Journal of Chemical Education, October 1986.
Phifer, Russell W., "Laboratory Waste Disposal," Chem Safety.
s a ' Understanding MSDSs Your Right T o Know
Under the Massachusetts Right to Know Law and the OSHA' Hazard Communication Stand- ard youareentitled to receiveinformation about the toxlc substances thal are used or stored In your workplace. This information Is available to you In the form of a Material Safety Data Sheet (MSDS) - a technical factsheet that describes the heallh effects and safe uses of the toxic products on the job. The MSDS is written by the product manufacturer who must give it to your employer. In tUrn, your employer must provide the MSDS to you, your union. or your doctor upon request.
The purpose of this newsletter is to be a gulde to the sections of an MSDS and to help you become more familiar with the technlcal language you are likely to find. MSDSs may take many dlfferent forms, but the one used here is theone youwillseemost often. I t Isdlvidedinto eight s.ctlona. A few paragraphs of this news- Ielter are devoted to each section of the MSDS. and all the terms will be defined. Unless noted otherwise. both the Massachusetts and the OSHA standards require that each section be Illled out.
The Massachusetts Right to Know Law de- l i n r approximately 2000 chemlcals as loxlc. and these chemicals make up the Massschu- setts Substance Llst. Under the OSHA standard Ihere I8 a base llst of about 1200 chemicals: othar chemicals must be evaluated by the chomkal manufacturer to determine If they are toxic or hazardous. Any material sold to your employer that has any of Its ingredients covered by Ihe appllcable law is a regulated material I f ynu am exwsed in a reqijlated mstrrlr i ~ O I J are mtlttod to all the protection8 ot the law
There are t h r w sources of Information avail- able to you under both laws: 1) material safety dola s h w b (MSDS): 2) container labels: and 3) employee tralnlng. The MSDS is the most important because I1 is the source of informa- tlon for labeling containers and Is the basis for tralnlng employees on the hazards of workplace oxpoaureaandsefe handling practices for those chemlcrla.
No1 all manufacturer9 will report information in the same way on an MSDS. so It Is a good Idea to check all sections for all the details. For more information on health problems associated wllh overexposure. It may be necessary to look up the chemical in another source. Because'the MSDS may not be a compiele source of informa- lion on the chemicals with which you work. be sure to ark your employer or trainer any ques- tlona that are not answered on Ihe MSDS. MSDSs ofIen have blank spaces in sections that ahould be filled out. Your employer should return such an MSDS to the manufacturer for more complete information.
The Right to Know and OSHA laws require th~tyouremployertrainyou toreadan MSDS I f you have any turther queStlons about MSDSs or your rights under the law. as4 your employer, your union, your area Occupational Safety and Health Coalition (COSH group). or the Depart- man1 of Labor end Induslries
MSDSa can be very useful tools in carrying out the goals of these two health and safely lam. The main goal Is to prevent occupational disease by Informing people about the hazards 01 toxlc aubrtances. Learning chemical iden- tlIies. health effects and protectlon from the dangen l i a t d on an MSDS can put you In a bolter poaiIion to correct or prevent potential h w r d a .
- 'OIHA - Occupational Saloty and Health Admlnlatratlon: (h.(.d.~l~gmcythairtrllmitaon workers'ex!maunto a l " k l i a a n d ~ n l o ~ wOrkpiaCeh*alth and 8lf.tviawa.
SECTION I: Product Identitv
This section provides information you need to match the material safety data sheet with tNe corresponding product at the workplace. i t lists the manufacturer's (or supplier's) name and address as well as the product name as it appears on the container label and on the workplace chemical inventory, i f required by law.
Identity - This is the name of the product as it appears on the label and the inventory of hazardous chemicals (if your workplace is covered by the OSHA Hazard Communication Standard). The inventory is a list of all the hazardous chemicals used or stored in your plant. Under the Hazard Communication Stand- ard your employer must put this list together and update it regularly.
Manufacturer's Information - This infor- mation includes the manufacturer's name, ad- dress and phone number, the date the MSDS was prepared, and an emergency phone num- ber to call after business hours. I f you have any questions about the information on the MSDS or want to know how the manufacturer determined the hazards, call the office phone number and ask to speak to the person or department that prepared the MSDS. The emergency phone number should be used for obtaining instruc- tions in the event of an accidental exposure. Don't well for en emergencyl Cali ahead and find out what type of medical or other inlorma- !Inn !hoy c:c premred 1 1 ?!*le ycu.
SECTION 11: Hazardous Ingredients
This is the most important section of the MSDS and should give you the information you need to do your own investigation of the physi- cal and health hazards of the product.
I f the product is a pure. single chemical. no ingredients need to be listed. If the product isa mixture, all the ingredients that are regulated. with a few exceptions, must be listed here.
Under the Massachusetts Right to Know (RTK) Law this section need only list those ingredients on the' Massachusetts Substance List (MSL). If your workplace is covered by the OSHA Hazard Communication Standard, this section lists only those ingredients that the manufacturer has determined to be hazardous according to the definitions in the law. But. on a good MSDS all Ingredients should be listed. However. the two laws only require that the manufacturer list hazardous materials that make up one percent or more of the product. An exception to this rule Is for carcinogenic (cancersausing) and other extremely hazard- ous ingredients: under the Massachusetts RTK Law the mlnlmum that must be listed Is 1 part per million (ppm), and under the federal standard It
is one-thousand Ppm." The percentage cam- Position (parts Of ingredients per 100 parts of product) of each ingredient in the mixture Should also be listed: however. only under the Massachusetts RTK is this required.
It is important to get the exact spelling 01 the chemicaisso that you can look up their effects in a chemical dictionary. I t is also important to remember that chemicals that have very Similar names (and very similar structures) olten have very different effects on your health.
The CAS number. which stands lor Chemical Abstracts Service number. is the best way of identifyingachemicai with certainty. In general, each chemical has only one CAS number even though it may have several acceptabiechemical names.
The Massachusetts RTK Law requires the CAS number to be written on the MSDS lor each ingredient on the Massachusetts Substance List. The Hazard Communication Standard, however, has no such requirement. To find out !he CAS number. you shoulij ask your employer to contact the manufacturer, or you can call the Division of Occupational Hygiene (617-969- 7177).
Under the Hazard Communication Standard the MSDS must list the limits of each ingredient towhichyoumaybeexposed: theRighttoKnow Law has no such requirement. There are two exposure limits: the PEL and the TLV. The PEL is the permlaslble expoaure Ilmlt required by OSHA regulation: it is the maximum amount of a particular substance legally allowed in the workplace air. The TLV is the threshold llmit v r l ~ t a recnmmcns'cd by the .?. -~r i=~.? P3nfpr- ence of Governmental Hygienists (ACGIH); the TLV is not legally enforceable.
There are lots of other recommendations for exposure levels - lrom the National Institute for Occupational Safety and Health (NIOSH). lrom other countries and sometimes from the manu- facturers.
Remember: You can't always judge a chem- ical by its PEL or TLV because very few chemicals have been thoroughly tested for long-term health hazards. such as reproductive effects or the potential to cause cancer. There- fore, you should encourage your employer to make the lowest feasible level the standard ih your workplace.
SECTION 111: Physical Data
This section is important because i t gives you the basic information about chemical properties needed to decide how to Store chemicals. how to avoid or tight fires and how a chemical behaves. It also indicates what chemical slate(s) (Le.: liquid, gas or solid) you will find a product in at the process temperatures and conditions used in your plant. This is important lor predict- ing the most likely ways the chemical can get into your body (breathing it in, swallowing it. or absorbing it through the skin or eyes).
Boiling Point - This is the temperature a! which a liquid boils. Flammable liquids usually have a low boiling point which can present fire hazards. The boiling point, like the vapor pres- sure, is a good indication of how easily the product will evaporate and giveoff vapors. If the product is a mixture, the boiling point may be presented as a range (such as 10-30°C or 80- 1 OO'F).
Vapor Pressure - At any given tempera- ture, a certain proportion of a liquid will evapo- rate and form a gas. The pressure of that gas at the surface of the liquid is called the vapor pressure. The higher the vapor pressure, the moreeasilyaliquid willevaporateandcatch fire.
Liquid materials that evaporate easily are considered voiatlle liquids: this means that Sir concentrations of vapors can build UP quickly. even though the substance you are working with is in a liquid form. .., llnm i "". ,,,n.,nn,,.rnom *I I%
- SECTION 111 fc0nt.J
Liquids with high vapor pressures may be particularly hazardous if you are working in an enclosed or confined area
Given two liquids with the same toxiclty rating the most hazardous one will be the one with the higher vapor pressure.
Vapor pressure is measured in units Of milli- meters of mercury (mm Hg) - as is atmospheric pressure on barometers.
Vapor Density - This is the weight 01 a vapor or gas compared with an equal volume of air. A vapor density of less than one means that the substance wilt tend to rise in still air; a vapor density greater than one means that it will fall. Substances with higher vapor densities will concentrate in the bottom of tanks and other anclosed areas. Therefore, i f you are at the bottom of a tank, you would be likely to breathe more of i t in.
Solublllly - This refers to the percentage. by weight. of the substance that can be dis- solved in water. "Negligible solubility" means less than 0.1%; "slight" means 0.1% to 1%; "moderate" means 1% to 10%; "appreciable" means more than 10%; and "complete" means it can be dissolved in all proportions. Salt. for example. is soluble in water; oil is not.
Appearance and Odor - This information may help you identify the chemicals to which you are exposed in your workplace. It is impor- tant to use your nose, but don't depend on it. Keep in mind that odor or smell may be a poor measure 01 the amount of the substance in the air. Our noses are incredibly sensitive. We can detect very small amounts of some substances. However, Other substances can reach hazard- ous levels and still have no noticeable odor (carbon monoxide, for example). The olfactory nerve of the nose, which senses odors, can also IOSB its sensitivity over the years, even over a period of minutes or hours of constant stimula- tion. You may cease to notice or "get accus- tomed.to an odor over time. If this happens, you may be exposed to toxic levels without knowing it.
Specific Gravily - This is a comparison of the weight of a volume of material with the weight of an equal volume of water at 392°F. A specilic gravity greater than one means that the substance will sink in water; a specific gravity less than one means it will float. This inlorma- lion may be useful to figure out the concentra- tion of vapor following a liquid spill.
Melting point - This is the temperature at which a solid becomes a liquid under normal room conditions.
Evaporation Rale - This is another meas- ure 01 the votatlllty 01 a liquid (see Vapor Pres- sure). The evaporation rate of the material IS usually compared to either butyl acetate (a chemical which evaporates very slowly) or to ether (a chemical which evaporates very quick- ly). The chemical which is being used in the comparison should be noted. If the evaporation rate is greater than one. i t
means that the substance evaporates more easily than the specified comparison chemical. If the evaporation rate is less than one. this means that the substance evaporates more slowly than the comparison chemical.
The faster a liquid evaporates. the faster it gets into theair. and themoreof i t you are likely to breathe into your lungs. '
SECTION IV: Fire and Exdosion Data -
This section provides the information needed to plan how to prevent fires and explosions.
Flash Point - This is the lowest tempera- ture at which a liquid will give off enough vapor to be ignited with a spark. Liquids with low flash points are more dangerous than those with high flash points (above 200°F). If a liquid hasa llash point around 70°F (room temperature) or less, all it takes to set it on fire is a spark from, for example, a cigarette, a lit match or a welding arc. Keeping chemicals at temperatures below their flash point will help prevent fires.
Flammable or Explorlve Llmlt - This refers to the amount of gas or vapor given off by a liquid that will burn or explode i f a source of ignition (spark, flame or cigarette) is present. The limit is usually expressed as a percent of the vapor or gas in the air. A value of one percent of volume is equivalent to 10,000 ppm. LEI. stands for the lower explosive limit and UEL stands for the upper explosive limit. Air concentrations that fall between the LEL and the UEL can lead to fires or explosions.
Extlngulihlng Media - This section liats the type of material in fire extinguishers that best puts out a fire where the substance on the MSDS is the fuel that keeps the fire burning. Some extinguishing materials are Completely
useless for certain types of fires; some can even spread the fire or make it worse. For example, water cannot put out a lire of cadmium powder. but sand can. Your employer should have the right extinguishers lor all posslble chemical fires.
Speclat Flrellghtlng Procedures - Thls includes any precautions that must be 1Y.m by firefighters when fighting a fire lueled by !ne material on the MSDS. This would inctijw, any respirators or other protective er.iJipment needed. It should also mention any estinguish- ing material that might be unsafe for corxrJlling this type of fire. Unless your job is as b irained firefighter this section should not apply :a you. I f there is a fire, you should immediatel; 1 Jave the area and notify the appropriate c.er,ple. Your company should have a posted procedure for fire emergencies. Don't be a hero1
SECTION V: Reactivitv Data I
This section indicates whether the chemical substance will change its actual composition - usually by combining with another Subetance or breaking down to create a new substance. Section IV. on the other hand, describes condi- tions in which a chemical will change its form (for example, from solid to liquid or from liquid to gas). New substances may be more hazard- ous than the original. and may enter your body by a different route 01 exposure than the original substance. A properly completed data sheet should tell you: 1. whether the substance is likely to :-reak
2. what conditions are likely to change its
3. what new hazards might result.
Stablllly - Stability measures how well a material in the workplacecan resist changifig its form when it's exposed to heat, water or air or when it's mixed with other chemicals. A stable material will not change easily, even under fairly extreme Conditions. An unstable material Wi l l change easily. Examples of changes we: 1) exploding under very hot conditions. cr 2) breaking down into more than one chemical and releasing toxic vapors or fumes. An uc.!abIe material Creates a possible safety hazard unless i t Is stored and handled very carelully.
down or react with other SubStanCeF.
composition;
2 UNDERSTANDING MSDS I-
e IncampltabHlly - This section provides a I# of substance8 that should not come into conl(lc1 wlth the chemical. Incompatible s u b smnces coyld react together to form a new h.urd or may bum or explode and break down Into new ham&.
Hozardws Docomporitlon or By-Products -This m t i o n lists the new hazardous materials formed when the substance breaks down or decomposes under certain conditions. For example, carbon monoxide may be a by-product of the chemical reaction in a gasoline engine.
Haurdous Polym~rlratlon - This is a type of chemical reaction that occurs when the mate- rial Is exposed to air. water. heat or other conditions that cause the release of a large amount of hest and. in some cases. toxic gas. Most materials that are likely to react in this way am treated with inhibitors, materials which can stop this type of chemical reaction. These in- hibitors may be toxic, even though they are present in very small amounts.
if the "may occur" box is checked, special storage procedures must be given in the section, "Conditions to Avold." These procedures must be followed to prevent serious injury.
I SECTION VI: Health Hazard Data
Despite the importance of this section of the MSDS. it usually lacks complete information. In other cases, ail the symptoms of exposure are listed. but no information Is given about what symptoms you will have at dlfferent levels of exposure. It is very important to know to what level you are being exposed so that you can use the information In this section.' If ail the ingredients are listed in Section II, you can look up the health effects in another source:.
Rout- of Entry - Before a chemical can cause health problems it must get into the body. There are t h r w ways hazardous substances can enter your body:
Inhalation: Substances can enter your body through your lungs. Dusts, mists, gases, vapors. snd fumes are all inhaled. Skin Absorptlon: hany chemicals cause damage where they contact the surface of the body - the skin and eyes. Certain chemicals 'can be absorbed through the skin and then enter the blood stream. Occasionally. vapors can also be absorbed by the skin. For ex- ample. w e n i t you use a respirator during a spray painting operation, the paint vapors can get through your skin unless special protective clothing is also worn. Ingestlon: Workers may sweiiow chemlcals and dusts when they are transferred from workroom air to cigarettes. food, coffee, make-up. etc.
Hdth Hazards - This part describes the harmful effects of the substance on your health. Them health hazsrds may be acute hazards (short-term) or chronic health hszards (iong- WN.
'1tyouremplq.r hessrposurer.COrd8 you nlv~lrlghltO ln IMm under the OSHA aCCe88 rule - C O n l l C l your a m OSHA ofllw lor more Inlormsllon
* *CUI I~~ (k. Olvlslon 01 Occupillonal Hyglene lor soma ~ 1 1 0 n S .
Acute and Chronlc Effects of Common Workplace Hazards
Asbestos Mild respiratory irritation. cough Asbestosis. cancer of the lung,
Carbon Monoxide Drowsiness. headache, Heart attacks and strokes confusion: and in very high amounts unconsciousness and death
"drunken"feeling. numbness. possibly liver cancer nausea and vomiting
Chronic . Acute
and sneezing pleura. larynx. stomach and intestines
Trichloroethylene Light-headedness. euphoria. Liver. kidney and brain damage,
An scute effect usually means a serious but temporaryeffect from exposure. That effect can usually be reversed If the exposure is not repeated.""
The term. "chronic health effect" usually de- scribes a health condition that has gradually deveioped,and is difficult to reverse:'* Often, there are no noticeable signs or symptoms in the early stages. Sometimes the illness may take many years. even decades to appear. When the disease is finally felt or noticed. it is often difficult to recover the function that is lost, although further disability or worsening of disease can often be prevented.
Some chemicals have both acute and chronic health effects, depending on the way the expo- sure is experienced over time. The table included on this page provides some examples of these scute and chronic effects.
Some illnesses are difficult to classify In one category or another. Cancers, for example, may be i n l t i ~ e d by short periods of acute exposures but take many years to develop and are con- sidered chronic illnesses.
Data sheets must tell you about both kinds of heaitheffects-chronicand acute. Butsinceso little is known about the effects of continual, low-level exposures, most of what you can learn from an MSDS will be about short-term reac- tions to high exposures.
e Carcinogenlclty - Carcinogenicity is the ability of a substance to cause cancer. Many experts agree that there Is no safe level of exposure to cancer-causing chemicals (carclno- gens). Even so. reducing your exposure reduces your risk. Therefore, it is important to avoid exposure as much as possible. Preferably, your employer will use a less toxic material instead of the carcinogen. if this is not possible. your employer may be able to enclose the process. Please see Section V l l l for control recommen- dations.
NTP"" This refers to the National Toxicol- ogy Program, a federal program that lists over 100 substances that cause cancer in humans or laboratory animals.
IARC:"" This refers to the International Agency for Research on Cancer. It has pub- lished several volumes reviewing the carcino- genicity of more than 200 chemicals.
OSHA-Regulated"" - This refers to the Occupational Safety and Health Administration. OSHA has exposure limits on approximately 500 chemicals, but regulates only a few as car- cinogens. Many more are commonly recognized as causing cancer, but It takes a long time for OSHA to pass a legal standard on a chemical. i f a substance Is regulated by OSHA, you can request a copy of the standard from your area OSHA office. These standards include ways of measuring and reducing exposures. Some ex- amples are air sampling, medical tests for workers, ventilation and other mechanical con- trols, respirators and protective clothing, and training on the hazards and safe handling Of the carcinogen.
- "'The words "aculn" and "ChrOnlC" can also be used to
dnacrlba on exposure An "acute exposure" usually means an exposure at a high Invei over a short period of llma The tarm "chronic exposure" usually mean¶ a NIOIIVOIY low level 01 exposure over n ralallvely long perlod 01 t h e
""Thew sactloni nrn no1 rsqulred by the MIssachUseIls Rlghl lo Know Law. but If the chemical causes cnncer. lhl8 (act must be manlloned at leas1 under " C h ~ O n l C alf6CIs" 01 the Hnallh Hnznrds aectlon Such CheBICOIS we mnrksd wlth 1 "C' on the Masmchuaettr Substanca L l l l
Signsand Symptoms of Exposure - Symp- toms are what you feel from being exposed. Signs are what a doctor sees on examining you following exposure. For example. i f you are exposed4o paint thinner, you need to know that i t can make you feel dizzy (symptom); you also need to know that with long-term exposure i t can cause tremors (sign) and damage your nervous system (cause of the symptoms and signs). The dizziness Is only a symptom of what is happening inside,
Medical Conditions Generally Aggravated By Exposure- Different people can beaffected in different ways by the same exposure. Some- times workers with a medical condition are aflected more seriously than others, even at extremely low levels. For example, people with heart conditions can have serious health effects from much lower levels of carbon monoxide than people with no prior heart problems. Threshold limit values (see Section II) areset to protect the "average worker" and don't account for differences in the wide range of people exposed.
e Emergency and First Aid Procedures - First aid should be described for all routes of entry. I f no information is listed here, your employer should call the manufacturer before there is an emergency. If there is an emergency, get attention from the nearest doctor or nurse. Bring a copy of the MSDS so they have informa- tion on thechemical that caused the emergency.
SECTION VII: i I Precautions for Handling I - - - - - - -. Steps To Be Taken In Case Material Is
Released Or Spilled - Many MSDSs deal with this section by saying "avoid breathing gases and vapors." or "avoid contact with liquids." This is clearly insufficient. This section should give you information you need lo plan an emer- gency evacuation, such as what types of emer- gency respirators to have on hand or how to pian routes of exit i f a product produces a toxic gas.
It should also tell you how to handle smaller spills - whether to vacuum up the substance, use a special absorbing material. or neutralize with another substance. i t is also important to know i f protective clothing should be worn when cleaning up a spill.
Waste Disposal - Any special procedures that should be used for disposing of hazardous workplace materials are noted here. Dumping hazardous waste in the garbage or down the drain or in an unlicensed landfill not only creates a problem for the surrounding communily. it exposes the cily or town disposal workers un- necessarilyto unknown hazards. if you have any questions about disposal methods. you can contact the Environmental Protection Agency's special hotline number: 1-800-424-9346.
&
Procautlonr To Be Taken In Handllng And Storlng - This section may advise, for example. not tostoreacidsand bases together, or organic chemicals around strong oxidizers, or to keep some chemicals in temperature-controlled areas.
Other Precautlonr - This section is a catch-all for any special precautions that may not have been discussed. Always check this section because sometimes information that should be listed somewhere else is only listed hare.
.
SECTION VIII: Control Measures
The best control measures for chemicals are those that reduceor eliminate the problem at the source (beforeanyonecan havecontact with it). They are called engineering controls. Control measures, such as ventilation, have to be de- ,
signed to fit the actual conditions of use and exposure. Personal protective equipment - respirators, clothing, goggles - should never be relied upon as the sole means of control. At best, they may be appropriate if an exposure is occasional or until ventilation or other controls are installed. Seek advice from your union, from your area Occupational Safety and Health Coali- tion (COSH group), from OSHA, from NlOSH or from the Division 01 Occupational Hygiene to plan proper controls.
Respiratory Protection - The type of respiratory protection recommendad must be specifii to the exposures in the workplace. If a product is a hazardous dust, but you also work with a solvent at the same time, the type of respirator recommended on the dust MSDS may not also be suitable to protect against the solvent you are using. However, there are masks that protect against both.
It Is also important to k w p In mlnd that different levels of exposure require dlfferent kinds of respirators. For example. while a half- mask, air-purifying respirator may be adequate for alevel of air contaminationsllghtlyabove the recommended or legal limit, a self-contained breathing apparatus (similar to scuba tanks)
'would be necessary for a contamination level that Is life-threatening.
Even il you are using the proper respirator and are following the procedures for fitting. clean- ing, medical testing, etc. required by OSHA standard 1910.134, there are cases in which respirators may not provide long-term protec- tion. For advice on specific situations or sub- stances contact one of the organizations listed above.
Local Venlllatlon -This type of ventilation usas an exhaust fan at the end of an enclosure that draws the dust, fumes, gas, mist or vaporg away from the source. If it works effectively, it will keep the surrounding air free from toxic levels. Examples of local exhaust are laboratory hoods and paint spray booths.
_ _ _ _ _ ~ ~
Compar ison 01 MSDS Requirements: Maasachuaatta RTK and OSHA' x = required
MAATK OSHA - = not required Product Identity identity
X chemical name x chemical and common name (as listed on the label)
manulacturer's information X X name X X address
X telephone number X emergency telephone number X date compiled or revised x ,
X x . chemicalname x . x commonname . X - CASnumber
Hazardous Ingredients (pure substance)
x exposure limits (OSHA, ACGIH, other) Hazardous Ingredients (mixture)
X x chemical names of hazardous ingredients x common names of ingredients
X - percentages 01 each hazardous subtance X - CAS number for each hazardous substance
x exposure limits lor each hazardous substance (OSHA, ACGIH, other) Phyrlcal Data
x boiling point
x vapor density
x appearance and odor x specific gravity x melting point
X x vapor pressure
X x solubility in water
X x evaporation rate
X X routes of entry X X health hazards (acute and chronic) X x carcinogenicity
X X signs and symptoms of exposure X X medical conditions which might be aggravated by exposure X X emergency and first aid procedures
Health Hazard Data
X MSDSs must indicate i f chemicals are included in certain listings of carcinogens (NTP. IARC. OSHA)
'Only those SeCllOnS having dlllerences beiween the Iwo laws have been presenled here
4 UNDERSTANDING MSDS
' 0 Mrhanlca l (General) Ventllallon - Thls type of ventilation dilutes the chemicals In the air with clean air In a general area, room or buildlng. A fan In the wall or ceiling is not very ellectlve unless fresh air is brought in at the same time. A floor fan does not help much without edditlonal ventilation. I t moves the chemicals around, but does not remove them.
Protecllve Glover - Protectlve glover should always be worn when working wlth material that can either be absorbed through the skin or damage theskin itself. The material used to make the gloves must be selected based on the properties of the combination of products with which you work. The MSDS should speclfy the appropriate glove material to use with each specific product.
Eye Protectlon - Eye protection is impor- tant to wear it there is any danger of splashing or contact with corrosive substances or dusts. If eye protection is recommended, your employer should look for ways of redesigning the job 10 avoid contact and make eyewash fountains qccessible to the work area.
Other Protecllve Clothlng or Equlpment- Other protective clothing may be recommended if vapors can penetrate the skin, or if the danger of spllla is great. Showers should be provided i f there is a danger of contact and, as discussed underEyeProtectlon,effortsshould beaimed at designing the job so that contact is avoided.
WorWHyglenlc Practicer - This section may deal with things like washing hands before eatlng or leaving the area, restricting food or drink in work areas, keeping an area free of dusts or liquids. These are coping, not control measures, but may make sense as work rules in your area even after other controls are in place.
Remamber: You have a right to be /u//y inlormed of the chemicals used in your work- place. I lyou feel that any olyour rights have been violated under the Massachusetts Right lo Know Law. contact:
DEPARTMENT OF LABOR AND INDUSTRIEI Dlvlslon 01 tndustrlml Satoty ,
100 Cambridge Street 283 Main Streel Worcesler 01608 Boston 02202
(617) 727-5816 (617) 752-6504 11 Lawrence Streel 908 Purchase Street Lawrence 01840 New Bedlord 02740
165 Liberlv Streel (617) 681-7798 (617) 997-8263
246 North Street I Springlield 01 103 Pittslield 01201 (413) 734-1421 (413) 445-4214 I
Dlvlslon 01 Occup~llonrl Myglen. 1001 Walertown Slreet West Newton 02165 (617)969-7177
Employees: For complainls involving the OSHA Hazard Communication Standard:
I OSHA (617) 223-6712 or I 14131 765-0123
Acknowledgements: This newsletter was prepared by the DOH/Right to Know Stall Joan Parker, Richard Rabin. Philip Korman. Maxine Garbo. Sal lnsogna and Thomas Trayers Much 01 the material in lhis publicalion is based, in part. on "How 10 Read MSDSs." 01 Ihe United Furniture Workers 01 America and Ihe United Paperworkers International Union. and "How 10 Read an MSDS." 01 the Massachusetta Coalition lor Occupational Safety and Health The drawinginthelirstcolumnonpage3islakenlrom "Toxicological Index" 01 the Commission de la sant4 et de la SBcurit6 du travvail du Quebec The drawing in tha lhird column of page three is taken from "Hazardous Materials Management" 01 the American Lung Association 01 San Francisco and was drawn by O r u ~ Cakmakli The drawing on page4is 1akenlromlhe"Occupalional Salelyand Health Level I1 Training Manual" of the Ontario Woikers' Occupational Safety and Health Centre This publication may be copied aa long as i t 18 not I done lor comme*ciaI OurDoses
i
HIGH-RISK SCIENCE CHEMICALS
Cautlon: This list is illustrative and is not an exhausthe list of risk chemicals. Each chemical requires a thorough risk evaluation by a qualified professional. Merely touching the top of some Containers may result in severe personal injury.
Explosive and/ or flre risk potassium chlorate benzoyl peroxide carbon disulfide collodion cyclo hexenel 1 ,4-dioxane? ethyl ether1 isopropyl ether1 tetrahydrofuran1 styrene, monomer p hosp homus pentoxide yellow (white phosphorus) magnesium powder2 formic acid (aged)3 anhydrous aluminum chloride (aged)3 lauryl peroxide potassium metal1 nitroglycerin nitrogen trioxide 2,rl-dinitrophenol 2&dinitrophenolhydrazine perchloric acid low flash point solvents aged and/or excessive oxidizers thermit picric acid leaking and/or improperly stored gas
cylinders
Reactiveslcorrosives bromine hydrofluoric acid titanium tetrachloride osmium compounds
Toxic ammonium metavanadate
. caffeine colchicine lead compounds mercury mercury compounds nicotine
. sodium azide potassium, silver, sodium cyanide thioacetamide thiourea brucine sulfate leaking andlor improperly stored gas
cylinders
Carcinogens arsenic carbon tetrachloride benzene formaldehyde chloroform aniline lead acetate
1 These compounds, among others, can form explosive peroxides. Please consult the National Safety Council article on peroxides listed in the references.
2 Excessive amounts and/or storage in damp conditions pose a serious fire risk.
3 Older containers do not have a pressure relief cap and may become stressed by werpressurization. Containers have exploded upon touch.
I 8
TABLE 2
HIGH-RISK ART PROCESSESCHEMICALS
Ceramics
Photography
Stained glass
Solvents
Inks
Silk-screening
Batik
Dyeing
Avoid lead, arsenic. cadmium and other toxic metals in glazes; properly vent the kiln
Provide a minimum of ten air exchanges per hour in darkrooms using standard photo chemicals. Specialized photo processes such as daguerreotype require specialized local ventilation and are not recommended
Provide proper ventilatiodead is very toxic
Use only in a fumehood or a spray booth. Avoid using turpentine
Use water-based inks. Avoid oil-based ink
Avoid oil-based silk-screening. Serious organ damage can result from solvents. Highquality water-based systems are available .
High hazard associated with heating WaX
Many dyes have been found to be carcinogenic; inhalation of dust is a serious risk factor
Spray fixatives Use only in a spray booth or fumehood
9
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Carbon Disulfide I Carbon Tetrachloride .Carney's Solution 1 Cerium Ammonium Nitrate
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DATE.
Chloroform Chromic Chloride Chromic Nitrate Chromic Potassium Sulfate *
Chromic Sulfate Chromium Oxide
CHEMICAL STORAGE AREA
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,Colchicine 1 Collodion 2. S-Dibromoanaline Dibromoacetic acid 1 -4-Dichlorobenzene I Digitonin 1, 4-Dioxane I -- -
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, Hvdrobromic Acid I Hydrofluoric Acid Hydrogen Peroxide 30% Hydrogen Sulfide I
Estrone Ethyl Ether Ethylene Diamine Ethylene Dichloride FAA Formaldehyde Formalin Formic Acid
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Glyoxal 1 I Hayen Diluting Fluid
Hydroauinone Lactic Acid Lead Acetate
Lead Dioxide '
Lead Monoxide (Yellow) Lead Nitrate I Lead Oxide (Yeltow) '
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, Lithium Nitrate I I Maleic Acid
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Mercuric Iodide Mercuric Nitrate
SCHOOL
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lnsoection Date I Building lnspectcr I Lab WDt. 1' DeDt. Mgr.
LABORATORY S A F m AUDIT
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COMPRESSED GAS CYLINDER INSPECTION SHEET
Vendor I TYDQ I Serial No. 1 D.O.T. Spec No. 1 Hydro Test Date f Hazard Class I
1
A. Wall Mount Chain I I Strao
C. Table Bracket Chain I ' I StraD B. Cylinder Foot Secure I I Not Secure
RCCB 1
R- I SUPPORT
H. Flashback (yes I ]NO I !Yes I (NO
CONDITION
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IN0 -
Is cylinder blocking fire extinguishers, egress Yes I I safety showers, etc.? EXPLAIN OBSTRUCTION
L. Additional comments
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U3HS N01133dSNl t13ClNllA3 3WI1331
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'LABORATORY ,SAFR"Y AUDIT Page 10 . . .
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ROOM No.
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v Electrlal I Yes I MI I Unknown Proper Ground .GFlc
: Master Shut-Off . I . ,Comments
LABORATO RY/ROOM (1 /3)
. Delectable Leaks 1 I I Master Shut-Off
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Fire Extinguishers I Number I Tvpe I Weiqht I
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Spill Control I Type I Amount
Explosion Proof Refrlgerator
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, Mercury Spill K i t I Ye; 1 bb L 1 I
e . - Eye Wash I Type I Testing I Purged Regularly I
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L I I I 1 Drench Shower I Type I Testing
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Master Water Shut-Off I I
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* - . Hazardous Waste Segregated and Stored
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AUTOMATIC FIRE Yes I I% EXTINGUISHING SYSTEM
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