Hazardous Waste Handling and Disposal at IMFT Satellite Accumulation Areas and Universal Waste

Hazardous WasteHandling and Disposal

at IMFT

Satellite Accumulation Areasand Universal Waste

EDM # 090078f380d4bee6 Owner: ESHS Version Date: 7/27/2012

You are required to take this training because you perform activities that generate Hazardous Waste (HW).

The EPA requires you to take this training every year.

This training has 8 segments

Common MistakesWhat is HW Roles/Responsibilities Handling HWHistory HW Disposal EPA Universal Waste

The History of Hazardous Waste Management

HistoryCommon MistakesWhat is HW Roles/Responsibilities Handling HW HW Disposal EPA Universal Waste

The Environmental Protection Agency (EPA) creates rules to controlour waste to ensure it doesn’t negatively impact our environment.

It is important to control our hazardous waste.

IMFT is committed to safeguarding our community

QuizWhy does IMFT care about controlling its

Hazardous Waste?

A. IMFT is committed to safeguarding UtahB. The EPA requires us toC. To make sure we do not negatively

impact our community and environmentD. All of the above


AnswerWhy does IMFT care about controlling its

Hazardous Waste?

A. IMFT is committed to safeguarding UtahB. The EPA requires us toC. To make sure we do not negatively

impact our community and environmentD. All of the above


The Environmental Protection Agency(EPA)

EPACommon MistakesWhat is HW Roles/Responsibilities Handling HWHistory HW Disposal Universal Waste

The EPA regulates all aspects of Hazardous Waste (HW) in the United States. They mandate how we:

–Handle HW–Accumulate HW–Respond to emergencies involving HW– Ship HW

Violation of these regulations results in fines, along with potential damage to our surrounding environment.


QuizWho mandates that IMFT controls its

Hazardous Waste?

A. OSHAB. The Library of CongressC. The UCCUD. The EPA


AnswersWho mandates that IMFT controls its

Hazardous Waste?

A. OSHAB. The Library of CongressC. The UCCUD. The EPA


What does the EPA consider Hazardous Waste?

What is Haz Waste?Common MistakesRoles/Responsibilities Handling HWHistory HW Disposal EPA Universal Waste

When any material at IMFT is no longer needed/useful, it is classified as “waste.”

Some waste is considered “Hazardous Waste” by the EPA and some is not.


Which of the following isconsidered EPA hazardous waste?


NONE

Just because a waste is hazardous to your health does not mean it is considered “EPA hazardous waste.”


Hazardous Waste definition

Unfortunately the EPA does not provide a simple, concise definition of Hazardous Waste. The definition of HW is quite confusing, and changes based on different situations.


Hazardous Waste definitionBelow are a few of the many intricacies of the EPA’s definition of HW:

Chemicals are not considered “waste” while in use. Therefore they cannot be HW.

Just because a bottle is “empty” in your eyes does not mean it’s “EPA empty.” Even if there is a small amount of liquid in the container, you may be required to treat the entire container as HW.

Depending on how a certain chemical is used, recycled, emptied, etc. it may or may not be considered a HW.


Hazardous Waste definition

Because of the many intricacies of the EPA definition of HW, only the ESHS Environmental Team (with the assistance of Air Liquide) will determine what is and is not considered Hazardous Waste at IMFT.


In other words, it is not your job to determine if a chemical is HW or not.


The Satellite Accumulation Area Quick Reference Card (QRC) in your area identifies common HW chemicals used in your area.

You must treat these listed chemicals as HW.


If you see any of these labels on a container, or if it is listed on your quick reference card,

you must treat it as Hazardous Waste.


QuizWho’s responsibility is it to identify hazardous waste?

A. All team members who handle chemicals

B. Air LiquideC. IMFT Environmental TeamD. Area owner


AnswersWho’s responsibility is it to identify hazardous waste?




QuizWhich of the following is considered Hazardous Waste?

A. Razor bladesB. Broken glassC. Used needlesD. None of the above


AnswersWhich of the following is considered Hazardous Waste?

A. Razor bladesB. Broken glassC. Used needlesD. None of the above


QuizAt which point is a chemical identified on the QRC considered “HW”?

A. As soon as the bottle arrives on siteB. As soon as the bottle is openedC. When the bottle is to be discarded and

no longer in useD. All of the above


AnswersAt which point is a chemical identified on the QRC considered “HW”?

A. As soon as the bottle arrives on siteB. As soon as the bottle is openedC. When the bottle is to be discarded and

no longer in useD. All of the above


Roles & Responsibilities

Roles & ResponsibilitiesCommon MistakesWhat is HW Handling HWHistory HW Disposal EPA Universal Waste

IMFT’s Environmental Team (part of the ESHS team) own the Hazardous Waste program. It is their job to oversee the program and training related to Hazardous Waste.

IMFT’s Environmental Team rely heavily on qualified team members to properly carry out the HW program.


Position Responsibility

ESHS Environmental Team • own the HW program, training, and EPA regulations• identify and classify chemicals as HW• perform area inspections• maintain QRCs• communicate HW classifications to Area Owners

HW Handlers (Air Liquide) • collect HW• prepare HW for shipment• transport HW• make HW determinations• provide new containers for HW

Emergency Response Team (ERT) • help determine proper response to spills, leaks, explosions, etc.• coordinate HW spill cleanup

Team Members who handle HW chemicals

• handle HW correctly• dispose of HW correctly (including proper labeling)• following area HW QRCs

QuizWho owns the entire Hazardous Waste program?




AnswersWho owns the entire Hazardous Waste program?




Handling Hazardous Waste

Handling HWCommon MistakesWhat is HWHistory HW Disposal EPA Universal WasteRoles/Responsibilities

Handling HW• Handle all HW just as you would handle any chemical (as

taught in LE 73653 – Hazard Communication)

• Wear proper PPE

• Verify that HW is placed into the proper storage container

• Call ERT if you any HW spills


EmergenciesCall ERT for fires, explosions, chemical spills, smoke, and other emergencies. They are trained to deal with HW.

– Phone on IMFT site: 7-7777

– Cell phone or off-site: 801-767-7777

– Radio channel A-1Handling HW

Common MistakesWhat is HWHistory HW Disposal EPA Universal WasteRoles/Responsibilities

QuizEvery time you handle HW it is important to…

A. Notify your supervisorB. Wear proper PPEC. Notify ERTD. Fill out a “Hazardous Waste Handling

Permit”E. All of the above


AnswerEvery time you handle HW it is important to…

A. Notify your supervisorB. Wear proper PPEC. Notify ERTD. Fill out a “Hazardous Waste Handling

Permit”E. All of the above


QuizWho is in charge of cleaning up HW spills?


B. Air LiquideC. IMFT Environmental TeamD. ERT


AnswersWho is in charge of cleaning up HW spills?


B. Air LiquideC. IMFT Environmental TeamD. ERT


QuizWhat should you do if you spill any HW

A. Notify your supervisorB. Notify ERTC. Fill out a “Hazardous Waste Spill

Permit”D. All of the above


AnswerWhat should you do if you spill any HW

A. Notify your supervisorB. Notify ERTC. Fill out a “Hazardous Waste Spill

Permit”D. All of the above


Disposing of Hazardous Waste

Common MistakesWhat is HWHistory EPA Universal WasteRoles/Responsibilities

HW DisposalHandling HW

IMFT has two different types of HW Storage areas:

Satellite Accumulation Area 90 Day Accumulation Area

Waste in a 90 day accumulation area must be shipped off site prior to 90 days of storage (regardless of how full the actual container is).

Used to accumulate waste close to chemical use area until container is full. Once the container is full it must go to a 90 Day Accumulation Area.



Satellite Accumulation Area 90 Day Accumulation Area

Your group does not use 90 day Accumulation Areas

Your group does not use 90 Day Accumulation Areas




Your group only uses Satellite Accumulation Areas

Satellite Accumulation Area




Accumulating HWThe EPA understands that it would be far too costly and inefficient to ship every bottle of HW the second it is generated.

Accordingly, the EPA allows sites to accumulate HW in local areas.



Quick Reference CardsWe have created and posted quick reference cards at each Satellite Accumulation Area.




The Quick Reference Card (QRC)…

- identifies common chemicals in the area that are considered HW- identifies the responsibilities of a HW handler- outlines the proper way to label HW




- Remember, the chemicals identified on the QRC are not considered HW while in use

- When you are done using a chemical that is listed on the QRC, and plan on discarding the chemical, it becomes a waste and must be treated as HW. Transfer the waste material to the Satellite Accumulation Area container.




The label must include the words “Hazardous Waste”

You must record the datethe Satellite Accumulation

container is full

Include basic chemical identity information

Labeling HW in a Satellite Accumulation Area






The QRCs in each area only identify the most common HW materials for that area, not all HW.

The “Hazardous Materials for Disposal” label is to be used when you are unsure if a waste chemical is HW or not.

Air Liquide, in coordination with the IMFT Environmental team, will see this label and determine if this waste is considered HW or not.

• Hazardous Materials for Disposal labels can be obtained from ESHS, near the west elevator, or through Matreq #400-00868.

• Correctly fill out the label, paying special attention to fill out the date (EPA regulation).

• Once the label is properly filled out, contact Air Liquide for retrieval (page airliquideoperations).



Here are the proper steps for handling and storing HW.

1. When you have a waste chemical, check a nearby QRC to see if it’s listed as HW.

2. If the QRC lists it as HW, pour any waste into the Satellite Accumulation Area HW container.

3. The Satellite Accumulation Area HW container should already have a label on it (however, the date section should be left blank for now).

4. Continue steps 1-3 until the Satellite Accumulation Area HW container is full. Once it is full, record the day’s date on the container.

5. Call Air Liquide to retrieve the full Satellite Accumulation Area HW container.

6. Air Liquide will bring a new empty Satellite Accumulation Area HW container. Make sure this empty container has a label affixed to it with everything but the date filled out.

Recap



QuizWhat should you do if you are unsure if a waste chemical is considered HW?

A. Treat it as HW just to be safeB. Label it as HW just to be safeC. Label it with a “Hazardous Materials for

Disposal” labelD. Answers A and B are correct



AnswerWhat should you do if you are unsure if a waste chemical is considered HW?

A. Treat it as HW just to be safeB. Label it as HW just to be safeC. Label it with a “Hazardous Materials for

Disposal” labelD. Answers A and B are correct



Universal Waste

Common MistakesWhat is HWHistory EPA Roles/Responsibilities Handling HW HW Disposal

Universal Waste

Universal WasteSome types of HW waste are so common that the EPA has classified them as “Universal Wastes.” The following are classified as Universal Waste (UW):

– Rechargeable batteries*– Mercury-containing equipment– Lamps

To dispose of UW, contact Air Liquide (page airliquideoperations)

* your area admin is authorized to collect rechargeable batteries


Universal Waste

Common wastes, such as ni-cad batteries or florescent light bulbs are classified as…?

A. De Minimus WastesB. Universal WastesC. Exempt WastesD. Common Wates

Quiz


Universal Waste

Common wastes, such as ni-cad batteries or florescent light bulbs are classified as…?

A. De Minimus WastesB. Universal WastesC. Exempt WastesD. Common Wates

Answer


Universal Waste

How should you dispose of Universal Waste?

A. Follow the HW QRC B. Contact Air LiquideC. Notify your supervisor D. Call 7-7777

Quiz


Universal Waste

How should you dispose of Universal Waste?

A. Follow the HW QRCB. Contact Air LiquideC. Notify your supervisor D. Call 7-7777

Answer

Universal WasteCommon MistakesWhat is HWHistory EPA Roles/Responsibilities Handling HW HW Disposal

Common Mistakes

Common EPA Violations

What is HWHistory EPA Roles/Responsibilities Handling HW HW Disposal Universal Waste

Common EPA violations

We will now address some of the EPA’s most common violations regarding HW.


Common Mistakes

HW storage containers should only be opened when adding or removing waste. Apart from this, they must remain closed at all times. Never leave an open container unattended.

Mistake #1

HW storage container left open


Common Mistakes

• Sometimes people fail to label HW

• Sometimes people label non-HW as HW

• 90-day accumulation containers also need HW labels

• All waste chemical containers must be labeled with either the Hazardous Material for Disposal label or a HW label (remember, they are not the same thing).

Mistake #2

Improper Labeling


Common Mistakes

• Remember to label all HW immediately (filling out all info except the ‘date’)

• As soon as the Satellite Accumulation container is full, put the day’s date on the label.

• Even the “hazardous material for disposal” labels need a date.

Mistake #3

Labels without a date


Common Mistakes

When are HW containers allowed to be open?

A. Only when adding or removing wasteB. There are no restrictions, they can be open

all the timeC. Any time except transportD. Only during transport

Quiz


Common Mistakes

When are HW containers allowed to be open?

A. Only when adding or removing wasteB. There are no restrictions, they can be open

all the timeC. Any time except transportD. Only during transport

Answer


Common Mistakes

True or false? Satellite accumulation containers need HW labels on them.

A. TrueB. False

Quiz


Common Mistakes

True or false? Satellite accumulation containers need HW labels on them.

A. TrueB. False

Answer


Common Mistakes

Contact infoFor more information regarding policies and guidelines surrounding Hazardous Waste handling and disposal, see the Chemical waste management program SharePoint site:

http://lebg/sites/facilities/ESHS/programs/Pages/default.aspx

IMFT environmental team: le_eshs_env


Common Mistakes

http://lebg/sites/facilities/ESHS/programs/Pages/default.aspx

mailto:[email protected]?subject=hazardous%20waste%20program

© 2010 IM Flash Technologies, LLC. All rights reserved. Products are warranted only to meet the applicable production data sheet specifications.Information, products and/or specifications are subject to change without notice. All information is provided on an “AS IS” basis without warranties of any kind. Dates are estimates only. Drawings may not be to scale. All trademarks are the property of their respective owners.

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Hazardous Waste Handling and Disposal at IMFT Satellite Accumulation Areas and Universal Waste