Universal Waste. Version 1.0

Transcription

1 This document is intended to provide basic safety guidelines for the Physical Plant Department at Community College of Allegheny County. The information provided in this guide may vary by site. Version 1.0

2 Table of Contents I. Background II. Program Requirements--Summary III. Specific Requirements IV. Training V. Record keeping Attachments: 1. Rules for Waste Storage Areas 2. Training Outline 3. Emergency Procedures--Mercury Releases and Spills 4. Training Sign-in Sheet 2

3 I. BACKGROUND Community College of Allegheny County Spent fluorescent lamps, batteries, capacitors, ballasts and mercury containing equipment can be hazardous waste. Fluorescent lamps often contain mercury. Batteries can contain hazardous chemicals. Ballasts and capacitors can contain PCBs. Even a lamp labeled low mercury may be hazardous waste. Only proper documentation and TCLP analytical tests, done by approved EPA methods by an approved EPA laboratory, will satisfy the legal requirement of proof that your waste is not hazardous. If you do not have documentation showing your lamps as non-hazardous, then the law requires you to assume that they are hazardous waste. Once this assumption is made, then you will be required to prove that you have disposed of the hazardous waste using legal means. Spent fluorescent lamps and batteries fall into a special classification of hazardous wastes called s. Most states (including Pennsylvania) allow s to be sent using common carriers without the need of a Hazardous Waste Manifest. This keeps the cost of transportation low and thus encourages recycling. (Note: The batteries referred to in this program refer to small, dry-cell types only. Acid filled automotive-type batteries should be reclaimed through a battery reclamation service as soon as the battery is taken out of service. Battery suppliers typically offer this type of service.) II. Ballasts and capacitors are not s but are able to be handled using procedures similar to s. For this reason, ballasts and capacitors are being included in this recycling program. Sending lamps, batteries, ballasts and capacitors to a responsible recycling organization will satisfy the State (PADEP) and Federal (EPA) requirements, provided the recycling organization is registered and is a bona fide recycling entity. Pesticides, oil-based finishes and mercury containing equipment are handled as hazardous waste. PROGRAM REQUIREMENTS--SUMMARY A. Waste Storage Location B. Waste Storage Containers/Cartons C. Sorting and Container Labeling D. Accumulation Time Limits E. Inspection of Waste Storage F. Recycling Company G. Training H. Record keeping 3

4 III. SPECIFIC REQUIREMENTS A. Waste Storage Location Spent fluorescent lamps, batteries, capacitors, ballasts and mercury-containing equipment must be stored in a separate location specifically designated for such a purpose. It must be a dry location, in a low traffic area, away from a floor drain, and must allow for some protection so that waste containers are not susceptible to damage. The size of the storage location should be based on the amount of waste to be generated and the size of the storage containers used. The storage location needs to be free from clutter, open and accessible to allow for weekly inspections. B. Waste Storage Containers/Cartons Waste storage containers/cartons must be structurally sound, adequate to prevent breakage and compatible with the contents. Containers/cartons must have lids or other means of closure. Such containers/cartons must remain closed except when waste is being placed in them. Suggested containers: Fluorescent tubes--reuse original shipping cartons or similar cardboard cartons. (Box end should be taped shut when full.) Compact fluorescent lamps (including HIDs)--Cardboard carton or plastic bucket with lid. Vendor will provide a 55-gallon barrel with lid if desired. Batteries--Cardboard carton or plastic bucket with lid. PCB Free Ballasts or capacitors - Cardboard carton or plastic bucket with lid. Vendor will provide a 55-gallon barrel with lid if desired. Non PCB Free ballasts or capacitors--cardboard carton or plastic bucket with lid. Vendor will provide a 55-gallon barrel with lid if desired. Mercury-containing equipment--the container must be closed, structurally sound, compatible with the contents of the device, must lack evidence of leakage, spillage or damage that could cause leakage under reasonably foreseeable conditions, and must be reasonably designed to prevent the escape of mercury into the environment by volatilization or any other means. C. Sorting and Container Labeling Lamps--Fluorescent tubes, CFLs, HIDs, etc., must be segregated by type and stored in separate containers. Containers must be labeled with a standard label. Standard Universal Waste labels should be filled out to include contents, accumulation start date (the date the first article was placed in the container) and the name and address of the CCAC facility. Batteries--Batteries must be segregated by type and stored in separate containers. Batteries with protruding terminals must have the terminals taped to prevent arcs from occurring. Containers for batteries must be labeled with a standard label. Standard labels should be filled out to include contents (type of battery), accumulation start date (the date the first article was placed in the container) and the name and address of the CCAC facility. Ballasts or capacitors labeled as PCB Free --Ballasts or capacitors that are specifically labeled as PCB Free, can be disposed of without special precautions but should be recycled if for no other reason but resource recovery. These containers can be simply labeled as non-hazardous waste. These ballasts 4

5 Specific Requirements, continued can and should be recycled with other hazardous wastes, but there is no specific accumulation time limit. Ballasts or capacitors NOT labeled as PCB Free --Unless a ballast or capacitor is specifically labeled as PCB Free, it must be handled as a hazardous waste containing PCBs. These containers must have two labels: one standard Hazardous Waste label and one standard Caution Contains PCBs label. Labels must be filled out to include contents, campus name/address and the accumulation start date (the date the first item was placed in the container.) Mercury-containing equipment--universal waste mercury containing equipment, or the container in which the equipment is to be stored, must be labeled or clearly marked with any of the following phrases: Mercury-Containing Equipment, Waste Mercury Mercury-Containing Equipment, or Used Mercury-Containing Equipment. D. Accumulation Time Limits Lamps & Batteries--One year from the time the first item is placed in the storage container/carton. Ballasts and capacitors labeled as PCB Free --No accumulation time limit. Ballasts and capacitors NOT labeled as PCB Free days from the time the first item is placed in the storage container. Mercury-containing equipment--180 days from the time the first item is placed in the storage container. E. Inspection of Waste Storage The waste storage location and containers are to be inspected weekly. Items to inspect include: Is the area neat, clean, orderly and free of clutter/debris? Are there any broken fluorescent lamps? Are all lids in place on all containers? Are there any leaking containers? Are all containers/cartons labeled properly? Are there any containers/cartons past the accumulation time limit? Records of these weekly inspections should be kept in some form of log book or other means noting the date, person performing the inspection, deficiencies and corrections made. F. Recycling Company There are a number of companies that provide services for proper recycling of this waste. The Facilities Department, with assistance from Purchasing, can assist with selecting a recycling vendor that provides convenient, efficient and economical recycling services. Once a vendor is selected, each campus will need to submit a requisition for a blanket purchase order. 5

6 Specific Requirements, continued Once the blanket purchase order is in place, each campus can simply call to schedule a pick-up. As a rule of thumb, four boxes of 4-foot fluorescent tubes should be considered a minimum pick-up order. A log of all shipments must be kept indicating items shipped, date and name of recycling vendor. The recycling vendor will deliver the products to a licensed reclamation facility. A Certificate of Reclamation will be mailed back to the campus to confirm that the hazardous products were discarded properly and legally processed. IV. TRAINING It is the employer s responsibility to ensure that all employees handling hazardous waste are aware of the hazard and are trained in the proper handling of this waste. Depending on the quantity of waste generated, employers may be required to keep a written record demonstrating that employees handling hazardous waste have been properly trained. For this reason, a written record of this training is included as a requirement of this recycling program. (The Facilities Department has developed a training module for proper handling of lamps, ballasts and capacitors that is available for use to meet the requirement for training.) V. RECORD KEEPING Detailed record keeping is required to demonstrate the proper handling and disposal of this waste. These records should be organized and readily available for review by an inspection official on demand. Records required to be kept include: A written recycling program/procedure (This document) Weekly waste area and container inspection records Records of pick-ups including date, items and quantities Certificates of Reclamation Employee training records 6

7 Recycling Program For Fluorescent Lamps, Batteries, Capacitors, Ballasts and Mercury-Containing Equipment Rules for Waste Storage Areas Area must be clearly labeled as a Hazardous Waste Storage Area. Post these rules in a conspicuous location at each Waste Storage Area. 1. The storage area must be neat, clean, orderly, dry and free of clutter/debris. 2. Broken fluorescent tubes shall be immediately cleaned up and disposed of as hazardous waste. Debris is not to be stored with items to be recycled. 3. Containers must have lids or some other form of closure and shall remain closed at all times, except when filling. 4. Containers must be in good condition with no visible signs of damage or leaks. 5. Containers are to be properly labeled with information that, at a minimum, includes the contents and accumulation start date (i.e., the date the first item of waste was placed in the container). Refer to III. Specific Requirements - C. Sorting and Container Labeling in this document for more detailed information on labeling. 6. No waste is to be stored for longer than the allowable accumulation time limit. Accumulation time limits are as follows: a. Fluorescent lamps & batteries--one year b. Ballasts & capacitors labeled as PCB Free --No time limit c. Ballasts & capacitors NOT labeled as PCB Free days Weekly inspection required. The responsible party for this Waste Storage Area is: Name Phone 7

8 Training Outline-- I. PROPER HANDLING PROCEDURES FOR FLUORESCENT LAMPS A. PURPOSE To ensure that an employee s exposure to mercury is minimized and that materials containing mercury are handled and disposed of in an environmentally sound manner. B. BACKGROUND All fluorescent lamps and most other types of energy efficient lighting contain elemental mercury. Mercury has a unique combination of properties that make it the most efficient material for use in fluorescent and HID lamps. The basic operating principles of fluorescent lamps depend on production of ultraviolet (UV) light, and mercury is the most efficient producer of the required UV. Safeguarding used lamps from breaking will minimize releases of mercury into the environment. Normal handling is a very low risk activity. Because this is low risk, used lamps are classified as a special type of hazardous waste called. C. CAUTION Mercury released from broken lamps and mercury-contaminated materials vaporizes at room temperature. Mercury vapor is extremely toxic. Mercury is the only heavy metal that is liquid at room temperature. Because of this and other useful properties, its usage is commonplace. It can be more harmful to inhale the vapor from a bead of mercury than to ingest the same bead. At room temperature, mercury vaporizes readily into an invisible, odorless, tasteless and potentially harmful element. Ambient mercury levels in the breathing zone can be controlled if personnel are aware of and trained in mercury management. Be conscious of the hazard of unseen mercury contamination in cracks, corners and untreated storage containers. D. HANDLING PROCEDURES Procedure for handling unbroken fluorescent lamps for packaging. Employees should wear the following safety equipment: 1. Gloves made of leather or the equivalent 2. Safety glasses with side shields or a full-face shield 3. Closed toe shoes or boots All employees who handle shall wash their hands with soap and water upon completion of working with these mercury-based products. No tobacco materials, food or beverages are to be consumed while working with mercury lamps. 1. Place used lamps into new or used cardboard boxes (the original egg crate material does not have to be placed back into the boxes) and tape the ends to secure the box, but do not make it hermetically sealed (air tight). 8

9 Proper Handling Procedures For Fluorescent Lamps, continued 2. Transport boxes of used lamps to the designated waste storage area for your campus. Contact your supervisor if you do not know where this designated waste storage area is located. 3. Label all containers of used lamps with the label. Fill out as follows: Contents-- Used Lamps and quantity (count) of lamps Shipper--name and address of CCAC Campus location Accumulation Start Date--date that the first item is placed in the container Note: Broken or crushed lamps should be collected and disposed of as a hazardous waste. (See procedure below.) Badly damaged boxes, wet boxes, etc., will not be accepted for transport. It is the employee s responsibility to ensure that these handling and disposal procedures are fully carried out. The proper use of the prescribed safety equipment will protect the employee from the potential dangers of contamination from the mercury. E. ACCUMULATION TIME LIMIT Storage time is a maximum of one year from the date the first used lamp was placed in the container. If you notice that a container in the designated storage area is beyond the accumulation time limit, please notify your supervisor. II. EMERGENCY PROCEDURES--BREAKAGE OF LAMP A. PURPOSE To ensure that accidental breakage is cleaned up without spreading the mercury and with minimum exposure to employees. B. BACKGROUND Lamps are fragile and can easily break. The regulations distinguish between accidental breakage that occurs during normal transport and intentional breakage or crushing. While there is no specific amount of breakage that is considered accidental, less than 5 percent is typical. Anyone who chooses to recycle lamps as should take standard precautions to minimize breakage, such as using the boxes from new lamps to store the old ones in. C. CAUTION The EPA provides the following breakage advisory for THE HANDLING OF SMALL NUMBERS OF BROKEN FLUORESCENT LAMPS: 1. If a lamp breaks in your home or workplace, close off the room to other parts of the building. 2. Open a window to disperse any vapor that may escape and leave the room for at least 15 minutes. 9

10 Emergency Procedures--Breakage Of Lamp, continued 3. Carefully scoop up the fragments with a stiff piece of paper or a broom and dustpan (do not use your hands) and wipe the area with a disposable paper towel to remove all glass fragments. 4. Do not use a vacuum, as this disperses the mercury over a wider area. 5. All fragments should be placed in a plastic bag and be sealed/closed. The bag containing the broken bulb fragments should be turned over to your supervisor. Supervisors shall have this waste disposed of as hazardous waste through the hazardous waste disposal program managed by Safety and Security. D. HEALTH EFFECTS No adverse effects are expected from occasional exposure to broken lamps. III. PROPER PROCEDURES FOR HANDLING AND DISPOSAL OF PCB AND NON-PCB BALLASTS/CAPACITORS A. PURPOSE To ensure that an employee s exposure to PCBs is minimized and that materials containing PCBs are handled and disposed of in an environmentally sound manner. B. BACKGROUND Polychlorinated biphenyls (PCBs) were used in the capacitors of fluorescent lamp ballasts and in the capacitors of high intensity discharge (HID) lighting fixtures. PCBs were also found in other electrical equipment including common household appliances. PCBs were used in these items as they were an excellent insulator and they would not burn. In 1978, the United States Environmental Protection Agency (EPA) banned the use of PCBs as they were found to pose a health risk to humans. Mineral oils and powdered materials replaced PCBs in lamps, ballast and capacitors manufactured after 1978, and these items generally bear a label reading No PCBs. The majority of ballasts and capacitors you will come into contact with in your day-to-day job activities pose no health risk. However, there are still ballasts and/or capacitors in service that contain very small amounts of PCB fluid. For handling these ballasts and capacitors, follow the handling and disposal procedures outlined below. C. HANDLING PROCEDURES Procedure for handling non-leaking fluorescent lamp ballasts and capacitors. Employees should wear the following safety equipment: Gloves made of leather, butyl rubber or chemical resistant neoprene coated Safety glasses with side shields or a full-face shield Closed-toe shoes or boots 10

11 Proper Procedures For Handling And Disposal Of PCB And Non-PCB Ballasts/Capacitors, continued All employees who handle ballasts and capacitors shall wash their hands with soap and water upon completion of working with these possible PCB-containing products. No tobacco materials, food, or beverages are to be consumed while working with ballasts and capacitors. 1. Before attempting to remove a ballast or capacitor, inspect for leaks. Once it is verified that the ballast or capacitor is not leaking, it can be removed from the fixture. If a leak is detected, stop work and notify your supervisor. Upon approval from your supervisor, the leaking ballast or capacitor can be carefully removed and should be double (plastic) bagged and placed in a plastic barrel or bucket with at least three (3) inches of absorptive granular material (kitty litter, sawdust, etc.) and a secure lid. The container should be labeled as hazardous waste and turned over to your supervisor for disposal. Supervisors shall have this waste disposed of as hazardous waste through the hazardous waste disposal program managed by Safety and Security. 2. Transport used ballasts or capacitors to the designated waste storage area for your campus. Contact your supervisor if you do not know where this designated waste storage area is located. 3. Separate ballast by type. Ballasts or capacitors labeled as Non-PCB (or similar) shall be stored separately from ballasts or capacitors with no such label. Place used ballasts or capacitors in the appropriate container. A sturdy cardboard box will suffice as long as it is able to be closed. 4. Label all containers of used ballasts or capacitors with the appropriate labels. Containers with ballasts or capacitors labeled as PCB Free are to have one green NON- HAZARDOUS WASTE label. Fill it out as follows: Contents-- Non-PCB Ballasts or Non-PCB Capacitors and the quantity of items. Leave all other information blank. Containers with ballasts or capacitors not labeled as free of PCB s are to have two labels: a. CAUTION CONTAINS PCB S --At this time, leave the also contact and Tel. No. blank. b. HAZARDOUS WASTE --Fill out as follows: Generator s Information--name and address of CCAC campus Accumulation Start Date--date the first item was placed in the container D.O.T. Proper Shipping Name, etc.--enter Used Ballasts or Used Capacitors Leave all other information blank D. ACCUMULATION TIME LIMIT For ballasts or capacitors not labeled as free of PCB s, the accumulation time limit is 180 days from the date the first used ballast or capacitor was placed in the container. If you notice that a container in the designated storage area is beyond the accumulation time limit, please notify your supervisor. 11

12 Emergency Procedures--Mercury Releases and Spills I. INTRODUCTION You can prevent potential mercury exposure to you and your environment by: A. Storing and handling responsibly products that contain mercury B. Following our tips when cleaning up mercury spills C. Recycling or otherwise properly disposing of products that contain mercury II. CLEANING UP SPILLS What Never to Do After a Mercury Spill A. Never use a vacuum cleaner to clean up mercury. The vacuum will put mercury into the air and increase exposure. B. Never use a broom to clean up mercury. It will break the mercury into smaller droplets and spread them. C. Never pour mercury down a drain. It may lodge in the plumbing and cause future problems during plumbing repairs. If discharged, it can cause pollution of the septic tank or sewage treatment plant. D. Never wash clothing or other items that have come in direct contact with mercury in a washing machine because mercury may contaminate the machine and/or pollute sewage. Clothing that has come into direct contact with mercury should be discarded. By "direct contact," we mean that mercury was (or has been) spilled directly on the clothing, for example, if you break a mercury thermometer and some of elemental mercury beads came in contact with your clothing. E. Never walk around if your shoes might be contaminated with mercury. Contaminated clothing can also spread mercury. III. WHAT TO DO IF A MERCURY THERMOMETER BREAKS NOTE: These instructions also apply to spills from other sources if the amount spilled is less than or similar to the amount in a thermometer. Have everyone else leave the area; don't let anyone walk through the mercury on their way out. Make sure all pets are removed from the area. Open all windows and doors to the outside if possible; shut all doors to other parts of the building. A. DO NOT allow children to help you clean up the spill. B. Mercury can be cleaned up easily from the following surfaces: wood, linoleum, tile and any similarly smooth surfaces. C. Contaminated items should be thrown away in accordance with the disposal means outlined below. Cut and remove only the affected portion of the contaminated carpet for disposal. D. Mercury spill clean-up kits are available in the Security Office. 12

13 IV. CLEANUP INSTRUCTIONS A. Put on rubber, nitrile or latex gloves along with safety glasses. B. If there are any broken pieces of glass or sharp objects, pick them up with care. Place all broken objects on a paper towel. Fold the paper towel and place it in a zip-close bag. Secure the bag and label it as mercury. C. Locate visible mercury beads. Use a squeegee or piece of cardboard to gather the mercury beads. Use slow sweeping motions to keep the mercury from becoming uncontrollable. Take a flashlight, hold it at a low angle close to the floor in a darkened room and look for additional glistening beads of mercury that may be sticking to the surface or in small cracked areas of the surface. Note: Mercury can move surprising distances on hard, flat surfaces, so be sure to inspect the entire room when "searching." D. Use an eyedropper to collect or draw up the mercury beads. Slowly and carefully squeeze the mercury onto a damp paper towel. Place the paper towel in a zip-close bag and secure. Make sure to label the bag as mercury waste. E. After you remove the larger beads, put shaving cream on top of a small paint brush and gently "dot" the affected area to pick up smaller, hard-to-see beads. Alternatively, use duct tape to collect smaller, hard-to-see beads. Place the paint brush or duct tape in a zip-close bag and secure. Make sure to label the bag as mercury waste. F. OPTIONAL STEP: It is OPTIONAL to use the mercury spill kit. It contains mercury vapor absorbent and is located in the Security Office. Note: Read the directions provided with the kit before use. G. For assistance with cleanup, please notify the Physical Plant. We can provide cleanup and will dispose of the contaminants in the proper manner. H. The Physical Plant will make any necessary contact with our local health department, municipal waste authority or your local fire department for proper disposal in accordance with local, state and federal laws. I. Remember to keep the area well ventilated to the outside (i.e., windows open and fans in exterior windows running) for at least 24 hours after your successful cleanup. Continue to keep pets and children out of the cleanup area. If sickness occurs, seek medical attention immediately. For additional information on health effects, the Agency for Toxic Substances and Disease Registry (ATSDR) provides a Mercury Fact Sheet that also presents information on the health effects related to exposures to the vapors from metallic mercury. Recommendation: If there are young children or pregnant women in the area, seek additional advice from your local or state health or state environmental agency. V. SPILLS OF MORE THAN THE AMOUNT, BUT LESS THAN OR SIMILAR TO TWO TABLESPOONS (ONE POUND) Cleanup Instructions: A. Have everyone else leave the area; don't let anyone walk through the mercury on their way out. B. Open all windows and doors to the outside. C. Turn down the temperature. 13

14 Spills Of More Than The Amount, But Less Than Or Similar To Two Tablespoons (One Pound), continued D. Shut all doors to other parts of the house and leave the area. E. Don't vacuum. F. Call your local or state health or environmental agency. VI. SPILLS OF ONE POUND OR MORE (i.e., IF IT LOOKS LIKE TWO TABLESPOONS OR MORE) Any time one pound or more of mercury is released into the environment, it is mandatory to call the National Response Center (NRC). The NRC hotline operates 24 hours a day, 7 days a week. Call Note that because mercury is heavy, only two tablespoons of mercury weigh about one pound. VII. STORING, TRANSPORTING AND DISPOSING OF MERCURY A. Packaging Mercury for Storage and Transportation 1. All mercury-containing products or containers of mercury should be placed inside a larger container with a tight fitting lid. 2. Kitty litter or oil-absorbent matter should be placed around the product to protect it from breaking or sudden shocks. 3. Clearly label the storage container as "Mercury--DO NOT OPEN" and affix a hazardous waste label. 4. If you must wait for a hazardous waste collection day, store products safely in their original containers with the labels intact. 5. Pick up of hazardous waste is done by contract on a biannual basis. B. Recycling and Disposal Options Waste mercury is handled as hazardous waste by the Physical Plant Department. 14

15 Training: Instructor: Date Name Department 15