Linearized (accessible) table 2

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General note: For clarity, table 2 contains 7 sub-tables, each with its own caption. Each sub-table is a list of checkpoints with methods to evaluate quality for each checkpoint and a suggested practice guide to be used as a point of departure in developing a management plan. The practice guide can serve as the management plan for any institution that lacks resources or prefers not to develop its own management plan.

Caption: Table 2A: Identification and segregation of waste in the laboratory.

Summary: Check points to be considered for identification and segregation of waste in the laboratory, methods to evaluate quality and a suggested practice guide.

• Check Point = 1. Is there a place in the workplace to put unwanted chemicals?
  • Evaluation Method = Observe workplace, ask workers
  • Practice Guide = Each location for unwanted chemicals is marked with a sign that also carries simplified labeling instructions, e.g. Figure 2.
• Check Point = 2. Are waste container and labeling requirements posted, understood and followed?
  • Evaluation Method = Observe containers and labels, ask randomly selected worker to demonstrate procedures
  • Practice Guide = Each location for unwanted chemicals is marked with a sign that also carries simplified labeling instructions, e.g. Figure 2.
• Check Point = 3. Are unwanted chemicals adequately secure?
  • Evaluation Method = Observe
  • Practice Guide = The location for unwanted chemicals is in a room where the same workgroup uses and/or stores other chemicals and is protected by the same level of security.
• Check Point = 4. Are there provisions for accident prevention / consequence control (e.g. secondary containment, spill control materials)?
  • Evaluation Method = Observe, ask workers
  • Practice Guide = Place unwanted chemicals in a pan that will hold the contents of the largest individual container. Provide lab with spill control equipment & materials.
• Check Point = 5. Are known incompatibles isolated from one another?
  • Evaluation Method = Observe
  • Practice Guide = Provide separate secondary containment pans for incompatible groups, labeled by group. See Figure 2.

Caption:Table 2B: Collecting waste from laboratories by central EH&S unit

Summary: Check points to be considered in procedures for collecting waste from laboratories, methods to evaluate quality and a suggested practice guide.

• Check Point = 1. Does the collection system accept "unknowns" with minimal or zero penalty?
  • Evaluation Method = Ask EH&S management
  • Practice Guide = No direct charges for unknowns. Apply administrative discipline to labs that repeatedly create unknowns through careless practices.
• Check Point = 2. Is pre-collection effort minimized for labortory personnel?
  • Evaluation Method = Observe, compare with other facilities, ask supervisors & workers
  • Practice Guide = Labs label unwanted chemicals with chemical name and/or classification. EH&S staff provide other needed info. Collection is routine or by phone call, email or web form. No other preliminary paper-work. No transport to an out-of-work-area location by lab workers required. Lab must provide packaging that is tight, compatible, sound enough for local transportation and adequate for storage until collected by contractor.
• Check Point = 3. Is collection service predictable and customer-friendly?
  • Evaluation Method = Ask laboratory workers. Ask EH&S staff about procedures
  • Practice Guide = Assign collection date occurring within 7 days to call-in requests. Perform routine and call-in collections as scheduled. Notify labs immediately in case of unavoidable schedule change.
• Check Point = 4. Is the lab charged directly for removal of waste?
  • Evaluation Method = Ask EH&S and laboratory management
  • Practice Guide = Do not assess direct charges to laboratories or departments for waste removal.

Caption: Table 2C: Transportation from laboratory to central facility by EH&S unit

Summary: Check points to be considered in transporting waste from laboratories to a central facility, methods to evaluate quality and a suggested practice guide.

• Check Point = 1. Is packaging and labeling information checked to verify adequacy for transportation?
  • Evaluation Method = Observe collection procedure
  • Practice Guide = EH&S staff re-package materials or use secondary packaging if needed and assign transportation compatibility classification.
• Check Point = 2. Are materials properly identified and segregated in accordance with transportation rules including "fingerprinting," analysis or isolated transportation, if needed?
  • Evaluation Method = Observe collection procedure
  • Practice Guide = EH&S staff re-package materials or use secondary packaging if needed and assign transportation compatibility classification.
• Check Point = 3. Is the bill of lading accurate and does it contain all required information?
  • Evaluation Method = Observe collection procedure
  • Practice Guide = Vehicle carries bill of lading that lists materials and quantities. Vehicle has placards, if needed.
• Check Point = 4. Are carts and vehicle equipped for spill containment and/or control?
  • Evaluation Method = Observe collection equipment
  • Practice Guide = Transport carts provide secondary containment. Spill control equipment and supplies available in vehicle and/or at loading area and/or on transport carts.
• Check Point = 5. Do individuals, including drivers know their roles in case of emergency and are they properly equipped?
  • Evaluation Method = Ask EH&S staff
  • Practice Guide = Staff are trained. Carts and vehicle are placarded with basic emergency information and phone numbers (Figure 3), (Figure 4).

Caption:Table 2D: Work practices at central chemical waste management facility

Summary: Check points to be considered in work practices at a central chemical waste management facility, methods to evaluate quality and a suggested practice guide.

• Check Point = 1. Is waste secure against vandalism, theft and unauthorized entry?
  • Evaluation Method = Compare with other facilities, observe levels of security at other facilities on campus
  • Practice Guide = Secure facility against unauthorized entry at all times. Perform a security survey and implement recommendations. Placard loading areas against leaving unauthorized waste and with instructions to obtain service. (Figure 5). Unload transport vehicles immediately unless fully secured.
• Check Point = 2. Are incoming materials evaluated as soon as reasonably feasible?
  • Evaluation Method = Observe procedures, check records
  • Practice Guide = Evaluate chemicals and perform hazardous waste determination within 7 working days.
• Check Point = 3. Is storage time tracked and reasonable, i.e. waste isn't being ignored?
  • Evaluation Method = Observe dates on materials, check records
  • Practice Guide = Ship chemical waste at least annually. Wastes that must be shipped in separate containers may be accumulated for up to 2 years if necessary for economical labpacking.
• Check Point = 4. Are containers inspected regularly and problems documented and fixed?
  • Evaluation Method = Check records
  • Practice Guide = Weekly inspection log is up to date and contains information on problems discovered and actions taken.
• Check Point = 5. Are aisle space, segregation and other storage conditions satisfactory?
  • Evaluation Method = Observe
  • Practice Guide = Facility meets OSHA, NFPA, RCRA and current building code fire safety standards, has fire suppression throughout and earthquake resistance if needed.

Caption:Table 2E: Emergency response preparedness planning

Summary: Check points to be considered in emergency response preparedness planning, methods to evaluate quality and a suggested practice guide.

• Check Point = 1. Can every person state their role in case of emergency?
  • Evaluation Method = Ask laboratory personnel and EH&S staff
  • Practice Guide = Each person can describe their duties and whom to notify in case of spill, fire, break-in, vehicle accident, etc.
• Check Point = 2. Are supplies and equipment available and adequate?
  • Evaluation Method = Observe, compare with other facilities
  • Practice Guide = Minimum: Containment boom, shovel, absorbent material, dust pan, broom, mercury vacuum or spill kit. Gloves, boots, coveralls and goggles for two people.
• Check Point = 3. Is there a written emergency plan (only required if 3 or more workers involved) for all aspects of the work?    a. Collection?    b. Transportation?    c. Central facility?
  • Evaluation Method = Check records
  • Practice Guide = Emergency plan may also serve as a training document. The principal points are captured on a posted placard (Figure 6).

Caption: Table 2F: Record keeping practices for chemical waste

Summary: Check points to be considered in chemical waste record keeping practices, methods to evaluate quality and a suggested practice guide.

• Check Point = 1. Can every waste item be tracked from source to ultimate destination?
  • Evaluation Method = Check records
  • Practice Guide = Minimum—Records are sufficient to show that all waste collected by the program is properly managed and disposed of. Recommended—Records allow any item of waste to be tracked from source to treatment, disposal, commingled barrel or labpack and outgoing manifest. Records also permit reverse tracking to allow problem items to be tracked back to source.
• Check Point = 2. Do records accurately reflect actual waste quantities for P-list wastes?
  • Evaluation Method = Check records, ask EH&S staff
  • Practice Guide = Only acute hazardous wastes are identified as such. Recommended—Records show actual waste amounts, excluding container weights, for P-list wastes . Document methods for estimating and excluding container weight.
• Check Point = 3. Are inspection records complete and accurate?
  • Evaluation Method = Check records
  • Practice Guide = There is a weekly inspection log for the central facility that documents any problems found, remedial actions and preventive actions.
• Check Point = 4. Are manifest records properly created and maintained?
  • Evaluation Method = Check records
  • Practice Guide = Retain all manifests for required time period.
• Check Point = 5. Have all required reports been filed or published as required?
  • Evaluation Method = Check records
  • Practice Guide = File all required federal, state and local reports.

Caption: Table 2G: General management practices

Summary: Check points to be considered in general management practices, methods to evaluate quality and a suggested practice guide.

• Check Point = 1. Is someone in charge of the waste?
  • Evaluation Method = Ask laboratory workers and EH&S staff, ask supervisors
  • Practice Guide = Assign responsibility and appropriate authority at all stages from lab to final shipment. Train responsible persons according to the needs of their job.
  • Check Point = a. Do all involved persons know the general requirements, emergency procedures, etc.?
    • Evaluation Method = Ask laboratory workers and EH&S staff, ask supervisors
    • Practice Guide = Assign responsibility and appropriate authority at all stages from lab to final shipment. Train responsible persons according to the needs of their job.
  • Check Point = b. Does EH&S unit have explicit authority covering the proper handling of the waste?
    • Evaluation Method = Ask person in charge, review policy documents
    • Practice Guide = Assign responsibility and appropriate authority at all stages from lab to final shipment. Train responsible persons according to the needs of their job.
• Check Point = 2. Is the waste properly labeled and stored?
  • Evaluation Method = Questions and observations similar to Table 2A
  • Practice Guide = Segregate stored waste by compatibility group and store in compliance with applicable fire safety and environmental protection rules and good practices.
• Check Point = 3. Is there a procedure for removing the waste or getting it removed (either to central storage or by contractor)?
  • Evaluation Method = Ask EH&S staff, ask supervisor
  • Practice Guide = Train each person involved with waste management to explain their role in waste management.
• Check Point = 4. Are all stages of normal operations periodically reviewed?
  • Evaluation Method = Review minutes of staff meetings.
  • Practice Guide = Hold EH&S staff meetings at least monthly. Review accidents and errors at each meeting. Review general operations at least annually. Use meeting minutes to document issues considered, decisions and actions.
• Check Point = 5. Are accidents and errors analyzed?
  • Evaluation Method = Review minutes of staff meetings.
  • Practice Guide = Hold EH&S staff meetings at least monthly. Review accidents and errors at each meeting. Review general operations at least annually. Use meeting minutes to document issues considered, decisions and actions.
• Check Point = 6. Is information used to improve the system?
  • Evaluation Method = Review minutes of staff meetings and observe operations to assure that documented changes have been implemented.
  • Practice Guide = Hold EH&S staff meetings at least monthly. Review accidents and errors at each meeting. Review general operations at least annually. Use meeting minutes to document issues considered, decisions and actions.

Rev. 20 Mar 06, 0800
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