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Even when not required by environmental regulations, the following best practices are recommended.
Activity: Chemical Storage
- Store incompatible chemicals separately, i.e., separate acid, bases, organic solvents and oxidizers.
- Flammable chemicals should be stored in a ventilated flammables storage cabinet.
- Do not store chemicals in walkways or hallways or other means of egress.
- Chemical containers should be stored in pans, or trays made of compatible material that will act as secondary containment if a container breaks or leaks.
- Do not store open containers of chemicals in laboratory hoods.
- Minimize the storage of chemicals on laboratory bench tops.
- Store the minimum quantity of chemicals necessary.
- Store acids and bases below eye level.
- Make sure container caps are secure.
- Make sure containers are properly labeled. Labels should include name of the chemical, hazards and precautions required. Do not reuse containers without relabeling the exterior and defacing the old label.
- Keep a chemical spill kit available adequate to clean up the largest anticipated spill that could occur in the lab. Train personnel on spill clean up procedures.
- Clean up all spills quickly.
- Maintain general housekeeping in the lab. Keep bench tops, aisles, and walkways clear.
- Have an emergency evacuation plan. Train personnel in key elements of the plan and run periodic drills.
- Minimize the storage of combustible material in labs.
- Perform and document in a logbook periodic inspections of chemical storage areas for leaks, container deterioration. Inspection items should include the following: external corrosion, structural failure, spills and overfills due to operator error, failure of piping system (pipes, pumps, flanges, couplings, hoses, and valves), visual inspections of new tanks or containers for loose fittings, poor welds, and improper or poorly fitted gaskets, and inspect tank foundations and storage area coatings for integrity.
- Accept chemical donations only after careful consideration of how the chemical will be used and after ascertaining that the chemical is not contaminated, out of date, etc.
Container Management
- Ensure containers with incompatible wastes are not stored near each other so that if the containers were to break there would not be an adverse reaction.
- Clearly label waste containers with the words "Hazardous Waste" and name of the waste type and hazards (e.g., "corrosive, toxic").
- Log chemicals and quantities added to waste containers as chemicals are added.
- Train laboratory personnel on safe procedures for transferring chemicals to waste containers.
- Maintain separate containers for broken glassware, sharps, biohazard and radioactive waste.
- Maintain separate waste containers for compatible waste streams (acids, bases, oxidizers, organic solvents, radioactive waste)
- Do not store waste containers where they have the potential to freeze or are exposed to high heat.
- Keep waste containers in tubs or other secondary containment.
- Waste containers should be in good condition, not rusted or dented.
- Make sure waste containers are compatible with the waste type they are expected to contain.
- Keep an adequate spill control kit nearby and know how to use it.
- Clean up spills quickly if you are properly trained and equipped to do so.
- Periodically inspect the waste container area and log observations and corrective actions taken.
- When handling waste containers use mechanical aids such as drum lifts, drum hand trucks, drum dollies etc. Do not roll drums on their side or edge.
Activity: Emergency Equipment
Even when not required by environmental regulations, the following best practices
for laboratory emergency equipment are recommended.
- Emergency eyewash stations & showers in areas where there is the potential
to come into contact with hazardous chemicals, with unobstructed access from
any point in the lab within 10 seconds, and located on the same level as the
potential hazard.
- Fire extinguishers easily accessible, and of of size and type to be effective
against an anticipated fire.
- Fire Blankets.
- Communications systems including telephones, radios, alarms.
- Emergency personal protective equipment including SCBA’s, disposable coveralls,
gloves, eye protection, short-term escape respirators.
- Spill control equipment including, spill pillows, absorbent pads, drum berms,
drain plugs, hand pumps, neutralization solutions.
- Air monitoring instrumentation, either portable or fixed systems if needed.
- First aid kit, including burn kit.
- Periodic inspection of equipment to ensure its effectiveness and availability.
- Hands-on training for laboratory personnel on the use of emergency equipment.
Activity: Sinks and Drains
Even when not required by environmental regulations, the following best practices
are recommended.
- Train laboratory personnel in waste management practices. Be sure they know
what can and cannot be disposed of down the drain.
- Periodic inspections should be performed to ensure proper disposal procedures
are being performed.
- Substitute the use of biodegradable cleaners for chromic-sulfuric acid when
washing laboratory glassware.
- Use microchemistry techniques where possible.
- Plan experiments to minimize waste generation.
- Clean up any spill promptly.
- Keep rags, mops, absorbents, and other cleanup supplies readily accessible
to all work areas.
- Keep a spill control kit and drain plugs nearby.
- Check with the local POTW or onsite wastewater treatment plant regarding
what can be safely disposed of down sinks and drains.
- Close off or guard laboratory hood cup sinks from spill within the hood.
Activity: Laboratory Hoods
Even when not required by environmental regulations, the following best practices
are recommended to minimize the emission of hazardous air pollutants from laboratory
hoods.
- Identify opportunities to eliminate or reduce emissions.
- Use microchemistry techniques.
- Do not store chemicals in laboratory hoods.
- Make sure containers that hold volatile chemicals are securely capped.
- Maintain pollution control equipment and keep maintenance records.
- Maintain laboratory ventilation systems and keep maintenance records.
Activity: Gas Cylinder Management
Laboratory personnel may occasionally be required to handle compressed gas
cylinders. Employees that perform work involving compressed gas cylinders should
be familiar with their hazards and safe practices. Even when not required by environmental
or OSHA regulations, the following best practices are recommended.
Identification and Labeling
- All gas cylinders must be clearly labeled.
- Do not accept a compressed gas cylinder for use that does not legibly identify its contents by name.
- Never rely on the color of the cylinder for identification.
- Gas lines leading from a compressed gas supply must be labeled to identify the gas, the laboratory or area served, and the relevant emergency telephone numbers.
- Signs must be posted in areas where flammable compressed gases are stored, identifying the substances and appropriate precautions (e.g., HYDROGEN - FLAMMABLE GAS - NO SMOKING - NO OPEN FLAMES).
Engineering Controls / Design Considerations
- Keep hazardous gas cylinders in gas cylinder cabinets or racks, with the exception of cylinders containing a non-toxic, flammable gas, and cylinders used in fume hood applications.
- Place a smoke detector adjacent to flammable gas cylinders, connected if possible to the building alarm system. If possible, interlock smoke detector activation with the shutdown of hazardous gas flow.
- Connect all ducts used to exhaust hazardous compressed gas cylinders or gas-carrying components to a ventilation alarm.
- Place a safety shower or eyewash with a wand in areas where corrosive gases are used or stored.
- Make sure that all gas piping is compatible with the gases used and capable of withstanding full cylinder pressure.
- Never lubricate, modify, force, or tamper with a cylinder valve. Use the appropriate regulator on each gas cylinder.
- Use check valves when there is the possibility of back flow into the cylinder.
Using Cylinders
- Always use safety glasses with side shields when handling and using compressed
gases, especially when connecting and disconnecting compressed gas regulators
and lines.
- Never use a cylinder that cannot be identified positively.
- Never use a cylinder of compressed gas without a pressure-reducing regulator
attached to the cylinder valve.
Activity: Mixed Waste
Even when not required by environmental regulations, the following best practices are recommended for minimizing and managing mixed wastes.
- Replace toluene based liquid scintillation fluid with non-ignitable fluid. This replacement results in having a potential mixed waste into a radioactive waste.
- Use low volume liquid scintillation vials.
- Use radionuclides with short half lives that can be allowed to decay in storage prior to disposal.
- Avoid cross contamination of other waste streams.
Activity: Satellite Accumulation Areas
Even when not required by environmental regulations, the following best practices are recommended.
- Only the waste generator may add waste to the Satellite Accumulation Area (SAA). The waste generator will have the most knowledge about the characteristics of the waste and will be in the best position to ensure the waste is properly labeled and not mixed with incompatible wastes. Poorly labeled waste or improper mixtures may require additional analysis or cause accidents.
- Every waste container in the Satellite Accumulation Area should be labeled with the words "Hazardous Waste", the common chemical name or names of the waste (not chemical formula), and hazardous properties.
- Consider keeping a log to record the date, amount and type of waste added to the SAA to prevent the mixing of incompatibles.
- Be sure container labels are compatible with the waste type. Some inks and markers may run or become illegible on contact with some solvents. Some adhesive labels may fall off or be damaged on contact with solvents, acid or bases. Better yet, use waste tags that attach to the containers with a wire tie.
- The SAA must be under the control of the generator, who should be accountable for managing the waste in the area.
- The ideal SAA might be a separate ventilated cabinet (often a fume hood) or containers stored in an area without floor drains and with secondary containment, either small tubs for containers of compatible wastes or drum tubs for drums. Secondary containment should be able to contain 100% of the largest container within it or 10% of the total volume of containers held within the secondary containment.
- SAAs should be located away from doorways, walkways or other means of egress.
- SAAs that accumulate flammable liquids such as organic solvents must also meet fire safety code requirements, such as storage in a ventilated flammables cabinet with a fire extinguisher nearby.
- Do not accumulate flammable liquids in glass containers. Red metal safety cans should be used.
- Secondary containment tubs of multiple containers should be compatible with the wastes they hold and hold only wastes that are compatible with each other.
- Do not store usable chemicals, reagents or unmarked bottles in the SAA. These may be mistaken for improperly labeled waste.
Activity: Toxic Use & Waste Minimization
Toxic use reduction and waste minimization activities apply not only to wastes but includes the management of releases to air, water, and generation of solid and non-hazardous waste. Best practices for a number of environmental areas related to pollution prevention in laboratories are described below.
Air Quality
- Implement microscale chemistry techniques where possible.
- Make sure the caps and container lids on volatile chemicals are secure.
- Do not store chemicals in laboratory fume hoods.
- Substitute less toxic or less volatile chemicals in processes where possible.
Wastewater
- Review processes and procedures for opportunities to minimize wastewater
generation.
- Implement microscale chemistry techniques where possible.
- Use organic dishwashing solutions instead of chromic-sulfuric acid mixtures
when washing glassware if possible.
Hazardous Waste
- Minimize the amount of chemicals stored in the lab to the minimum quantities
needed to avoid having to dispose of chemicals that expire or deteriorate
during storage.
- Develop an inventory of chemicals no longer needed in your lab that could
possibly be used by another.
- Where possible substitute less toxic chemicals where toxic chemicals are
used in a procedure or process.
- Evaluate ways to reduce the amount of toxic chemicals used in lab procedures.
- Re-use or recycle spent solvent.
- Avoid contaminating non-hazardous waste streams with hazardous, radioactive
or biohazardous material.
- If possible, small amounts of hazardous waste may be effectively treated
in the laboratory, rendering it non-hazardous prior to disposal. (Note: This
action may require a RCRA permit in some circumstances) On site treatment
techniques may include:
- pH neutralization
- Treatment in accumulation containers, i.e., precipitation of heavy metals,
- Onsite recycling
- Burning in boilers or furnaces
- Include detoxification or waste treatment steps in lab procedures
Radioactive and Mixed Waste
- Replace toluene based liquid scintillation fluid with non-ignitable fluid making a potential mixed waste into a radioactive waste.
- Use low volume liquid scintillation vials.
Non-Hazardous and Special Waste
- Use two sided copying
- Make procedures, MSDSs, manuals, etc. available electronically
- Use e-mail instead of hard copies
- Share trade periodicals rather than maintaining multiple subcriptions
- Use reusable containers
- Use rechargeable batteries
Activity: Training
More detailed training information is provided in the regulatory requirements sections of the EVC. Even when not required by environmental regulations, the following best practices are recommended.
- Training courses should be developed in a systematic manner, including the development of a course lesson plan. Course development should include:
- An assessment of training needs
- Learning objectives
- Structured course design and presentation
- Development of evaluation methods
- Methods to determine successful completion of the course
- The physical training environment should be:
- Safe
- Comfortable
- Free from distractions
- Trainers should have adequate technical knowledge to teach the course content, and be familiar with training delivery methods and adult learning.
- Trainees should have the opportunity to ask questions about material presented.
- Training for physical activities and skills such as use of personal protective equipment (PPE) or container handling should include a hands-on skills development and assessment segment.
- Trainees should be evaluated to assess their level of understanding, skill development and abilities.
- Trainers should be evaluated to assess subject matter knowledge, and presentation skills to assist in course improvement.
- Training records/documentation should be readily retrievable and include:
- Date, location and duration of the course
- Title and description of course content
- Names of instructors
- Names of attendees
- If training certificates are issued to attendees they should include the following:
- Name of the student
- Title of the course
- Date and duration of class
- Statement of successful completion
- Reference to regulatory citation if training is intended to meet specific regulatory requirement.
- Name, signature and date of instructor
Activity: Waste Determinations
Even when not required by regulations, the following best practices are recommended.
- Retain records of analytical data that is used in making waste determinations for a minimum of three years, keep these files in an organized manner so they are easy to find.
- Develop a filing system for waste determination files, sorted by waste stream.
- Ensure that waste determination is confirmed by the generator, even if an outside company performs the analysis and renders an opinion of the waste determination.
- Avoid mixing waste in the same container, which can result in a waste classification for the entire volume of waste that is not necessary.
- Review your waste determination process every six months at a minimum to evaluate whether these determinations are accurate and consistent.
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