Project XL Final Rule	Final Project Agreement Final Agreement XL Stakeholders Leighton Letter Regulatory Relief XL Rule	Legal Aspects RCRA and Labs LSEM RCRA interp Minimizing Costs Current Reg Arena UConn RCRA Workshop Yale RCRA Inspection	UVM XL Info Development of a Laboratory EMP Glassware Waste Project Waste Min Project Contacts and Info	RCRA LabWAM Priorities and Accomplishments Background Information Fixing RCRA (Powerpoint) Chemical Safety Levels Kids in Labs (Powerpoint) California Colorado Enforcement Region 1 Region 2 Region 3
The R&D NESHAP Development Process Clean Air Act
Pilot Schools' Draft EMP's	Boston College BC Plan BC Standards	UMASS Boston EMP Environmental Management Standard	University of Vermont EMP Lab Workers' FAQ's The Rule, UVM docs
Baseline Report	Informatics	Green Bridge	Websites	LabXL Home

 

Preface

On September 28, 1999, the Environmental Protection Agency (EPA), in conjunction with the Department of Environmental Protection (DEP), published the final rule "University Laboratories XL Project - Laboratory Environmental Management Standard," 40 CFR 262.100. See Appendix A. This new standard, which applies to laboratories meeting the definition of laboratory use of hazardous chemicals, is effective on __________ for Boston College Laboratories.

The guidelines specified in this Environmental Management Plan (EMP) identifies standards and procedures, responsibilities, pollution control, performance criteria, resources and work practices that both protect human health and the environment from the hazards presented by laboratory wastes. Many of the standards and procedures recommended in this plan are referred to in Boston College’s Chemical Hygiene Plan (CHP).

Copies of this plan will be:

• available on line at http://www.bc.edu/ehs
• situated in the Office of Environmental Health and Safety
• situated in each laboratory and department office

Requests for additional copies and questions regarding the EMP should be addressed to:

Suzanne Howard
Director, Office of Environmental Health and Safety
St. Clements, Room 120
email: howardsu@bc.edu
phone: (617) 552-0308

1.0 Administration

1.1 Policy

Boston College’s Policies and Procedure Manual documents the function and responsibility of Environmental Health and Safety. This policy can be found on line at:

http://www.bc.edu/bc_org/evp/polpr/I/1-310-001.html

The College is also committed to the policies and procedures outlined in this EMP. Implementation of this program will be through the Office of Environmental Health and Safety, however, safe practices and compliance is everyone’s responsibility. Section 1.3 outlines relevant responsibilities to members of the college community.

The Administration of Boston College commits to providing the necessary resources for environmental protection while fostering intellectual development for it’s students, promoting insight and understanding for it’s research activities, and providing a safe, effective and efficient workplace for it’s faculty, staff, students and visitors.

______________________________________________________ ____________

Date

1.2 Coverage

The policies set forth in this EMP are applicable to all laboratory workers generating laboratory chemical waste. This includes faculty, staff, graduate students (ie. , teaching assistants, research assistants, laboratory assistants), undergraduate students, contractors and visitors at Boston College. Laboratory policies, however, cover only duties and tasks performed by laboratory workers while physically situated in BC laboratory facilities. Materials excluded from this plan include: radiological waste, biological waste, equipment, and photographic waste. These wastes are managed under separate Boston College plans.

The departments covered under this Plan include laboratories in Chemistry situated in the Merkert Chemistry Center; Physics and Biology situated in Higgins Hall; Psychology situated in McGuinn and Higgins Hall, and Geology & Geophysics situated in Devlin Hall.

Each department will maintain a list of faculty and their laboratories identified by room numbers. All of the lab rooms, under the administration of one faculty member situated in one building, may be considered "one laboratory" under this EMP. This shall be defined on the list provided by each department (Appendix B). A copy of this list should be forwarded to the Office of EH&S on an annual basis and or whenever a change occurs. Shared* laboratory spaces may not store laboratory waste, except as approved by the Office of Environmental Health and Safety and if listed on annual department list. Waste generated in shared spaces not approved for storage must be brought back to the researchers laboratory identified in the departmental list.

*Shared laboratory space is a room used for multiple research or academic interests that is not under the control of one person.

1.3 Administration of Responsibility

To fully implement policies, the assistance and cooperation of all Boston College faculty, staff and students is necessary. The following descriptions outline key roles and responsibilities involved in implementation and maintenance of this plan.

1.3.1 Environmental Health and Safety Oversight Panel

The EH&S Oversight Panel is comprised of senior level administrators to include the Financial Vice President and Treasurer, the Director of Buildings and Grounds, the Director of Research Administration, General Counsel, Director of Health Services, Director of Risk Management, Associate Director of University Housing, Associate Vice President of State and Community Relations, Chemistry Department Faculty, and the Director of Environmental Health and Safety. The Panel’s mission is to review and assist the Office of EH&S in developing, recommending and approving safety and enviornmental policies and management systems. The Panel will serve as an umbrella committee for other EH&S related committees on campus to ensure the University’s compliance with federal, state and local regulations and best practices to safeguard members of the community and protect the environment.

In this, the Panel will review on an annual basis, activities and issues regarding the administration of this EMP.

1.3.2 Office of Environmental Health and Safety

The Office of EH&S reports to the Director of Buildings and Grounds at Boston College. The organizational chart for Boston College Administrators is in Appendix C. The Office of EH&S will oversee the Environmental Management Plan for Boston College and will:

• periodically inspect, at least once a year, laboratory facilities to ensure compliance with the provisions of the EMP.
• investigate environmental releases.
• coordinate maintenance of training records.
• update the EMP as necessary.
• ensure that safety equipment, including emergency response equipment is inspected and working properly and appropriate to the hazards in the lab
• remain abreast of regulatory and legal requirements associated with use of laboratory waste.
• assist departments with the annual Hazardous Chemical of Concern (HCOC) inventory

1.3.3 Science Departments

Each department which generates laboratory waste is responsible for the implementation of the EMP within the laboratories under its administrative control. Each department will assign an individual or committee (department representative) to work with the Office of EH&S to:

• ensure that his/her workers know and follow policies and practices,
• ensure that his/her workers have been properly trained in regards to this EMP, and that training activities have been properly documented.
• ensure that control measures are employed.
• ensure that appropriate personal protective equipment is utilized.
• periodically inspect laboratory facilities to ensure compliance
• inform the EH&S Office of any environmental releases. Provide recommendations concerning these incidents, and ensure that corrective action is taken.
• supervise the annual hazardous chemicals of concern inventory.

1.3.4 Laboratory Supervisors/Faculty

The immediate supervisor of laboratory workers is responsible for coordinating with the designated departmental representative to implement the policies and procedures of the EMP. It is the responsibility of each laboratory supervisor to:

• ensure that workers know and follow policies and practices
• ensure that workers have been properly trained in regards to this EMP, and that training activities in the lab are documented
• ensure that control measures selected for use are adequate and protective equipment is readily available
• follow recommendations made by the University to correct any unsafe laboratory conditions.
• maintain HCOC inventory
• coordinate with department designee

1.3.5 Laboratory Workers

Laboratory workers are expected to:

• Laboratory workers are expected to learn, understand, and observe all policies and practices listed herein.
• become familiar with good standard practices with procedures and chemicals they are involved with by reviewing current literature, available Material Safety Data Sheets and applicable Boston College policies.
• wear appropriate personal protective equipment.
• use engineering controls and safety equipment properly
• participate in all required training programs
• report to the responsible faculty all facts pertaining to incidents resulting in releases of hazardous chemicals, and any action or condition that may cause an incident with hazardous chemicals.

1.3.6 Hazardous Waste Contractor

The hazardous waste contractor servicing Boston College will perform the following duties in regards to this EMP:

• alert EH&S staff of non-compliance issues noted in laboratories
• perform follow-up lab inspections as requested
• may determine when a material is a laboratory waste
• check P-listed waste accumulation per lab
• remove laboratory waste from lab to main accumulation areas
• remain aware of pollution prevention opportunities
• assist in the survey of the hazardous chemicals of concern
• participate in required training
• observe University policies and procedures

1.3.7 Visitors and Contractors

Visitors of laboratories at Boston College who generate hazardous waste, and contractors who work in laboratories who need to be aware of this EMP observe University policies and procedures.

1.4 Minimum Performance Criteria

Appendix A, the Standard, lists all the Minimum Performance Criteria in section 262.104. Compliance with these standards will be checked when performing laboratory inspections. They include requirements on the following and will be discussed in relevant sections of this plan:

• Labeling (2.3)
• Accumulation (2.4)
• Container Management (2.4)
• Emergency Response (3.3)
• Incident Investigation (3.3)
• Transfer of Waste (3.2)
• Information & Training (6.0)

1.5 Environmental Goals

The University, through the Office of Environmental Health and Safety and departments covered under this plan, will review and update environmental objectives and targets important to the goals of the University, to student education and in support of research. These goals will be reviewed by the Environmental Health and Safety Oversight Panel.

On an annual basis, the Director of EH&S, or designee, will review legal requirements, lab inspection reports, reportable laboratory incidents, and other appropriate information (identified in Section 1.6) to set the upcoming year’s goals. The form listed in Appendix D will be utilized to set these goals. Once set, this form will be sent to departments covered under this plan for comment. The spring meeting of the EH&S Oversight Panel will review these goals and provide comment. The Director of EH&S, or designee, will then put these goals into action and disseminate information accordingly.

Some of the objectives may include:

• Sustained compliance with EMP
• Increased awareness of environmental issues in laboratories and their impact
• Pollution prevention opportunities
• Reduce the amount of waste generated and disposed of in labs on campus
• Share information with laboratories at other institutions on successes and failures

For the first year of the pilot study, the goal will be to implement this EMP in laboratories at Boston College.

1.6 Identification & Tracking Legal Requirements

The Office of EH&S will identify and track legal requirements applicable to Laboratory Waste through the following means:

• Journals - (may include Chemical Health and Safety, published by Elsevier Science for the American Chemical Society)
• Newsletters - (may include Laboratory Safety & Environmental Management published by PRIZIM, Inc.)
• World Wide Web - (may include EPA Web Site, DEP Web Site)
• Professional Association Meetings such as the Campus Safety Health and Environmental Management Association.
• EPA Compliance Assistance Program

Lab workers will be updated with new information via the following means:

• Boston College Laboratory Safety Newsletter
• Boston College Office of EH&S Web Site
• Memoranda to Faculty and Staff
• Meetings
• Trainings

1.7 Lab Inspections

Periodic inspections will be performed by the Office of EH&S. These will consist of formal reviews of conformance with policies and procedures stated in this document. Inspections may occur during annual Chemical Hygiene Inspections. See EMP Laboratory Checklist in Appendix E. Inspections may be unannounced; however, the Office of EH&S will attempt to include faculty members during inspections of their work areas.

The completed checklist will be sent to the Principal Investigator or designee. Upon receipt, the PI will correct any issues, sign-off on the checklist and send a copy back to the Office of EH&S.

All affected laboratories will perform annual self reviews, using the EMP Checklist as a guideline, to ensure compliance with this Plan. These self-inspections will be reviewed by EH&S during periodic inspection.

Waste containers should be inspected and documented on the posted Waste Inspection Form every week. See Appendix F.

Weekly waste pick ups may also be a time to review compliance with the EMP. Boston College’s hazardous waste service contractor will be responsible to alert the Office of EH&S and lab workers of non-compliance issues for corrective action.

1.8 Non-Conformance

Issues of non-conformance found in a laboratory that can be taken care of immediately shall be addressed at that time. This can be determined during routine inspections or during informal reviews.

The EMP checklist will be used during periodic EH&S inspections and will be forwarded to the principal investigator (PI) when complete. Upon receipt of the checklist, the PI, or designee will correct any issues of non-conformance and sign off on the form. A signed copy will be returned to EH&S. The Office of EH&S will then confirm corrective action taken.

EH&S will forward the checklist to the contractor and note items that should be reviewed. The contractor will note down on the checklist the action taken in the lab and drop off the form in the EH&S Office within 24 hours of being on site.

If the same issue is noted after the second inspection, and is considered significant in the professional judgement of EH&S staff or designee, the department head will also be notified in writing. If, after three inspections of a laboratory, the same significant issue exists, a report will be sent to the Dean of Arts and Sciences for further action, and the University Chemical Hygiene Committee.

In cases of imminent danger to life, health or the environment, the Director of EH&S, or designee, is authorized to order the cessation of hazardous activity until the danger from such a condition is abated or adequate measures have been taken.

1.9 Recordkeeping Requirements

Documents to be maintained in the Office of EH&S applicable to this program include:

• Training Records
• Laboratory Inspection reports
• Reports summarizing performance against annual objectives and targets
• Records of non-conformance and corrective action
• Applicable regulations
• Environmental Management Plan
• Hazardous Chemicals of Concern
• List of faculty and laboratories identified by room number
• Incident Reports
• Safety equipment inspection reports
• Chemical Hygiene Plan
• Laboratory Guide for Renovations, Remodels, Moves and Terminations

Records to be maintained in Department Offices and or individual laboratories include:

• Hazardous Chemicals of Concern lists will be kept in departmental files.
• Environmental Management Plan
• List of faculty and laboratories identified by room number
• Weekly container inspections (should be posted near accumulation areas)
• Laboratory Inspection reports and corrective actions taken
• Material Safety Data Sheets

Records will be kept for three years or in accordance with other legal requirements as they apply.

1.10 EMP Updates

Proposed revisions to the EMP can be submitted to the Office of EH&S. EH&S will bring proposed revisions to the University Chemical Hygiene Committee for review and approval. Minor changes to the EMP can be made as necessary by the Office of EH&S.

The EMP will be kept updated on the EH&S web page. Laboratories will be advised of changes through the Lab Safety Newsletter or via interoffice memorandums.

2.0 Laboratory Protocols

This section will describe the process of determining a laboratory waste, labeling containers, storage of waste containers, allowable amounts of accumulated material and removal of waste containers from a laboratory.

Definitions:

Laboratory Waste

A hazardous chemical that results from laboratory scale activities and includes the following: excess or unused hazardous chemicals that may or may not be reused; RCRA hazardous waste (see below) and chemicals determined not to be RCRA hazardous waste.

Laboratory waste must not result in the release of hazardous constituents into the land, air and water where such release is prohibited under federal law.

Chemical Hazardous Waste :

Under EPA’s Hazardous waste statute, the Resource Conservation and Recovery Act (RCRA), a hazardous waste is defined as a "solid waste or combination of solid wastes, which because of its quantity, concentration, or chemical, or infectious characteristics may (1) cause or significantly contribute to an increase in mortality or an increase in serious irreversible or incapacitating reversible illness or (2) pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of or otherwise managed." EPA also states a waste is hazardous if it is "ignitable, corrosive, reactive or toxic", or fits one of these lists: (1) Non-Specific Source Wastes (F Codes); (2) Discarded Commercial Chemical Products, Off-Specification Species, Container Residues and Spill Residues; (3) Acute Discarded Waste [in its original form](P Codes); (4) Toxic Discarded Waste [in its original form] (U Codes). Contact EH&S for lists.

2.1 Waste Determination

Several individuals may determine when a material becomes a laboratory waste. This includes:

• Laboratory worker,
• EH&S personnel,
• Hazardous waste contractor.

A material can be designated as laboratory waste when:

• it has gone through a research process, or
• it is a virgin chemical no longer needed, or
• it is clean up material from a chemical spill.

When a laboratory waste container is ready for removal, it will be removed and directly transported to the main accumulation area. Main accumulation areas are situated in Higgins Hall and Merkert Chemistry Center. Upon reaching the main accumulation area, the hazardous waste contractor or trained EH&S staff will determine if the laboratory waste will be reused, if it must be managed as RCRA hazardous waste, or is a non-hazardous waste.

2.2 Identifying Acutely Hazardous Waste

Acute hazardous waste (or P-listed waste) is defined in 40 CFR 261.33 and 310 CMR 30.136. In the laboratory setting, this type of waste could be a commercial chemical product not yet used, remains from a spill, or the residue and the container of a P listed waste commercial product . The generic name(s) of the chemicals are shown on the list of acutely hazardous waste in Appendix G.

Laboratory workers will be responsible for ensuring that no more than 1 liter (one quart) of acutely hazardous laboratory waste is accumulated at one time in a lab. This may be checked when filling out the weekly Waste Inspection Form. The hazardous waste contractor will also check accumulated amounts of P-listed waste during weekly waste pick ups. Lastly, EH&S’s annual inspections will look at the accumulation of acutely hazardous waste in a laboratory. Once one liter of this material is accumulated, follow procedures for pick up of the waste material from the laboratory.

2.3 Labeling Waste Containers

All laboratory waste must be labeled with:

• the words "Laboratory Waste"
• chemical name(s) of all hazardous compounds
• name of responsible faculty member
• room number
• date the container is filled
• general hazard class (ie. ignitable, corrosive, oxidant toxic, other)

If the container is too small to hold a label, then it shall be placed on a larger secondary container with a label. Printed labels can be obtained from the Office of EH&S, the department office or the hazardous waste service contractor.

2.4 Accumulation & Storage of Waste

Each lab may temporarily hold an aggregate of 208 liters (55 gallons) of laboratory waste and 1 liter (one quart) of acutely hazardous laboratory waste. Appropriate size containers for waste should be utilized.

Segregate hazardous chemical waste in containers according to chart in Appendix H. Store incompatible containers of laboratory waste in separate areas. See Figure One in the CHP for a list of incompatible chemicals. Also refer to reference material such as Prudent Practices in the Laboratory available in each department office.

Containers of waste must be securely closed with a cap, lid or funnel (with attached lid), etc. at all times except when wastes are being added to (including during in-line waste collection) or removed from the container. In line waste collection refers to any system that accumulates laboratory wastes automatically, periodically or continuously, and is associated with a chemical or instrumental operation in a laboratory. The following standards will apply to in-line waste collection:

• The collection system must be constructed to prevent the release of laboratory waste into the environment.
• Fail-safe mechanisms should be put in place by the laboratory.
• The researcher responsible for the activity must be present in the lab, at all times, during in-line waste collection if the collection of waste is manual.
• If the collection is through an automatic system, secondary containment and periodic inspections are required to ensure issues such as leakage or full containers are identified.
• Any failures of in-line waste collection procedures that results in an environmental release must be immediately reported to EH&S. Corrective actions to remediate the failure must be taken immediately.
• In-line systems at Boston College refers to three pieces of equipment: a Liquid Chromotographs and Peptide or DNA Synthesizers. Prior to a laboratory utilizing another in-line system, approval by EH&S is required. The system will then be included in this section of the Plan.

2.5 Removal of Waste from Labs

Dated laboratory waste has 30 days to be directly transferred, by the contracted hazardous waste hauler, to the University’s main accumulation area(s).

A hazardous waste service company is used to remove waste from laboratories and bring it to the main accumulation area. No laboratory workers can take laboratory waste to the main accumulation area, unless authorized by EH&S.

The service company will come on campus weekly to remove waste from the laboratories. Labs can sign up to have an automatic pick up, or drop off the Hazardous Waste Collection Form (Appendix I) in your department office, or call the Office of EH&S at 2-0308 for a pick up.

Use the following steps to have processed laboratory wastes removed:

• Attach a laboratory waste sticker to a container when first adding in waste.
• Fill out label as indicated.
• Situate waste in designated waste pick up area for your lab when container is full.
• Waste is ready to be removed from the laboratory if the containers are full, the lab has reached its waste accumulation limits, or the laboratory requests removal.
• Inventory the waste on the Hazardous Waste Collection Form.
• Drop off completed forms at your department office. The hazardous waste service company will pick up the inventory forms to determine which labs to collect waste from.
• If your laboratory has a large amount of waste due to a clean-out, contact the EH&S Office for disposal procedures. DO NOT include waste clean outs in the regular weekly pick-ups.

Use the following steps to have virgin chemicals removed:

• Check with other laboratories to determine if the material can be used.
• Forward the amount of material recycled/reused within the University documenting: chemical name, amount, lab originating from, and lab destination to the Office of EH&S at howardsu@bc.edu.

If not,

• Date the container on the original label when it is no longer wanted.
• Determine if the material is a P-listed waste and if so, assure that the amount does not exceed 1 liter or weight equivalent.
• Situate waste in designated waste pick up area for your lab.

Follow the steps outlined above to remove waste from laboratories.

2.6 Laboratory Clean outs

Refer to BC’s ‘Laboratory Guide for Renovations, Remodels, Moves, and Termination’s’

3.0 Standard Operating Procedures

3.1 Physical and Chemical Hazards/Control Measures

Refer to Section 2.0, Standard Operating Procedures, and 3.0, Control Measures in Boston College’s Chemical Hygiene Plan which will include:

• Engineering Controls such as fume hoods,
• Personal Protective Equipment
• Hygiene Practices, and
• Containment strategies

3.2 Transferring and Moving Lab Wastes

All laboratory chemicals will be transferred and moved in accordance with policies set in Boston College’s Chemical Hygiene Plan. See Section 2.5.6 in the Chemical Hygiene Plan, Transport of Hazardous Chemicals.

Laboratory wastes will be moved by trained personnel, designated by EH&S personnel, following applicable regulatory guidelines to the main accumulation areas.

3.3 Emergency Preparedness and Response Procedures

Procedures for laboratory workers for hazardous material emergency preparedness and response is covered in Boston College’s Chemical Hygiene Plan, Section 2.6 "Emergency/Contingency Planning". Emergency contact information is also posted near or at laboratory phones.

Emergency response equipment (ie. spill kits to manage incidental spills) will be situated in each laboratory, labeled and stored with other safety equipment. Replenishment material is available in each department (contact Department Administrator), or in the Office of EH&S.

Laboratory waste spills, exposures and other incidents that trigger a reportable emergency or that require reporting under institutional policy will be investigated and documented using BC’s Incident Report Form (Appendix J). Corrective actions to prevent future incidents will be recommended by the individual(s) investigating the incident to appropriate department head and or faculty in-charge.

Evacuation Procedures

In the event that an incident poses an actual or potential threat to human health or safety, the immediate evacuation of personnel in the affected area is required. If evacuation of the area around the campus is deemed necessary, Boston College’s Emergency Coordinator will advise local authorities (i.e. fire, police) of the potential threat to human health and or the environment.

The Emergency Coordinator or any personnel who discovers a release or fire involving hazardous waste should activate the facility fire alarm and contact Boston College Police Department at their emergency number, 2-4444.

The on-scene Emergency Coordinator shall direct the evacuation until the Fire Department arrives.

• In each occurrence of an evacuation emergency, it shall be the responsibility of the top ranking member of each department to take charge of the personnel and property in his/her department.
• In all cases where the building is being evacuated, stop all activities and shut down all operations, if possible.
• All occupants of the building (students, employees, and visitors) shall leave the building immediately and in an orderly manner.
• When evacuating the building, all personnel shall proceed to a designated assembly area. See Appendix K for designated areas for Merkert, Higgins, Devlin and McGuinn. In inclement weather, Merkert occupants shall proceed to Conte Forum, Higgins occupants to Fulton Hall, and Devlin occupants to O’Neill Library.
• During the evacuation, the on-scene Emergency Coordinator and appointed aides shall ensure that all unauthorized personnel shall not enter the evacuated area.
• The on-scene Emergency Coordinator and Department Heads shall attempt to account for all personnel in the affected building. Department Heads will make a head count and report any missing personnel to the on-scene Emergency Coordinator.
• The decision to re-enter the facility shall be made by the on-scene Emergency Coordinator after consultation with the local and other government officials.
• The on-scene Emergency Coordinator shall obtain rescue services for injured people where required.

4.0 Pollution Prevention

EPA’s definition of pollution prevention, or P2, include the following: P2 is source reduction and other practices that reduce or eliminate the creation of pollutants through the increased efficiency in the use of raw materials, energy, water or other resources, or the protection of natural resources by conservation.

The Office of EH&S will work with science faculty to promote pollution prevention activities. The goal is to decrease the amount of hazardous waste generated or reduce the toxicity of the waste generated in laboratories. Reduction lowers disposal costs, reduces hazards, reduces long-term liability and promotes a cleaner and healthier environment.

BC’s hired hazardous waste hauler will also remain aware of potential pollution prevention opportunities and inform both EH&S and the faculty of these opportunities.

Pollution prevention opportunities will be evaluated during annual laboratory inspections conducted by EH&S. With the assistance of the hazardous waste hauler, EH&S will look at significant waste streams generated by the labs to determine which methods, as described below, can be used. The P2 Form in Appendix L will be used to measure and evaluate activities. At least one evaluation for pollution prevention will occur annually.

Success of P2 activities will be promoted to other laboratories and information disseminated via the EH&S website and the EH&S quarterly laboratory newsletter. Successful programs will noted on the EMP checklist.

Methods:

Chemical Redistribution

Unopened or unused portions of chemicals can be redistributed to other laboratories. Prior to disposing of unused chemicals during lab clean-outs, moves, etc., check with other laboratories to see if they could use the material. If not, contact EH&S and these materials will be managed in the hazardous materials storage area in Higgins Hall. Therefore, prior to ordering new chemicals, check with EH&S to see if any of the surplus chemicals is what you are looking for, and you can have it for free.

End of Process Treatment

End of process treatments can be incorporated into research protocols. This can include neutralization procedures or other standard practices outlined in many reference materials. End of process treatments can change a hazardous material to a less hazardous or non-hazardous material. One excellent book is the "Second Edition, Hazardous Laboratory Chemicals Disposal Guide" by Margaret-Ann Armour, CRC Press.

Gas Cylinders

Rental of gas cylinders is the best approach. Determine if lecture size cylinders can also be rented. If not, ensure that one can return used cylinders back to the manufacturer for disposal.

Management

Periodic inventories of chemical supplies, inventory control, and purchase of minimal quantities are all ways to manage chemicals in your area. Order smaller quantities of chemicals to ensure you use up chemicals before the expiration date, save money (if disposal of chemicals is needed), free up storage space and create less hazards in the event of a spill.

Process Modification

Use of micro-scale techniques or a decrease in the use of hazardous materials in research will reduce the amount of waste generated.

Product Substitution

Use of non-hazardous and less toxic chemicals in your research is a safe and environmentally friendly way to reduce chemical hazardous waste.

Recycling

Currently, Boston College recycles photofixing chemicals to reclaim silver.

Segregation and Characterization

Hazardous and non-hazardous waste should not be mixed. Follow guidelines in Appendix H on the proper segregation of hazardous waste to minimize costs and ensure best disposal practices.

Training

Laboratory workers will be made aware of the above concepts to reduce waste generated during annual trainings.

Pollution prevention will be an environmental goal as described in section 1.5. The targeted decrease of waste generated is 10% over the life of the XL pilot study.

The American Chemical Society’s Task Force on Laboratory Waste Management publishes a booklet entitled "Less is Better". To receive your free copy either contact the Office of EH&S at BC or contact: ACS, Dept. of Government Relations & Science Policy, 1155 16^th St NW, Washington, DC 20036.

Two other excellent references include:

1. Laboratory Waste Management, A Guidebook written by the American Chemical Society’s Task Force of Laboratory Waste Management.

2. Pollution Prevention and Waste Minimization in Laboratories by Peter A. Reinhardt, K.L. Leonard and P.C. Ashbrook, CRC Press.

Both of these books are available in the Office of EH&S in St. Clements Hall.

5.0 Surveys of Hazardous Chemicals of Concern (HCOC)

Proper management of chemical inventories can also help minimize laboratory waste streams. Each laboratory will be responsible to conduct an annual inventory of chemicals and ensure that all chemical containers are properly labeled and stored correctly.

For the first year of the pilot project a full inventory of all hazardous chemicals in each laboratory will be conducted. The Office of EH&S will assist in coordinating the inventory for the first year. In subsequent years, an assessment, by an ad-hoc laboratory committee, will be completed to determine if a full inventory is required annually thereafter. The assessment will be based upon a true risk of the chemical if not stored in accordance with defined practices and procedures.

Some items to take into consideration in conducting the survey will be:

• professional judgement of trained personnel to determine inclusion or exclusion of chemicals in the annual survey
• container integrity
• chemicals with expiration dates as specified by Boston Fire Department regulations
• expiration dates as specified by the chemical manufacturer which will pose a safety hazard

If an issue is found with a chemical, or it’s container, during a survey, the laboratory will contact EH&S as soon as possible to determine what, if any, further action is warranted. EH&S will base their determination on best practices, professional expertise, the assistance of the hazardous waste contractor and local officials.

6.0 Information and Training

6.1 Laboratory Workers

Boston College will provide laboratory workers with information and training so that they understand and can implement the elements of the Environmental Management Plan relevant to their responsibilities.

6.2 Frequency

Trainings will be conducted in accordance with the same frequency as training for the Chemical Hygiene Plan. Currently this training is provided by the Office of EH&S in September and October, and again in January and February. Other information will be provided on an on going basis through informal discussions, newsletters, memorandums and publication of material on the EH&S web page.

6.3 Visitors

Laboratory visitors, such as on-site contractors, visiting scientists, or environmental vendors, that require information and training under this EMP will be informed of the availability of this standard and be provided with the outline of the training program. Individuals responsible for a lab will provide this information to visitors. EH&S is available to conduct more intensive training for these groups.

Visitors will require information if they generate or handle waste chemical in a Boston College laboratory.

Chemical Waste Segregation

Acids - Inorganic & Pesticides

Acids - Organic & Photo Fixer

Bases - Alkaline & Photo Developer

Bases - Flammable & Photo - Other

Flammable Liquids & Reactives

High Hazard Peroxide Formers & Silica Gel

Mercury or any solutions containing Oil

Metals or Solutions Containing Oxidizers

Solvents-Non-halogenated organic Solvents-Halogenated

Water Reactive Compounds