Campus Consortium for Environmental Excellence


University of Vermont

The University of Vermont Laboratory Environmental Management Plan

Table of Contents:
I. Purpose II. Environmental Policy
for Laboratory Operations
III. Laboratory Waste Container Management
IV. Avoiding Releases to the Environment V. Emergency Response in Laboratories VI. Training for Laboratory Workers
VII. Roles and Responsibilities VIII. Identifying and Tracking Legal Requirements IX. Identifying Physical and Chemical Hazards
X. Pollution Prevention XI. Annual Surveys of Hazardous Chemicals of Concern (HCOC) XII. Laboratory Inspections
XIII. List of Laboratories Covered by EMP XIV. Hazardous Waste Determination XV. Document Control


I. Purpose:

The purpose of this plan is to outline the specific measures the University of Vermont will take to protect human health and the environment from hazards associated with the management of laboratory wastes and from the reuse, recycling or disposal or such materials outside the laboratory. 40 CFR 262.105(a) The University of Vermont will develop and oversee the implantation of the plan 40 CFR 262.105(c)(1), and maintain records to document its conformance with the plan 40 CFR 262.105(b)(17) and the Minimum Performance Criteria set forth in 40 CFR 262.104, and 40 CFR 262 105(b)(1) of the Laboratory Environmental Management Standard.

EMP Guidance Documents:
Project XL Final Project Agreement
The Laboratory Environmental Management Standard


II. Environmental Policy for Laboratory Operations - Introduction

The University of Vermonts Environmental Policy for Laboratory Operations has been signed by the Universitys senior management and includes commitments to regulatory compliance, waste minimization, risk reduction and continual improvement of the environmental management system. 40 CFR 262.105(b)(2)

The University of Vermont will continue to comply with all Federal, State and local environmental laws and regulations not specifically deferred by the Laboratory XL project. 40 CFR 262.103. This project will not result in media transfer of chemicals (e.g., will not result in former RCRA wastes being inappropriately disposed to the air or water.)

Final Project Agreement Project XL Acceptance Criteria A. 1. (e) pg 20

University of Vermont Environmental Policy for Laboratory Operations:
http://esf.uvm.edu/labxl/UVM%20XL%20information/envpolicy.html


III. LABORATORY WASTE CONTAINER MANAGEMENT

40 CFR 262.105(b)(9)

(1) Laboratory Waste Container Management Policy

The University is committed to promoting good laboratory practices including proper management of laboratory wastes. All laboratory wastes must be properly labeled, stored in appropriate containers and removed from the laboratory in a timely fashion as outlined in the EPAs Minimum Performance Criteria (link) and Prudent Practices in the Laboratory. (link)


(2) Laboratory Waste Container Labelling and Timely Removal - 40 CFR 262.104(a)

Labelling Laboratory Waste Containers

Laboratory personnel must assure that all containers of laboratory waste are labelled with the general hazard class and the words laboratory waste or with the chemical name of the contents. Laboratory personnel must complete and attach either the Laboratory Waste Label (link to Laboratory Waste Label) or the Laboratory Waste Tag (link to Laboratory Waste Tag) to all containers used to store laboratory wastes.

Laboratory personnel use the Laboratory Waste Label on containers which are in the process of being filled with laboratory wastes, Once a container of laboratory waste is ready for removal from the laboratory, or once a storage threshold has been met (see Laboratory Waste Storage Limits below) laboratory personnel are responsible for filling out the Laboratory Waste Tag.

Laboratory Waste Tag

The Laboratory Waste Tag is used as the means to have laboratory wastes removed from the laboratory. Laboratory personnel are responsible for filling out the Laboratory Waste Tag which includes the chemical name and general hazard classification of the waste, the date the container was filled, and the department, building and room number where the waste container is located. Laboratory personnel are responsible for submitting a copy of the Laboratory Waste Tag to the ESF and attaching the remaining copies of the Laboratory Waste Tag to the waste container.

Laboratory Waste Storage Limits

Each laboratory may temporarily store up to 55 gallons of laboratory waste or one quart of acutely hazardous laboratory waste, or weight equivalent, but upon reaching these thresholds, the University must mark the laboratory waste container (or secondary container) with the date when this threshold was met. link 40 CFR 262.104(b) Laboratory waste which exceeds this threshold must be removed from the laboratory within 30 days. link 40 CFR 262.104(c)

It is the Universitys responsibility to assure that no more than 110 gallons of laboratory waste total, or no more than two quarts of acutely hazardous waste total, stored in a laboratory at any one time. 40 CFR 262.104(d) It is the laboratorys responsibility to inform the University of the presence of laboratory waste by using the Laboratory Waste Tag as discussed above.

Compliance with laboratory waste storage limits is established by the dates marked on the Laboratory Waste Tags by laboratory personnel and recorded by the University in the Tags Database. It is the Universitys responsibility to maintain the Tags Database and to mark laboratory waste containers when the thresholds discussed above are met.

Removal of Laboratory Wastes

Within five working days after the Laboratory Waste Tag is received at the ESF, University personnel will remove the waste. 40 CFR 262.105(b)(10) Laboratory personnel are responsible for assuring that all waste containers are stored in appropriate areas designated by the laboratory within the room noted on the Laboratory Waste Tag.

The University is responsible for removing containers of laboratory waste from laboratories and transferring them either to the designated waste accumulation area (Bunker), or to a permitted hazardous waste vehicle for transport to a TSDF following applicable regulatory requirements for transporters. 40 CFR 262.104(i)(1) and (2) The University is also responsible for assuring that the accumulation area (Bunker) is managed in accordance with Federal and State RCRA regulations.

University personnel designated to remove laboratory wastes and transfer them to either the Bunker or to a TSDF are familiar with emergency procedures and are equipped with appropriate personal protection and spill control equipment. These University personnel are also trained, at a minimum, in OSHA 24 hour HAZWOPER. 40 CFR 262.105(b)(14)

Labelling Secondary Storage Containers

If a laboratory chemical or waste container is too small to hold a Laboratory Waste Label or a Laboratory Waste Tag, or if groups of compatible chemicals are stored together in a secondary container, the Laboratory Waste Label or the Laboratory Waste Tag must be placed on a secondary container.

Laboratory Waste Storage Limits

Each laboratory may temporarily store up to 55 gallons of laboratory waste or one quart of acutely hazardous laboratory waste, or weight equivalent, but upon reaching these thresholds, Laboratory personnel must mark the laboratory waste container (or secondary container) with the date when this threshold was met. link 40 CFR 262.104(b) Laboratory waste which exceeds this threshold must be removed from the laboratory within 30 days. link 40 CFR 262.104(c)

It is the laboratorys responsibility to assure that no more than 110 gallons of laboratory waste total, or no more than two quarts of acutely hazardous waste total, stored in a laboratory at any one time. 40 CFR 262.104(d) It is the laboratorys responsibility to inform the University of the presence of laboratory waste ready for removal by using the Laboratory Waste Tag as discussed above.


(3) Procedures pertaining to laboratory waste container labelling and timely removal

The University is responsible for supplying Laboratory Waste Labels and Laboratory Waste Tags. Call the ESF at 65400 to acquire Laboratory Waste Labels and Laboratory Waste Tags.

Examples of properly filled out waste University Chemical Labels

University Chemical Labels are to be used on laboratory chemical containers accumulating laboratory waste.

Examples of properly filled out Laboratory Waste Tags

Laboratory Waste Tags are to be used when laboratory waste containers are ready to be removed from the laboratory (link to plan)

Laboratory waste classification system

All laboratory waste containers should be labelled with the chemical name of the contents. If the chemical name is not known, the container must be labelled with general hazard class of the contents. The following laboratory waste classification system is used when the chemical name of a waste is not known, or when the general hazard class is more descriptive than the chemical name:


(4) Records pertaining to laboratory waste container labelling and timely removal

Laboratory Waste Database


(2) Laboratory Waste - Condition of Containers 40 CFR262.105(b)(9)

Closed containers

Laboratory personnel must assure that containers of laboratory wastes are securely closed with a cap, lid, or other appropriate device except when wastes are being added to or removed from the container either manually, or automatically by means of an in-line waste collection system. 40 CFR 262.104(e)(1)

(See in-line waste collection discussion below.) Snap caps, such as those found on milk bottles, miss-sized caps, parafilm, or other loose fitting lids are not acceptable. Laboratory waste containers can be closed with a funnel only if the funnel has a tight-fitting lid and secondary containment, or if the lidded funnel fits securely into the container so that if it turned over, the contents would not spill out. Solid debris can be packaged into sealed plastic bags.

Open containers connected to in-line waste collection systems

In-line waste collection refers to any system that automatically collects laboratory wastes and is directly connected to a laboratory activity. If a container of laboratory waste is connected to an appropriate in-line waste collection system it does not have to be closed with a cap or lid. An acceptable in-line waste collection system must be constructed and operated in a manner which prevents the release of any laboratory waste into the environment.

The following standards apply to in-line waste collection systems:

    In-line waste collection systems must have secondary containment in case of an accidental overflow.

    In-line waste collection systems must be attended or periodically inspected by trained laboratory personnel frequently enough so that if there was an accidental overflow, the contents would not overflow the secondary container before the system was shut off.

    There must be specific emergency response instructions posted near the in-line collection system.

Examples of appropriate in-line waste collection systems:

(Need examples here - e.g. HPLC with diagram)

Avoiding leaks

Laboratory personnel must assure that containers of laboratory wastes are maintained in good condition and stored in the laboratory in a manner to avoid leaks. Leaks can be prevented by leaving empty space at the top of the containers. Dirty containers must be wiped off before affixing labels and waste tags. If a container leaks, the leaking container must be either packed in a secondary container, or transferred to an intact container. 40 CFR 262.104(e)(2)

Containers of laboratory wastes must be made of or lined with materials which are compatible with the laboratory waste so that the container is not impaired by the contents. Laboratory personnel must not commingle incompatible wastes. 40 CFR 262.104(e)(3)

The University is responsible for supplying containers suitable for waste storage and transport.

Appropriate storage locations

Laboratory personnel are responsible for assuring that laboratory wastes are stored only in active laboratories or supervised and secured storage rooms with ventilation and fire suppression systems. Containers of laboratory wastes must not block emergency egress or safety showers. Teaching labs, closets or unused rooms are not appropriate for chemical storage. Laboratory wastes stored on the floor must have secondary containment. The University is responsible for supplying secondary containment bins.

Laboratory inspections and storage surveys

Containers of laboratory wastes must be inspected regularly by laboratory personnel to ensure that they meet the requirements of this section. The University will also conduct routine laboratory inspections. Laboratory personnel are responsible for correcting any non-compliances by the determined deadline. (link to Inspections)

On an annual basis, the University will oversee a storage survey of hazardous chemicals of concern, (HCOC). At that time laboratory personnel are responsible for conducting an inspection of laboratory waste containers to ensure that they meet the requirements for container managment discussed in this section. Laboratory personnel are also responsible for completing and returning the chemical inventory form supplied by the Risk Management Department on an annual basis. (link to HCOC) 40 CFR 262.104(e)(4)


(3) Procedures Pertaining to Condition of Containers

Link to Laboratory Inspection check list

Link to HCOC survey


(4) Records Pertaining to Condition of Containers

Link to Annual HCOC Survey Report

Link to Inspection Database


(5) External Documents Pertaining to Condition of Containers

Prudent Practices and Safety in Academic Chemistry Laboratories Chapter 4.E Storage of Chemicals in Stockrooms and Laboratories

Safety in Academic Chemistry Labs compatibility chart


(2.) Laboratory Decommissioning

A laboratory will be decommissioned as a result of laboratory renovation, relocation or a change in laboratory supervision which results in the need to transfer containers laboratory wastes to either the hazardous waste accumulation area or a TSDF. The University is responsible for assisting laboratory personnel with laboratory decommissioning and unknown chemical identification.

Laboratory personnel are responsible for notifying the University at least two weeks prior to the proposed laboratory moving date. This can be done by filling out the Laboratory Moving Form described below. Also prior to moving, laboratory personnel must segregate all chemicals that will not be used in new laboratory locations and tag each container with the UVM Laboratory Waste Tag. Unknown chemicals must be identified prior to moving. It is the responsibility of laboratory staff to maintain the integrity and accuracy of chemical labels to avoid the occurance of unknown chemicals.

40 CFR 262.105(b)(8)


(3.) Procedures Pertaining to Laboratory Decommissioning

Risk Management Department Laboratory Moving and Closing Policy and laboratory moving form (link)

The Laboratory Moving Form must be filled out by laboratory personnel at least two weeks prior to the laboratory renovation, relocation or change which will result in any laboratory chemicals or wastes being transferred from that location.


(4.) Record Pertaining to Laboratory Decommissioning

Laboratory decommissioning report


IV. AVOIDING RELEASES TO THE ENVIRONMENT

40 CFR 262.104(f)

* Sink Disposal

(1.) Policy - avoiding releases to the environment

sink disposal policy

Sink disposal of hazardous laboratory chemicals is forbidden. According to the Burlington sewer use ordinance, solutions with a pH equal to or less than 5.0 and greater than or equal to 10.5 should not be discharged into the sewer system. Likewise any laboratory chemical which exhibits a flammable, toxic or reactive characteristic or is a dye, has a strong odor, high viscosity or is oily is prohibited from sink disposal. It is acceptable to discharge simple aqueous salt and sugar solutions down the drain, but always err on the side of caution. If you have specific questions about whether a chemical is suitable for sink disposal, call the ESF at 65400 before you pour it down the drain.


(2.) Plan - pertaining to sink disposal, continual improvement

Once ESF staff have evaluated a specific chemical to determine whether it is suitable for sink disposal, the outcome of the evaluation will be documented by adding the chemical to a list declaring it suitable for sink disposal. This list will provide an on-going protocol for proper sink disposal of laboratory waste.


(3.) Procedure - pertaining to sink disposal

Request for sink disposal evaluation documentation


(4.) Records - pertaining to sink disposal

On-going list of laboratory wastes suitable for sink disposal


(5.) External Documents - pertaining to sink disposal

Burlington sewer use ordinance

sink disposal guidelines from Prudent Practices


* Prohibition of evaporation in fume hood

(1.) Policy - avoiding releases to the environment

Fume hoods are used to control exposure to vapor emissions during experimental processes, and by design may increase the evaporation rate of the chemicals being used. However, it is forbidden to use fume hoods as a means to evaporate laboratory chemicals for the purpose of disposal. Close caps tightly and seal containers to minimize escape of vapors. Avoid storing chemicals, including wastes, in the fume hood. Excess storage clutters the hood work space and inhibits the air flow needed for proper fume hood operation.


(2.) Plan - fume hood inspection plan


(3.) Procedures - laboratory inspection section pertaining to fume hoods (link)


(4.) Records - pertaining to fume hoods

on-going list of fume hood locations

inspection nonconformance pertaining to fume hoods (link)


(5.) External Documents - pertaining to proper use of fumehoods

Fume hood book

proper fumehood use guidelines from Prudent Practices

something from the air pollution regs or our operating permit about fume hood emissions


* Prohibition of mixing lab waste with nonhazardous waste streams

(1.) Policy - avoiding releases to the environment

Intentionally mixing hazardous laboratory wastes with ordinary trash is forbidden. Keeping hazardous laboratory wastes and ordinary trash separated is important in order to help minimize the amount of hazardous waste generated in the lab, and to assure the proper disposal of all waste streams generated in the laboratory.


(2.) Plan - Prohibition of mixing hazardous lab waste with nonhazardous waste streams

The University is responsible for determining the correct disposal method for all wastes generated in the laboratory. Laboratory personnel are responsible for understanding the difference between ordinary laboratory trash and hazardous laboratory wastes and the procedures for keeping these waste streams separated.

Laboratory personnel are responsible for following the procedures described in the Laboratory Waste Container Management (link) section of the EMP, thereby assuring that laboratory chemical waste is correctly labelled and removed in a timely fashion.

In the event that a University custodian suspects that laboratory chemical waste is being mishandled in a laboratory, the custodian will report the situation to the University by using the Custodial Waste Review Form shown below. The University is responsible for promptly investigating all Custodial Waste Review Forms and rectifying any situation where laboratory chemical waste has been mis-handled.


(3.) Procedure

Prohibition of mixing hazardous lab waste with nonhazardous waste streams

Example of Custodial Review Form


(4.) Record

Prohibition of mixing hazardous lab waste with nonhazardous waste streams

Completed Custodial Review Forms


(5.) External Document

prohibition of mixing hazardous lab waste with nonhazardous waste streams

Link to relevant statement in Pollution Prevention Plan


V. EMERGENCY RESPONSE IN LABORATORIES

40 CFR 262.105(b)(11)

1.) Policy - Emergency Response in Laboratories

In the event of a chemical spill or release, laboratory personnel will respond as outlined in the Universitys Hazardous Waste Contingency Plan. The size and contents of the spill will determine the appropriate response. The University will take responsibility for cleaning up chemical spills when there is any doubt about a laboratory personnels ability to clean up the spill safely

(2.) Plan - Emergency Response in Laboratories

Emergency notification

It is the laboratory personnels responsibility to post telephone numbers of emergency personnel, supervisors and other personnel deemed appropriate to contact in case of an emergency on each laboratory entrance. Laboratory personnel are responsible for keeping the notification procedures up-to-date and following them in the event of an emergency.

40 CFR 262.104(g)(1), 40 CFR 262.104(g)(3)

University Emergency Phone Numbers:

UVM Police (24 hours) 911

Environmental Safety Facility 65400, or 911 after hours

Poison Control Center 658-3456

Emergency response equipment

Laboratory personnel are responsible for posting the locations of emergency response equipment that would be used in the event of an emergency.

40 CFR 262.104(g)(1) The University is responsible for documenting that emergency response equipment is appropriate to the hazards in the laboratory. This will be done as part of the routine inspection process. 40 CFR 262.104(g)(2)

Evacuation procedures

The University is responsible for posting evacuation procedures 40 CFR 262.104(g)(1)

Contingency Plan implementation

In the event of an emergency, the University is responsible for investigating, documenting and taking actions to prevent future incidents.

40 CFR 262.104(h)


(3.) Procedures - pertaining to emergency response in laboratories

example of properly filled out notification sticker

example of posted emergency response equipment

example of evacuation procedures

example of a contingency plan implementation report form


(4.) Records

contingency plan implementation report


(5.) External Documents - pertaining to emergency response in labs

Campus Contingency Plan


VI. TRAINING FOR LABORATORY WORKERS

40 CFR 262.104(j), 40 CFR 262.105(b)(12), 40 CFR 262.105(c)(6)(ii)

(1.) Policy - Training for lab workers

The University will provide training for laboratory workers that includes the information necessary to understand and implement the elements of UVMs EMP that are relevant to their responsibilities. It is the responsibility of all laboratory personnel to attend training provided by the University about the aspects of UVMs EMP that are relevant to their jobs and to stay up-to-date with the contents and goals of UVMs EMP. The University will make available its EMP to laboratory workers, vendors, on-site contractors, and upon request, to governmental representatives.

40 CFR 262.105(d)(1), 40 CFR 262.105.(d)(4)(vi), 40 CFR 262.105(6)(i)


(2.)Training Plan

Laboratory personnel training programs will include, at a minimum, the following topics:

    * information about the Laboratory Environmental Management Standard and implementing and complying with the Environmental Management Plan 40 CFR 262.105(d)(4)(i)

    * location and availability of the Environmental Management Plan 40 CFR 262.105(d)(4)(ii),

    * pollution prevention practices at the university, including employee involvement in identifying and implementing pollution prevention opportunities 40 CFR 262.105(b)(6)

    * emergency response measures 40 CFR 262.105(d)(4)(iii)

    * signs and indicators used to detect the presence of a hazardous substance or release 40 CFR 262.105(d)(4)(iv), 40 CFR 262.105(d)(5)(i)

    * chemical and physical hazards associated with the lab wastes in their work area 40 CFR 262.105(d)(5)(ii)

    * personal protective equipment and relevant measures can take to protect human health and the environment 40 CFR 262.105(d)(5)(iii)

    * location and availability of reference materials 40 CFR 262.105(d)(4)(v)

The University will establish training outlines based on the topics listed above which specify who is to receive training. 40 CFR 262.105(d)(3)

Laboratory personnel will receive initial information on implementing the EMP - when first assigned to a work area where laboratory wastes may be generated

40 CFR 262.105(d)(2)(i) Laboratory personnel training will occur within six months of assignment to work area. Re-training will occur at a regular frequency and when ever a new or unique hazard exists in the laboratory. 40 CFR 262.105(d)(2)(ii)

The University will identify visitors that require information and training and inform them of the existence and relevant sections of the EMP.

40 CFR 262.105(d)(6)(i),(ii) and (iii)


(3.) Training Procedures

Training is available in the form of:

    * EMP website

    * Literature, videos

    * Group and individual training.

To schedule a training session, call the ESF at 656-5400.


(4.) Training Record

The University will provide records of training by maintaining the following: 40 CFR 262.105(d)(7)

    training record documenting laboratory personnel who have attended

    training outline

    Environmental Awareness Survey results (link to pollution prevention)


VII. ROLES AND RESPONSIBILITIES

40 CFR 262.105(b)(3)

(1.) Policy - Roles and Responsibilities

The University will assign roles and responsibilities for the effective implementation and maintenance of the Laboratory EMP

40 CFR 262.105(c)(3)


(2.) Plan - Roles and Responsibilities

The following descriptions outline key roles and responsibilities with regard to the implementation and maintenance of this plan.

(5.) External Document - roles and responsibilities

University of Vermont Responsibility Document (link)


VIII. IDENTIFYING AND TRACKING LEGAL REQUIREMENTS

40 CFR 262.105(b)(4), 40 CFR 262.105(c)(5)(i)

(1.) Policy

The University will identify and track legal requirements applicable to laboratory wastes and their management.


(2.) Plan - Identifying and tracking legal requirements

The Risk Management Department Environmental Safety Facility Staff will identify and track legal requirements applicable to laboratory wastes and their management through journals, such as Chemical Health and Safety, newsletters, such LS&EM, applicable web sites, and by participating in associations such as CSHEMA and the LCEE.

Laboratory personnel will stay up-to-date with the contents and goals of the Environmental Management Plan and any new, pertinent information by means of the Environmental Safety Facility web site, memorandums to faculty and staff, Environmental Council meetings, and scheduled training sessions


(5.) External Documents and associations - identifying and tracking legal requirements

Journals - eg. Chemical Health and Safety

Newsletters - eg. LS&EM

Websites - eg.

Associations - eg. CSHEMA, LCEE


IX. IDENTIFYING PHYSICAL AND CHEMICAL HAZARDS

40 CFR 262.105(b)(5)

(1.) Policy

The University is responsible for developing, implementing and maintaining a Chemical Hygiene Plan which sets forth criteria for the identification of physical and chemical hazards and the control measures to reduce the potential for releases of laboratory wastes to the environment. Laboratory personnel are responsible for developing and implementing appropriate chemical hygiene policies and practices specific to the operations in their labs.


(2.) Plan - Identifying physical and chemical hazards and control measures to reduce the potential for releases

1.) engineering controls, fume hood,(link) ventilation, chemical storage (link)

2.) personal protective equipment - glove selection, safety glasses (link)

3.) containment strategies (link)

4.) Administrative Controls - reducing toxicity, or reducing exposure (link to ChemSource)

5.) Work practices - capping containers, (link) housekeeping (link to avoiding releases), hand washing


(5.) External Documents - identifying physical and chemical hazards

University of Vermont Chemical Hygiene Plan


X. POLLUTION PREVENTION

40 CFR 262.105(b)(6),

(1.) Policy - Pollution Prevention

UVM is committed to the use of processes and practices that reduce or eliminate the use of hazardous materials and the generation of pollutants and wastes at the source. In instances where hazardous materials cannot be eliminated or reduced at the source, UVM will investigate methods for reuse and recycling. UVM will identify environmental objectives and targets on an annual basis. By adopting the policies, plans and procedures outlined in this EMP, the University of Vermont will continually improve its environmental performance. The University is responsible for making available the resources necessary to implement the pollution prevention measures described in the EMP.

The University is responsible for providing training for laboratory workers which includes the elements of UVMs EMP that are relevant to their responsibilities. This training covers pollution prevention practices at the university, and promotes employee involvement in identifying and implementing pollution prevention opportunities. 40 CFR 262.105(d)(1)

The EMP is reviewed at least annually by senior management to ensure its continuing suitability, adequacy and effectiveness. 40 CFR 262.105(c)(6)(iii). This review includes an evaluation of the policies and procedures which ensure ongoing identification, evaluation and implementation of pollution prevention opportunities. In addition, the University submits an Annual Pollution Prevention Performance Report describing progress in meeting current objectives and targets to the Vermont Agency of Natural Resources.

This plan is available to the public as part of the Universitys EMP, which is located on the web at _____. Copies of the EMP are also available by contacting the ESF.


(2.) Plan - Pollution Prevention

* baseline assessment

40 CFR 262.105(c)(5)(ii)

Final Project Agreement -IV. Performance Goals and Indicators pg. 30

    a.) Conduct a baseline survey of HCOC (link) and quantity stored on the shelf laboratories

    b.) measure laboratory wastes generated during a defined period of time

    c.) conduct an environmental awareness survey of laboratory workers

    d.) evaluate the amount of laboratory wastes reused or redistributed

    e.) measure costs of compliance including waste disposal costs

* Pollution prevention opportunity identification and evaluation

ChemSource -buying in smaller lots, opportunities for non-hazardous or less hazardous substitutions. (link to ChemSource)

Annual HCOC surveys - encourage laboratories to cull inventory of unused chemicals before shelf life of chemicals is exceeded (link to HCOC)

Environmental awareness training including employee involvement in identifying and implementing pollution prevention opportunities (link to training)

Housekeeping - prohibition of mixing lab waste with nonhazardous waste

Do not mix chemical laboratory wastes with ordinary trash. This is important in order to help minimize the amount of hazardous waste generated in the lab, and to assure the proper disposal of all waste streams generated in the laboratory.(link to avoiding releases)

* Objectives and Targets

40 CFR 262.105(c)(2)(i)

a.) Objective: Measure hazardous materials reuse and redistribution

Goal: 20% increase over life of XL Project

b.) Objective: Measure laboratory waste generation rates

Goal: 10% reduction of hazardous waste over life of XL Project

c.) Objective: Verify annual HCOC surveys for completeness

Goal: 100% completion of surveys each year

d.) Objective: Identify, evaluate and implement pollution prevention opportunities

Goal: Conduct at least one laboratory pollution prevention project each year

e.) Objective: environmental awareness

Goal: Increased environmental awareness, performance based on improved scores and increased number of students and lab workers receiving training over the life of the XL Project

f.) Objective: compliance with EMP

Goal: improved performance based on above objectives and goals, and inspection results over the life of the XL Project

g.) Objective: identification and adoption of improvements in the EMP

Goal: annual senior management review of the policies and procedures which ensure ongoing identification, evaluation and implementation of pollution prevention opportunities


(3.) Procedures - pertaining to objectives and targets

Describe how we measure re-use and redistribution - forms

Describe how we measure laboratory waste generation rates -annual report

Describe annual pollution prevention projects

Environmental awareness questionaires (link)


(4.) Records - pertaining to objectives and targets

Annual pollution prevention progress report including statistics on reduction of waste and increase in re-use/redistribution

Data from Hazardous Waste Annual Report

Training record (link)

Laboratory inspection database (link)

Annual Survey of HCOC report (link)

Senior management annual review report forms (?)


(5.) External Documents - Pollution prevention objectives and targets

Final Project Agreement - Table 4 Environmental Goals and Indicators, pg. 31


XI. ANNUAL SURVEYS OF HAZARDOUS CHEMICALS OF CONCERN (HCOC)

40 CFR 262.105(b)(7)

(1.) Policy- Annual Surveys of HCOC

Goal of HCOC surveys

100% completion of surveys

all HCOC on shelf are within their defined "shelf life"


(2.) Plan - Annual Surveys of HCOC

The University of Vermont has defined a list of hazardous chemicals of concern based on several years of surveying the types of hazardous chemicals stored in the various labs. A chemicals on the HCOC list meets one or more of the following criteria:

    it has an expiration date based on safety considerations

    it has the characteristics of a RCRA reactive or corrosive waste

    it is listed as a RCRA acutely hazardous waste in 40 CFR 261.33

    it has a Poison Inhalation Hazard (PIH) designation by DOT

    other chemicals as determined by professional judgement

This list is included as part of the annual HCOC survey form (link)

Conducting and updating annual HCOC surveys:

The University is responsible for suppling the HCOC survey form to the laboratories, maintaining the data and reporting the results.

Laboratory personnel responsible for completing the form

What is done with the information?


(3.) Procedure - Annual Surveys of HCOC

Example of an Annual Survey of HCOC form and instructions


(4.) Record - Annual Surveys of HCOC

Example of an Annual Survey of HCOC report


XII. LABORATORY INSPECTIONS

40 CFR 262.105(b)(15)

(2.) Plan - Laboratory Inspections

1.) Description of a routine laboratory inspection.

2.) Identifying EMP noncompliance and follow-up

The University is responsible for maintaining the Laboratory Inspection Database.

40 CFR 262.105(b)(16)

The University and the laboratory personnel are both responsible for performing routine laboratory inspections. The University will assist in correcting non-compliances found during inspections, but ultimately it is the responsibility of the laboratory personnel satisfactorily address any problems discovered during an inspection within a reasonable time frame.

During a routine inspection, ESF staff and laboratory personnel will address and correct any noncompliance with the EMP inspection protocol that can be corrected at that time. If the noncompliance can not be corrected immediately, a compliance deadline will be determined and documented on the inspection form, and designated laboratory personnel will report back to the ESF staff in writing once the noncompliance has been corrected. A follow-up inspection of the lab will occur if more than a written response is necessary to assure compliance.

ESF staff will notify the principal investigator of the lab in noncompliance after the first inspection. If the noncompliance has not been corrected by the determined deadline, the lab will be re-inspected and the Department Chair will be notified in writing. If after three inspections of a laboratory the same problem persists, the ESF staff will issue a report which will be sent to the Chemical and Biological Safety Committee for further action.

In the case of an imminent danger to life, health or the environment, the Chemical and Biological Safety Committee is authorized to immediately order the cessation of the hazardous activity and close down laboratory activities until such activity has ceased and and responsible individuals have taken adequate measures to correct the situation and prevent reoccurrence of the noncompliance.


(3.) Procedure - laboratory inspections

Example of Laboratory Chemical Storage Safety Survey

Example of a non-compliance notification memo

Example of a "back to compliance" form

Example of a non-compliance report to the CBS committee for further action


(4.) Record - laboratory inspections

Laboratory Inspection Database


XIII. LIST OF LABORATORIES COVERED BY EMP

40 CFR 262.105(c)(2)(ii)

(2.) Plan - list of laboratories covered by EMP

UVM laboratories are defined by their physical extent and may include more than a single room if in the same building and under the same supervision. All UVM laboratories are covered by the requirements of the Laboratory Environmental Management Plan


XIV. HAZARDOUS WASTE DETERMINATION

40 CFR 262.105(c)(4)

(2.) Plan - hazardous waste determination

A laboratory chemical is designated as a laboratory waste when:

    1.) it has gone through a research process and is no longer needed, or

    2.) it is a virgin chemical no longer needed, or

    3.) it is a clean up material from a chemical spill.

University personnel or appropriate designee will remove laboratory wastes and transfer them either to the designated waste accumulation area (Bunker), or directly to a TSDF.

For laboratory waste sent from a laboratory to the Given Bunker, the University of Vermont will evaluate the laboratory wastes to determine whether they are hazardous wastes. This evaluation will occur as soon as the laboratory wastes reach the Given Bunker. At this point, the University of Vermont will determine whether the laboratory waste will be reused or whether it must be managed as RCRA hazardous waste.

For laboratory waste sent from a laboratory directly to a TSD facility permitted to handle the waste, the University of Vermont will evaluate the laboratory wastes to determine whether they are hazardous wastes. This evaluation will occur prior to the 30-day deadline for removing dated laboratory wastes from the laboratory.

Once the University of Vermont determines that a laboratory waste is a hazardous waste, it will be managed in accordance with all applicable provisions of 40 CFR Parts 260 through 270.

Identifying acutely hazardous wastes

Acutely hazardous waste is defined by regulation. The list of generic names of acutely hazardous wastes can be found in the State and Federal Hazardous Waste Regulations. (link to 40 CFR 261.33)

Laboratory personnel are responsible for marking the date a threshold of one quart of acutely hazardous laboratory waste is accumulated, and assuring that no more than two quarts of acutely hazardous waste are stored in the laboratory at any one time. (link to container management - timely removal of wastes from labs)


(5.) External Documents - hazardous waste determination

40 CFR 261 (link)