Introduction

Learning Goals:
Review some of the details of RCRA
Understand that there are exceptions to RCRA
Some administrative requirement will depend on the total amount of waste generated

Here is a slide show that covers all the highpoints of this submodule. Please go through it carefully, then use your BACK button to return here. Slideshow. You were already familiar with the lists and characteristics. We will discuss the "Landban" in a later module.

Storage
Note that there are definite limits on how long a hazardous waste can be stored by the generator. Remember Junior Soprano's yard. Companies in financial trouble would just store waste on site to put off spending money. Then, if they went bankrupt, the waste would still be there. There are no exceptions, as a practical matter, for the difficulty of transportation. For example, in Alaska, if you miss the barge season, you may be fined or have to ship the waste some other way. $$$.

Training
Your book discusses two types of training, Hazwoper and HazComm. They are different, but overlap. Hazwoper (HAZardous Waste Operations and Emergency Response, 29 CFR 1910.120) deals with workers that clean up hazardous waste sites. HazComm (Hazardous communication standard. 29 CFR 1910.1200) applies to any hazardous chemicals in the workplace, which include hazardous waste generated in the course of manufacturing operations. Both are discussed in your book, you should look at Table 9.2 that has a typical syllabus to an OSHA 40-hour Hazwoper course. The regulatory requirements for Hazwoper training are much more detailed than HazComm, which has only very general requirements. There is a common problem with both kinds of training.

• Hazwoper: A worker takes the 40-hour training once, then takes an 8-hour refresher course once a year and gets a certificate and usually a wallet card. Elsewhere in the regulation, each employer is required to make up specific plans and train all the employees to their plan. But this training is typically given by providers to employees of several employers and is generic training, not specific to any particular operation. The employer often photocopies a generic plan or someone else's plan. The result is that the employee never receives any specific training to the particular hazardous waste site they are trying to clean up. This is an OSHA violation, all right, but not commonly caught, unless a worker gets hurt.
• HazComm. The employer is required to have an MSDS available for all the hazardous chemicals the workers use. What some employers will do is purchase large volumes of MSDS sheets for hundreds of chemicals, then put these out, and never give any thought to the particular chemical that are actually in the workplace. Again this is OSHA violation, again, it is still common..

Labeling
Two stories:

1. In Chicago a few years ago, an employer was using illegal immigrants to clean vats. (It is common for sleazy employers to use illegals for dangerous work, because the workers are reluctant to report violations or unsafe working conditions. It is also common for well-off unionized industrial workers to "look the other way" when their employer hires a contractor to do particularly dangerous or dirty jobs. ) The chemicals were quite dangerous and the barrels they came in were clearly labeled, both with chemicals data and universal warning signs. So, the employer scraped the labels off, so the workers would not be troubled to the chemicals in the closed spaces of the vat. One day several workers were killed by the chemicals. The employer was cited by OSHA and, it is quite rare, the employer was charged with criminal offenses. The OSHA regulations relating to labeling are quite detailed. For example, there are detailed specifications for how much chemical can be put in the bucket before the bucket must be labeled.

2. About six years ago I was sitting in my office when the front desk asked me to take a call from the Federal Railway Inspector. I thought it was a joke; I did not know there was such a person. Well there is, and he was in Seattle, Washington. My employer, the Corps of Engineers, had shipped boxes of hazardous material from some small radar stations on the arctic coast. The boxes we used had been used for other materials and were being recycled. The original labels were high quality plastic labels. Our contractor's workers marked out the old labels with felt-tipped pens, then put new labels on the boxes. By the time the boxes got to Seattle by barge, the felt-tipped marks had evaporated from the plastic labels, and the boxes arrived with two sets of labels, one indicating a hazardous contents and one a non-hazardous contents. Now it was obvious from the manifest what they were, but apparently this railroad inspector controlled the yard where the barged materials were transferred. His point of view was that the boxes were improperly labeled and would not go through his yard (kingdom) until they were properly labeled. We had to have someone from the Seattle office of the contractor to go to the rail yard and remove the old, incorrect labels, before the hazardous waste could continue on its way.

So labels are important, both practically and administratively. Here is a site with some chemical labels
and another style.,

GHS, Globally Harmonized System, is the new standard for labeling and SDS (old MSDS). We did not emphasize that in Module 2, since there is little practical differene between the GHS/SDS and the ANSI standard MSDS. However there are many detials that do differ. The labels required are much more detailed than the former HazComm labels. Here is an excellent YouTube video that you should watch: https://www.youtube.com/watch?v=DaZw5B1A9F4

The HazComm labels, whatever format, are not necessarily hazardous waste labels. You might perceive another problem. Some hazardous waste is not a "chemical" but a mixture of chemicals, sometimes unknown, at the time you are handling them. The proper way to handle this is to label the material with labels that indicate it is unknown waste, then hold it until the laboratory tests are back. Again you might perceive that waste site might have hundreds of barrels that need to be tested. So clear marking and inventory of the barrels is required, in order to match up the lab results with the barrels. Once the contents are known, the barrels can be properly labeled. There are also on-site tests that are pretty good. We'll talk about them later.

Module 07 Index

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