TO: All Chemistry Department Faculty and Laboratory Directors
FROM: Paul M. Lahti, Chemistry Safety Coordinator
DATE: 16 April 1997
SUBJECT: Safety standards update

At a meeting of departmental safety coordinators on 14 April 1997, a variety of topics were discussed that affect proper safety protocol. Most of these are not new measure for the EPA or for a number of universities that have recently suffered megabuck level fines, but they may require clarification for us. All personnel receiving this memo should institute whatever actions they deem appropriate within their groups to adhere insofar as possible to the following guidelines.

(1) All metallic sharps are officially classified biological waste, and must be disposed of specially. These include syringes, syringe needles, cannulas, razors, X-Acto blades, and similar blades. They are NOT to be combined with glass waste or other waste streams. They ARE to be placed in a plastic container with an appropriate label. These containers are available for free from the UMass Environmental Health and Safety personnel, specifically Dr. Valerie Steinberg. Please contact her for these boxes. Noncompliance can have severe consequences, as well as placing unfair and unnecessary burdens on custodial personnel. If custodians get cut, they must go through many weeks of testing for pathogens, which is a very trying experience. Be professional, and follow this rigidly.

(2) All laboratories using serological materials (tissues, fluids, bloods, etc.) are responsible for having an appropriate, certified biohazards cabinet. Dr. Valerie Steinberg at EHS can provide information and guidance for the procedure in obtaining and certifying such cabinets. It is the responsibility of the laboratory principal investigator to know if such a cabinet is required. If you are not sure, call Dr. Steinberg. In addition, laboratory workers using such materials are required to undergo special training through EHS. Again, contact Dr. Steinberg for such information if you are not sure.

(3) All hazardous chemical disposal remains subject to the tenets of the EHS guide "Waste Management at UMASS", a red flip-folder available from EHS upon request. It is particularly helpful to sequester chemicals strictly by FLAMMABLE NONHALOGENATED vs. HALOGENATED solvents, since the former can be used as fuel! In particular, avoid mixing into the FLAMMABLE waste stream any acids, aqueous wastes, or halogens that can result in extra charges for waste disposal (and which render the waste useless as fuel). In addition, note the following very important points:

(a) All waste, all containers, all bottles must have a written label (not a symbol or chemical structure or laboratory notebook index number). This includes every single container in the lab: squirt bottles with water, sample vials, capped jugs with solvent saved for recycling, and (of course) all waste containers., among others. Any container without a label is considered hazardous unknown waste. This is very onerous, I know, but it is the requirement of EPA guidelines .
(b) Any waste container, once full, must be labeled with the date at which it was capped off, following which it must be sent to EHS within three days . This is virtually impossible with our present pickup schedule, but I very strongly urge all laboratories to dispose of hazardous waste containers as soon as possible after they are filled (i.e., during the next week's EHS waste pickup). In my laboratory, I have made up a rota of people responsible on a month-by-month basis for checking all lab workers' waste containers, for nagging them about proper recording of the waste stream, and for send waste pickup requests to EHS on a weekly basis.
(c) A reminder that all waste containers should have labels that have the generator name, phone number, location, and date when full. Contents must be entered as they are added to the container (no symbols or structures, but names!).
(d) Disposal of chemicals that "might be needed by someone, someday" is a long term money saver for you and the university. EPA has fined some universities for having chemical containers with dust on them, on the basis that they are clearly waste that has not been disposed of within the proper time period, if they are not being used! This is a particularly distasteful notion, given the growing, ongoing financial pressures on all of us from the outside world and from the university administration. However, this is NOT a case of a penny saved, a penny earned. Please try to get rid of chemicals that you are not using. Feel free to offer them to others or to the EHS chemical recycling program, but try to get rid of them.

(4) The university now has a new waste stream for several toxic items in typical use. These items should not be placed into the standard waste containers or glass containers.
(a) fluorescent light bulbs or batteries of any sort; call 5-0618 for pickup
(b) mercury bearing items (separate containers, properly labeled, and call EHS)
(c) banned pesticides (separate containers, properly labeled, and call EHS)

PML