BOS 3125 Columbia Southern University Hazardous Material management Questions Question 1 A research lab uses acetone (CAS registry # 67-64-1) as a solvent

BOS 3125 Columbia Southern University Hazardous Material management Questions Question 1 A research lab uses acetone (CAS registry # 67-64-1) as a solvent for cleaning glassware. The spent solvent is consolidated into containers for disposal. Use a decision chart to determine if this disposal is subject to Resource Conservation and Recovery Act (RCRA) Subtitle C regulations. Explain how you reached your decision. You may assume that acetone has not been delisted by the Environmental Protection Agency (EPA). Your response should be at least 75 words in length. Question 2 The Conditionally Exempt Small Quantity Generator (CESQG) category has been renamed to Very Small Quantity Generator, (VSQG). Explain the major differences between a VSQG and a Small Quantity Generator. What are some of the possible problems when classifying your organization as a VSQG? Your response should be at least 75 words in length. Question 3 Explain the relationships between the Resource Conservation and Recovery Act (RCRA), the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), the Superfund Amendments and Reauthorization Act (SARA), and the Emergency Planning and Community Right-to-Know Act (EPCRA). Why do you think there are so many different laws governing hazardous materials and hazardous waste? Your response should be at least 200 words in length. UNIT I STUDY GUIDE
Hazardous Waste
Course Learning Outcomes for Unit I
Upon completion of this unit, students should be able to:
1. Examine standards that govern the management of hazardous substances in the workplace.
1.1 Explain the relationship among federal laws that govern hazardous waste operations.
1.2 Characterize hazardous wastes using criteria defined by the U.S. Environmental Protection
Agency.
1.3 Explain the requirements for hazardous waste management under the Resource Conservation
and Recovery Act.
Course/Unit
Learning
Outcomes
1.1
1.2
1.3
Learning Activity
Unit Lesson
Chapter 1
RCRA Orientation Manual, Chapter I
Unit I Assessment
Unit Lesson
Chapter 1
RCRA Orientation Manual, Chapter III
40 C.F.R. §261.31
Unit I Assessment
Unit Lesson
Chapter 1
RCRA Orientation Manual, Chapter III
Unit I Assessment
Reading Assignment
Chapter 1: Hazardous Waste
In order to access the following resources, click the links below:
Read the following sections of the RCRA Orientation Manual 2014 (ROM), which can be accessed below.
Chapter I: Introduction to the Resource Conservation and Recovery Act, pp. I-1 to I-7
Chapter III: Hazardous Waste Identification, pp. III-3 to III-28 and Universal Wastes, pp. III-35 to III-37
U.S. Environmental Protection Agency. (2014). RCRA orientation manual 2014. Retrieved from
https://www.epa.gov/sites/production/files/2015-07/documents/rom.pdf
Read the following section in the resource below: §261.31 Hazardous wastes from non-specific sources.
U.S. Government Publishing Office. (2017). Title 40: Protection of environment: Part 261—Identification and
listing of hazardous waste. Retrieved from http://www.eC.F.R..gov/cgi-bin/textidx?SID=8ccceadd64f50f286f21052876447870&mc=true&node=sp40.28.261.d&rgn=div6#se40.28.2
61_131
BOS 3125, Hazardous Materials Management
1
Unit Lesson
UNIT x STUDY GUIDE
Title
Here we are, ready to start a course about hazardous materials
management, but the first course unit and first chapter in the book are
titled “Hazardous Waste.” What is that about? Is hazardous waste not at
the end of the lifecycle, and is it not more appropriate for the end of the
course? Besides, safety practitioners are not responsible for hazardous
waste—that is an environmental thing, right?
To manage hazardous materials in the workplace effectively, we need to
start with the end in mind (i.e., what happens to the material when we
are done with it). The Resource Conservation and Recovery Act (RCRA)
of 1976 introduced us to the cradle-to-grave concept of hazardous
materials management by focusing efforts on the final disposal of
hazardous substances (Haight, 2012). The improper disposal of
industrial waste over many decades had created enormous health and
environmental issues, as well as a nearly insurmountable cleanup
problem.
While the acronym RCRA comes from the act signed into law in 1976, it
has evolved into an umbrella designation for the many and varied rules,
regulations, and policies promulgated by the U.S. Environmental
Protection Agency (EPA) over the last 40 years. These include the
Hazardous and Solid Wastes Amendments of 1984, the Federal
Facilities Compliance Act of 1982, and the Land Disposal Flexibility Act
of 1996. Regulations that codify the provisions of RCRA and its
amendments are published in the U. S. Code of Federal Regulations
(C.F.R.), Title 40 (EPA, 2014).
Special precautions must be taken
for disposing of hazardous materials
as in this area near El Centro in the
Imperial Valley, California.
(National Archives and Records Administration,
1972a)
EPA’s Impact
EPA has created regulations for the safe disposal of hazardous waste but, more importantly, has forced
industries to think about the materials they use, how those materials are stored and handled, and how those
materials are to be discarded when no longer needed. The escalating cost of the disposal of hazardous waste
in accordance with EPA rules has caused many industries to change to materials that are less hazardous or
to change processes so that hazardous materials are no longer needed. Recycling and reusing hazardous
materials has become more cost-effective than disposal. One of the goals of RCRA is to prevent future
problems caused by irresponsible waste management (Haight, 2012). This goal is being achieved by
managing the full lifecycle of hazardous materials.
The importance of managing hazardous substances throughout the lifecycle is illustrated in the U.S. Navy’s
decommissioning of submarines. For decades, it was standard practice to dispose of submarines that
reached their useful service life by sinking them out at sea. Some were used to create artificial reefs. When
the first nuclear-powered submarines were ready for decommissioning in the early 1990s, the Navy
recognized that the radioactive materials used to power these ships could not simply be sent to the bottom of
the ocean. The Navy developed a plan to remove the reactor compartments and send them to designated
nuclear waste sites (Navy League of the United States, 2013). The subs would then be dismantled and the
materials recycled. Many of these ships were built in the 1960s and contained large quantities of asbestos,
lead, polychlorinated biphenyls (PCBs), and other hazardous materials now covered by EPA hazardous
waste rules. All hazardous materials needed to be removed and disposed of in accordance with laws written
decades after the subs were built. No one else in the world was recycling submarines, so new processes
needed to be developed using emerging technologies. The project was, and continues to be, enormous in
scope and cost.
EPA or Occupational Safety and Health Administration
Safety practitioners are most often concerned with the Occupational Safety and Health Administration
(OSHA) regulations and the effects of hazardous materials on the workers, and these safety practitioners
might feel that compliance with EPA regulations belongs to someone else. Some organizations do have a
separate environmental compliance office, and other organizations choose to combine the safety and
BOS 3125, Hazardous Materials Management
2
environmental functions. Regardless of how the responsibilities are divided, the
safety
practitioner
must be
UNIT
x STUDY
GUIDE
familiar with EPA rules and regulations because he or she is central to the decisions
Title made regarding
hazardous materials in the workplace. Over the years, the connection between OSHA and EPA has become
even closer due to OSHA’s Hazardous Waste Operations and Emergency Response (HAZWOPER) and
hazard communication standards. It is interesting to note that RCRA predates OSHA standards.
Safety practitioners also need to be aware of the Comprehensive Environmental Response, Compensation,
and Liability Act (CERCLA), which is commonly known as the Superfund. Through a tax levied on the
chemical and petroleum industries, CERCLA created a trust fund that is used for cleaning up abandoned or
uncontrolled hazardous waste sites (EPA, n.d.). EPA has established a National Priority List (NPL) for the
long-term planning of hazardous waste cleanup and administers the program through its 10 regional offices.
The Superfund Amendments and Authorization Act of 1986 (SARA) increased the size of the CERCLA fund,
added requirements to increase focus on human health, and stressed the importance of permanent remedies
for hazardous waste site cleanup (Haight, 2012).
In another connection to OSHA, the Emergency Planning and Community Right-to-Know Act (EPCRA) of
1986 mandates that facilities that are required to keep safety data sheets as a part of the OSHA Hazard
Communication Standard (29 C.F.R. §1910.1200) must provide a list of the chemicals used at the facility to
local emergency response organizations and report on chemical releases.
Hazardous Waste Identification
The core of RCRA is the identification of hazardous waste. The first determination is whether a material is a
solid waste. Anything that is discarded is considered a solid waste, but not all solid waste is hazardous. The
next consideration is whether the waste is excluded by EPA from the definition of solid or hazardous waste.
Household waste and agricultural waste used as fertilizer are examples of exclusions from the definition of
solid waste (Haight, 2012). The full list can be found at 40 C.F.R. §261.4.
A solid waste not otherwise excluded from the definitions may be designated as hazardous in one of the four
RCRA hazardous waste code lists (F, K, P, and U). The F list is of particular importance because it includes
many of the more common hazardous waste found across multiple industries. If the material is not listed, it
can still be classified as hazardous if it exhibits one or more of the criteria of ignitibility, corrosivity, reactivity,
and toxicity. There are very few types of industrial waste that will not fall into one of the categories above.
Figure 1 illustrates the decision-making process.
As an example of applying the decision process, consider the scenario below.
Your company has a refrigeration system that uses anhydrous ammonia. The system is going to be
replaced, and the ammonia on hand is to be discarded. Is the ammonia a hazardous waste? Please
see the resource below for more information on ammonia.
ChemicalBook. (n.d.). Ammonia. Retrieved from
http://www.chemicalbook.com/ProductChemicalPropertiesCB9854275_EN.htm
Anhydrous ammonia does meet the definition of solid waste since it is a gaseous material resulting from an
industrial or commercial operation. It is not listed on the EPA F, K, P, or U waste code lists. Anhydrous
ammonia has not been delisted. See the resource below for more information.
U.S. Government Publishing Office. (2017). Appendix IX to Part 261—Wastes excluded under §§260.20 and
260.22: Table 1—Wastes excluded from non-specific sources. Retrieved from
https://www.ecfr.gov/cgi-bin/textidx?SID=434f83e458bd77c30958aca1880477ce&mc=true&node=ap40.26.261_11090.ix&rgn=div9
As you can see, anhydrous ammonia does exhibit the corrosivity characteristic, so it is subject to RCRA
Subtitle C Regulations (Haight, 2012).
BOS 3125, Hazardous Materials Management
3
Responsibilities
UNIT x STUDY GUIDE
Title
Producers of hazardous waste are called
generators. Hazardous waste generators
must determine what category applies to
them—Small Quantity Generator, Large
Quantity Generator, or Conditionally Exempt
Small Quantity Generator. The
determination requires a comprehensive
inventory of all hazardous materials in use
and an understanding of the waste streams
produced. The inventory is often the same
one used by safety practitioners to comply
with OSHA standards; again, we see the
connection.
Cost-benefit analysis is often used to
determine whether hazardous materials
should be replaced with less hazardous
ones or whether materials can be reused or
Figure 1: The hazardous waste identification process
recycled. Since ultimate disposal of
(EPA, n.d.-a)
hazardous materials is subject to a myriad of
regulatory requirements, it is often the costliest option. At this point, we can see the positive effect on some
additional RCRA goals, which are listed below.
1. Protect human health and the environment.
2. Conserve energy and natural resources.
3. Reduce the amount of hazardous waste generated.
In the 1960s, America found itself awash in hazardous waste. Lakes and rivers were polluted, and numerous
uncontrolled hazardous waste dumpsites were leaching hazardous substances into our soil and water supply.
The RCRA was intended to be a pollution prevention solution (EPA, 2002). For the safety practitioner, it has
also aided significantly in injury prevention by reducing the quantity and types of hazardous materials in the
workplace, reducing the risks to all workers.
Role of the States
Under RCRA, hazardous
waste management is
intended to be a joint federal
and state effort. Using the
RCRA framework, each
state creates its own waste
management plans to meet
its specific needs and
establishes its own
regulatory requirements.
This unit will discuss only
the federal RCRA
provisions. It is important
that safety and
environmental practitioners
also become familiar with all
of their state and local
hazardous waste
requirements. Most state
information can be found on
the Internet.
BOS 3125, Hazardous Materials Management
The polluted South Platte River, Denver, Colorado
(National Archives and Records Administration, 1972b)
4
References
UNIT x STUDY GUIDE
Title
Haight, J. M. (Ed.). (2012). Hazardous material management and hazard communication. Des Plaines, IL:
American Society of Safety Engineers.
National Archives and Records Administration. (1972a). Special precautions must be taken for disposing of
hazardous materials as in this area near El Centro in the Imperial Valley [Photograph]. Retrieved from
https://catalog.archives.gov/id/553905
National Archives and Records Administration. (1972b). The polluted South Platte River Denver, Colorado
[Photograph]. Retrieved from https://catalog.archives.gov/id/544810
Navy League of the United States. (2013). Puget Sound Naval Shipyard: Ship-submarine recycling program.
Retrieved from https://bremolympicnlus.wordpress.com/2013/12/17/puget-sound-naval-shipyard-shipsubmarine-recycling-program/
U.S. Environmental Protection Agency. (n.d.-a). The hazardous waste identification process [Image].
Retrieved from https://www.epa.gov/hw/learn-basics-hazardous-waste#cradle
U.S. Environmental Protection Agency. (n.d.-b). Superfund: CERCLA overview. Retrieved from
https://www.epa.gov/superfund/superfund-cercla-overview
U.S. Environmental Protection Agency. (2002). 25 years of RCRA: Building on our past to protect our future
[Brochure]. Retrieved from
https://nepis.epa.gov/Exe/ZyPDF.cgi/10000MAO.PDF?Dockey=10000MAO.PDF
U.S. Environmental Protection Agency. (2014). RCRA orientation manual 2014. Retrieved from
https://www.epa.gov/sites/production/files/2015-07/documents/rom.pdf
Suggested Reading
In order to access the following resources, click the links below:
Small businesses often have a difficult time understanding complex federal regulations. The Environmental
Protection Agency (EPA) has a small business guide, which provides a good overview.
U.S. Environmental Protection Agency. (2001). Managing your hazardous waste: A guide for small
businesses. Retrieved from https://www.epa.gov/sites/production/files/201412/documents/k01005.pdf
Read more about the history and legacy of EPA in this brochure:
U.S. Environmental Protection Agency. (2002). 25 years of RCRA: Building on our past to protect our future.
Retrieved from https://nepis.epa.gov/Exe/ZyPDF.cgi/10000MAO.PDF?Dockey=10000MAO.PDF
For more details on hazardous waste generators, read the following section in Chapter III of the ROM:
“Regulations Governing Hazardous Waste Generators” (pp. III-39 to III-48).
U. S. Environmental Protection Agency. (2014). RCRA orientation manual 2014. Retrieved from
https://www.epa.gov/sites/production/files/2015-07/documents/rom.pdf
Learning Activities (Nongraded)
Nongraded Learning Activities are provided to aid students in their course of study. You do not have to submit
them. If you have questions, contact your instructor for further guidance and information.
BOS 3125, Hazardous Materials Management
5
State and Local Regulations vs. EPA: Who’s Tougher?
UNIT x STUDY GUIDE
Title
Research the hazardous waste regulations established by your state and local area. Are they more restrictive
than the Environmental Protection Agency (EPA) requirements? Create a table that highlights the major
differences.
What Is In Your House?
Create an inventory of cleaning products on hand in your home. Based on the major ingredients listed on the
label, determine if each product would be a hazardous waste (if you were a regulated generator). Use the
EPA definitions of characteristic wastes and the listed wastes (F, K, P, & U) in 40 C.F.R. §261 to make your
determinations.
BOS 3125, Hazardous Materials Management
6
UNIT II STUDY GUIDE
Regulation of Hazardous
Material Spill Response
Course Learning Outcomes for Unit II
Upon completion of this unit, students should be able to:
1. Examine standards that govern the management of hazardous substances in the workplace.
1.1 Explain the roles of the federal and state agencies that regulate the handling, transportation,
and disposal of hazardous substances.
1.2 Determine the reporting requirements for hazardous substance spills and releases.
1.3 Identify measures of toxicity used to evaluate hazardous substance spills and releases.
5. Apply industry best practices for managing hazardous substances.
5.1 Explain how risk assessments contribute to an effective emergency response action plan.
6. Discuss transportation requirements for hazardous substances.
6.1 Summarize the role of the U.S. Department of Transportation in hazardous substance
management and spill reporting.
Course/Unit
Learning
Outcomes
1.1
1.2
1.3
5.1
6.1
Learning Activity
Unit Lesson
Chapter 2
NRT (2001)
RCRA Orientation Manual, Chapter III
Unit II Assessment
Unit Lesson
Chapter 2
Unit II Assessment
Unit Lesson
Chapter 2
OSHA Fact Sheet
Unit II Assessment
Unit Lesson
Chapter 2
Unit II Assessment
Unit Lesson
Chapter 2
OSHA Fact Sheet
RCRA Orientation Manual, Chapter VI
Unit II Assessment
Reading Assignment
Chapter 2: Hazardous Material Spills and Response, pp. 37–59
In order to access the following resources, click the links below:
Review the National Response Team’s Hazardous Materials Emergency Planning Guide (pp. 1–14) below.
National Response Team. (2001). Hazardous materials emergency planning guide. Retrieved from
https://www.epa.gov/sites/production/files/2014-09/documents/cleannrt10_12_distiller_complete.pdf
BOS 3125, Hazardous Materials Management
1
Read the fact sheet below, which briefs the topic of hazardous waste operations
andx emergency
response.
UNIT
STUDY GUIDE
Title
Occupational Safety and Health Administration. (n.d.). OSHA fact sheet: Hazardous waste operations and
emergency response. Retrieved from https://www.osha.gov/OshDoc/data_General_Facts/factsheethazardouswaste.pdf
Read the following chapters in the RCRA Orientation Manual 2014, which can be accessed by clicking the
link below.
Chapter III: Managing Hazardous Waste, pp. III-135 to III-141
Chapter VI: Other Environmental Statutes, pp. VI-9 to VI-14.
U.S. Environmental Protection Agency. (2014). RCRA orientation manual 2014. Retrieved from
https://www.epa.gov/sites/production/files/2015-07/documents/rom.pdf
Unit Lesson
When the Occupational Safety and Health Administration (OSHA) was created in 1970, there was already a
cadre of safety practitioners working in the industry and actively involved in accident prevention efforts. The
American Society of Safety Engineers (ASSE) had been active for many years, as had other safety-related
nongovernment organizations such as the National Fire Protection Association (NFPA), the National Safety
Council (NSC), and the American Conference of Governmental Industrial Hygienists (ACGIH). The OSHA
standards that were created had roots in these private organizations and forced companies to finally pay
attention to worker safety.
The U.S. Environmental Protection Agency (EPA) was also created in 1970 with specific air quality, water
quality, and solid waste responsibilities transferred to it from the Department of the Interior, the Department of
Agriculture, and the Department of Health, Education, and Welfare. The goal was to provide the nation with a
focal point for addressing the growing problem of pollution (EPA, 1992).
EPA was given broad powers to publish and enforce standards, and since an environmental profession did
not yet exist, industry found itself with very limited in-house expertise to deal with the new federal and state
requirements. Some companies chose to assign environmental responsibilities to safety departments, but
many sa…
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