SOP 4.4 Waste Packaging



SOP 4.4: Waste Packaging

Contents

1. Introduction 1

2. Regulatory and contractual requirements 1

3. Staff qualifications 1

4. Health and safety precautions 2

5 Spill response 2

6 Equipment and supplies 3

7. Packaging HW 3

Attachment A: Example inventory sheet 7

Attachment B: Example container log 8

Attachment C: Explanation of container labels and markings 9

1. Introduction

Proper packaging procedures will correctly guide the processing of Hazardous Waste (HW) received at this Household Hazardous Waste (HHW) Facility. HW packaging includes lab packing and loose packing. This process follows the prescreening of incoming materials and ensures proper preparation of HW for transport and disposal.

2. Regulatory and contractual requirements

The packaging of HW is governed by the requirements established in the HW program and state agency contract (see Exhibit A), Department of Transportation (DOT) 49 Code of Federal Regulations, 49 CFR 173.12 (b)(2)(iii), 173.12 (b)(1), Minn. Rules pt. 7045.0310, subp 3 and 7045.0205 through 7045.0320, and Occupational Safety and Health Administration (OSHA) 29 CFR 1910.120 (a) and (q).

3. Staff qualifications

The designated Program staff responsible for ensuring HW is properly packaged is the Facility Manager. This person shall enforce HW regulatory standards, rules, and policies as they relate to staff actions and conduct. Prior to sorting, managing, or preparing HW for highway transport, staff shall complete Hazardous Categorization, OSHA, and DOT (or equivalent) trainings. Staff shall be trained within six months of being hired or starting a new position or be supervised by trained staff. Refresher training shall be conducted annually.

4. Health and safety precautions

4.1 Safety

4.1.1 Only staff trained and medically approved (if Facility is enrolled in a medical monitoring program) shall package HW, see SOP 2.13 Medical Monitoring.

4.1.2 Staff shall follow safety measures and precautions as outlined in this Facility’s Emergency Contingency Plan and Health and Safety Plan. Staff shall also take precautions to prevent environmental impacts.

4.1.3 No smoking shall be allowed in this Facility, and there are designated areas for eating or drinking which are located away from chemical processing or storage areas.

4.1.4 Routinely look for immediate dangers to nearby staff and property. Keep alert for suspicious activities or behaviors: see SOP 4.15 DOT Security Issues.

4.1.5 Proper ergonomic techniques shall be utilized while packaging wastes; see SOP 2.11 Ergonomics.

4.2 Personal protective equipment (PPE) requirements

This Program may choose to implement a more restrictive PPE policy, as engineered solutions to environmental conditions and experienced staff judgment may be used for unique conditions and situations, see SOP 2.4 Personal Protective Equipment. At a minimum, the following PPE shall be used when packaging HW:

• safety glasses, goggles, or equivalent eye protection

• footwear with reinforced toe or toe caps or equivalent foot protection

• appropriate protective gloves

• long-sleeved shirt and long pants, or equivalent, Tyvek or equivalent

• respirator use (only if Facility has respirator program, see SOP 2.5 Respirator Program).

5. Spill response

Facility staff shall be responsible for cleaning up incidental spills that could happen in the course of packing HW which may pose potential safety or health hazards. Only trained emergency response staff or an emergency contractor shall respond to control and clean up of spills requiring assistance beyond the capabilities of Facility staff. Facility staff shall be trained and be able to respond to small spills only. This Facility shall make prior agreements with emergency response teams or HW contractors who could be used in case of an emergency: see SOP 2.6 Spill Response and SOP 2.10 HW Contingency Plan.

6. Equipment and supplies

1. Staff requires adequate space to process, separate, organize, and package HW. A sorting area shall be set up to segregate the different wastes into labeled secondary containers. This prevents commingling of incompatible wastes and prepares the waste for lab packing.

2. Waste packaging areas shall have flooring that is impermeable to the HW being processed and shall be away from public drop off areas.

3. Proper equipment and supplies shall be available to process all materials received, including:

1. UN-approved containers (e.g., metal, poly, fiber)

2. Poly liners to be placed inside fiber/cardboard containers

3. Compatible absorbents as appropriate for each waste type (e.g., clay type, oil dry, vermiculite, sawdust)

4. Container inventory forms (as required by the state-contracted HW disposal company)

5. Facility drum log

6. Waste classification reference manuals (provided by state-contracted HW disposal company)

7. Marking pens

8. Labels (hazardous waste, non-hazardous, DOT, “Up” arrow)

9. Strapping or duct tape

10. Carts

7. Packaging HW

The HW packaging process takes place after presorting or prescreening has been completed. The state-contracted HW disposal company provides Facility staff with packaging and container specifications and assistance for waste stream identification as HW will need to be segregated into individual categories based on their chemical constituents. See the state-contracted HW disposal company’s Hazard Categorization Manual or SOP 4.2 Waste Sorting.

The three methods of packaging HW include bulking, lab packing, and loose packing. For additional information on bulking wastes, see SOP 4.5 Waste Bulking. Lab packs require a detailed inventory while loose packs do not require an inventory. Loose packs are sometimes referred to as a “sorted waste stream.”

7.1 Selecting containers

7.1.1 Select a container using state HW contractor packaging and container specifications. See Attachment C of this SOP: Understanding Markings on Containers.

7.1.2 Choose containers and absorbent materials that are compatible with waste stream, i.e. do not place corrosive acids into metal containers.

7.1.3 Fiber containers must contain a 6 ml. poly liner.

7.2 Container markings and preparation

7.2.1 Correctly mark or label the container before packaging waste. Each container should be marked appropriately with the following:

7.2.1.1 “Hazardous Waste” or “Non-hazardous”

7.2.1.2 The DOT hazard class (e.g., corrosive, flammable solid, oxidizer, etc.). For a list of lab pack classes, see Attachment C of this SOP.

7.2.1.3 The accumulation start date. 55-gallons and smaller sized containers shall be marked once the container is full. Containers larger than 55 gallons shall be marked the day product is first placed in the container.

7.2.1.4 “Up” arrow labels are required for containers holding liquid wastes.

7.2.1.5 Each container shall be marked with a unique number assigned by this Facility to be used for tracking purposes.

7.2.1.6 Container markings and labels shall be located on the container within six inches of each other and visible for inspection purposes.

7.2.1.7 Only one of each different required label shall be displayed on each package, however, duplicate labels are displayed on at least two sides or two ends (other than the bottom).

7.2.1.8 Labels shall be clearly visible and not obscured by markings or attachments.

7.3 Lab packing

7.3.1 Container inventory/tally sheets

7.3.1.1 A complete inventory form (provided by the state-contracted HW disposal company) shall accompany each lab pack, for an example inventory form, see Attachment A of this SOP. Tally sheets may be used with or in place of an inventory sheet. Container inventories list the:

• unique container number

• contents of the lab pack

• quantity, weight, or size of container

• physical state and chemical name of each item contained inside

7.3.1.2 Record each HW container on the inventory sheet.

7.3.1.3 Inventory/tally sheets are typically stored on a clipboard and stored on or near the accompanying waste container.

7.3.2 Placing waste items into lab packs

7.3.2.1 Pour a thin layer (about 3 inches) of absorbent on the bottom of the outer container. Staff shall ensure the absorbent material (e.g., clay type, oil dry, vermiculite, sawdust) is appropriate for each waste type. Absorbent protects items from breakage and absorbs spills.

7.3.2.1 Containers holding liquids shall be placed upright into the lab pack with all container openings facing up. Place waste items into lab packs by:

1. Ensure glass containers have at least one-half inch of space between containers to provide room for additional absorbent, although cardboard, plastic, and metal containers may be placed against each other.

2. Place an additional 2 inches of absorbent between the waste container and the side of the outer container. Place a single layer of waste containers onto the absorbent, making sure each container does not exceed the maximum size limit allowed (no single container placed into a lab pack should be larger than a five-gallon pail or have a weight greater than 50 pounds. Reference the state-contracted HW disposal company’s Hazard Categorization Manual for specifics).

3. Fill the outer container with alternating layers of waste containers and absorbent.

4. Cover/top off the lab pack inner containers with 2 to 3 inches of absorbent material.

5. If the container has a liner, close and seal by taping. Fold liner down, inside the container.

6. Securely fasten on the container lid; for fiber containers without rings, tape the perimeter of the lid to secure.

7. Mark the container number on the lid and record this number into the Facility drum log. This individual container number consists of the waste category and a facility-specific sequential number. For an example drum log, see Attachment A of this SOP.

8. Attach one copy of the completed inventory sheet to the container, submit one copy to the state HW disposal contractor and keep one for Facility records. Keep this document on file with corresponding manifest for at least five years.

7.4 Loose-packing

7.4.1 Loose-packing is a packaging method used to aggregate containers within an established waste profile (as identified by the state-contracted HW disposal company). This process eliminates the need to complete an inventory form. Waste streams commonly loose-packed may include aerosols, flammables, corrosives, paints, and pesticides. To place items into loose-packs:

1. Place a one-inch layer of absorbent in the bottom of the package container to prevent breakage and absorb spills.

2. Limit the potential for spills by placing containers upright, and each container is closed prior to placing items into the loose pack.

3. If the container has a liner, close and seal by taping. Fold liner down, inside the container.

4. Securely fasten on the container lid; for fiber containers without rings, tape the perimeter of the lid to secure.

5. Write the container number on the lid and record the container number into the Facility drum log. This individual container number consists of the waste category and a facility-specific sequential number. For an example drum log, see Attachment A of this SOP.

Attachment A

Example Inventory Sheet: State-Contracted HW Disposal Company

Organic acid container inventory (example)

Generator name Container type/size

Container number Date

Profile/manifest # Gross weight of container

Shipping name: waste corrosive liquids, acidic, organic, n.o.s. 8, un3265, ii

|Waste description |1 gallon |1 quart |1 pint |½ pint |# |

|Acetic acid 10% | | | | | |

|Thiourea | | | | | |

|Citric acid | | | | | |

|Coffee pot cleaners | | | | | |

|Glycolic acid | | | | | |

|Hydroxyacetic acid | | | | | |

|Lime-Away with hydroxyacetic acid and| | | | | |

|sulfamic acid | | | | | |

|Most wallpaper strippers (when pH is | | | | | |

|acidic) | | | | | |

|Oxalic acid | | | | | |

|Photo fixer with acetic acid | | | | | |

|Formic acid | | | | | |

|Formalin | | | | | |

| | | | | | |

| | | | | | |

| | | | | | |

Attachment B

Example Container Log

State-contracted HW disposal company: Page:

20 Container Log Book

Facility location:

|Container # |Start date|Container size |Gross weight |Profile/WIP# |Manifest # |Ship date |Treatment facility |

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Attachment C

Explanation of container labels and markings

For more information, research CFR 49 172.101 Hazardous Materials Table.

Packaging example 1

Packaging for magnesium powder in a container with markings: 1H2/X25/S/0406/USA/XXX

This marking indicates the container:

• 1H2—an open head plastic container.

• X—the container can hold a Packing Group X material.

• 25—container will contain a gross weight < or = 25 kg.

• S—will contain a solid.

• 0406—manufactured 2004, June.

• USA—manufactured in the United States.

• XXX—manufactured by XXX company.

• Inner package will be a plastic receptacle.

• The magnesium powder was placed into a 1 pint sized plastic lined container and overpacked into 5-gallon plastic bucket that had the UN marking on it (49 CFR 178 subpart L).

• Name and address not required on packaging. No RQ on packaging.

Packaging example 2

Packaging for phosphoric acid in a container with markings: 1H1/Y1.8/150S/0406/USA/XXX

This marking indicates the container:

• 1H1—is a closed head plastic container.

• Y—can hold a Packing Group Y material.

• 1.8—will contain a liquid with a specific gravity < or = 1.8.

• 150—has a hydrostatic pressure < or + 150 kilopascals.

• 0406—manufactured 2004, June.

• USA—manufactured in the United States.

• XXX—manufactured by XXX company.

• The phosphoric acid was bulked into a 55- gallon plastic container that had the UN marking on it (49 CFR 178 subpart L).

Packaging example 3

Packaging for dichloromethane (methylene chloride) in a container with markings: 1A1/Y1.6/150/04/USA/XXX

This marking indicates the container:

• 1A1—is a closed head steel container.

• Y—can hold a Packing Group Y material.

• 1.6—will contain a liquid with a specific gravity < or = 1.6.

• 150—has a hydrostatic pressure < or + 150 kilopascals.

• 04—manufactured 2004.

• USA—manufactured in the United States.

• XXX—manufactured by XXX company.

• The methylene chloride was bulked into a 55- gallon steel container that had the UN marking on it (49 CFR 178 subpart L).

Labeling example 1

|Labeling and marking requirements for magnesium powder in a 55 gallon container: |

|Labels for magnesium powder: |Markings for magnesium powder: |

|Primary label is: DANGEROUS WHEN WET |Magnesium Powder |

|(49 CFR part 172.423) |UN1418 |

|Subsidiary label is: SPONTANEOUSLY |1H2/X25/S/0406/USA/XXX |

|COMBUSTIBLE |UN Symbol |

|(49 CFR part 172.422) |No RQ, name or address required on package. |

| |No markings required on inner packaging. |

|Placarding for magnesium powder if placarding and transporting: |

|The magnesium powder is a Class 4.3 hazardous material. |

|DANGEROUS-WHEN-WET quantities are less than 1,001 pounds, so no placard would be required for this hazard class. |

Labeling example 2

|Labeling and marking requirements for phosphoric acid in a 55 gallon container: |

|Label for phosphoric acid: |Markings for phosphoric acid: |

|Primary label is: CORROSIVE |Phosphoric acid |

|(49 CFR part 172.442) |UN2834 |

|No subsidiary label is required. |1H1/Y1.8/150/0406/USA/XXX |

| |UN Symbol |

| |No RQ, name or address required on package. |

|Placarding for phosphoric acid if placarding and transporting: |

|CORROSIVE quantities are less than 1,001 pounds, so no placard would be required for this hazard class. |

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