Lab Safety Manual: Chemical Management

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rev 11/2008

Chemicals cycling through Cole Science Center must be tracked in order to provide proper storage, use safety awareness, and disposal. The lab manager is responsible for monitoring chemical storage and use in the CSC, and will require regular assistance from faculty members carrying out research and course work activities.

6.1 Ordering and Receiving  

Ordering is conducted through the lab manager. Before accepting a package, the lab manager should inspect it for visible damage. If there are any signs of damage, the package should not be accepted from the shipper. 

Material Safety Data Sheets (MSDS) are requested for each chemical ordered. MSDS are received by the office of environmental health and safety, entered into the MSDS inventory, and given to the lab manager. MSDS copies are kept at the CSC and in environmental health and safety.

Upon receipt, the lab manager, or designated person, opens the package and  tags each chemical container with a unique container number and enters it into the chemical database before moving it to the designated storage area.

If someone other than the lab manager opens the package, the lab manager must be informed of its receipt and location and given the paperwork (e.g., packing slip and MSDS). The lab manager will then locate the container, tag it, and enter it into the chemical inventory.

6.2 Labeling

Manufacturer's container labels are the primary source of information on the physical and health hazards of a hazardous chemical. These labels should not be removed or defaced until the container is empty and decontaminated, if that is necessary (see Section 6.4.6 for requirements for acutely hazardous waste). Storage areas should be checked frequently to ensure that labels are tightly affixed to the container. Any loose labels should immediately be taped in place using clear packing tape. Labels must be removed or covered prior to using a container for another chemical or waste.

Containers into which hazardous chemicals are transferred, or in which solutions are prepared, must be labeled with, at a minimum: the chemical name (do not use chemical formulas or abbreviations), date, and the user's name. Containers in which the hazardous chemical is to be stored must also be labeled with the appropriate hazard warning(s). All labeling should be done with an indelible marker or preprinted labels; containers should be checked frequently to make sure that the information is legible. Dating is especially important in the case of compounds that degrade to hazardous compounds (e.g., ethers to peroxides) or have limited shelf life, as well as for determining when to best dispose of them. 

Chemical inventory tags must not be removed or defaced. Empty containers must be cleaned and returned to designated locations to ensure the container is removed from the active chemical inventory. The lab manager will then remove the tag and make the containers available for use as waste containers.

Unknowns for instructional use must be identified with a code with a key indicating the chemical content. The key must be kept by the responsible faculty or staff member. When the containers are returned to storage, the key should be kept with the containers. The potential hazards of the constituents must be communicated to those handling the unknowns.

6.3 Chemical Storage

Proper storage minimizes the potential for fire or a release of hazardous chemicals due to accidental chemical reactions.

A chemical inventory is kept of all chemicals in Cole Science Center. This inventory provides information on the name of chemicals and products, their manufacturer, and storage location. If a container is moved to a different storage location, the lab manager must be informed so the inventory can be updated. 

To safely store chemicals, the following guidelines should be adhered to:

• Chemicals will not be stored on the floor, on bench tops, or in fume hoods.
• Amounts of chemicals stored will be as small as practical.
• Large containers of reagents will be stored only on low shelving.
• Liquids will be stored in chemical-resistant trays to contain leakage or spills.
• Chemical storage areas will be separated from offices and laboratory work areas.
• Odorous chemicals must be labeled and stored inside cabinets or underneath fume hoods.
• Storage areas must be ventilated.

While the lab manager regularly checks laboratories to assure chemicals are stored properly and kept in their proper storage areas and are not out in the open laboratory space, faculty are responsible for proper handling of materials used in association with their classes or student projects.

Formal inspection of chemical storage areas are conducted annually. Stored chemicals are examined for deterioration and container integrity. Chemical containers without accompanying labels, or those unattended or unneeded items, will be removed by the lab manager for disposal (see Section 6.5). 

6.3.1 Storage by Compatibility Groups

Hazardous chemicals should always be segregated into compatible groups during storage to prevent hazardous reactions in the event of an accident. Storage areas and shelves should be clearly labeled as to appropriate hazard class. The major laboratory chemical distributors have established colored coded systems for chemical storage based on compatibility. Be aware that the systems vary somewhat between distributors. Table 6-1 provides examples of incompatible hazardous chemicals. Appendix 6-A provides additional information for specific chemicals.

Chemicals are stored based on compatibility first, and then in alphabetical order within each compatibility class, in accordance with the Guidelines for the National Fire Protection Association: NFPA 49. Any combination of acids, bases, and flammables should never be stored together. These materials must be stored separately and in appropriate and designated cabinets (e.g., acid storage cabinet). Storage cabinets containing corrosives must have resistant secondary containment to retain the material in the event of a spill or container failure. 

6.3.2 Compressed Gases and Liquids

Procedures for the handling and storing of compressed gases and liquids are described in Section 5.4. 

6.4 Moving and Shipping Chemicals

Secondary containment should be used when chemicals are moved out of the lab area, through corridors, on stairways or in elevators. Using secondary containment means placing the container in another larger, chemically resistant container. Under no circumstances should anyone transport chemical containers in a passenger elevator without the use of secondary containment.

All shipments of hazardous materials (e.g., chemicals, biological materials) for Hampshire College to another location must comply with all Department of Transportation (DOT) and International Air Transport Association (IATA) requirements.

6.5 Waste Disposal

6.5.1 What is Hazardous Chemical Waste?

In order to determine proper handling procedures and disposal, a decision must be made regarding whether a chemical waste is hazardous. Massachusetts Department of Environmental Protection (DEP) and federal Environmental Protection Agency (EPA) regulations define various categories of hazardous chemical waste. Appendix 6-B contains a summary of the hazardous waste typically generated in laboratories.
 
Faculty members are responsible for determining whether waste generated is defined as a hazardous waste by regulation. Appendix 6-C can be used to assist in that determination. Questions should be addressed to the lab manager or to the office of environmental health and safety.

Faculty should make every effort to minimize the amount of hazardous waste produced in the laboratory. Any chemical waste determined to be non-hazardous and destined for sewer or trash disposal must be confirmed as such by the lab manager. 

There are also other chemical wastes that have not been defined as hazardous waste by DEP or EPA, which should be handled as hazardous waste. These include:

• carcinogens that have not been deactivated (see Section 5.8.7 Select Carcinogens)
• reproductive toxins, e.g., ethidium bromide, that have not been deactivated (see Section 5.7.7 Reproductive Toxins)
• any other chemical waste that poses a threat to public health or the environment when disposed of as a non-hazardous waste.

Other chemical wastes may be designated to be handled as hazardous based on knowledge of the hazards of the waste. When in doubt, the waste should be collected as hazardous waste. If you need assistance, call the lab manager.

6.5.2 Disposal of Non-hazardous Chemical Waste

Liquid wastes that are non-hazardous, are water soluble, and do not contain solids may be flushed to the sewer with copious amounts of water. Liquids that are not water-soluble must be solidified (absorbed) and disposed of as a solid. Non-hazardous solid waste must be labeled "non-hazardous" and can then be put in the laboratory trash.

6.5.3. Hazardous Waste Collection and Lab Accumulation

A poster describing laboratory waste collection requirements is posted in each lab and included as Appendix 6-D.

All hazardous chemical waste must be collected for disposal by an EPA-approved method at a licensed facility. Hazardous waste cannot be diluted to make it non-hazardous and cannot be evaporated. Hazardous waste should be collected in each laboratory in screw-top containers that are compatible with the waste. Containers must be kept closed except when waste is being added.

Each container should be labeled with a preprinted red and white "Hazardous Waste" label (available from the lab manager) at the time waste is first put into the container. The label must contain:

• waste name (specify chemical name if a single element or compound, or generic name, e.g. chlorinated solvents)
• waste components (all chemicals present must be identified, no abbreviations)
• hazards (e.g., flammable, oxidizer, corrosive, reactive, toxic)

The "Date Full or Removed to Storage" space must be completed when the container is full or, if not full but the waste is no longer being generated, when it is moved to storage. Indelible markers should be used for labeling and abbreviations should not be used. 

To minimize the hazard of incompatible chemical reactions, wastes should not be mixed in the laboratory without prior approval from lab manager. It is also important to keep halogenated and non-halogenated wastes in separate containers whenever possible, as non-halogenated solvents can be processed for reuse and halogenated solvents must be incinerated. 

Laboratory waste containers should be kept in the locations designated "Satellite Hazardous Waste Accumulation Areas" which must be appropriate to the hazards of the waste. The area must be near the point of generation and all liquid waste must be in secondary containment. The secondary containment must provide for separation of wastes that are incompatible. The containment should only contain waste;  non-waste chemicals cannot be kept in the same tray.

The amount of waste accumulated in the laboratory at any time should be minimized. No more than one container of a particular waste can be kept in the lab at one time and all waste containers must fit into the secondary containers provided for those locations. When full, waste containers must be moved to the waste storage area within three days, so notifying the lab manager immediately when you have a full container is essential.

6.5.4 Laboratory Waste Removal

When a container of waste is full or when that type of waste will no longer be generated, the lab manager should be notified. The container will be removed to the waste storage area within three days. 

6.5.5 Waste Storage and Disposal

Hazardous waste storage for laboratory waste is located in the main storage area behind the Cole Science Center. The office of environmental health and safety inspects the waste storage area weekly. Emergency information, including the name and number of the emergency coordinator, is posted in the area.

In the waste storage area, all waste is separated and stored by hazard category. To minimize the potential for releases, all liquid waste containers are placed in secondary containment.

Waste is shipped off-site using a licensed hazardous waste transporter. The majority of the waste is packaged by the transporter into lab packs for shipment. All hazardous waste is taken to licensed facilities that treat, recycle, incinerate, or otherwise dispose of the materials using EPA-approved methods for the particular waste type.

6.5.6 Disposal of Empty Containers

Most empty containers can be safely and legally disposed of as laboratory trash with three exceptions.

• Empty ether cans: When empty, leave in the hood overnight and then triple rinse with water before disposal in the trash.
• Acutely Hazardous Waste Containers: Containers that contained "P-listed" wastes, as shown in Appendix 6-E, must either be triple rinsed with an appropriate solvent prior to disposal (and the solvent disposed of as hazardous waste) or the empty container can be labeled and disposed of as hazardous waste.
• Aerosol canisters that are still pressurized must be collected as hazardous waste.

6.5.7 Disposal of Gas Cylinders

Prior to ordering of gas cylinders, arrangements should be made with the distributor for return of empty cylinders. Empty non-returnable cylinders should be capped and the lab manager contacted for disposal as hazardous waste.

6.5.8 Disposal of Lab Equipment

The lab manager must approve disposal of all equipment. If laboratory equipment is to be discarded, qualified personnel should remove any hazardous materials (e.g., batteries, capacitors, transformers, mercury switches, oil, asbestos linings, radioactive sources, CFCs from refrigerators, etc.) from the equipment before disposal. Contact the lab manager for assistance.

6.5.9 Disposal of Unknowns

It is extremely difficult and costly to identify the contents and hazards of unlabeled materials. As discussed in Section 6.2, it is crucial that maintaining labels be a standard laboratory practice. If you have unknowns, please contact the lab manager. Please indicate to the best of your knowledge what the material is likely to be, based on its characteristics and the location at which it was found.

6.5.10 Universal Waste

Universal waste includes mercury containing lamps, CRTs, and certain batteries that would be hazardous if disposed of including: nickel/cadmium, mercury, and silver. These materials should be taken to designated collection (see lab manager) to be recycled.

6.5.11 Satellite Area Inspections

The lab manager inspects the satellite accumulation areas in the labs weekly when waste is present. Deficiencies that could result in a release of waste are corrected immediately; other deficiencies are referred to the responsible faculty member for correction. The lab manager then confirms that the correction has been completed.

6.5.12 Working Containers

DEP Working Container provisions allow more than one container of a particular waste in the laboratory for immediate use at the bench top. The working container must be:

• emptied into the satellite container in the laboratory at the end of each laboratory period or day, or when full, whichever comes first
• closed except during active use
• located on an impervious surface and managed to prevent spills
• labeled as "hazardous waste" with words describing the hazard
• located at or near the point of generation
• under the control of faculty of staff responsible for the laboratory

Appendix 6-A: Chemical Storage Segregation Guidelines

Appendix 6-B: Hazardous Waste Identification

Appendix 6-C: Hazardous Waste Determination

Appendix 6-D: Hazardous Waste Collection

Appendix 6-E: P Listed Hazardous Waste (Acute Toxins)