Safety

CH Department HazComm—HazComm information that is required to be presented to all employees in the Department of Chemistry by their supervisors. This excludes only undergraduate students in their normal lab courses. Everyone else must receive this training.

CH Department HazComm Form—The official checklist designed to accompany the presentation above. Completion certifies that the signee has had HazComm training from his/her supervisor.

• The Hazard Communication (Right-To-Know) Standard (OSHA 1910.1200; MIOSHA R325.77001-77003)
• MIOSHA. PART 431, Hazardous Work in Laboratories
• The National Institute for Occupational Safety and Health Appendix C - Supplementary Exposure Limits

• Michigan Tech HazComm Program
• Michigan Tech HazComm Labeling Rules
• Michigan Tech Safety Manual

Is it in the original container? Yes–Go to 1) No–Go to 2)

1) Do not obscure the original label.

• On the back of the container, affix a label with clear tape (packaging tape is best).
• The label should say "Excess Inventory Dispose."
  • Add the lab room number and a date.
• Take the container to University Chemical Stores.

2) For a reagent not in its original container, you must generate a label sufficient to describe the reagent. (No, ink on the bottle is not sufficient.)

• On the container, affix a label with clear tape (packaging tape is best) providing the following information:
  • Reagent name
  • EPA waste code (if applicable—not all reagents have a waste code)
  • Any applicable hazard warnings (oxidizer, corrosive, water reactive, etc.)
  • The label should also say "Excess Inventory Dispose"
  • The lab room number and a date
• Take the container to University Chemical Stores.

Do you think you know what the material is? Yes–Go to 1) No–Go to 2)

1) Label the container with as much information as you know.

• Affix a label with clear tape (packaging tape is best) providing the following information:
  • "Unknown chemical reagent" or "unknown material"
  • The label should also say "hazardous waste tentative identification as (xxxxxx)"
  • Your name
  • The lab room number and a date
• Fill out the Hazardous Waste Pickup Form and follow the Hazardous Waste Collection and Disposal Procedures.

2) Label the container as hazardous waste.

• Affix a label with clear tape (packaging tape is best) providing the following information:
  • "Unknown chemical reagent" or "unknown material"
  • The label should also say "hazardous waste"
  • The lab room number and a date
• Fill out the Hazardous Waste Pickup Form and follow the Hazardous Waste Collection and Disposal Procedures.

As waste accumulates, keep a log (or inventory) of each addition to the waste container. This is hazardous waste, and by EPA regulations, your lab cannot accumulate more than 5 gallons of total hazardous waste or keep the accumulated waste for more than six months from the date you started collection in this container.

We use the Hazardous Waste form as both a log and ultimately a label for the container. We keep the form in a plastic sleeve tied to the waste container, but not attached to it. In this way we can make additions to the container without fear of ruining the log.

• When the container is full, fill out the Hazardous Waste Pickup Form (one form per mixed waste container).
  • You need only declare the major (> 5 percent) components of your mixed waste, unless you have something particularly toxic. If in doubt, list it.
  • Fill out all the EPA Waste ID numbers.
  • Follow the instructions on the EHS waste disposal website in order to accomplish waste disposal.
• Keep the mixed waste in your lab until picked up.

The term "hazardous waste" has a specific regulatory meaning.

• It can't accumulate in your lab for more than six months.
• It can't be stored anywhere other than your lab or the single authorized collection point at Michigan Tech. In other words, we cannot store anything labeled "hazardous waste" in Chem Stores or Used Chemical Storage.

"Excess inventory" refers to all those reagents that you have sitting on the shelf that you will use "someday." There are no specific regulations that apply to "excess inventory" items. When you decide you want to get rid of them, do not call them "hazardous waste," as that puts them into a different disposal category. We can accumulate "excess inventory" with the intent of getting rid of it during a waste haul. We cannot accumulate "hazardous waste."

Resources

• The Compleat (sic) Guide to EPA Waste Identification Numbers (261.30CFR)—The original source of all the F-, K-, P- and U-number lists.
• Hazardous Chemical Waste Management Guide (University of Minnesota)—An excellent source of how and why.

• SIRI
• Seton
• Avantormaterials
• General MSDS search for Sigma-Aldrich
• Sigma-Aldrich by catalog number

Additionally, you can search online using the following key phrases: "MSDS + CAS number/chemical name" or "MSDS CAS number + supplier."

Digital copies of Safety Data Sheets (SDS) for chemicals used at Michigan Tech are available through the MSDSonline (mtu.edu/sds)