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HAZARDOUS MATERIAL SAFETY
PROCEDURES
Effective Date: January 1, 1992
Revised Date: March 1993
UT Memphis shall implement a program that protects its employees
from hazardous chemical in accordance with Section 1910.1200 of the
Occupational Safety and Health Act (OSHA), entitled ³Hazard
Communication², and the State of Tennessee House Bill No. 731, entitled
³The Hazardous Chemical Right-to-Know Law,² and, in doing so, shall meet
the general requirements summarized below:
- It shall post notices (prepared by the Tennessee Department of
Labor) of employee rights under the acts.
- It shall maintain and make available to employees the most current
Material Safety Data Sheets (MSDSs) for hazardous chemicals used in
their workplaces.
- If the MSDS is not available as required, after a compliance
procedure is exhausted, the employee may refuse to work with the
hazardous chemical without penalty.
- It shall maintain labels on containers, and if the hazardous
chemical is transferred to another container, it shall appropriately
label the transfer container.
- It shall not require employees to work with a hazardous chemical
if the container is not properly labeled.
- It shall provide an education and training program for employees
pursuant to standards established by regulation and shall provide
annual refresher courses.
- It shall inform employees of exposure to hazardous chemicals,
provide access to the workplace chemical list and MSDSs, and provide a
copy of the MSDS on request.
- It shall not retaliate against any employee for exercising rights
under the acts.
- It shall not require prospective employees to waive any right
under the acts as a condition of employment.
- It shall file with the Tennessee Department of Labor a workplace
chemical list for chemicals stored in any one building in excess of
fifty-five gallons or five hundred
pounds. This list shall contain the CAS (Chemical Abstract Services)
number, if such number is on the MSDS, and the list must be updated at
least annually.
- It shall keep copies of such lists for thirty years.
- Any information provided under the acts shall not release it from
liability under any other law.
- It shall implement procedures contained in the Procedures for the
Use of Hazardous Chemicals at The University of Tennessee, Memphis to
enable it to comply with the legal requirements of OSHA and State of
Tennessee House Bill No. 731.
A copy of the Procedures for the Use of Hazardous Chemicals at The
University of Tennessee, Memphis is included as an appendix.
Chemical Hygiene Plans (CHPs) shall be prepared and implemented for each
laboratory by the appropriate department or unit as the foundation for
compliance with requirements contained in Occupational Exposures to
Hazardous Chemicals in Laboratories, as noted in Subject H. Laboratory
Safety. Items in the CHP include labeling of hazardous chemicals;
engineering controls, such as biological safety cabinets and fume hoods;
contaminated waste removal and disposal; spills; recordkeeping; personal
protective equipment; training; chemicals requiring approval for use;
medical consultations and examinations; on-the-job injuries; and
Department of Transportation and Environmental Protection Agency (EPA)
classifications of hazardous chemicals.
A sample Chemical Hygiene Plan is included in the UT Memphis Safety
Manual.
The Resource Conservation and Recovery Act (RCRA) establishes a
³cradle-to-grave² system for the handling of wastes deemed by the RCRA
to be hazardous. Under RCRA, the EPA separately regulates hazardous
waste generators, transporters, and owners and operators of hazardous
waste treatment, storage, or disposal facilities. If UT Memphis
generates between 100 kg and 1,000 kg per month of non-acute hazardous
waste and less than 1 kg per month of acute hazardous waste (see sample
CHP for definitions), it is subject to the RCRA generator rules which
are found in the Code of Federal Regulations (CFR) at 40 CFR Part 262
and shall meet the following general requirements:
- It shall review each of its solid wastes to determine whether the
waste is hazardous.
- It shall obtain an EPA identification number.
- It shall comply with certain requirements regarding preparation of
wastes for off- site shipment, including packaging, labeling, marking,
and placarding standards.
- It shall comply a manifest form for wastes shipped off-site,
retain a copy for its own records, and provide copies to the waste
transporter.
- It shall certify on the manifest that it has made a good faith
effort to minimize waste generation and to select the best waste
management method that is available and that it can afford. The UT
Memphis Waste Minimization and Chemical Disposal Guide has been
developed in this regard, and a copy is appended to this document.
- If it does not receive a copy of the manifest signed by the
facility to which the waste was being sent within 60 days after the
waste was taken off-site, it shall file an ³Exception Report² with the
EPA, or a delegated state authority, with a copy of the manifest and a
note advising that the generator has not received confirmation
of delivery.
- It shall retain for at least three (3) years copies of manifests
and test results, waste analyses, or other information used in
determining whether its wastes are hazardous.
- It shall only accumulate hazardous wastes on-site for up to 180
days, or up to 270 days if the wastes must be transported 200 miles or
more for off-site treatment, storage or disposal.
- It shall not accumulate more than 6,000 kg of hazardous waste on
site at any one time.
- It shall see that waste containers are clearly marked with the
date that accumulation begins and with the words ³Hazardous Waste.²
- It shall follow EPA-specified emergency preparedness and
prevention procedures.
- It shall see that accumulation tanks, containers, and hazardous
waste storage areas meet appropriate design and operational criteria.
If UT Memphis generates more than 1,000 kg of non-acute hazardous waste
or more than 1 kg of acute hazardous waste, it shall also meet the
following requirements, also set forth in 40 CFR Part 262:
- It shall provide accumulation tanks and containers in accordance
with more stringent EPA requirements than the requirements above,
including containment and release detection requirements for tanks and
standards for closure of accumulation areas.
- It shall implement a formal program to train personnel in proper
hazardous waste management procedures.
- It shall develop a formal contingency plan to mimimize health or
environmental risks from fires, explosions or sudden releases of harmful
elements into the environment.
- It shall submit a Biennial Report to EPA, or a delegated state
authroity, on March 1 of each even-numbered year concerning wastes
shipments and waste minimization efforts during the preceding year, and
such report shall be retained for at least three (3) years.
- It shall accumulate wastes for no more than 90 days (an emergency
extension of up to 30 days may be granted on a case-by-case basis),
rather than the 180/260- day time period for smaller generators
discussed above.
- The exception to the manifest requirement for wastes that are
shipped off-site for reclamation shall not apply.
- It shall certify that it has a waste miminization program in place
and that it has selected the available method of storage, treatment or
disposal that minimizes environmental risks. The UT Memphis Waste
Minimization and Chemical Disposal Guide has been developed in this
regard, and a copy is appended to this document.
- It shall implement the following, more stringent, Exception Report
requirements rather than those discussed above:
- If it has not received a signed copy of the manifest from the
storage, treatment, or disposal facility within 35 days after the waste
was taken off-site, it shall contact the transporter and/or the waste
facility to determine the status of the waste.
- If the signed copy of the manifest is not received within 45 days
of date of shipment, it shall file with the state an Exception Report
consisting of a copy of the manifest and a cover letter explaining the
efforts taken to locate the waste and the results of those efforts.
- Such reports shall be retained for at least three (3) years.
The Tennessee Hazardous Waste Management Act, administered by the
Tennessee Department of Conservation, Division of Hazardous Waste
Management, requires that UT Memphis, as a hazardous waste generator,
develop and maintain a hazardous waste emergency plan. A copy of
the Hazardous Waste Emergencies Contingency Plan is appended to this
document.
If UT Memphis exceeds the waste accumulation limits, it then becomes a
RCRA storage facility. In such cases, it shall apply for a storage
permit under 40 CFR Part 270, and it shall meet additional related
requirements contained in the RCRA.
The Safety Office shall develop requirements for transport, treatment,
and disposal of hazardous wastes, and shall work with Purchasing in the
award of a contract to the vendor submitting the lowest and best bid to
provide these services. As a generater, UT Memphis shares
responsibility with the vendor for the safe management and ultimate
disposal of its hazardous wastes. Facilities and Purchasing shall
carefully consider vendor qualifications to insure that wastes are not
released into the environment.
The Campus Safety Officer shall prepare a Hazardous Waste Annual Report
and forward to the State of Tennessee Department of Conservation and
Environment, Division of Solid Waste Management, upon receipt of forms
from, and in accordance with the schedule established by, that agency.
The Campus Safety Officer shall provide a copy of the report to the
University-wide Safety and Health Administration Office.
The OSHA Bloodborne Pathogens Standard contains procedures established
to reduct on-the- job risks for all employees exposed to blood. UT
Memphis shall implement a program to comply with this standard and, in
doing so, shall meet the following general requirements:
It shall develop a written Exposure Control Plan, to
include:
Exposure Determination (identification of workers with
occupational exposure to blood and other potentially
infectious material):
Schedule and Method of implementaiton for:
Methods of Compliance, including:
Universal Precautions
Engineering and Work Practice Controls
Personal Protective Equipment
Laundry
HIV and HBV Research Laboratories and Production
Facilities, including:
Research and Production Laboratory Criteria
Hepatitis B Vaccination and Post-Exposure Evaluation and
Follow-up, including:
Hepatitis B Vaccination
Post-Exposure Evaluation and Follow-up
Information Provided to Heatlhcare Professionals
Healtcare Professional¹s Written Opinion
Communication of Hazards to Employees, including:
Labels and Signs
Information and Training
Recordkeeping, including:
Medical Records
Training Records
Availability
Transfer of Records
UT Memphis shall follow the Protocol for Evaluation, Prophylaxis and
Follow-up of Faculty, Housestaff, Other Employees and Students Exposed
to Blood Borne Pathogens (i.e., HIV, Viral Hepatitis) that has been
developed by the UT Memphis Committee on Infection Control.
A copy of the Exposure Control Plan is included in the UT Memphis Safety
Manual.
The Safety Office shall develop requirements for the designation,
segregation, packaging, storagetransport, treatment, and disposal of
infectious waste, and shall work with Purchasing in the award of a
contract to the vendor submitting the lowest and best bid to provide
these services. EPA recommends the following separate categories of
infectious waste:
Isolation waste.
Cultures and stocks of infectious agents and associated
biologicals.
Human blood and blood products.
Pathological waste.
Contaminated sharps.
Contaminated animal carcasses, body parts, and bedding.
Miscellaneous, including any waste known to be infected with
bloodborne diseases.
A copy of the Facilities Inspection Program, which includes waste
management, is included in the UT Memphis Safety Manual.
Statements which may reference appended materials are not included in this Administrative
Manual but are available as appendices in the Campus Safety and Health Procedures Manual or by
contacting the Campus Safety Officer.
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