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Date: Wed, 14 Sep 2005 02:01:49 -0400
Reply-To: Denise Aronson <daronson**At_Symbol_Here**SAFETYPARTNERSINC.COM>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Denise Aronson <daronson**At_Symbol_Here**SAFETYPARTNERSINC.COM>
Subject: Response to earlier question by Daniel Leberman - Satellite Waste
Accumulation Containers
reply-type=original
From Safety Partners, Inc. employee Robert Vassallo:
The size and construction material of the container is an important factor
in determining how to proceed, other factors are container location and how
the containers are filled, of special concern is the speed in which they are
filled.
OSHA 1910.106 is totally inadequate to guide us in handling the static
discharge concern. The regulation mentions numerous times to ensure
grounding and bonding of the nozzle to the metal floor plate and when
reviewing these sections closely we see the regulation is really geared
towards operations on a larger scale (tanks & piping systems)not laboratory
scale in which someone may be pouring a liter or two (generally much
less)into a SAA container or a HPLC machine is direct feeding a SAA
container.
Ensure your (for this issue I am not including 2-5 gallon capacity safety
cans since they are easily bonded/grounded and have flame arrestors
installed) 2-5 gallon plastic containers and 15-55 gallon metal drums meet
the requirements of the DOT.
Check the fire prevention regulations for the state in which the company is
located. In Massachusetts, 527CMR14 addresses grounding and bonding of only
metal containers not plastic.
NFPA 30 Flammable/Combustible Liquids Code(referenced in its entirety by the
MA building code)is more detailed than OSHA1910.106 but again no real help
on the issue.
NFPA 45 Fire Protection in Labs using Chemicals(not referenced by the MA
building code but NFPA 30 directs you to this code for further information
relative to chemical handling)does touch on the subject.
NFPA 77 Control of Static Electricity (not referenced by the MA building
code but NFPA 30 & 45 directs you to this code for further information
relative to the control of static discharge and flammable liquids)addresses
the subject.
Container size - Plastic containers over 5 gallons must be bonded or
grounded when filling or pouring off. Smaller plastic containers do not need
to be bonded or grounded. Metal containers of any size need to be grounded
or bonded.
Plastic containers can be purchased with carbon black used in the
manufacturing process or they can be purchased with a carbon strip installed
for purposes of grounding and/or bonding.
If the SAA is located within a fume hood or similar type ventilated
enclosure static discharge is not likely to occur. Static discharge is also
not likely to occur if you utilize manual filling, slow pour rates (such as
a typical HPLC set up), avoiding bottom filling, avoiding splashes and
turbulence. In piping systems flow rates of 3 feet per second are considered
safe. HPLC rates and typical manual pour rates are slower than this.
Static charges can be built up due to the flow of the liquid, low humidity,
flooring material or issues associated with the movements/clothing of the
employee. If it is a concern then anti static devices can be purchased.
I only require bonding and grounding during waste bulking operations into 55
gallon drums in my waste room. The rest of my SAA's are in fume hoods with
the exception of my HPLC SAA's.
Denise Aronson
President
Safety Partners, Inc.
781-718-5330
http://www.safetypartnersinc.com/courses_chemistry.php
Register for the biotech 'Chemistry for EHS', professional development
course.
> ----- Original Message -----
> From:
> To:
> Sent: Tuesday, September 06, 2005 11:27 AM
> Subject: [DCHAS-L] Satellite waste accumulation containers.
>> Happy day after Labor Day.
>> For those of you that generate waste solvents in laboratories and
> collect wastes in satellite acumulation areas, how do you meet the
> requirements of OSHA 1910.106?
>> Do you ground the containers in SAA areas? How do you prevent or
> control problems associated with static electricity ?
>> Your response(s) will be much appreciated.
>> Dan Liberman
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