Check out Safety Emporium for your N95, N99, and face shield needs.
Date: Tue, 2 Nov 2010 13:50:17 -0400
Reply-To: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Alan McCartney <firesafeguy**At_Symbol_Here**GMAIL.COM>
Subject: Re: FW: Lab safety showers
In-Reply-To: <A22AEA28E740094F9C69038215C80388491788AA**At_Symbol_Here**Tesmail2.teledynees.local>
I might be mistaken, but the placement of the berm, will violate the life
safety code (and rleated bulding codes) regarding smooth, trip free walking
surfaces. I believe this limitation is 1/8".
On top of this, this triping hazard will directly compound & negatively
affect the worker's compensation exposure for the associated employees.
I would think that the this trumps the local water / sewer inspectors
request.
Alan
On Mon, Nov 1, 2010 at 9:18 AM, Williams, Mark wrote:
> Thank you for the citation, Rob!
>
> Mary, if you run across the letter of interpretation sometime in the
> future, would you post it here for us?
>
> Thanks
>
>
>
>
>
>
>
> Mark Williams
>
> Teledyne Energy Systems Inc.
>
> 38 Loveton Cr
>
> Sparks MD 21152
>
> 410-472-7733
>
> mark.williams**At_Symbol_Here**teledynees.com
>
>
> ------------------------------
>
> *From:* ILPI [mailto:info**At_Symbol_Here**ILPI.COM]
> *Sent:* Thursday, October 28, 2010 9:33 PM
>
> *Subject:* Re: Lab safety showers
>
>
>
> Excellent. With that lead from Mary, I was able to look up where shower
> water is apparently exempted:
> http://edocket.access.gpo.gov/cfr_2005/julqtr/40cfr261.3.htm
>
>
>
> Sec. 261.3 Definition of hazardous waste.
>
> (snip)
>
> *however, the following mixtures of solid wastes and hazardous wastes
> listed in subpart D of this part are not hazardous waste*s (except by
> application of paragraph (a)(2)(i) or (ii) of this section) if the genera
tor
> can demonstrate that the mixture consists of wastewater the discharge of
> which is subject to regulation under either section 402 or section 307(b)
of
> the Clean Water Act (including wastewater at facilities which have
> eliminated the discharge of wastewater) and;
>
> (snip)
>
>
>
> (D) A discarded commercial chemical product, or chemical intermediate
> listed in Sec. 261.33, arising from de minimis losses of these materials
> from manufacturing operations in which these materials are used as raw
> materials or are produced in the manufacturing process.
>
> For purposes of this paragraph (a)(2)(iv)(D), ``de minimis'' losses inclu
de
> those from normal material handling operations (e.g., spills from the
> unloading or transfer of materials from bins or other containers, leaks f
rom
> pipes, valves or other devices used to transfer materials); minor leaks o
f
> process equipment, storage tanks or containers; leaks from well maintaine
d
> pump packings and seals; sample purgings; relief device discharges; *disc
harges
> from safety showers and rinsing and cleaning of personal safety equipment
;
> * and rinsate from empty containers or from containers that are rendered
> empty by that rinsing; or
>
>
>
> (E) Wastewater resulting from laboratory operations containing toxic
> (T) wastes listed in subpart D of this part, Provided, That the annualize
d
> average flow of laboratory wastewater does not exceed one percent of tota
l
> wastewater flow into the headworks of the facility's
>
> wastewater treatment or pre-treatment system or provided the wastes,
> combined annualized average concentration does not exceed one part per
> million in the headworks of the facility's wastewater treatment or
> pre-treatment facility. Toxic (T) wastes used in laboratories that are
>
> demonstrated not to be discharged to wastewater are not to be included in
> this calculation; or.....
>
>
>
> Rob
>
>
>
> =======================
=========================
======
>
> Safety Emporium - Lab & Safety Supplies featuring brand names
>
> you know and trust. Visit us at http://www.SafetyEmporium.com
>
> esales**At_Symbol_Here**safetyemporium.com or toll-free: (866) 326-5412
>
> Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012
>
>
>
>
>
>
>
> On Oct 28, 2010, at 5:54 PM, Mary Cavanaugh wrote:
>
>
>
> I don=92t have time to dig it up right now, but there is an EPA letter
of
> interpretation that says that runoff from an emergency drench shower is n
ot
> hazardous waste. So containment is only necessary if your local POTW is
> requiring it.
>
>
>
> From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On
> Behalf Of Alan Hall
> Sent: Thursday, October 28, 2010 3:15 PM
>
> To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
> Subject: Re: [DCHAS-L] Lab safety showers
>
>
>
> I agree with Rob Torecki,
>
> This is a senseless regulation that would do much more harm than
> good, and presents a slip-and-fall hazard full time, not just when the
> emergency shower is in use.
>
> I also agree with how dilute most chemical splashes would be by the time
> you dilute them with 15 minutes **At_Symbol_Here** 20 gallons/minute = 300 gallons of wa
ter.
>
> Alan
> Alan H. Hall, M.D.
>
>
> Date: Thu, 28 Oct 2010 14:55:20 -0400
> From: info**At_Symbol_Here**ILPI.COM
> Subject: Re: [DCHAS-L] Lab safety showers
>
> To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
>
> Wow, thanks for sharing. That one is a poster child for Bad Regulations.
>
>
>
> 1. Let's say the berm encompasses a 4' x 4' area around the shower. That
's
> 16 square feet, one inch high, for a volume of 1.33 cubic feet = 10 gal
lons.
> Under ANSI Z358, showers must put out at least 20 gallons per minute. A
nd
> that shower is likely to flow for 5, if not 15 minutes. So the berm is
> essentially useless.
>
>
>
> Now, if the reg is calling for a berm that say, stretches across an entir
e
> hallway or doorway - heck, or just around the drain itself, that might wo
rk
> by flooding the rest of the building, as all it does is make the floor dr
ain
> non-functional. Plugging the floor drain permanently is an easier soluti
on.
>
>
>
> 2. The amount of hazardous material on a victim is going to be so
> exceedingly small and so diluted in the drains that it boggles the mind.
> Seriously - you get what, 10 mL of concentrated acid on you and that was
hes
> down the drain with 100 gallons of water? Yeesh. And if the stuff was
so
> nasty toxic that it is a hazard even that dilue, this city review departm
ent
> thinks it's better to spread the hazmat all over the building and down a
> couple floors onto various objects and people than it is to send it down
the
> drain.
>
>
>
> 3. When you're blinded by something and trying to find a shower on foot o
r
> on a wheelchair, even that 1" sloped bump is a barrier. And no doubt a t
rip
> hazard the rest of time no matter how well it's marked with floor tape.
>
>
>
> Rob Toreki
>
>
>
> =======================
=========================
======
>
> Safety Emporium - Lab & Safety Supplies featuring brand names
>
> you know and trust. Visit us at http://www.SafetyEmporium.com
>
> esales**At_Symbol_Here**safetyemporium.com or toll-free: (866) 326-5412
>
> Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ 08012
>
>
>
>
>
> On Oct 28, 2010, at 2:31 PM, Betsy Shelton wrote:
>
>
>
> I am currently involved in construction of two new laboratories and was
> instructed by the city commercial building review department to include a
1"
> high curb around the shower area to keep hazmat from entering the floor
> drain in the event of a spill. Also, the curb has to be sloped on both
> sides to allow accessibility.
>
> --
>
> Best regards,
>
> Betsy Shelton
> 512.636.1905
> retrosynthesis**At_Symbol_Here**gmail.com
>
>
>
>
>
> ______________________________________________________________________
> This e-mail has been scanned by MCI Managed Email Content Service, using
> Skeptic(tm) technology powered by MessageLabs. For more information on MC
I's
> Managed Email Content Service, visit http://www.mci.com.
> ______________________________________________________________________
>
I might be mistaken, but the placement of the berm, will violate the life s
afety code (and rleated bulding codes) regarding smooth, trip free walking
surfaces. I believe this limitation is 1/8".=A0
On top of this
, this triping hazard will directly compound & negatively affect the wo
rker's compensation exposure for the associated employees.
I would think that the this trumps the local water / sewer inspectors r
equest.
Alan
On Mon, Nov 1, 2010 a
t 9:18 AM, Williams, Mark
<Mark.Williams**At_Symbol_Here**teledynees.com> wrote:
Thank you fo
r the citation, Rob!
Mary<
/font>, if you run across the letter of
interpretation sometime in the future, would you post it here for us?
Thanks
=A0
Sec. 261.3 =A0Definition of hazardous wast
e.
however, the followi
ng mixtures of solid
wastes and hazardous wastes listed in subpart D of this part are not hazard
ous
wastes
(except by application of paragraph (a)(2)(i) or (ii) of this section) if t
he
generator can demonstrate that the mixture consists of wastewater the disch
arge
of which is subject to regulation under either section 402 or section 307(b
) of
the Clean Water Act (including wastewater at facilities which have eliminat
ed
the discharge of wastewater) and;
=A0=A0 (D) A discarded commercial chemical
product, or
chemical intermediate listed in Sec. 261.33, arising from de minimis losses
of
these materials from manufacturing operations in which these materials are
used
as raw materials or are produced in the manufacturing process.=A0
For purposes of this paragraph (a)(2)(iv)(
D), ``de minimis''
losses include those from normal material handling operations (e.g., spills
from the unloading or transfer of materials from bins or other containers,
leaks from pipes, valves or other devices used to transfer materials); mino
r
leaks of process equipment, storage tanks or containers; leaks from well
maintained pump packings and seals; sample purgings; relief device discharg
es; discharges from safety showers an
d rinsing and
cleaning of personal safety equipment; and rinsate from empty
containers or from containers that are rendered empty by that rinsing; or
=A0=A0 =A0(E) Wastewater resulting from la
boratory
operations containing toxic (T) wastes listed in subpart D of this part,
Provided, That the annualized average flow of laboratory wastewater does no
t
exceed one percent of total wastewater flow into the headworks of the
facility's=A0
wastewater treatment or pre-treatment syst
em or provided the
wastes, combined annualized average concentration does not exceed one part
per
million in the headworks of the facility's wastewater treatment or
pre-treatment facility. Toxic (T) wastes used in laboratories that are=A0
demonstrated not to be discharged to waste
water are not to
be included in this calculation; or.....
=A0=A0=========
=========================
====================<
/p>
Safety Emporium - Lab & Safety
Supplies featuring
brand names
Fax: (856) 553-6154,
PO Box 1003, Blackwood, NJ 08012
=A0
On Oct
28, 2010, at 5:54 PM,
Mary Cavanaugh wrote:
I don=92t have time to dig it up right now, but ther
e is an EPA letter of
interpretation that says that runoff from an emergency drench shower is not
hazardous waste.=A0 So containment is only necessary if your local POTW is
requiring it.=A0
I agree with Rob
Torecki,
=A0
This is a senseless regulation that would do much more harm than
good,=A0and=A0presents a slip-and-fall hazard full time, not just when
the emergency shower is in use.
=A0
I also agree with how dilute most chemical splashes would be by the time yo
u
dilute them with 15 minutes **At_Symbol_Here** 20 gallons/minute = 300=A0gallons of water.
=A0
Alan
Alan H. Hall, M.D.
=A0
Date:
Thu, 28 Oct 2010 14:55:20 -0400
From:=A0info**At_Symbol_Here**ILPI.COM
Subject: Re: [DCHAS-L] Lab safety showers
Wow, thanks for sharing. =A0That one is a poster chi
ld for Bad
Regulations.
1. Let's say the berm encompasses a 4' x 4&#
39; area around the shower.
=A0That's 16 square feet, one inch high, for a volume of 1.33 cubic fee
t =
10 gallons. =A0Under ANSI Z358,
showers must put out at least 20 gallons per minute. =A0And that shower is
likely to flow for 5, if not 15 minutes. =A0So the berm is essentially
useless.
Now, if the reg is calling for a berm that say, stre
tches across an
entire hallway or doorway - heck, or just around the drain itself, that mig
ht
work by flooding the rest of the building, as all it does is make the floor
drain non-functional. =A0Plugging the floor drain permanently is an easier
solution.
2. The amount of hazardous material on a victim is g
oing to be so
exceedingly small and so diluted in the drains that it boggles the mind.
=A0Seriously - you get what, 10 mL of concentrated acid on you and that
washes down the drain with 100 gallons of water? =A0 Yeesh. =A0And if the
stuff was so nasty toxic that it is a hazard even that dilue, this city rev
iew
department thinks it's better to spread the hazmat all over the buildin
g and
down a couple floors onto various objects and people than it is to send it
down
the drain.
3. When you're blinded by something and trying t
o find a shower on foot
or on a wheelchair, even that 1" sloped bump is a barrier. =A0And no
doubt a trip hazard the rest of time no matter how well it's marked wit
h floor
tape.
=A0=A0===============
=========================
==============
Safety Emporium - Lab & Safety Supplies featurin
g brand names
Fax: (856) 553-6154,
PO Box 1003, Blackwood, NJ 08012
On Oct
28, 2010, at 2:31 PM,
Betsy Shelton wrote:
I am
currently involved in construction of two new laboratories and was instruct
ed
by the city commercial building review department to include a 1" high
curb around the shower area to keep hazmat from entering the floor drain in
the
event of a spill.=A0 Also, the curb has to be sloped on both sides to allow
accessibility.
--=A0
______________________________________________________________________
This e-mail has been scanned by MCI Managed Email Content Service, using
Skeptic(tm) technology powered by MessageLabs. For more information on MCI&
#39;s
Managed Email Content Service, visit http://www.mci.com.
______________________________________________________________________
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