It’s time to get rid of the “Land Disposal Restriction” form
Mar21

It’s time to get rid of the “Land Disposal Restriction” form

I may have ranted about this a few times in the past 25 years or so… but why give up now? It is time to get rid of the Land Disposal Restriction (LDR) form. A little history: Back in 1984, when the Resource Conservation and Recovery Act (RCRA) was reauthorized, the Environmental Protection Agency (EPA) banned the land disposal of hazardous waste and created one of the most useless government-bureaucracy-wasteful forms ever in the process. Generators of hazardous waste, including laboratories, were required to complete a “notification” to their disposal facility telling them what kinds of waste they were providing and what could be done with it according to RCRA. A “one time only” notification is required for each waste stream; but for laboratories that means that each and every lab pack–a drum packed with smaller containers of chemicals–offered for disposal requires the completion of a non-standardized form which runs about 3 to 5 pages in length. Although the disposal facility’s permit already specifies what it is allowed to do, a waste generator still has to tell the facility how to handle the waste. Okay, maybe this form was useful for a year or two… I’ll give EPA 1984 and 1985. Now all the LDR notification does is waste money. Lots of it. If you assume, conservatively, that one million lab packs are shipped in the U.S. annually (the laboratory I handle has 25 employees and generates about 50 lab packs each year), and the completion of the form for each takes 5 minutes, that’s more than 83,000 manhours a year. With an average billing of a lab pack team (all sitting there either completing the forms or waiting for someone doing it) at about $100/hour, that’s more than $8 million annually that U.S. labs are spending to comply with LDR. I’ve been trying to get rid of this requirement since 1990, 22 years ago. To take my math a step further, it’s quite likely that U.S. labs have spent well over $100 million complying with this law since 1990. Efforts (not just my own) to implore EPA to get rid of LDR have included repeated petitioning, complaints at EPA public hearings, and meetings with EPA and congressional staff. So why doesn’t EPA get rid of the forms?  Probably because EPA thinks it has bigger fish to fry. EPA estimated in the early 1990s that laboratory waste represents less than 1 tenth of 1 percent of all hazardous waste, so pretty much any regulatory effort that comes along is going to be aimed at the other 99.9%. If you agree with me, say so. If you can find any reasonable justification for...

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Developing laboratory safety certification
Feb16

Developing laboratory safety certification

Responding to a request from several former ACS presidents, the ACS Division of Chemical Health & Safety is attempting to develop an online laboratory safety certification program aimed at chemistry graduate students. The program ideally would address longstanding complaints from industry that Ph.D. programs do not adequately educate students to work safely in industrial research and development laboratories. A well-planned and peer-reviewed online certification program could be part of the solution to this training gap. The development cost for online training programs, according to an informal survey of commercial online training providers, is approximately $20,000 for each presentation hour of this type of safety course. This means that developing an 8- to 10-hour course with about a dozen training modules would cost $160,000 to $200,000. The division is now facing the following questions and would welcome input from Safety Zone readers: How might costs be lowered? What work could be done by volunteers rather than paid consultants? Does ACS have the resources to develop the program without using a training provider? Several organizations are willing to support program development: the ACS Corporate Associates, National Academy of Sciences, National Research Council, and Council for Chemical Research. Are there others that might be interested? Is there sufficient demand to warrant developing the program? Can it meet industry’s needs? What topics should be covered, and what is a realistic amount of time to commit for effective training? Is taking an online course and passing tests sufficient for certification or should there be other components? Related post: Teaching safety to chemical...

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Chemical Safety at the ACS Southwest Regional Meeting
Nov17

Chemical Safety at the ACS Southwest Regional Meeting

The ACS Southwest Regional Meeting in Austin last week featured a wide-ranging program that included a strong focus on chemical safety. I presented two workshops on “Laboratory Waste Management” and “How to be an effective chemical hygiene officer,” and there was also a half-day session on “Recent Advances in Chemical Safety” that was well attended. Of particular interest in the symposium was a talk by Ephraim Massawe, a professor of computer science and industrial technology at Southestern Louisiana University, on a subject I had never really thought about but has wide-ranging implications: “Nanoinformatics for nanoscale chemistry and nanotechnology: Opportunities for preventing occupational exposures in nanoenabled remediation.” While most discussion of nanomaterial safety focuses on air exposures, Massawe pointed out that there are safety considerations for environmental remediation of Superfund and other abandoned waste sites using slurries containing iron, silver, and other metal-based nanomaterials. Obviously, the  surface area advantages of nanomaterials present many opportunities in the remedial field, and evidence suggests there have been a number of successful applications. The costs, according to data Massawe presented, are significantly lower than traditional pump and treat and other common technologies.  Since there is so little real toxicological data available for nanomaterials in general, and most of what is available is focused on air exposure, what are the implications of application to injection wells? Is there potential for adverse impact on groundwater supplies? Are aquifers at risk or is the earth capable of filtering these materials when in liquid form as a slurry? It was an interesting talk and clearly there are challenges for those keeping an eye on the safety of nanomaterials. A big Texas shout-out should go to Texas State University, San Marcos, chemistry professor Linette Watkins and Applied Nanotech safety officer Betsy Shelton for a very successful regional meeting that attracted over 1100 registrants. A special treat was hearing Nobel Laureate Robert Curl from Rice University tell the story behind the discovery of fullerenes, aka “Bucky balls” (and why that’s the common name for C<sub>60</sub> instead of soccerenes or...

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CSB report on Texas Tech includes recommendation for ACS action
Oct19

CSB report on Texas Tech includes recommendation for ACS action

The U.S. Chemical Hazard & Safety Investigation Board today released its report on its investigation into the explosion at Texas Tech University nearly two years ago. While the nature of the problems at Texas Tech have been well documented previously, today’s CSB webinar enabled the attendee to get an overall picture from several perspectives. As the Texas Tech Director of Communications noted, it was a “disturbing, poignant presentation” that essentially pointed out that the organizational structure prevented any chance of effectively protecting students. Overall, I thought the webinar was well organized, and while I’ve heard some disappointment that no new material was presented, one thing that was clearly new was the recommendations made to Texas Tech, the Occupational Safety & Health Administration (OSHA), and the American Chemical Society. While I am not completely versed on previous CSB reports, I was struck by the directive to ACS to create hazard guidance and evaluation tools. Specifically, the report recommended that ACS “Develop good practice guidance that identifies and describes methodologies to assess and control hazards that can be used successfully in a research laboratory.” So how should ACS proceed? And is there enough consistency in how research institutions address safety to suggest that one size fits all? How do university environmental health and safety (EH&S) offices and staff fit in? As several institutions have noted, there is great variance in the organizational structure of university safety programs, and many EH&S offices have better working relationships (authority, resources, sufficient staff) with research groups than others where safety is not taken as seriously....

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To certify or not to certify
Sep27

To certify or not to certify

Safety professionals who want to document their experience and skills have many options for professional certification. The Board of Certified Safety Professionals alone lists seven different programs, from the Certified Safety Professional to the Safety Trained Supervisor. Other organizations providing such programs include the World Safety Organization (17 different certifications), the National Association of Safety Professionals (a mind-boggling 50 programs), and the Board of Environmental, Health & Safety Auditors (just one, but in various specialties). I haven’t even mentioned venerable programs like the Certified Industrial Hygienist, which certainly requires some safety expertise. And how about the Polevault Safety Certification Board, for coaches and participants? Oh, wait, I’m supposed to focus on chemical safety here. For those specializing in laboratory safety, the best known certification may well be the Certified Chemical Hygiene Officer (CHO) program, offered by the National Registry of Certified Chemists (NRCC). The NRCC is heavily supported by the American Chemical Society, and the CHO certification is by far the most popular of its seven programs for chemists. Effective October 1, I will be taking over as executive director of the NRCC from long-time Director Gilbert Smith. With this alphabet soup of choices, where should a chemical safety professional go for certification, and is it worth the effort? First, I’ll say a qualified yes that it can be a good idea. Some states have certification requirements for certain positions. Some employers require or “prefer” certification as a condition of employment. These requirements may apply only to one certification program, or several may be listed as meeting criteria. Anyone in a job search for a chemical safety career should certainly consider becoming certified in at least a specialty field, if for no other reason than to have his or her resume stand out from the crowd. On the downside, some of these certifications are expensive to achieve and maintain. Many if not all require continuing education in order to maintain certification, and there are fees for application, testing, and renewal.  I’m interested in how our readers feel about this – has certification been of value to you? Is it required for your job? Is it worth the...

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