SCIENCE DIVISION SAFETY PLAN Part 2

3. Staff Training Program.

The program for handling hazardous chemicals will be presented to the Science Division staff (including teaching assistants) who may be exposed to hazardous chemicals in the normal course of employment, or who are likely to be exposed to hazardous chemicals in the event of an emergency. A video provided by Labelmaster will be used to explain the HMIS hazard label system, and an explanation of MSDS content and location will be offered. The use of appropriate personal protective equipment for specific types of chemicals will be emphasized. The employees will be informed of their right to obtain information on hazardous chemicals with which they may come into contact during their normal employment activity, and the manner in which such information can be obtained (specifically, from the MSDS on file, or from Michigan Department of Public Health, Division of Occupational Health, 3500 North Logan Street, Lansing, MI 48906, Phone #(517)335-8250, or Michigan Department of Labor, 7150 Harris Drive, Lansing, MI 48909).

The MSDS will be explained, with the various categories of information pointed out and interpretations presented. Institutional policies regarding laboratory activity will be reviewed, and emergency procedures regarding accidental exposure to hazardous materials or medical emergencies will be presented. All staff, including faculty, are expected to participate in this training. All participants will sign, date, and list their social security numbers in a register which will be kept on file to document their participation. After the initial presentations to the existing staff, opportunities for training sessions will be offered during the first two weeks of each Fall and Spring semester. The chairperson of the Science Division Safety Committee, or his/her designate, will be responsible for scheduling, planning, and conducting these training sessions.

4. Outside Contracting Notification.

In the event that outside contractors are scheduled to work within the Science Building, they have the right to request a list of hazardous materials housed in the location of their work. The Quattro Pro program listing of Hazardous Materials will be used to construct such an inventory for the rooms involved. Also, a request may be made of the contractors to list the hazardous materials which they will bring into the area for their use during the construction. This request may be made by any staff member so interested, and will be channeled through the Safety Committee. The Safety Committee will thus serve as the intermediary between outside contractors and the staff.

HAZARDOUS WASTE CONCERNS

In November, 1984, the Federal Hazardous and Solid Waste Amendments modified the Resource Conservation and Recovery Act to include colleges and universities as being responsible for proper disposal of the hazardous waste which they generate. Waste material is characterized as being in one of three categories:
  1. acutely hazardous: This category includes material which is fatal to humans in low doses, and is specifically listed in 40 CFR 261.33 (e) (CFR refers to the Code of Federal Regulations, a holding which is available in the Government Documents section of the library at Calvin College). The list supersedes Environmental Protection Agency (EPA) listings, and is more inclusive.
  2. hazardous: Materials in this category would include those with characteristics of ignitibility, corrosivity, reactivity, or those containing low doses of substances deemed acutely hazardous. The listing is in 40 CFR 261.33 (f).
  3. non-hazardous: Materials not listed in the above categories are considered non-hazardous. All solid biological and chemical waste and discarded liquids and gases in containers (e.g., aerosol cans) fall into this category, and must be disposed of using facilities having a permit to treat and dispose of wastes in a manner which does not pollute the environment.
The EPA has established three classes of waste generators:
  1. Conditionally Exempt Small Quantity Generators (40 CFR 261.5) are those organizations which generate less than 100 Kg per month hazardous waste.
  2. Small Quantity Generators (40 CFR 260.10) are those organizations which generate 100 to 1000 Kg per month hazardous waste. Organizations in this category are required to notify the EPA of their activities and to be licensed by the EPA.
  3. Large Quantity Generators are those organizations which produce more than 1000 Kg per month hazardous waste. These also require EPA licensing and oversight.
Calvin College is currently classified as a Small Quantity Generator, and has received an EPA license (ID #MIG 000007234). While the quantities of hazardous waste generated by the Science Division is far less than 100 Kg per month, this rating is for the entire Calvin community. The amounts of waste generated across campus is not known, but estimates indicate that the total amount generated averages less than 100 Kg per month, so the present rating appears appropriate. The Small Quantity Generator rating obligates the College to follow more stringent regulations regarding the storage and disposal of the hazardous waste than those for the Conditionally Exempt Small Quantity Generators. This area of regulation can best be divided into three sections: 1. the on-site storage and handling of the waste, 2. the transportation of the waste to a disposal site, and 3. the method of disposal and the suitability of the disposal site.

1. On-site storage. Detailed storage regulations requiring a special permit take effect after on-site storage of acutely hazardous waste exceeds 1.0 Kg or if the hazardous waste exceeds 1000 Kg per month. Since the accumulation within the Science Division lies well below these quantities, the special provisions do not apply. Regulations allow small quantity generators to keep 1000 Kg of waste for up to 180 days without a special permit. The amount of hazardous waste generated by the Science Division varies, but is not expected to exceed 250 Kg per year. The amount generated by the remainder of the campus is not known, but should be quantified by some level of administration to ensure compliance with the applicable regulations since they are enforced on an institution wide basis.

Storage of these hazardous chemicals should be in heavy duty plastic containers or metal safety cans (to eliminate the possibility of spills due to breakage of glass containers), with the size of the container depending on the volume of waste generated. The waste should be segregated into the following categories:

  1. halogenated solvents
  2. non-halogenated solvents
  3. aqueous solutions of mixtures of compounds not listed elsewhere
  4. organic solids
  5. inorganic solids
  6. reactives
Dilute acids and bases can be washed down the sink with copious water flow after they have been neutralized to a less extreme pH. Small amounts of organic solids can be disposed of in the organic solvent container, and inorganic solids in the aquaeous solution container. Solvents and waste solvents should be housed in approved containers stored in exhaust fume hoods or in acid-base cabinets. Concentrated acids and bases should be housed in fume hoods or in acid or base cabinets. The containers should be clearly labeled with the nature of the contents and with an appropriately marked HMIS label. Once a container is filled, it should be transferred to the solvent storage room in the Science Building basement until transportation is arranged to a disposal site. A shipping date will be scheduled at least once per year, preferably in the Spring, to remove all of the stored hazardous materials.

2. Transportation of hazardous waste. The generator of hazardous waste is responsible for tracking the waste until it reaches the ultimate disposal site. An EPA license is required to transport hazardous waste, and the shipping manifests issued by the licensed transporter must be kept in perpetuity by the generator. Since the disposal site utilized by Calvin College (see below) is also a licensed transporter, a single manifest is issued and must be retained in perpetuity.

3. Disposal of hazardous waste. The disposal service utilized by Calvin College is:

Drug & Laboratory Disposal, Inc.
P.O. Box 148
331 Broad Street
Plainwell, MI 49080 (616)685-9824

Since the company provides service as both transporter and disposal facility, only one manifest is required. Drug & Laboratory Disposal, Inc. has EPA licenses for both transporting (ID# MID092947928) and disposal (ID# MID059695452). Most of the waste materials are incinerated by Drug & Laboratory Disposal using environmentally sound methods and equipment. To arrange for disposal, a list of types and volumes of hazardous materials must be submitted in writing to the disposal company, and the company will schedule a pickup. The materials must be in disposable containers, or the company will supply containers and transfer the contents of our storage containers to theirs, charging a flat rate charge for the time required for the transfer. The company must be notified in advance of the volume of containers needed to insure that adequate containers are available for the transfer. All hazardous materials are to be disposed of in this manner.

Preserved Biological materials are not classified as hazardous material, not even those preserved with a formalin solution. The formalin solution used for preserving laboratory specimens is only 1.8 parts of 37% formaldehyde per 100 parts of solution. Although formaldehyde is classified as a hazardous substance, the unregulated disposal is allowed because of the low concentration. Excess formalin solution packed with the animals can be washed down the sink, again because of the low concentration of formaldehyde. All material contaminated with human blood or other biological fluids, and all microbiological contaminated material must be autoclaved with a minimum of 121oC and 15 psi pressure for a minimum of 15 minutes. If the material does not contain a hazardous substance, it can then be disposed of in an unregulated manner.

While not deemed hazardous, the carcasses of animals used in laboratory investigation are classified as medical waste, and are now to be disposed of by using Valley City Refuse Disposal service (address below), calling them in advance to arrange each pickup.

Valley City Refuse Disposal, Inc.
1040 Market SW
Grand Rapids, MI 49503-4893
phone # 235-1500

SAFETY IN THE TEACHING LABORATORY

As a teaching institution, Calvin College is responsible for maintaining the safety of its students involved in laboratory study. This responsibility includes designing laboratory experiments which are not inherently dangerous or for which proper safety guards or procedures are available and are utilized, emphasizing proper procedure for handling hazardous materials and emergency procedures to follow in the event of a laboratory accident, and for oversight of the laboratory situation even after safety concerns are expressed and proper procedures are outlined.

The role of the instructor. The instructor in the teaching laboratory represents the college and is therefore responsible for the activity which occurs in the laboratory. The role of the instructor is further defined in the paragraphs below.

The instructor is responsible to teach good safety procedures and rules. The most effective method of teaching is often by example, so it is imperative that the instructors utilize model techniques and procedures in the laboratory - it is part of the job. Also, it should be made clear to the students that the topic of safety is not just an afterthought, or something which is mentioned at the beginning of the semester and then overlooked or forgotten. Besides good technique, the use of emergency equipment should be demonstrated, and the location of eyewash stations, fire extinguishers and blankets, and safety showers should be pointed out repeatedly. In order to further emphasize the importance of safety, it may be a good idea to include safety material pertaining to the experiments on any quizzes or laboratory reports required of the students. Good techniques learned early on in their laboratory experience will follow the students throughout their schooling and professional careers; bad techniques will do likewise.

The instructor must also enforce the rules which are applicable in each laboratory session. If the students feel that the instructor is ambivalent about the rules, shortcuts will be attempted and safety will be compromised. The activity of students left unattended for any period of time beyond short breaks remains the responsibility of the staff member in charge of the laboratory. There are legal precedents in which the instructor of a laboratory was held responsible for the injuries received by students involved in clearly unauthorized behavior while left unattended in a regularly scheduled laboratory period. It is therefore in the instructor's own best interests to maintain supervision of the lab. If lab assistants are utilized, they may be left in charge for part of the laboratory period, but the responsibility ultimately remains with the instructor.

It is the responsibility of the instructor to maintain the equipment and supplies in good operating order. Using faulty equipment which may present a safety hazard is strictly forbidden. The importance of completing a particular lab exercise on time pales in comparison to the injuries which may result from using faulty equipment.

Finally, it is also necessary for the instructor to utilize good judgement in teaching. Where specific safety procedures are not mandated or are not listed, it is up to the instructor to insist upon safe and reliable techniques in the performance of the laboratory exercise.

Laboratory safety requirements. In order to maintain a safe environment for the students in the laboratory, consideration should be given to various aspects of safety in the individual laboratory rooms. These issues are addressed in the paragraphs below.

Eyewash stations should be present in each laboratory in which caustic solutions or organic solvents are used. The use of the stations should be demonstrated by the instructor at the beginning of each semester. The eyewash bottles used in some laboratories should have their volumes checked on a monthly basis, and the contents should be removed and the bottles washed and refilled on a semiannual basis. The faucet mounted eyewash stations should be tested on a yearly basis.

Medical first aid kits should be available in each department. The contents of each kit should include at least the following:

The kits will be checked monthly and restocked, if necessary by the Science building Custodial supervisor. Individual items will be replaced when broken torn, cracked, opened, or missing. The expiration date on the crimp of the antibiotic ointment tube will be checked.

In laboratory experiments in which hazardous solutions are used by anyone in the room, or in which potentially explosive materials are used, eyewear protection should be worn. The protection should be, minimally, safety glasses with side shields. Better protection is afforded by goggles with hooded ventilation or by face shields. Each exhaust fume hood shall have stored near it safety splash goggles and a protective apron for use by anyone who uses the hood. If undiluted hazardous chemicals are to be removed from the hood, suitable protective gear should be worn for the duration of the time the person is dealing with the material. For general laboratory work, no open-topped shoes are allowed, and the wearing of long pants is strongly encouraged.

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