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New England Universities Laboratories
XL Proposal
Proposed Laboratory Environmental Management Standard
January 30, 1998
A. Scope and Application: This standard applies to all workplaces
engaged in the laboratory use of hazardous chemicals as defined below:
1. Where this standard applies, it shall supersede, within the laboratory,
the requirements of 40 CFR Parts 260 through 265, and parts 270, 271 and
124 of Chapter I of 40 CFR.
2. This standard shall not supersede any other legal requirements, including, but not limited to, OSHA, Fire Codes or other legal requirements applicable to laboratories
B. Definitions
"Benchtop Treatment" means the final step in an experimental protocol
in which a researcher may eliminate or minimize the hazardous properties
of the hazardous substance in the laboratory process.
"Chemical Hygiene Plan" (CHP) means a written program developed and implemented
by the employer which sets forth procedures, equipment, personal protective
equipment and work practices that are capable of protecting employees
from the health hazards presented by hazardous chemicals used in the particular
workplace and meets the requirements as defined in 29 CFR 1910.1450.
"Emergency" means any occurrence such as, but not limited to, equipment
failure, rupture of containers or failure of control equipment which results
in a potential uncontrolled release of a hazardous chemical to the environment
which may require notification and reporting.
"Environmental Management Officer" means an employee or individual who
is designated by the organization, and who is technically qualified by
training or experience, to i) provide guidance in the development and
implementation of the Environmental Management Plan, and ii) is responsible
for overseeing implementation of the Environmental Management Plan within
the organization. This definition is not intended to place limitations
on the position description or job classification that the designated
individual shall hold within the employer=s organizational structure.
"Environmental Management Plan" means a written program developed and
implemented by the organization which sets forth procedures, responsibilities,
pollution control equipment, performance criteria, resources and work
practices that (i) are capable of protecting human health and the environment
from the hazards presented by laboratory process byproducts within the
LPU (ii) meets the plan requirements defined elsewhere in this standard.
Certain requirements of this plan are satisfied through the use of the
Chemical Hygiene Plan, or equivalent, and other relevant plans (e.g.,
waste minimization plan). The Environmental Management Plan may be integrated
into such existing plans, incorporated as an attachment, or developed
as a separate document.
"Environmental Management System" (EMS) means the part of an organization's
management system that includes organizational structure, planning activities,
responsibilities, practices, procedures, processes and resources for developing,
implementing and maintaining the environmental requirements of the organization.
A"Environmental Performance" means results of the data collected pursuant
to implementation of the Environmental Management Plan as measured against
policy, objectives and targets.
"Environmental Performance Indicator" means a specific criteria that provides
information about the organization's environmental performance.
"Environmental Objective" means an overall environmental goal of the organization
which is verifiable.
"Environmental Target" means an environmental performance requirement
of the organization which is quantifiable, where practicable, verifiable
and designed to be achieved within a specified time frame.
"Hazardous Chemical" means a chemical for which there is statistically
significant evidence based on at least one study conducted in accordance
with established scientific principles that acute or chronic health effects
may occur in exposed employees. The term "health hazard" includes chemicals
which are carcinogens, toxic or highly toxic agents, reproductive toxins,
irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins,
agents which act on the hematopoietic systems, and agents which damage
the lungs, skin, eyes or mucous membranes.
A"Hazardous Substance" mean: i) any material that poses a threat to human
health and/or the environment (Typical hazardous substances are toxic,
corrosive, ignitable, explosive or chemically reactive.) and ii) any substance
designated by EPA to be reported if a specified quantity of the substance
is spilled in the waters of the United States or if otherwise released
into the environment.
"Hazardous Waste" means a hazardous waste as defined in Section 261.3
of the Resource Conservation and Recovery Act. It is a subset of hazardous
materials as defined by the Department of Transportation.
"Laboratory" means, for the purpose of this standard, an area within a
facility where the "laboratory use of hazardous chemicals" occurs. It
is a workplace where relatively small quantities of hazardous chemicals
are used on a non-production basis.
"Laboratory Process Byproduct" means a hazardous substance that results
from a laboratory experimental process. Waste determinations of such byproducts
are conducted after the substance exits the LPU.
"Laboratory Process Unit" (LPU) means a laboratory room, or group of laboratory
rooms, within a building, that is managed by a laboratory supervisor and
which share to a significant degree equipment, materials and/or personnel.
"Laboratory Scale" means work with substances in which the containers
used for reactions, transfers and other handling of substances are designed
to be easily and safely manipulated by one person. "Laboratory scale"
excludes those workplaces whose function is to produce commercial quantities
of materials.
"Laboratory Supervisor" means an individual assigned by the organization
to manage LPU activities in accordance with the Environmental Management
Plan.
"Laboratory Use of Hazardous Chemicals" means handling or use of such
chemicals in which all of the following conditions are met: (i) chemical
manipulations are carried out on a "laboratory scale;" (ii) chemical procedures
or chemicals are used; (iii) the procedures involved are not part of a
production process, nor in any way simulate a production process; and
(iv) "Protective laboratory practices and equipment" are available and
in common use to minimize the potential for employee exposure to hazardous
chemicals.
"Laboratory Worker" means a person who is assigned to handle hazardous
chemicals in the laboratory.
"Legal and Other Requirements" means requirements imposed by, or as a
result of, governmental permits, governmental laws and regulations, judicial
and administrative enforcement orders, non-governmental legally enforceable
contracts, research grants and agreements, certification specifications,
formal voluntary commitments and organizational policies and standards.
"Nonconformance" means, for the purposes of this standard, activity, behavior
or work practices that do not conform to the requirements of the Environmental
Management Plan.
"Organization" means institution, company, corporation, firm, enterprise
or authority or part or combination thereof, whether incorporated or not,
public or private, that has its own functions and administration.
"Protective laboratory practices and equipment" means those laboratory
procedures, practices and equipment accepted by laboratory health and
safety experts as effective, or that the organization can show to be effective,
in minimizing the potential for employee exposure to hazardous chemicals.
"Senior Management" means senior personnel with overall responsibility,
authority and accountability for managing laboratory activities within
the organization.
"Small Scale Treatment" means the treatment of single or aggregated laboratory
process byproducts which, under no circumstances, shall exceed 55 gallons
or equivalent weight.
"Waste Minimization" means practices and measures that minimize waste
including, but not limited to, source reduction, reuse, recycling and
bench-top treatment of laboratory process by-products or small scale treatment
of hazardous wastes.
C. Hazardous Waste Management
An organization affected by this standard will manage the disposal of
hazardous wastes in accordance with RCRA regulations. In addition, waste
materials which are determined to pose significant hazards will be similarly
managed, even if they are not explicitly covered by RCRA.
D. Organizational Responsibilities
Under the requirements of this standard, the organization shall be responsible
for the following:
1. Developing and overseeing implementation of the Environmental Management Plan.
2. Defining Laboratory Process Units (LPUs) and applicable thresholds below which LPUs would not be required to meet the requirements of Section D of this standard
3. Ensuring that a laboratory supervisor is assigned responsibility in each LPU for conformance to the Environmental Management Plan.
4. Determining whether laboratory process byproducts or unused hazardous virgin chemicals are to be managed, after exiting the LPU, as solid and hazardous wastes.
5. Defining annual environmental program objectives and targets.
6. Developing, implementing and maintaining policies, procedures and practices governing the organization's compliance with applicable Resource Conservation and Recovery Act, and state equivalent laws and regulations.
7. Developing and implementing procedures to monitor and measure relevant conformance and environmental performance data for the purpose of supporting continuous improvement of the environmental management system.
8. Assuring that employees or designated personnel handling hazardous waste receive appropriate training.
9. Developing, implementing and maintaining policies and procedures for managing environmental documents and records in accordance with legal and other requirements.
10. Ensuring that the Environmental Management Plan is reviewed at least annually by senior management to ensure its continuing suitability, adequacy and effectiveness. The reviews may include, but not be limited to, a consideration of monitoring and measuring information, EMS performance data, assessment and audit results and other relevant information and data.
E. Environmental Management Plan - General
(Appendices provide performance criteria to assist organizations in the
development and implementation of an effective Environmental Management
Plan. Appendices A and B are currently drafted as minimum performance
criteria. Recommended guidance is found in "Prudent Practices in the
Laboratory: Handling and Disposal of Chemicals." National Research
Council, 1995)
LPUs covered by this standard shall implement the provisions of a written
Environmental Management Plan.
1. The Environmental Management Plan shall be readily available to individuals in the LPU, including laboratory workers, vendors, employee representatives, visitors, on-site contractors and, upon request, to governmental representatives.
2. The Environmental Management Plan shall be implemented in each LPU which produces byproducts that present significant health or environmental risks, based upon a risk analysis performed by the Environmental Management Officer.
3. The Environmental Management Plan shall include each of the following elements and shall indicate specific measures that each LPU and the organization will take to protect human health and the environment from hazards associated with the management of laboratory process byproducts and from the reuse, recycling or disposal of such byproducts outside the LPU.
a. An environmental or environmental, health and safety policy, signed by the organization's senior management, which shall include commitments to regulatory compliance, waste minimization, risk reduction and continual improvement of the EMS.
b. An assignment of roles and responsibilities for the implementation and maintenance of the Environmental Management Plan, including the designation of an Environmental Management Officer.
c. The organization's system for identifying and tracking legal and other requirements applicable to LPUs, including the procedures for providing updates to laboratory supervisors.
d. Criteria for the identification of chemical hazards and the control measures to reduce the potential for releases of laboratory process byproducts in the LPU, including engineering controls, the use of personal protective equipment and hygiene practices, containment strategies and other control measures.
f. A waste minimization plan, including a program whose goal is to reduce the volume and toxicity of laboratory process byproducts and minimize the accumulation and disposal of unused hazardous chemicals.
g. The organization's system for conducting periodic hazardous chemical surveys in the LPU.
h. The procedures for conducting laboratory decommissioning with regard to the safe disposal of hazardous chemicals.
i. The criteria that laboratory workers shall comply with for managing, containing and labeling laboratory process byproducts that accumulate in the LPU.
j. Special container or labeling circumstances, such as the aggregation of laboratory process byproducts into larger secondary containers (e.g., boxes, bottles, test tube racks) with other compatible by-product material and the labeling of the secondary containment.
k. The procedures relevant to the timely removal of laboratory process byproducts from the LPU for the purpose of waste determination and reuse, recycling or disposal.
l. A requirement that fume hoods and other protective or control equipment are functioning properly and specific measures that shall be taken to ensure proper and adequate performance of such equipment.
m. The emergency preparedness and response procedures, including facility and locality information, evacuation, notification, response management, incident documentation and training.
n. Provisions for information dissemination and training, as defined elsewhere in this document.
o. The circumstances under which a particular LPU operation, procedure or activity shall require prior approval from the organization's environmental professional staff or its designee.
p. The procedures for the development and approval of changes to the Environmental Management Plan.
q. The criteria governing the transportation of laboratory process byproducts to an accumulation or storage area for waste determination.
r. The procedures for inspecting the LPU to assess conformance with the requirements of the Environmental Management Plan.
s. The procedures for the identification of EMS nonconformance and the assignment of responsibility, timelines and corrective actions to prevent their reoccurrence.
t. The procedures governing benchtop and small-scale treatment to reduce the quantity and hazardous properties of laboratory process byproducts under prescribed, approved conditions which are based upon accepted practices as outlined in Prudent Practices in the Laboratory, or identified in other technical, peer-reviewed sources. (See Appendix B for small-scale performance criteria.)
u. Special provisions for managing and accumulating "P" and "U" or other difficult to dispose of wastes in a safe and cost-effective manner. (Note: Laboratory process byproducts are not P or U wastes)
v. The recordkeeping requirements to demonstrate compliance with applicable legal and other requirements.
F. Information and Training
The organization shall provide laboratory workers with information and
training to ensure that they are knowledgeable of the relevant elements
of the Environmental Management Plan.
1. Such information shall be provided at the time of a laboratory worker's
initial assignment to a work area where laboratory process byproducts
may exist. Retraining will occur when new substances are brought into
the area and as frequently as needed to maintain knowledge of procedures
of the environmental management plan.
2. Laboratory workers shall be informed of:
a. The contents of this standard and its appendices.
b. The location and availability of the organization's Environmental Management
Plan
c. Emergency response measures
d. Signs and indicators of a hazardous substance release
e. The location and availability of known reference materials relevant
to implementation of the Environmental Management Plan
f. Applicable environmental training requirements
3. Laboratory worker training shall include:
a. Methods and observations that may be used to detect the presence or release of a hazardous substance (such as monitoring conducted by the organization, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released)
b. The chemical hazards associated with laboratory process byproducts in their work area.
c. The relevant measures employees can take to protect human health and the environment
d. Applicable details of the Environmental Management
Plan
1. LPU visitors
a. LPU visitors, such as on-site contractors or environmental vendors, that require information and training under this standard will be identified in the Environmental Management Plan.
b. LPU visitors identified in the Environmental Plan will be informed of the existence and location of the Environmental Management Plan
c. LPU visitors identified in the Environmental Plan will be informed of relevant policies, procedures or work practices to ensure conformance to the requirements of the Environmental Management Plan
Appendix A. Environmental Management Plan Minimal Performance Criteria
The following performance criteria shall be incorporate into an organization's
Environmental Management Plan.
1. Each laboratory process byproduct or secondary container shall be labeled
or tagged with the chemical name, hazard warning and dated when byproduct
is first accumulated and the date when the chemical container is full.
2. Containers of laboratory process byproducts shall be closed at all times, except when byproducts are being added to or removed from the container, or under appropriate circumstances approved by the organization, in accordance with the Environmental Management Plan
3. The volumes of laboratory process by-products shall be minimized, but in no case shall a single process byproduct accumulate in the LPU in excess of 55 gallons, or weight equivalent.
4. Upon completion of the laboratory process, a full container of a single laboratory process by-product shall not remain in the LPU in excess of 20 business days.
5. An area or areas within the LPU shall be designated for accumulation of laboratory process byproducts.
6. Laboratory process byproducts which are transported on public roadways to a central accumulation or storage area for waste determination shall, if and to the extent applicable, conform to applicable Department of Transportation regulations regarding marking, placarding, packaging and labeling.
7. Volumes of laboratory process byproducts, transported within and from an LPU, greater than the following quantities shall require non-breakable secondary containment at all times: 4 liters for glass containers; 10 liters for plastic containers; and 15 liters for metal containers.
8. Areas designated for the accumulation of laboratory process byproducts shall be inspected periodically in conformance with the Environmental Management Plan.
9. The discharge of laboratory process byproducts to the sewer system shall be strictly controlled in accordance with legal [regulatory and local limits] and other requirements.
10. Emergency notification information and evacuation procedures shall be visible in each laboratory room.
11. Each LPU shall have spill response equipment or implement procedures for emergency response appropriate to the hazards in the laboratory.
12. All hazardous chemical spills, exposures and other incidents that trigger notification shall be investigated and the review documented.
Appendix B Small-Scale Treatment
Small-scale treatment to reduce the hazard [and/or volume] of hazardous
materials may be performed, under prescribed, approved conditions, by
trained and qualified professionals.
General Treatment Standards
- Treatment methods shall not result in the release of hazardous constituents into the land, air and water which are prohibited or in excess of the regulatory limits.
- Treatment methods shall be designed to minimize any hazard that could result in an explosion, fire or the generation of airborne toxic constituents.
- Management of hazardous materials shall conform with all applicable environmental, health and safety requirements and the standards, plans and procedures articulated by the institution/organization.
Small Scale Treatment Performance Criteria
1. Small scale treatment may be conducted only following a waste analysis and determination by the organization.
2. A procedure shall be developed, implemented and maintained for the small scale treatment of hazardous waste.
3. A treatment plan shall be developed and implemented for each small scale treatment of waste and include, but not be limited to, treatment protocol, environmental, heath and safety controls, security measures, monitoring and measuring, container management and specific emergency preparedness and response measures.
4. Eligibility for small scale treatment shall be first reviewed for approval/disapproval by Environmental, Health and Safety (EHS) professionals who are competent on the basis of education, training and experience.
5. Small scale treatment protocols and procedures shall be reviewed by an organizational treatment committee including, but not limited to, EHS professionals, management, laboratory workers and interested parties, including community members.
6. Small scale quantities of hazardous materials collected and aggregated from LPUs in a central area shall be treated only by trained and qualified professionals.
7. Criteria shall be specified to define trained and qualified professionals under this standard.
8. Approved treatment shall occur within time periods specified by RCRA, and corresponding state regulations, for the accumulation and storage of hazardous waste.
9. Residuals remaining after treatment shall be subject to hazardous waste determination.
10. The quantities of all hazardous materials and wastes before and after treatment shall be recorded and the records maintained for a period of three years.
11. A list of pre-approved small scale treatment protocols shall be maintained and updated as appropriate.
12. Treatment shall be based upon accepted practices as outlined in "Prudent Practices," protocols included in the Environmental Management Plan or identified in other technical, peer-reviewed sources (to be documented).
13. Quantities for treatment shall not exceed 55 gallons, or weight equivalent.
14. Treatment methodologies and competencies shall be shared with LPUs, other institutions and organizations with laboratory activities.
15. All small scale treatment shall require notification to EHS and be documented.