Managing Waste Chemicals for Disposal

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• Managing Waste Chemicals for Disposal

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Purpose Content

• Define the process for managing waste chemicals
  on site
• Key Legislation
• Cost
• Curtin University Procedures

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Outcomes

• Participants should leave this presentation with
  an understanding of
• key legal requirements covering chemical waste
  disposal
• the cost basis for collection and disposal of
  chemicals
• key requirements for managing chemical wastes on
  site
• their obligations and role in support of the
  process
• opportunities to improve the process
• The contractors system for preparing for and
  managing the collection of chemical waste

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Key Legislation

• There are 4 key legal aspects to Waste Chemical
  Management and Disposal
• Occupational Health and Safety Legislation
• Dangerous Goods Legislation
• Environmental Protection Legislation
• Water Corporation Legislation

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1. Occupational Health Safety

• Outside the mining and petroleum industries in WA
  the health and safety of employees is covered by
  the Occupational Safety and Health Act 1984 and
  the related Occupational Safety and Health
  Regulations 1986.
• This legislation places a general duty of care
  on
• employers to provide a safe place and systems of
  work
• employees to comply with the legal requirements
  of their employers
• A wide variety of government standards, codes of
  practice, guidelines and support documentation is
  readily available to both parties
• NOHSC publications (http//www.ascc.gov.au/ascc)
• Worksafe WA (http//www.worksafe.wa.gov.au)

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1.1 OHS Duty of Care

• Safe Place of Work
• Workplace hazards must be identified and
  controlled (the Hierarchy of Controls principal
  must be applied)
• Safe Systems of Work
• Adequate training and information must be
  provided
• Safety equipment and safe work procedures must be
  in place and employees must abide by them
• NOTE Failure to comply is an offence penalties
  range up to 25,000 for employees 250,000 for
  employers and 400,000 for organisations

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1.2 OHS Publication Sources

• NOHSC (http//www.ascc.gov.au)
• NOHSC1015(2001) Storage and Handling of
  Workplace Dangerous Goods
• NOHSC10005 (2005) List of Designated Hazardous
  Substances
• Worksafe WA (http//www.worksafe.wa.gov.au)
• Hazardous Substances example register
• Hazardous Substances example risk assessment

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2. Dangerous Goods

• In WA the storage of Dangerous Goods is covered
  by the Dangerous Goods safety Act 2004 and the
  associated Dangerous Goods (Storage and Handling
  of Non-explosives) Regulations 2007.
• The Act and the Regulations are administered by
  the Dangerous Goods Safety Branch, Resources
  Safety Division of the Department of Mines and
  Petroleum.
• Premises at which dangerous goods are stored are
  subject to site licensing requirements.
• Compliance to appropriate Australian Standards
  constitutes compliance with the Regulations
  themselves.
• NOTE Failure to comply is an offence penalties
  can include fines, imprisonment or both

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2.1 Licensing Requirements

• Storage of more than minor storage quantities,
  as defined in the Regulations or a supporting
  Australian Standard, requires a licence.
• Exceeding the quantity listed below for a
  particular class of DG at a specific location
  requires that location to be licensed.

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(No Transcript)
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2.2 Key Australian Standards

• AS 2243.10 - Safety in Laboratories (Storage of
  Chemicals)
• AS 3833 - The storage and handling of mixed
  classes of dangerous goods, in packages and
  intermediate bulk containers
• AS 1940 The storage and handling of flammable
  and combustible liquids
• NOTE the above are generally applicable, other
  standards may apply to storage of individual DG
  Classes

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3. Environmental Protection

• In WA legislation governing exposure to pollution
  for the general community and the environment is
  covered by The Environmental Protection Act
  1986, and the supporting Environmental
  Protection Regulations 1987.
• General processes for controlling discharges to
  the environment and for disposal of wastes are
  specified
• The disposal of hazardous waste is specifically
  covered in detail by the Environmental
  Protection (Controlled Waste) Regulations 2004
• NOTE Failure to comply with the EP Act is an
  offence penalties can include fines,
  imprisonment or both

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3.1 Controlled Waste Regulations

• All Controlled Waste
• generators require a licence
• movements must be pre-advised to DEP
• transporters must be licensed by DEP
• be disposed of in an approved manner at an
  approved location
• The contractor
• is licensed to transport and dispose of
  controlled waste
• can advise clients how to meet their legal
  obligations and manage the government formalities
  
• NOTE Failure to comply is an offence penalties
  under these Regulations include modest fines
  however the EP Act can apply for serious
  breaches

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4. Water Corporation

• Discharge of Industrial Waste to sewer requires
  a permit
• this dictates what can be disposed of to sewer
• guidelines are available at
• www.watercorporation.com.au
• Trade wastewater must not enter the stormwater
  drainage system.
• NOTE Failure to comply is an offence penalties
  can include loss of permit
• and/or fines however the EP Act can apply for
  serious breaches

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Contractor Services

• The contractor will
• Assist with the manifest
• Colour code for segregation
• Pack
• Remove and dispose

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Waste Collection

• Materials No change to the inventory without
  prior written agreement
• Timing should be set with regard to internal
  traffic hazards, must be realistic and adhered to
• Organisation paperwork, security and facility
  access, equipment etc must be in place, on time
• Support Relevant staff must be informed and
  available to assist as required (e.g. internal
  experts, security, ER team

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Transport Disposal Operation

• Contractors responsibility. Contractor will
  provide
• Copy of signed Controlled Waste receipts provided
  to Curtin
• Certificates of disposal provided on request (no
  charge)

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The Curtin Process

• EduSafe to fund waste disposal in 2007 and 2008
• Areas to prepare to request budgets for disposal
  from 2009 using information gained from
  2007/2008.
• To participate in EduSafe funded program
  electronic Manifests must be forwarded to EduSafe
  by advertised due dates.
• EduSafe will co-ordinate a university wide
  approach on an ongoing basis to assist with cost
  minimisation.

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Curtin Contacts
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• ANY QUESTIONS?

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Waste Service Components

• Containers options to use own and/or Contractor
  to supply
• Packing Contractor provide vermiculite FOC
• Labelling Contractor will provide FOC on the
  day of collection
• Collection time-based fee structure
• Transport Disposal Contractor responsibility

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Packing Requirements

• Bulk products
• Some products may lend themselves to bulking into
  a large capacity drum. Supervision and labelling
  is critical (Contractor can advise).
• Individual containers
• Fit for purpose and properly labelled is adequate
• Multiple containers packaged together
• Each container fit for purpose and properly
  labelled
• Must be compatible
• Securely wrapped to avoid contact and breakage
• Leak proof (with absorbent in place for liquids)
• Copy of inventory on inside and outside of
  containers

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Chemical Compatibility

• Chemicals that can react dangerously if mixed
  MUST NOT be packed together
• e.g. acids and alkalis oxidisers and flammables
• Chemicals MUST NOT be packed in incompatible
  packaging materials
• e.g. oxidisers and combustibles (this applies to
  both primary and secondary containers)

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Container Quality

• Suitability must be fit for purpose
• Liquid containers and lids must be in good
  condition, liquid tight and secure
• Solids containers must be robust and leak-free
• Compatible with contents (applies to primary and
  secondary containers)
• Fragile containers (eg vials) will require
  special handling/packing

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Labelling Containers for Transport

• Contents Labels required standard
• Legible and in good condition
• Accurately reflect the contents
• DG class diamond attached to Contractor disposal
  manifest sticker attached
• Contractor Colour Coded
• see following slide

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Colour Coding Chemical Grouping
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Chemical Manifests
NOTE A copy of the manifest must be attached to
the outside of an over-pack container and a
copy placed on the inside both copies must be
inside protective plastic sleeves
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MSDS Other Safety Resources

• It is a legal requirement that ready access be
  available to OHS information for all hazardous
  chemicals on site
• Curtin subscribes to the Chem Alert MSDS
  database system, accessible via the intranet
• Some locations also use hard copy file stations.
• Curtin Chemical Risk Assessment Process see
  following slides

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Example from Hazardous Substances Register
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Curtin University Chemical Risk Assessment
The Chemical Risk Assessment Work Sheet is
designed to prompt you to think about the risks
you face when using chemicals and whether you
believe the current controls will adequately
protect you. You should not proceed with the use
of a product if you believe it is unsafe. You
will need to obtain an MSDS for the product to be
able to complete the assessment. This can be
obtained from Chem Alert or upon request from the
supplier.For further information on risk
assessments, refer to section 5 of Edusafes
guide to Making the Workplace Safe The risk
assessment work sheet can be found in the
Hazardous substances section of the EduSafe web
site.
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• ANY QUESTIONS?