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HAZARDOUS WASTE
REFRESHER TRAINING - 2000
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MAIN TOPICS FOR DISCUSSION:
Container Usage, Labeling & Storage Hazardous Waste Tracking Logs Storage Area Inspections Shipping Waste & Recordkeeping Training Emergencies ReferencesContainer Usage, Labeling & Storage Place waste material in properly labeled 20, 30 or 55-gallon DOT-approved drum (except for inks for plants with onsite ink recycling systems) 00do not mix different wastes in 1 drum, especially hazardous waste with non-hazardous waste. Labels should read 00azardous Waste00or 00on-Hazardous Waste00/b> depending on the waste profile sheet, and should list the type of waste (waste ink, etc.). Date drum on first drop of waste for containers stored in the storage area. Most plants are 00mall Quantity Generators (SQG)00and must remove drums within 180 days via Safety Kleen (South Brunswick and Riverside are 00arge Quantity Generators (LQG)00and have only 90 days to remove drums via Safety Kleen). Drums stored near the point where waste is generated are called 00b>satellite drums00 and don00 need to be dated until full. Once full, they must be moved to storage area within 3 days. All waste container lids/bung caps must be kept closed when not in use 00no funnels left in the bung openings! Drums must be kept clean and labels readable; any spilled waste on top of drums or on floor must be cleaned up immediately! There is no need to date the waste from a Safety-Kleen parts cleaner. The recycled solvent is not considered a waste (while in use) until the day it is removed from service (which is the same day it is picked up by Safety-Kleen). Follow procedures for properly storing and disposing common wastes, such as fluorescent bulbs, batteries, and computer scrap, which have hazardous components. Hazardous Waste Tracking Logs
This log (attached) needs to be completed every time a waste container enters the storage room or leaves during shipment, and updated at least monthly. For most plants, this is completed by the Building or Maintenance Department. The log helps to:
ensure waste is not past allowed storage period (SQG-180 days) verify that a signed copy of manifest was returned from disposal facility determine generator status Storage Area InspectionsWeekly inspections are required to ensure that the waste drums are in good condition, per EPA rules. For our sites, this is completed using the Hazardous Materials Weekly Inspection Form (attached).
Shipping Waste & Recordkeeping Safety Kleen is the only approved waste contractor for our sites. Although Safety Kleen is currently operating under a Chapter 11 bankruptcy mode, they continue to maintain their service operations and disposal facilities as before. DJ is reviewing other contractors as a precaution, however we feel Safety Kleen will continue to remain the largest hazardous waste contractor in the U.S. for the foreseeable future. Wastes can only be shipped to final disposal sites listed on DJ00 Approved Treatment, Storage, Disposal, & Recycling Facility (TSDRF) list located in Appendix 7 of the Hazardous Waste Management Plan (HWMP). This approved list was developed to ensure our waste is properly managed and to minimize any potential future Superfund cleanup liabilities for Dow Jones. Proper Department of Transportation (DOT) diamond-shaped labels must be placed on waste containers prior to shipment. This is normally completed by the local Safety Kleen representative during preparation of shipment. All hazardous waste shipments from the plant must be documented on a 00b>Hazardous Waste Manifest.00nbsp; Only personnel trained in hazardous waste, hazard communication and DOT HAZMAT are allowed to sign manifests (see training section below). A 00azardous Waste Shipping Checklist00/b> (attached) should be filled out during each shipment in order to ensure that the manifest was properly completed and that the shipment met the basic requirements under EPA rules. A Land Disposal Restriction (LDR) form must accompany the manifest to show the proper treatment required for a listed EPA hazardous waste for any hazardous wastes that may need to be landfilled. It should be attached to the waste manifest before the shipment. LDRs are NOT required for non-hazardous waste shipments. Certificates of disposal (CODs) that indicate the TSDRF name, type and date of treatment, should be received from the Safety Kleen service center for all wastes shipped. The COD certifies that the waste was properly treated, recycled, or disposed according to EPA guidelines. Copies of Manifests and LDRs must be sent to state EPA agencies as noted on your Hazardous Waste Site-Specific Matrix. Copies must also be keep in your plant00 E&S filing system (along with the CODs), with a copy sent to corporate E&S (Dave Lasky--WSJ plants, Ed Thomas--Ottaway plants). Signed copies of the manifest from the disposal facility must be received within 30 days of shipment. If not received within 30 days, contact corporate E&S. Training Hazardous Waste training is required annually for anyone who handles, uses or stores chemicals or their wastes. All new employees in 2000 must take the CD-ROM training that combines Hazard Communication & Hazardous Waste training. Employees who took that CD-ROM course in 1999 can take this refresher training to fulfill the annual training requirement for 2000. Those employees who are involved with the preparation or shipment of hazardous waste must also take the DOT HAZMAT CD-ROM training every 2 years (in addition to hazardous waste training and HAZCOM training.) Emergencies For any spills, fires or medical emergencies, call your local emergency phone number. For a chemical spill that leaves the plant and enters the soil or waterway, the local and state environmental agencies need to be contacted immediately, along with corporate E&S. See your sites00Emergency Management Plan for details. References Hazardous Waste Management Plan (on E&S website at http://pouch.dowjones.com/ESP/) 00a complete instruction manual to properly manage hazardous waste. Hazardous Waste Flowchart (section 1.4 of HWMP) 00a helpful 1-page flowchart which summarizes the steps needed to properly manage hazardous waste. Site-specific Hazardous Waste Matrix (Appendix 1 of the HWMP) -- provides useful info about profile #s, disposal costs, waste descriptions, and final disposal sites for your plant. Attached forms: - Hazardous Waste Tracking Log- Hazardous Materials Weekly Inspection Form
- Hazardous Waste Shipping Checklist
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Hazardous Waste Refresher Training - 2000 Page of 3
