It's Not Easy Being Green

By Roger S. Hill, MA Certified Hazard Control Manager
Chemicals are vital in lab operations and using them safely in an environmentally responsible manner is a management responsibility that should not be taken lightly. Non-compliance with OSHA and EPA regulations will place your lab at risk for substantial civil and possible criminal penalties.

The OLA has developed a manual to assist its member labs in addressing common safety and environmental concerns in their operations. This new manual will be available this summer. The topics will include laboratory chemical waste management, chemical spill clean-up, safe handling of chemicals, and the OSHA Hazard Communication Program. The first step to begin in your lab’s chemical management program is to conduct an inventory of all chemicals used in your lab. The chemical inventory will be the basis of your chemical management plan. Many of the chemicals should be non-hazardous but it is prudent to obtain the Material Safety Data Sheet to review all your lab chemicals. Evaluating employee safety issues while working with the chemical is also critical. The chemicals found in your labs that are expired and no longer being used should be disposed of properly. Many chemicals, even if they are non-hazardous, are frequently not allowed to be poured down the drain without a waste discharge permit. Remember, environmental liability for your lab is a significant concern, if chemicals are disposed improperly.

Many state and local governments provide free advice on the proper disposal of chemicals. You generally do not have to give your name when requesting information, but remember about Caller ID if you do not want to bring attention to your lab. It is common for cities to have small quantity hazardous waste pickups at no cost. Checking to see if this is available and whether or not your business is allowed to turn in chemicals in this manner could save you in chemical disposal costs.

Once the chemicals and their amounts for your lab operation are determined, the next step is developing a lab chemical authorized use list. This list is the chemicals and their quantities allowed in your lab. This could actually save your lab money, since before any new chemicals are purchased the lab manager should review the need for the chemical as well as any hazards. You would be surprised how many unneeded chemicals with duplicate uses this process could uncover. Controlling chemical purchases will reduce your environmental liability.

The next part of your Chemical Management Program is a Hazard Communication Program. The Hazard Communication Standard (HAZCOM) was developed by OSHA to protect employees from chemicals in the workplace. This requirement applies to nearly every wholesale laboratory. The OLA Manual for Chemical Management devotes a complete chapter on this program and how to start one for your lab. The most common OSHA violation is lack of an effective HAZCOM Program.

The key of the HAZCOM program is the Material Safety Data Sheet (MSDS). It contains detailed chemical information provided by the chemical manufacturer or distr ibutor. It describes the chemical hazards and precautions of each specific chemical employees use. An employer must maintain a complete and accurate MSDS for each hazardous chemical that is used in their business. The OLA has a free Web-based program for member labs to maintain and update your Material Safety Data Sheets.

To determine HAZCOM Program effectiveness, OSHA will often interview employees. Employees should be able to explain how labeling conveys the hazards posed by chemicals in containers. They must not only know that labels are required, but also they must be able to show what the label indicates about the hazard.

The safe disposal and treatment of chemical wastes from lab production processes will also be included in the OLA manual. Optical labs produce waste from lens polishing, coolants, AR coatings, and lens blocking alloy that have to be properly disposed. Safe chemical spill clean up that meets EPA requirements are discussed. This program is discussed in detail in the OLA publication.

Your lab is required by law to manage your waste in compliance with EPA, state and local environmental regulations. An effective environmental program will not only greatly reduce your company’s liability of fines from the EPA, but will also contribute to improve production efficiencies. The penalties under U.S. environmental laws could result in up to $25,000 a day per violation fine. In some cases, criminal penalties could result. The types of wastes that are typically produced by optical labs include:

• Non-Hazardous Waste (Non-Regulated Waste): Industrial process waste not considered a hazardous waste under Federal environmental laws. This waste could be suitable for sewer disposal if approved by the local sewer district. Examples of nonhazardous waste are tints and polish waste.

Hazardous Waste: Any substance or mixture of substances having properties capable of producing adverse effects on the health or safety of a human being. Lead based alloys used in labs produce hazardous waste.

Unnecessary wastes from lab processes generally add to your cost of doing business. It is too easy for optical labs to use the most convenient method of disposal, an open drain to either a sewer system or storm drain. In most instances, it is illegal to discharge industrial waste in the local sewer system unless a permit is obtained from the local sanitary sewer district. Even if a chemical is non-hazardous or it is labeled biodegradable, it does not automatically make it suitable or legal for sewer disposal. Typical optical laboratories' non-hazardous waste is generally not suitable for untreated disposal in the sewer system including tinting waste, lens polish and liquid coolants. Disposal of theses wastes depend on your local environmental regulations.

Hazardous wastes (HW) could include some types of low-melting point alloy contaminated wastes, solvents, and some cleaners. Hazardous waste must be disposed of using a licensed HW contractor. This waste is generally not allowed in sewer systems without specialized treatment. Hazardous waste disposal costs are high and are also a liability concern to labs. It is much better to reduce and eliminate hazardous waste rather than pay for disposal and risk substantial EPA fines. ALWAYS use a reputable hazardous waste contractor that has local experience to provide guidance in hazardous waste disposal.

Once your lab generates hazardous waste, it becomes your responsibility forever, even if you give it to a contractor for disposal. The EPA calls it “cradle to grave” waste liability. Illegal dumping of industrial waste in storm drains; streams and rivers could result in criminal penalties and substantial fines. If someone sees you dumping waste, your lab is phone call away from an EPA visit.

Lens tinting is another common operation that produces waste. Many optical tints are biodegradable, but it does not mean that it could be disposed using the sewer system without approval from the local sewer district. Some tints are not suitable for disposable into the sewer system because of High Chemical Oxygen Demand. In other words, the tinting waste removes oxygen from the sewage that bacteria need to treat waste at the sewage plant. A suggestion is to ask your tint distributor to request approval from your local sewer district for disposal of their product into the sewer system.

Protecting the environment is not just the right thing to do, but is a good business decision. There are many other environmental products that you could use in your laboratory, but always make sure that the data supports any environmental claims. Having a green business is being part of the solution to the environmental problems facing us now and for future generations.

ROGER S. HILL, MA, IS A CERTIFIED HAZARD CONTROL MANAGER. THIS ARTICLE WAS SPONSORED BY THE OPTICAL LABORATORIES ASSOCIATION (OLA).

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Labtalk November/December 2018