SOP 4.12: Waste Staging for Shipment

Contents

1.Introduction

2.Regulatory and contractual requirements

3.Training......

4.Health and safety precautions...... 2

5.Shipping day preparations...... 3

1.Introduction

The proper preparation of household hazardous waste (HHW) packaged materials ensures safe storage and transport. Staff shall ensure hazardous waste (HW) pre-shipping requirements are followed prior to transport off site by a Minnesota State-contracted HW disposal company.

2.Regulatory and contractual requirements

Procedures for staging HW for shipment is governed by the requirements established in the HHW program and state agency contract (Exhibit A), Minn. Rules Chapter 7045, and DOT49 Code of Federal Regulations; see

3.Training

3.1Only designated staff shall be authorized to prepare waste for transport from this Facility. The designated person for ensuring HW is properly staged for shipment is the Facility Manager.

3.2This Facility shall have a written training program that describes the management of wastes relevant to job duties and shall include function-specific training, safety, regulatory, and emergency procedures; see SOP 1.4 HHW Training Requirements.

3.3Thorough knowledge and training in the proper use of Facility equipment is required. Staff shall review all manufacturer operation manuals prior to operating equipment to become familiar with design and maintenance; see SOP 5.1 Equipment Maintenance.

4.Health and safety precautions

4.1Staff safety requirements

4.1.1Follow safety and emergency requirements as outlined in the Facility HW Contingency Plan; see SOP 2.10 HW Contingency Plan.

4.1.2 Maintain careful awareness to chemical safe handling while processing HW.

4.1.3Abide by this Facility’s Medical Monitoring Program if exposed to HW for 30 or more days per year. It is this Program’s responsibility to establish procedures to continually verify the medical monitoring program is adequate and meeting requirements and regulations. Engineering and work practice controls shall be utilized to minimize or eliminate exposures: see SOP 2.13 Medical Monitoring Recommendations.

4.1.4 Do not smoke, eat, or drink inFacilityprocessing or storage areas.

4.1.5 Be aware of immediate dangers to nearby staff and property and keep alert for suspicious activities or behaviors; seeSOP 4.14 DOT Security Issues.

4.1.6 Use proper ergonomic techniques while managing HW; see SOP 2.11 Ergonomics.

4.2Personal protective equipment (PPE)

Engineered solutions to environmental conditions and experienced staff judgment may be used for unique conditions and situations. PPE shall be utilized if the potential for exposure remains after the institution of work practice controls; see SOP 2.4 Personal Protective Equipment. This Facility may choose to implement a more restrictive PPE policy while managing wastes andminimally includes:

  • Safety glasses with side shields, goggles, or equivalent eye protection
  • Footwear with reinforced toe or toe caps or equivalent foot protection
  • Nitrile gloves or equivalent hand protection
  • Chemical splash apron, Tyvek coveralls, or equivalent body protection

4.3Emergency response

Only trained emergency staff shall respond to incidents requiring assistance beyond the capabilities of Facility staff. This Facility shall make prior agreements with emergency response teams to be used in case of an emergency; see SOP 2.10 HW Contingency Plan.

5.Shipping day preparations

5.1Advance preparations

  • Document each container being shipped out in the Facility Drum Log (e.g., date of shipment, manifest number, destination site).
  • Contact the state-contracted HW disposal company at least 15 business days before desired shipment date. For any late additions to the amount of waste being shipped, contact the disposal company at least two days prior to the scheduled pickup date.
  • The disposal company will contact the Facility if there are shipment concerns, including written instructions if repacking wastes is required. Forward the following information tothe disposal company:
  1. A summary sheet indicating the number and type of waste containers to be shipped.
  2. Completed labpack inventories or packing lists (retain a copy with each container; this may not be required for loose packs).
  3. Inventory listing or tally sheets (supplied by the disposal company) work order form.
  4. Unknown material screening report forms.
  5. Cylinder questionnaires.
  6. Waste stream profile sheets for new wastes.

5.2Shipment day tasks

  • Segregate the shippingcontainersfrom the materials destined to remain at theFacility.
  • Ensure approved DOT containers and complete/applicable markings or labels are attached.
  • To decrease the loading process time, use a drum dolly or other equipment to segregate and placecontainersin staging area.
  • Waste loading protocol is based onthe total weight being offered for shipment,as balancing the transport truck axle weight evenly and throughout the entire load isrequired by DOT. Some waste containers may be left behind at the Facility if the weight on the vehicle is incorrect.

5.3Transportation requirements

  • HW shall be shipped from this Facility by a licensed transporter(the state’s contracted HW disposal company).
  • The disposal company prepares all legal shipping paperwork (manifests), although this Facility is responsible for accuracy. Prior to signing, designated Facility staff shall reviewmanifest, bill of lading and land disposal restriction (LDR) documented information.

4.12 Waste Staging for Shipment1