SOP 4.4: Waste Packaging

Contents

1.Introduction......

2.Regulatory and contractual requirements

3.Staff qualifications......

4.Health and safety precautions

5Spill response...... 2

6Equipment and supplies...... 3

7.Packaging HW...... 3

Attachment A: Example inventory sheet...... 7

Attachment B: Example container log...... 8

Attachment C: Explanation of container labels and markings...... 9

1.Introduction

Proper packaging procedures will correctly guide the processing of Hazardous Waste (HW) received at this HouseholdHazardous Waste (HHW) Facility. HW packaging includes lab packing and loose packing. This process follows theprescreening of incoming materials and ensures proper preparation of HW for transport and disposal.

2.Regulatory and contractual requirements

The packaging of HW is governed by the requirements established in the HW program and state agency contract (see Exhibit A), Department of Transportation (DOT) 49 Code of Federal Regulations,49 CFR 173.12 (b)(2)(iii), 173.12 (b)(1), Minn. Rules pt. 7045.0310, subp 3 and 7045.0205 through 7045.0320, and Occupational Safety and Health Administration (OSHA) 29 CFR 1910.120 (a) and (q).

3.Staff qualifications

The designated Program staff responsible for ensuring HW is properly packaged is the Facility Manager. This person shall enforce HW regulatory standards, rules, and policies as they relate to staff actions and conduct. Prior to sorting, managing, or preparing HW for highway transport, staff shall complete Hazardous Categorization,OSHA,andDOT (or equivalent) trainings. Staff shall be trained within six months of being hired or starting a new position or be supervised by trainedstaff. Refresher training shall be conducted annually.

4.Health and safety precautions

4.1Safety

4.1.1Onlystafftrained and medically approved (if Facility is enrolled in a medical monitoring program) shall package HW, see SOP 2.13 Medical Monitoring.

4.1.2Staff shall follow safety measures and precautions as outlined in this Facility’s Emergency Contingency Plan and Health and Safety Plan. Staff shall also take precautions to prevent environmental impacts.

4.1.3No smoking shall be allowed inthis Facility, and there are designated areas for eating or drinking which are located away from chemical processing or storage areas.

4.1.4Routinely look for immediate dangers to nearby staff and property.Keep alert for suspicious activities or behaviors: see SOP 4.15 DOT Security Issues.

4.1.5Proper ergonomic techniques shall be utilized while packaging wastes; see SOP 2.11 Ergonomics.

4.2Personal protective equipment (PPE) requirements

This Program may choose to implement a more restrictive PPE policy, as engineered solutions to environmental conditions and experienced staff judgment may be used for unique conditions and situations, see SOP 2.4 Personal Protective Equipment. At a minimum, the following PPE shall be used when packaging HW:

  • safety glasses, goggles, or equivalent eye protection
  • footwear with reinforced toe or toe caps or equivalent foot protection
  • appropriate protective gloves
  • long-sleeved shirt and long pants, or equivalent, Tyvek or equivalent
  • respirator use (only if Facility has respirator program, see SOP 2.5 Respirator Program).

5.Spill response

Facility staffshall be responsible for cleaning up incidental spills that could happen in the course of packing HWwhich may pose potential safety or health hazards. Only trained emergency response staff or an emergency contractor shall respond to control and clean up of spills requiring assistance beyond the capabilities of Facility staff.Facility staffshall be trained and be able to respond to small spills only. This Facility shall make prior agreements with emergency response teams or HW contractors who could be used in case of an emergency: see SOP 2.6 Spill Response and SOP 2.10 HW Contingency Plan.

6.Equipment and supplies

6.1Staff requires adequate space to process, separate, organize, and package HW. A sorting area shall be set up to segregate the different wastes into labeled secondary containers. This prevents commingling of incompatible wastes and prepares the waste for lab packing.

6.2Waste packaging areas shall have flooring that is impermeable to the HW being processed and shall be away from public drop off areas.

6.3Proper equipment and supplies shall be available to process all materials received, including:

  1. UN-approved containers (e.g., metal, poly, fiber)
  2. Poly liners to be placed inside fiber/cardboard containers
  3. Compatible absorbents as appropriate for each waste type (e.g., clay type, oil dry, vermiculite, sawdust)
  4. Container inventory forms (as required by the state-contracted HW disposal company)
  5. Facility drum log
  6. Waste classification reference manuals (provided by state-contracted HW disposal company)
  7. Marking pens
  8. Labels (hazardouswaste, non-hazardous, DOT,“Up”arrow)
  9. Strapping or duct tape
  10. Carts

7.PackagingHW

The HW packaging process takes place afterpresorting or prescreening has been completed. The state-contracted HW disposal company provides Facility staff with packaging and container specifications and assistance for waste stream identification as HW will need to be segregated into individual categories based on their chemical constituents.See the state-contracted HW disposal company’s Hazard Categorization Manual orSOP 4.2 Waste Sorting.

The three methods ofpackaging HW includebulking, lab packing, and loose packing.For additional information on bulking wastes, see SOP 4.5 Waste Bulking.Lab packs require a detailed inventory while loose packs do not require an inventory. Loose packs are sometimes referred to as a“sorted waste stream.”

7.1Selecting containers

7.1.1Select a container usingstate HW contractor packaging and container specifications. See Attachment C of this SOP: Understanding Markings on Containers.

7.1.2Choose containers and absorbent materials that are compatible with waste stream, i.e. do not place corrosive acids into metal containers.

7.1.3Fiber containers must contain a 6 ml. poly liner.

7.2Container markings and preparation

7.2.1Correctly mark or label the container before packaging waste. Each container should be marked appropriately with the following:

7.2.1.1“Hazardous Waste” or “Non-hazardous”

7.2.1.2The DOT hazard class(e.g., corrosive, flammable solid, oxidizer, etc.). For a list of lab pack classes,see Attachment C of this SOP.

7.2.1.3The accumulation start date.55-gallons and smaller sized containers shall be marked once the container is full. Containers larger than 55 gallonsshall be marked the day product is first placed in the container.

7.2.1.4“Up” arrow labelsare required for containersholding liquid wastes.

7.2.1.5Each container shall be marked with a unique number assigned by this Facility to be used for tracking purposes.

7.2.1.6Container markings and labels shall be located on the container within six inches of each other and visible for inspection purposes.

7.2.1.7Only one of each different required label shallbe displayed on each package, however, duplicate labels are displayed on at least two sides or two ends (other than the bottom).

7.2.1.8Labels shall be clearly visible and not obscured by markings or attachments.

7.3Lab packing

7.3.1Container inventory/tally sheets

7.3.1.1A complete inventory form (provided by the state-contracted HW disposal company) shall accompany each lab pack, for an example inventory form, see Attachment A of this SOP. Tally sheets may be used with or in place of an inventory sheet. Container inventorieslist the:

  • unique container number
  • contents of the lab pack
  • quantity, weight, or size of container
  • physical state and chemical name of each item contained inside

7.3.1.2Record each HW container on the inventory sheet.

7.3.1.3Inventory/tally sheets are typically stored on a clipboard and stored on or near the accompanying waste container.

7.3.2Placingwaste items into lab packs

7.3.2.1Pour a thin layer (about 3 inches) of absorbenton the bottom of the outer container. Staff shall ensure the absorbent material (e.g., clay type, oil dry, vermiculite, sawdust) is appropriate for each waste type. Absorbent protects items from breakage and absorbs spills.

7.3.2.1Containers holding liquids shall be placed upright into the lab pack with all container openings facing up. Place waste items into lab packs by:

  1. Ensure glass containers have at least onehalf inch of space between containers to provide room for additional absorbent, although cardboard, plastic, and metal containers may be placed against each other.
  2. Place an additional 2 inches of absorbent between the waste container and the side of the outer container. Place a single layer of waste containersonto the absorbent, making sure each container does not exceed the maximum size limit allowed (no single container placed into a lab pack should be larger than a five-gallon pail or have a weight greater than 50 pounds. Reference the state-contracted HW disposal company’s Hazard Categorization Manual for specifics).
  3. Fill the outer container with alternating layers of waste containers and absorbent.
  4. Cover/top off the lab pack inner containers with 2 to 3 inches of absorbent material.
  5. If the container has a liner, close and seal by taping. Fold liner down, inside the container.
  6. Securely fasten on the container lid; for fiber containers without rings, tape the perimeter of the lid to secure.
  7. Mark the container number on the lid and record this number into the Facility drum log. This individual container number consists of the waste category and a facility-specific sequential number. For an example drum log, see Attachment A of this SOP.
  8. Attach one copy of the completed inventory sheet to the container, submit one copy to the state HW disposal contractor and keep one for Facility records. Keep this document on file with corresponding manifest for at least five years.

7.4Loose-packing

7.4.1Loose-packing is a packaging method used to aggregate containers within anestablished waste profile (as identified by the state-contracted HW disposal company). This process eliminates the need to complete an inventory form.Waste streams commonly loose-packedmay include aerosols, flammables, corrosives, paints, and pesticides. To place items into loose-packs:

1.Place a one-inch layer of absorbent in the bottom of the package container toprevent breakage and absorb spills.

2.Limit the potential for spills by placing containers upright, and each container is closed prior to placing items into the loose pack.

3.If the container has a liner, close and seal by taping. Fold liner down, inside the container.

4.Securely fasten on the container lid; for fiber containers without rings, tape the perimeter of the lid to secure.

5.Write the container number on the lid and record the container number into the Facility drum log. This individual container number consists of the waste category and a facility-specific sequential number.For an example drum log, see Attachment A of this SOP.

Attachment A

Example Inventory Sheet: State-Contracted HW Disposal Company

Organic acid container inventory (example)

Generator name______Container type/size______

Container number______Date______

Profile/manifest #______Gross weight of container______

Shipping name: waste corrosive liquids, acidic, organic, n.o.s. 8, un3265, ii

Waste description /

1 gallon

/

1 quart

/

1 pint

/ ½ pint / #
Acetic acid <10%
Acetic acid >10%
Thiourea
Citric acid
Coffee pot cleaners
Glycolic acid
Hydroxyacetic acid
Lime-Away with hydroxyacetic acid andsulfamic acid
Most wallpaper strippers (when pH is acidic)
Oxalic acid
Photo fixer with acetic acid
Formic acid
Formalin

Attachment B

Example Container Log

State-contracted HW disposal company:______Page:______

20____ Container Log Book

Facility location:______

Container # / Start date / Container size / Gross weight / Profile/WIP# / Manifest # / Shipdate / Treatment facility

Attachment C

Explanation of container labels and markings

For more information, research CFR 49 172.101 Hazardous Materials Table.

Packaging example 1

Packaging for magnesium powder in a container with markings: 1H2/X25/S/0406/USA/XXX

This marking indicates the container:

  • 1H2—an open head plastic container.
  • X—the container can hold a Packing Group X material.
  • 25—container will contain a gross weight < or = 25 kg.
  • S—will contain a solid.
  • 0406—manufactured 2004, June.
  • USA—manufactured in the United States.
  • XXX—manufactured by XXX company.
  • Inner package will be a plastic receptacle.
  • The magnesium powder was placed into a 1 pint sized plastic lined container and overpacked into 5-gallon plastic bucket that had the UN marking on it (49 CFR 178 subpart L).
  • Name and address not required on packaging. No RQ on packaging.

Packaging example 2

Packaging for phosphoric acid in a container with markings: 1H1/Y1.8/150S/0406/USA/XXX

This marking indicates the container:

  • 1H1—is a closed head plastic container.
  • Y—can hold a Packing Group Y material.
  • 1.8—will contain a liquid with a specific gravity < or = 1.8.
  • 150—has a hydrostatic pressure < or + 150 kilopascals.
  • 0406—manufactured 2004, June.
  • USA—manufactured in the United States.
  • XXX—manufactured by XXX company.
  • The phosphoric acid was bulked into a 55- gallon plastic container that had the UN marking on it (49 CFR 178 subpart L).

Packaging example 3

Packaging for dichloromethane (methylene chloride) in a container with markings: 1A1/Y1.6/150/04/USA/XXX

This marking indicates the container:

  • 1A1—is a closed head steel container.
  • Y—can hold a Packing Group Y material.
  • 1.6—will contain a liquid with a specific gravity < or = 1.6.
  • 150—has a hydrostatic pressure < or + 150 kilopascals.
  • 04—manufactured 2004.
  • USA—manufactured in the United States.
  • XXX—manufactured by XXX company.
  • The methylene chloride was bulked into a 55- gallon steel container that had the UN marking on it (49 CFR 178 subpart L).

Labeling example 1

Labeling and marking requirements for magnesium powder in a 55 gallon container:
Labels for magnesium powder: / Markings for magnesium powder:
Primary label is: DANGEROUS WHEN WET
(49 CFR part 172.423)
Subsidiary label is: SPONTANEOUSLY
COMBUSTIBLE
(49 CFR part 172.422) / Magnesium Powder
UN1418
1H2/X25/S/0406/USA/XXX
UN Symbol
No RQ, name or address required on package.
No markings required on inner packaging.
Placarding for magnesium powder if placarding and transporting:
The magnesium powder is a Class 4.3 hazardous material.
DANGEROUS-WHEN-WET quantities are less than 1,001 pounds, so no placard would be required for this hazard class.

Labeling example 2

Labeling and marking requirements for phosphoric acid in a 55 gallon container:
Label for phosphoric acid: / Markings for phosphoric acid:
Primary label is: CORROSIVE
(49 CFR part 172.442)
No subsidiary label is required. / Phosphoric acid
UN2834
1H1/Y1.8/150/0406/USA/XXX
UN Symbol
No RQ, name or address required on package.
Placarding for phosphoric acid if placarding and transporting:
CORROSIVE quantities are less than 1,001 pounds, so no placard would be required for this hazard class.

4.4 Waste Packaging1