Hazardous Materials and Waste Handling Program

Hazardous Materials and Waste Handling Program

Hazardous Waste: Accumulating, Storing, Shipping

The waste generated at ENPOINTE has and will continue to be evaluated to ensure compliance with Minnesota Pollution Control Rules. Proper labeling and the required shipping manifests are the responsibility of the Vice President, Operations and shipping lead. Hazardous waste trained personnel and the Vice President of Operations are authorized to release waste to our Hazardous Waste Hauler.

Because our company is ever changing (growth, new products and increased volumes), and because government regulations are ever changing, it is the policy of ENPOINTE to evaluate the products we use and the waste we generate. It is the responsibility of all employees to assist in the selection, safe use and handling of our products and waste.

Requirements for hazardous waste containers include the following:

  • Containers must be made of sturdy, leak-proof materials and must meet DOT specifications for materials and construction.
  • The container must be made of or lined with materials which will not react with the hazardous waste you plan to store in it.

CONTAINER MAKING

As soon as hazardous waste is placed in a container:

  • The container must be marked with the words “Hazardous Waste”.
  • The container must be labeled in a manner which clearly identifies or describes its contents to employees and emergency personnel.

CONTAINER LABELING

The MPCA and DOT regulations require that hazardous waste containers be properly labeled prior to shipment off-site. Labels should always be kept in clear view for easy inspection. All hazardous wastes shipped must have four (4) identifications. These include:

Hazard Labels

Hazard labels are the small 4×4 inch labels of DOT hazard categories, such as FLAMMABLE, CORROSIVE, OR OXIDIZER. The DOT Hazardous Materials Table (Table 172.101 of 49 CFR) indicates which label to use. For example, some solvents require a “FLAMMABLE” label and waste sulfuric acid requires a “CORROSIVE” label. Some wastes may require two labels, such as “FLAMMABLE” and “CORROSIVE”. If two labels are required, place them side-by-side.

DOT Shipping Name

Each waste has a precise DOT name. The proper shipping name for a hazardous material can be found in the DOT Hazardous Material Table. For hazardous wastes, the word “WASTE” must precede the DOT name. “Waste Methylene Chloride” is an example of a proper DOT shipping name. This name must appear on the container or on the container’s label.

DOT Identification Numbers

Each waste has a six-digit number assigned to it which identifies how to handle the waste in case of an accident. The identification number has a prefix of either NA or UN (for numbers used in North America or assigned by the United Nations for international use). The prefix is followed by a four-digit number. This number can be found in the DOT Hazardous Materials Table.

Hazardous Waste Labels

Large 6×6 inch labels with the words “HAZARDOUS WASTE” must be placed on hazardous waste containers. You must indicate on these labels the company name, address, EPA identification number, manifest document number and accumulation start date. Most labels have spaced for the DOT shipping name and DOT identification number.

HAZARDOUS PLACARDS

Hazardous placard are large “labels” to be placed on hazardous waste transport vehicles. It is the generator’s responsibility to supply the transporter vehicle with the proper DOT hazard placard. However, the transporter usually carries an assortment of vehicle placards.

Hazardous MAT Specialist

PH: 1-800-467-4922, 651-215-6330

CHARACTERISTICS OF HAZARDOUS WASTE

Ignitability (D001):

A liquid is ignitable if it has a flash point below 140 degrees Fahrenheit.
(i.e., many solvents)

A solid is ignitable if it can spontaneously catch on fire and burn so persistently that is creates a hazard.

Oxidizer (D001):

Adds oxygen to a reaction or fire.
(i.e., oxides, peroxides, nitric acid, chlorine, etc.)

Corrosivity (D002):

A water based waste which has a PH of less than or equal to 2.0 or greater or equal to 12.5 (i.e., nitric acid, hydrochloric acid, strong caustics). Please note: “water based” does NOT mean sewerable!!

Reactivity (D003):

An unstable waste which reacts violently when brought into contact with water.

Wasters that can generate toxic gasses, vapors and fumes (i.e., hydrogen cyanide or hydrogen sulfide.)

Lethality (MN01):

Waste or its components which have been found to be lethal in animal testing.

Toxicity:

Waste that exhibits the characteristics of toxicity equal to or greater than the allowable concentration levels

WASTE SOLVENTS

The waste solvents captured at ENPOINTE are generated primarily in the pressroom.

Press cleanup generates a solvent and ink waste that must be placed in the waste solvent drum.

Note: Processor systems cleaners may require PH adjustment prior to sewering. See the Vice President, Operations for methods approval and documentation.

WASTE INK

Waste ink generated at ENPOINTE has been tested (TCLP) and classified as non-hazardous. However, it is a regulated waste that cannot be landfilled. Proper handling of our waste ink includes storage, labeling, manifesting, shipping and disposal.

NOTE: Special care must be taken to prevent waste ink from going into the dumpster. Ink cans must be scrapped to less than 1/4 inch in the bottom of the can to meet our standards of compliance.

WASTE OIL MANAGEMENT

The following work practices relating to waste oil are effective immediately:

  • Used oil must be put in the 55 gallon drum labeled “Used Oil”.
    Warning: Do Not Put Any Other Material In This Drum!
    (Periodically this drum will be shipped out and the oil recycled)
  • Machines should be maintained to minimize oil leaks and spills.
  • In the event of a leak or spill the oil should be cleaned up using shop rags
  • Shop rags containing oil must be placed in the dirty rag fire containers prior to centrifuge spinning.
  • Waste oil spun from shop rags must be placed in the waste press solvent drum – NOT in the oil drum as there may be solvent contamination of the oil.
  • Under no circumstances will waste oil or waste oil soaked rags be placed in the dumpster.
  • Your cooperation is mandatory.

Record Keeping

Effective 10/95 MPCA requires records to be kept to track used oil shipments. The person in charge of recording the hazardous waste manifests will keep a log of used oil shipments.

MANAGEMENT OF FLORESCENT LAMPS

The U.S. Environmental Protection Agency’s (EPA) implementation of the Toxicity Characteristics Leaching Procedure Test (TCLP) placed many new wastes into the hazardous category, including fluorescent lamps, high intensity discharge lamps; and mercury vapor lamps. Many lamps are hazardous waste. Some, however, are nonhazardous, depending upon the lamp and the manufacturer of the lamp. Materials of concern are mercury and lead, which are heavy metals that can do damage in even small amounts.

Mercury escapes into the atmosphere when lamps are broken causing environmental problems when the mercury vapor comes down to the ground and into surface waters with rain. In addition, a potential health hazard exists to people who become exposed to the mercury vapor when lamps are broken. Therefore, the MCPA requires the following:

  • Do not break or crush.
  • Store until a shipment is prepared for recycling.
  • If a lamp breaks, place it in a box labeled “one broken lamp” and store until a shipment is prepared for recycling.
  • Use a shipping manifest and a licensed transporter.

Transportation Requirements For Lamps From Businesses

  • Pack lamps in a way to protect them from breaking.
  • Use shipping papers when shipping lamps within the State of Minnesota.
  • Use a licensed hazardous waste transporter and a manifest when transporting to other states from Minnesota.

Storage Requirements From Lamps

  • Store in an area and a manner that will prevent breakage.
  • Use signs and notices that show employees where and how to store lamps.

Record Keeping

Any time bulbs are stored or shipped off-site records need to be kept. Businesses should keep track of three things:

  • The number of lamps removed from service during each calendar year.
  • The storage location of the lamps.
  • When and where the lamps were shipped.

ENPOINTE Storage Policy

Old lamps must be packed into shipping containers and placed in the designated storage area. The Maintenance Department Lead is responsible for the storage, retrieval and shipment of used lamps. Record of the number of used lamps accumulated each year along with shipping manifests, purchase orders and certificates of destruction must be filed in the Maintenance Department office.

Do Not Put Fluorescent Lamps In The Trash!

HAZARDOUS MATERIALS STORAGE

The following inspection of hazardous materials storage is completed on a weekly basis:

HAZARDOUS MATERIALS STORAGE INSPECTION CHECKLIST

  • All hazardous waste barrels are closed except to add or remove waste.
  • After adding or removing waste, close funnels.
  • All containers need to be positioned so they can be inspected easily.
  • Inspect all containers for leaks or deterioration of containers
  • Care is to be taken to avoid spilling any materials, virgin or waste, on the ground either inside or outside the plant. The Vice President, Operations must be informed immediately if a spill causes injury or if the material/waste fails to be contained (leaves the building via a floor drain or door.)
  • Incompatible wastes must be kept separate (a strong acid and an organic solvent).
  • Waste materials are monitored to make sure only like materials are stored together.
  • All hazardous waste containers are properly labeled with appropriate labels noting “Hazardous Waste”, identification of contents along with accumulation start date, etc. All labels are placed slightly to the side of the bung, barrels are positioned to be able to read all waste labels.
  • Waste must be stored in a secure area, protected from unauthorized access and damage from vehicles or equipment.
  • Check materials for accumulation and shipping deadlines.
  • All containers storing hazardous materials must be stored inside the building away from high traffic areas and floor drains
  • Containers may be thrown into the trash or dumpster under certain circumstances. Containers are defined as plastic jugs, cans, pails or barrels. No containers should be put in a dumpster unless they are brush clean or drip clean. Additionally, the container should be slashed or crushed so they cannot accumulate any liquid on a secondary use.
  • The responsible party completes and signs the inspection log posted in the appropriate area.

PRESSROOM CHEMICALS MATERIAL HANDLING

Receiving & Storage

Hazardous Material Drums will be placed in the fire cabinets for storage and use as soon as possible when received. Hazardous Waste Drums will be stored away from the dock doors and out of the way of forklifts, either by the waste oil or waste ink drums.

Make sure barrel is completely empty before changing. When inserting the spout and air release valve make certain that they are in an upright position and tight, to avoid dripping. To place a full drum in the cabinet, use the ramp and handle stored by the waste oil and the cart in the cabinet. Move the cart upright under the barrel, making sure that the fingers are placed evenly under the barrel. Insert the handle through the cart and hook on drum. Slowly lower the barrel using the handle. Use the ramp to roll the barrel cart into cabinet with the ramp.

Material Transfer

Original Container to Process Container
(55-gallon drum to 5-gallon can)
Process Container to Immediate Use Container
(5-gallon can to 1-gallon can)

Flammable liquids can create static sparks during handling that must be neutralized. Drums in storage will be grounded. When filling metal safety can or containers the fill spout, nozzle or pipe shall be kept continuously in contact with the container being filled. When contact cannot be made a bond wire will be used. The bond wire shall be connected between the container to be filled and the drum or to a grounding bar or wire.

Containers that are completely plastic and less than 5 gallons need not be grounded.
Approved plastic containers should be used when possible.

PPE Required

Safety glasses required – rubber apron and gloves provided, to be used at employee’s discretion.

SPILLS OF HAZARDOUS MATERIAL OR WASTE

During the normal operations of a printing facility minor spills of materials will occur. The proper method of clean up depends upon the material spilled. Most liquid (solvent type) spills should be cleaned up with shop rags. The shop rags must be stored in the fire containers until centrifuging is completed.

In the event of any spills, employees’ safety, spill containment and spill cleanup is the express responsibility of all employees.

The Vice President, Operations must be informed immediately if a spill causes injury or if the material/waste fails to be contained (leaves the building via a floor drain or door).

 

Reviewed 10/31/22