Luke Hendricks & Troy Vannieuwenhoven Advantages of DOT Segregation for Storage of Waste Chemicals at UW-Madison Luke Hendricks & Troy Vannieuwenhoven

3,200+ research labs Over $1 billion per year in research grants 42,000 students 16,000+ faculty Hospital Veterinary school 12 Agriculture Research Stations

5 Waste Management employees $200,000 annual budget Weekly lab visits for chemical pickups Shipped last year: 27,800 lbs of labpacks 128,200 lbs of solvents

Old Way Only 1 person doing segregation Inventory was by each individual container Minimum 5 day labpack Segregate by: Waste vs Redristribution Waste: Organic vs Inorganic Functional groups Acids/bases Seg process was a bottle neck Seg as in a laboratory – created by a chemist’s thought as to how chemicals should be disposed Each individual bottle was entered and labeled Ex: Phenol segregated as “general organic” vs DOT corrosive Ex: Sodium azide (azo functional group) vs DOT 6.1 Org Hg ships to a separate facility than Inorg Hg

New Way Segregate by: Multiple people can segregate DOT hazard classes & packing groups Vendor’s own special provisions Multiple people can segregate New inventory kept for each 90 day shipment

Simplified storage & layout of facility Why Switch? Cost Safety Simplified storage & layout of facility Ease of segregation & inventorying

Cost Saves time & labor during labpacks Pre-segregated for vendor Inventory list sent to vendor prior to their arrival Unknown identification/reactives expense Do our own identification of unknowns & stabilizations of reactives Results: Shortened labpack by 1-2 days Saves roughly $6,000 per year in labor Unknown ID with HAZCAT kit and knowledge of vendor’s shipping requirements Shorter labpack = $1,200/day for 2 guys in labor for 5 shipments a year - labor, fuel surcharge, mobilization fee, etc.

Safety Chemicals now stored according to more specific compatibility DOT hazard classes and compatibility groups Full inventory of chemicals to be labpacked Communication to emergency responders the hazards regarding chemicals currently being stored More than just the 9 DOT classes: divide into subgroups & packing groups within the DOT Haz classes - 6.1 PG 1 (6.1.1.) chems all packed by themselves & stored separate

Mercury & Mercury compounds shelves Org Hg Inorg. Hg Hg metal Mercury & Mercury compounds shelves

Simplified storage & layout Better utilization of storage space Vented cabinets & shelves for smelly, volatile, and reactive compounds A greater degree of separation for incompatible hazard classes - Different rooms for flammables vs everything else - Different cabinets for each haz class Example: Org Acid separate from Inorg Acid

Properly labeled according to RCRA Clear labeling Less confusion for the vendor between waste items & items for redistribution Properly labeled according to RCRA Old labels looked too similar creating confusion Led to waste items being missed (not shipped) and Redistribution items being accidentally shipped Researched requirements for labeling Chemical name, “HAZ WASTE” (if characteristically haz), Date

Ease of segregation & inventorying Chemical hazards are easier to segregate into DOT classes than by their functional groups Chemicals are shipped according to DOT hazard classes Inventory matches manifest for billing purposes Doesn’t take a PhD chemist to know the hazard classes Segregated by DOT classes, which is how they are shipped anyway

How we made the change Filled open positions with Labpack & DOT shipping experienced people Used Vendor’s facility requirements to dictate segregation requirements Use chemistry knowledge, old manifests, MSDSs to classify into a hazard class Researched RCRA labeling & inventory requirements We’ve found that it’s more important to have fewer employees that are more knowledgable than more employees that don’t have a clue Good knowledge base of most common chemicals HAZ Class Know special shipping requirements for certain chems what needs to be wetted what goes self-pack Know Vendor’s special provisions for where a specific chemical is being shipped for destruction Quantity limits per container for certain chems Ex: direct to incineration vs de-pack at 10 day facility Thiols/mercaptos & amines have separate disposal destinations

Hazcat trained to identify own unknowns Unknowns identified to at least convey haz class (not necessarily to each carbon chain/functional group) Hazcat trained to identify own unknowns

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