Custodial Services Training Foothill - De Anza Colleges Department of Environmental Health and Safety Mona Voss: Director Susan Boraston: Environmental Specialist

Training Objectives Custodians have a Special Role  “Refresh” knowledge of regulations  Recognizing the Agencies  Hazardous Material and Waste Recognition  Use, handling and storage of requirements  Universal Waste  E-Waste  Spill Response Basics

Resource Conservation and Recovery Act (RCRA) began regulations  RCRA, passed by Congress in 1976 provides a cradle-to- grave management of hazardous waste.  Enforced by the following governmental hierarchy of agencies:  Federal - Environmental Protection Agency (EPA)  State - Department of Toxic Substance Control (DTSC)  Regional – California Unified Program Authority - CUPA  Santa Clara County Department of Environmental Health – FHC  Santa Clara County Central Fire Department– DAC  Stipulated Judgment and Campus Policy

Labeling of all containers is critical to Hazard Communication EVERY container must be labeled or it is considered to be “unknown” The label must have: Name of the contents written out in English Primary Hazard Class [Is it flammable, toxic, corrosive or reactive?] Even common substances like water, hand soap, detergent, etc. must be labeled.. No exceptions Labeling requirements increase as a material becomes more dangerous.

Types of Hazardous Waste Generators  Large quantity generator (LQG):  >2,200 lbs/month of hazardous waste  >2.2 lbs/month of acutely hazardous waste  FH/DA 2,550 lbs/month – Large Quantity  Small quantity generator (SQG):  Between ,200 lbs/month of hazardous waste  < 2.2 lbs/month of acutely hazardous waste  Conditionally exempt small quantity generator:  Up to 220 lbs/month of hazardous waste  < 2.2 lbs/month of acutely hazardous waste

What must a Large Quantity Generator (LQG) do? Foothill and De Anza must have: EPA Generator Identification Number Reporting requirements Training for Workers Waste stored less than 90 days Manage all Manifests Undergo Regulatory Inspections

A Hazardous Material is: One that may cause or significantly contribute to a potential treat to human health or the environment if released Santa Clara County also defines it to be one that contains 1% or more of any chemical “Listed” as a hazardous threat by State or Federal Regulation MSDSs indicate status

Hazardous Material Labeling Label must have the name of the substance written out in English The name of manufacturer links the material to the MSDS The primary hazard provides fast safety information The best label is the original label Secondary container must be labeled as indicated here

Label Secondary Container (something poured over) Hydrochloric Acid 38% Corrosive Liquid J T Baker Name of Contents written out in English Primary Hazard – [Is it flammable, toxic, corrosive or reactive?] Name of Manufacturer [Recommended]

Hazardous Waste  RCRA definition:  Causes or significantly contributes to an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness; or poses a substantial present or potential future hazard to human health or the environment when improperly treated, stored, transported or disposed, or otherwise mismanaged.

What is Hazardous Waste  Any waste that has the following characteristics:  Ignitable  Corrosive  Reactive  Toxic  Is listed as a waste in CFR 40 [Federal regs.] or Title 22 CCR [State regs.] as harmful to individuals or the environment or is made by a process that is known to generate waste.

Hazardous Characteristics u Ignitable Flash point < 140 o F (simply, catches on fire easily and burns) Examples: Alcohols, acetone, ether, gasoline, certain paints and varnishes, other flammable solvents

Waste Characteristics u Corrosive pH 12.5 (simply, burns the skin) Examples: Acids, bases, glass cleaner, hydroxides, drain cleaners, others

Waste Characteristics u Reactive Unstable and may explode under certain conditions such as heat, friction or pressure (simply, material that my react violently under normal conditions) Examples: Picric acid, peroxide forming chemicals, ethyl ethers, di-nitro compounds, others

Waste Characteristics u Toxic Fails Toxic Characteristic Leaching Procedure (TCLP) Test – simply, small amounts make you sick when you get it in your body (eat or drink) or absorbs through your skin. Examples: Heavy metals: mercury, lead, silver, zinc, chromic acid, many E-wastes, others

What is the Difference? Hazardous Material New material Materials in use Saved products Labeled in English Can hurt you Hazardous Waste Used, contaminated or expired Chemicals for disposal or recycle Bright Yellow Labels Can hurt you

Similarities between Hazardous Materials and Hazardous Waste LABELED according to requirements Secondary containment required Kept securely closed except when in use Compatible storage – segregation Perform Inspections, reporting & record keeping Never “dumped” into trash, sewer or storm drain Inclusion on the Hazardous Material Inventory Statement (HMIS or HMBP)

Waste Labels  A hazardous waste label must be placed on the waste container as soon as the first drop of waste is added.  A waste label must be represent what is in the container (contents).  Waste labels look like this:

Universal Waste Rule (CCR ) u First established by EPA in u The Universal Waste Rule (UWR) permits certain wastes with hazardous characteristics to be managed under simplified requirements that will encourage the collection, recycling or disposal of the waste. u Universal waste is widespread, found in medium to large volumes, and presents low level hazards or can be easily managed. u Sanitary garbage disposal is PROHIBITED!

Universal Waste Types u Examples and toxicity (heavy metals): u Batteries – Nickel, cadmium, mercury, metal hydrides u Fluorescent Lights – mercury or lead u Other high intensity discharge lamps, neon, mercury vapor, high pressure sodium, and metal halide lamps – mercury, cadmium, antimony u Mercury thermostats – mercury u Non-empty aerosols – propellants with pressure u E-waste (CRTs and Consumer Electronic Devices or CEDs) – lead, cadmium, chrome, copper

Where do Batteries go? Place all batteries (except large vehicle lead acid ones) in the red collection pails marked “Universal Wastes” at strategic areas on campus. Locations are: Plant services office, ETS, mechanic’s office, chemistry stockroom, photo departments, police station, district office and the universal waste shed.

What about fluorescent lights? Report burned out lights to plant services for replacement by using the work order request system. A “trades person” will remove and replace the light and take the old lamp to the Universal waste storage shed for storage and disposal. If you see “light tubes” in the trash left by “someone”, PLEASE call 6146 and report it. Place “ordinary light bulbs” in the trash

What about non-empty Aerosol cans? Concern relates to both the propellant and the contents of the cans Cans with propellants are small pressurized containers which may “react” or release pressure aggressively [the propellant make it dangerous]. Others can be “hazardous waste” based upon what is in the can. Collect the can and put it into a collection drum located in the ……………

E-Waste is a “BIG” concern for the campuses E-waste is electronic waste or Universal Waste Electronic Devices (UWED) which historically has high level of metals in its components Monitors have lead in the glass Circuit boards have copper & lead (solder) FHDA designates two types of waste which then determines who will manage the equipment Category I has software licenses, programs, data, which must be removed by ETS before recycling Category II has toxic substances (no information) but is managed as surplus to an approved recycler

What happens to Electronic Waste? FHDA staff call ETS to evaluate, clear the data and determine deposition of items. The custodial staff never picks up E-Waste! They tell everyone to call ETS. Do not let anyone pressure you into taking E-Waste. Report any abandoned E-Waste setting around to supervisor and EH&S. (Educational Technology Services – ETS)

Electronic Equipment Clean-up Clean-up is necessary when a monitor or computer shatters. The goal is to collect and contain all fragments of all broken pieces. The clean-up is performed by Plant Services staff [they’ve been trained]! Tell your supervisor or Plant Services whenever you see broken E-Waste.

Custodial Responsibilities Keep the custodial closets neat… Everything must be labeled, Nothing limiting access to electrical panels, Keep only a working supply of products, Get more product from the lead who in turn gets it from storage.

Spills in Scope to Clean Clean-up small spills if you:  Are familiar with the properties of the spilled materials – use them regularly and know they have a very low hazard level – you just spill something.  Have materials to collect spilled material and a container or bag for the spilled material – remember to label the bag as to what waste material is in there.  Have the proper personal protective equipment [gloves]  Remember to complete the Spill Log.

Emergency Spill Response  Fluorescent lights and shattered monitors can be cleaned up by trained Plant Service staff - call PS immediately  If a spill is not something that you use everyday, do not attempt to clean it up  Call your supervisor who will call the numbers on the posted Emergency Procedure Chart

Storm Drains are for storm water… not for disposal The rain water from a storm goes through a system of connections to the Bay. This water does not go through a treatment plant so anything in the storm drain goes into our natural resources. Nothing, simply nothing, should go into the storm drains, except natural rain water. The posted signs “No dumping - Drains to Bay” are intended to serve as a constant reminder to restrict any discharge into drain

Sanitary Sewer Districts Restrict the Disposal of Chemicals Every sewer district has strict limits as to what can be discharged and they monitor to confirm these limits are being maintained. Treatment plants were generally constructed for household material and strong chemicals can destroy the system. The only material that can be disposed of down the drain is one that has been approved by your department.

Contact Information Department of Environmental Health and Safety Mona Voss, x 6146 Plant Services Frank Nunez, x 5437 Marilyn Williams, x 7264 Gil Delgado, x 6154 E-Waste x 8324