Veterinary Compliance Assistance

Managing Hazardous Materials

Good operating practices

This section presents good operating practices that can help improve safety, reduce the volume of hazardous material present in a facility, and reduce the volume of hazardous waste generated.

The following was adapted from material available on the Western Regional Pollution Prevention Network (WRPPNTM) website, originally published by the Santa Clara County Hazardous Materials Advisory Committee.

Purchasing Procedures

Good purchasing procedures will identify and reduce potential waste before it enters your business

  • Material Review:  Evaluate the materials used by your business, look for less- or non-toxic substitutes, and purchase:
    • The least toxic and least costly-to-handle products that work
    • Higher-purity raw materials
    • Noncorrosive raw materials
  • Container Review:  Consider your intended use and standard operating practices, and purchase materials in the size and type of container which will minimize material losses and costs:
    • Buy in smaller containers if transfer from large to smaller containers is generally required before use (There will be less potential for spills, material evaporation, contamination from unused material returned to the original container, and expiration of unused materials.)
    • Buy in pre-weighed packages to reduce handling losses (if applicable)
    • Buy materials used often in larger containers (Buying in bulk can reduce the number of containers requiring disposal, especially if refillable containers are used.)
    • Buy containers that are wider than tall (They have less "cling," resulting in greater material use and less container residue.)
    • Buy containers which minimize disposal problems (e.g.  fillable pressurized spray cans in place of single use aerosol spray cans)
  • Chemical Samples:  Establish a policy for accepting samples so they do not accumulate and add to waste disposal load:
    • Designate one person responsible for acceptance of chemical samples
    • Test on a bench scale basis to reduce volume needing disposal
    • Require that suppliers accept back the unused samples they provide
  • Equipment Evaluation:  Prior to purchase, ensure that new equipment:
    • Is that which will generate the least amount of hazardous waste possible
    • Can be easily maintained (Preventive maintenance can save 3-4 times the equipment cost by reducing breakdowns and malfunctions.)
    • Complies with applicable environmental and safety standards (Check with regulating agencies.  Use suppliers knowledgeable in these areas.)
  • Centralized Purchasing:  Channel material purchases through a central person or department to:
    • Eliminate unnecessary purchases
    • Ensure that all waste reduction purchasing policies are followed
  • MSDSs:  Make certain that distributors supply you with Material Safety Data Sheets for all purchased hazardous materials in order to:
    • Know material hazards, proper safety precautions, and handling and emergency response procedures
    • Comply with worker and community Right-to-Know laws
    • Help you determine the nature of your wastes
  • Evaluate Facility Design:  Consider waste reduction when planning expansions, and evaluate potential building purchases/leases to determine whether the building design is amenable to waste reduction.  Make sure that:
    • Hazardous materials storage areas exist or can be easily installed
    • Space and utilities are available for proper recycling and treatment needs, etc.  

Inventory Control Procedures

Inventory control procedures are important for reducing management costs and potential hazards associated with excess, off-spec, and expired materials

  • Set Inventory Limits:  Set according to emergency response capacity.  (How large an inventory can your spill/emergency response equipment and personnel handle? The more inventory of hazardous materials, the greater the chance for overcrowding storage areas and resulting safety problems such as spills, exposures and fires.)
  • Minimize Inventory:  Buy and stock only what you need (Costs associated with hazard risks, hazardous materials fees, and disposal of excess or expired stock may outweigh the costs of waiting for resupply shipments.):
    • Carefully consider large purchases (especially if only to get a discount)
    • Time deliveries to coincide with production needs ( "just-in-time" system)
  • Track Materials:  Effectively track the shelf-life of time-sensitive materials and use the oldest stock first ("first-in, first-out"):
    • Label, date, and inspect new materials as they are received
    • Keep records of dates of receipt and usage to help reduce overstock and material degradation
    • Inventory raw materials at least once per year
    • Consider computerizing your tracking system
  • Storage Conditions:  Maintain proper temperature, humidity, etc.  to reduce material degradation
  • Reduce the Number of Similar Products (e.g.  If you use several types of solvents, could fewer do the job? Reducing the number of solvents would improve inventory control and enhance recycling opportunities.)
    • Look for substitutes with longer shelf lives
    • Use waste exchanges for overstock, off-spec, or expired materials
    • Work with vendors to accept back excess, off-spec, or expired materials

Receiving Procedures

Good receiving procedures will prevent acceptance of shipments which are off-spec, incorrect, or improperly packaged, and reduce unnecessary waste generation, returns, and spills

  • Control all incoming materials by:
    • Receiving them in a specific, designated area
    • Designing the area to prevent and control release of materials
  • Train receiving dock employees on proper handling of shipments to prevent property losses, injuries, and costly waste disposal
  • Inspect shipments prior to acceptance:
    • Check for opened, damaged, or leaking containers
    • Check expiration dates and ensure proper labeling
    • Test for off-spec materials
    • Obtain MSDS if product is new
  • Use quality suppliers (quality and reliability are as important as cost):
    • Supplier should deliver goods intact and according to your specifications
    • Check the track record of your supplier with other companies or references
  • Review or create purchase agreements:
    • Specify terms and conditions for receiving material orders
    • Include provisions which allow you to inspect materials prior to acceptance
    • Address responsibility in the event of a release (Specify terms under which each party is responsible for cleanup or other expenses incurred to control an incident.)
  • Document agreements to ensure that specified procedures are followed (Remember, suppliers want your business and should be willing to ship on your terms.  If not, try to find another supplier or change products.)

Raw Materials Use & Handling

More efficient utilization of raw materials will reduce losses and unnecessary waste generation

  • Ensure that employees:
    • Use supplies only for their intended purpose
    • Use only the amount necessary
  • Keep frequently used hazardous materials near the site of use to minimize spills/accidents
  • Provide transfer methods which prevent spills and quality problems:
    • Pipelines for intermediate transfer
    • Gravity spigot or pump to dispense bulk liquid materials
    • A spout and funnel for transferring liquids to different containers
    • Proper connection/disconnection of hoses and lines
  • Control access to hazardous raw materials:
    • Designate central personnel to distribute materials
    • Limit access to employees trained in hazardous materials handling and who understand the importance of first-in first-out policy
  • Keep records of when and why larger spills occurred in order to identify spill prevention opportunities and document related costs

Proper Labeling

Proper labeling is extremely important to prevent accidents and extra disposal costs

  • Ensure proper labeling of all incoming materials as they are received (Include product name, weight, concentration, lot number, date, hazard class and any other information useful in tracking material location, quality, age or use.)
  • Always label hazardous waste at its point of generation where it can still be easily identified (Testing later to determine the contents is expensive.)
  • Label all stationary tanks, pipelines, etc.  containing hazardous materials or wastes
  • Label all portable "squeeze" bottles

Storage Areas

Well-designed hazardous materials and waste storage areas minimize and contain spills and provide for easy inspection of containers

  • Use high quality, resealable containers to prevent spills, evaporative losses, and contamination; and keep the lids/seals closed when not in use
  • Arrange raw materials storage with access to front and back of shelving so new materials can be placed behind older stock
  • Keep raw material and waste storage area aisles clear of obstructions:
    • Allow elbow room to access all containers easily and minimize spills
    • Space containers to allow inspection for corrosion and leaks
    • Maintain clear, even surfaces on pathways used by workers or equipment
  • Keep storage areas clean and well-lit
  • Stack containers no higher than recommended by manufacturer, in a way which minimizes the potential for tipping, tearing, puncture, or breakage
  • Don't stack equipment against containers
  • Make sure containers and shelving or storage areas are earthquake safe
  • Insulate electrical circuitry and check frequently for corrosion and potential sparking
  • Raise drums off floor to prevent corrosion from concrete "sweating"
  • Provide secondary containment and maintain proper distance between different materials
  • Install sloped concrete floors and curbs or berms for spill containment in areas such as vehicle maintenance
  • Cover outdoor storage areas to prevent contamination of storm water
  • Secure storage areas to minimize liability and hazards of intrusion or dumping

Hazardous Materials & Waste Stream Segregation

Use of simple segregation practices can prevent accidents or emergencies, reduce waste disposal costs, and enhance recovery/recycling opportunities

  • Segregate raw and waste materials
  • Segregate incompatible materials/wastes by hazard category to prevent reactions (e.g.   strong acids and bases)
  • Segregate hazardous from non-hazardous wastes (Never mix non-hazardous waste with hazardous waste - all of it becomes hazardous.)
  • Place distinct waste streams in separate containers and segregate containers holding different wastes
  • Segregate empty containers by prior contents
  • Set up manned collection centers to prevent unauthorized mixing of wastes

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