Recent EPA Inspection

Since 2004, EPA has spent more of its time on the more friendly approach to environmental compliance, that being voluntary audit agreements (http://www.epa.gov/region02/capp/cip/agree.htm).  Now that the audit agreements have largely come to a close, EPA appears to be getting back in the enforcement mode with a recent inspection at Lamont Doherty on July 29th.  The focus during the inspection was…surprise, surprise…hazardous waste/materials management.  The inspection focused on hazardous waste management practices both in lab satellite accumulation areas (i.e., where chemical waste is stored in the laboratory prior to pick-up) and in the main accumulation areas (i.e., where waste is stored after it is removed from the laboratories prior to transport and disposal).  The inspection went well and no violation notices are expected.  The inspector noted that the waste handling practices observed during inspections in the labs correlated closely with the content of the University’s safety training program and guidance documents. Through their ongoing efforts to integrate environmental health and safety requirements into their work, the labs were prepared. This should serve as a reminder that EPA (or any other regulatory agency) can make an unannounced inspection at any time and we must remain vigilant in our efforts to maintain a high level of compliance at all times.
We would also like to remind everyone of the training and education programs that we provide to ensure that the regulatory requirements for hazardous materials are made available to the University community and are applied in a consistent manner. 
The following safety training should be reviewed periodically:

Contact EH&S at any time with questions, concerns or ideas about safety, health and environmental issues.   

Shipping with Dry Ice-Safely, Legally

Solid carbon dioxide or dry ice, is commonly used during transit as a refrigerant to keep materials cold.  Shipments containing dry ice pose several hazards during transit, including a risk of explosion, suffocation and tissue damage.  Dry ice is therefore regulated as a “dangerous good” by the International Air Transport Authority (IATA) and the Department of Transportation (DOT).  To mitigate these hazards, several precautions must be taken when offering packages containing dry ice for shipment.

  • Packages must be allowed to ventilate to prevent the build-up of dangerous levels of pressure from sublimating carbon dioxide.
  • Packages must be of sufficient strength to withstand the rigors of transit and handling, including changes in temperature, humidity and altitude.
  • Dry ice must be shipped in containers compatible with its extremely low temperature; certain plastics can become brittle at these temperatures.
  • Packages must be labeled to indicate their contents.
  • Specific paperwork must be completed.

From Omaha Steaks and other perishable food products, to cell lines and tissue samples, the extremely low temperature of dry ice is ideal for in-transit refrigeration, as long as shipments are packaged, labeled and manifested properly. Personnel shipping packages containing dry ice shipment must complete a safety training program to understand the hazards of dry ice, and the requirements under IATA and DOT to mitigate those hazards.  A new training program has been developed, and is available via RASCAL, to access, go to the ‘Training Center’, select ‘Safety Courses’ and then select ‘Shipping with Dry Ice’ (TC0076).

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