For many years, Columbia University has managed peroxide-forming chemicals in accordance with New York City Fire Department (FDNY) requirements. A recent revision to FDNY’s requirements, creating alignment with a National Fire Protection Association (NFPA) consensus standard, brings a change in FDNY’s enforcement strategy and, consequently, impacts all laboratories operating in New York City. Effective immediately, all peroxide-forming chemicals must be dated at the time of opening for disposal within 6 months of the opening date. On or before the 6 month date, a request for disposal can be sent to EH&S @ http://vesta.cumc.columbia.edu/ehs/wastepickup/.
Historically, the FDNY rule required containers to be dated at the time of opening for disposal within 12 months. FDNY has been increasing its enforcement of the rule change for disposal after 6 month of opening, but is also allowing peroxide-forming chemicals to be tested within 6 months of the documented opening date. Laboratory personnel may test the chemical for the presence of peroxides and if deemed safe for continued use, with the test date documented on the container, the rule allows the laboratory 6 additional months of use (i.e., 12 months in total from initial opening) before disposal is absolutely required. Several commercially available test methods, including commonly used semi-quantitative test strips, are available from laboratory suppliers and testing procedures should be followed carefully when making an assessment as to whether a chemical is suitable for continued use. Laboratories must keep a record of and document their testing procedures.
FDNY rules, in fact, regulate all time-sensitive chemicals. EH&S is developing guidance for research laboratories to use in making assessments of common time-sensitive chemicals. Until guidance is released, please follow manufacturer’s recommendations for storage (including temperature), handling and shelf-life.
Further information, and a list of common time-sensitive chemicals, can be viewed on the EH&S website. Contact an EH&S Research Safety Specialist as soon as possible if you suspect a time-sensitive chemical has exceed the prescribed storage/use limits or is otherwise unsafe for use. Again, if a container is expired and/or no longer safe to use, EH&S must be contacted to arrange safe disposal (http://vesta.cumc.columbia.edu/ehs/wastepickup/).
Vacating a laboratory due to relocation or renovation requires a significant amount of planning and coordination. The amount of work and time involved in the vacating process may be stressful for the laboratory staff. EH&S will work closely with the laboratory’s designee(s), as well as Facilities Management & Space Planning, to help prepare for the safe and efficient turnover of the space and make the process simpler and faster.
The “Procedures for Vacating a Laboratory” instructions provide important reminders that guide the laboratory through the safety-related aspects of the process. These items include proper disposal/decontamination of radioactive material (RAM), proper disposition of controlled substances, and appropriate disposal of chemicals and regulated medical waste and sharps. Following the laboratory’s completion of the vacating procedures, EH&S will issue “Clearance” to your department and/or Facilities Management to proceed with the next steps in the vacating process. Please contact a Research Safety Specialist to help you in your preparation: http://www.ehs.columbia.edu/ LabAssignment.html.
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