The Environmental Protection Agency (EPA) performs periodic compliance audits for air emissions, asbestos, lead-based paint, pesticides, PCB's, hazardous waste, regulated medical waste, waste water, universal waste, bulk chemical storage, oil storage, storm water, used oil and more.
Common issues found during previous audits include:
- Failure to perform hazardous waste determinations on several materials including lead solder, stains, fixers and developers
- Improper labeling of hazardous waste
- Most commonly, the UB Hazardous Waste Label was not used and therefore the words “Hazardous Waste” were mission from the label
- Label not completely or properly filled out
- Stock chemical labels were degraded, illegible or missing
- Failure to keep hazardous waste containers closed (i.e., waste stored in open containers)
- Sateliite aaccumulation area (SAA) not located “at or near” the point of generation (i.e., movement of waste between rooms)
- In a few instances, failure to declare accumulated materials as waste (i.e., stockpiles of chemicals that are clearly not being used but have not been labeled as waste)
- Several lab samples were being stored in the same secondary containment bin as hazardous waste. Waste should be separated from all usable chemicals.
- Unlabeled or poorly labeled unknowns
- Storage of wastes by compatibility
- Used oil labeled as “hazardous waste” rather than “used oil” (corrected on site)
Principal Investigators and Lab Managers are responsible for making sure that incoming personnel are properly trained on the specific procedures related to handling hazardous waste in each lab. It is important to identify new people in the laboratory who need hazardous waste training and personnel who need a refresher class. EH&S hold regular training classes on laboratory safety.