UMass Boston 1st Year Status Report
June 28, 2001
Introduction
UMass Boston's Integrated Chemical Hygiene and Environmental Management (CH/EM) Plan was completed in October 2000. Since then, the Environmental Health & Safety Office (EH&S) Staff has been implementing the new plan through distribution of information packets, training, compliance audits and website postings. The new CH/EM Plan has been distributed to every laboratory worker who has received training in the new program and is available to all laboratory workers via the EH&S website.
The following is a summary of initial environmental performance as measured by the nine Environmental Performance Indicators (EPIs) described in the Project XL Final Project Agreement (FPA).
EPI#1: Outdated Chemicals on Shelves
To date, UMass Boston has not directly tracked the absence of outdated chemicals on laboratory shelves. Instead, we require comprehensive inventories of all laboratories and highlight generic categories of Hazardous Chemicals of Concern (HCOCs) in training sessions. To date, we have seen decreases in amounts of these types of material being disposed of (see EPI# 5).
Additionally, Principal Investigators (PIs) are asked to evaluate peroxide-forming chemicals and nitro compounds when completing the Monthly Laboratory Self-inspection Checklists. These compounds are the most prevalent and problematic HCOCs that we have on campus.
EPI#2: Inventory/Hazardous Chemicals of Concern (HCOCs)
UMass Boston has designated the following chemicals as HCOCs. As described above, laboratory workers receive guidance with respect to the management of these chemicals during the Ch/EMP training.
EPA P-listed wastes
OSHA Special carcinogens
OSHA Teratogens/Reproductive toxins
OSHA designated highly toxic substances
Explosive nitroarenes
Peroxide-forming chemicals
Pyrogens
Shock-Sensitive Explosives
The EH&S Office has tagged or highlighted these materials on inventory sheets for each laboratory. However, the current system for conducting the chemical inventory is undergoing significant change. Under the old system, the EH&S Office generates, in August, a chemical inventory list for each lab from its database and sends it to all Principal Investigators. PI's have one month to update lists, sign them, and return them to EH&S for input into a central database. In the past, this manual process has taken an enormous amount of time for the PIs and EH&S staff. The typical update time period from start to finish has taken as much as 18 months. To minimize this problem and create more accurate inventories, EH&S is in the process of implementing ChIM 5.2, a new chemical bar code based tracking system on a lab-by-lab basis. We believe that the bar code system will speed up collection of our inventories and provide us with more accurate and reliable data. This tracking system will also likely enhance the ability EH&S to identify potential pollution prevention and redistribution opportunities. The new system will also be much quicker, more efficient, and will allow EH&S to track chemicals from lab to lab. The current number of laboratories on campus is 122.
Currently, EH&S is testing the efficacy of the software with a pilot project based on the labs under the supervision of one professor, who oversees 5 very active labs in the Chemistry Department at UMass. The pilot was implemented in the fall of 2000, and has returned promising results which indicate that the barcoding system will indeed have each of the aforementioned benefits for our inventory management. EH&S hopes to have this new system in place for each laboratory by the end of 2001. In the meantime, we do not plan on conducting our annual inventory update because all of our resources will be carrying out the barcoding effort. We should have completed a campus-wide inventory/HCOC Survey by January 2002.
EPI#3: Pollution Prevention Assessments
The focus of both the EH&S Office and the Chemical Hygiene Committee has been training. During training, emphasis is placed on pollution prevention and researchers are encouraged to incorporate minimization into their everyday work pollution prevention ideas such as product substitution, limited purchasing and waste minimization. We encourage researchers to examine, during the experimental design phase, the materials they are working with to determine if there are better alternatives. If not, we remind them to purchase only what they need. Finally, we suggest that they determine whether or not a treatment method that can be incorporated at the end of the experiment.
Another campus-wide initiative currently underway is a mercury thermometer swap and a registration process for any remaining mercury containing devices. The Chemical Hygiene Committee is developing the campus-wide program. To date, a number of departments have been slowly replacing mercury-containing thermometers. The Chemical Hygiene Committee is documenting this activity as well as insuring that all mercury-containing thermometers are replaced. In those instances where replacement is not possible, or the device is not a thermometer, the mercury containing device and its location will be registered with the Committee and the information maintained in a database.
The Committee will be meeting in July 2001 to determine the next P2 priority area(s).
EPI#4: Re-Use and Redistribution
In January 2001, EH&S sent out a pamphlet to all PIs describing the purpose of a re-use and redistribution program. A formal reuse and redistribution has never been in place prior to the XL Project. The pamphlet also contained a tear-off sheet for PIs to fill out and return to EH&S if they had any material available. We have also been introducing the idea and promoting the program during our training sessions.. EH&S obtains information concerning redistribution possibilities from direct mail, email, departmental postings, laboratory decommissionings and laboratory waste pickups. Approximately twenty (20) liters of materials have been collected and EH&S is in the process of developing an inventory. By September 2001, when the new EH&S storage area is in place, we will publish a list of materials available for redistribution on our website so that it will be accessible at any time. When materials are identified as potentially re-useable, they will be labeled with the date. Each time they are used, they will be tracked by EH&S. If materials are in storage for more than two years, they will be disposed of.
EPI#5: Hazardous Waste Generation
A determination of total laboratory wastes, in pounds, was generated for the calendar year 1999 and 2000 (Table 1), from University manifests and the biennial report. For the year 1999, the University generated 5584.76 pounds of laboratory waste. In the year 2000, the total pounds of laboratory waste generated has decreased to 4928.23 pounds which is equivalent to an 11.76% decrease when compared to 1999 data. The decrease can be attributed primarily to smaller numbers of acutely hazardous wastes, organic peroxides, pyrophorics, flammable liquids and compressed gases. There were slight increases in overall amounts of corrosives, flammable solids and oxidizers.
EPI#6: Environmental Awareness Survey
In order to measure general environmental awareness on campus among faculty, staff, and students, a survey was distributed in April of 2000. Results were tabulated in the summer of 2000, and are posted on the EH&S web site. A second survey was distributed in February of 2001, rather than in April, to allow for a broader, more general sampling of the population, to determine if environmental awareness on campus has improved or remained the same. Unfortunately, despite our best efforts to induce a large return of the distributed surveys, EH&S has received just over 50 completed surveys. The returned surveys have been tallied and results are shown in Table 2. EH&S will continue throughout the month of July to collect additional surveys so that overall results will be comparable to last year. These partial results suggest…
EPI#7: Training
Prior to formal training, EH&S formulated and distributed summary pamphlets about Project XL and specifics about laboratory waste collection to members of each relevant department at the beginning of October.. In addition, EH&S has also posted new signage in each lab consistent with the CH/EM Plan and distributed new tie-on laboratory waste tags.
EH&S began notifying all relevant departments in September 2000 that training would begin at the end of October of 2000. At that time, we asked departments to identify individuals, particularly students, who needed training. EH&S already maintains a list of all Principal Investigators (faculty and staff) so we directly contact them when the need arises. Training in the new CH/EM Plan for all faculty, staff, graduate students and undergraduates who work alone in laboratories began at the end of October 2000, and continued over the next several months. The training program is a general introduction to the new regulations set forth in the CH/EM planand is carried out predominantly on a lab-by-lab basis. Each trained lab workers receives a copy of the CH/EM Plan. When feasible, EH&S has trained groups from departments in a single session. Each session lasts for roughly one to one and a half hour. Our goal was to have all laboratory personnel trained in the CH/EM Plan by March of 2001. We have since discovered that this was a far too ambitious goal. As of June 2001, EH&S has trained the Anthropology, Physics, and some of the Chemistry and Biology departments. Training for the ECOS, Psychology, and remaining members of the Chemistry and Biology departments will be completed at the beginning of the fall semester of 2001. EH&S estimates that there are approximately 200 laboratory personnel from these departments. Since October, 146 people have been trained. Based on our past experiences, the rate at which laboratory workers are receiving relevant training is greatly compressed. In the past, it took as many as 18 months to conduct all the training. We anticipate that the majority of those remaining to be trained will be captured within the first two weeks of the Fall 2001 semester (first two weeks in September 2001).
EH&S is also in the process of building a more accurate training database. We have sent out forms to the PIs asking them to identify all laboratory personnel under their supervision that require training. EH&S will enter the information into a database. We will then be able to generate the information on a semester-by-semester basis for the PI to update, thus insuring that our training records are accurate and up-to-date.
EPI#8: Program Effectiveness
The following list represents a review of the goals of the XL Program as set for in the Project XL FPA.
- EPI#1 It appears as though there is a sharp decline in outdated chemicals in laboratory--however, it has not been directly measured to date.
- EPI#2 The EH&S Office has a complete chemical inventory on file. It needs to be updated but will be delayed until January 2002 when the new barcoding system is in place.
- EPI#3 Campus-wide mercury thermometer replacement and mercury-containing device registration is underway. The next round of assessments will be identified by July 2001 by the Chemical Hygiene Committee.
- EPI#4 The amount of laboratory waste collected for reuse has increased substantially, however the amount of laboratory waste reused or redistributed has not yet increased by 20%.
- EPI#5 The amount of laboratory waste disposed of decreased by 11.76% in 2000.
- EPI#6 The Environmental Awareness Survey was completed and the partial results demonstrate that
- EPI#7 The number of laboratory workers trained increased significantly from previous years and currently approximately 75% of the total number of laboratory workers have been trained in the CH/EM Plan.
- EPI#8 Some EPIs are on-track (decrease in laboratory waste disposal, outdated chemicals, internal and external audits); others need more attention (pollution prevention, environmental awareness surveys).
- EPI#9 Both external and internal audits show significant compliance with the Minimum Performance Criteria of the XL Regulation.
EPI#9: Conformance with the EMP
Conformance with the UMass Boston CH/EM Plan has been measured internally by the EH&S Office staff and externally by auditors from the Campus Consortium for Environmental Excellence (C2E2). Summaries of the two audits are given below:
External Audit Report
The external audit was conducted on April 4th, 2001, by Tom Balf of the C2E2, and David Messier from Worcester Polytechnic Institute and the C2E2. The audit included one anthropology lab, three biology labs, four chemistry labs, three ECOS labs, and two psychology labs. In conducting the audit Mr. Balf and Mr. Messier evaluated labs conformance with the Minimum Performance Criteria Protocol. The most common and consistent problem observed during the audit concerned labeling. In many cases, the laboratory waste "tie on" labels were filled out incompletely or incorrectly, or were not being used at all. Other common problems were uncapped bottles and monthly container inspection checklists that were not filled out.
Internal Audit Report
The internal audit began in June of this year, and is currently being conducted by EH&S personnel. Thus far, roughly two thirds of the laboratories on campus have been audited. The common problems that were observed a few months earlier in the external audit have disappeared for the most part, which can be attributed to increased emphasis during training on these issues. The problems EH&S has observed thus far have included a few open containers and improperly filled out laboratory waste "tie-on" tags. The most common problem with the tags has been that laboratory workers are identifying the date the waste bottle started to accumulate waste, rather than the date container is deemed full or ready for pick-up. All deficiencies were immediately corrected. Qualitatively, however, the internal audit appears to show that management of laboratory waste and adherence to the CH/EM Plan regulations has improved dramatically. EH&S is also working to tailor the training sessions to address the lingering problems.
| Key Objectives and Targets | Status |
|---|---|
| Development of new Integrated Chemical Hygiene and Environmental Management (CH/EM) Plan | Complete (August 2000) |
| Develop training materials for CH/Em Plan by October 2000 | Complete |
| Training of all laboratory personnel by March 2001 | To be complete by September 2001 |
| Roll out redistribution/re-use program by January 2001 | Posted to EH&S website by September 2001 |
| Design of new centralized chemical storage | Complete (March 2001) |
| Building of new centralized chemical storage area | On-target to be complete by September 2001 |
| Identify and replace or register elemental mercury-containing instruments | On-target to be complete by September 2001 |
TABLE 1
University of Massachusetts Boston
Laboratory Waste Generation Data
Total Pounds
| Waste Stream | 1999 | 2000 |
|---|---|---|
| Labpack with poisons | 192.83 | 350.05 |
| Labpack with corrosives | 1161.46 | 1520.16 |
| Labpack with acutely hazardous wastes | 31.48 | 14.43 |
| Labpack with misc. hazardous waste | 739.57 | 413.53 |
| Labpack with organic peroxides | 19.87 | 0.00 |
| Labpack with spontaneously combustible material | 11.68 | 30.21 |
| Labpack with pyrophorics | 21.34 | 0.00 |
| Labpack with flammable liquids | 2470.02 | 1655.83 |
| Labpack with flammable solids | 11.70 | 47.10 |
| Labpack with oxidizers | 148.48 | 249.04 |
| Compressed gases and aerosols | 264.27 | 60.41 |
| Non-hazardous/non-regulated waste | 512.07 | 587.47 |
| TOTAL | 5584.76 | 4928.23 |
| Difference | 656.53 lbs | |
| % Difference | -11.76 % |
TABLE 2
Survey Results–2001
| 2000 | 2001 | |
|---|---|---|
| Number of Respondents | 87 | 54 |
| 1. Which federal agency regulates the disposal of chemical wastes: | ||
| a. Occupational Safety and Health Administration | 25 | 13 |
| b. Environmental Protection Agency | 42 | 81 |
| c. Department of Transportation | 9 | 6 |
| d. National Institutes of Health | 11 | 0 |
| 2. Ultimately, most chemical wastes generated in laboratories are: | ||
| a. incinerated | 28 | 17 |
| b. sent to a landfill | 13 | 6 |
| c. released to a sewer | 20 | 28 |
| d. treated | 27 | 49 |
| 3. What are the four main reasons researchers should keep containers of laboratory waste securely closed except when adding chemicals? | ||
| 1 reason | 54 | 15 |
| 2 reasons | 12 | 26 |
| 3 reasons | 17 | 36 |
| 4 reasons | 0 | 23 |
| 4. Which costs more, purchase or disposal of laboratory chemicals? | ||
| a. disposal costs more | 44 | 82 |
| b. purchase costs more | 21 | 4 |
| c. costs are roughly the same | 22 | 14 |
| 5. In the book, "Prudent Practices in the Laboratory", what is the preferred waste management hierarchy for pollution prevention? Use a scale of 1-4 with 1 being the preferred management method. | ||
| Source Reduction | 0 | 70 |
| 6. What is the proper way to dispose of strong mineral acids? | ||
| a. Dilution with water | 23 | 14 |
| b. Neutralization with lime | 29 | 26 |
| c. Collection for pick-up by hazardous waste personnel | 7 | 60 |
| d. Mixing with organic chemicals | 7 | 0 |
| 7. What is the maximum amount of acutely hazardous laboratory waste that your laboratory is allowed to accumulate? | 31 correct | 42 correct |
| 8. What emergency response equipment is available in your laboratory to respond to a hazardous chemical spill? | ||
| 0 | 14 | 19 |
| 1-3 items | 68 | 72 |
| 4-6 items | 7 | 9 |
| 7 items | 0 | 0 |
| 9. How is waste water from your laboratory buildings treated? | ||
| a. Purification before release to the sewer | 21 | 7 |
| b. pH is controlled by acid neutralization, then released to the sewer | 32 | 37 |
| c. Diluted with the rest of the building's water, then goes to the sewer for municipal treatment by aerobic digestion | 22 | 56 |
| 10. In general, how are fume hood emissions controlled in your laboratory? | ||
| a. Filtration to remove particles | 27 | 16 |
| b. Carbon filtration to remove gases | 26 | 19 |
| c. Dilution with laboratory room air | 21 | 65 |
| 11. The last time you needed health and safety information about a particular chemical, what resource(s) did you use? | ||
| 0 responses | 15 | 24 |
| 1 response | 41 | 41 |
| 2 responses | 15 | 24 |
| 3 responses | 4 | 11 |
| 12. Typically, what is the largest environmental impact of laboratory work? | ||
| a. release of toxic chemicals through the fume hood | 13 | 7 |
| b. disposal of toxic chemicals with a hazardous waste disposal company | 22 | 22 |
| c. release of chemicals to the sewer system | 28 | 57 |
| d. energy use to cool or heat laboratory space | 13 | 14 |
| 13. The last time you disposed of laboratory hazardous waste, what four pieces of information did you put on the label? | ||
| 0 | 19 | 28 |
| 1-3 | 23 | 70 |
| 4-6 | 29 | 2 |
| 14. What document(s) describes how to dispose of laboratory hazardous waste at your institution? | 0 correct responses (The Environmental Management Plan had not yet been publicized in campus laboratories) | 51 |
| 15. What is your current role in your laboratory? | ||
| Faculty | 19 | 15 |
| Staff - Administrator | 5 | 1 |
| Staff - Lab Tech | 9 | 9 |
| Graduate Student | 12 | 16 |
| Undergraduate Student | 39 | 12 |
| 16. How many years have you been working in college or university laboratories? | ||
| less than 1 year | 34 | 28 |
| 1-2 years | 18 | 18 |
| 3-5 years | 8 | 16 |
| more than 5 years | 24 | 38 |
| 68% of respondents in 2001 report having attended a EH&S training session on the CH/EM Plan |
