To be
honest with all those who are interested in this topic, the berm idea
does not make any sense considering the rare events where showers are
used. As it was mentioned, the hazardous materials are so diluted
that it is not logical to flood the floor (building) for the sake of
preventing trace amounts of hazardous materials from going down the
drain.
Thanks =85
M.A
I might be mistaken, but the placement
of the berm, will violate the life safety code (and rleated bulding
codes) regarding smooth, trip free walking surfaces. I believe this
limitation is 1/8".
On top of this,
this triping hazard will directly compound & negatively affect the
worker's compensation exposure for the associated employees.
I
would think that the this trumps the local water / sewer inspectors
request.
Alan
On Mon, Nov 1,
2010 at 9:18 AM, Williams, Mark <Mark.Williams**At_Symbol_Here**teledynees.com<
/a>> wrote:
Thank you for
the citation, Rob!
Mary, if you
run across the letter of interpretation sometime in the future, would
you post it here for us?
Thanks
Sec. 261.3 Definition of hazardous
waste.
however, the following
mixtures of solid wastes and hazardous wastes listed in subpart D of
this part are not hazardous wastes (except by application of paragraph (a)(2)(i) or
(ii) of this section) if the generator can demonstrate that the mixture
consists of wastewater the discharge of which is subject to regulation
under either section 402 or section 307(b) of the Clean Water Act
(including wastewater at facilities which have eliminated the discharge
of wastewater) and;
(D) A discarded commercial chemical product, or chemical
intermediate listed in Sec. 261.33, arising from de minimis losses of
these materials from manufacturing operations in which these materials
are used as raw materials or are produced in the manufacturing
process.
For purposes of this
paragraph (a)(2)(iv)(D), ``de minimis'' losses include those from normal
material handling operations (e.g., spills from the unloading or
transfer of materials from bins or other containers, leaks from pipes,
valves or other devices used to transfer materials); minor leaks of
process equipment, storage tanks or containers; leaks from well
maintained pump packings and seals; sample purgings; relief device
discharges; discharges from safety
showers and rinsing and cleaning of personal safety equipment; and rinsate from empty
containers or from containers that are rendered empty by that rinsing;
or
(E) Wastewater resulting from laboratory operations
containing toxic (T) wastes listed in subpart D of this part, Provided,
That the annualized average flow of laboratory wastewater does not
exceed one percent of total wastewater flow into the headworks of the
facility's
wastewater treatment or
pre-treatment system or provided the wastes, combined annualized average
concentration does not exceed one part per million in the headworks of
the facility's wastewater treatment or pre-treatment facility. Toxic (T)
wastes used in laboratories that are
demonstrated not to be discharged to wastewater are not to be included
in this calculation; or.....
Rob
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Safety Emporium - Lab & Safety Supplies
featuring brand names
Fax:
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08012
On Oct 28, 2010, at 5:54 PM, Mary Cavanaugh
wrote:
I don=92t have time to dig it up right now, but
there is an EPA letter of interpretation that says that runoff from an
emergency drench shower is not hazardous waste. So containment is
only necessary if your local POTW is requiring
it.
I agree with Rob Torecki,
This is a
senseless regulation that would do much more harm than
good, and presents a slip-and-fall hazard full time, not just
when the emergency shower is in use.
I also agree with how
dilute most chemical splashes would be by the time you dilute them with
15 minutes **At_Symbol_Here** 20 gallons/minute = 300 gallons of
water.
Alan
Alan H. Hall, M.D.
Date:
Thu, 28 Oct 2010 14:55:20 -0400
From:
info**At_Symbol_Here**ILPI.COMSubject: Re:
[DCHAS-L] Lab safety showers
Wow, thanks for sharing. That one
is a poster child for Bad
Regulations.
1. Let's say the berm encompasses a 4' x 4' area
around the shower. That's 16 square feet, one inch high, for a
volume of 1.33 cubic feet = 10 gallons. Under ANSI Z358, showers
must put out at least 20 gallons per minute. And that shower is
likely to flow for 5, if not 15 minutes. So the berm is
essentially useless.
Now, if the reg is calling for a berm that say,
stretches across an entire hallway or doorway - heck, or just around the
drain itself, that might work by flooding the rest of the building, as
all it does is make the floor drain non-functional. Plugging the
floor drain permanently is an easier
solution.
2. The amount of hazardous material on a victim
is going to be so exceedingly small and so diluted in the drains that it
boggles the mind. Seriously - you get what, 10 mL of concentrated
acid on you and that washes down the drain with 100 gallons of water?
Yeesh. And if the stuff was so nasty toxic that it is a
hazard even that dilue, this city review department thinks it's better
to spread the hazmat all over the building and down a couple floors onto
various objects and people than it is to send it down the
drain.
3. When you're blinded by something and trying to
find a shower on foot or on a wheelchair, even that 1" sloped bump is a
barrier. And no doubt a trip hazard the rest of time no matter how
well it's marked with floor
tape..
<
div>
=============
=========================
================
Safety Emporium - Lab & Safety Supplies
featuring brand names
Fax: (856) 553-6154, PO Box 1003, Blackwood, NJ
08012
On Oct 28, 2010, at 2:31 PM, Betsy Shelton
wrote:
I am currently involved
in construction of two new laboratories and was instructed by the city
commercial building review department to include a 1" high curb around
the shower area to keep hazmat from entering the floor drain in the
event of a spill. Also, the curb has to be sloped on both sides to
allow accessibility.
--
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