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Is the water that comes out
of the safety showers held in a tank or does it come directly from the main
water supply? I know nothing about safety showers but I heard once that th
e water comes from a holding tank. If this is the case then <
/font>couldn't
the water be redirec
ted back into the tank for proper disposal if there is concern of contamination? I agree
that the berm would be a tripping hazard but it would also prevent chairs
, tables, and desks from being stored under the safety shower also. I c
an't tell you how many times I have walked into the lab and seen various th
ings stored under the safety shower or directly blocking access to it.
; 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 tra
ce
amounts of hazardous materials from going down the drain. <
/span> Thanks =85 M.A From: DCHAS-L Discussion
List [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of Alan McCartney I might be mistake
n, but the
placement of the berm, will violate the life safety code (and rleated bul
ding
codes) regarding smooth, trip free walking surfaces. I believe this limit
ation
is 1/8".
On top of this, this triping hazard will directly compound & negati
vely
affect the worker's compensation exposure for the associated employees.
I would think that the this trumps the local water / sewer inspectors reque
st.
Alan On Mon, Nov 1, 2010 at 9:18 AM, Williams,
Mark <Mark.Williams**At_Symbol_Here**t
eledynees.com>
wrote: Thank you for the
citation, Rob! Mary, if you run across
the letter of interpretation sometime in the future, would you post it he
re for
us? Thanks Mark
Williams Teledyne
Energy Systems Inc. 38 Loveton
Cr Sparks MD
21152 410-472-7733 From: ILPI [mailto:info**At_Symbol_Here**ILPI.COM] Excellent.
With that lead from Mary, I was able to look up where shower wate
r is
apparently exempted: http://edocket.access.gpo.gov/
cfr_2005/julqtr/40cfr261.3.htm Sec. 261.3 Definition of
hazardous waste. (snip) 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 t
he
generator can demonstrate that the mixture consists of wastewater the disch
arge
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 eliminat
ed
the discharge of wastewater) and; (snip) (D) A discarded
commercial chemical product, or chemical intermediate listed in Sec. 261.
33,
arising from de minimis losses of these materials from manufacturing operat
ions
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 mater
ials
from bins or other containers, leaks from pipes, valves or other device
s 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 a
nd
rinsing and cleaning of personal safety equipment; and rinsate from e
mpty
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 ========
=========================
===================== Safety Emporium -
Lab & Safety Supplies featuring brand names you know and
trust. Visit us at http://www.SafetyEmporium.com esales**At_Symbol_Here**safetyemporium.com
or toll-free: (866) 326-5412 Fax: (856)
553-6154, PO Box 1003, Blackwood, NJ 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 POT
W is
requiring it. From: DCHAS-L
Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIS
T.UVM.EDU] On
Behalf Of Alan Hall Subject: Re: [DCHAS-L] Lab safety showers<
/p>
I
agree with Rob Torecki, 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. Th
at's
16 square feet, one inch high, for a volume of 1.33 cubic feet = 10 g
allons.
Under ANSI Z358, showers must put out at least 20 gallons per min
ute.
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 hal
lway
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. Seriou
sly -
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 th
inks
it's better to spread the hazmat all over the building and down a couple fl
oors
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
. Rob
Toreki =======
=========================
====================== Safety
Emporium - Lab & Safety Supplies featuring brand names you
know and trust. Visit us at http://www.SafetyEmporium.com esales**At_Symbol_Here**safetyemporium.com or
toll-free: (866) 326-5412 Fax:
(856) 553-6154, PO Box 1003, Blackwood, NJ 08012 On
Oct 28, 2010, at 2:31 PM, Betsy Shelton wrote:
--
Betsy Shelton
______________________________________________________________________ Amber
Potts
Date: Tue, 2 Nov 2010 13:16:24 -0700
From: ms.alnajjar**At_Symbol_Here**PNL.G
OV
Subjec
t: Re: [DCHAS-L] FW: Lab safety showers
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Sent: Tuesday, November 02, 2010 10:50 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] FW: Lab safety showers
Sent: Thursday, October 28, 2010 9:33 PM
Subject: Re: Lab safety showers
Sent: Thursday, October 28, 2010 3:15 PM
Date: Thu, 28 Oct 2010 14:55:20 -0400
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 yo
u
dilute them with 15 minutes **At_Symbol_Here** 20 gallons/minute = 300 gallons of w
ater.
Alan
Alan H. Hall, M.D.
From: info**At_Symbol_Here**ILPI.COM
Subject: Re: [DCHAS-L] Lab safety showers
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.
Best regards,
512.636.1905
retrosynthesis**At_Symbol_Here**gmail.com
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