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Subject: Re: [DCHAS-L] Safety Showers, Drains and ADA Compliance
Date: Tuesday, March 13, 2018 at 9:38:09 AM
Author: Joseph M. Crockett <jcrocket**At_Symbol_Here**BRIDGEWATER.EDU> 		Next by Date:
Subject: Re: [DCHAS-L] Safety Showers, Drains and ADA Compliance
Date: Tue, 13 Mar 2018 14:01:06 +0000
Author: Wayne Wood

From: ILPI Support <info**At_Symbol_Here**ILPI.COM>
Subject: Re: [DCHAS-L] Safety Showers, Drains and ADA Compliance
Date: Tue, 13 Mar 2018 09:53:43 -0400
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU>
Message-ID: 508A90B3-F671-4832-A90A-28FD31D98175**At_Symbol_Here**ilpi.com
In-Reply-To


Wow, that's been asked and answered here so many times.  Safety shower wastewater is a de minimis allowed loss.   I had to search for the updated US Code reference as they changed the numbering, but for solid wastes it is currently 40 CFR 261.3(a)(iv)(D).  https://www.law.cornell.edu/cfr/text/40/261.3 to wit:


(iv) It is a mixture of solid waste and one or more hazardous wastes listed in subpart D of this part and has not been excluded from paragraph (a)(2) of this section under =A7 =A7 260.20 and 260.22, paragraph (g) of this section, or paragraph (h)of this section; 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 hazardous waste, commercial chemical product, or chemical intermediate listed in  =A7 =A7 261.31 through 261.33, arising from de minimis losses of these materials. For purposes of this paragraph (a)(2)(iv)(D), de minimis losses are inadvertent releases to a wastewater treatment system, including 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 wellmaintained 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. Any manufacturing facility that claims an exemption for de minimis quantities of wastes listed in  =A7 =A7 261.31 through 261.32, or any nonmanufacturing facility that claims an exemption for de minimis quantities of wastes listed in subpart D of this part must either have eliminated the discharge of wastewaters or have included in its Clean Water Act permit application or submission to its pretreatment control authority the constituents for which each waste was listed (in 40 CFR 261 appendix VII) of this part; and the constituents in the table "Treatment Standards for Hazardous Wastes" in 40 CFR 268.40 for which each waste has a treatment standard (i.e., Land Disposal Restriction constituents). A facility is eligible to claim the exemption once the permit writer or control authority has been notified of possible de minimis releases via the Clean Water Act permit application or the pretreatment control authority submission. A copy of the Clean Water permit application or the submission to the pretreatment control authority must be placed in the facility's on-site files; or

Rob Toreki

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On Mar 13, 2018, at 9:12 AM, Nickie Norton <nnorton**At_Symbol_Here**SHEPCHEM.COM> wrote:

We were not allowed to have floor drains at my previous employer because that would allow contaminated water to enter the sewer system.  The intent was to collect the water and properly dispose of it rather than have it go down the drain..
 
Nickie Norton
Research Chemist
The Shepherd Chemical Company
4900 Beech Street
Norwood, OH  45212
513-842-9332
 
 
 
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of GOODE, SCOTT
Sent: Monday, March 12, 2018 10:36 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Safety Showers, Drains and ADA Compliance
 
 
=================
Scott Goode, Distinguished Professor Emeritus
Fellow of the American Chemical Society, ACSF
Department of Chemistry and Biochemistry
University of South Carolina
631 Sumter Street
Columbia SC 29208
 
Mobile: 803-622-1060
 
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Pam
Sent: Monday, March 12, 2018 5:48 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Safety Showers, Drains and ADA Compliance
 
Debbie
 
I second that motion 
 
There have been a number of people who are in the process of building new labs. I personally wish I had know some of the points made before our new building went up.
 
How about Lab design with Safety in Mind.
 
The second topic that has been of great interest to be is the confluence of ADA and safety. There was discussion of  service dogs .. I have worked with hearing impaired students who could not hear auditory alarms and have asked that we also have visual alarms in place. 
 
Pam
 
Pamela Auburn, PhD
2041 Branard
Houston TX 77098

 

From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**PRINCETON.EDU> on behalf of Debbie M. Decker <dmdecker**At_Symbol_Here**UCDAVIS.EDU>
Sent: Monday, March 12, 2018 12:11 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Safety Showers, Drains and ADA Compliance
 
I think that's a great suggestion and a good fit for Orlando.  I'd be happy to collaborate on a symposium on this topic.
 
Debbie
 
Debbie M. Decker, CCHO, ACS Fellow
Past Chair, Division of Chemical Health and Safety
Councilor and Programming Co-Chair
University of California, Davis
(530)754-7964
(530)304-6728
 
Birkett's hypothesis: "Any chemical reaction
that proceeds smoothly under normal conditions,
can proceed violently in the presence of an idiot."
 
 
 
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Wilhelm, Monique
Sent: Saturday, March 10, 2018 7:33 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Safety Showers, Drains and ADA Compliance
 
There are always so many questions about safety showers and eye washes.  I think that we need to have a symposium on them-.I will have to remember this for Orlando
 
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Bruce Van Scoy
Sent: Thursday, February 1, 2018 6:07 PM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Safety Showers, Drains and ADA Compliance
 
Melissa,
Push for the drains!  Show the cost over time of having testing performed at the recommended frequency without them vs. having them.  My experience has shown when the drains were removed due to initial installation costs (proposed as "value engineering"), it wasn't too long after that they were screaming about the frequency of performing flushing/testing.  If memory serves, I provided a CDC reference about the eye-damaging bacteria that reproduce in stagnant pipes with the presence of chlorine.  The architects and accountants were not available later to justify or defend their "value engineering" decisions, but the initial construction cost did save a few dollars.  My recommendation is to push for the drains or define accountability standards to apply later, e.g., is installation cost v. recovery in 1-yr or 5-yr?
BruceV   
 
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU] On Behalf Of Suzanne Howard
Sent: Thursday, February 1, 2018 10:54 AM
To: DCHAS-L**At_Symbol_Here**PRINCETON.EDU
Subject: Re: [DCHAS-L] Safety Showers, Drains and ADA Compliance
 
Hi Melissa,
We are in the process of designing a new science bldg and was told that we can't have drains for the safety showers and the eyewashes.  Our architects state the reason is that the size of the drains would have to be very large.....?  They also indicate that the cost for plumbing is too great.  Have not yet decided if EHS should push for drains or not, or, if it is even possible. 
Suzanne
 
-- 
Suzanne Howard
Director EHS
Wellesley College
300 Central Street
Wellesley, MA
781-283-3882
 
On Thu, Feb 1, 2018 at 10:21 AM, Melissa Anderson <mwanderson08**At_Symbol_Here**gmail.com> wrote:
Greetings Everyone,
 
We're working with architects right now to plan out chem labs for a new science building. We've asked for drains under the safety showers and were told that wouldn't be possible because in order to be ADA compliant and have drains, the safety showers would take up too much space- has anyone encountered such an argument? 
 
(Note, we're extremely constrained on space due to some very complicated politics I won't go into here, so making the labs bigger is not an option.)
 
Thanks,
Melissa Anderson
Instructor
Pasadena City College
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