Chemical Engineering December 2010 - 45

affect chemical reactions or final product
properties. Overall, the CPI have
done a good job utilizing continuous
improvement techniques to manage
their supply chains.
Once received, the materials must
be stored in accordance with local,
state and provincial regulations, or
the International Code Council's
(ICC) International Building and International
Fire Codes, and handled
in accordance with company EH&S
procedures. In the U.S., handling
must follow the Occupational Health
& Safety Admin.'s (OSHA) Code of
Federal Regulations (Title 29 CFR
1910.1200), which covers Hazard
Communication Standards (HCS),
the federal Risk Management Program
for certain highly toxic chemical
compounds regulated under the
Clean Air Act, and the Chemical Hygiene
Standard for laboratories (Title
29 CFR 1910.1450).
Production and laboratory use
As materials move into the second
phase of the lifecycle - use in a production
environment or laboratory -
the potential for handling errors increases.
Although industrial users and
researchers are concerned with, and
trained in, safe handling procedures
for hazardous materials, they are less
likely to focus on storage and removal.
This leads to some potential problems
in chemical lifecycle management.
Chemicals are generally well managed
in production environments
since production procedures are welldefined
and engineered. Failure most
often results from human error or
system breakdowns. Although the
results can be catastrophic, they are
largely preventable through adherence
to established EH&S procedures,
effective maintenance practices and
frequent training.
Research environments are less
systematized, which presents greater
opportunity for errors. Researchers
often work independently on projects
and they use smaller quantities of a
greater number of chemicals. This
presents an exponentially higher
number of possible chemical reactions
and storage issues.
Working alone or on small teams,
researchers often neglect to properly
label chemicals in secondary containers
at their stations. Unlabeled or improperly
labeled chemicals violate hazardous
communication (Hazcom) regulations.
Informal practices also lead to
the potential for abandoned chemicals
as researchers move on to other jobs or
projects. Unidentified chemicals may
require testing, special handling and
expensive disposal if they cannot be
verified by the researcher.
Consistency and training, supported
by accurate, up-to-date labeling
and recordkeeping, are key
ingredients to a successful chemical
management program.
Post-use
Handling of solvents, catalysts and
other chemicals can become much
more problematic once they have
been used in a production or laboratory
process. They are no longer in
their original containers and are often
combined with other substances. In
the U.S. for example, OSHA, the Environmental
Protection Agency (EPA),
Dept. of Transportation (DOT) and, in
some cases, Drug Enforcement Admin.
(DEA) regulations also come into play.
A few important fundamental facts
must be kept in mind at all times: In
the U.S., all chemical storage areas
fall under Resource Conservation and
Recovery Act (RCRA) regulations and
are subject to inspection by regulators.
To comply with that, a limited number
of conveniently positioned and properly
organized satellite accumulation
areas (SAAs), under the control of the
EH&S or chemical hygiene manager,
should be set up near production or
research areas.
There are a number of RCRA rules
for SAAs. For instance, containers
must be in good condition without
rust, dents, or cracks; they cannot be
stored near drains or other structures
that could pose an environmental
risk; hazardous waste containers cannot
exceed 55 gal; acutely hazardous
waste cannot exceed one quart; SAAs
must be inspected weekly. There are
additional guidelines including requirements
for clear and visible labels
stating " hazardous waste " and listing
the container contents, as well as the
" three-day rule " that requires that the
containers are immediately marked
with the current date when full, and
removed within three days to the main
storage area (MSA).
The MSA is governed by additional
rules. One of the most important relates
to allowed accumulation time
once materials enter the MSA. Small
quantity generators (SQGs) - organizations
that generate more than 100
kg but less than 1,000 kg of hazardous
waste per month - can accumulate
materials for 180 days from the
start date.1
Large quantity generators (LQGs)
- those that generate 1,000 kg or
more of hazardous waste per month,
or more than 1 kg per month of acutely
hazardous waste - are subject to a
90-day accumulation rule.2
Regardless of size, the MSAs must
be secured against unauthorized entry;
hazardous waste and container contents
labeling rules must be followed;
containers must be inspected weekly
with reports kept on file; and preparedness
and prevention equipment
(for example an emergency phone,
alarm, fire suppression and spill prevention
equipment) is required.
There are additional regulations
and exceptions to the rules noted
above. For instance, peroxide formers,
such as ethers and dioxane, are
generally managed under a peroxideformer
program that tracks the material
based on the manufacture and
retention dates from the day it arrives
onsite until the day it is consumed or
disposed of. SAA storage times and
90/180-day MSA rules are all subordinate
to the peroxide-former deadlines.
So, if the earliest peroxide-former retention
date is 45 days in the future,
that is the container's deadline. Even
the waste disposal company must
track peroxide formers and follow expedited
destruction schedules based
on the retention date.
Managing chemical storage areas.
A minimum number of properly
trained staff should be assigned to
transport materials from the SAAs to
the MSA and manage the materials in
all of the storage areas. Some operations
are large enough to have a dedi1.
http://www.epa.gov/waste/hazard/generation/
sqg/index.htm
2. http://www.epa.gov/solidwaste/hazard/
generation/lqg.htm
ChemiCal engineering www.Che.Com DeCember 2010 45
http://www.epa.gov/waste/hazard/generation/ http://www.epa.gov/solidwaste/hazard/ http://www.Che.Com
Chemical Engineering December 2010

Table of Contents for the Digital Edition of Chemical Engineering December 2010
