Chemical Engineering December 2010 - 46

TRI ChemICals
Environmental Manager
cated full-time staff, while for others it
is a part-time function (that requires
the same annual refresher training).
Properly organizing the handling
and in-house movement of chemicals
removes the responsibility from researchers
and substantially reduces
training requirements.
Another benefit of using dedicated
staff is that it puts a third party in position
to regularly inspect warehouse,
production and laboratory areas to
ensure that chemicals are properly
stored and handled in accordance with
regulatory and company policies. Here
are some best practices that we have
seen in the field and that we practice
at our own sites and for customers:
* Ensure that proper procedures
(such as labeling and tracking) are
being followed at each production
and laboratory location, and that
waste chemicals are stored only at
approved sites
* Conduct periodic safety training for
research and production personnel
* Establish collection schedules to efficiently
move materials from SAAs
to the MSA in a timely way
* Ensure that SAA containers are in
good condition, properly closed and
placed within secondary containers,
and that incompatible materials are
properly segregated
* Catalog, store and consolidate MSA
materials in bulk containers and
pack smaller quantities, elbow bottles,
and so on, for transportation
* Identify unknowns before shipping
* Follow up on the disposal or recovery
of chemicals for company and
regulatory reporting
Software. Most large companies
utilize chemical inventory management
systems, while many laboratories
still use spreadsheets to manage
their inventories. Spreadsheets can be
helpful, but they are not the answer
for corporate-wide or comprehensive
lifecycle-management programs. They
are generally home-grown standalone
applications without built-in reporting
mechanisms. They do not extend
beyond the department or integrate
with corporate systems. They do not
tie into industry resources and documentation,
such as material safety
data sheet (MSDS) databases, that are
necessary to build chemical profiles.
n added benefit of recycling and reusing chemicals can be reducing the volume
of materials listed in Toxics Release Inventory (TRI) reports. This can contribute to
reduced taxes and annual fees associated with RCRA regulations. TRI chemicals
have included the following:
Aluminum (fume or dust)
Aluminum oxide (fibrous forms)
Ammonia (anhydrous and aqueous)
Asbestos (friable)
Hydrochloric acid (acid aerosols)
Nitrate compounds (water dissociable;
aqueous solution)
Phosphorus (yellow or white)
Sulfuric acid (acid aerosols)
Vanadium (except when contained in an
alloy)
Zinc (fume or dust)
The TRI listing for the following three
chemicals is based on the chemical activity
rather than the form of the chemical:
1. Dioxin and dioxin-like compounds
(only if they are manufactured at the facility;
or are processed or otherwise used
when present as contaminants in a chemical
but only if they were created during the
manufacture of that chemical)
2. Isopropyl alcohol (only if it is being
manufactured by the strong acid process)
3. Saccharin (only if it is being manufactured)
SOURCE:
U.S. Environmental Protection Agency: EPA 260-R-09-006 October 2009 " Toxic Chemical Release
Inventory Reporting Forms and Instructions - Revised 2009 Version " (http://www.epa.gov/TRI/report/rfi/
ry2009rfi121709.pdf). See Table II-3, p. 143 for the full alphabetical list of chemicals and qualifiers
Perhaps, most importantly, they may
not stand up to regulatory scrutiny if
the need arises.
Specialized software and online
chemical-waste-management systems
handle all of these issues and also
address many other important criteria,
such as chemical movements,
90/180-day storage-time limits, chemical
expiration dates and reporting.
More sophisticated software and online
tracking systems assign cost center
allocations, and facilitate movement,
inventorying and packing, as
well as documenting the transfer of
the material to a certified waste disposal
company.
Waste disposal companies
Given the complexity of effective
waste-chemical management, many
companies find that it is more efficient
and cost effective to turn to
waste disposal companies to handle
their chemical waste throughout the
entire post-use lifecycle phase. Service
companies manage the entire process
including onsite movements, storage,
packing and removal. In that way,
generators do not have to invest as
heavily in RCRA training and can rely
on the contractor to apply its expertise,
provide staff and backup staff as
necessary, monitor regulatory federal,
state and local developments, and implement
best practices.
This allows plant and laboratory
management to properly oversee the
function without adding headcount. It
also enables staff to focus on their core
responsibilities and not be burdened
with additional training or oversight
of chemical management functions.
46 ChemiCal engineering www.Che.Com DeCember 2010
Using the same outsourcer to handle
materials in-house as well as for removal
and disposal eliminates interorganizational
hand-offs and can further
reduce costs.
Communications between waste
generators and chemical disposal
companies. Before a waste disposal
company can remove hazardous
chemicals from a generator, all paperwork
must be in order, the materials
must be properly labeled and packaged
and ready to go. It is important
that chemical waste is properly characterized
in order to avoid unnecessary
expense or, in a worst case, additional
transshipping to another waste
disposal site. Confusion creates lost
time and increased costs for chemical
characterization tests and EPA and
DOT documentation.
Communications with the waste
disposal company are key. Direct links
between the generator and the waste
disposal company are efficient since
any materials or paperwork that are
not in compliance will be identified
early, waste profiles and DOT manifests
can be generated, and placards
assigned before the disposal company
arrives on site.
A direct link to the waste disposal
company can also report containers
that are ready for packing and/or
pickup, enabling the removal company
to cost-effectively schedule pickups.
Automated procedures also help companies
stay in compliance with RCRA
90/180-day rules or special handling
requirements for peroxide formers
and other acute hazards.
Regardless of the degree of automation
and communications, underA

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Chemical Engineering December 2010

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