Annual Survey of Hazardous Chemicals of Concern Sample Clauses

Annual Survey of Hazardous Chemicals of Concern. The EMP includes a requirement that each University define a list of “hazardous chemicals of concern” (“HCOC”) and annually conduct a risk evaluation survey of these chemicals in the laboratory. This list will be generated by EHS professionals at each University based on regulatory concerns, risk concerns and potential chemical reactions. The criteria at each University includes: • Chemicals given an expiration date by the manufacturer due to safety considerations (e.g., peroxide forming chemicals, etc.) • Chemicals which meet the RCRA definitions of reactive or corrosive (flammables are covered by fire department restrictions; in general, toxics are hazardous during their use, not during storage) and have been determined by professional judgment to present a risk to non-lab workers or the environment • Poison Inhalation Hazard designation by DOT (covers serious toxics) • Other chemicals as determined by professional judgment to present a risk to non-lab workers or the environment • Chemicals may be removed from the HCOC list if there are insufficient quantities to pose a risk. The HCOC list will be developed on a university-by-university basis, because the types of hazardous chemicals at a particular university will vary with the type of research work performed there. This list will be reviewed on an annual basis and updated to assure that it covers an appropriate breadth of hazardous materials. This documented evaluation will enhance both waste and risk minimization efforts by identifying and evaluating chemicals of concern and moving them out of the laboratories, and it will help laboratory personnel and inspectors avoid semantic and enforcement battles over whether a hazardous material on the shelf is a RCRA waste. By placing the emphasis on the safe and careful handling of all chemicals, whether raw chemicals or waste chemicals, the time and effort of laboratory, environmental, health, and safety personnel and RCRA inspectors will be focused on the most important objectives of RCRA and OSHA, which are protection of human health and the environment. The annual survey directly addresses the problems associated with the accumulation of old hazardous chemicals on the shelf. Federal EPA and State inspectors have repeatedly stressed that this problem is a priority concern . This University Laboratory XL Project goes beyond the “waste” management regulations prescribed in RCRA by addressing this particular “upstream” issue at its source. By providing regular...