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American Veterinary Medical Association Guidelines for Practice or Workplace
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Hazardous Materials—Overview
This website provides comprehensive information on how to
handle hazardous materials from the point at which they enter to the point
at which they exit your facility.
It is important to understand the difference between the
general term "hazardous materials" and the more specific term "hazardous
wastes".
- "Hazardous materials" generally
applies to certain raw materials or products, purchased from outside suppliers,
that are stored and used at your facility.
- "Hazardous wastes" is a term
with a specific legal meaning that applies to certain materials that have
been generated as wastes from processes carried out at your facility.
This page provides some basic background information on the
rules -- where they come from, what their purpose is, and who enforces them. You
will also find links to additional pages with more detailed discussions of
specific hazardous materials commonly found in veterinary facilities, and to
information on specific management issues.
What is a hazardous
material?
In general terms, materials are designated as "hazardous
materials" when they pose a significant risk to people or property. The
specific definitions depend on the agencies that write the rules.
Hazardous materials are of particular concern for:
Worker Health and Safety
The federal Occupational Safety and Health Agency (OSHA),
and its counterpart agencies at the state level, are responsible for developing
and enforcing the rules for hazardous materials that relate to worker health
and safety issues.
The rules cover two main topics:
- Determining whether a particular material poses a risk
to workers
- Informing workers when they need to take appropriate
precautions
A material's manufacturer (or the importer, if it is manufactured
in another country) is responsible for determining whether or not a material
is hazardous from a worker safety standpoint. OSHA provides detailed
guidance for how this determination is to be carried out.
If a material is determined to be hazardous, the manufacturer or importer must provide a Safety Data Sheet [SDS and formally known as Material Safety Data Sheet (MSDS)] to its customers. Any
company that uses these chemicals in the workplace must communicate information
on the hazards and provide appropriate training to any worker who might be
affected by the material.
Transportation
The federal Department of Transportation and its state counterparts
write the rules for determining whether or not a material is hazardous from
a transportation safety standpoint. The determination generally involves
a somewhat different set of criteria from worker health and safety concerns.
The Federal Motor Carrier Safety Administration's page on complying
with Federal Hazardous Materials Regulations contains descriptions of
what types of materials are considered hazardous under federal transportation
regulations, and summarizes the responsibilities of transporters that carry
those materials.
More information
on hazardous materials
The VetCA website provides specific information on the following common
hazardous materials in veterinary facilities:
You can also find guidance
for managing hazardous materials onsite covering
the following topics:
What is a hazardous
waste?
The term "hazardous waste" is reserved
for materials that meet very specific criteria spelled out in the federal Resource
Conservation and Recovery Act (RCRA) and the regulations associated with it.
Hazardous waste regulations are developed and
enforced by the Environmental Protection Agency (EPA), and by state and local
environmental agencies.
Any facility that generates hazardous wastes
is subject to detailed rules concerning topics such as
- How the wastes must be stored on site
- How long they may be stored
- Who is allowed to transport and receive them
- What kinds of records have to be maintained
The basic regulatory approach taken by RCRA
is to separate the responsibilities of those who generate hazardous
waste from those who treat and dispose of it. It is easy
to qualify as a generator of hazardous waste, and much harder to qualify as
a "treatment, storage, and disposal", or "TSD" site.
If your veterinary facility generates hazardous waste,
you are required to obtain an EPA Identification Number. (You may be
exempt in some states if the quantity you generate is small enough.) EPA
provides a useful
booklet with details on the procedure to follow.
More information
on hazardous waste
More information on hazardous
waste management and disposal is available on the VetCA website, covering
the following topics:
How
does a material become a hazardous waste?
There are two primary ways that a waste material
can become classified as a hazardous waste, subject to the RCRA requirements:
- Listed wastes: Wastes from
certain industrial processes are automatically classified as hazardous. Each
waste of this type is given a code number. The full list of hazardous
waste codes appears in the Code of Federal Regulations, 40
CFR 261.
- Characteristic wastes: Wastes
that do not appear on the CFR lists may nevertheless be classified as hazardous
if they have one of four properties:
- Ignitability
- Corrosivity
- Reactivity
- Toxicity
In addition, materials can acquire hazardous
waste status if they are mixed with, or contaminated with, or are derived from,
other wastes that are themselves hazardous.
The generator of the waste is responsible for
determining if the waste is hazardous. The rules can get complicated.
In addition to determining whether a waste
is hazardous, you will need to know how each particular waste is classified. The
rules that apply to your facility will depend on how much waste, and what type
of waste, you generate. Misclassifications can (and do) lead to citations
and penalties.
The Hazardous
Waste Determination page provides more detailed information on this critical
topic.
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