EVALUATION OF THE

HAZARDOUS MATERIALS HANDLING FACILITY

AT THE UNIVERSITY OF WATERLOO


ERS 285 SPRING 1997

FINAL PROJECT

Jasmine Budak, Julie Ellison, Jennifer Niece, Gerard Reuss


TABLE OF CONTENTS

Executive Summary

1.0 Identification of System

2.0 Objectives of the Project

3.0 System Diagrams

4.0 Actors

5.0 Criteria to Evaluate the System

6.0 Means to Collect Data

7.0 Key Contacts

8.0 Observations Based on Survey Results

9.0 Conclusions

10.0 Recommendations

References

APPENDIX A: Raw Data: Criteria to Evaluate the Hazardous Materials Handling Facility

APPENDIX B: Interview Notes With Scott Paterson

APPENDIX C: Interview Notes With Ian Fraser


Executive Summary

Sustainability is an important concept in the field of environmental studies, and it can be worked towards in many different ways. In order to assess sustainability, the systems involved in day to day lifestyles must be understood. One of these systems, present on the University of Waterloo campus, is the disposal of hazardous waste.

The irresponsible treatment of hazardous materials can pose health risks to humans both in and outside of the workplace. Hazardous waste has the potential to contaminate ecosystems, thereby entering the food chain and affecting human health and ecosystem integrity. Diligence is necessary in handling these materials to prevent such contamination.

The University of Waterloo's Hazardous Materials Handling Facility (HMHF) is designed to accept and deal with all hazardous materials that are generated in on-campus labs, studios and health care facilities. An audit was performed on the HMHF to ensure that hazardous materials on campus are being handled in the safest manner possible, in accordance with government protocols. The audit was based on applicable municipal by-laws, the Fire Code of Canada, and the Environmental Protection Act, the Atomic Energy Control Act, and Guidelines for the Management of Biomedical Waste in Canada. Results of this study were based on personal observations and interviews with the HMHF and U of W Safety Office staff. For the purposes of this study, it was assumed that the government standards were designed to promote sustainability.

Additional information to supplement the survey was collected through three tours of the facility, and attendance on a weekly pickup around campus. The tours were guided by both Safety Office staff and HMHF staff on separate occasions, and the pickup was led by Scott Paterson of the HMHF.

Results of personal observations during the tours and pickup, as well as survey results were compiled to create an overall understanding of the strengths and weaknesses of the hazardous materials handling system. The HMHF was found to be in compliance with 64.7% of the standards evaluated. Areas for improvement include the storage of waste oil, storage of flammable/combustible materials and safety precautions involving the transportation of hazardous materials. Recommendations have been made to assist the HMHF to improve the rate of compliance with the standards evaluated in this study.


1.0 Identification of System

1.1 Significance of the System Study to the Sustainability of the Campus

1.2 Background Information

1.3 Study Rationale

1.4 Context of the System


2.0 Objectives of the Project


3.0 SYSTEM DIAGRAMS

FIGURE 1. WASTE TREATMENT SYSTEM AT THE UNIVERSITY OF WATERLOO

Figure 1 illustrates the governing structures that influence waste treatment at the University of Waterloo and the sources and flows of waste through campus operating systems. Red boxes refer to off campus policies and regulations. Blue boxes are on-campus waste sources and administrative bodies. Green boxes represent options for diversion and disposal of wastes while the purple box is the system directly under investigation (The Hazardous Materials Handling Facility).

FIGURE 2. HAZARDOUS MATERIAL FLOWS THROUGH CAMPUS

Figure 2 illustrates the generation and flow of hazardous materials though the HMHF system. It outlines the collection system which brings hazardous materials to the HMHF and decision making process for the classification of hazardous materials after they enter the HMHF. As in Figure 1, blue boxes represent on campus administrative bodies and sources of waste. Purple represents all components and decision making within the HMHF while green represents components that are involved once the materials have left the HMHF.

Boundaries:


4.0 Actors

4.1 Major Issues Involving Actors


5.0 Criteria to Evaluate the System


6.0 Means to Collect Data


7.0 Key Contacts


8.0 Observations Based on Survey Results

1. An oil spill occurred on morning when survey was conducted. This could have been caused by a variety of factors such as the questionable integrity of the storage drum, combined with the particularly corrosive materials inside (most of the drums contain corrosive materials). There was also evidence of previous spills (e.g. stains on the floor) that were overlooked during the initial tour of the HMHF because they were covered with full drums which were sent for treatment just before the survey. Fortunately, the recent shipment of materials facilitated access to the leaking drum. The leaking drum was scheduled to be removed in a shipment, before the end of the summer, its contents were transferred to a new container and will be disposed of in the next shipment.

2. Although Scott Paterson does not have all by-laws memorized, they are accessible and he appears to diligently consult the appropriate documentation if he is unsure as to the proper disposal of a substance.

3. Solutions with multiple components are disposed of according to the most dangerous component.

4. PCBs are not considered "waste" until they are shipped (e.g. light ballasts).

5. "Flammable Materials" stickers on cabinet doors are damaged / difficult to read.

6. Biomedical waste is not compacted.

7. 45 gallon drums are not labeled as flammable or combustible.

8. 45 gallon drums in lab are not closed, but are ventilated to the outside.

9. Waste oil tank room is not identified on the outside with "Waste Oil Tank of 230L inside" for fire fighting purposes.

10. Waste oil tank is not labeled on two sides, must have overflow protection, rust coating, drip tray, and should be opened only when needed.

11. Waste oil tank is not vented to the outside (cap is always open, therefore ventilation occurs into the storage room).

12. Biomedical waste is not separated into specified categories and colour coded according to these categories. (Biomedical waste is not treated after it is received from the original generator.)

13. Facilities do not exist to store biohazardous waste below 4 degrees Celsius. However, biohazardous waste is generally kept frozen at the department of origin until it is transported to the HMHF just before a shipment out.

14. Although the Transportation of Dangerous Goods Act does not apply at U of W because it is private property, Certificates of Approval as required under section 13 of the Environmental Protection Act, Regulation 309 are not obtained for the transportation of hazardous materials on campus.

15. The vehicle transporting dangerous goods does not comply with all safety standards, e.g. the body is not leak proof.

16. Someone is not present with the hazardous materials at all times during pickups (based on personal communication).

17. Not all rooms in the HMHF contain drainage systems that terminate where a potential spill will not create a risk to the environment or to human health and safety.

18. Containers with flammable or combustible liquids are sometimes left open when not in use (but these are ventilated).

Note: With regards to recommendations 7-11, 17-18, Section 4 of the Fire Code is still only proposed in Ontario, and is not yet law. In anticipation of this Code becoming law in the future, it is important to comply with it to minimize future changes.


9.0 Conclusions

Results of the audit indicate that the University of Waterloo's Hazardous Materials Handling Facility is in overall compliance with 55/85 or 64.7% of the by-laws and regulations included in this study. The audit itself was divided into four sections: Handling/Disposal, Storage, Transportation, and General Safety Measures of the HMHF. The facility was found not to be in compliance with 23/85 or 27.1% of the questions posed, while 7 questions (8.24%) were either not answered or were deemed inapplicable to the study.

Specifically, the HMHF was found to have high compliance rates in the areas of Handling/Disposal (86.4%), and Safety Measures (85.7%). In general, the HMHF procedures are very sensitive to regulations for the treatment of radioactive materials, the disposal of hazardous solutions into sewage systems as well as spill response preparedness within the facility. Compliance is met in obtaining permission for the professional disposal of bulk volumes of hazardous substances. Although not addressed specifically during the HMHF audit, it should be noted that improvements have been made in recent years to increase the reclamation of reusable materials and to reduce the volume of hazardous wastes that must be disposed of from on campus activities.

The facility was found to be less compliant in the areas of Storage (50% compliance), and Transportation (69.2%). Major areas of concern surround the storage of waste oil and flammable materials. Protocols for the transportation of dangerous goods were also found to be frequently not in compliance. (Transportation issues do not involve the Transportation of Dangerous Goods Act which is not applicable on private property but are stipulated in Regulation 309 of the Ontario Environmental Protection Act.)

Based on the assumption that the applicable laws and policies promote sustainability, the University of Waterloo's Hazardous Materials Handling Facility cannot be considered sustainable because of its low rate of compliance in the areas of storage and transportation.. However, other components of the system, such as safety measures, and handling/disposal are well in compliance. A sustainable system would have a high rate of compliance in all areas. As sustainability is considered to be a process, and not a measurable endpoint, the Hazardous Materials Handling Facility is currently promoting many sustainable practices.


10.0 Recommendations

Handling/Disposal of Hazardous Waste:

Storage of Hazardous Waste:

Transportation of Hazardous Waste:

Safety Measures (Within the HMHF):

10.1 General Recommendations:


REFERENCES

Atomic Energy Control Act - Transport Packaging of Radioactive Materials Regulations; SOR/83-740 (as am. By SOR/89-426; 90-172; 90-192;91-304; and 92-150)

Fire Code of Canada. Section 4.

Fraser, Ian. University of Waterloo Safety Office. Personal Communication. June, 1997.

Guidelines for the Management of Biomedical Waste in Canada. February, 1992.

Government of Ontario. Environmental Protection Act, October 1990. Revised Statutes of Ontario, 1980, ch141 and Regulation 308, Revised Regulations of Ontario, 1980 as amended to O.Reg.90/90.

Government of Ontario. Environmental Protection Act, Regulation 309.

Paterson, Scot. University of Waterloo Hazardous Materials Handling Facility. Personal Communication. June 12, 1997.

Regional Municipality of Waterloo. By-Law #1-90. Sewer Use By-Law.

Theisen, Eric J.. Driver's Guide to the Transportation of Dangerous Goods Act, 3rd Edition. Carswell Thomson Professional Publishing. copyright 1996.