Considerations before Submitting a Radioactive Waste Request
EHS waste staff aims to pick up radioactive waste submitted by research personnel in a quick, efficient and hassle-free manner. Following are a few things you should do before submitting your request for pickup to ensure that your waste is picked up in a timely fashion. By following these instructions, EHS staff can pick up your waste on the Tuesday after your request is submitted, without interrupting you and your research.
- Fill the waste tag out completely using pencil. Correctly completing the tag will guarantee that your waste will be removed and that waste staff will not have to find lab personnel to inquire about something that is not filled out. Things the waste staff looks for on the tag:
- Is the external contamination box checked?
- Is the activity listed?
- Are all liquid chemicals, buffers, media, acid, bases, solvents listed on the back of the tag and equal to 100%, and the pH listed?
- Is the liquid scintillation cocktail that is used listed for LSC vials?
- Waste with incomplete tags cannot be collected.
It is only necessary to complete the back of the radioactive waste tag if the waste is a liquid.
- Identify each chemical component and its percentage – this must equal 100%.
- Do not abbreviate chemical names.
- Indicate pH if waste is aqueous.
- If waste is a liquid scintillation cocktail – identify the brand name.
- Read the tag carefully. One of the most common mistakes is to mark the “External Removable Radioactive Contamination <22 dpm/cm^2” box incorrectly. If you performed a wipe of the container and it was less than 22 dpm/cm^2, then check the box “Yes."
- Make sure the bag inside the dry waste barrel is sealed with zip tie, tape, or with a knot and do not overfill, so the lid can be closed.
- If lead shields are being disposed of make sure that a radioactive waste tag is provided with the lead, that wipes have been performed, and the “external removable radioactive contamination” box is marked “YES.”
One other consideration is to ensure that lab staff are available to provide EHS access to the room where radioactive waste is stored. (As you are aware, leaving the lab open and unattended is a radiation security violation.) Waste staff typically make pickups between 9:00AM-2:00PM on Tuesdays.
Remember to Update Your Bloodborne Pathogens Exposure Control Plan
All departments that have staff classified as ‘at risk’ for Bloodborne Pathogens (BBP) must have an Exposure Control Plan (ECP) tailored to the work in their department or lab. Each department's Exposure Control Officer should ensure that this plan is updated on an annual basis and available to all of the laboratories covered by the plan. The current ECP template is available on the EHS website. Other changes needed annually are to verify that the list of employees and job categories that have staff ‘at risk’ for BBP is up-to-date. If you have any questions about the Bloodborne Pathogens Program or need assistance in updating your ECP, please contact Rachel White at 353-5679.
More Changes Coming for EHS Lab Reviews
EHS has begun conducting lab reviews using tablet computers, as reported in the November 2013 Lab News.
Next Step - Phase Two will enable EHS to query personnel ICON training records prior to lab visits. Once fully implemented, less time will be needed on the lab’s part to collect training records from employees every year.
We hope this phase will be very helpful for labs and we plan to begin implementing this phase very soon.
This first year, there will be some upfront time that EHS will ask you to invest. Here is what to expect:
- Prior to your annual review, your EHS safety advisor will ask the lab contact to fill out a form with a list of lab employees and the types of work each employee conducts in the lab.
- Based on the information provided to EHS, we will enter the names of the lab employees into our system and assign required ICON courses to each worker.
- Once set up, the system can produce a report showing missing required training, if any. The advisors will bring this report to the lab when they visit for the audit. In successive years, we will resend what you previously submitted for personnel and activities and ask for updates to this list.
If you have questions about our transition to mobile lab inspections, please contact LuAnn Hiratzka at 335-7964.
Reminder: Laboratory Close-out Procedures
When closing out a lab, the Principal Investigator (PI) and PI’s department are responsible for ensuring that all hazardous materials (biological, chemical and radiological) are removed from the lab space. To assist with this, EHS has created a laboratory close-out procedure.
The procedure provides a timeline for notifying EHS as well as a checklist that provides guidance on specific issues related to transferring, transporting, or disposing of hazardous materials commonly found in labs.
Additionally, equipment, supplies or furniture, whether staying in the lab or being sent to Surplus, must be properly cleaned or decontaminated. Complete an Equipment Clearance Record Form for items that are being sent to Surplus.