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Identifying and Segregating Contaminated
Materials Reduces Hazardous Waste
Process
Background
Fisher-Rosemount designs, manufactures, distributes and services
high performance measurement, control, analytical and valve
instrumentation worldwide. The Eden Prairie Fisher-Rosemount
facility manufactures measurement instrumentation for flow,
level, pressure and temperature.
During the cleaning and assembly
processes, a variety of materials come in contact with hazardous
chemicals, such as methanol, acetone and isopropyl alcohol.
These materials include rags, gloves, wipes, swabs, mixing
sticks and epoxy applicators.
All contaminated materials,
whether or not they had contact with hazardous chemicals,
were disposed of as hazardous waste. Fisher-Rosemount placed
these materials in containers labeled, "Type A,"
and managed and disposed of them as hazardous waste.
The environmental administrator
at Fisher-Rosemount believed that many of the contaminated
items discarded in designated "Type A" hazardous
waste containers were not hazardous. The purpose of the intern
project was to identify the types of waste and develop a procedure
that would segregate hazardous from nonhazardous waste in
order to reduce the amount of contaminated materials treated
as hazardous waste.
Incentives
For Change
By reducing the amount of "Type A" hazardous waste,
Fisher-Rosemount could reduce its hazardous waste disposal
costs, and perhaps allow the company to be reclassified from
a large quantity generator to a small quantity generator.
Intern Activities
The intern's activities focused on developing a procedure for reducing hazardous waste throughout the Fisher-Rosemount production processes. This involved:
- dentifying and evaluating processes that generated contaminated materials;
- identifying chemical components of process waste streams;
- reviewing hazardous waste regulations to determine what contaminated materials were considered hazardous; and
- developing a procedure for segregating hazardous from nonhazardous wastes.
Identifying
Waste Streams and Chemical Components
The intern began the project by reviewing waste streams
from all production processes throughout the facility and
identifying the processes that generated "Type A"
hazardous wastes. These wastes were collected from "Type
A" waste containers and weighed to develop a baseline
measurement for each process area throughout the facility.
Once the wastes were collected
from each process, information was obtained from material
safety data sheets (MSDS) to identify the ingredients of chemicals
used in each process. This information was used to determine
whether or not the chemicals were classified as hazardous.
Reviewing
Hazardous Waste Regulations
Applicable hazardous waste regulations that affected the
identified chemicals (found in Chapter 7045 of the Minnesota
Hazardous Waste Rules) were reviewed, and interpretation of
these rules was gathered from telephone interviews with staff
from the Minnesota Pollution Control Agency (MPCA).
After reviewing MSDS and regulatory
information and consulting with MPCA staff, the intern concluded
that only materials that came in contact with certain F-listed
chemicals (mostly solvents) required disposal as "Type
A" hazardous waste. This verified the earlier theory
that many of the contaminated materials placed in the "Type
A" containers were unnecessarily being disposed of as
hazardous waste.
Developing
a Procedure for Segregating Hazardous from Nonhazardous Wastes
Based on the information gathered on the hazardous process
chemicals, the intern developed a simple method for properly
segregating the hazardous from the nonhazardous wastes.
First, containers of hazardous
chemicals were clearly marked with the letter "A"
using adhesive labels. The "A" indicated that the
containers contained hazardous chemicals and any materials
that came in contact with these chemicals must be disposed
of in the "Type A" hazardous waste container. All
other nonhazardous contaminated materials (that did not come
into contact with "Type A" chemicals) were placed
in separate waste containers.
The new labeling procedure
was tested in one process area before it was implemented in
other areas. During the test process, employees received training
on the new labeling and waste segregation procedure. All the
waste collected in "Type A" containers was measured
and compared to the previously collected baseline data.
By the conclusion of the project,
this procedure had been implemented in almost all other process
areas where "Type A" wastes were generated. Employee
training sessions for using the new labeling procedure were
held in each process area during regularly scheduled employee
meetings. Data on the amount of "Type A" hazardous
waste also was collected in the other process areas and compared
to baseline data.
Results
According to data gathered after the labeling procedure was
implemented, proper waste segregation through the use of a
simple container-labeling procedure could potentially reduce
hazardous waste by over 85 percent. This reduction would result
in an annual cost savings of over $15,000 for the entire facility,
and in reclassifying Fisher-Rosemount as a small quantity
hazardous waste generator. In addition to the ease of implementation
and cost savings, the capital cost to implement this procedure
was minimal. Fisher-Rosemount has now incorporated the labeling
procedure into its employee training materials.
The intern suggested that all
chemicals being considered for use by Fisher-Rosemount be
reviewed before they are purchased to determine if they would
cause process materials to become hazardous on contact. By
doing this pre-purchase review, Fisher-Rosemount would have
the opportunity to find nonhazardous substitutes before purchasing
chemicals. Fisher-Rosemount has since changed its pre-purchase
agreement to require reviewing hazardous material content
before chemicals are purchased.
Additional
Information
For more information about this intern project, or to receive
technical assistance with identifying and reducing your hazardous
waste, contact MnTAP at 612.624.1300 or 800.247.0015 if calling
from greater Minnesota.
This project was conducted
in 1994 by MnTAP intern Jeff Mortensen, a chemical engineering
student at the University of Minnesota, Duluth.
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