In evaluating this inspection item, consider the chemicals used in the lab. Specifically, could the chemicals in use result in a listed waste when spilled or a characteristic waste when spilled or allowed to contaminate materials? Also, look for evidence of spills and the condition of bench paper. If there are potentially regulated chemicals in routine use, and significant evidence of spills, the lab should be collecting bench paper and possibly PPE for disposal through EHS.
Remember, spills of U or P-listed chemicals or F-listed waste will result in a listed waste. If a material is contaminated with a listed waste that is only listed for being characteristically ignitable, corrosive or reactive, it would only carry the codes if the spill residue still demonstrate the characteristic. Examples include F003 spent solvents or product methanol. Consult the waste specialist if you’re not sure whether a particular waste stream in a particular lab may be regulated.
As a side note, we did receive a Notice of Violation (NOV) for a PPE container that was not closed. Basically, PPE was being placed in zip lock bag and labeled as containing heavy metals. The zip lock bag was open at the time of inspection. Therefore, it is important to remember that if a lab is collecting these materials, a closed container must be used for accumulation and storage. However, open PPE/debris collection containers would not be cited here; it would be cited under WAS03, collection containers are not closed. Have the lab close the containers before you leave the lab.