Flexible Work Arrangement

Hazardous Materials Considerations and Prohibitions

 

 

 

Environmental Considerations (EPA/NYSDEC)

 

Because of State & Federal Regulations regarding disposal and transport of hazardous waste materials, individuals participating in the University’s Flexible Work Arrangement Program and working in a non-SU owned, operated, or controlled work environment (for example: telecommuting from home) will need to consider and restrict the use and transport of certain types of materials.

 

If work activity, as performed in an environment described above, produces a waste that is considered “hazardous” as defined in Federal (EPA 40 CFR Part 261) and/or NY State (NYSDEC 6NYCRR Part 371) regulations, the material is prohibited from purchase, use, or storage in the non-SU owned, operated, or controlled work environment.  Therefore, if home work activity may result in the generation of waste material that is:

Ignitable (materials that are flammable or can cause fire either through combination with other materials or through friction.)
Corrosive (liquids with a pH of less than 2 or greater than 12.5, or that corrode certain grades of steel.)
Reactive (materials that react violently with water or form explosive mixtures or generate toxic gases when mixed with other materials)
- and / or -
Toxic(materials that exceed specified regulatory thresholds for metals, pesticides, or other organic chemicals.)

[see SU’s Hazardous Waste Management Manual – Appendix A for further definitions]

 

…then the material cannot be used in that work environment.  University owned / purchased electronic equipment (computers, faxes, etc.) which may constitute a “hazardous waste” at the end of it’s useful life, must not be discarded at home, but returned to the University for evaluation for either resale or recycling through Excess Property.

 

Contact the Hazardous Waste Manager for technical assistance regarding this topic at 443-9132.

 

 

 

Occupational Exposure Considerations (OSHA)

 

Definition:   "Hazardous chemical" means any chemical that has a physical hazard or a health hazard. (OSHA 29 CFR 1910.1200)

 

If a work activity includes the use of a “hazardous chemical” as defined above, the material is prohibited from use in a home work environment under the University’s Flexible Work Arrangement Policy.  Hence, if a Material Safety Data Sheet (MSDS) has been created by the manufacturer, then, in general, its use in the non-SU work environment is prohibited.

 

Exemption:   Office products, such as liquid toner, white out, etc (which are hazardous chemicals by definition) may be exempt and can be used in the home office only when they are used in the same manner that a consumer would use them, i.e.; where the duration and frequency of use (and therefore exposure) is not greater than what the typical consumer would experience. Also, MSDSs are not required for these exempted products.

 

Contact the Manager of Occupational Health for technical assistance regarding this topic at 443-9131 or by e-mail at gjmoll@syr.edu.