Recently, after a late night and hours of work in an organic chemistry lab, a graduate student finished up his experiments, dutifully collected his waste and added it to the waste container in the hood. He sealed the container and left for the evening. Unfortunately, a few hours later the one-gallon amber glass bottle decided to increase its entropy and scattered itself and its contents all over the hood and the laboratory.
Fortunately, no one was in the lab when the minor explosion took place, so only the hood and the lab were damaged. What happened? We all know that this was a case of mixing incompatible wastes. But why did it happen? And how do we prevent occurrences like this?
This month the Safety Guys provide an introduction to and overview of waste handling in a typical research laboratory. Our focus is on hazardous chemical wastes, as these are the main culprits when it comes to accidents like the one described above. However, proper management of chemical waste is important not only for safety but for economic health, since serious fines and penalties are possible if waste is not handled according to regulations. We touch on the federal regulations, present a model program for chemical waste management and discuss satellite accumulation areas. Our hope is that this will start a discussion leading to in-depth follow-up articles on topics you, our readers, are interested in.
A look back to the beginning
The federal Resource Conservation and Recovery Act (RCRA of 1976) initiated our having to deal with hazardous chemical wastes. With this act Congress mandated that the Environmental Protection Agency (EPA) develop regulations for treatment, storage and disposal of all hazardous wastes. The goal was to keep harmful wastes out of the environment and curtail illegal disposal. This law put in place a record keeping and tracking system to follow hazardous wastes “from cradle to grave.”
RCRA defines those wastes that are hazardous, that is, those that must be tracked, and specifies the manifest system by which to do this. The details are contained in the Code of Federal Regulations, Title 40, Protection of the Environment, parts 260 to 2651. Essentially, a waste record or manifest is developed by the generator of the waste and passed to the shipper or transporter and finally to the disposal facility. The manifest is checked and signed by each entity, and, after final disposal, the completed manifest is returned to the generator, documenting the proper “cradle-to-grave” management.
Getting started: Developing your model program
Most lab managers who have been at this for a while can skip this section, because we know that you have already done your homework and have a program in place. For new labs and those getting started, we strongly encourage you to develop a written plan and policy statements. The plan should designate a lab waste manager, assign responsibilities for the manager as well as laboratory workers, list required training and the method used to document training, and provide the standard operating procedures you will use to run your waste management program.
A written program also allows you to clearly state any specific policies that must be followed, such as “no hazardous wastes shall be disposed in the sinks or trash.” Finally, your written plan should include segments on periodic review of policy and operating procedures to address any changes or additions to your lab’s activities and methods to evaluate the program’s overall effectiveness.
We must emphasize that, although the federal regulation establishes a baseline, some states and local jurisdictions have waste or chemical management requirements that go beyond EPA compliance. Therefore, it is critical to check with state and local entities regarding additional regulations.
Second step: Identification and accumulation
If your lab generates a waste stream, the first step is to determine whether the waste is hazardous or not. The burden is on you, the generator, to characterize the waste. Very simply for laboratories, it is considered hazardous waste if any components are on one of two lists of chemicals (P-list for acutely hazardous or U-list for general toxic chemicals) or it has one of the characteristics for ignitability, corrosivity, reactivity or toxicity as defined in 40CFR 261.20. If you are unsure, we urge you to contact an experienced professional to assist in making the determination through either documented generator knowledge or proper testing. If the waste is not hazardous, it can be disposed of locally via the sewer system or the general refuse collection. However, you must perform due diligence and confirm with local providers and authorities to ensure that all local codes and ordinances are followed.
After completing your waste characterization for the various wastes generated, you will need to design and implement a collection and storage strategy. For most research laboratory facilities, wastes are collected at the point of generation. Usually this is done using small volume and appropriately compatible containers. As these containers are filled they are moved to a larger segregated storage area.
Collection near the point of generation is known as a satellite accumulation area. EPA has developed strict guidelines for these satellite accumulation areas to ensure safety and avoid abuse of a storage area. The first requirement is to have signage posted in the area or have it labeled as a satellite accumulation area. The second most important requirement is to stay below the accumulation limits. For a satellite area, this is 55 gallons total of hazardous wastes and no more than one kilogram (about one quart) of any acutely toxic (P-listed) wastes. Satellite accumulation limits should be confirmed with state and local jurisdictions. For example, the state fire marshal may have stricter requirements if your waste is flammable.
There are a few more requirements that pertain to accumulating wastes, for both satellite areas and storage areas. These represent the most common errors (read citations with fines) found during compliance inspections. Number one is proper labeling of containers. Labels must contain the words “Hazardous Waste” and list all constituents (spelled out, no abbreviations or chemical formulas) with their percentage of the total. Make sure the list totals 100%. Next, containers must remain closed except when adding waste. Do not leave funnels in drums or open containers in hoods. Containers must be in good condition and compatible with the types of waste stored. For example, do not put corrosive wastes in metal containers. One last thing to check is proper segregation. It is very important to keep incompatible chemicals separated, for instance flammable liquids and oxidizers or acids and bases.
Proper management of hazardous chemical waste is important for maintaining safety and avoiding potential expensive regulatory fines. If you are new to handling laboratory waste, this article should get you on the right path. If you are an old hat, then hopefully there is some useful information here to help you review your current operations. In future articles on topics pertaining to waste management, we hope to discuss nuances of defining a hazardous waste with a focus on the four characteristic categories, waste compatibility and waste minimization. We look forward to these and lots of reader feedback.
1 – Environmental Protection Agency, 40 CFR, Subpart I Solid Wastes, Parts 260-265. http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?sid=34398760c105d0c852fa1fd2cddea656&c=ecfr&tpl=/ecfrbrowse/Title40/40cfrv25_02.tpl
2 - Prudent Practices in the Laboratory: Handling and Disposal of Chemicals. National Research Council. National Academy Press, Washington, D.C., latest edition.