Whether you work in academic, research, development, or production labs, the diverse processes can present complex challenges, especially when it comes to proper waste handling. And, should you be visited by local, state, and/or federal inspectors, you will quickly realize the importance of knowing all your waste streams and understanding the myriad regulations on handling and management. One of the most common transgressions uncovered by inspectors is a failure to fully determine the hazardous characteristics of all wastes.
This month, the Safety Guys present an overview of hazardous waste management. We focus on laboratory chemical wastes, because these are the main offenders when it comes to waste streams in research or production facilities.
Proper management of chemical waste is not only important for the environment and human health, but also for safety and economic concerns. Serious fines and penalties are possible if wastes are not handled according to regulations.
Understand the basic regulatory framework
The main governing body when it comes to hazardous waste is the Environmental Protection Agency (EPA), which developed a cradle-to-grave process first promulgated in 1976.1 The process regulates hazardous waste from the time it is created to while it is transported, treated, or stored to the time of its final disposal. This regulation is known as the Resource Conservation and Recovery Act (RCRA).
Although the EPA regulation establishes the baseline, we must emphasize that some states and local jurisdictions have waste or chemical management requirements that go beyond the EPA. Therefore, it is critical to check with state and local entities regarding any additional requirements.
Characterize all wastes and identify the hazardous wastes
The burden is on the generator, i.e., the creator of the waste, to characterize all wastes produced by the lab or facility and identify those that are hazardous. RCRA defines which wastes are hazardous, i.e., managed cradle to grave. The details are contained in the Code of Federal Regulations, Title 40, Protection of the Environment, parts 260 to 265.2
Specific lists of hazardous chemicals that when disposed of become hazardous chemical wastes are given a waste code. For the average laboratory, a waste is considered hazardous if any components are on one of two lists of chemicals (P-list for acutely hazardous or U-list for general toxic chemicals).
The U-list covers discarded chemical products, off-specification chemicals, container residues, and spill residues that have been identified as toxic wastes and receive a corresponding U-code. The P-list refers to a special sublist of compounds identified as acutely toxic and subject to smaller quantity exclusions. These lists are found in 40 CFR 261.33.
In addition, there are smaller lists for chemicals from nonspecific sources, mixtures of spent solvents, wastewater sludges, and distillation bottoms, which fall under the F-codes (found in 40 CFR 261.31). Wastes from specific procedures such as wastewater treatment sludges and distillation wastes from certain chemical production processes receive a K-code (found in 40 CFR 261.32).
Evaluating waste characteristics
But, what if your lab generates a waste stream and it does not contain any U-listed or P-listed material, and does not fall into one of the F- or K-listed categories? How do you make a determination of whether the waste is hazardous or not? Very simply. You must determine whether it meets one of the hazardous characteristics: ignitability, corrosivity, reactivity, or toxicity, as defined in 40 CFR 261.20.
All waste streams, including unconventional, temporary, or short-term wastes, need full characterization for proper disposal. As mentioned above, the four hazard characteristics are ignitability, corrosivity, reactivity, and toxicity. Testing is sometimes avoided with sufficient general knowledge, i.e., knowledge of the specific constituents used and the process by which the waste is generated. In most cases, however, representative samples are collected and tested to make the determination.
Ignitable wastes are given the code D001 and exhibit any of the following properties:
- A liquid that has a flash point less than 60°C (140°F), determined by the Pensky–Martens Closed Cup Tester or the Setaflash Closed Cup Tester;
- A nonliquid that is capable of causing fire through friction, adsorption of moisture, or spontaneous chemical changes;
- An ignitable compressed gas as defined in 49 CFR 173.300; or
- An oxidizer as defined in 49 CFR 173.151.
Corrosive wastes are given the code D002 and exhibit any of the following properties:
- Aqueous liquid with a pH less than 2 or greater than 12.5; or
- A liquid that corrodes steel at a rate greater than ¼ inch (6.35mm) per year at a test temperature of 55°C (130°F).
Reactive wastes are given the code D003 and exhibit any of the following properties:
- Is normally unstable and undergoes violent change without detonating;
- Reacts violently with water;
- Forms potentially explosive mixtures with water;
- Generates toxic gases or vapors when mixed with water;
- Is a cyanide or sulfide containing waste that can generate toxic gases or vapors;
- Is capable of detonation or explosion if heated or subjected to a shock; or
- Is an explosive as defined in 49 CFR 173.
Toxic wastes are given a D-code if any of the toxic compounds listed in Table 1 of 40 CFR 261.24 are present, and equal to or above the respective limits as determined by the Toxicity Characteristic Leaching Procedure, known as TCLP. This is basically a water-extraction procedure for determining whether toxic compounds can leach out of the waste. TCLP is defined in Test Method 1311.3
In these cases, we encourage you to contact an experienced consultant to assist with sampling and testing waste to determine whether it has any hazardous characteristics. If the waste is not hazardous, then disposal locally via the sewer system or the general refuse collection might prove an alternative. However, we caution you again to confirm with local providers and authorities to ensure all local codes and ordinances are followed.
To operate safely and to avoid potentially expensive regulatory fines, proper management of hazardous chemical waste is paramount. If you are new to handling laboratory wastes, this article should get you moving down the right path. If you are an experienced lab manager, then hopefully there is some useful information here to help you review your current operations.
1. Learn the Basics of Hazardous Waste. Hazardous Waste, US Environmental Protection Agency, Washington, D.C. August 2017. https://www.epa.gov/hw/learn-basics-hazardous-waste
2. Protection of the Environment. Environmental Protection Agency, 40 CFR, Subpart I Solid Wastes, Parts 260-265. http://www.gpo.gov/fdsys/search/pagedetails.action?collectionCode=CFR&searchPath=Title+40%2FChapter+I%2FSubchapter+I%2FPart+261&granuleId=&packageId=CFR-2000-title40-vol1&old-Path=Title+40%2FChapter+I%2FSubchapter+I&-fromPageDetails=true&collapse=true&ycord=157
3. Test Methods for Evaluating Solid Waste, Physical/Chemical Methods. EPA Publication SW-846. Environmental Protection Agency, Washington, D.C. Latest edition.