In 2022, US companies could be fined a civil penalty up to $81,540 per violation, per day for Resource Conservation and Recovery Act (RCRA) hazardous waste violations.1 However, the monetary cost is small when you think of the costs associated with injuries or environmental incidents that can come from ineffectively handling hazardous waste.
Here are seven tips to help lab managers effectively manage chemical lab waste.
An organized lab has many benefits. Safety is certainly at the top of the list, but it also allows a scientist to be more efficient and productive. Additionally, organization helps with the handling of hazardous wastes. A scientist who knows where or how to easily find a chemical they need doesn’t spend more money buying it when it’s already on site. This also means the site isn’t storing more of a hazardous chemical than is necessary, which is a more environmentally friendly choice. Finally, organization is key during waste disposal. The US Environmental Protection Agency (EPA) and each state have strict regulations regarding how waste is separated and stored. Without a well-organized waste disposal location, a site could accumulate a lot of costly fines and increase its risk for an incident.
Use a computer-based inventory system
One of the four goals of RCRA is to find ways to reduce the amount of waste generated.2 A computer-based inventory system can be an effective tool in helping to meet this goal by keeping the site’s chemicals organized. Scientists need an online repository for safety data sheets (SDSs), a way to know who owns a chemical and where it is located, when a chemical was received and when it expires, and a labeling system that includes the chemical name, location, chemical hazards, and unique identifier, such as a barcode or QR code. Lab and safety managers also need the ability to track hazardous chemicals on site for state or federal reporting purposes.
While several systems are available for purchase online, lab and safety managers should examine and evaluate each to find one that fits the site’s needs. Some companies have even custom built their own. Key things to look for in an inventory system include the system’s customer service, user friendliness, and flexibility or adaptability. Finally, the ability to scan each chemical container’s label for inventory reconciliation is especially important for sites with a large number of chemicals. No employee enjoys reconciliation, but digital tools can speed up the task.
Regularly inspect waste storage areas
RCRA “is the public law that creates the framework for the proper management of hazardous and non-hazardous solid waste,” which is overseen by the EPA.3 Inspecting waste storage areas is among one of many regulations set forth by RCRA, which can be found in title 40 of the Code of Federal Regulations (CFR) parts 239-282. For instance, 40 CFR 264.174 states that “areas where containers are stored” must be inspected “[a]t least weekly.”4 Lab managers should take note that some auditors may interpret “weekly” differently. Some auditors will believe that it’s too lax to interpret weekly as simply once every work week, i.e., allowing an employee to inspect the storage area on a Monday one week and on a Friday the next week. As such, it’s best practice to assume that weekly inspections should occur at least every seven days.
“The best rule of thumb for effective waste handling is to never make assumptions.”
Keep waste storage containers and areas tidy and clean
While not explicitly stated in the CFR, auditors can and will find fault in labs or waste storage areas that they feel are not clean and tidy enough. Auditors are human, and they have pet peeves. An auditor who believes a lab or storage area is overly cluttered or contains expired chemicals may be more prone to find violations with the site, especially if the site has several areas with these issues. Like lab organization, lab cleanliness can help keep employees safe and efficient.
Adopt waste policies that are stricter than your state/federal regulations
Everyone gets busy and distracted. With that in mind, set your site up for success by keeping your site or company standards stricter than the standards set by state and federal regulations. For instance, 40 CFR 262.16 (b) states that hazardous waste can stay on site for “no more than 180 days” for small quantity generator sites.5 The state in which your site is located may have an even stricter requirement. If a site adopts a policy for getting waste off site that exceeds the state or federal regulations, and the site’s requirements are met, then the site will always be in compliance with state or federal regulations.
Lab managers should know that employees who directly handle chemicals are required to participate in training for waste handling. But were you aware that everyone on site is also required to receive at least a minimum level of hazardous waste training? This includes contractors, office employees, visitors from other sites, upper management, etc. It would also be prudent to provide a brief awareness level training to any visitor coming on site.
What does the minimum level of training include? According to 40 CFR 262.17 part 7, sites are required to train facility personnel so that they “are able to respond effectively to emergencies.”5 A non-lab employee should know how to respond if they see a spill while walking down the hall or through a parking lot. Whereas, a lab employee should know the difference between a spill that is small enough for them to handle on their own or large enough for them to call for help. All employees must receive training within six months of starting at the site, must not work unsupervised without having received this training, and must repeat this training every year.
Never make assumptions
The best rule of thumb for effective waste handling is to never make assumptions. The state and federal regulations are vast and are updated as necessary. It is highly likely that a lab manager will either misremember or confuse the regulations. Don’t allow pride or time restraints to get in the way of doing the job correctly and safely. A great practice is to post the site’s safety policies online. This way, commonly used pages can be bookmarked and keywords can be searched. Additionally, every employee will be able to easily and quickly access the policies. If there are any employees without access to the internet, post the guidelines in the areas on site that will be most useful to them—just remember to post the most up-to-date guidelines as soon as they are updated.
Managing hazardous waste is complicated and difficult, and the consequences of not effectively doing it can be dangerous and expensive. Benjamin Franklin once said, “an ounce of prevention is worth a pound of cure.” One of the best and easiest ways a lab manager can save their company money is to adopt a fastidious attitude regarding waste management.