Managing chemical waste in the laboratory is a complicated undertaking, and understanding the guidelines put forth by regulatory agencies is critical. Knowing the appropriate resources, training laboratory staff, and conducting regular compliance audits are key to maintaining a safe and effective chemical (hazardous) waste program. Following the standards can prevent safety issues and potential regulatory fines.
The waste management plan
The laboratory should have a written plan for managing each waste stream, such as non-hazardous wastes, regulated medical waste (RMW), hazardous (chemical) waste, radioactive waste, universal waste (such as light bulbs and batteries), and mixed wastes. The plan should instruct users on proper waste handling, storage, and transport from the moment of generation to the final disposition step of the waste management process.
A waste management plan includes a set of documents—policies, procedures, and job aids— that guide staff through each step of the overall chemical waste processes. Effective procedures will help staff determine when a waste is generated, how it must be labeled, and where it must be stored. The plan should also guide staff on what movement of hazardous waste is permitted, and how it can be safely performed. Information needs to be present about chemical waste pick up (typically by a vendor), signing waste manifests, and the proper management of waste records. An overview of hazardous waste records should detail manifest filing and retention, and information should be included regarding land disposal restriction forms and waste profiles.
“Reducing the amount of hazardous waste generated by a facility not only benefits the environment, but it can also reduce regulatory costs and work performed by a facility.”
A complete waste management plan addresses specific training needs. Training is required by regulatory agencies for those who handle chemical waste, those who sign waste records, and those who transport the waste. For example, the United States Department of Transportation requires specific training for employees who prepare and offer hazardous waste shipments for transportation by ground, and for those who sign waste manifests. This training includes topics such as general awareness, function-specific training, and safety training, and must be repeated every three years. Review vendor training records also. It may be acceptable for the vendor to act as an agent of the lab and sign waste manifests, for example, but they must have proof of training.
Finally, an annual auditing process should be incorporated into the policies that helps laboratories to determine the effectiveness of the chemical waste management plan and prepares the department for regulatory inspections. These audits should include a physical walk-through of the laboratory and associated waste storage areas, a review of documentation (including policies and waste manifest records), and development of an action plan to correct any nonconformities discovered during the audit. During your walk-through, look for proper waste storage and movement, check labels and dates on all containers, ensure all waste containers are closed when not in use, and all records are complete.
Waste labeling and storage
Once a chemical waste is generated, it must be properly labeled and stored. The Environmental Protection Agency (EPA) requires that each waste label contains the words “hazardous waste,” the identity of the waste, and some sort of hazard warning indication. The hazard warning may be a pictogram or another standard hazard warning convention.
Chemical waste can be stored in the area where it is generated, also known as a satellite accumulation area (SAA). Laboratories can have multiple SAAs, but these storage places must be within line of sight from where the waste is generated. If the waste is flammable, place it inside a flammable storage cabinet. SAAs may hold up to 55 gallons of waste, and these chemicals may be moved to a central accumulation area (CAA). Hazardous waste may never be moved from one SAA to another SAA.
A CAA is a designated final on-site storage area where waste is usually picked up by a contracted vendor. The storage limits in a CAA depend on the facility’s EPA waste designation. If the facility is a very small quantity generator (VSQG), less than 100 kilograms of waste may be generated and stored each month. A small quantity generator (SQG) may store up to 1,000 kilograms of waste each month, and large quantity generator (LQG) facilities are those that generate more than 1,000 kilograms of chemical waste.
There are also time limits to CAA waste storage based on the facility’s waste generator status. Hazardous waste may be kept on-site for up to 180 days in a SQG, and for 90 days in a LQG site (there is no time limit for a VSQG site). Once waste is moved into the facility’s CAA, a date must be applied to the label so that everyone is aware of when storage began and when the waste needs to be removed. Accumulation start dates should never be applied to labels of chemical waste stored in a SAA.
Waste disposition and waste reduction
Chemical waste must be tracked from its point of generation to its final disposal. Hazardous waste disposal may occur via incineration, fuel blending, or even burial. Reduction of this hazardous waste is of obvious environmental importance. It is mandated by some laboratory accrediting agencies, and in some cases, by EPA. If a facility is designated as a LQG, for instance, there must be a note in the required biennial report to the EPA regarding the actions the facility has taken to reduce its overall volume of hazardous wastes.
Hazardous waste is often removed from laboratories by a contracted waste hauler. This company may charge for its services by chemical weight, the number of barrels removed, or time spent in waste collection.
There are methods of reducing this hazardous waste before it needs to be taken away, and these processes can be used to effectively reduce the overall waste volume of the facility. One such method is neutralization. For example, some laboratories use a neutralizing agent to treat formaldehyde waste. If the aldehydes can be neutralized and the pH brought to a neutral value, this waste can be disposed of down the drain if permitted by the local wastewater authority.
“Proper training and knowledge of the current regulations combined with regular checks of the hazardous waste program can help an organization prevent errors and costly regulatory fines.”
Distillation and recycling on-site are other methods used to reduce hazardous waste volumes from the laboratory. Used alcohols, xylenes, and formaldehyde solutions are distilled for reuse. This practice can generate cost savings for the facility in terms of reagent purchase, but it also greatly reduces the amount of hazardous wastes generated by the laboratory. While distillation devices usually require capital funds to purchase and can be difficult to maintain, they can pay for themselves through reagent purchase savings in a relatively short amount of time.
Reducing the amount of hazardous waste generated by a facility not only benefits the environment, but it can also reduce regulatory costs and work performed by a facility. For example, a LQG facility must be inspected by the EPA every five years. They must also pay a fee to the EPA annually, develop a waste emergency contingency plan, and submit a waste disposal summary report every two years. A SQG site does not have any of those requirements. The waste designation of a facility is determined by the entire volume of waste generated by the entire facility (not just in the laboratory), and waste reduction practices may enable the facility to change its waste generator status to its advantage.
The tracking of hazardous waste removed from a facility is handled via a manifest record system. Every time a contracted waste handler takes waste away, they should provide the facility with an initial manifest (paper or electronic). Once the waste has reached its final disposal, a final manifest that needs to match the original is sent to the generating facility. Final manifests should be received by the facility within 45 days of waste removal. Contact the waste vendor to obtain any missing final waste manifests.
Supervision of laboratory chemical waste generation, labeling, storage, record-keeping, auditing, and training can seem like a massive undertaking, but it can be done effectively. Proper training and knowledge of the current regulations combined with regular checks of the hazardous waste program can help an organization prevent errors and costly regulatory fines. A successful laboratory waste management program provides the necessary cradle-to-grave oversight that will ensure safety for the laboratory, the facility, and the environment.