Standard Guide for Disposal of Laboratory Chemicals and Samples
“Stand-alone” laboratories rarely generate or handle large volumes of hazardous substances. However, the safe handling and disposal of these substances is still a matter of concern. Since the promulgation of the Resource Conservation and Recovery Act (RCRA) of 1976, more attention has been given to the proper handling and disposal of such materials. States may adopt more stringent requirements; information on this may be found along the path EPA Home > Wastes > Regions/States/Tribes > RCRA State Authorization > Data, Charts and Graphs (STATS) > State/Regional. To keep track of this, EPA classifies state regulatory language as (1) authorized, (2) procedural/enforcement, (3) broader in scope, and (4) unauthorized, and it publishes notices concerning the first three in the Federal Register.
Laboratory management should designate an individual who will be responsible for waste disposal and must review the RCRA guidelines, in particular: 40 CFR 261.3 - definition of a hazardous waste, 40 CFR 261.33 -specific substances listed as hazardous, 40 CFR 262 - generator requirements and exclusions, and proper shipping and manifesting procedures.
Because many laboratory employees could be involved in the proper (and improper) treatment and disposal of laboratory chemicals and samples, it is suggested that a safety and training program be designed and presented to all regarding procedures to follow in the treatment and disposal of designated laboratory wastes and is required by the EPA (40 CFR 265.16). For those who pack and ship, Hazardous Materials Shipper training is also required by DOT (49 CFR 172.203).
If practical and economically feasible, it is, of course, recommended that all laboratory waste be either recovered, re-used, or disposed of in-house. However, should this not be the case, other alternatives are presented. This guide is intended only as a suggested organized method for classification, segregation, and disposal of chemical laboratory waste. A university can set up its own chemical distributor to take orders from departments, order in economical quantities, sell at prorated bulk price plus expenses, and take back what is unused. For an example of a university central facility for minimizing over-ordering, storing chemical packages between uses, and disposing of hazardous wastes, see the web site of the University of Vermont, especially Procedure 12: Laboratory Waste Pickup and RCRA Hazardous Waste Determination.
The handling of laboratory samples, especially those received in large numbers or quantities from a specific source, can often be accommodated by returning the material to the originator, so he can account or process them, or both, and potentially combine them with larger quantities for recycling or disposal. Shipments of hazardous waste, including samples, are subject to RCRA regulations that do not apply to shipments of what is similar but not waste-like. A sample that was not a waste as received, and has not been contaminated or labeled as waste, need not be a waste when it is returned.
The small quantity generator exclusion (40 CFR 261.5) applies to some laboratories (those which generate less than 100 kg per month ~25 gal liquid). It is important to note that not every state allows the small quantity exclusion in this amount. Even so, the professional laboratory supervisor and his or her employers must balance the importance of (1) protecting human health and the environment from the adverse impact of potential mismanagement of small quantities of hazardous waste with (2) the need to hold the administrative and economic burden of management of these wastes under RCRA within reasonable and practical limits. Additionally, all lab supervisors should be aware of all current local, state and federal regulations, and of specific hazardous waste management facility criteria. Special rules have been made for some academic laboratories; see 40 CFR 262.100-108. Commercial services to facilitate Internet access to the regulations, and even to alert users to changes in chosen parts of these regulations, are available.
1.1 This guide is intended to provide the chemical laboratory manager with guidelines for the disposal of small quantities of laboratory wastes safely and in an environmentally sound manner. This guide is applicable to laboratories that generate small quantities of chemical or toxic wastes. Generally, such tasks include, but are not limited to, analytical chemistry, process control, and research or life science laboratories. It would be impossible to address the disposal of all waste from all types of laboratories. This guide is intended to address the more common laboratory waste streams.
1.2 This guide is intended to support compliance with environmental laws in the United States of America. Some of these laws provide for states to take over regulation of air quality or natural water quality with the approval of the Environmental Protection Agency (EPA). Other matters, such as laboratory waste tracking, disposal as household garbage and use of sewers, are handled at the state, local or provider level throughout the country. Examples of providers are air scrubber services, municipal sewer systems, municipal and private garbage services, and treatment, storage or disposal facilities (TSD). Go to the EPA home page, click Wastes > Regions/States/Tribes > States to get help locating state regulations. Unfortunately, it is not possible for any one source to provide all the information necessary for laboratories to comply with all regulations. To ensure compliance, the laboratory manager must communicate with regulators at all four levels.
1.3 Though it would be convenient to cite each reference by its Universal Resource Locator (URL), this guide eschews that (because such references are too labile) with the exception of http://www.epa.gov for the United States Environmental Protection Agency, http://www.dot.gov or http://www.hazmat.dot.gov for the United States Department of Transportation, and http://thomas.loc.gov to follow pending federal legislation in the United States. Intra-site links suggested here are also subject to obsolescence. However, one can enter in the web site search box the title of the document cited to locate it.
1.4 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety and health practices and determine the applicability of regulatory limitations prior to use.
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