DAB Disposal in NYC
By Courtney Drayer, Technical Services Representative
3,3'-Daminobenzadine tetrahydrochloride (DAB) is an organic molecule that is oxidized by hydrogen peroxide in the presence of hemoglobin to produce a dark brown color that histologists can used to stain nucleic acids and proteins. Although DAB waste is not specifically regulated by the Environmental Protection Agency (EPA) or the New York State Department of Environmental Conservation (NYS DEC), DAB comes from a class of molecules (benzadines) which are known carcinogens. In fact, all benzadines that have been studied have been determined to have mutagenic properties by the US National Toxicology Program. Since DAB is not regulated, specifically, by EPA or NYS DEC, lab personnel may be tempted to "detoxify" and/or dispose of DAB through the sewers. It should be noted, however, that most methods of treatment result in either a hazardous solid or chlorinated byproducts that are also mutagenic. So what's an EH&S manager to do?
There is at least one more regulatory agency in New York City to consider while deciding how to handle your DAB waste; The Department of Environmental Protection. The DEP governs and enforces the RCNY (Rules of the City of New York) regulatory body which covers "Materials and Substances Excluded from Public Sewers" in Title 15, Chapter 19-03. This chapter describes materials that not permitted to be discharged down the drain and Line 10 (iii) states that:
Toxic substances in such quantities, which the person knows or has reason to know, may when discharged from a single source or in combination with other sources; (iii) be detrimental to the health of human beings, animals, or aquatic life.
Since benzadines are known carcinogens, they are detrimental the health of humans and animals. Within NYC, the RCNY is the regulatory basis for the collection, treatment, and ultimate disposal of DAB as a non regulated but toxic material. Outside of NYC, line 10 (iii) is still regulation with a lot of common sense. If you wouldn't want to drink it and it causes harm to people and the environment, please don't put it down the drain.