Hazardous Waste Determination
Posted on Mon, Sep 28, 2009 @ 10:27 AM
By Kate Carpenter, Technical Services Representative
If you are an up and coming life science company, there is a chance that you are growing so quickly that your safety programs haven’t had time to catch up. One of the first elements you should consider is your hazardous waste program. Failure to have a safe and compliant hazardous waste program may not only have environmental implications, but also large fines associated with inspections. Potentially the most elemental key of running a compliant hazardous waste program is determining what needs to be collected. Incorrectly assuming that something can go down the drain can lead to huge fines, in addition to the impact it may have on our local ecosystems and ground water.
The first step is to determine if a waste needs to be collected is if it is considered hazardous. The best bet is to consult manufacturer’s MSDS, where vital information may be gleaned from. If it is regulated by the Resource Conversation and Recovery Act (RCRA) then you can correctly identify it as hazardous waste. RCRA will specifically call out waste codes for particular compounds, and additionally they will code for waste that has a hazardous characteristic. Examples of these include common laboratory reagents such as methanol (for ignitability), sodium hypochlorite (for corrosivity), and activated carbon (for reactivity). Additionally, you may need to collect waste if it is high in toxicity or can be damaging to the environment.
If you determine that a waste is non-hazardous, then the next step is to see if you can pour it down the drain or if you should collect it as non-hazardous waste. For example, Ethidium bromide is not regulated by RCRA or Department of Transportation, but it is environmentally hazardous and should be managed and disposed as such. Similarly, wastewaters can be below the requirements for the RCRA hazardous code for mercury, but above the 1 ppb requirements of the MWRA and so it must be collected. As always, if you have any questions regarding compliance or waste determination, please do not hesitate to contact your trusted environmental advisors.