Life Science Startup Companies – Hazardous Waste Management
Posted on Wed, May 19, 2010 @ 11:34 AM
By Kate Carpenter, Technical Services Representative
Do you generate hazardous waste from lab work? Perhaps you generate a small volume of hazardous waste, and you don’t think that it’s enough to worry about. You may want to know that regardless of your company size, you need to manage hazardous waste in a safe manner. You are required to dispose of it properly in accordance with state and federal regulations, but there are less stringent standards if you qualify as a Very Small Quantity Generator (VSQG).
If you are new to the game of hazardous waste, the first thing you should do is to determine what type of waste streams you have. Materials that are determined to be ignitable, reactive, corrosive or toxic will need to be considered. Then you should judge how much you generate of each waste. In Massachusetts for example, if you generate less than 220 pounds (27 gallons) of hazardous waste a month and no acutely hazardous waste then you can register as a VSQG, if it is more you will have to look into becoming a Small Quantity (between 220-2,200 lb and/or less than 2.2 lb of p-listed waste) or a Large Quantity Generator (over 2,200 lb and more than2.2 lb of acutely hazardous waste). As a VSQG, you can accumulate up to 1, 000 kilograms (or 2,200 lb/ 270 gallons) onsite for an infinite amount of time, but can never store more than that onsite. You should be mindful to never exceed these limits or you will have to register as a SQG or a LQG and you should always check your state regulations for specifications. Minimizing the amount of hazardous waste generated by using non-hazardous substitutes and/or recycling and reusing alternatives whenever possible can help you stay under these limits.
If you meet the criteria for a VSQG, you are given more flexibility than the larger generators, but you still have specific requirements you must follow. You may still need to register with your state environmental agency (look on their website for registration forms) and you are still responsible for correctly managing your waste. A few of the requirements are listed below.
- Store hazardous waste on an impervious surface
- Secure the storage area against unauthorized access
- Post Hazardous Waste signs near the storage area.
- Label each container as hazardous waste with the name of the waste fully spelled out and its associated hazard(s) such as “ignitable” “corrosive” “toxic” or “reactive”
- Retain records of all hazardous waste manifests for shipment as well as any records of the type/quantity of waste generated and the date/method of treatment, recycling or disposal.
If you’re unsure about any step in the process, check your state’s environmental webpage or contact an environmental advisor to review your current procedures and jumpstart your environmental health and safety program.