Harvard University
All chemical laboratories eventually produce chemical waste, if only as a result of unused chemicals. In addition to ethical obligations to properly manage the waste to minimize harm to the environment and other personnel, Federal and state regulations have established "cradle to grave" waste management, tracking, and disposal requirements. Both criminal and civil liability permanently follow the waste generator.
The 1976 Federal Resource Conservation and Recovery Act and subsequent amendments created waste management responsibilities for waste generators, transporters, and treatment storage and disposal facilities. In addition, the 1980 "Superfund" Act requires generators to clean up waste dumps, regardless of whether or not their practices were improper at the time of disposal. Both these laws have been applied mainly to chemical or manufacturing companies, but academic and research laboratories are not exempt. While academic and research laboratories have been estimated to generate only 0.1 to 1% of the total US hazardous waste, they generate thousands of different chemicals. Several universities have been placed on the Superfund's National Priorities List for responsibility for cleanup of certain disposal sites they have used. The US Environmental Protection Agency (EPA), the federal agency that enforces chemical hazardous waste regulations, recently fined Yale University $69,570 (with a requirement to spend an additional $279,000 to institute other environmental programs), and the California Department of Toxic Substances Control fined Stanford University approximately $900,000 for hazardous waste handling practices. In both cases, the bulk of the chemical waste was generated in laboratories. The universities were cited for: improper waste storage, mislabeled waste, inadequate training in chemical waste management, improper mercury dumping, and open containers of waste.
Hazardous waste is a chemical or mixture which, if improperly handled, may pose harm to human health or the environment. A waste from your laboratory may meet the regulatory definition of "Hazardous Waste" and be subject to regulation if it:
* meets the definition of "Solid Waste" and it is not specifically excluded by the regulations, and
* meets EPA characteristic waste definitions of Ignitable, Reactive, Toxic, or Corrosive (common examples: broken mercury thermometers, waste oils, unused laboratory chemicals, HPLC waste); or
* is listed on specific Federal or State waste lists.
Unless your institution is a licensed Treatment, Storage and Disposal facility, you generally cannot evaporate, distill, neutralize, or chemically convert your waste. Rather, it must be collected for appropriate disposal at an EPA-approved facility. Discharge of chemicals to the sanitary sewer system is becoming increasingly limited and is not permitted in most jurisdictions.
Local authorities may have more stringent requirements, but there are practical steps you can take to prevent some of the common deficiencies that have been found in laboratories by the EPA:
* Inadequate training. Waste generators are required to be trained in proper waste management practices.
* Un/mislabeled chemical containers. Containers must be labeled with the words "Hazardous Waste" and the chemical name (rather than chemical formulas or code names). Other requirements, such as accumulation date, depend upon your institution's permit.
* Improper storage of chemicals. Containers must be compatible with the waste, in good condition, closed at all times that waste is not actively being added (i.e., no funnel), and segregated from incompatible waste containers (e.g., oxidizers and flammable, acids and bases).
* Specific requirements. Storage time limits in your laboratory and waste accumulation area, label dating practices, and specific waste characterizations are determined by your institution's permit and local waste and sanitary sewer requirements.
Much of your laboratory's waste is probably disposed in "lab packs", 55-gallon drums that are capable of holding approximately 15 gallons of waste in cans and bottles. Absorbent material such as vermiculite fills the voids between containers to protect them from damage and absorb any liquid that might leak from cans and bottles. The disposal cost for each lab pack typically ranges from $200 to $700, depending upon the waste hazard classification and market rate. These drums are specially transported to one of the few designated incinerators or landfills in the US. Due to the rising costs of proper transportation and disposal, chemical waste costs often exceed purchase costs.
The best hazardous waste programs begin with a strong waste minimization program to reduce waste at its source. Some practical actions that you can take to reduce waste volume include:
* Prevent costly "Unknowns" in your laboratory by labeling all containers and ensuring that the labels remain affixed and legible.
* Downsize your chemical container size and inventories. Minimize surplus chemicals. Many companies now offer smaller container sizes. Unused chemicals account for approximately 40% of the hazardous waste generated from laboratories, and disposal often costs more than the purchase price. Half-empty bottles in lab packs cost the same to dispose as full bottles.
* Store chemicals carefully to prevent spills because spill cleanup generates more hazardous waste. A secondary bin or container is advisable.
* Monitor your laboratory's chemical inventory to prevent costly disposal of expired peroxide-forming chemicals (e.g., isopropyl and diethyl ether, picric acid, tetrahydrofuran).
* Recycle and exchange chemicals whenever possible.
* Segregate hazardous and non-hazardous wastes.
* Use alternate or small-scale procedures to minimize waste volume and hazards.
Consult your institution's waste management office for other suggestions for waste minimization and waste handling. Your institution may have a chemical waste recycling and exchange program.
Added benefits of chemical downsizing (both container size and quantity of containers) include: increased reagent freshness, less potential for incompatible storage, increased storage space, and reduction of flammable and other hazardous chemical load.
There are many more specific requirements, and local, state, and federal inspectors (even those within the same agency) often differ in their interpretation of the existing regulations. The National Academy of Science has developed specific recommendations to the EPA and other regulatory agencies (see reference 1, pp. 9-10) to advocate a performance-based approach to regulating laboratory chemical waste.
How comfortable are you with your laboratory's compliance with your institution's hazardous waste management program? Contact your waste management or safety coordinator to ask for the specific details that apply at your institution or for a review of your program.
References
1. National Research Council's Committee on Hazardous Substances in the Laboratory, Prudent Practices for Disposal of Chemicals from Laboratories, National Academy Press, Washington, D.C., 1983.
2. Task Force on RCRA, Less is Better; Laboratory Chemical Management for Waste Reduction, American Chemical Society, Washington, D.C., 1985.
3. H.J. Sanders, 1986, Hazardous Wastes in Academic Labs, Chemical and Engineering News, February, 1986.
4. J. Cohen (1994) Science 266, 213. "Toxic Dispute Costs Stanford $1 Million."
The author may be contacted at Harvard University, Environmental Health and Safety Office, Longwood Campus Office, 200 Longwood Ave., Boston, MA 02115.
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