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Waste From Laboratories 

Background

See Resource Conservation and Recovery Act — General and Resource Conservation and Recovery Act — Solid and Hazardous Wastes.


Key Concepts

See Resource Conservation and Recovery Act — General and Resource Conservation and Recovery Act — Solid and Hazardous Wastes.

Acute Hazardous Wastes (P-Listed Wastes)

Certain hazardous wastes are subject to higher levels of regulation. These are acute hazardous or “P-listed” wastes. Laboratories are usually the only places on a campus that will generate these wastes. Examples include arsenic compounds, azides, cyanides, and osmium tetroxide. The complete P-list is in 40 CFR 261.33.

Used reagents on this list are not automatically acute hazardous wastes. Under federal standards, an acute hazardous waste is only an unused discard, an off-specification product, or a container residue where the chemical in the P-list is the sole active ingredient. There are specific rules in 40 CFR 261.7 for empty containers that held these wastes.


Does this apply to my campus?

Yes. Laboratory activities conducted at campuses and universities produce a variety of wastes, most of which are subject to at least some Resource Conservation and Recovery Act (RCRA) requirements.


What do I have to do?

First, perform hazardous waste determinations on solid wastes generated by the various laboratory activities. Note that laboratory reagents, as well as cleaning materials and equipment that contains mercury, are potential sources of hazardous waste.

Next, determine how your campus will meet RCRA management requirements prior to offsite disposal. You might elect to accumulate wastes in the labs that generate them or move them to accumulation areas.

Also, you might include treatment as part of the laboratory operation or neutralize corrosive wastes in the laboratory or nearby. Conditionally exempt small-quantity generators (CESQGs) may perform other treatments to reduce hazard and volume of waste. Beyond elementary neutralization of corrosive wastes and treatment by CESQGs, most treatment options either require a permit or at least consultation with the state or federal RCRA enforcement agency.

The hazardous waste regulations also allow drain disposal of small amounts of wastes under specific conditions. The local sanitary sewer authority (publicly owned treatment works or POTWs) may have an ordinance that limits this practice. Land disposal restriction notifications may also apply. See Clean Water Act — Sewer Use (POTW).

Under federal rules, up to 55 gallons of waste may be stored in each Satellite Accumulation Area (SAA) in individual laboratories. You might decide that moving waste to accumulation areas more often makes laboratories safer and more efficient.

Activities in laboratories vary as new products and processes become part of the curriculum. Personnel change routinely, and new and visiting faculty may add new wastes to the existing list of waste streams. Update your management plan as needs change.

In any event, waste containers must remain closed, in good condition, and compatible with the wastes they hold. Containers must have labels that indicate their contents. You must dispose of laboratory waste before applicable accumulation time limits pass.


Hazardous Wastes Typically Found in Labs

Lab-Related Hazardous Wastes

Regulatory Description

Waste Codes

Solvents, alcohols, acetone, acetonitrile/water blends, aerosol can residues, etc.

Ignitable: Flash point < 140 ºF

D001

Acids, bases, etc.

Corrosive: pH < 2 or pH > 12.5

D002

Cyanides, sulfides, aerosol cans, organic peroxides, picrates, alkaline metals, etc.

Reactive: cyanides, sulfides, compressed gasses, materials that react spontaneously or with water

D003

Metals solutions, mercury, some waste pesticides, some toxic solvents such as carbon tetrachloride, benzene, chloroform, etc.

Toxic

D004–D043

Spent solvents, including methylene chloride, carbon tetrachloride, xylene, acetone, alcohol, etc.

Solvent waste: See 261.25 for specific list of solvents and solvent mixtures

F001–F006

Outdated products, including excess solvents, acids, MEK, MIBK, etc.[STEVE: Define MEK and MIBK?]

Outdated or excess products in which the listed chemical is the sole active ingredient

U001–U409

Outdated cyanides, osmium tetroxide, strychnine, brucine, toxaphene, nicotine, etc.

P001–P205 (acute hazardous)

 

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