Best Practices 

Even when not required by environmental regulations, the following best practices are recommended. In some instances, best practices presented here are actually required by regulations.

Employee Training

Training employees on proper procedures to reduce your facility’s impact on the environment is a best practice. Employee training may include the following:

1. Spill response training for personnel who handle hazardous material,
2. Right-to-know awareness training, and
3. Hazardous materials management.

Amalgam Management Procedures

Utilize these best practices to lessen the impact of amalgam handling:

1. Consider purchasing an amalgam recycling unit, or if not cost-effective, utilize the services of an amalgam recycler.
2. Consider the use of mercury-free materials, as appropriate.
3. Use precapsulated alloys of the smallest possible size to minimize amalgam waste that needs to be managed.
4. Place leftover material in an airtight container for recycling.
5. Place empty capsules in the trash.
6. Shavings and drilling waste from restoration procedures can be intercepted by drain traps and screens. Consult with your equipment supplier to determine the most appropriate mesh size to use in the drain traps.
7. Clean screens and traps at least once a week or more frequently as needed.
8. Screen, draintrap material, or extracted filled teeth should not be placed in the medical waste bag or general solid waste. Medical waste may be incinerated and will release the mercury to the atmosphere.
9. Care should be taken when amalgam waste that has contacted human body fluids is handled. Some dentists place the removed traps inside a glove to prevent exposure. The container in which contact amalgam is stored should be red or labeled with the appropriate symbol and the word "biohazardous."

Amalgam Handling “Don’ts”

1. Never put scrap amalgam in the sharps container or in the red biohazard bag.
2. Never place scrap amalgam in the trash.
3. Never rinse scrap amalgam down the drain.
4. Never place extracted teeth with the amalgam in the red biohazard bag. Extracted teeth should be put in the “CONTACT AMALGAM” container.

Silver Recovery Process

Using a silver recovery process may save you money and allow you to avoid handling many materials used/produced as part of the X-ray process. Suitable recycling methods include:

Hazardous waste management firm - Developer/fixer disposal can be handled through a silver reclamation facility that is licensed to accept hazardous waste. Make certain you obtain the appropriate copy of the manifest and certificates of reclamation for shipments sent to these companies.

Purchase your own silver recovery unit - Purchase and use your own silver recovery unit on-site. Operating this type of unit will require certain regulatory obligations. Make certain that the residual concentration of silver in your recovery process waste is allowable to be discharged to the local sewer system.

Waste Handling and Disposal

Best practices related to waste handling and disposal include the following activities:

1. Perform regular housekeeping activities in waste storage areas.
2. Reuse or recycle materials whenever possible.
3. Inspect waste management areas for spills and waste management containers for leaks.
4. Track waste generated, evaluate the process generating the waste and look for ways to reduce waste generation.
5. Characterize waste streams.
6. Find substitutes for harmful chemicals; properly dispose of unusable chemical inventory.
7. Segregate and separate wastes.
8. Do not dispose of liquid wastes such as oils or hazardous materials into dumpsters.
9. Maintain adequate supplies of spill response equipment and materials in accessible locations near areas where spills may be likely to occur.
10. Perform and document in a logbook periodic inspections of hazardous and non-hazardous waste storage areas.

Waste Determination

1. Train technicians in the characteristics of what defines a hazardous waste. The generator of the waste has the most process knowledge of the waste and can help with the most accurate characterization of the waste at the time of generation without having to submit waste to an analytical laboratory for analysis.
2. Generators should place waste material in Satellite Accumulation Areas with accurate information to allow for characterization.
3. Maintain record of accumulation so process knowledge can be retrieved if needed.
4. If necessary have waste characterized by a certified laboratory.

Storage in Satellite Accumulation Areas
Satellite Accumulation Areas (SAA) have certain aspects that are mandated by regulation such as:

1. Only 55 gallons of a hazardous waste or one quart of an acutely hazardous waste may accumulate in a SAA.
2. While at the federal level there is no time limit for accumulation in an SAA, many states or local authorities have limited the time wastes can accumulate in SAAs. Check with your EH&S staff on state requirements.
3. Full containers must be transferred to a hazardous waste accumulation area within 72 hours.
4. Waste must be segregated by chemical compatibility, waste classification and physical state.
5. Waste containers must be labeled as “Hazardous Waste” in accordance with state and local waste handling regulations.
6. Waste containers must be compatible with the waste they contain, be in good condition and kept closed except for transferring waste to or from the container.

Beyond these regulatory requirements some best practices that can be implemented in the management of SAAs include:

1. Waste containers should be labeled not only as Hazardous Waste, but should also include the generator’s name and phone number, chemical name of the waste, hazardous properties, and a log should be kept that records the date, amount and type of waste added to the SAA. Be sure labels are compatible with the waste type. Some inks and markers may run or become illegible on contact with some solvents. Some adhesive labels may fall off or be damaged on contact with solvents, acid or bases.
2. The SAA should be assigned to a specific individual who is accountable for managing the waste. Ideally this will be the generator of the waste or the generator that adds most of the waste to the area.
3. Best practices would have the SAA be a separate ventilated cabinet or drums stored in an area away from floor drains and with secondary containment. Either small tubs for containers of compatible wastes or drum tubs for drums. Secondary containment should be able to contain 100 percent of the largest container within it or 10 percent of the total volume of containers held within the secondary containment.
4. SAAs should be located away from doorways, walkways or other means of egress.
5. SAAs that accumulate flammable liquids such as organic solvents must also meet fire safety code requirements, such as storage in a ventilated flammables cabinet and have a fire extinguisher nearby.
6. Do not accumulate flammable liquids in glass containers. Red metal safety cans should be used.
7. Secondary containment tubs of multiple containers should be compatible with the wastes they hold and hold only wastes that are compatible with each other.
8. Do not store usable chemicals, reagents or unmarked bottles in the SAA. These may be mistaken for improperly labeled waste.
9. Do not store wastes or other chemicals in laboratory fume hoods.
10. Do not allow volatile wastes to evaporate and escape to the atmosphere or lab environment.

Container Management

Best practices for the storage and handling of hazardous waste containers in the laboratory include:

1. Maintain separate waste containers for compatible waste streams (i.e., acid, bases, oxidizers, organic solvents, radioactive waste, etc.).
2. Separate containers with incompatible wastes with a berm, tub or other barrier.
3. Clearly label containers with the name of the appropriate waste type in addition to identify the container as a hazardous waste container.
4. Log chemicals and quantities added to waste containers as chemicals are added.
5. Train laboratory personnel on safe procedures to transfer chemicals to waste containers.
6. Maintain separate containers for broken glassware, sharps, biohazard and radioactive waste.
7. Do not store waste containers where they have the potential to freeze or are exposed to high heat.
8. Keep waste containers in tubs or other secondary containment.
9. Waste containers should be in good condition, not rusted or dented.
10. Clearly mark the area as a hazardous waste storage area.
11. Make sure waste containers are compatible with the waste type they are expected to contain.
12. Keep an adequate spill control kit nearby. Clean up all spills quickly.
13. Periodically inspect the waste container area and log observations and corrective actions taken.
14. When handling waste containers use mechanical aids such as drum lifts, drum hand trucks, drum dollies, etc. Do not roll drums on their side or edge.

Waste Minimization
Hazardous Waste

1. Minimize the amount of chemicals stored in the lab to the minimum quantities needed to avoid having to dispose of chemicals that expire or deteriorate during storage.
2. Develop an inventory of chemicals no longer needed in your lab that could possibly be used by another.
3. Implement microscale chemistry techniques where possible.
4. When preparing standards and reagents that contain hazardous waste, only prepare the amount necessary for near term use to avoid generation of waste.
5. Use organic dishwashing solutions instead of chromic-sulfuric acid mixtures when washing glassware if possible.
6. Where possible substitute less toxic chemicals where toxic chemicals are used in a procedure or process.
7. Evaluate ways to reduce the amount of toxic chemicals used in lab procedures. Examples include:
   · Using stool preservatives that do not contain copper or mercury.
   · Use-pre-filled formaldehyde containers for specimen collection. Use smaller four ml specimen containers if possible.
   · Use mercury free hematoxylin stains.
   · Perform chlorine analysis using Ion Selective Electrode (ISE) methods that generate less waste than colorimetric methods.
8. Re-use or recycle spent solvent.
9. Avoid contaminating non-hazardous waste streams with hazardous, radioactive or biohazardous material.
10. If possible, small amounts of hazardous waste may be effectively treated in the laboratory, rendering it non-hazardous prior to disposal. (Note: This action may require a RCRA permit in some circumstances) On site treatment techniques may include:
    · pH neutralization
    · Treatment in accumulation containers, i.e., precipitation of heavy metals
    · On-site recycling
    · Burning in boilers or furnaces
    · Include detoxification or waste treatment steps in lab procedures
    

Radioactive and Mixed Waste

1. Replace toluene based liquid scintillation fluid with non-ignitable fluid making a potential mixed waste into a radioactive waste.
2. Use low volume liquid scintillation vials.
3. Use radionuclides with short half lives that can be allowed to decay in storage prior to disposal.

Non-Hazardous and Special Waste

1. Use two sided copying
2. Make procedures, MSDSs, manuals etc. available electronically
3. Use e-mail instead of hard copies
4. Share trade periodicals
5. Use reusable containers
6. Use rechargeable batteries
7. Set up recycling programs for cardboard, glass, drink cans, plastics

Emergency Equipment

Best practices for laboratory emergency equipment includes the following:

1. Emergency eyewash stations and showers in areas where there is the potential to come into contact with hazardous chemicals, unobstructed access from any point in the lab within 10 seconds, and located on the same level as the potential hazard.
2. Fire extinguishers easily accessible, and of size and type to be effective against an anticipated fire.
3. Fire Blankets.
4. Communications systems including telephones, radios, alarms.
5. Emergency personal protective equipment including SCBA’s, disposable coveralls, gloves, eye protection, short term escape respirators.
6. Spill control equipment including, spill pillows, absorbent pads, drum berms, drain plugs, hand pumps, neutralization solutions.
7. Air monitoring instrumentation, either portable or fixed systems if needed.
8. First aid kit, including burn kit.
9. Periodic inspection of equipment to ensure its effectiveness and availability.
10. Hands-on training of laboratory personnel in the use of emergency equipment.

Sharps

1. Segregate medical wastes at the point of generation; do not mix medical or infectious waste with hazardous or radioactive waste. Further segregate wastes into three categories, Sharps, Waste for Incineration and Waste for Other Disposal/treatment options. This will minimize the amount of waste that must be incinerated and possibly keep the incinerator in a lower operating classification minimizing the regulatory requirements of the incinerator.
2. Be sure medical and infectious waste is properly bagged and/or containerized as close to its source of generation as possible. This will protect those that transport and handle the waste downstream.
3. Store medical waste in sturdy 3 mil plastic bags. Bags or other containers should be sturdy and not subject to leakage. Label bags with information identifying the generator, date, and type of waste contained. Use red bags that do not contain toxic metals or toxic inks.
4. Wastes should be stored in areas with adequate ventilation and waste should not be allowed to decay to prevent creation of odors. If necessary, refrigeration may be needed.
5. Areas used to store medical and infectious waste should be durable, impermeable to liquids and easily cleaned and disinfected. The area should be protected from rodents and other vermin that could potentially spread infectious material. The area should be protected from the weather.
6. Waste areas should be clearly marked and secured and controlled to allow access to only authorized personnel.
7. Clearly mark containers as containing medical/infectious waste and be sure these markings (labels) comply with the OSHA Bloodborne Pathogens Standard.
8. For wastes that are autoclaved, maintain a log indicating date, time and material disinfected along with parameters such as temperature, run duration, pressure, etc.
9. Dispose of sharps separately in specified sharps containers. Do not fill containers more than ¾ full.
10. Where possible seek environmentally appropriate treatment options. Avoid incineration where possible. Treatment options for medical and infectious waste may include:
    - Chemical treatment - usually used to treat sharps prior to disposal as solid waste. Some infectious fluids can be chemically treated and discharged to a sanitary sewer. Be sure to check with the wastewater treatment plant or local regulators before discharging any wastes to the sanitary sewer system. Chemicals used for treatment can include chlorine solutions, bactericides, fungicides, and may be considered hazardous.
    - In some cases certain biological and infectious fluids can be discharged directly to the sanitary sewer. Check with the wastewater treatment plant to be sure as to what is allowed in your area.
    - Steam sterilization may be used to treat sharps, pathological wastes, and some animal wastes. Steam sterilization has the advantage of not producing chemical wastes but usually requires equipment operated by trained personnel.
    - Incineration can be used to treat a large volume of wastes. However incineration requires adherence to special regulations for medical incinerators because of the potential to pollute the air and the ash may need to be managed as hazardous waste if it meets the characteristics of hazardous waste.
11. Review opportunities for waste minimization. Conduct a waste stream analysis and identify areas where wastes can be minimized or recycled.
12. Educate employees on the importance of following waste minimization and segregation.

Medical Waste/Incinerators

1. Segregate medical wastes at the point of generation, do not mix medical or infectious waste with hazardous or radioactive waste. Further segregate wastes into three categories, Sharps, Waste for Incineration and Waste for Other Disposal/treatment options. This will minimize the amount of waste that must be incinerated and possibly keep the incinerator in a lower operating classification minimizing the regulatory requirements of the incinerator.
2. Seek alternative treatments other than incineration for some types of medical or infectious wastes. Sharps can usually be chemically treated and then disposed of as solid waste, in some cases certain biological fluids may be disposed of down the sanitary sewer system if approved by the local waste water treatment plant, other biological fluids may be chemically treated and then disposed of through a sanitary sewer system.
3. Be sure medical and infectious waste is properly bagged and/or containerized as close to it’s source of generation as possible. This will protect those that transport and handle the waste downstream.
4. Clearly mark containers as containing medical/infectious waste and be sure markings comply with the OSHA Bloodborne Pathogens Standard.
5. Store medical and infectious waste near its point of generation to limit the amount the waste must that be handled.
6. Review opportunities for waste minimization. Where practical reduce the use of single use disposable plastic items and use washable, sterilizable items that can be reused.