Health and Safety

Mixing incompatible chemical wastes can be hazardous to your health.

The Safety Guys have to agree with a recent anonymous blog posting stating “most lab accidents…were the result of carelessness.” Like this example:

After a long day and hours of work in a research lab, a graduate student finished cleaning up and dutifully placed his damp rags in the waste container in the lab and left for the evening. Unfortunately, a few hours later, the fire in the trash container set off the fire alarm. Fortunately, no one was injured and only the lab and equipment were damaged when the heated closed container scattered shards of glass everywhere.

What happened? We all know that this was a case of mixing incompatible wastes. But why did it happen? And, how do we prevent these occurrences?

This month the Safety Guys will provide an introduction and overview of waste handling in a typical research laboratory. Even animal research facilities use chemicals and some are quite hazardous depending on the research focus. This article will zero in on hazardous chemical wastes as these are the main culprits when it comes to accidents, like the one described above. However, proper management of chemical waste is not only important for safety but also for economic health as well; serious fines and penalties are possible if regulated wastes are not handled according to the law.We will touch on the federal regulations, present a model program for chemical waste management, and discuss satellite accumulation areas. Our hope is that this will start a discussion leading to in-depth follow up articles on topics you, our readers, are interested in.

A Look Back to the Beginning
The federal Resource Conservation and Recovery Act (RCRA) of 1976 initiated our having to deal with hazardous chemical wastes. With this Act, Congress mandated that the Environmental Protection Agency (EPA) develop regulations for treatment, storage, and disposal of all hazardous wastes. The goal was to keep these harmful wastes out of the environment and curtail illegal disposal. This law put in place a recordkeeping and tracking system to follow hazardous wastes from “cradle to grave,” i.e. from the moment the waste is generated to its final disposal.

RCRA defines those wastes which are hazardous (and must be tracked) and specifies the manifest system to do this. The details are contained in the Code of Federal Regulations, Title 40 Protection of the Environment, parts 260 to 265.¹ Essentially, a waste record or manifest is developed by the generator of the waste and passed to the shipper or transporter and finally to the disposal facility. The manifest is checked and signed by each entity and after final disposal, the completed manifest is returned to the generator documenting the proper “cradle to grave” management.

Getting Started: Developing Your Model Program
Most laboratories that have been at this for a while can skip this section, because we know that you have already done your homework and have a program in place. For new labs and those getting started, we strongly encourage developing a written plan and policy statements. One excellent reference to begin with is Prudent Practices in the Laboratory, which can guide you in your safety plan development. ² This plan should designate a lab waste manager, assign responsibilities for the manager as well as laboratory workers, list required training and the method used to document training has occurred, and provide the standard operation procedures you will use to run your waste management program.

A written program also allows you to clearly state any specific policies that must be followed, such as “no hazardous wastes shall be disposed in the sinks or trash.” Finally, to complete your written plan include segments on periodic review of policy and operating procedures to address any changes or new additions to your laboratory’s activities and methods to evaluate the program’s overall effectiveness.

We must emphasize that although the federal regulation establishes a baseline, some states and local jurisdictions have waste or chemical management requirements that go beyond EPA compliance. Therefore, it is critical to check with state and local entities regarding any additional regulations.