Managing chemical (hazardous) waste in the laboratory is easily one of the most complicated areas of safety to understand. The regulations are set forth by the Environmental Protection Agency (EPA) and enforced by them or representatives of their state branches. For laboratories that are housed in hospitals or other large facilities, hazardous waste is often removed and handled through other departments like environmental services or maintenance. In the eyes of the EPA, the waste generated by the lab is the responsibility of the lab until it gets to its final disposal location. If other departments manage lab waste, the lab should routinely make sure it is being handled appropriately.
One of the most common areas where hazards occur in waste management regards storage. There are two types of chemical waste storage areas that can be designated in a facility, a Satellite Accumulation Area (SAA) and a Central Accumulation Area (CAA). Chemical waste is initially stored in a SAA which must be within the line of vision from where the waste is generated. Labs may store up to 55 gallons of waste in a SAA, and the EPA does not permit moving waste from one SAA to another. If the waste stored at the SAA is flammable, it should be kept inside of a flammable storage cabinet, but that cabinet would also need to be visible from the point of waste generation.
A second common issue surrounding hazardous waste is container labeling. In most US states, it is required that all containers of chemical waste display the words “hazardous waste.” The label must also show a description of the waste (i.e. stain waste, xylene waste, etc.). Finally, there must be some sort of hazard warning on the label. That warning may be in the form of a pictogram, a NFPA or HMIS warning label. If waste is poured into an empty reagent container, no elements from the original product label may be used, even if the waste is the same as the original reagent. Cross out the original label and place a new complete hazardous waste label on the container.
Containers placed in a SAA should not have an accumulation start date on the container. Facilities are allowed to store waste on site for specific periods of time based on the generator status selected as part of the EPA registration process. However, that storage time limit does not start until the waste is moved to the Central Accumulation Area. All waste in the CAA must be labeled with an accumulation start date.
The third hazard that crops up often in laboratories surrounds recordkeeping. Chemical waste vendors will come to the facility and they may remove waste containers from the CAA or any SAA. When they remove waste, they present a waste manifest which must be signed by a facility representative. Whoever signs that initial manifest must have a specific hazardous waste training that is required by the Department of Transportation (DOT). It is easy for a lab to monitor their own staff training, but if a different department signs waste manifests for lab waste, you need to check that those signing have the required training documentation.
Keep initial waste manifests in a file. The facility should receive final waste manifests within 45 days, and those final copies should be matched up with the initial paperwork so the lab can be sure all waste has been delivered to its final destination point. If the manifest records are kept in other areas of the facility, a lab representative should make routine checks to ensure records are kept up to date.
As you can see, it is fairly easy to make an error when managing hazardous waste for your facility. The regulations are complicated, and we only scratched the surface of them in this blog. Perform waste audits regularly, and include all storage areas and departments in the facility that may handle your waste. Reach out to the EPA or a state branch representative and feel free to ask questions. Managing hazardous chemical waste can be tricky, but it can be done so that the lab follows all regulations and laboratory staff can remain safe.
–Dan Scungio, MT(ASCP), SLS, CQA (ASQ) has over 25 years experience as a certified medical technologist. Today he is the Laboratory Safety Officer for Sentara Healthcare, a system of seven hospitals and over 20 laboratories and draw sites in the Tidewater area of Virginia. He is also known as Dan the Lab Safety Man, a lab safety consultant, educator, and trainer.
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