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Reducing the Amount and Toxicity of Hazardous Waste
Not all potentially hazardous waste must be shipped off-site for treatment or
disposal. EPA and many states provide several regulatory exclusions that allow
generators to treat hazardous waste without a permit as part of a broader mandate
to further waste reduction efforts. In its publication “Little Known but Allowable
Ways to Deal with Hazardous Waste,” published in 2000, the EPA describes
five strategies for minimizing hazardous waste. These include the domestic
sewage exclusion, elementary neutralization, recycling, treatment in accumulation
containers and burning in small boilers. Recall that each state sets its own
requirements for compliance with RCRA regulations. Requirements cannot be less
strict than federal law, but states may impose more limitations than federal law.
Thus 28 states allow treatment in accumulation containers, two prohibit it, and the
others impose some conditions or restrictions on treatment methods. (A complete
state-by-state listing of all allowable waste reduction strategies can be found in the
Appendix to the EPA publication cited.)
Source reduction, or pollution prevention, is the preferred method for reducing
the environmental burden of hazardous wastes. Materials also may be reclaimed
by processing them to recover useful products. When source reduction and reuse
or recycling are not feasible, waste may be treated to reduce its volume and
toxicity. EPA allows drain disposal of even hazardous wastes via the “domestic
sewage exclusion” provided that amounts and chemicals are in compliance
with all wastewater standards and discharge limits imposed by publicly owned
water treatment works. Among the allowed chemical treatments are elementary
neutralization of acids and bases, precipitating metals from solution to obtain
insoluble salts and oxidation–reduction reactions. Treatment residues may still
require management as a hazardous waste, and residues destined for land disposal
are subject to land disposal restriction standards. Never dispose of chemicals
in a septic system or storm sewer. Make sure chemicals will not react with
piping systems, and do not specifically rely on dilution to reduce the reactivity of
chemicals or render them nonhazardous.
Licensed Hazardous Waste Disposal
Some chemicals always will require licensed hazardous waste disposal. These
include toxic heavy metal salts and their solutions, including mercury, lead,
cadmium and chromium; arsenic and its compounds; halogenated organic solvents,
such as methylene chloride, chloroform, trichloroethylene or perchloroethylene; and
various pesticides.
Summary
Most schools and many small colleges will fall into the least regulated “conditionally
exempt small quantity generator” class for complying with EPA regulations
regarding the storage and disposal of hazardous waste; however, it is important
to know your status. It is the responsibility of every school to identify all types
of hazardous waste that they generate—whether characteristic wastes or listed
wastes. An accurate and up-to-date chemical inventory is the most effective means
of keeping track of all chemicals and thus preventing the accumulation of unused
chemicals that will need to be discarded. This is especially important for discarded
chemicals that would be designated as P-list, or acutely toxic, hazardous waste. Of
the more than 2,400 chemicals that Flinn Scientific sells, only six are on the P-list.
Laboratory chemicals or chemical byproducts are not generally considered to be
waste until they have left the lab. To avoid restrictions on treating hazardous waste,
always incorporate treatment of excess chemicals or chemical byproducts from a
lab activity into the lab procedure itself. Please consult this Flinn Scientific Catalog/
Reference Manual for general guidelines and specific procedures, and review all
federal, state and local regulations that may apply, before proceeding. In its effort
to reduce the amount and toxicity of hazardous waste, the EPA provides several
exclusions for the treatment of hazardous waste without a permit. However, not
all states allow all of these procedures. Among the generally allowed treatment
methods are acid–base neutralization reactions, oxidation–reduction reactions and
precipitating metals to obtain insoluble salts. Some chemicals always will require
licensed hazardous waste disposal. Please call or email Flinn Scientific if you have
any questions or if we can offer additional assistance.
Review of Chemical Disposal Procedures
The administration, faculty and staff share responsibility for minimizing the amount
of hazardous waste and disposing of those wastes in a way that safeguards human
health, protects the environment and complies with all relevant environmental laws
and regulations.
It is suggested that regular safety meetings are conducted. The discussion period
will vary depending on the issues that need to be addressed.
It is important to keep a copy of safety training notes and a signed attendance
sheet to verify that regular safety training meetings were held. The sign-up sheet
is almost as important as the training notes and is usually the first thing that is
requested and reviewed by regulatory inspectors. A copy of the sign-up sheet that
we suggest using may be found at www.flinnsci.com/forms/signup.aspx.
References
1. “Hazardous Waste Management for School Laboratories and Classrooms,” EPA
Publication 908-F-06-001, February 2006. Available online (accessed August
2015)
2. “Chemical Management Resource Guide for School Administrators,” EPA
Publication 747-R-06-002, December 2006. Available online (accessed August
2015)
3. “Little Known but Allowable Ways to Deal with Hazardous Waste,” EPA Publication
233-B-00-002, May 2000. Available online (accessed August 2015)
4. ACS Task Force on Laboratory Waste Management; Laboratory Waste
Management: A Guidebook; American Chemical Society: Washington, DC (2012).
5. Margaret-Ann Armour, Hazardous Laboratory Chemicals Disposal Guide, Third
Edition; CRC Press, Lewis Publishers: Boca Raton, FL (2003).
6. National Research Council; Prudent Practices in the Laboratory: Handling and
Management of Chemical Hazards; National Academies Press: Washington, D.C.
(2011).
Review of Chemical Disposal Procedures, continued
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