Please note, however, that this book is not a compliance manual, and as such, its compliance information is incomplete. In particular, this chapter focuses on federal rules that apply to laboratory waste but not the many different requirements particular to each state or locale. Chapter 11 contains additional information on the institutional regulation of laboratory waste (as well as other environmental requirements) to complement this chapter’s details of laboratory waste regulation. There are many good compliance references to augment this book, and regulatory agencies should not be overlooked as another source of helpful information. Do not hesitate to seek legal advice when needed.


8.B.1 In-Laboratory Hazard Reduction

The first and second tiers of waste management broadly describe methods of reducing quantity and level of hazard of laboratory waste. Hazard reduction is part of the broad theme of pollution prevention that is encouraged throughout this book. From a chemist’s point of view, it is feasible to reduce the volume or the hazardous characteristics of many chemicals by conducting reactions and other hazard reduction procedures in the laboratory. It is becoming increasingly common to include such reactions as the final steps in an experimental sequence. Such procedures, as part of an academic or industrial experiment, usually involve small amounts of materials which can be handled easily and safely by laboratory personnel. Performing a hazard reduction procedure as part of an experiment has considerable economic advantages by eliminating the necessity to accumulate, handle, store, transport, and treat hazardous waste after the experiment. Furthermore, the laboratory professional who generates the potential waste often has the expertise and knowledge to safely handle the materials and perform hazard reduction procedures.

Conducting laboratory hazard reduction procedures for chemical hazardous waste makes most sense for hard-to-dispose-of waste, such as multihazardous waste, or for small or remote laboratories that generate very small quantities of easily treatable hazardous waste. In some cases, a simple procedure can make waste suitable for sewer disposal. When it can be done safely, knowledgeable laboratory staff may treat very small amounts of reactives that would otherwise pose a storage or transport risk. In some cases, waste is stabilized or encapsulated to enable safe storage and transport. More details can be found in section 8.B.6, below.

Keeping up-to-date chemical inventories can also reduce the in-laboratory hazards by simply reducing the quantity of hazardous material on-site. Ordering the smallest quantity of hazardous material required and reusing materials are also effective means of minimizing generation of hazardous waste.

Before beginning a detailed discussion of the handling of waste once it has been generated, it is important to understand the definition of waste, how it is characterized, and the regulations that govern it.

8.B.2 Characterization of Waste

Waste must be categorized as to its identity, constituents, and hazards so that it may be safely handled and managed. Categorization is necessary to determine a waste’s regulatory status, hazardous waste ID number, and treatability group, and to determine its proper U.S. Department of Transportation (DOT) shipping name, and to meet other transport, treatment, and disposal requirements.

The great variety of laboratory waste makes waste categorization challenging. Transport and waste regulations are written for commercially available high-volume chemicals, which may make it difficult to categorize some laboratory chemicals, such as experimental or newly synthesized materials. Categorization procedures must account for the common laboratory waste management practices of placing small containers of waste chemicals into a larger overpack drum, and combining of many solvents and solutes into a single drum of flammable liquids.

There are several acceptable information sources for waste characterization, including the identity of the source or raw materials, in-laboratory test procedures (such as those described below), and analysis by an environmental laboratory. Generator knowledge can be used for waste characterization, such as the knowledge of waste characteristics and constituents by laboratory personnel who conducted the process, procedure, or experiment.

8.B.2.1 Characterization for Off-Site Management

When waste is to be shipped off-site for recycling, reclamation, treatment, or disposal, the waste characterization information needed depends on the waste management facility’s requirements and its permit. Analytical methods have been established by the U.S. Environmental Protection Agency (EPA), and environmental laboratories that use EPA methods are often certified or accredited. Most of these methods are for commercially available chemicals, and so approved analytical procedures may not be available for some laboratory chemicals. It is important to work with your waste disposal firm to determine how laboratory waste is to be categorized. To avoid redundant analysis for recurring waste streams (e.g., chlorinated solvents,

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