tion. Records of costs, internal tracking, and so forth can provide information on the success of the hazardous waste management program.
Multihazardous waste is a waste that presents any combination of chemical, radioactive, or biological hazards. This array of waste constituent hazards makes the management of multihazardous wastes difficult and complex. For example, low-level mixed waste (LLMW) is a multihazardous waste that contains both RCRA hazardous wastes that EPA regulates and low-level radioactive wastes (LLW or LLRW) that the USNRC regulates. The hazardous characteristics, treatment methods, and disposal requirements for these wastes are different and often incompatible. Other factors that further complicate the management of multihazardous wastes include a complex federal, state, and local regulatory framework; limited disposal options; and high disposal costs. Commercial treatment or disposal facilities for multihazardous waste from laboratories are scarce. There is little incentive for the development of a commercial market to treat and dispose of laboratory multihazardous waste because most of the waste that laboratories generate is unique to laboratories and small in volume. The management of multihazardous waste is particularly challenging for research laboratories where there are frequent changes in protocols, procedures, materials, and waste generating processes. These difficult and complex management issues can also make it difficult to promote and sustain prudent pollution prevention practices.
Medical, clinical, forensic, and environmental laboratories, and biomedical, biochemical, radiological, and other types of research laboratories generate multihazardous waste. Prudent management of these wastes is necessary to protect the health and safety of all laboratory personnel who handle, process, and store the waste for disposal, and to minimize the potential of harm to public health and the environment. A further objective of prudent management of multihazardous waste is to promote excellence in environmental stewardship. The Congress established a federal initiative for preventing or reducing pollution in the Pollution Prevention Act of 1990. This initiative can serve as a guide for developing prudent practices for managing multihazardous wastes.
The Pollution Prevention Act of 1990 established a national policy that emphasizes source reduction as the most desirable approach for preventing or reducing pollution. The policy created a new hierarchy for the management of hazardous wastes. The elements of that hierarchy are listed in order of priority and importance for accomplishing the objectives of the Pollution Prevention Act.
• Source reduction. Pollution should be prevented or reduced at the source whenever feasible.
• Recycling. Pollution that cannot be prevented should be recycled in an environmentally safe manner whenever feasible.
• Treatment. Pollution that cannot be prevented or recycled should be treated in an environmentally safe manner whenever feasible.
• Disposal. Disposal or other release into the environment should be employed only as a last resort and should be conducted in an environmentally safe manner.
Federal agencies are required to promote programs to advance this policy within their agencies and nationwide. The major research agencies within the federal government, and particularly the Department of Energy, National Institutes of Health (NIH), and EPA, are providing leadership in implementing the nation’s pollution prevention policy, and are achieving results in source reduction. For example, NIH’s low-level mixed waste (LLMW) minimization program demonstrated that a significant amount of mixed waste currently being generated can be reduced or eliminated. References found on the accompanying CD provide more detail about the source reduction and pollution prevention initiatives of those agencies, the achievements of which have encouraged academic research universities and corporate research facilities to focus their pollution prevention programs on source reduction. EHS programs at these institutions often share information on their Web sites regarding source reduction, recycling, treatment, and disposal.
Prudent waste management methods include a commitment by senior management to develop and support a waste minimization program. The program development should involve experienced laboratory personnel in planning waste minimization strategies and identifying source reduction options, such as incorporating pollution prevention goals into project proposals. Training of laboratory personnel to recognize opportunities for source reduction, reviewing research proposals to ensure adoption of available source reduction strategies, improving compliance with regulatory requirements, and institutional policy are among the new management initiatives at research institutions promoting pollution prevention. Multihazardous waste requires complex attention because of its combination of hazards and regulatory controls, as detailed in the following guidelines: