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Prudent Practices in the Laboratory: Handling and Disposal of Chemicals
Recent years have seen a proliferation in the number of laws, regulations, and ordinances, federal, state, and local, that affect laboratories. This body of law is vast, complex, and intricate in its details and interrelationships. Both the law and its application vary from state to state, among federal regulatory agency regional offices, and among local jurisdictions. The individual researcher or laboratory worker cannot possibly be familiar with all of these regulations, but it is important that there be a strong institutional capacity, usually in a specialized office of environmental health and safety professionals, that is familiar with the details of these rules and can act as a resource for the researcher. In those smaller institutions that may not have such a specialized office, a researcher or an assigned individual, perhaps from the chemistry department, should seek advice directly from the regulatory agencies, from knowledgeable environmental health and safety professionals from other institutions, or from private environmental health and safety professionals and consultants.
In addition, all researchers should be familiar with the principal provisions and concepts of the most important laws and regulations that affect laboratories across the country. The two most important are the Occupational Safety and Health Administration's regulation, Occupational Exposure to Hazardous Chemicals in Laboratories (the OSHA Laboratory Standard) and the Resource Conservation and Recovery Act (RCRA), under which the Environmental Protection Agency (EPA) regulates hazardous waste. Because of its importance, the text of the OSHA Laboratory Standard is reprinted in Appendix A. Researchers, laboratory workers, and, in particular, laboratory managers and supervisors should read and understand these regulations.
9.BRISK AND REGULATION
Within the scientific research community, ambivalence about environmental health and safety regulations has raised much attention. The ethical conduct of science encourages excellence in scientific discovery while upholding societal values. Not surprisingly, highly trained chemists and other scientists, while fully supporting prudent and safe practices in the laboratory, sometimes feel that regulatory requirements do not distinguish scientifically among the varying levels of risk presented by some substances and procedures. To some extent this is true, but carried to an extreme, this perception can preclude a sufficient understanding of the rationale and realities that underlie environmental health and safety laws and regulations.
The basic laws-the Occupational Safety and Health Act, governing worker safety and health, the Resource Conservation and Recovery Act, governing the safe generation, storage, transport, and disposal of hazardous chemical waste, and the Clean Air Act and Federal Water Pollution Control Act, protecting public health and the environment-have been conceived soundly. These and other laws reflect congressional, state, and local legislative concern about the problems they address and generally enjoy strong public support. These and other relevant laws, along with their associated regulations, are listed in Table 9.1.
The research chemist might ask, ''Why do I have to label all the chemicals in my laboratory? I know what's in those bottles." "Why can't I pour this chemical down the drain? It's such a small quantity that it will be diluted to harmlessness." "Why must I fill out detailed labels for the waste containers in my laboratory? Who needs all this paperwork?" and so forth.
The regulator would answer, "Yes, but if your chemicals aren't labeled, new workers in the laboratory won't know what is in those containers. If they don't know the contents, how can they properly use, store, or dispose of the unlabeled chemicals? Also, what happens if there's a fire or other emergency? The emergency crew responding won't know what's in your laboratory." Or, "If everyone poured just a little bit of that chemical down the drain, it could, cumulatively, seriously degrade water quality in sensitive rivers, lakes, or streams."
This debate is complicated by the fact that it is a virtual impossibility for environmental health and safety regulators to weigh every risk precisely. To attempt chemical-by-chemical regulation of the thousands of known, and unknown, chemicals would be so onerous and time-consuming as to leave many serious hazards unregulated. Consequently, the regulators have tried to strike a balance, regulating by class of risk, for example, ignitability, corrosivity, reactivity, and toxicity, and relying on employers to exercise reason and prudence in caring for the safety of their employees, as in OSHA's "General Duty" clause and the Hazard Communication Standard and the Laboratory Standard.
Those managing and working in laboratories should also recognize that violation of environmental health and safety laws and regulations not only may pose unnecessary risks to those in the laboratory and the surrounding community, but also can result in serious collateral consequences-imposition of civil penalties (fines of up to $25,000 per day per violation), as well