Safety, Storage and Treatment of High
Level Disinfection Chemicals
CHAD FISHER
HAZARDOUS WASTE COMPLIANCE INSPECTOR
WA STATE DEPARTMENT OF ECOLOGY
JANUARY 29, 2016
Overview for Today
 Dangerous waste (DW) management overview
 High Level Disinfectants: Examples and Safety Concerns
 Treatment and disposal to sewer
 Challenges (violations) we’re seeing during dangerous
waste inspections … with example photos
 Useful resources: online guidance and labels
Dangerous Waste Management Overview
 Must designate waste
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WAC 173-303-070 through -100, -170
 Notification – based on generator status
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WAC 173-303-060, -170, -070(8)
 Annual reporting – based on generator status
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WAC 173-303-220, -390, -070(8)
 On-site management – based on generator status
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WAC 173-303-200, -201,-202, -320, -630, -640, -070(8)
 Manifest waste – based on generator status
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WAC 173-303-180, -070(8)
Managing Hazardous/Dangerous Waste:
General Context
 Container Management Requirements:
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labeling: hazardous/dangerous waste label
risk label, if applicable
accumulation start date, if applicable
closed containers, unless in use
containers in good condition and not leaking
aisle space between containers, if applicable
accumulation time limit: depends on generator status
weekly inspections of hazardous waste accumulation area
High Level Disinfectants: Examples and
Safety Concerns
 Glutaraldehyde:
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Often used at 2-4%; designates as dangerous waste at 1%
Linked with a variety of health effects, ranging from mild to
severe, including asthma, breathing difficulties, respiratory
irritation, and skin rashes
Best Practices for the Safe Use of Glutaraldehyde in Health
Care: https://www.osha.gov/Publications/glutaraldehyde.pdf
 ortho-phthalaldehyde (OPA):
o Often used at 0.55%; designates as dangerous waste at 0.01%
o May cause eye, skin and respiratory irritation
o May elicit an allergic reaction
o May cause sensitization by repeated skin contact
High Level Disinfectants: Examples and
Safety Concerns
 Peracetic Acid
 Corrosive and oxidizer; designates as dangerous waste at 0.1%
 Poison by ingestion
 Corrosive to skin and can cause serious eye damage
 Severely irritating to respiratory tract, potentially lethal
 Ethylene Oxide (EtO)
 Flammable and highly reactive
 Acute exposures to EtO gas may result in respiratory irritation
and lung injury, headache, nausea, vomiting, diarrhea,
shortness of breath, and cyanosis
 Chronic exposure has been associated with the occurrence of
cancer, reproductive effects, mutagenic changes, neurotoxicity,
and sensitization
 OSHA Safety and Health Topics:
https://www.osha.gov/SLTC/ethyleneoxide
Treatment and Disposal to Sewer
 Treatment by Generator (TBG)
 Notification requirement, log and report:
https://fortress.wa.gov/ecy/publications/SummaryPages/96412.html
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Aldehyde Deactivation:
https://fortress.wa.gov/ecy/publications/SummaryPages/1404003.html
 Discharge to Sewer after Treatment
 May be managed under the Domestic Sewage Exclusion, which
requires written authorization from the sewer authority
 May be managed under Permit by Rule and a wastewater
discharge permit
 See the TBG Guidance document for additional information
about the Domestic Sewage Exclusion and Permit by Rule
Treatment and Disposal to Sewer
 List of water and sewer districts in Washington:
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www.mrsc.org/subjects/governance/spd/spd-watsew.aspx
 Laboratory Waste Management Guide, King County:
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www.lhwmp.org/home/publications/eDownload.aspx?DocID
=o5fpDUrc%2f%2bc%3d
Local sewer discharge requirements will differ from those in
King County. Keep this in mind when using this resource.
Location: Ultrasound
Instrument Cleaning
Station
Waste: The blue
solution is Cidex waste.
Dangerous Waste
Violations:
• Lack of a “dangerous
waste” or “hazardous
waste” label.
• Lack of a risk label.
Location: Hazardous Waste
Accumulation Area
Waste: This box holds
approximately thirty smaller
containers of S40 sterilant consisting
of 35% peracetic acid.
Dangerous Waste Violations:
• Lack of a “dangerous waste” or
“hazardous waste” label.
• Lack of a risk label.
• Lack of an accumulation start
date.
• Waste accumulated without
proper segregation. Peracetic
acid is a corrosive organic acid.
This container is located within
the flammable cabinet. Corrosive
organic dangerous wastes and
flammable dangerous wastes
must be kept separate.
Location: Hazardous Waste
Accumulation Area
Waste: Ethylene Oxide
Dangerous Waste
Violations:
• Lack of a “dangerous
waste” or “hazardous
waste” label
• Lack of a risk label.
• Lack of an accumulation
start date.
Location: Hazardous Waste
Accumulation Area
Waste: “Unknown Cleaner
or ETO Cide”
Dangerous Waste Violations:
• Lack of a risk label.
• Lack of an accumulation
start date.
Top Ten Dangerous Waste Violations
 Source: Shoptalk, Vol. 23, No. 1, Dec. 2012; pub. # 13-04-001a):
https://fortress.wa.gov/ecy/publications/publications/1304001a.pdf
 #1: No label for risk or dangerous/hazardous waste on containers
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 #2: Not properly designating (identifying) the wastes
 #3: No accumulation start date on waste container
 #5: Not properly closing waste containers
 #7: Not conducting weekly inspections of waste containers in the
hazardous waste accumulation area
Dangerous Waste Regulations and
General Resources
 Guide for Dangerous Waste Generators in Washington:
https://fortress.wa.gov/ecy/publications/SummaryPages/981252HWTR.html
 What is a Small Quantity Generator? Your Regulatory Status
Under the Dangerous Waste Regulations:
https://fortress.wa.gov/ecy/publications/SummaryPages/96404.html
 All Dangerous Waste Regulations available online:
http://www.ecy.wa.gov/programs/hwtr/reg_comp_guide/173-303.HTM
 Weekly Inspection Checklist:
https://fortress.wa.gov/ecy/publications/SummaryPages/1204019.html
 Free Waste Labels:
http://www.ecy.wa.gov/programs/hwtr/hw_labels/index.html
Contacts: Pollution Prevention and
Dangerous Waste Management
Northwest Region
 Technical assistance
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Jenny Yoo
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
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425.649.7166
[email protected]
 Compliance assistance
 Chad Fisher
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Southwest Region
 Compliance assistance
425.649.7281
[email protected]
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Holly Cushman
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509.575.2724
[email protected]
 Compliance assistance
 Amy Cook
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509.575.2477
[email protected]
360.407.7553
[email protected]
Eastern Region
 Compliance assistance
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Andy Maher
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Central Region
 Technical assistance
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Lisa Perle

509.329.3612
[email protected]
Statewide Questions – Ecology HQ

Tom Cusack
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360.407.6755
[email protected]