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LIFE SCIENCES LINE
In This Issue
Bar-Codes and Laser Beams
Lab Trash - Differentiating Lab Haz and Non-Haz
Project Jumpstart
Bar-Codes and Laser Beams
Written by Matt Chiasson, Field Chemist
Over the past year, Triumvirate Environmental's Chemical Inventory has grown
substantially. Companies have begun to see the value in implementing a database for their
chemical supplies, especially with the enforcement of the Department of Homeland
Security's chemical watch list. This regulation requires companies to be able to prove if
they have any chemicals of interest pertaining to the list; and chemical inventory systems
provide just that. A database provides chemical location, quantity, size, expiration,
hazards, and MSDS reports. Separate reports can be created to run flammable limit alerts,
low chemical level amounts, and DHS chemical watch list alerts. Many systems can also be
configured to custom specifications desired by the user.
Some may view inventory as redundant or and time-consuming. Nevertheless, creating a
massive database completely revolutionizes a client's ability to track their chemicals and
bring them to the cutting edge of chemical management is far more gratifying and
beneficial to Triumvirate than anyone could imagine. After a week or two, a relationship
grows through the process of creating the inventory. Green becomes a familiar color in the
labs. Researchers watch for days as Triumvirate chemists delve into hoods and flame
cabinets, carefully excavating chemicals out to record size, make, product number, cas
number, chemical name, location, bar-code and finally scan them into the system before
meticulously placing them back into their habitats as if they had never been touched. This
process is a great way to establish a presence in labs and show Triumvirates'
professionalism, promoting the prospect of providing more services. Traveling from
lab-to-lab allows for the observation of waste streams, lab practices, and how a company
operates. This knowledge is a great advantage and tool for getting the premeditated WOW!
from the work Triumvirate draws from the Chemical Inventory service.
New Office Locations
Triumvirate Environmental is
pleased to announce the
acquisition of three new offices
in Baltimore, MD, Salisbury, MD
and Stafford, VA.
Triumvirate now offers the
following services to the
mid-Atlantic Region: Vacuum
Truck, Tanker, and Vactor
Service; Oil/Water Removal and
Recycling; Industrial
Maintenance and Cleaning;
24-Hour Emergency Response
and Spill Cleanup; Laboratory
Relocation & Lab Pack Services;
Petroleum-Contaminated Soil
Removal and Disposal; Roll-Off
Box Services; AST and UST
Cleaning; OPA-90 Contracts,
OSRO, and AMPD Coverage &
Exercises; PCB Removal,
Remediation, and Disposal;
Marine Transfers and Ship &
Separator/Floor Drain Cleaning;
Bilge Pumping and Cleaning.
Upcoming Events
Initial IATA Dangerous Goods
Training
February 12, 2009
Woburn, MA
RCRA/DOT Refresher TrainingMA Specific Requirements
February 18, 2009
Marlborough, MA
Initial Hazardous Waste (RCRA)
Training
February 25, 2009
Woburn, MA
Chemical Inventory can be applied anywhere that chemicals are used. Some locations may
require a greater effort to manage than others, but these are the places that need it most.
As chemicals fall through the cracks, companies lose money by not being able to accurately
account for what they have in stock and how much they are using. Using a Chemical
Inventory database provides the best and most up to date information of every chemical's
quantity, type, and location, and is the safest and most practical method of managing
chemical supplies to date.
Lab Trash - Differentiating Lab Haz and Non-Haz
Written by Kristina Florentino, Field Chemist
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Introduction
The Resource Conservation and Recovery Act (RCRA) is our nation's primary law governing
the proper management, transportation, and disposal of solid and hazardous waste. The
goals of RCRA are to protect human health and the environment from the potential hazards
of waste disposal, to conserve energy and natural resources, to reduce the amount of waste
generated, and ensure that waste is managed in an environmentally sound manner. Under
RCRA Subtitle C (the hazardous waste program), hazardous waste is regulated from the
time it is generated until the time of its disposal; effectively, from cradle to grave.
Hazardous Waste
So what is hazardous waste? Hazardous waste is material that possesses inherent
characteristics that make it dangerous or potentially harmful to human health or the
environment. Hazardous wastes come in many forms, such as, a liquid, solid, containerized
gas, or sludges, and can originate from the by-products of manufacturing processes,
laboratory experiments, or simply from the discarding of commercial products.
In determining if your lab waste is regulated under RCRA or is simply non-hazardous trash,
you will need to establish whether or not your waste is hazardous. In order to do this,
there are some questions you will need to ask yourself: is the waste a solid waste? Is it
specifically exempt from the regulations? Does it exhibit at least one of four characteristicsignitability, corrosivity, reactivity, or toxicity? Or does it appear on one of the four
hazardous wastes lists (F-list, K-list, P-list, or U-list)?
Is it a solid waste?
Under RCRA, a solid waste is defined as any discarded material (substance that is
abandoned, recycled, inherently waste-like, or military munitions) that is not excluded
under 261.4(a), 260.30 or 260.31. The material may be in the liquid, solid, or semi-solid
form.
Is the waste excluded?
Once it is determined that the material is a solid waste, as defined by RCRA, the next step
is to establish whether or not the given substance is specifically excluded from the
regulations. Some materials are exempt from the regulations for a number of reasons; to
encourage recycling, regulation under another statute, potential for negative economic
impact, or the impracticality to regulate. Some common examples of wastes that are
excluded are household wastes, radioactive wastes, and industrial discharges.
Is it a charateristic or listed waste?
If the given waste is determined to be a solid waste and is not specifically exempt, it must
be established if it would fall under the definition of hazardous. Wastes are classified as
hazardous whenever they exhibit one of the four characteristics, defined under Subpart C.
The four characteristics are as follows:
Ignitability (D001) - Ignitable wastes are substances which are capable of creating
fires under certain conditions, are spontaneously combustible, or have a flash point
less than 60 °C (140 °F). Common examples of ignitable wastes are oxidizers,
solvents, and organic peroxides.
Corrosivity (D002)- Corrosive wastes are acidic or alkaline with a pH value of less
than or equal to 2 or greater than or equal to 12.5 (aqueous), or have the that
ability to corrode steel (40 CFR 261.22).
Reactivity (D003) -A waste is considered reactive when it is unstable under normal
conditions or is capable of detonation. Examples include compounds which reactviolently with water, self-heating compounds, and materials that form toxic gases
when exposed to a corrosive environment (40 CFR 261.23).
Toxicity (D004 - D043) - Toxicity is defined through a laboratory procedure called the
Toxicity Characteristic Leaching Procedure (TCLP). The test replicates the leaching
process in municipal landfills, and is used to identify wastes that could potentially
leach concentrations that may be detrimental to human health or the environment
(40 CFR 261.24).
Waste that does not meet the definition of a characteristic waste, may still be considered a
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hazardous waste if included on one of the four lists created by the EPA. The lists are as
follows:
The F-list (non-specific source wastes) - This list identifies wastes from common
manufacturing and industrial processes. These processes occur in many different
sectors of industry, thus, the F-listed wastes are known as wastes from non-specific
sources (40 CFR 261.31). Solvents from processes such as HPLC machines are a
common example frequently seen in the lab.
The K-list (source-specific wastes) - This list regulates specific waste streams from
distinct industries, such as wood preservation, chemical manufacturing, and
petroleum refining (40 CFR 261.32).
The P-list and the U-list (discarded commercial chemical products) - These lists apply
to certain discarded virgin (unused) commercial grade chemicals (40 CFR 261.33).
Mixture and Derived from Rule
Now it gets a little more complicated; what happens when you have a mixture of a
hazardous waste with non-hazardous material or debris, such as personal protective
equipment (PPE), contaminated with hazardous materials/waste? The mixture and
derived-from rules address these issues. They were created to ensure that hazardous waste
generators do not try to elude regulation by intentionally diluting the waste with other
non-hazardous materials, and claiming that the waste no longer corresponds to the
applicable listing descriptions.
The mixture rule states that a mixture composed of any amount of a non-hazardous waste
and any amount of a listed hazardous waste is considered a hazardous waste. Thus, any
amount of a listed waste, no matter how minute, mixed with a large volume of
non-hazardous waste will carry the same waste code and regulatory status as the initial
waste carried. The rule is applicable regardless of the chemical composition and properties
of the resulting mixture. Fortunately, the EPA revised the rule, deciding that once a
characteristic waste no longer exhibits one of the four characteristic properties, it is no
longer warranted to regulate the waste as hazardous. However, any material that comes
into contact with a non-characteristic listed waste (D001-D003) will be classified as listed,
regardless of its chemical composition or concentration. Let's take a closer look. Say a
researcher's gloves come into contact with a chemical; are those gloves now considered
hazardous waste? Well, the answer isn't that simple. In this scenario, you need to
determine at what point the chemical is considered waste. For instance, say the
researcher's glove came into contact with virgin isopropanol, while adding the chemical to
an HPLC machine. Assuming that the amount is small and that the gloves do not show the
ignitability characteristic, the isopropanol is not yet classified as a hazardous waste and the
gloves can be disposed of as regular trash. Now let's say that the researcher came into
contact with spent solvents, carrying a F003 code. The gloves have been combined with a
listed waste, and thus, will be classified as such.
The derived-from rule pertains to materials that are generated through the treatment of a
hazardous waste, such as the ash generated by incinerating hazardous material. In this
case, the ash would be considered "derived-from" hazardous waste and thus, would be
regulated as such, regardless of the ash's actual properties. Furthermore, it would carry all
the codes that the original waste held.
Accordingly, once a waste matches a listed description, it will always be classified as a listed
hazardous waste, regardless of how it is mixed, treated, or further altered.
RCRA Empty
So what about containers which formerly held the aforementioned materials? RCRA allows
containers which previously held chemicals or hazardous waste to be disposed of with
regular trash when empty, as defined by the regulation. The definition states that a
container, or an inner liner removed from a container, that previously held any hazardous
waste is empty if all wastes that can be removed using common practices, such as pouring
and pumping, have been removed. The residual material left in the container may not
exceed 2.5 centimeters (one inch) or be more than three percent by weight of the total
capacity of the container, if the given container is less than or equal to 119 gallons in size.
A container that has held a hazardous waste that is a compressed gas is determined to be
empty when the pressure in the container approaches atmospheric.
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It should be noted that with materials classified as acutely hazardous waste (P-listed), the
container or inner liner must be triple rinsed before disposal using a solvent capable of
removing the product, and the associated rinse aid must be treated as hazardous.
Project Jumpstart
Written by Kathryn Carpenter, Field Chemist
As more awareness is placed on the management of hazardous materials in a laboratory
setting, there is more pressure to be compliant with state and federal regulations. The
responsibilities of an Environmental Health and Safety program include, but are not limited
to:
Employee safety
Hazardous waste
Proper flammable materials storage
Managing "chemicals of interest"
Storing controlled substances and keeping accurate logs
Transportation of hazardous materials
Air emissions
Wastewater
Radiation safety
Bio-safety
Trainings
As a result, Triumvirate created Project Jumpstart - a program developed specifically for life
sciences companies to quickly assess their current program, perform a gap analysis, and
bring their program into compliance. By drawing on extensive training and experience, our
staff can assist you within many regulatory realms, such as environmental and safety
consulting, waste management, corporate audits, and wastewater management.
The first phase of Project Jumpstart is the assessment of the current program. In many
cases, employees are not aware of potential infractions due to the complexity of
regulations. The members of the Triumvirate team isolate areas that need immediate
attention, areas that may be improved or better managed, and areas that currently work
well.
After the assessment, a corrective action plan is developed in collaboration with your
compliance officers, researchers, safety committee, top management, and EH&S staff.
Triumvirate can provide the labor to implement the modifications. This could be a few
visits, or continued onsite services if necessary. In regards to waste management,
continuing support may include duties such as hazardous waste pick-ups, consolidations,
inspections, and implementing the best management strategies so employees can focus,
primarily, on their job responsibilities. To supplement the plan, a calendar is created to call
attention to all important compliance dates. This includes when reports are due, the
renewals of licenses and permits, and annual trainings required for employees, among
other important dates specific to your facility. It is a daunting task to meet all requirements
put forth by the many regulatory agencies, but Project Jumpstart is an opportunity to
assess and better your current environmental health and safety program as quickly and
effectively as possible!
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The authors of the Life Sciences Line attempt to ensure factual accuracy of all content. However, Triumvirate Environmental is not responsible for unintentional errors.
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