Pathology Labs
Best Management Practices For
Hazardous Materials/Waste Handling
(3/16/07)

 

Best Management Practices (BMPs) should be thought of as “good housekeeping” procedures. In medical facilities there are many waste streams that could be considered non- hazardous if properly recycled instead of thrown into the trash or dumped down the drain.

To the right of the waste heading you will find references to the respective federal and state law. Federal laws for waste management can be found in the Resource Conservation and Recovery Act (RCRA) - 40 Code of Federal Regulations (CFR) 260-266, 268, 270-273, 279, 280-282, and 148. State laws for waste management can be found in Florida Administrative Code (FAC) 62-730 and various Florida Statutes (F.S.). State laws on waste management are typical more stringent than federal laws.

 

Types of Waste:

 

1. Laboratory Solvents: [40 CFR 261 & 40 CFR 262 | FAC 62-730.030 |  F.S. 403.721]

Laboratories use a multitude of solvents when performing analysis. Solvents, such as xylene, methanol, ethanol, etc..., are used to dissolve samples and prepare slides. Any waste produced by using these solvents will be hazardous as many solvents are listed under the 40 Code Of Federal Regulations (CFR)  268.40. Most other solvents will be hazardous due to their ignitability characteristic, having a flash point < 140°F. Containers used to store solvent waste must be in good condition (no severe rusting, apparent structural defects or deterioration) and not leaking (no visible leaks). Drums should also be Department of Transportation (DOT) approved. Storage containers must be marked with the words “Hazardous Waste”, the date accumulation starts, and a list of the solvents in the order of decreasing amount.
If you produce 30-gallons or more of solvent waste a month, you will be a Small Quantity Generator (SQG). A SQG is defined as a business that generates between 220 — 2200 lbs. of hazardous waste in a given month. 30-gallons of solvent waste should exceed 220 pounds. Once you become a SQG, your business is subject to a higher level of regulation, and an EPA ID # must be obtained. To be in compliance with hazardous waste regulations, the spent solvent needs to be hauled by a licensed hazardous waste hauler to a licensed hazardous waste treatment, storage and disposal (TSD) facility. Records must be kept on site for all hazardous waste taken from your site for a minimum of three years.

2. Formalin or Formaldehyde: [40 CFR 261 & 40 CFR 262 | FAC 62-730.030 |  F.S. 403.721]

Some wastes are listed as hazardous under 40 CFR 268.40 due to their known potentially detrimental effect to health and the environment. Waste produced when using formaldehyde and formaldehyde mixtures is one such waste having the waste code U122. All formaldehyde waste must be collected and stored in containers that are in good condition (no sever rusting, apparent structural defects or deterioration) and not leaking (no visible leaks). Storage Containers should also be Department of Transportation (DOT) approved. Storage containers must be marked with the words “Hazardous Waste”, the date accumulation starts, and a list of contents in the order of decreasing amount. If you produce 26-gallons or more of formaldehyde waste a month, you will be a SQG. 26-gallons of formaldehyde waste exceeds 220 pounds. Once you become a SQG, your business is subject to a higher level of regulation. To be in compliance with hazardous waste regulations, the spent formaldehyde needs to be hauled by a licensed hazardous waste hauler to a licensed hazardous waste TSD facility. Records must be kept on site for all hazardous waste taken from your site for a minimum of three years.

3. Metal Compounds: [40 CFR 261 & 40 CFR 262 | FAC 62-730.030 |  F.S. 403.721]

Pathology laboratories use many metal containing compounds such as silver nitrate and chromic acid. Any waste produced from the use of compound containing silver, chromium, arsenic, barium, cadmium, lead, mercury, or selenium are potential hazardous wastes. These wastes should either be disposed of as hazardous or analyzed by an environmental laboratory using the TCLP method. If these substances are deemed hazardous waste then it is advisable to store each metal in a separate container, to avoid any unwanted reactions. Containers should be labeled as “Hazardous Waste” with a start accumulation date and a list of contents in decreasing order of amount.

4. Acids and Bases: [40 CFR 261 & 40 CFR 262 | FAC 62-730.030 |  F.S. 403.721]

Many different acids and bases are used in laboratories. A waste determination must be made for any waste produced from the use of acids and bases. If the resulting waste has a pH <2.0 or >12.5 it is considered corrosive and must be treated as hazardous. Acids and bases should be stored separately in containers marked “Hazardous Waste” with a start accumulation date.

5. Disinfectant waste: [40 CFR 261 & 40 CFR 262 | FAC 62-730.030 |  F.S. 403.721]

Most of the solvent waste generated at medical facilities come from the disinfectant or cleaning of instruments. Depending on the concentration of the solution you are using, the waste may be hazardous. Reading the Material Safety Data Sheet for your disinfectant will determine your disposal method. If the waste is hazardous, it must be captured in a container that is sealed so no evaporation occurs and treated as hazardous waste. All records for disposal or recycling must be kept on site for three years.

6. Fluorescent Bulbs: [40 CFR 273.13 | FAC 62-737 | F.S. 403.7186]

Fluorescent bulbs/devices are considered hazardous waste because they contain the element Mercury. However, if you recycle your Fluorescent bulbs/devices, they do not qualify as hazardous. Caution: if a supplier tells you that their bulbs are environmentally safe remember that they are trying to sell you a product, and they may not be familiar with the State and Local regulations that pertain to the proper recycling or disposal of these mercury-containing bulbs. Under the Universal Waste Rule lamps or devices with ANY mercury MUST be recycled. All records for disposal or recycling must be kept on site for 3 years.

Additional Fluorescent Tube Information

*Material Safety Data Sheets are a good start to determine if your waste stream will be hazardous waste. They do have their limitations if they are too vague. MSDS’s do not take into account what process or system the product may be used in or what your management practices are for preventing cross contamination. Before purchasing any product, request the MSDS to see what is in it and to help avoid costs associated with the purchase, use, and disposal of the product.

• Do not store any materials/waste near storm drains, ditches, creeks, rivers, canals or any bodies of water that would be contaminated if a spill occurs.

• Do not throw away or send receipts that show proper disposal of waste materials to a bookkeeper. They are required to remain on site for a minimum of three years. This includes contracts with hazardous waste haulers.

• Do not take the word of any sales person who will not supply MSDS for the product he/she is selling. Some will say that the material is biodegradable or environmentally friendly, but the process that you use the material in may contaminate the product and cause it all to be regulated (i.e., equipment degreasing and rinsing).

 

• Do not dispose of any material into your septic system, sanitary sewer, or storm sewer. If you want to do this you must have written permission from the regulatory agency that permits that particular system. For Septic Systems it is the Department of Health and Rehabilitative Services; For Sanitary Sewers it is the local utility district that you are located within.

• Do not store hazardous waste out of containment areas. Make sure all containers are labeled properly (include dates where necessary).

If you have any questions, please call the Pollution Prevention Program at
(239) 652-6126. We are here to serve your interest in the proper management of hazardous waste.