Words of Waste-dom

By Dan Scungio, MT(ASCP) SLS

 

Do you have a handle on the hazardous waste that is leaving your laboratory?  I don't mean the regulated medical waste, the "red bag trash" and "sharps" waste. Most facilities handle that through a licensed vendor, and it is incinerated or treated.  The Environmental Protection Agency (EPA), a federal agency charged with protecting human health and the environment, defines hazardous waste via a multi-step process known as hazardous waste identification.  For most laboratories, however, this refers to the untreated chemical waste that is removed from your facility usually by a licensed vendor.

 

As a generator of hazardous waste, you are responsible for the handling and final disposition of that waste, even though your company may not be the one that ultimately performs disposal.  The way this is done is by proper record keeping, or the use of waste manifests.  When waste is removed from your site, you should be given an initial manifest, a record of information that includes your EPA identification number, your waste handler (vendor) information, and the waste identification information. To see an example manifest, go to www.epa.gov/wastes/hazard/transportation/manifest/pdf/newform.pdf

Another form that should accompany your manifest is a Land Disposal Restriction (LDR) form.  This form is a notification from the generator (that's you) stating that shipped wastes can or cannot be disposed in a landfill without proper treatment.  This form is generally provided to you by your hazardous waste handler along with the initial manifest.  Keep these two forms together, your waste records are not yet complete.

For your own knowledge, ask your waste handler what is the nature of your waste's final disposition.  The EPA expects you to know that information, and it can be eye-opening.  I learned that some wastes from our lab sites, for example, end up as a fuel additive at a concrete manufacturing plant.  The waste increases the burning to the temperature needed to make concrete, and it gets incinerated as a result of the process.

Once the waste meets its end, a final manifest will be sent to your site.  The final manifest looks like the initial manifest except that the bottom section is filled out and signed by the designated waste facility.  Using the manifest number, match the initial manifest, the LDR form and the final manifest and keep them together.  Local and state regulations may vary, but keep these forms for a minimum of three years. Keep your records neat and up to date.  If you are inspected by the EPA or the Department of Environmental Quality (DEQ), they will want to see that your records are orderly.  In some hospitals, the facilities department may be responsible for waste records.  If manifests are not kept in the laboratory, be sure to inspect the records for completeness at regular intervals.  If the records are within the department, be sure to audit them for completeness at least quarterly.

The DEQ is an agency also working to protect the environment at the state level.  If the EPA comes to inspect your facility, they will likely bring a DEQ representative with them.  The DEQ may also inspect independently of the EPA.  Both agencies may inspect randomly, but in some states the DEQ may have specific time patterns, and the EPA will inspect at regular intervals if your facility meets certain qualifications.

Do you know how much hazardous waste your facility produces?  Most community hospitals are what is known by the EPA as a "Small Quantity Generator," producing between 100 kg and 1000kg of waste per month.  If your site produces more than 1000kg (1200lbs) monthly, however, you must change your designation (via application) with the EPA to a "Large Quantity Generator (LQG)."  The designation is based on the total weight of all waste from your facility, so if your site is suddenly generating more waste from other areas (pharmacy amounts may be increased based on recently changed regulations), your waste amounts may not be what you expect.  You can calculate your waste amounts by looking at your manifests and totaling the weight generated by your entire facility.  One gallon of liquid waste weighs about 8.34 pounds.  Also, your waste handler may be able to provide this information for you.

There is much more to know about waste handling.  Are their chemicals that you can pour down the drain?  How may you move and store waste within your facility?  What about waste from analyzers?  What happens if you treat waste in your laboratory?  We will tackle these questions and more in a future column. In the meantime, it's fine to be "waste-ful," just be sure to keep a complete record of it!