Transcript Laboratory Chemical Waste Management Practices

The Sentinel Event
During a routine annual hazardous waste
management inspection by the Hazardous
Waste Section of NC DENR, violations in
laboratory practices were identified, citations
were issued, and an administrative penalty was
assessed. As part of the Consent Order,
Duke agreed to develop a laboratory chemical
waste management practice.
The Sentinel Event
During the inspection, the following violations were noted:

Duke failed to make waste determinations for waste generated in
some labs.
 Waste was stored in a defective container and not transferred to a
container in good condition.
 Certain wastes were not properly marked with the words “Hazardous
Waste” or “Waste Chemical”.
 Wastes were stored in open containers.
This informational presentation will familiarize you with the
requirements of the Laboratory Chemical Waste
Management Practice. Once you have read through the
practice, please contact OESO EP with any question you
may have.
Laboratory Chemical Waste
Management Practices
Occupational and Environmental
Safety Office
Environmental Programs Division
Purpose / Background
Research, teaching and clinical
laboratories produce a variety of waste
chemicals that may be subject to
regulatory management standards.
 If improperly managed in the laboratory,
waste chemicals could pose a risk to
human health and the environment.

Purpose / Background
Laboratory chemical wastes are regulated
by the Environmental Protection Agency
and the North Carolina Department of
Environment and Natural Resources
 The Occupational and Environmental
Safety office is tasked with ensuring that
all laboratories understand and comply
with these regulations

Scope
This practice applies to all
teaching, research, and clinical
laboratories at Duke University,
Duke University Medical Center,
and Duke University Health
Systems
Procedures


Any laboratory that will generate waste
chemicals must obtain a generator ID by
registering with the Occupational and
Environmental Safety Office Environmental
Programs Division (OESO EP) prior to beginning
processes that will generate chemical waste
Waste chemicals generated in a laboratory must
be managed in accordance with the following
procedures
Collection of Waste Chemicals

Waste chemicals collected either during
the operation of a process or otherwise
accumulated in the laboratory must be
placed into containers that are in good
condition, compatible with the contents,
and able to contain the contents without
leaking.
Container Labeling and Marking

Container Contents
Containers used to collect waste chemicals
must be clearly marked with the words
“Waste (name of chemical)”
 Containers must be marked or labeled at the
time waste is first placed in the container
 OESO EP will provide pre-printed labels for
laboratories

Container Labeling and Marking

Waste Collection Dates
Containers must have an “open date” listed
on the container label, and when full or no
longer being filled, a “fill date”.
 The “open date” is the earliest date that waste
is placed in the container whereas the “fill
date” is the date that the container is filled and
will no longer be used to accumulate waste.

Container Labeling and Marking

Unused, unwanted, or unopened
chemicals that are to be discarded must
be labeled with the words “Waste (name of
chemical) and the date that they were
determined to be unwanted or unusable.
Container Labeling and Marking

Small or odd shaped containers that are
difficult to place a label on must be placed
in a larger sealed container and labeled on
the outside. (zip-lock bags, plastic
containers, etc.)
Unknown Chemicals

Containers holding chemicals that cannot
be identified by chemical name, chemical
constituents, or process generating the
waste must be labeled as “Waste
Unknown” with the date that they are
considered to be no longer needed.
Removal of Unknown Chemicals

Chemicals identified by the laboratory as
an unknown must be removed from the
laboratory no later than 30 days after
being designated as no longer needed.
Container Management
Waste containers must be compatible with
their contents.
 Waste containers must be kept closed
except when adding or removing wastes.
 Waste containers should be kept clean
with no visible contamination on the
outside of the container.
 Waste labels and markings must be
readable and not defaced.

Container Management



Areas where waste chemicals are accumulated
must have secondary containment sufficient to
collect any incidental spills from container
failure.
Waste containers should not be overfilled. Full
containers must have at least a 10% headspace
to allow for expansion.
Filled waste containers must be stored in a
secure area under the control of the operator
Improper labeling and storage of a waste chemical
Open when not in use/
funnel left in container
Unlabeled container
No secondary containment
Correct labeling and storage of a waste chemical
Container Management

Wastes collected during processes:

Wastes that are collected as part of a
continuous process (such as HPLC wastes)
must be collected via tubes that are fed
through a cap or other container closure to
insure that the container is kept closed. This
closure must be a positive closing lid.
Parrafilm and similar closures will not be
acceptable.
Improper labeling and storage of a HPLC waste
chemical
Open Container
Unlabeled container
No secondary containment
Correct labeling and storage of a HPLC waste chemical
Container Management

Containers used to collect waste
chemicals on a frequent, routine basis
must be closed when a procedure or
experiment has been completed.
 EXAMPLE:
Containers used to collect acetone
washes must be kept closed except when actively
adding or removing wastes from the container.
Laboratory Shutdowns or
Closeouts
Whenever a laboratory is shut down or
closed out the principal investigator must
insure that all waste chemicals are
properly identified and labeled so that they
can be removed.
 Laboratory closeout procedures can be
found in section 5 of the Laboratory Safety
Manual at:

http://www.safety.duke.edu/SafetyManuals/LabManual/index.htm
Roles and Responsibilities
 Principal
Investigators, Laboratory
Directors

Principal Investigators or Laboratory Directors
are responsible for insuring that these
practices are implemented in the laboratory.
They may choose to assign or designate a
laboratory waste manager to implement this
practice
Roles and Responsibilities

Laboratory Waste Manager

Laboratory waste managers are responsible
for insuring that all processes generating
chemical wastes comply with these practices
on a day to day basis.
Roles and Responsibilities

OESO EP

OESO EP will provide support and oversight
to the laboratories through education, training,
routine assessments of laboratory
performance, and timely removal of chemical
wastes from the laboratory.
Chemical Waste

How do we get waste picked up?

First you must determine - Are you or your group
registered generators?


If no, call 684-2794, ask for chemical waste personnel and
request set up as a generator. You will receive a packet of
information containing your generator ID number, labels,
barcode labels, and a waste pick up request form.
If yes,




Place one barcode label on the waste container.
Place the matching barcode label on the pick up request
form.
Fill out the chemical description and container size that
corresponds to that barcode number.
Repeat the above steps for additional waste containers.
Chemical Waste




Fax (684-2422) or email ([email protected])
the completed form to OESO EP.
Once OESO EP receives a request, it will be entered into
our database and the waste will be picked up within 5
business days.
A member of OESO EP will contact your lab if there is a
problem with the pick up request.
A summary of the waste pick up process
can be found at OESO EP General
Guidance for Chemical Waste Pickups.
Questions / Concerns
A copy of the Laboratory Chemical Waste
Management Practice can be found here.
Any other inquiries:
Environmental Programs Division
Box 3914
684-2794
[email protected]
www.safety.duke.edu