Frequently Asked Questions
Chemical Waste - Definitions
Chemical waste primarily consists of harmful chemicals, yet being harmful doesn’t automatically classify it as hazardous. To be deemed hazardous, it must exhibit characteristics such as ignitability, corrosivity, reactivity, or toxicity, as specified by the US Environmental Protection Agency.
Distinct handling and disposal criteria apply to hazardous and extremely hazardous chemical waste. Refer to the list of Known Hazardous and Extremely Hazardous Wastes for your material at: ucsd.edu/safety/research-lab/hazardous-waste/disposal-guidance/extremely
Chemical Waste - Lab Packing
A comprehensive lab pack service, such as what Hazardous Waste Experts provides, generally includes the following:
- Identification of all materials within the lab.
- Creation of an inventory for those materials.
- Utilization of DOT-certified containers.
- Completion of necessary paperwork, including profiles, shipping manifest, labels, placards, and more.
- Provision of all labor associated with the pack.
- Coverage of all travel expenses linked to transport.
Prior to placing any chemical containers into the lab pack, a qualified individual must compile an inventory of all expired, damaged, or out-of-date chemicals slated for disposal. This inventory should meticulously document every item intended for inclusion in the pack, ensuring the proper and safe disposal of chemicals that are no longer needed.
Loading the lab pack (drum) involves packing small vials and containers, ranging from one-quarter ounce to gallon jugs, into a larger container. This larger container must be packed based on waste type, making the waste segregation process crucial. For instance, flammable items should be packed alongside other flammable items, and corrosive waste should be packed with similar corrosive waste. It is essential to avoid mixing flammable, corrosive, or reactive materials within a single large container.
Materials frequently transported in a lab pack encompass toxic, flammable, corrosive, pyrophoric, or explosive substances, along with acids, aerosols, compressed gases, solvents, oxidizers, chemical reagents, cleaning and disinfecting agents, radioactive materials, organic peroxides, paints, paint thinners, varnish strippers, and reactive materials derived from metals.
Lab packs find common usage in universities, laboratories, dry cleaners, and other industries generating chemical waste. When it comes to disposing of multiple chemicals with diverse hazardous properties, lab packs offer a convenient and cost-effective solution for transporting such materials off-site. The primary lab pack container is filled with smaller containers holding materials or chemicals that share similarities, such as acids, flammables, and oxidizers. This container is appropriately marked with its designated shipping name for easy sorting during transportation.
Lab packing involves placing chemicals into a container approved by the Department of Transportation (DOT) and transporting them to a permitted waste disposal facility. Given the hazardous nature of many of these substances and their potential for increased danger when combined with other chemicals, it is crucial that only individuals with expertise in lab packing operations undertake these tasks. A skilled lab packing technician possesses the knowledge to handle and segregate chemical substances in a manner that is both safe and in compliance with regulations.
Hazardous waste transportation is exclusively allowed for companies authorized under both the US DOT hazardous materials regulations and the US EPA’s hazardous waste regulations. The waste generator is accountable for ensuring that their chosen transporter possesses full permits, as some service providers may subcontract transportation to a third party. Opting for a third-party transporter introduces an additional layer of risk, particularly when contemplating lab pack disposal.
The “Lab Packer” bears the responsibility of identifying and appropriately segregating each substance in accordance with the regulations of the US Department of Transportation. Due to differing hazard classes, many flammable substances cannot be combined with other chemicals. For instance, picric acid is a chemical that becomes explosive with age, demanding careful handling and expertise. Whether one is a Chemist or a Hazardous Waste partner, it is crucial for the individual overseeing lab packing to possess knowledge about the substances they are handling.
Chemicals qualify for lab pack disposal if they meet the following criteria:
- They are within six months of their expiration date, as indicated on the label of the chemical container. It is recommended, regardless of the expiration date, not to retain hazardous chemicals for more than five years.
- The storage condition of the chemical has been compromised, such as exposure to inappropriate temperatures or inadequate sealing.
- The chemical is not regularly used or needed, or it presents an unacceptable hazard risk.
Educational institutions, including community colleges, high schools, and universities, house a variety of toxic, corrosive, flammable, reactive, and poisonous chemicals utilized in class demonstrations and training within their chemistry laboratories. Given their defined shelf life, proper disposal is essential at the conclusion of each semester or school year. Lab packing emerges as the safest and most compliant method for packaging and transporting a diverse array of laboratory chemicals in bulk.
Lab packs containing highly hazardous chemicals like cyanide or arsenic, as well as containers with toxic heavy metals, are obligated to adhere to specific treatment standards. When utilizing the alternative treatment standard for lab packs, generators are not mandated to identify underlying hazardous constituents (UHCs).
The transportation of lab packs is subject to specific regulations outlined in the US DOT guidelines at 49 CFR 173.12(b), (d), and (f). These regulations stipulate that the materials included in lab packs must share the same DOT hazard classification and be compatible. The outer packaging must meet UN performance packaging standards, commonly taking the form of open-head drums constructed from steel, plastic, other metals, or fiberboard. Furthermore, each inner container within the lab pack must not surpass a capacity of 20 liters, and the overall weight of the lab pack must not exceed 205 kilograms.
Lab packing involves a chemical collection and transportation method employing smaller inner containers enclosed within a larger outer container for packing and shipping purposes. This approach promotes cost and space efficiency during the transportation of similar materials while preventing the mixing of incompatible chemicals. If small containers remain intact within their respective primary containers, they can be consolidated into a drum of 55 gallons or less and undergo lab packing with the inclusion of inert packing material, typically vermiculite or another compatible absorbent. It’s crucial to note that specific DOT. regulations mandate the precise amount of packing material required for each drum size, and combining chemical bottles in the same outer container can pose risks if not executed accurately.
Chemical Waste - Treatment
Chemical waste disposal treatment involves one of four processes: biological, chemical, physical, or thermal. Chemical treatment methods encompass ion exchange, precipitation, oxidation and reduction, and neutralization. Among these, incineration stands out as the most used form of thermal treatment.
Expired Products - Definition
No, it is not recommended. Expired healthcare products, including hand sanitizer, syringes, IV bags, and tubing, should be disposed of following specific guidelines to ensure proper handling of potentially hazardous materials.
Expired Products - Waste Categorization
Classified as a Class 3 Flammable liquid, hand sanitizer has the potential for combustion when concentrated at high levels. For instance, pouring around 50 gallons of alcohol-based sanitizer down the drain could result in vapors combustible enough to displace manhole covers in the municipal waste system. If disposed of in a dumpster, there is a risk of a literal dumpster fire, or the garbage disposal truck may catch fire during the compaction process.
Because of their elevated alcohol content, hand sanitizer products are classified as ignitable, placing them within a regulated class of hazardous waste under the Resource Conservation and Recovery Act (RCRA). Moreover, specific hand sanitizers have been subject to recalls by the Food & Drug Administration (FDA), necessitating hazardous waste disposal irrespective of their expiration date.
Industrial Waste - Compliance
For secure and compliant management of industrial waste, the EPA recommends the following steps:
- Identify all hazardous waste generated.
- Measure the quantity of hazardous waste produced.
- Obtain your EPA Identification Number.
- Prepare waste for shipment by appropriately packaging and labeling containers.
- Adhere to the prescribed timeline for on-site waste storage.
- Enlist a qualified waste transport provider for waste treated offsite.
- Maintain accurate, detailed records and submit regular biennial reports on your waste management activities.
Industrial Waste - Definitions
Regulated under RCRA Subtitle C, hazardous industrial waste encompasses waste not covered by RCRA Subtitle D (non-hazardous solid waste). This category includes various materials such as sewage, radioactive waste, shredded circuit boards, spent sulfuric acid, and numerous others.
Industrial waste, including toxic or hazardous waste, poses risks if not handled appropriately, potentially causing harm to humans, animals, and the environment. Improper management can lead to contamination of fresh waterways, affecting animals and food cultivation.
Toxic waste typically emerges as a byproduct of materials produced at factories, hospitals, and manufacturing facilities. Handling and disposal requirements vary by state.
Industrial wastes arise from or are linked to operations in industry, manufacturing, mining, or agriculture. Instances include wastes generated by manufacturing facilities, power generation plants, and research laboratories affiliated with an industry. In contrast, non-industrial wastes originate from sources like universities, hospitals, churches, dry cleaners, most service stations, and laboratories catering to the public.
Three types of waste fall under the category of “industrial waste”. These are:
- Chemical Waste: Generated primarily by factories, processing centers, warehouses, and plants.
- Solid Waste: Encompassing various materials such as paper, cardboard, plastics, packaging materials, wood, and scrap metal in industrial settings.
- Toxic and Hazardous Waste.
Industrial Waste - Storage and Accumulation
To comply with EPA regulations on hazardous waste disposal, the majority of industrial waste generators must initially acquire an EPA identification number. While waste can be stored on-site for a period ranging from 90 to 180 days (depending on the volume of waste generated), there are instances where an extension of the onsite storage period is possible. This extension is applicable when waste needs to be transported more than 200 miles for treatment and disposal. Storing waste on-site beyond the permitted timeframe can result in severe penalties, including potential fines of up to $50,000 per day. Additionally, improper on-site waste treatment may lead to the imposition of jail time.
Industrial Waste - Transport and Disposal
Much like a household shop vacuum, a vacuum truck is equipped with a holding tank. A robust pump removes air from the tank, creating a vacuum inside. By opening primary and secondary shutoff valves on the suction hoses, the tank pressure equalizes, allowing the truck to effectively suction up liquids and sludges.
Also referred to as a ‘vacuum tanker,’ vacuum trucks are frequently employed for extensive liquid and sludge cleanup tasks, such as sewer and septic system maintenance. In both industrial and municipal settings, these trucks are utilized to suction water and debris remaining from hydro-excavation or drilling operations. They play a crucial role in clearing mud to free up utility lines or prevent sewer system overloads.
The transportation of industrial waste is contingent upon the type of waste being transported. Various methods include the use of tankers, dewatering boxes, air movers, or simpler roll-off boxes. If uncertain about how to transport a specific type of material, it is advisable to consult with industrial waste removal professionals.
Medical Waste - Compliance
The regulations governing the collection, treatment, and disposal of biohazardous waste are established by the US Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA). The Centers for Disease Control and Prevention (CDC) supplements these regulations with additional guidelines for the management and disposal of biohazardous waste. Furthermore, state and local authorities, along with universities and individual facilities, may enforce their own specific standards and practices.
Medical Waste - Definitions
Biohazard remediation involves the comprehensive cleaning, sanitization, and deodorization of a site where a fatal accident has taken place. This specialized form of hazardous waste management entails handling human blood, body fluids, and feces, exposing workers to potential risks of staph, hepatitis, HIV, and other communicable diseases.
Regulated Medical Waste falls into the packaging group PG II and is appropriately labeled as regulated medical waste, n.o.s. It is categorized under Hazard Class 6, Division 6.2. As a Division 6.2 infectious substance, which encompasses regulated medical waste, it is subject to regulation under the Hazardous Materials Regulation (HMR). All individuals engaged in its transportation, including loading, unloading, handling, and preparing or reviewing shipping papers, must undergo training as HazMat employees.
A medical waste generator is generally an individual or entity engaged in the following activities:
- The diagnosis, treatment, or immunization of human beings or animals.
- Research related to the activities above
- The production and testing of biological agents.
Infectious medical waste refers to waste produced during the diagnosis, treatment, or immunization of human beings or animals that has been or is likely to have been contaminated by an organism capable of causing disease in healthy individuals. While waste generators are obligated to adhere to CDC isolation precautions, the majority of discarded biological waste products or materials that are potentially infectious can be disposed of as regulated medical waste.
Sharps waste is a stream of regulated medical waste composed of used “sharps”, aka any device or object used to puncture or lacerate the skin. Common items typically categorized as sharps include hypodermic needles, disposable scalpels and blades, lancets, broken capillary tubes, and culture slides. All used sharps must be disposed of in an approved sharps disposal container.
Referred to interchangeably as biohazardous, biomedical waste, or biowaste, this waste stream encompasses:
- Cultures of infectious diseases and/or agents
- Sharps (e.g., needles, scalpels, and lancets)
- Items soaked in blood, such as gloves, gauze, and gowns
- Human body tissues
- Animal body tissues
- Human body fluids
- Wastes from rooms of patients with communicable diseases
- Substances containing environmentally-restricted molecules or organisms
- Multi-hazardous substances, named so because they contain a combination of noxious elements where neutralizing one can render the other more dangerous (e.g., tissue samples preserved in formalin).
Regulated medical waste is a waste stream that includes blood, body fluids, or other potentially infectious materials. RMW is also recognized as “biomedical waste” or “infectious medical waste.”
Medical Waste - Sharps Collection
Sharps containers should never exceed the fill level recommended by the manufacturer. In cases where the manufacturer has not provided a specific fill level, it is advised not to fill the sharps container beyond ¾ of its capacity before replacing it.
Glass, being capable of puncturing the skin, is deemed a sharp object and should be appropriately disposed of in a safety-grade sharps container.
When full and properly sealed, single-use sharps containers can be discarded in the regulated medical waste stream. This commonly involves placing them in a designated cardboard box or container labeled appropriately for regulated medical waste (often recognized as red bag waste).
Sharps containers are specifically crafted to confine needles, syringes, lancets, scalpels, and other sharp objects that may be contaminated with blood or bodily fluids. Additionally, they are suitable for gauze pads or other absorbent materials that, when compressed, could release bodily fluids.
Medical Waste - Storage
At the point of origin, medical waste should be segregated from other waste. All regulated medical waste must be placed in either a red bag or a designated medical waste container. These containers should be rigid, leakproof, and leak-resistant, featuring a tight-fitting lid. They must be appropriately labeled with the words “Biohazardous Waste” or display the international biohazard symbol along with the word “BIOHAZARD.”
Medical Waste - Transport and Disposal
Any entity involved in transporting toxic material must possess the proper “permit” and license for such activities. In the case of the majority of hospitals and clinics, this typically involves engaging a reputable company to transport regulated medical waste (RMW) offsite to a treatment, storage, or disposal facility. The transportation of such waste necessitates a specialized bill of lading known as a hazardous waste manifest. Additional documentation, like a land disposal restriction form, might also be required. It is crucial to note that if the required documentation is inaccurate or missing, the legal responsibility rests with the hospital or clinic rather than the transporter. Therefore, it is highly important to thoroughly understand the partners involved and possess comprehensive knowledge of any subcontractors or third parties.
Medical Waste - Treatment
Medical waste autoclaves are specifically employed for the treatment of regulated medical waste, encompassing items contaminated by blood, bodily fluids, or other potentially infectious materials. This includes:
- Used medical sharps and sharps containers.
- Bloody bandages or gauze.
- Masks or gowns worn by doctors or patients.
An autoclaving machine is a device designed to sterilize regulated medical waste, utilizing steam heated to approximately 300 degrees Fahrenheit for the sterilization process.
Operating specifications for this machine can differ from state to state. For instance, in some states, the requirement exists for sterilized waste to undergo shredding before being landfilled, while in other states, this additional step may not be mandated. Additionally, the duration that biohazardous waste needs to remain in the autoclaving machine can also vary across states.
Medical Waste - Waste Categorization
Exceptions aside, linens are typically reused and, as a result, do not become part of the waste stream. According to the Centers for Disease Control and Prevention, “Although soiled linen may harbor large numbers of pathogenic microorganisms, the risk of actual disease transmission from soiled linen is negligible… common-sense hygienic practices for processing and storage of linen are recommended.” (Source: cdc.gov/hai/prevent/resource-limited/laundry)
Pharmaceutical Waste - Definitions
The term “sole active ingredient” indicates that the ingredient, which might qualify as a P- or U-listed hazardous waste, is the sole chemically active component in the pharmaceutical responsible for performing its intended function.
Pharmaceutical Waste - Waste Categorization
Drugs and medications, falling under the broad category of pharmaceuticals, are considered hazardous waste under the Resource Conservation and Recovery Act (RCRA) when they are considered nonviable (returned, expired, or damaged). The quantity and classification can determine the permitted volumes for storing pharmaceuticals, the generator status, and the packaging requirements for disposal.
Approximately 5% to 10% of pharmaceutical products are accurately categorized as hazardous waste. To ascertain whether a pharmaceutical product is regulated by the EPA as hazardous waste, four essential questions must be addressed:
- Is it a solid waste?
- Does it meet the criteria for an exemption?
- Does it exhibit characteristics of hazardous waste?
- Is it listed as hazardous waste?
Nitroglycerin was designated as hazardous waste due to its reactivity, specifically its explosive properties. However, medicinal nitroglycerin does not demonstrate the reactivity characteristic. As a result, it is not classified as listed hazardous waste P081. Nonetheless, it may exhibit other hazardous waste characteristics.
Unused medication remaining in an IV bag or another container is not considered used for the purpose of categorizing it as hazardous waste. This remains true even if a portion of the medication was administered and the remaining medication is prohibited from being used on another patient. The P and U hazardous waste listings exclusively pertain to unused commercial chemical products. Therefore, if the discarded medication in a container is unused, it must be assessed to determine if it qualifies as a listed or characteristic hazardous waste.
Solid waste attains the classification of hazardous waste if it satisfies a listing or displays a characteristic as outlined in Title 40 of the Code of Federal Regulations (40 CFR) Part 261.