Hospitals for a Healthy Environment (H2E) © 1 Region 7 Universal and Laboratory Waste Janet Brown,...

Hospitals for a Healthy Environment (H2E) ©1

Region 7Region 7Universal and Laboratory WasteUniversal and Laboratory Waste

Janet Brown, H2E Partner Coordinator

www.h2e-online.org


Universal WastesUniversal Wastes

• EPA finalized the Universal Waste Rule on May 11, 1995– Done to streamline recycling efforts for

commercial and industrial groups. Exempts hazardous wastes that are generated domestically as well

– Universal wastes are not regulated under full RCRA Subpart C, but rather by streamlined Universal Waste Rules (40 CFR 273)


Universal Waste RuleUniversal Waste Rule

• These waste streams are:– Hazardous waste batteries (except

lead-acid batteries managed under 40 CFR Part 266 Subpart g);

– Hazardous waste lamps;– Hazardous waste mercury-containing

equipment (other than lamps and batteries); and

– Hazardous waste pesticides that are recalled or collected as part of a pesticide collection program.


Mercury Containing Mercury Containing EquipmentEquipment

• Mercury-containing equipment (MCE) is any device or part of a device that contains elemental mercury integral to its function;

• The definition of MCE excludes batteries and lamps;

• MCE includes, but is not limited to, thermostats, barometers, manometers, mercury switches, thermometers, flow meters, pressure relief gauges, mercury regulators, water treatment gauges, and gas safety relays.


Universal Waste Rule Universal Waste Rule ContinuedContinued

• States have autonomy when it comes to the Universal Waste Rule:– States do not have to adopt it– States can add or remove wastes– States can also have more stringent

requirements– NY uses the old federal guidelines for

Universal Waste– NJ has state guidelines for Universal Waste

Rule and includes computer monitors (CRTs) as universal wastes

– Federal rule applies in VI– PR has not adopted the Universal Waste Rule


Overarching IssuesOverarching Issues

• Hazardous Waste Identification• Proper Waste Disposal• Substitution of Less Toxic

Alternatives• Recycling/Reprocessing of

Chemicals• Using Less Chemicals


State Universal Waste Rules

http://www.epa.gov/epaoswer/hazwaste/id/univwast/statespf.htm


•Aerosol Cans (CO);

•Antifreeze (LA, NH);

•Ballasts (MD, ME, VT);

•Cathode Ray Tubes (CRTs) (ME, MI, NH, RI);

• Electronics (CO, CT, NJ);

• Oil-Based finishes (NJ);

State Universal Waste Rules (Cont’d)


Examples of Hospital Universal Waste

• Nickel cadmium or sealed lead-acid batteries found in– Electronic equipment– Mobile phones– Emergency back up lighting

• Mercury-containing equipment such as thermostats, thermometers, manometers, etc.

• Lamps that have a hazardous component– Fluorescent lights– High intensity discharge lamps– Neon lamps– Mercury vapor lamps– High pressure sodium lamps– Metal halide lamps


Proposed RuleProposed Rule

• Proposed rule - June 12, 2002

• Exclusion from the definition of solid waste which would streamline RCRA management requirements for used CRTs and glass removed from CRTs sent for recycling

• http://www.epa.gov/epaoswer/hazwaste/id/univwast/crt-fr.pdf


Types of Universal Waste Types of Universal Waste HandlersHandlers

• Small Quantity Universal Waste Handlers (SQHUW) accumulate less than 5,000 kilograms (11,000 lbs) of all universal waste categories at any one time.

• Large Quantity Universal Waste Handlers (LQHUW) accumulate 5000 kilograms or more of all universal waste categories at any one time. Once a handler triggers the LQHUW status, they remain for the rest of the calendar year


Notification Includes:Notification Includes:

• Statement indicating that the facility is a LQHUW(Large Quantity Universal Waste Handler)

• Name, physical and mailing address of facility

• Name and business phone number of person responsible for managing universal waste at facility

• List of all types and quantities of universal waste managed by the facility (e.g. batteries, pesticides, mercury-containing equipment, lamps)


Proper ManagementProper Management

• All handlers of universal waste must manage them in a way that prevents releases of the universal waste or component of universal waste to the environment

• All handlers of universal waste must mark or label the universal waste to identify the type of universal waste


Implementation StrategyImplementation Strategy

• Leadership Support• Meeting with

Engineering/Facilities/Biomedical Engineering

• Review records and reduce mercury at point of purchase

• Policy development• Facility Audit• Identify Storage area• Bid contract/Background/Facility Check• Implementation, Education, Training• Monitoring, Reporting, Record Keeping


LabelingLabeling

• Universal Waste – Battery(ies); or Waste Battery(ies); or Used Battery(ies).

• Universal Waste-Pesticides; or Waste Pesticides.

• Universal Waste-Mercury Containing Equipment (thermostat); or Waste Mercury Containing Equipment (thermostat), or Used Mercury Containing Equipment (thermostat).

• Universal Waste-Lamp(s); or Waste lamp(s); or Used lamp(s).


Accumulation Time LimitsAccumulation Time Limits

• All handlers of universal waste can only All handlers of universal waste can only keep the universal waste on-site for a keep the universal waste on-site for a year unless they can prove that a longer year unless they can prove that a longer period is necessary to accumulate period is necessary to accumulate enough universal waste to facilitate enough universal waste to facilitate proper recovery, treatment or disposalproper recovery, treatment or disposal

• All handlers of universal waste need to All handlers of universal waste need to be able to demonstrate the length of be able to demonstrate the length of time that the universal waste has been time that the universal waste has been accumulatedaccumulated


Laboratory ChallengesLaboratory Challenges

• Minimal space• Run 24/7• Familiarity with laboratory

“language”• Resistance to change


Be like Mercury – Persistent!Be like Mercury – Persistent!

• Designate team leader

• Pilot – Start Small if you need to

• Take a team approach – include multiple departments

• Check with your GPO – We’re driving markets!

• Educate


I. Hazardous Waste I. Hazardous Waste IdentificationIdentification

• # 1 RCRA Violation for Region 2• Mercury, Solvents, sodium

hydroxide, alcohols• Understanding of P, U and D in the

lab• Proper Labeling• Proper storage for flammable and

reactive chemicals• Lab Clean outs and Generator

Status


Chemical Waste Inventory – Chemical Waste Inventory – Why?Why?

• Health & Safety• Regulatory Compliance

– Someone with a clipboard taking notes– Protective Gear– Spill Supplies & Fire Extinguisher– Telephone, Eyewash and Phone– Sign on the door – inventory in

progress


Suit Up for InventoriesSuit Up for Inventories

• Goggles• Mask• Long Pants• Long Sleeves• Nitrile Gloves


Chemical Storage “Issues”Chemical Storage “Issues”

• Incompatible chemicals stored together

• Stored near a drain• Lack of secondary containment


Chemical IncompatibilityChemical Incompatibility

• Acids by Caustic Bases• Oxidizing Acids (Nitric, Sulfuric) by

combustible glacial acetic acid.• Volatile compounds in leaky

containers reacting (hydrochloric acid vapors & ammonia vapors = crystals


Chemical Use by DrainsChemical Use by Drains

• Do not pour hazardous chemicals into secondary containers over drains.

• Spills = illegal disposal• Sends the wrong message to staff• Blocks access to eye wash units on

sinks.


Fume Hood IssuesFume Hood Issues

• Intended for chemical use, not storage

• There’s a drain back there.• Chemicals need secondary

containment. (Including those in the cabinets below the hood.)


2. Improper Waste Disposal2. Improper Waste Disposal

• Study on improper mercury disposal in labs

• Where to throw? Mixed wastes– Training– Identification first!– Pipes and traps– Catch 22 waste – mercury? RMW?


3. Substitution of Less Toxic 3. Substitution of Less Toxic MaterialsMaterials

• Mercury elimination• Inventory mercury-containing

devices and chemicals (required for MMMF)

• Substitution protocol– Blind Trials– Sustainable Hospitals Project– Low Hanging Fruit– Pockets of success


Problems with Identifying Sources Problems with Identifying Sources

of Mercury in the Labof Mercury in the Lab

• Material Safety Data Sheets (MSDS) don’t identify mercury levels below 1% in the product. MSDSs are required to list ingredients that are health hazards and which comprise 1% or more of the chemical or reagent mixture (0.1% for carcinogens).

• Unfortunately 1% (10,000 ppm) can be well above some regulated wastewater limits.


• Plumbing can contain mercury from previous mercury spills

• Check P-traps, elbows and low points

• System made need to be flushed if extensive contamination. Some hospitals have replaced lab plumbing.

Problems with Identifying Problems with Identifying Sources of Mercury in the LabSources of Mercury in the Lab


Require Vendor DisclosureRequire Vendor Disclosure

• Request that vendors and manufacturers disclose all ‘hazardous’ materials contained in their products- especially mercury

• Make it a contract requirement

• Explain you want levels below those detailed on the MSDS (vendors have this info)


CAP supports mercury CAP supports mercury eliminationelimination

• New College of American Pathology (CAP) statement on elimination of mercury-containing chemicals in the lab setting

• The Laboratory Accreditation Program added a Lab General Checklist question: "Does the laboratory have a written plan to reduce or eliminate mercury?"

• A “no” answer results in a ‘recommendation’ and request for follow-up.


IV. Recycling/Reprocessing IV. Recycling/Reprocessing of Chemicalsof Chemicals

• Alcohol, Xylene, Formalin• Hazardous waste accumulation

(generator status)• Solvent Reprocessing Stills

– Cost Savings– ROI often less than one year– Decrease in purchasing– Decrease in disposal costs– Quality Assurance Protocol a must


Solvent Recycling Case Solvent Recycling Case StudyStudy

Albany Medical CenterAlbany Medical Center• Savings is in both avoided disposal costs

and avoided purchase costs.• Saved over $2.6 million since programs

inception in 1996.• Reclaimed more than 205 tons of

chemicals.• Facility and equipment costs $150,000 to

construct. ($75,000 in equipment purchase and $75,000 in renovations to a decommissioned incinerator room.)

• Paid for itself in six months.


Solvent Recovery Case StudySolvent Recovery Case StudyAlbany Medical CenterAlbany Medical Center

Year Savings

1996 $274,485

1997 $242,611

1998 $238,269

1999 $264,448

2000 $216,263

2001 $169,560

2002 $126,016

2003 $110,662

2004 $315,663

2005 $395,006


Facility DetailsFacility DetailsAlbany Medical CenterAlbany Medical Center

• 4 – 20 liter capacity B/R Instrument distillation units and a CBG Biotech Alcohol-xylene mobile recycling unit.

• Requires 2 technicians working an average of one hour a day with a PhD chemist doing QC about one hour a week.


Albany Medical CenterAlbany Medical Center

• EPA did a multi media, unannounced inspection in September 2003.

• Albany Medical received a letter commending their efforts in hazardous waste minimization and assuring compliance with RCRA.

• No violations received from EPA.


Albany Med in 2006Albany Med in 2006

Solvent Amount this year

Alcohol 15,000 lbs

Xylene 10,000 lbs

Formalin 8,000 lbs

Propanol 4,000

Total 36,000 lbs


For More InformationFor More Information

• Russ MankesAssociate Professor/Chemical Hygiene OfficerAlbany Medical Center518 [email protected]


V. Chemical Use ReductionV. Chemical Use Reduction

• Microscale Chemistry• Smaller, pre-filled containers• Less purchase, less waste, less

safety risk• Comparison of amounts of xylene

used in microscale vs. macroscale• http://www.epa.state.oh.us/dhwm/

pdf/NotifierWinter05.pdf

http://www.epa.state.oh.us/dhwm/pdf/NotifierWinter05.pdf

http://www.epa.state.oh.us/dhwm/pdf/NotifierWinter05.pdf


For More InformationFor More Information

• Minnesota Technical Assistance Program – Free Technical Assistance in Minnesota

• http://www.mntap.umn.edu/• Washington State Guidance on Proper Disposal

of Cidex OPA http://www.govlink.org/hazwaste/publications/LabGuidelinesRevAugust06.pdf

• King County Laboratory Waste Management Guide - http://www.govlink.org/hazwaste/publications/LabGuidelines_05.pdf

• Howard Hughes Medical Institute – Free Lab Training Videos

• http://www.hhmi.org/• MA Institute of Technology – Green Chemical

Alternatives Wizard http://web.mit.edu/environment/academic/purchasing.html

http://www.govlink.org/hazwaste/publications/LabGuidelinesRevAugust06.pdf

http://www.govlink.org/hazwaste/publications/LabGuidelinesRevAugust06.pdf

http://www.govlink.org/hazwaste/publications/LabGuidelines_05.pdf

http://www.govlink.org/hazwaste/publications/LabGuidelines_05.pdf

http://web.mit.edu/environment/academic/purchasing.html

http://web.mit.edu/environment/academic/purchasing.html

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