In 2022, U.S. businesses could be fined up to $81,540 per violation per day for hazardous waste violations of the Resource Conservation and Recovery Act (RCRA).1 However, the monetary cost is small when considering the costs associated with injuries or environmental incidents that can result from inefficient hazardous waste management.
Here are seven tips to help lab managers manage lab chemical waste effectively.
An organized laboratory has many advantages. Safety is definitely at the top of the list, but it also allows a scientist to be more efficient and productive. In addition, the organization assists in the handling of hazardous waste. A scientist who knows where and how to easily find a chemical he needs does not spend more money to buy it when he is already there. It also means that the site does not store more hazardous chemicals than necessary, which is a more environmentally friendly choice. Finally, organization is key when disposing of waste. The US Environmental Protection Agency (EPA) and each state have strict regulations regarding how waste is separated and stored. Without a well-organized waste disposal site, a site could rack up many costly fines and increase its risk of an incident.
Use a computerized inventory system
One of the four goals of the RCRA is to find ways to reduce the amount of waste generated.2 A computerized inventory system can be an effective tool to help achieve this goal by keeping site chemicals organized. Scientists need an online repository for Safety Data Sheets (SDS), a way to find out who owns a chemical and where it is, when a chemical was received and when it expires , and a labeling system that includes the chemical name, location, chemical hazards, and a unique identifier, such as a barcode or QR code. Laboratory and safety managers also need to be able to track hazardous chemicals onsite for state or federal reporting purposes.
Although several systems are available for purchase online, laboratory and safety managers should review and evaluate each to find one that meets site needs. Some companies have even custom built their own. Key things to look for in an inventory system include customer service, usability, and the flexibility or adaptability of the system. Finally, the ability to scan the label of each chemical container for inventory reconciliation is especially important for sites with a large number of chemicals. No employee appreciates reconciliation, but digital tools can speed up the task.
Regularly inspect waste storage areas
RCRA “is the public law that creates the framework for the proper management of hazardous and non-hazardous solid waste,” which is overseen by the EPA.3 Inspection of waste storage areas is one of many regulations established by RCRA, which can be found in Title 40 of Parts 239-282 of the Code of Federal Regulations (CFR). For example, 40 CFR 264.174 states that “areas where containers are stored ‘must be inspected'”[a]at least weekly.4 Lab managers should note that some auditors may interpret “weekly” differently. Some listeners will think it’s too lax to interpret weekly as simply once a work week, i.e. allow an employee to inspect the storage area on a Monday a week and a Friday a week next. As such, it is best to assume that weekly inspections should take place at least every seven days.
“The best rule of thumb for effective waste management is to never make assumptions.”
Keep waste containers and storage areas tidy and clean
Although not explicitly stated in the CFR, auditors can and will find faults in laboratories or waste storage areas that they believe are not sufficiently clean and tidy. Listeners are human and they have pet peeves. An auditor who thinks a lab or storage area is too cluttered or contains expired chemicals may be more likely to find violations with the site, especially if the site has multiple areas with these issues. Like lab organization, lab cleanliness can help keep employees safe and efficient.
Adopt stricter waste management policies than state/federal regulations
Everyone is busy and distracted. With that in mind, set up your site to succeed by maintaining your site or company’s standards higher than the standards set by state and federal regulations. For example, 40 CFR 262.16(b) states that hazardous waste may remain on site “no longer than 180 days” for small quantity generator sites.5 The state your site is in may have an even stricter requirement. If a site adopts an offsite waste disposal policy that exceeds state or federal regulations and the site requirements are met, the site will still be in compliance with state or federal regulations.
Laboratory managers should be aware that employees who directly handle chemicals must undergo waste handling training. But did you know that everyone on site must also receive at least a minimum level of hazardous waste training? This includes contractors, office workers, visitors to other sites, senior management, etc. It would also be prudent to provide brief awareness level training to any visitor coming to the site.
What does the minimum level of training include? According to 40 CFR 262.17 Part 7, sites are required to train facility personnel to “be able to respond effectively to emergencies.”5 A non-laboratory employee should know what to do if they see a spill while walking down the hall or in a parking lot. While a lab worker should know the difference between a spill small enough for him to handle on his own or large enough for him to call for help. All employees must receive training within six months of entering the site, must not work unsupervised without having received this training, and must repeat this training annually.
Never make assumptions
The best rule of thumb for effective waste management is to never make assumptions. State and federal regulations are extensive and are updated as necessary. Chances are a lab manager is misremembering or confusing the regulations. Don’t let pride or time constraints keep you from doing the job properly and safely. It is good practice to post the site’s security policies online. This way commonly used pages can be bookmarked and keywords can be searched. In addition, each employee will be able to easily and quickly access the policies. If there are employees who do not have Internet access, post the guidelines in areas of the site that will be most useful to them. Remember to post the most recent guidelines as soon as they are updated.
Managing hazardous waste is complicated and difficult, and the consequences of not doing it effectively can be dangerous and costly. Benjamin Franklin once said, “an ounce of prevention is better than cure”. One of the best and easiest ways for a lab manager to save money for their business is to adopt a meticulous attitude towards waste management.