Waste Prevention Round
Managing Chemicals From Hospitals and Biomedical Labs II
Spill Procedures Handout (pdf, 116KB). There is also a lot of good
information on the web (especially the UW website) that you can borrow
from to help you develop procedures for a new facility.
-hospital- Have written training
on spill procedures as part of 'Right to Know'. Where the spill occurs
is part of determination on how it will be handled. For example, spill
in the lab often handled by staff there since they are familiar with the
chemicals and their hazards. In other areas they may evacuate and/or hire
in a company to do clean-up. Knowledge about whether there is a respiratory
issue with the spill is important.
-hospital- Have 20 staff trained
for preliminary evaluation they have a contractor come in for the more
-hospital- Having a consultant
on contract is a step up from old system of all in-house work. Contractor
is up to date, there is more information coming in from the outside to
help keep all staff more current. Contractor involvement has led to measurable
improvement in reaction time etc. at this facility
-biotech- have 5-6 person spill
team but also have access to a contractor whenever needed.
-Dave Waddell- Fire dept crews
may not have large knowledge about chemicals, if the hazmat teams come,
they may have more knowledge. Many fire departments will not clean up,
they only establish a safe perimeter and stabilize the situation, and
you must still clean up yourself or hire contractor to do. Varies by fire
Be aware that calling something
a chemical spill vs. an incidental release can be very important in how
fire dept's react and in how penalties or costs are assessed. A chemical
spill is a 'big deal' and fire dept is required by law to be a first responder
on the scene. In an incidental release L&I is the regulating agency and
impact on the facility is likely to be much less.
-hospital- They do make this
distinction, sometimes the size of the release, or the toxicity etc. will
determine which it is. They don't maintain their own hazwopper staff,
it's too expensive. Some separate areas within the VA have their own spill
plans. The plans ask questions like 'how much spilled, what is it, is
it evaporating?' to help determine if response will be in-house, contractor,
or HAZMAT team.
-biotech- Have an emergency
response team at level B, w/ SCBA but also have a level at which they
determine to call in the fire dept. With any incidental release, plan
calls for staff to stop first and review MSDS to verify the safety of
any further action.
It's important to have MSDS's
for all chemicals! May also be important to include in spill plan what
should be referred to as an incidental release and what as a spill.
COMMON DISINFECTANTS FOR HOSPITAL
Disinfectants Handout (pdf,
-Dave Waddell- It's not hazardous
waste until the very end of the process. Only after it is done, rinsed,
cleaned-up etc. See the handout for 5 different classes of disinfectants
and their advantages and disadvantages.
In King County the sewer discharge
limits are based on the hazardous waste determinations. If it is hazardous
waste it won't be legal for sewer discharge. One exception is gluteraldehyde,
it has been proven to break down in the treatment process to levels below
concern at discharge, and proven to cause no harm to workers at the treatment
plants. Burden of proof for such exceptions is on the waste producer.
Many places switching from
phenol disinfectants to quaternary amines, even though some of the quats
may be more toxic. The phenols are very hard on the counters and surfaces
in the labs. This is why the switch is occurring.
X-RAY AND PHOTO PROCESSING
Handout (pdf, 72KB). UW problem example, new labs downtown with new
x-ray machines. These machines designed to direct all 3 waste streams
(used fixer, used developer, rinsewater) into one pipe, the problem is
to separate out the fixer as haz waste and collect it. (probably only
the fixer is hazardous and piping together means either hw will be dumped
to sewer or that non hw will need to be disposed expensively as hw.
Dave Waddell's problem example.
A large hospital has an electrolytic treatment system but every single
system in hospital is plumbed to it how much of the fixer is going to
the sewer untreated? It is important to match the size of the treatment
system with the flow of waste. Some systems need constant flow, some systems
can't handle large flows. Also note that these treatment systems require
maintenance, they aren't automatically good forever.
-Dave Waddell- Most silver
treatment systems are inadequate to remove enough silver to completely
meet sewer limits, but you should be sure you are using the best available
technology. Storage and hazardous waste disposal via a vendor are probably
cost and space prohibitive for a large facility. Note that mixing fixer
and developer is a bad idea because the developer inhibits the ability
to recover silver from the fixer. If the hazwaste vendor can't recover
the silver then your costs for disposal will be that much higher. Used
developer is OK to go down the drain (new developer isn't , it has a pH
issue and contains hydroquinone (a hazardous waste)).
-biotech- New Hallmark silver
recovery system with two canisters. State of the art. Handles a fairly
constant flow of fixer. Sample ports between and after the canisters.
They capture and hold effluent until lab testing for silver complete,
then release it to the sewer.
-Dave Waddell- best way to
maintain a two-canister system - put newest canister in second position,
as a polisher. Sample between the two until notice breakthrough in the
first canister. Remove first canister for reclamation, move second to
first position and put new one in second position, this allows full use
of each canister without breakthrough that violates sewer discharge limits.
Be sure to check test strips for sensitivity, the sewer limit is 3 ppm,
some test strips only detect down to 300 or 3000 ppm
CMX also sells a good recovery
Don't always believe what your
vendor is telling you, double check and test yourself - you maintain the
-hospital- What do you use
if you have many isolated machines and can't plumb them to one location
where a big treatment system can be used?
-Alan Jones- many hospitals
have a single canister or crc by each x-ray machine, but if an electrolytic
unit can only get silver down to 100-150 ppm it is still over the limit
and not adequate treatment.
-hospital and biotech - both
have technicians on staff to handle this waste stream. A very good idea
if you can afford it. Many hospitals don't really know what they are doing
with this waste, again ask pointed questions of your equipment rep.
UW treats about 40,000 pounds
of fixer per year and recovers enough silver to make money on the process
(I missed how many pounds of silver they get)
Many x-ray machine manufacturers
are now packaging an electrolytic treatment unit in with, and as part
of, the x-ray machine. This is good for them, they get a maintenance contract
on the unit and they get the money from the silver it recovers. It may
or may not be a good deal for the hospital or lab since you will still
be discharging silver over the legal limit.
-Dave Waddell- Also, what do
you use to clean the lines? Some places use chromic acid, which is releasing
hexavalent chrome into the sewer in large quantities (illegal). Other
facilities just use bleach or even water to clean the lines. Use the least
toxic chemical that will do the job. Check with your vendor, what are
they using to clean it?
Ron Claus, UW has an address
for a publication from the Silver Council on details of various types
of treatment and how they work. Call Ron (206-685-3759) for information
on getting the publication. Also call Dave Waddell (206-263-3069) for
information about treatment systems and sewer limits in King County.
TREATING HAZARDOUS WASTE ON
Labs are generally good candidates
for treating hazardous waste due to knowledge of staff and lab set-up.
See Treating Hazardous Waste Handout (pdf,
99KB). Even if doing Treatment by Generator (TBG) still required to count
your waste, track what you generate, and log what you treat. Also a regulatory
'glitch': must count the full amount of what you treat, and any sludge
produced and remaining hazardous after the treatment. So some of the waste
gets counted twice, but you still benefit by saving money by reducing
the quantity of waste that must be shipped. If interested in details about
treatment methods seeSee Treating Hazardous
Waste Handout (pdf, 99KB) or contact Dave Waddell (206-263-3069),
or Tiffany Yelton at Department of Ecology at (425 649 7055). If Tiffany
is unavailable call the DOE general line at (425 649-7000) and ask to
speak with someone in the hazardous waste program.
NOTE that any treatment process
that can be hard piped into the work process becomes part of the process
(see above, new x-ray machines for an example) and nothing is counted
as waste until after the process is complete. In some instances this may
mean that you don't have to count anything (or as much) as waste if treatment
gets the hazardous ingredients out or down to acceptable levels.
Digital x-rays produce no hazardous
waste. Should be considered, but also there is a concern that records
could be altered so there is a potential legal concern.
-hospital- they do use digital,
since their work is so internal and insurance not really an issue the
legal concerns are minimized for them.
-Dave Waddell- In San Francisco
the Bay and the sewage treatment plant outfall are very shallow. They
have very strong regulations about silver since they had been finding
it in the sediments in the bay. Through regulation they have been able
to get to zero discharge at the outfall.
STAINS SOLUTIONS - HAZARDOUS
Please refer to the following
external web sites:
Typical question - Can stains
go down the drain? Typical answer - It depends.
Most of the typically used
stains were characterized for the Stain Solutions Handout (not yet available).
Some stains also contain heavy metals, which are regulated at certain
Remember that if something
is regulated as hazardous waste there is no de minimus standard. A teaspoon
of the waste is just as regulated as a gallon of the waste. Also dilution
is not a legal treatment method.
"Laboratory Waste Management
Guide" has helpful tables that show King County sewer limits for
metals, alcohols, pH, etc. Also the toxicity tables used in the Dangerous
Waste Regulations. Call Dave Waddell for a copy.
Alcohol is a typical solvent
in stains. Different alcohols have different limits for legal sewer discharge.
Many stains would be OK to go down the drain EXCEPT for the fact that
they are in an alcohol base, which is flammable, which at certain concentrations
makes the stain a hazardous waste.
Remember that you do not designate
the unused stain (unless it's old or bad and you want to toss it), you
wait until the end of the whole stain line and the whole process and designate
the combined stains and rinses.
The Stains Handout is based
on the concentration of the stock solution since each lab may use it differently.
You still need to designate your waste if you are starting with a stain
Two books listed on the back
of the Stains handout are very good references. Dave Waddell can also
assist you in the designation process.
Note: halogenated organic compounds
are regulated as hazardous because of persistence. They don't break down
in the environment and are generally toxic.
Is it OK to change the expiration
date on your stock solution so it doesn't become waste? That is an internal
decision. If lab feels they can meet QAQC standards with the old solution
it may be OK. Need to also consider whether in will impact the quality
of patient care. But, also note that if you are sending out a "Lab pack"
of hazardous waste that isn't quite full - one more bottle of waste in
the lab pack won't make it cost any more to get rid of.
Remember when getting rid of
hazardous waste that you, the generator are responsible from cradle to
grave for the proper disposal of your waste. Research your vendors. You
may want to look at the State of Washington's contract for Higher Education
Hazardous Waste Management. They have carefully researched the vendors
on the list for what they take, where they take it and what they do with
it and what the financial stability of the company is. Even if you can't
piggyback onto the contract it is good information.
KEEP RECORDS of everything
you do. Employers need to keep MSDS's for 25 years for staff medical records,
hazardous waste records need to be kept, etc.
-Pinky Feria - Are facilities
keeping track of their waste streams? Do they know what they are shipping
-biotech- Yes, keep track of
what goes into the waste stream. But also do lab analysis on some streams
-hospital- Almost never test,
assume that the lab knows what went in to the waste stream and has properly
recorded that information.
-Pinky Feria- There is the
possibility of getting a certificate of non-designation for some of these
standard waste streams. Call Pinky at Ecology (425-649-7085) or Dave Waddell
(206-263-3069) for information.
-hospital- The various UW labs
are supposed to be accurate in reporting what's in their waste. If it
turns out not to be accurate and UW gets caught, fined etc. then the lab
that generated the waste is financially responsible for paying any of
the associated costs.
-hospital- Probably ship some
things as hazardous waste that don't actually designate. Feel its better
to err on that side and assume it is hazardous waste than the other way.
They assume it is hazardous unless it is highly documented that it does
Many other facilities do this
too. It's safer than potential illegal disposal. Also sometimes testing
to determine if it designates as hazardous costs more that disposing of
it as hazardous waste.
-Dave Waddell- If you have
consistent waste streams that you think are not hazardous, get the government
to help you. We can help pay for an analysis and we can give you written
documentation that we've checked that waste stream and helped you determine
it isn't hazardous. This will help you if you get inspected…
When calling government for
help, always remember to call technical assistance rather than compliance!!
What happens to them?
-hospital- In Canada the Pharmaceutical
industry formed an entity that takes back consumer prescriptions. This
is due to legislation.
-hospital- has a company that
comes through and checks stock and removes expired chemicals of at least
some brands. Chemo waste is collected and disposed as hazardous waste.
Not sure where vendor gets rid of what he takes. Rest goes to hazardous
waste, or trash or sewer. Used to incinerate it when they had an operating
-EPA- some vendors who pick
up end up selling these in third world countries. Again, always ask your
vendor where things go after they leave your facility.
-Alan Jones- many investigational
drugs are not permitted to go to the solid waste due to contract rules.
-biotech- require that unused
and expired drugs come back to Immunex. Including kits, including the
sharps etc. Cost of this is built in to the cost of purchasing the drug.
Drug comes with a prepaid mailer.
-Pinky Feria- many drugs are
"P" or "U" listed, meaning if they are no longer product they are automatically
-Ron Claus- tried to designate
the list of drugs usually dispensed by UW pharmacies. Some are hazardous
waste, some are OK to toss. Gave list to pharmacists who tried to separate.
But very time intensive effort, didn't want to throw away in packages,
concerned about theft from garbage so tried to remove all from packs (think
blister packaging). Eventually determined that it is cheaper for a large
institution like UW to dispose of all expired drugs as hazardous waste
than to pay highly trained staff pharmacists to mess with trying to separate