Prevention Round Table
From Hospitals and Biomedical Labs
Center for Urban
Horticulture April 6, 2000
Dave Stitzhal, Full Circle Environmental
Ron Claus, University of Washington
Dave Waddell, King County Hazardous Waste Mgmt Program
Focused on 3 waste
-Alcohols (a solvent but regulated and used differently than other solvents
in biomedical settings)
-(and start on stains)
Ron Claus (UW): Use 3000 gal./year. Much from histology/pathology. It
is managed at the UW's waste facility so recycling includes costs of transportation
from various facilities.
-Distill w/ 20 liter solvent recycler, and repackage. Some into one-gallon
bottles which go to UW stores. Some to five-gallon carboys delivered directly
-If disposed, per gal. - cost $1.50 disposal plus $1.50 for transport
-If recycled, per gal. - $1.50 for transport and labor plus $1.50 distilling
cost plus cost of bottle ($10 each, only some come back from labs for
recycling) total $6.00 per gal.
-Cost to purchase new xylene $20.00 per gal. (Puget Sound Institute of
Pathology (PSIP) purchases xylene for $34/ 4 gal.)
-UW bulk packaging even cheaper because it eliminates expensive bottle
(PSIP): uses CBG
Biotech Recycling unit ("still") for ethanol and xylene.
-2.5 gal. capacity
-ethanol process takes 3 - 3.5 hrs., do everyday
-xylene takes 2 hrs., do weekly
-virtually no set up time for a run
-xylene from cytology and histology are recycled together
-machine has lots of safeguards
-$15,000 - $17,000 cost and 2 year payback
Bellingham): uses VR Instruments recycling unit for toluene and Clearite,
a xylene substitute with lower human toxicity than xylene or toluene
-4 gal. capacity · toluene process takes 3.5 - 4 hrs
-Clearite takes 2 hrs.
-set up time about 0.5 hours due partly to location of machine and location
of stored used solvent
-plan to recycle alcohols too but haven't gotten an acceptable product
yet, still working on it
-machine has safeguards and alarms
-$17,000 cost, if doing alcohols too would have a 14 month payback
NOTE these two
machines are not considered "stills" by fire departments based on several
factors, including that they cannot increase the strength of the alcohol/solvent
put into the machine (if you put 80% in you can't get it to produce 90%).
(Immunex): using CBG unit but couldn't get to high enough percent alcohol
for their needs with it, so amended their liquor license and now use 190
Lisa (VA Hospital):
they use a filtering system, not a still, keep filtering until product
is too dilute to use again. Likes the system, but heard the manufacturing
company was going out of business (see below)
-One gallon alcohol takes about one hour
- Filter cartridge life depends on concentrations of stains removed, etc.
Rex Johnson (Creative
Waste Solutions): Yes Naiad Technologies went out of business but same
process now available from his company. Gravity system, can be used to
filter alcohol, xylene, and now testing a cartridge for formalin.
Waddell (King County): guidelines for what can go down the drain differs
from place to place based in part on where the sewage treatment plant's
discharge goes. Example: Seattle discharges to Puget Sound, metals limits
are in the 3-5 ppm range. Snoqualmie discharges to the Snoqualmie River,
copper limit is 3 ppb (billion!). Know where your sewage is going and
research the limits you are required to meet.
If something designates
as a dangerous waste in WA it can't go down the drain to the King County
sewer system unless specifically allowed by the local sewer agency. So
F-listed solvents if at concentrations of >10% and/or with flash point
below 140 degree F can't go down the drain.
Contact Dave Waddell (206)
263-3069 or firstname.lastname@example.org if you didn't get a copy of the Laboratory
Waste Management Guide , contains tables noting King County sewer and
solid waste guidelines.
NOTE: alcohols have a Federal
exemption from being regulated as an ignitable liquid IF their concentration
is less than 24%. Federal exemption says <24% isn't ignitable waste, therefore
it isn't hazardous waste so it's OK. BUT in WA some alcohols designate
for toxicity at 10% to 24% concentrations so in WA they are hazardous
waste, they may not be in other states. Ethanol is ignitable liquid if
>24%. If below 24%, not regulated as hazardous waste.
NOTE: Dilution as a treatment
method for hazardous waste is illegal. Most medical solvent and alcohol
waste is >10-24% so legal treatment methods (filtering, distillation)
that have a 2-3 year payback period may be very good investments.
SOLVENT ALTERNATIVES: (Children's
Hospital): Unfortunately, they were unable to attend, but we're aware
they're using a xylene substitute which has a much higher flash point
than xylene, and have been recycling it on site for several years successfully.
What's being used for disinfection?
Immunex switched to, and is trying to now get away from, aerosolized isopropanol,
70%. Found mold spores in a pump-spray bottle once so switched to aerosols.
They've had problems with it being used inappropriately in hoods and staff
get a face-full sometimes from excessive over-spray.
Does anybody have an automated
stain line plumbed directly to sewer? Not in this group.
(Alan Jones, Lance Environmental
Services). Is there a problem with labs trying substitutes in terms of
certification of methods, and perhaps payments by insurers etc.?
(Lisa, VA Hospital) It's OK to substitute but different solvents/stains
lead to different look on the slides so either need to retrain the whole
staff or stick with old method, usually cheaper to stick with the old
way, not to retrain..
(Participant, NW Hospital) Not aware of any restrictions against new methods.
What about d-limonene? Can
nauseate some people. Has high fish toxicity and is ignitable so does
designate as a hazardous waste. Many people also have strong allergic
reaction. It's a good defatter so gets in blood stream quickly, bad reaction
to it shows up quickly. Just because it is a 'natural' product doesn't
make it a safe product.
What's the difference between
a still and a recycler? Some difference in the heat used and the process,
a still can remove water to some extent and give you a higher percentage
alcohol. A recycler only gives back the same strength that was put in.
NOTE: Fire departments see red flags when they hear "still" and so even
if the difference is a semantic/legal one it may be best to use "recycler"
when discussing with fire department.
NOTE: Get the local fire department
involved BEFORE you purchase a $17,000 piece of equipment. Implementation
of the fire code differs from town to town, occupancy ratings means in
some places its OK to install, others not. You generally need to have
a fire department permit to operate one. Get the permit first so you don't
have an expensive paper weight.
Watch for contamination with
other solvents - boiling points may be too similar to separate for adequate
Vacuum assist can lower boiling
temperature needed, fire departments like that.
Alan Jones (Lance Environmental):
neither type can get all the water out of dilute alcohols. 50 ml water
with 50 ml alcohol will not yield 100 ml of liquid. They form an azeotrope,
strong Hydrogen bonds form that distillation can't break. 96-97% pure
is the best you can get from a distiller unless you've started with a
Rex (Creative Waste) can supply
the name of a person in Florida who has a lot of experience with many
types of these machines and is willing to discuss it.
Dave Waddell: Lab guide pages 8-12. Once you use a product to the point
you can't reuse it, it becomes a waste. If it is hazardous at that point
it is a hazardous waste, and according to the regulations, it must be
counted toward assessing your generator status. You can then treat and/or
recycle it on-site to make it non-hazardous or reusable. If you do that
and you are an SQG you don't have to report the amount that you treated
or recycled but you still need to track it and keep a record of it. Keep
You must · track it · handle
it safely · dispose of it properly
Log includes: · What it is
· Where it's from - what process · How much put in · When put in · Who
put it in
Logs need to be kept for formalin
neutralization and filtration. Solvent and alcohol filtration and recycling.
Also acid neutralization
Regulatory technicality: You
count everything that goes in to treatment. Then you must also count the
sludge or still bottoms that are left over if they designate as hazardous
waste. Yes, it is double counting that portion. Both of these amounts
count toward your annual generator status. Only the still bottoms that
are sent off-site need to be included in annual reporting for Pollution
Prevention Planning. NOTE: This was a unclear in the discussion. We can
discuss this again at session #4, or you could contact Ecology or Dave
Waddell for clarification.
Ron Claus (UW): he has a sheet
available with details on treatment methods and cost recovery. This is
a significant part of the UW's waste stream. Tried distillation but had
problems with how long it took to do and with the smells it generated.
different chemical treatment methods for neutralization. If you do any
of this remember that OSHA/WISHA exposure guidelines need to be met.
Have been using
Neutralex successfully. It is · quick · effective · reasonably inexpensive
· there is documentation data available about the process that led to
approval for discharge to the treatment plant · has a good dipstick test
method to see when treatment is complete · works on gluteraldehyde too
In King County
discharge limit is 0.1% since that is the point at which it designates
as a hazardous waste. Neutralex instructions are for treatment to 0% so
UW uses less than instructions since trace amounts OK for discharge. Still
need to monitor for exposure, but haven't found any, no PPE needed by
staff doing the procedure.
about $1.50 /gal. Which is much less than disposal would cost.
Some labs are
treating their own by pouring into pre-loaded carboys.
use it on 37% formaldehyde, generates heat & fumes
Formalex leaves a solid residue that needs to be filtered out, makes it
less convenient and more labor intensive
Annatex is an
oxidation process, better for small quantities of formalin
a very smelly process but effective for formalin deactivation.
See Lab Guide
page 15 for formaldehyde guidance
disinfectants in concentrations of no more than 4% can go down the drain
in King County, testing shows the King County treatment plants can treat
those quantities and there is no danger to workers in the process
In King County
you must determine concentrations at the point of disposal (the sink)
to determine if it OK for sewer disposal, some jurisdictions measure at
NEW PROCESS: formalin
recycling. Dynacare testing system from Creative Waste Solutions. If it
continues to work well, they estimate an annual saving of over $16,000
by filtering and reusing formalin rather than disposing or treating it
and buying new. Pre-filter tissues and can use it for formalin from both
processors and tissue.
Alan Jones: Another
source of formaldehyde is kidney dialysis centers, typically using stronger
formaldehyde, not formalin and typically plumbed directly to sewer. Substitute
products are corrosive and may or may not be worse on the system.
filter cartridges are reusable - at least the alcohol ones. (DW) but remember
to check the flushing wash water when complete - does it designate?
NEXT UP, STAINS:
Please fill out
survey and fax back. Add any stain processes you use. We will try to get
disposal procedures for them by the September 7 seminar.
Many lab stain
processes are done over the sink and rinsed right down. How do you deal
with that? (DW) Remember that the rinsing may be part of the process and
so if the whole batch including the rinse water is collected and tested
it may not designate. If so that's fine.
Are there good
substitutes for picric acid?? No answers to this question yet. Perhaps
for the next seminar.
session will include discussion of janitorial supplies, some are very
dangerous. Also remember that maintenance staff working in the labs have
little knowledge of materials in use, they may be injured when changing
traps in sinks etc. Be aware of their safety too.
Also next: disinfectants,
mercury, stains part 2, expired chemicals and prescriptions
Which drugs designate
as hazardous waste??
has a trade association of pharmaceutical companies that developed a separate
entity to buy back expired medicines. Costs are built into purchase price
of drugs. Some US companies will buy back their own medicines for company
credit towards new purchases.
What are people
doing about spill clean up??
looking for ideas that they , and local government can help with that
will produce measurable change based on what is learned in these seminars.
Let us know about your ideas.
-Cooperative to buy a recycler? Business opportunity to be a mobile recycler?
- Need your managers to talk to managers who have approved alternate technologies
and are reaping monetary benefits? We can facilitate these types of discussions.
Sometimes peer to peer communications are the most valuable.
-Can you document changes you have made? Costs? Savings? Willing to share
that information with this group?
-Do you want recognition from the public for doing the right thing? Local
governments have programs to do that for you. Call us.
The Portable Rechargable
Battery Organization sells a 5 gallon bucket with prepaid UPS sticker
for $30. Holds 40 pound of Nicad batteries. That's all you need to spend.
Get shipped to American Nickel and they recycle the nickel, and send the
cadmium for recycling. Radio Shack and Ace Hardware are participating
vendors can take batteries from home there to recycle.
and toxicology labs end up with "soups" of mixed solvents. Then as part
of the process they evaporate the solvent to get the residues. Is that
OK? Is there a process for capturing the evaporated solvents? (Dave W.
and Immunex) Yes it's OK as long as there is a coil condenser that is
designed to capture vapors in that type of process.