Laboratory Chemical Waste Management
Introduction
The Environmental Health & Safety (EHS) Department manages and directs a comprehensive
chemical & laboratory safety program. To ensure that environmental and work place safety
regulations are being met and maintained, the EHS Department manages and oversees all
hazardous chemicals and wastes used or generated at the Medical Center.
The medical center policy is zero tolerance for non-compliance with Environmental Regulations.
The enclosed procedures must be followed to comply with rules from the U.S. Environmental
Protection Agency (EPA) and the Massachusetts Department of Environmental Protection (DEP),
which regulate the disposal of hazardous wastes. The following recommendations are provided to
help ensure proper regulatory compliance and provide and safe work environment.
General Guidelines
Potentially Hazardous chemicals must be disposed of in accordance with federal and state
regulations and procedures established by EHS. Your department may also have procedures that
you are required to follow. Contact your supervisor, instructor or EHS before discarding of any
potentially hazardous chemical.
The following guidelines will assist waste collection:
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Disposal of chemicals by way of the sanitary sewer system is prohibited.
To determine if the chemical you want removed from your laboratory or work area is a
regulated hazardous waste contact EHS, or consult the EPA regulation 40 CFR 261Identification and Listing of Hazardous Waste.
Waste containers must remain near (within 3 feet) or at the point of generation. This
means within the laboratory where the waste is generated. Such sites are called "Satellite
Accumulation Areas".
All lab personnel must be familiar with the location and composition of all wastes
produced in the lab.
Waste containers must remain closed except when actually adding waste. Open
containers violate state and federal waste regulations.
Keep waste containers off the floor. Store only on impermeable lab surfaces such as
bench tops, in hoods, or in secondary containers. Remember to check for leaking or any
damage to container
Use only containers that are in good condition and compatible with the waste. Original
product containers could be reused in most cases. Be sure containers are clean and can
be capped.
Waste chemicals must never be placed or left for removal in hallways, or abandoned at
the Main Accumulation Areas
Only one container per waste stream per "satellite accumulation area" is allowed
The container should never need to exceed one gallon or 4 liters. When containers over
one gallon are considered, contact the EHS office. Materials that are "Acutely Toxic"
must be collected in containers no larger than one quart.
Handle waste containers with care to prevent ruptures and leaks.
Within 72 hours of the fill-date, the chemical waste must be stored in the main
accumulation area. If you have chemical waste containers which already are, or will be,
filled and dated, you must contact EH&S and set up a disposal time. For disposal or pick
up information, call 617-667-5143.
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For disposal of mixed wastes (radioactive & chemical) materials call Radiation Safety at
617-667-2510.
Satellite Accumulation Areas
These are locations within laboratories where chemical wastes are collected and properly stored
until they are picked up by EHS.
 Each area must be posted designating it as the Satellite Accumulation Area. See sign
below.
SATELLITE ACCUMULATION AREA
Please Post
Do you know your responsibilities for proper handling of hazardous waste?
Please review the following requirements to ensure that you comply with environmental regulations
and safe handling procedures.
Chemical Waste Disposal Service
The Environmental Health & Safety Department has a chemical waste disposal service in place that is
designed to keep the Medical Center and Research Laboratories in regulatory compliance with proper
disposal requirements. The Chemical Waste Collection program requires the laboratory generating chemical
waste to contact the hazardous waste pickup line at 7-5143 or pager 94186 for BIDMC or 30861 for
CLS to schedule a collection or drop off time. All chemical waste must be brought to a collection area within
3 days of filling a chemical waste container.
The following are designated as Main Accumulation areas for chemical waste collections (waste will be
collected at the location which it is generated).
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Slosberg-Landay Basement, SL-B03
Research North 1st floor, RN-185
Clinical Center West, 2nd floor
CLS Loading Dock
Hazardous Waste Defined
Hazardous materials have hazardous characteristics such as: flammable, corrosive, reactive, toxic,
radioactive, poisonous, carcinogenic or infectious. In a general sense, these materials are considered
hazardous because they present a potential risk to humans and/or the environment. By law a hazardous
waste is defined as a waste, or combination of wastes, that because of its quantity, concentration, or
physical, chemical or infectious characteristics may cause or significantly contribute to an increase in serious
irreversible, or incapacitating reversible illness or pose a substantial present or potential hazard to human
health, safety or welfare or to the environment when improperly treated, stored, transported, used or
disposed of or otherwise managed. Hazardous waste management plans generally separate waste into
three broad groups: radioactive, chemical and biological. This guide addresses only chemical waste.
Hazardous waste includes a wide range of material such as discarded commercial chemical products,
process wastes and wastewater. Some chemicals and chemical mixtures are hazardous wastes because
they are specifically listed by the EPA. Most of the common laboratory solvents are listed wastes. A
chemical waste that is not listed by the EPA is still a hazardous waste if it has one or more of EPA's four
hazardous characteristics: ignitablity, corrosivity, reactivity or toxicity.
Classification of Chemical Waste
A chemical waste is considered to be a hazardous waste if it is specifically listed by the EPA or DEP as a
hazardous waste or if it meets any of the four hazardous characteristics below. If a chemical waste is not on
the EPA list of hazardous wastes, and does not meet any of the hazardous waste characteristics, it is a
nonhazardous waste. For complete definitions of hazardous characteristics of waste see the EPA regulation
40 CFR 261-Identification and Listing of Hazardous Waste.
Ignitable/Flammable
A liquid which has a flash point of less than 60°C is an ignitable waste (e. g. Acetone, Methanol). A solid is
an ignitable waste if it is capable of causing fire through friction or absorption of moisture, or can undergo
spontaneous chemical change which can result in vigorous and persistent burning under standard
temperature and pressure (e. g. Benzoyl Peroxide). A substance which is an ignitable compressed gas or
oxidizer is an ignitable waste (e. g. Propane, Hydrogen Peroxide).
Corrosive(Acid/Base)
An aqueous solution which has a pH less than or equal to 2 or greater than or equal to 12.5 (e. g.
Hydrochloric Acid, Sodium Hydroxide),or is a liquid and corrodes steel at a rate greater than 6.35 mm per
year at a test temperature of 55°C, is a corrosive waste.
Reactive
A reactive waste is a material that is normally unstable and undergoes violent chemical change without
detonating, can react violently with water to form potentially explosive mixtures or can generate dangerous
or possibly toxic gases, vapors or fumes in a quantity sufficient to present a danger to public safety, health
or welfare or to the environment; or a material that is capable of detonation or explosive decomposition or
reaction at standard temperature (e. g. Picric Acid, Potassium Cyanide, Lithium Aluminum Hydride).
Toxic
A waste that contains one of the constituents in concentrations equal to or greater than the values listed in
EPA regulation 40 CFR 261-Identification and Listing of Hazardous Waste is a toxic waste.
Disposal of Unknowns
All chemicals must be identified and containers properly labeled at all times. Each laboratory is responsible
for seeing that this requirement is met. If an unknown chemical is discovered, label it as "unknown" and
attach a note detailing any information about what the chemical may be or what experiment it may have
been used for and where it was found. Contact EHS for disposal information. If you find any unlabeled
chemical that has crystallized or there is any other indication that it may be unstable, DO NOT TOUCH IT!
Contact EHS (617) 667-3088 immediately.
Requirements for Hazardous Waste Management in the Laboratory
Laboratories and other areas that generate hazardous waste are required to comply with the generator
requirements of the Resource Conservation and Recovery Act (RCRA, CFR Title 40) and Massachusetts
Hazardous Waste Management Regulations (310 CMR 30.0). Every generator site (laboratory) is subject to
inspection by the EPA and DEP. The steps necessary for compliance are summarized below.
 Weekly Inspections - items to be inspected are listed on the Satellite Accumulation Area checklist.
The Principal Investigator/Lab Safety Coordinator is responsible for assuring this inspection is done
weekly.
 Segregation and Containment - the wastes must be separated by chemical compatibility groups.
Each group of containers must be provided with appropriate secondary containment. Containment
trays and tubs are available from EHS. Additional information on compatibility is provided below.
 Storage - only one container per waste stream (type of waste) is allowed in a lab, i.e., one
container for halogenated solvents, one container for non-halogenated solvents.
 Closed Containers - all containers must be closed at all times except when actually adding waste.
Labeling
Each container must be labeled with a BIDMC Chemical Disposal Label. When the container is full place
the date when full on the label. Plan ahead and contact Environmental Health & Safety at 7-5143 or
pager 94186 for BIDMC or 30861 for CLS to arrange for a waste pick-up.
 You must provide your own collection container.
 Collect hazardous chemical waste in a labeled, screw top container (glass or plastic – depending
on waste to be collected)
 Fill out the Hazardous Waste Disposal Label when waste generation has begun; complete the label
once the container is full. Fill out all areas when generation has begun except the Fill Date. This is
required when the bottle is full and ready for pickup. Use chemical names on the label. Do not use
formulas or abbreviations.
 Constituents of chemical by volume percentages is required.
Hazardous Waste for Disposal
Complete label and affix onto container prior to collecting waste
Room # _________________________ Fill Date ______________
Department ___________________________ Ext _____________
Contents
1._______________________________ % ________
2)_______________________________ % ________
3._______________________________ % ________
4.________________________________% ________
Check the HAZARD:
____ Ignitable ____ Corrosive ___ Reactive ____ Toxic
Chemical Compatibility
The following chart is provided as a guide to segregating hazardous waste containers; it is not to be used for
mixing chemicals. Containers of incompatible wastes must be stored in separate areas. Secondary
containment bins are available for purchase; contact EHS at 7-3088 for recommended products.
Many hazardous wastes, when mixed with other waste or material, can produce effects which are harmful to
human health and the environment, such as (1) heat or pressure, (2) fire or explosion, (3) violent reaction,
(4) toxic dusts; mists, fumes, or gases, or (5) flammable fumes or gases. Below are examples of potentially
incompatible wastes, waste components, and materials, along with the harmful consequences that might
result from mixing material in one group with material in another group. The list is intended only as a guide
to indicate the need for special precautions when managing these potentially incompatible waste materials
or components.
This list is not all-inclusive. In the lists below, the mixing of a Group A material with a Group B material might
have the potential consequences as noted.
Chemical Compatibility Chart
Group 1-A
Group 1-B
Alkaline Liquids
Acid Liquids
Potential consequences: Heat generation, violent reaction
Group 2-A
Group 2-B
Aluminum
Wastes in Group 1-A or 1-B
Beryllium
Water
Calcium
Air
Magnesium
Alcohols
Sodium
Other reactive metals and metal hydrides
Potential consequences: Fire or explosion generation of flammable hydrogen gas
Group 3-A
Alcohols
Water
Group 3-B
Concentrated waste in Groups 1-A or 1-B
Calcium
Lithium
Metal hydrides
Potassium
Other water-reactive wastes
Potential consequences: Fire, explosion, or heat generation; generation of flammable or toxic gases.
Group 4-A
Group 4-B
Alcohols
Concentrated Group 1-A or 1-B wastes
Aldehydes
Group 2-A wastes
Halogenated hydrocarbons
Nitrated hydrocarbons
Unsaturated hydrocarbons
Other reactive organic compounds and solvents
Potential consequences: Fire, explosion, or violent reaction.
Group 5-A
Spent cyanide and sulfide solutions
Group 5-B
Group 1-B wastes
Potential consequences: Generation of toxic hydrogen cyanide or hydrogen sulfide gas
Group 6-A
Group 6-B
Chlorates
Acetic acid and other organic acids
Chlorine
Concentrated mineral acids
Chlorites
Group 2-A wastes
Chromic acid
Group 4-A wastes
Hypochlorites
Other flammable and combustible wastes
Nitrates
Ammonia
Nitric acid, fuming
Perchlorates
Permanganates
Peroxides
Potential consequences: Fire, explosion, or violent reaction.
Empty Containers
Generally empty chemical containers are not considered hazardous waste. The container must be
completely empty, that is all of the contents that can be removed by normal means must be removed and
the residue must be less than 1%. The word "empty" must be written across the label. The container may
then be disposed of in the regular trash.
An exception to the above applies to containers that held chemicals listed by the EPA and MADEP as
"Acutely Hazardous Wastes". The most common laboratory chemicals found on this list are:
 Acrolein
 Allyl alcohol
 Compounds containing Arsenic
 Carbon Disulfide
 Compounds containing Cyanide
 2,4, Dinitrophenol
 Nitric oxide
 Nitrogen dioxide
 p-Nitroaniline
 Osmium Tetroxide
 Phosgene
 Phosphine
 Sodium Azide
 Vanadium pentoxide
A complete list of the Acutely Hazardous Wastes can be found the EPA regulation 40 CFR 261-Identification
and Listing of Hazardous Waste. Empty containers that formerly held any of these Acutely Hazardous
Wastes in the pure unused form, not mixtures or spent material, must be disposed of as hazardous waste.
Mutagen Carcinogen Policy
Mutagens and carcinogens are used extensively in laboratories. A list of the most commonly used chemicals
in this category is provided in the following table. (Remember this is not a comprehensive list). Mutagen or
carcinogen waste in solid form or concentrated solution is hazardous chemical waste and must not be
thrown in the trash or down the drain. Call the EHS office (7-5143) to arrange for pick-up of your hazardous
waste or if you need more information.
Chemical
CAS Number
Chemical
CAS Number
1,2-Dibromo-3-chloropropane
96-12-8
2-Aminofluorene
153-78-6
Benz[a]anthracene
56-55-3
1,1-Dimethylethylenimine
Ethylenedibromide
106-93-4
Benzo[a]pyrene
50-32-8
Propylenimine
75-55-8
Chlorambucil
305-03-3
Ethionine
67-21-0
Cycasin
14901-08-7
Diazomethane
334-88-3
Dibenz[a,h]anthracene
53-70-3
7,12-Dimethylbenz[a]anthracene
57-97-6
3'-methyl-4-amino-azobenzene
Urethane
51-79-6
Bromoethylmethanesulfonate
Chloromethylmethylether
107-30-2
4-Dimethylaminazobenzene
60-11-7
Diepoxybutane
1464-53-5
3-3'-Dimethylbenzidine
612-82-8
Dimethyleaminobezene
60-11-7
1,4-Dinitrosopiperazine
140-79-4
1,1-Dimethylhydrazine
57-14-7
N-Hydroxy-2-acetylaminofluorene
1,2-Dimethylhydrazine
540-73-8
3-Methylcholanthrene
56-49-5
Ethidium Bromide
1239-45-8
4,4'-Methylenebis(2-chloroaniline)
101-14-4
Ethylmethanesulfonate
62-50-0
Methyazomethyl acetate
5926-62-1
Hydrazine
302-01-2
1-Methyl-3-nitro-1nitrosoguanidine
Methylhydrazine
60-34-4
1-Naphthylamine
Methylmethanesulfonate
66-27-3
N-[4-(5-Nitro-2-furyl)-2-thiazoyl]formamide
N-Nitorsodiethylamine
55-18-5
N-Nitroso-N-ethylurea
N-Nitrosodimethylamine
62-75-9
N-Nitroso-N-methylurea
684-93-5
N-Nitrosodi-n-butylamine
924-16-3
4-Nitroquinoline-1-oxide
56-57-5
N-Nitrosodi-n-propylamine
621-64-7
Procarbazine
366-70-1
1,3-Propanesultone
1120-71-4
N-Nitroso-N-ethylurethane
70-25-7
N-Nitroso-N-methylurethane
615-53-2
m-Toluenediamine
95-80-7
N-Nitrosopiperidine
100-75-4
Uracil mustard
66-75-1
Polychlorinatedbiphenyls
11141-16-5
4-Aminobiphenyl
92-67-1
ß-Propiolactone
57-57-8
Benzidine
92-87-5
3,3'-Dichlorobenzidine
91-94-1
N-Acetoxy-2-acetylaminofluorene
2-Acetylaminofluorene
53-96-3
3,3'-Dimethoxy-benzidine
20325-40-0
Aflatoxins-
1162-65-8
2-Naphthylamine
91-59-8
97-56-3
4-Nitro-biphenyl
Methylnitrosourea
17ß-estradiol
ø-Aminoazotoluene
Chemical Waste Minimization
The specialized handling and disposal required for hazardous chemical wastes, as well as the hazards,
result in operational, economic, and safety reasons for minimizing the generation of such wastes. Listed
below are several waste minimization techniques that may be put to practical use throughout the hospital.
This is not a comprehensive list of all possible waste minimization methods, but those most likely to be
found feasible to employ within the hospital environment. For more information, please contact the EHS
Department.
All chemical users are required to consider hazardous chemical waste minimization during the planning of all
chemical procedures. Waste minimization activity will be a periodic focus of safety audits in labs so that we
can identify what works and build on our success throughout the rest of the organization.
Planning purchases
A substantial portion of the hazardous waste produced at this hospital consists of unused, outdated
chemicals sometimes in unopened original containers.
Prior to purchase careful consideration must be given to:
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the amount of chemical required over a given period of time
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the shelf life of the chemical
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the costs of disposal.
Purchasing in bulk, in an attempt to reduce the purchase price of individual items, frequently results in
needless disposal costs that far outweigh the savings in the original purchase.
Inventory practices
Set up good inventory practices to check for and use products before expiration dates occur.
Properly rotate all stock.
Order only when necessary to prevent overstocking. Avoid the use of standing orders.
Substitution
Replace or substitute a toxic or hazardous chemical product with a non-toxic or less toxic substance. Check
with suppliers and manufacturers for possible alternatives to the hazardous products being used. Many less
hazardous substitutes are currently being developed.
Microscale procedures
Occasionally, work can be adapted to reduce the scale of experiments or procedures, thereby achieving
acceptable results while using smaller quantities of chemicals and resulting in a decreased amount of waste.
The use of smaller quantities of chemicals can also reduce occupational exposures to chemical hazards.
Recovery
Commercial waste processing companies recover many chemicals for reuse in the manufacture of
commercial products. Silver and mercury may be recovered on site through commercially available filtration
methods. The recovered material can then be reused or sold. Silver recovery is currently practiced in the
Photography and Radiology departments and numerous labs. Recovery activity must be coordinated
through the Safety Office to assure that proper permits are obtained and that the recovery complies with all
other pertinent regulations.
Recycle/reuse
Some chemicals can be reused several times in a procedure before needing to be disposed of as waste.
Certain chemicals can be re-purified by distillation prior to reuse. Check with chemical manufacturers and
distributors for technical information concerning chemical reuse. The Pathology department currently
recycles quantities of xylene, xylene-substitutes and formalin using distillation methods. All recycling/reuse
must be coordinated through the Safety Office to assure that proper permits are obtained and that the
activity complies with all other pertinent regulations.
MWRA Compliance Page & List of Chemicals Restricted from Sink Disposal