Regulated Chemically Hazardous Waste

Once material becomes a waste by a generator s decision or by regulatory definition, the first responsibility for its proper disposal rests with the laboratory worker. These experimentalists are in the best position to know the characteristics of the materials they have used or synthesized. It is their responsibility to evaluate the hazards and assess the risks associated with the waste and to choose an appropriate strategy to handle, minimize, or dispose of it. As discussed earlier in this volume (see Chapter 3, section 3.B), there are numerous sources of information available to the laboratory worker to guide in the decision making, including those required under various Occupational Safety and Health Administration (OSHA) regulations. 

Because proper disposal requires information about the properties of the waste, it is recommended that all chemicals used or generated be identified clearly. In general, they must be retained in clearly marked containCTs, and if they have been generated within the laboratory, their source must be defined clearly on the container and ideally in some type of readily available notebook record. In academic laboratories where student tumova- is Irequent, it is particularly important that the materials used or generated be identified. This practice can be as important for small quantities as it is for large quantities of material. 

It is usually quite simple to establish the hazardous characteristics of clearly identified waste. Unidentified materials present a problem, however, because treatment disposal facilities are prohibited from accepting materials whose hazards are not known. In those cases when the identity of the material is not known, it is possible to carry out simple tests to determine the hazard class into which the material should be categorized. Because the generator may be able to apply some gen 

Generally, it is not necessary to determine the molecular structure of the unknown material precisely. Hazard classification information usually satisfies the regulatory requirements and those of the treatment disposal facility. However, it is important to establish that the disposal facility will accept the analytical data that are ultimately provided. 

The first concern in identification of an unknown waste is safety. The laboratory worka- who carries out the procedures should be familiar with the characteristics of the waste and any necessary precautions. Because the hazards of the materials being tested are unknown, it is imperative that proper personal protection and safety devices such as fume hoods and shields be employed. Older samples can be particularly dangerous because they may have changed in composition, for example, through the formation of peroxides. (See Chapter 3, section 3.D.3.2, and Chapter 5, section 5.G.3, for more information on peroxides.) 

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Hazardous Chemical Wastes. NCRP has not considered studies of particular wastes containing low levels of hazardous chemicals that are potential candidates for exemption. However, studies in support of proposed regulations to establish exemption levels for listed hazardous wastes (EPA, 1992d 1995c 1999c) indicate that substantial quantities of waste currently managed as chemically hazardous waste could be classified as exempt for purposes of disposal. 

EPA) defines chemically hazardous waste under the Resource Conservation and Recovery Act (RCRA), and the U.S. Nuclear Regulatory Commission (U.S. NRC) defines radioactivity hazards. Biological hazards are generally not defined within federal regulations. 

The section of the RCRA of most concern to the chemical industry is Subtitie C, the hazardous waste management regulations. The purpose of this section is to regulate hazardous wastes from their generation to their disposal. FaciUties that generate, treat, store, or dispose of hazardous wastes ate coveted by these regulations. 

Thiophene and 3-methylthiophene are Hsted on the TSCA chemical substances inventory. Thiophene is regulated as a hazardous material under OSHA and also regulated under the Clean Air Act, Section 110, 40 CFR 60.489, but there are no exposure limits or controls set for 3-methylthiophene. Both materials are regulated under sections 311/312 of the Superfund Amendments and Reauthorization Act, 1986 (SARA), as materials with an acute health and fire hazard, and under the Resource Conservation and Recovery Act, as ignitable hazardous wastes (DOOl). 

Enter in the spaces provided, the name and address of each location (other than POTWs) to which you ship or transfer wastes containing toxic chemicals. Do not include locations to which you ship the toxic chemical for recycle or reuse, tf you do not ship ortransfer wastes containing toxic chemicals to offsite locations, enter not applicable, NA in the off-site location name line of 2.1. Also enter the EPA Identification Number (RCRA I.D. Number) for each such location if known to you. This number may be found on the Uniform Hazardous Waste Manifest, which is required by RCRA regulations. Also indicate in the space provided whether the location is owned or controlled by yourfacility or your parent company. If thefacility does not have a RCRA 1.0. number, enter not applicable, NA, in this space. 

This act governs in detail how the chemical industry must manage hazardous wastes. Generation, handling, transportation, and disposal are included in the regulations. 

Mineral Oil Hydraulic Fluids. Disposal of used mineral oil hydraulic fluids is regulated as used oil under the Solid Waste Disposal Act as amended by the Resource Conservation and Recovery Act (RCRA) and as amended by the Used Oil Recycling Act (42 U.S.C. 6901, 6905, 6935, 6937-6939, and 6074, see 40 CFR parts 260, 261, 266, 271, and 279). Used mineral oil hydraulic fluids to be recycled are not listed as hazardous wastes and can be burned for energy recovery or recycled. In general, the newer mineral oil hydraulic fluids (including water-in-oil emulsion fluids) do not contain known chemicals or other materials that are listed in 40 CFR 261 (RCRA) and can be burned for energy recovery or recycled. However, this may not apply to some of the older hydraulic fluids, particularly those containing PCBs. 

TSCA has a direct effect on RCRA through controls on the disposal methods of certain chemicals, such as PCBs. For example, while TSCA regulates PCB disposal, RCRA also regulates PCB disposal when the PCBs are mixed with hazardous waste. 

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