Overview
Spill residues/materials, wipers/rags, bench papers or PPE contaminated with solvents, listed chemicals or are otherwise characteristically hazardous are not properly collected and tagged for pick up by EHS.
Common Laboratory Chemicals (which could result in a hazardous waste when spilled or allowed to contaminate items such as PPE, bench paper, wipers, etc.):
- Acetonitrile, Benzene, Carbon Tetrachloride, Chlorobenzene, Chloroform, 1,4-Dioxane, Formaldehyde, Methylene Chloride, Methyl Ethyl Ketone, Nitrobenzene, 2-Nitropropane, Phenol, Pyridine, Trichloroethane, Trichloroethylene, Triethylamine, Tetrachloroethylene, Toluene, etc. as well as RCRA metals.
- Spills residues/materials of listed (U, P and F) waste will carry the hazardous waste codes (a few limited exceptions for wastes listed for only being characteristically ignitable, corrosive or reactivity).
This is akin to WAS05, There is evidence of improper disposal. But, like soldering waste an individual checklist item was added specifically for this waste stream because it is so widely generated and improper disposal is very common. Thus far, inspectors have not looked too closely at items like contaminated bench paper and PPE. However, additional scrutiny during future inspections could be possible.
Items normally discarded after use that have become contaminated with certain chemicals may be regulated as ‘hazardous waste’ when disposed depending on the nature of the waste material, conditions of use, and/or concentration of chemical contaminants in the waste items.
During use, small amounts of chemicals may come in contact with or contaminate items that are ordinarily discarded after each use (i.e., paper towels, gloves, absorbent bench paper, pipette tips, microfuge tubes, etc.). This contamination may occur as a result of accidental spills or drips from laboratory equipment such as pipettes or beakers. Used pipette tips are considered RCRA empty, because these qualify as a “container” rather than a spill residue.
Citations and Related Resources