1. Hospitals for a Healthy Environment (H2E) © 1 Region 7 Universal and Laboratory Waste Janet Brown, H2E Partner Coordinator www.h2e-online.org

2. Hospitals for a Healthy Environment (H2E) © 2 Universal Wastes EPA finalized the Universal Waste Rule on May 11, 1995 –Done to streamline recycling efforts for commercial and industrial groups. Exempts hazardous wastes that are generated domestically as well –Universal wastes are not regulated under full RCRA Subpart C, but rather by streamlined Universal Waste Rules (40 CFR 273)

3. Hospitals for a Healthy Environment (H2E) © 3 Universal Waste Rule These waste streams are: –Hazardous waste batteries (except lead-acid batteries managed under 40 CFR Part 266 Subpart g); –Hazardous waste lamps; –Hazardous waste mercury-containing equipment (other than lamps and batteries); and –Hazardous waste pesticides that are recalled or collected as part of a pesticide collection program.

4. Hospitals for a Healthy Environment (H2E) © 4 Mercury Containing Equipment Mercury-containing equipment (MCE) is any device or part of a device that contains elemental mercury integral to its function; The definition of MCE excludes batteries and lamps; MCE includes, but is not limited to, thermostats, barometers, manometers, mercury switches, thermometers, flow meters, pressure relief gauges, mercury regulators, water treatment gauges, and gas safety relays.

5. Hospitals for a Healthy Environment (H2E) © 5 Universal Waste Rule Continued States have autonomy when it comes to the Universal Waste Rule: –States do not have to adopt it –States can add or remove wastes –States can also have more stringent requirements –NY uses the old federal guidelines for Universal Waste –NJ has state guidelines for Universal Waste Rule and includes computer monitors (CRTs) as universal wastes –Federal rule applies in VI –PR has not adopted the Universal Waste Rule

6. Hospitals for a Healthy Environment (H2E) © 6 Overarching Issues Hazardous Waste Identification Proper Waste Disposal Substitution of Less Toxic Alternatives Recycling/Reprocessing of Chemicals Using Less Chemicals

7. Hospitals for a Healthy Environment (H2E) © 7 State Universal Waste Rules http://www.epa.gov/epaoswer/hazwaste/id/univwast/statespf.htm

8. Hospitals for a Healthy Environment (H2E) © 8 Aerosol Cans (CO); Antifreeze (LA, NH); Ballasts (MD, ME, VT); Cathode Ray Tubes (CRTs) (ME, MI, NH, RI); Electronics (CO, CT, NJ); Oil-Based finishes (NJ); State Universal Waste Rules (Contd)

9. Hospitals for a Healthy Environment (H2E) © 9 Examples of Hospital Universal Waste Nickel cadmium or sealed lead-acid batteries found in –Electronic equipment –Mobile phones –Emergency back up lighting Mercury-containing equipment such as thermostats, thermometers, manometers, etc. Lamps that have a hazardous component –Fluorescent lights –High intensity discharge lamps –Neon lamps –Mercury vapor lamps –High pressure sodium lamps –Metal halide lamps

10. Hospitals for a Healthy Environment (H2E) © 10 Proposed Rule Proposed rule - June 12, 2002 Exclusion from the definition of solid waste which would streamline RCRA management requirements for used CRTs and glass removed from CRTs sent for recycling http://www.epa.gov/epaoswer/haz waste/id/univwast/crt-fr.pdf

11. Hospitals for a Healthy Environment (H2E) © 11 Types of Universal Waste Handlers Small Quantity Universal Waste Handlers (SQHUW) accumulate less than 5,000 kilograms (11,000 lbs) of all universal waste categories at any one time. Large Quantity Universal Waste Handlers (LQHUW) accumulate 5000 kilograms or more of all universal waste categories at any one time. Once a handler triggers the LQHUW status, they remain for the rest of the calendar year

12. Hospitals for a Healthy Environment (H2E) © 12 Notification Includes: Statement indicating that the facility is a LQHUW (Large Quantity Universal Waste Handler) Name, physical and mailing address of facility Name and business phone number of person responsible for managing universal waste at facility List of all types and quantities of universal waste managed by the facility (e.g. batteries, pesticides, mercury-containing equipment, lamps)

13. Hospitals for a Healthy Environment (H2E) © 13 Proper Management All handlers of universal waste must manage them in a way that prevents releases of the universal waste or component of universal waste to the environment All handlers of universal waste must mark or label the universal waste to identify the type of universal waste

14. Hospitals for a Healthy Environment (H2E) © 14 Implementation Strategy Leadership Support Meeting with Engineering/Facilities/Biomedical Engineering Review records and reduce mercury at point of purchase Policy development Facility Audit Identify Storage area Bid contract/Background/Facility Check Implementation, Education, Training Monitoring, Reporting, Record Keeping

15. Hospitals for a Healthy Environment (H2E) © 15 Labeling Universal Waste – Battery(ies); or Waste Battery(ies); or Used Battery(ies). Universal Waste-Pesticides; or Waste Pesticides. Universal Waste-Mercury Containing Equipment (thermostat); or Waste Mercury Containing Equipment (thermostat), or Used Mercury Containing Equipment (thermostat). Universal Waste-Lamp(s); or Waste lamp(s); or Used lamp(s).

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18. Hospitals for a Healthy Environment (H2E) © 18 Accumulation Time Limits All handlers of universal waste can only keep the universal waste on-site for a year unless they can prove that a longer period is necessary to accumulate enough universal waste to facilitate proper recovery, treatment or disposalAll handlers of universal waste can only keep the universal waste on-site for a year unless they can prove that a longer period is necessary to accumulate enough universal waste to facilitate proper recovery, treatment or disposal All handlers of universal waste need to be able to demonstrate the length of time that the universal waste has been accumulatedAll handlers of universal waste need to be able to demonstrate the length of time that the universal waste has been accumulated

19. Hospitals for a Healthy Environment (H2E) © 19 Laboratory Challenges Minimal space Run 24/7 Familiarity with laboratory language Resistance to change

20. Hospitals for a Healthy Environment (H2E) © 20 Be like Mercury – Persistent! Designate team leader Pilot – Start Small if you need to Take a team approach – include multiple departments Check with your GPO – Were driving markets! Educate

21. Hospitals for a Healthy Environment (H2E) © 21 I. Hazardous Waste Identification # 1 RCRA Violation for Region 2 Mercury, Solvents, sodium hydroxide, alcohols Understanding of P, U and D in the lab Proper Labeling Proper storage for flammable and reactive chemicals Lab Clean outs and Generator Status

22. Hospitals for a Healthy Environment (H2E) © 22 Chemical Waste Inventory – Why? Health & Safety Regulatory Compliance –Someone with a clipboard taking notes –Protective Gear –Spill Supplies & Fire Extinguisher –Telephone, Eyewash and Phone –Sign on the door – inventory in progress

23. Hospitals for a Healthy Environment (H2E) © 23 Suit Up for Inventories Goggles Mask Long Pants Long Sleeves Nitrile Gloves

24. Hospitals for a Healthy Environment (H2E) © 24 Chemical Storage Issues Incompatible chemicals stored together Stored near a drain Lack of secondary containment

25. Hospitals for a Healthy Environment (H2E) © 25 Chemical Incompatibility Acids by Caustic Bases Oxidizing Acids (Nitric, Sulfuric) by combustible glacial acetic acid. Volatile compounds in leaky containers reacting (hydrochloric acid vapors & ammonia vapors = crystals

26. Hospitals for a Healthy Environment (H2E) © 26 Chemical Use by Drains Do not pour hazardous chemicals into secondary containers over drains. Spills = illegal disposal Sends the wrong message to staff Blocks access to eye wash units on sinks.

27. Hospitals for a Healthy Environment (H2E) © 27 Fume Hood Issues Intended for chemical use, not storage Theres a drain back there. Chemicals need secondary containment. (Including those in the cabinets below the hood.)

28. Hospitals for a Healthy Environment (H2E) © 28 2. Improper Waste Disposal Study on improper mercury disposal in labs Where to throw? Mixed wastes –Training –Identification first! –Pipes and traps –Catch 22 waste – mercury? RMW?

29. Hospitals for a Healthy Environment (H2E) © 29 3. Substitution of Less Toxic Materials Mercury elimination Inventory mercury-containing devices and chemicals (required for MMMF) Substitution protocol –Blind Trials –Sustainable Hospitals Project –Low Hanging Fruit –Pockets of success

30. Hospitals for a Healthy Environment (H2E) © 30 Problems with Identifying Sources of Mercury in the Lab Material Safety Data Sheets (MSDS) dont identify mercury levels below 1% in the product. MSDSs are required to list ingredients that are health hazards and which comprise 1% or more of the chemical or reagent mixture (0.1% for carcinogens). Unfortunately 1% (10,000 ppm) can be well above some regulated wastewater limits.

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32. Hospitals for a Healthy Environment (H2E) © 32 Plumbing can contain mercury from previous mercury spills Check P-traps, elbows and low points System made need to be flushed if extensive contamination. Some hospitals have replaced lab plumbing. Problems with Identifying Sources of Mercury in the Lab

33. Hospitals for a Healthy Environment (H2E) © 33 Require Vendor Disclosure Request that vendors and manufacturers disclose all hazardous materials contained in their products- especially mercury Make it a contract requirement Explain you want levels below those detailed on the MSDS (vendors have this info)

34. Hospitals for a Healthy Environment (H2E) © 34 CAP supports mercury elimination New College of American Pathology (CAP) statement on elimination of mercury- containing chemicals in the lab setting The Laboratory Accreditation Program added a Lab General Checklist question: "Does the laboratory have a written plan to reduce or eliminate mercury?" A no answer results in a recommendation and request for follow- up.

35. Hospitals for a Healthy Environment (H2E) © 35 IV. Recycling/Reprocessing of Chemicals Alcohol, Xylene, Formalin Hazardous waste accumulation (generator status) Solvent Reprocessing Stills –Cost Savings –ROI often less than one year –Decrease in purchasing –Decrease in disposal costs –Quality Assurance Protocol a must

36. Hospitals for a Healthy Environment (H2E) © 36 Solvent Recycling Case Study Albany Medical Center Savings is in both avoided disposal costs and avoided purchase costs. Saved over $2.6 million since programs inception in 1996. Reclaimed more than 205 tons of chemicals. Facility and equipment costs $150,000 to construct. ($75,000 in equipment purchase and $75,000 in renovations to a decommissioned incinerator room.) Paid for itself in six months.

37. Hospitals for a Healthy Environment (H2E) © 37 Solvent Recovery Case Study Albany Medical Center YearSavings 1996$274,485 1997$242,611 1998$238,269 1999$264,448 2000$216,263 2001$169,560 2002$126,016 2003$110,662 2004$315,663 2005$395,006

38. Hospitals for a Healthy Environment (H2E) © 38 Facility Details Albany Medical Center 4 – 20 liter capacity B/R Instrument distillation units and a CBG Biotech Alcohol-xylene mobile recycling unit. Requires 2 technicians working an average of one hour a day with a PhD chemist doing QC about one hour a week.

39. Hospitals for a Healthy Environment (H2E) © 39 Albany Medical Center EPA did a multi media, unannounced inspection in September 2003. Albany Medical received a letter commending their efforts in hazardous waste minimization and assuring compliance with RCRA. No violations received from EPA.

40. Hospitals for a Healthy Environment (H2E) © 40 Albany Med in 2006 SolventAmount this year Alcohol15,000 lbs Xylene10,000 lbs Formalin8,000 lbs Propanol4,000 Total36,000 lbs

41. Hospitals for a Healthy Environment (H2E) © 41 For More Information Russ Mankes Associate Professor/Chemical Hygiene Officer Albany Medical Center 518 262-5490 mankesr@mail.amc.edu

42. Hospitals for a Healthy Environment (H2E) © 42 V. Chemical Use Reduction Microscale Chemistry Smaller, pre-filled containers Less purchase, less waste, less safety risk Comparison of amounts of xylene used in microscale vs. macroscale http://www.epa.state.oh.us/dhwm/ pdf/NotifierWinter05.pdfhttp://www.epa.state.oh.us/dhwm/ pdf/NotifierWinter05.pdf

43. Hospitals for a Healthy Environment (H2E) © 43 For More Information Minnesota Technical Assistance Program – Free Technical Assistance in Minnesota http://www.mntap.umn.edu/ Washington State Guidance on Proper Disposal of Cidex OPA http://www.govlink.org/hazwaste/publications/LabGuide linesRevAugust06.pdf http://www.govlink.org/hazwaste/publications/LabGuide linesRevAugust06.pdf King County Laboratory Waste Management Guide - http://www.govlink.org/hazwaste/publications/LabGuidel ines_05.pdf http://www.govlink.org/hazwaste/publications/LabGuidel ines_05.pdf Howard Hughes Medical Institute – Free Lab Training Videos http://www.hhmi.org/ MA Institute of Technology – Green Chemical Alternatives Wizard http://web.mit.edu/environment/academic/purchasing. html http://web.mit.edu/environment/academic/purchasing. html