We found that managing “lab debris” opens the potential for RCRA violations. An inspector walks into any lab, finds a glove in the trash, and asks-
“did you perform a hazard determination on the glove?” (insert other lab debris such as Kimwipes ™ etc)
Separate receptacles for gloves, paper towels simply were an open invitation to discard any waste, including normal trash.
So, we decided to play the game. We accumulated lab debris from many labs, random sampling, over the course of many weeks, and submitted the samples for RCRA
analysis. Yes, it was costly up front, but we ended up with documentation that the lab debris never triggered RCRA characteristic. We continue to perform random sampling, and maintain our records for the authorities to check.
-Stefan Wawzyniecki, CIH, CHMM
University of Connecticut
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU]
On Behalf Of Murphy, Dr. Ruth Ann
Sent: Tuesday, December 10, 2013 4:34 PM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] Disposal of Lab Gloves
Sheila,
We dispose of them as hazardous waste. The Housekeeping personnel (who are untrained in Chemical safety) handle the lab trash which is mostly paper towels.
Ruth Ann
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU]
On Behalf Of Kennedy, Sheila
Sent: Tuesday, December 10, 2013 2:23 PM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] Disposal of Lab Gloves
Ruth Ann,
Why are you uncomfortable with putting them in the lab trash?
What would you do with gloves collected in a separate container? Add them to the lab trash in the dumpster or dispose as hazardous waste or ??
Sheila
_________________________________
Sheila Kennedy, C.H.O.
Safety Coordinator | Teaching Laboratories
UCSD Chemistry & Biochemistry |MC 0303
s1kennedy**At_Symbol_Here**ucsd.edu | http://www-chem.ucsd.edu
Office: (858) 534-0221 | Fax: (858) 534-7687
_________________________________
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU]
On Behalf Of Murphy, Dr. Ruth Ann
Sent: Tuesday, December 10, 2013 11:16 AM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: [DCHAS-L] Disposal of Lab Gloves
Hi,
Has anyone found a suitable container in which students can leave the gloves they wore in lab? We prefer not to put the gloves in with the regular trash and
would like something obvious that maybe could be on the wall by the door – as a reminder to remove gloves before leaving the lab. Thank you!
Ruth Ann
Ruth Ann Murphy, Ph.D.
Professor of Chemistry
Chairperson, Department of Chemistry, Environmental Science and Geology
Chairperson, Health Professions Advisory Committee
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