Monique,

I'd start with discussing why EHS feels you need to characterize the waste monthly. Per the rules, you only need to do it when you first generate the waste and only need to recharacterize it when the process changes or you have reason to believe the characterization has changed.

Jeff

"2.4.2 DETERMINING IF YOU GENERATE HAZARDOUS WASTE

All facilities must determine if the waste they generate meets is a hazardous waste or not. This is necessary when a waste is first generated and must be re-evaluated if changes are made that may change the nature or composition of the waste. The waste must be re-evaluated if the materials used in the process change, the process generating the waste is changed, or operational changes are made that may change the composition and nature of the waste (e.g. cross contamination from material overspray or even a change in storage temperatures that can result in a change in the nature or composition of the waste). "

You can also note that "Process Knowledge is a legitimate characterization technique.

" 2.4.2.b Information Used to Make the Waste Determination

Waste can be characterized using the generator's knowledge or by testing a representative sample.

Process knowledge may be used in making a listed or characteristic waste determination. Information used for making a listed waste determination may include the waste origin, composition, the process producing the waste, feedstock, and other reliable and relevant information.. Information on the SDS or other supplier and manufacturer literature may be useful when you have unused product needing disposal. Knowledge that may be used in making a determination that the waste exhibits one or more characteristics of a hazardous waste includes process knowledge; feedstocks and other process inputs; knowledge of products, by-products, and intermediates produced by the manufacturing process; chemical or physical characterization of the wastes; information on the chemical and physical properties of the chemicals used or produced by the process or otherwise contained in the waste; or other reliable and relevant information about the properties of the waste or its constituents. An SDS often provides information about the flashpoint, pH, and if a discarded product is a hazardous waste or contains hazardous constituents. Note, however, that an SDS is not completely reliable for determining if a used material is a hazardous waste because it does not include information about contaminants that might be in the waste from use. Since the SDS is designed to meet occupational safety requirements, it also may not include all hazardous constituents requiring evaluation under the environmental regulations. A waste stream may be presumed (by knowledge) to contain certain constituents above regulatory thresholds for compliance purposes; however, testing may be required to adequately document a hazardous or non-hazardous waste determination."

On Mon, Feb 8, 2021 at 12:21 PM Monique Wilhelm <mwilhelm**At_Symbol_Here**umich.edu> wrote:

Hello Everyone,

I work in academia and most of teh haz waste taht I generate are
mixtures that come from our courses. Because they all follow the same
set procedure and are using known chemicals, I know the contents and
teh hazards prior to the wste benign generated and therefore it is
very unusual for me to have to do any actual tests to characterize the
waste prior to shipping it out.

I have been determine the hazards of our waste based on the materials
we supply them for the experiment and even use the 49 CFR to include
the hazard class for most of the chemicals in these mixtures of the
bottle label.

Our new EHS person wants us to start logging each waste bottle monthly
on a form similar to the one here
https://www.michigan.gov/documents/deq/Optional_Waste_Characterization_Record_Form_460914_7.pdf

Does anyone else do this or have any guidance for streamlining this process?

Thank you,
_________________________________________________________
Monique Wilhelm
Lab Manager
CAS, Department of Chemistry & Biochemistry | The University of Michigan-Flint
303 E. Kearsley St | Room 572 MSB | Flint, MI | 48502-1950
NEW EMAIL ADDRESS: mwilhelm**At_Symbol_Here**umich.edu

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Jeff Lewin

Director of Chemical Laboratory Operations

Research Integrity Office

Laboratory Operations

205 Lakeshore Center

Michigan Technological University

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