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Previous by Date: Subject: [DCHAS-L] US Chemical Safety Board Job Posting: Chemical Incident Investigator Date: Friday, June 24, 2022 at 3:29:18 PM Author: CHAS membership <membership**At_Symbol_Here**DCHAS.ORG> |
Next by Date: Subject: [DCHAS-L] Chemical Safety headlines (14 articles) Date: Mon, 27 Jun 2022 05:40:59 -0400 Author: Ralph Stuart |
Fellow Listers,
I read this post and considered the historical perspective of regulation. Federal EPA passed Subpart P to apply to healthcare facilities and reverse distributors on 2/22/2019. The intent of the rule was to eliminate and prevent the disposal of pharmaceuticals that have a impact on the environment. Why? Because pharmaceuticals were being passed through treatment plants and causing effects on ecosystems. The microgram quantities that they are working with pertains to their exposure only, not the 100-200 mg disposal over weeks either disposed of via drain or chemically treated to breakdown the kanamycin antibiotics. Here is a strong suggestion, look up and evaluate the Managing Hazardous Waste at Academic Rulemaking law applicable to educational/teaching facilities in the light of what is required of, and what it takes to become a Treatment, Storage and Disposal (TSDF) facility. It seems you can either segregate, collect and dispose of as hazardous waste or treat kanamycin to unspecified or quantified degradants while potentially becoming a TSDF. When you are performing your cost analysis, please be sure to include the segregation of kanamycin (with triple rinsing wastes) compared to hazardous waste disposal or even becoming a TSDF. Make sure you include legal when evaluating risks of becoming a TSDF.
Dilution is not the solution, neither is becoming a TSDF. The best advice I can provide is developing/maintaining a strong segregation process to minimize hazardous waste generation while minimizing costs.
It's all perspective.
BruceV
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> On Behalf Of Jennifer Gile
Sent: Friday, June 10, 2022 1:48 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: [DCHAS-L] Disposing of kanamycin
All,
The NIH Drain Disposal guide came across my email recently, and it has left us with a question specifically about kanamycin. https://nems.nih.gov/Documents/NIH_Drain_Discharge_Guide.pdf
One of our researchers uses kanamycin in their antibiotic resistance studies. The total amount used over 10 weeks is about 100mg and would never exceed 200mg. They are working with microgram quantities on a weekly basis.
The NIH Drain Disposal guide suggests kanamycin should be treated as hazardous waste (collected and sent to disposal) Is anyone familiar with alternative disposal for kanamycin? Our concern is the very small amount of kanamycin in the large amount of water and bleach would have a drastic effect on our waste stream.
Is bleach sufficient to render the kanamycin appropriate for drain disposal? I have also seen suggestions that kanamycin be treated with acid to render it inactive and thus okay for drain disposal; but then wonder would neutralizing the acid (to make that appropriate for drain disposal) nullify the acid inactivation?
We do have access to an autoclave, but the NIH guide seems to suggest heat does not render kanamycin safe for the drain.
Your thoughts are appreciated,
Jennifer.
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