Clarifying the University’s “No Drain Disposal” Policy
As a member of the Columbia University research community, you should be familiar with the University’s “No Drain Disposal” policy for laboratory chemicals. Sometimes EH&S is asked for clarification and because the regulations behind this policy statement are numerous and convoluted, we will (use this article to) clarify the “No Drain Disposal” policy.
Let’s begin with the regulatory basis of the policy and how the laws define “hazardous waste.” The US EPA and NY State DEC define hazardous waste as anything that can pose a substantial or potential hazard to human health or the environment when improperly managed. EPA and DEC go on to say that chemical wastes that have the characteristic of ignitability, corrosivity, reactivity, or toxicity are hazardous wastes, as are any chemicals that appear on specific lists (e.g., F-list, P-list, U-list) created by the agencies.
In addition to the broad net cast by EPA and DEC, the New York City Department of Environmental Protection (DEP), the agency that regulates the City’s sewage treatment plants and thus the laboratory drains that feed them, forbids flammable liquids and toxic substances from entering the public sewers. Again, flammable liquids and toxic substances cover a wide array of laboratory chemicals. Municipalities in Rockland and Westchester Counties have similar prohibitions on substances entering the sewers.
When considering the combined requirements and restrictions of EPA, DEC and DEP, little wiggle room exists for the drain disposal of chemicals. And even where some room exists, Columbia has chosen to take a conservative approach to chemical waste collection and requires the collection of ALL laboratory chemical waste because attempting to debate the definition of hazardous, toxic, etc with the regulators is futile.
So once we have determined what is subject to the hazardous waste regulations, we can turn to the University’s “5Ls of Hazardous Waste Management,” 5 basic principles of chemical waste collection and management (http://www.ehs.columbia.edu/5L.html). The “5Ls” were developed by EH&S as a translation of the complex Federal, State, and local hazardous waste regulations into concise, easy to follow steps for ensuring compliance. In accordance with hazardous waste regulations and the “5Ls,” all hazardous chemical waste must be collected and properly disposed of. The overwhelming majority of Columbia’s laboratory chemicals meet the criteria for collection as hazardous waste, prohibiting drain disposal as an option. In support of the University’s No Drain Disposal policy, here are some classic examples of chemicals EH&S is frequently questioned about:
Ethanol: an ignitable/flammable chemical that meets the ignitability characteristic of
hazardous waste as defined by EPA/DEC. As a flammable liquid, it is also forbidden from entering the public sewer (even with copious amount of water). It is clear and unequivocal that ethanol must be collected for hazardous waste disposal.
Acetone: see Ethanol
Methanol: see Ethanol
Chromerge: a sulfuric acid (corrosive) and chromium trioxide (toxic) solution used for cleaning laboratory glassware. This mixture is a corrosive, toxic hazardous waste and a pretty nasty actor all around. EH&S always recommends laboratories try alternative glass cleaner products (e.g., Alconox or NoChromix).
Dyes and Stains: the exact contents of dyes and stains will determine whether they can be drain disposed. For example, Coomassie Blue and “Destain,” which contain methanol and acetic acid, would both be considered hazardous wastes and prohibited from drain disposal. EH&S prefers all dyes and stains be collected for hazardous waste disposal.
There are two very important issues related to drain disposal and hazardous waste collection that must also be mentioned. The EPA, DEC and DEP generally DO NOT recognize quantities or volume limits in their definitions, which means even small
quantities of chemical waste must be collected for proper disposal. Also, the evaporation, intentional dilution or neutralization of a hazardous chemical waste for the purpose of avoiding collection of that chemical as a hazardous waste is illegal.
Please contact EH&S with questions about the University’s “No Drain Disposal” policy.