Sink Disposal Information Guide

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1 Sink Disposal Information Guide This resource developed by LabCentral for the Pagliuca Harvard Life Lab Revision 1, Effective March 6, 2017

2 Table of Contents 1.0 PURPOSE AND SCOPE OVERVIEW APPLICABLE SINK LOCATIONS MATERIALS PERMITTED FOR SINK DISCHARGE Approved Waste Stream Composition Liquid Biological Waste Review Process PROHIBITED MATERIALS FOR DISCHARGE Hazardous Waste Corrosive Solutions (ph 5.5 or 12.0), which are not considered RCRA hazardous wastes Flammable or Explosive Substances Other Prohibited Materials DILUTION PROHIBITION REVISION HISTORY...8 Page 2 of 8

3 1.0 PURPOSE AND SCOPE Laboratory operations often generate significant quantities of nonhazardous aqueous waste. Any wastewater or aqueous waste that is discharged onsite must comply with the Pagliuca Harvard Life Lab s wastewater permit. The permit outlines limitations and prohibitions established by the local wastewater treatment authority, the Massachusetts Water Resources Authority (MWRA). The Life Lab is required to report all chemical discharge violations to the MWRA that can result in enforcement actions. MWRA enforcement actions are cumulative and can ultimately result in fines or penalties that can jeopardize the Life Lab s research and operational capabilities. In addition, repetitive discharge violations can ultimately lead to requirements for closer monitoring of routine laboratory operations. 2.0 OVERVIEW The Life Lab utilizes a BERT Process Equipment ph neutralization system to maintain compliance with MWRA regulations. When supplied as a continuous flow through system, the module will automatically adjust incoming wastewater to the desired, usually ph, with a proportional addition of a caustic (50% sodium hydroxide) or acid (50% sulfuric) reagent. This system is designed to only adjust ph levels, and cannot manage anything other than nonhazardous aqueous wastewater that is within the acceptable. This neutralization system has the ability to treat drain discharge with higher ph ranges than are permitted by Harvard University EH&S policies. As such, this document should be used as guidance for the Life Lab instead of the manufacture s operation manual. This document summarizes what materials may be discharged into laboratory sinks and subsequently treated by the wastewater system. It also identifies many chemical substances that are limited or prohibited from drain disposal. Ultimately the decision to permit sink disposal will be granted by the Life Lab Safety Officer and Harvard University Environmental Health and Safety (EH&S) staff in conjunction with Triumvirate Environmental. This document can be used as a guideline for Life Lab members to request sink disposal of certain aqueous waste streams. Any approved waste stream must be in full compliance of the Life Lab s wastewater permit, Harvard University s drain disposal guide, and all other applicable standard operating procedures. Harvard s drain disposal guide can be found at Page 3 of 8

4 3.0 APPLICABLE SINK LOCATIONS Sink discharge of aqueous waste streams is only approved at sinks inside lab spaces at the Life Lab. At no point can any aqueous lab waste be discharged into sinks outside of laboratories. Sinks in bathrooms, kitchens, facility closets, as well as floor drains and toilets are never to be used for discharge of aqueous lab wastes. 4.0 MATERIALS PERMITTED FOR SINK DISCHARGE 4.1 Approved Waste Stream Composition In order to be considered for discharge into a sink, a waste stream must comply with each of the following criteria: Must contain at least 99% water Must have a ph within the range of > 5.5 and < 12.0 Must contain less than 1% nonhazardous material. These materials include, but are not limited to: o Sodium Chloride, Potassium Phosphate, Calcium Chloride and other nonhazardous salts o Dilute nonhazardous buffer solutions o Sugars, including glucose, sucrose, dextrose, etc. o Disinfected biological material, proteins, and amino acids Must not contain any material outlined in section 5.0 of this document 4.2 Liquid Biological Waste Decontamination of liquid biological waste must occur in a biological safety cabinet or in an aspiration flask system by combining the waste with disinfectant. If using bleach (5.45% sodium hypochlorite solution) as the disinfectant, use 10% final concentration in the liquid volume. The waste must remain in contact with the disinfectant for at least 20 minutes. The disinfected liquid may then be carefully transported to the appropriate sink for disposal into the sink drain with copious amounts of water by running the faucet for at least two minutes. See sections 4.2 Aspiration Flasks and 6.1 Liquid Biological Waste of the Life Lab Biosafety Practices document for specific steps for the bleach inactivation of liquid biological waste. Page 4 of 8

5 4.3 Review Process There are strict criteria for the kinds of contaminants that are permitted into the wastewater system. It is impossible to list every approved and prohibited material in this document. If any questions or concerns arise about what exactly can be discharged into sinks, residents are encouraged to reach out to the Life Lab facility safety officer or the TEI consultant to review their material composition before disposal. 5.0 PROHIBITED MATERIALS FOR DISCHARGE The following materials are strictly prohibited from sink disposal, regardless of the quantity or concentration. 5.1 Hazardous Waste All hazardous waste is prohibited from sink disposal and/or sewer discharge. A material is considered a hazardous waste if it meets any of the following criteria: It contains a substance listed by the Massachusetts Department of Environmental Protection (DEP) as a hazardous waste. A complete list of hazardous wastes can be found at It is considered a corrosive hazardous waste, with a ph 2.0 or o Note: Some Aqueous solutions with a mid-rage ph are not considered Resource Conservation and Recovery Act (RCRA) regulated hazardous wastes. However, they still do not meet the MWRA and/or Harvard University s requirements for drain disposal. These solutions should be collected in containers, labeled as Nonhazardous waste, stored in Hazardous Waste Satellite Accumulations areas, and discarded with hazardous wastes. This specifically applies to aqeous solutions with a ph greater than 2.0 but less than or equal to 5.5, as well as solutions with a ph greater than or equal to 12.0 but less than (See section 5.2 for a detailed breakout of s.) It is considered a flammable hazardous waste, with a flashpoint of less than 140 C. It is considered a reactive hazardous waste. o Reactive wastes include material that is normally unstable and readily undergoes violent change, reacts violently with water, or forms potentially explosive mixtures with air or water. A comprehensive guideline for reactive waste can be found on the EPA website, Page 5 of 8

6 5.2 Corrosive Solutions (ph 5.5 or 12.0), which are not considered RCRA hazardous wastes The Life Lab contains a wastewater treatment system for the neutralization of lab wastewater that may need a mild ph adjustment. Only solutions with a ph > 5.5 and < 12.0 can be considered for sink disposal. Corrosive solutions with s (ph 2.0) and (ph 12.5) at the conclusion of a lab process must be managed as hazardous waste, and should be collected at designated hazardous waste satellite accumulation areas. Even if an aqueous waste does not meet the ph criteria for a hazardous waste, it still must be within the that complies with Harvard s drain disposal guidelines. In order for an aqueous waste to be considered for drain disposal, it must have a ph > 5.5 and < Table 1: Aqueous Solution ph Range Guide 2.0 > 2.0 and 5.5 > 5.5 and < and < Must be collected in sealable containers, and managed as hazardous waste. Containers must be affixed with a hazardous waste label, and stored in a hazardous waste satellite accumulation area. These containers will be collected by EH&S for disposal. Must be collected in sealable containers, and managed as nonhazardous waste. Containers must be affixed with a nonhazardous waste label, and stored in a hazardous waste satellite accumulation area. These containers will be collected by EH&S for disposal. Aqueous solutions within this range can be considered for sink disposal, provided they meet all other criteria outlined in sections 4 and 5. Must be collected in sealable containers, and managed as nonhazardous waste. Containers must be affixed with a nonhazardous waste label, and stored in a hazardous waste satellite accumulation area. These containers will be collected by EH&S for disposal. Must be collected in sealable containers, and managed as hazardous waste. Containers must be affixed with a hazardous waste label, and stored in a hazardous waste satellite accumulation area. These containers will be collected by EH&S for disposal. Page 6 of 8

7 For sink disposal, 10% bleach is typically used to render a solution noninfectious. A solution of 10% bleach (0.54% total sodium hypochlorite) should ph at approximately This solution falls within the acceptable. If higher concentrations of bleach are required, and the final solution has a ph that is or exceeds 12.0, it cannot be discharged into a sink. 5.3 Flammable or Explosive Substances Solutions that are flammable (flash point less than 140 o F) or explosive at the time of disposal must not be disposed into a sink or drain. The drain disposal of flammables/explosives can create an unsafe condition for lab and facilities personnel. Prohibited flammable substances include, but are not limited to alcohols, acetone, gasoline, ketones, aldehydes, peroxides, ethers, xylene, toluene, and pyridine. 5.4 Other Prohibited Materials Only aqueous solutions containing at least 99% water and up to 1% other nonhazardous constituents, can be considered for drain disposal. There are strict criteria for what materials can make up the acceptable 1% of nonhazardous constituents, and the Life Lab s Safety Officer and TEI Consultant must review every product to decide if it is acceptable. The following list summarizes some material that cannot compromise any portion of that 1%. Therefore, all materials listed below are barred from drain disposal in any concentration. Heavy metals - including mercury, lead, and silver Infectious biological waste that has not been appropriately disinfected with bleach Radioactive wastes Polychlorinated Biphenyls (PCBs) Sodium Azide (includes mixtures that may have sodium azide present from kits) Stains and dyes (including cell stains) Any liquid with a temperature higher than 180 F Oils, fats and grease Petroleum Hydrocarbons at levels above 15 mg/l Pesticides Noxious or malodorous liquids Page 7 of 8

8 Groundwater, storm water, surface water, roof or surface runoff, or subsurface drainage Any solid or viscous substance in amount or size that may obstruct flow (e.g. sand, animal tissues, debris, gels, polymers, etc.) 6.0 DILUTION PROHIBITION The dilution of an aqueous waste in an attempt to achieve compliance with these guidelines is strictly prohibited. The increased use of process water in place of proper treatment shall be considered dilution and is prohibited. Note for rinsate: In many cases, the first rinse (with water and/or acetone) of a flask, beaker, etc. previously containing any prohibited material must not be discharged into a sink and must be collected as hazardous waste. Subsequent rinses, in which very low concentrations of the materials exist, may be discharged into a sink. However, if the container formerly held a chemical that is on the RCRA acutely toxic chemicals list (the P-list), all of the rinsate must be collected as hazardous waste and none can be discharged into the sink. A list of p-listed chemicals can be found on the EPA s website: REVISION HISTORY Change Reason Effective Date New Document New guidance document for scientists wishing to discard nonhazardous aqueous waste into a sink. Mar 2017 Page 8 of 8