[Histonet] RE: Waste Flammable Info Please

[Elizabeth Chlipala]

Teri

That's interesting since we need to fill out a form every year that tabulates the waste generated and not what we purchase.  I thought it was based upon the amount of waste generated.  

That was not our experience.  The state came and audited us once we started disposing of waste at a rate of 55 gallons per month.  That pushed us past that 650 gallons for a conditionally exempt small quantity generator and therefore we became a small quantity generator.  They never asked us how much we purchased only what the waste stream was.  

Just my experience.  Since the states monitor for this, it may vary from State to State how the EPA regs are interpreted or if State laws override federal regarding waste and classifications. 

Liz

Elizabeth A. Chlipala, BS, HTL(ASCP)QIHC
Premier Laboratory, LLC
PO Box 18592
Boulder, CO 80308
(303) 682-3949 office
(303) 682-9060 fax
(303) 881-0763 cell
liz <@t> premierlab.com
www.premierlab.com

March 10, 2014 is Histotechnology Professionals Day

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1567 Skyway Drive, Unit E
Longmont, CO 80504


-----Original Message-----
From: histonet-bounces <@t> lists.utsouthwestern.edu [mailto:histonet-bounces <@t> lists.utsouthwestern.edu] On Behalf Of Teri Johnson
Sent: Tuesday, April 15, 2014 12:00 PM
To: 'Dennis.Hahn <@t> cookchildrens.org'
Cc: histonet <@t> lists.utsouthwestern.edu
Subject: [Histonet] Waste Flammable Info Please

Hi Dennis,

I don't think that recycling will fix your EPA license issue. They care about how much you GENERATE through use, not whether it is actually being disposed of or even recycled. We had an issue with the EPA regarding our xylene generation at another facility I used to work in. When I tried to point out that we were recycling it, they said that didn't make a difference. Once it goes into use, it becomes generated waste.

You might want to look at changing your practices so that you generate less, i.e. changing the processors according to block numbers or alcohol dilution rather than number of runs, or using smaller containers at the staining bench.

Alcohol recycling is great, but you will never get back anything more pure than about 98% so you will need to continue to purchase absolute alcohol. The biggest difficulty is making sure you keep any xylene contaminated alcohol separate and out of the recycler. Xylene will not be removed from alcohol during alcohol recycling so you will still have contaminated alcohol. Anything containing xylene must be recycled as xylene (or manifested out as waste).

I hope this helps,

Teri Johnson
Manager, Histology
Genomics Institute for
Novartis Research
Foundation
San Diego, CA
858-332-4752

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