Labs spend significant sums on buying and disposing of histology solvents. Unseen to most, are the regulatory costs of complying with local and federal hazardous waste regulations. The more hazardous waste your facility generates, the greater the regulations.
Waste solvents from the lab are classified as hazardous waste by the US EPA. Depending on the amount of hazardous waste your facility generates, you are assigned to one of three hazardous waste generator categories.
Solvent recycling will reduce the amount of hazardous waste coming from the histology/pathology labs by up to 90%. This reduction in hazardous waste can put you in a lower generator category, dramatically reducing paper work and compliance burdens.
Large and small quantity generators must make and implement a waste minimization plan. Recycling your solvents should be part of that plan. It will demonstrate that you are working hard to minimize your hazardous waste generation.
In the United States, RCRA regulates hazardous waste management standards. These are found in title 40 of the Code of Federal Regulations in part 262 and 40 ยง261.5. The table below is a brief summary of the most notable requirements.
Looking at the table it becomes obvious that there are significant advantages to reducing the amount of hazardous waste you generate.
| Conditionally Exempt Small Quantity Generators | Small Quantity Generators | Large Quantity Generators | |
|---|---|---|---|
| Quantity Limits | 100 kg/month (for liquids < about 100 liters or 26 gallons) | 100 < 1000 kg/month (for liquids between 100 and 1000 liters or 26 to 260 gallons) | 1000 kg/month (for liquids > about 1000 liters or > 260 gallons) |
| EPA ID Number | Not Required | Required | Required |
| On site Accumulation Quantity | < 1000 kg | < 6000 kg | No Limit |
| Accumulation time limits | None | < 180 days | < 90 days |
| Personal | Not required | Basic Training Required | Advance Training Required |
| Emergency Plan | Not required | Basic Plan Required | Full Plan Required |
| Air Emissions | Not required | Not required | Required |
| Record Keeping | Not required | Required | Required |
| Biennial Report | Not Required | Not Required | Required |
| Exception and Additional Reporting | Not required | Required | Required |
| Waste Minimization Plan | Not Required | Good faith effort required | Program in place required |
| Pre-Transport Requirements | Only, if required by DOT | Required | Required |
| Manifest | Not Required | Required | Required |
| Land Disposal Restrictions | Not Required | Required | Required |
| Accumulation Requirements | None | Basic Requirements | Full Compliance |
Recycling solvents saves money, saves paperwork, and saves the environment!
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