doc. no 413 state of california department of toxic ...“the case against mercury: rx for pollution...

DOC. NO 413

DTSC

State of California Department of Toxic Substances Control Office of Pollution Prevention and Technology Development Contact: Mary Pride Phone: (916) 324-1088

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ACKNOWLEDGEMENTSThis document was compiled by Mary K. Pride under the direction of James T. Allen, Ph.D., Chief,Kim Wilhelm. P.E., and Dave Hartley, M.P.H., of the Department of Toxic Substances Control(Department), Office of Pollution Prevention and Technology Development. The Departmentexpresses appreciation to David M. Snyder of Russell Resources for the preparation of the “Haz-ardous Waste Minimization Checklist and Assessment Manual - General Medical and SurgicalHospitals (excluding infectious wastes)”, Ecology and Environment, Inc., for the preparation of the“Waste Audit Study - General Medical and Surgical Hospitals”, and Jacobs Engineering Group,Inc., for the preparation of the “Guide to Waste Minimization in Selected Hospital Waste Streams”for the U. S. Environmental Protection Agency. Ben Fries is acknowledged for providing help withthe original compilation of the Checklist with Russell Resources.

REVIEWERS/CONTRIBUTORSTom Barron, Business and Engineering Consultant, Lafayette, California

Pat Bennett, P.E., Hazardous Substances Engineer, State of CaliforniaDepartment of Toxic Substances Control

Craig Carrero, Environmental Health and Safety Senior Technician,University of California Medical Center, Davis

Lacey Friedman-Vasquez, Hazardous Waste Reduction Specialist,Contra Costa County Health Services Department

Dave Hartley, M.P.H., Supervising Hazardous Substances Scientist, State of California Departmentof Toxic Substances Control

Hollie Shaner, R.N., M.S.A., CGH Environmental Strategies, Inc., Vermont

Barbara Smisko, Kaiser Permanente, Western Environmental Health and Safety HUB

Ken Torke, Industrial Waste Investigator, Palo Alto RWQCP

Kim Wilhelm, P.E., Chief, Office of Pollution Prevention and Technology Development, State ofCalifornia Department of Toxic Substances Control

SOURCES OF CASE STUDY ABSTRACTSChildren’s Hospital of Los Angeles/Los AngelesCity of Hope National Medical Center/DuarteKaiser Permanente/FresnoKaiser Permanente Medical Group Regional Lab/BerkeleyLos Angeles County King-Drew Medical Center/Los AngelesUniversity of California Davis Medical Center/Sacramento

DISCLAIMERThe mention of commercial products, commercial services, their sources or their use in connectionwith material, herein, is not to be construed as actual or implied endorsement of such products orservices by the Department.

MEDICAL WASTEInformation on Medical Waste (including biohazardous and sharps waste) is available from theDepartment of Health Services, Medical Waste Management Program, P.O. Box 942732 (MS 396),Sacramento, California 94234-7320. Their telephone number is (916) 327-6904 and their fax numberis (916) 323-9869.

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REFERENCES“Best Management Practices for Laboratories”, “Best Management Practices for Hospitals andMedical Facilities” - Regional Water Quality Control Plant, 2501 Embarcadero Way, Palo Alto,California, 94303, (415) 329-2598.

Contra Costa County Health Department - Hazardous Materials, Martinez, California, 94553-2295,(510) 646-2286, FAX 646-2073.

“Guides to Pollution Prevention - Selected Hospital Waste Streams” - EPA/625/7-90/009, UnitedStates Environmental Protection Agency, Center for Environmental Research Information, Cincin-nati, Ohio, 45268, (513) 569-7562.

“RX for a Healthy Environment” - San Francisco Water Pollution Prevention Program, Departmentof Public Works, Bureau of Environmental Regulation and Management, Water Pollution Preven-tion Program, 1997, (415) 554-3421.

“The California Waste Exchange” - Department of Toxic Substances Control, Hazardous WasteManagement Program, P.O. Box 806, Sacramento, CA, 95812-0806, (916) 422-4742, FAX (916) 327-4495, or for online access contact http://www.calepa.cahwnet.gov/dtscdocs/cawastex.txt

“The Case Against Mercury: Rx for Pollution Prevention” - Terrene Institute, Washington, D.C.,(703) 548-5473.

“Waste Audit Study, General Medical and Surgical Hospitals” - Ecology and Environment, Inc., forthe Department of Toxic Substances Control, August 1988, (916) 322-3670, FAX 327-4494.

“Writing a Waste Reduction Plan for Health Care Organizations” - The University of TennesseeCenter for Industrial Services, Nashville, Tennessee, 37219-1804, (615) 532-8657, FAX 532-4937.

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TABLE OF CONTENTSINTRODUCTION - PURPOSE OF THE GUIDE.................................................. 1

Hazardous Waste Source Reduction andManagement Review Act of 1989 (SB 14) and Hospitals

SECTION 1: GENERAL WASTE MINIMIZATION INFORMATION............................. 3General Discussion Of Major Waste Streams In HospitalsDefinition Of Waste Minimization................................................................................................3

Principles of Waste MinimizationAssessing Waste Minimization Opportunities

Management Practices ....................................................................................................................4Material Safety Data Sheets ...........................................................................................................5Materials Inventory And Storage..................................................................................................5

Drums and ContainersSpill Control

HAZARDOUS WASTE MINIMIZATION - APPLICATIONS ....................................10FACILITIES ................................................................................................... 10

Aerosols ......................................................................................................................................... 10Batteries .......................................................................................................................................... 10Construction ................................................................................................................................... 11Hot Water Systems ........................................................................................................................ 11Housekeeping ................................................................................................................................ 11Laundry.......................................................................................................................................... 12Lighting .......................................................................................................................................... 12Offices ............................................................................................................................................. 12Paints .............................................................................................................................................. 12

Paint Gun Washer and Recycler Case StudyParts Washing................................................................................................................................ 13Pesticides ....................................................................................................................................... 14Plumbing ....................................................................................................................................... 14

LABORATORIES.............................................................................................. 14Inventory ....................................................................................................................................... 14Cleaning ......................................................................................................................................... 15

Autoclave Labware Washing Process Case StudyMercury .......................................................................................................................................... 16Cell Sorting and Counting Instruments .................................................................................... 16Automated Systems or Other Instrumentation for Lab Chemistry Analyses .................... 16

Automatic Slide Stainer Case StudyMicroanalytical Techniques ........................................................................................................ 17

Case StudyCarbon Dioxide as a Laboratory Euthanizing Agent ............................................................. 17

Case StudyChloroform .................................................................................................................................... 18

Case StudyCytospin or Thin Prep Technology ............................................................................................ 18Atomic Absorption Standards .................................................................................................... 18Analysis of Chloride by Ion-Selective Electrode (ISE) ............................................................ 18Glucose Tests without Zinc ......................................................................................................... 18

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Bouin’s Solution ............................................................................................................................ 18Carrier Liquid ............................................................................................................................... 19

Case StudyZenker’s Solution and Mercury B-5 .......................................................................................... 19Preserving Stool Samples ............................................................................................................ 19Thimersol ....................................................................................................................................... 19Glutaraldehyde ............................................................................................................................. 20Formaldehyde/Formalin ............................................................................................................ 20

Onsite Formalin Recycling Case StudyFormalin Substitute for Tissue Fixation Case Study

Other Solvents ............................................................................................................................... 22Reduction of Slide Baths Case StudySubstitution of Low Grade Solvents with High Grade Solvents Case StudyOnsite Recycling of Xylene and Reagent Grade Alcohol Case StudyCentralized Recycling of Xylene, Xylene Substitutes, and Alcohol Case Study

NURSING, PATIENT CARE, PHARMACY, PHYSICIANS.....................................28Chemotherapy and Antineoplastic Wastes .............................................................................. 28Mercury Containing Equipment ................................................................................................ 28

Replace Mercury Sphygmomanometers withAneroid Sphygmomanometers Case Study

Non-mercury Thermometers, and Electronic/ChemicalPiezometric Devices Case Study

Waste Anesthetic Gases ............................................................................................................... 29Hemodialysis-Formaldehyde ..................................................................................................... 30Prescriptions .................................................................................................................................. 30

RADIATION THERAPY....................................................................................... 31

RADIOLOGY .................................................................................................. 31Recycling of Spent Photographic Fixer Solution Case Study

RESOURCE RECOVERY ..................................................................................... 33

TREATMENT AND PRETREATMENT ....................................................................... 34

HAZARDOUS WASTE STORAGE AND HANDLING ....................................................... 34

SECTION 2: EVALUATION OF WASTE MINIMIZATION AND WASTE MANAGEMENTOPTIONS - A Summary Listing of All of the

Waste Minimization Applications Listed in the Guide..................................37

SECTION 3: EVALUATION OF COSTS AND SAVINGS .......................................51

APPENDICESAPPENDIX A: SELF-AUDIT GUIDE - HAZARDOUS WASTE INVENTORY FOR

WASTE MINIMIZATION ASSESSMENTAPPENDIX B: ADDITIONAL SB14 REQUIREMENTSAPPENDIX C: TECHNOLOGY TRANSFER ADVISORIESAPPENDIX D: TIERED PERMITTING FACT SHEET 1772B -

CONDITIONAL EXEMPTION FOR SPECIFIED WASTE STREAMS

ADDITIONAL PUBLICATIONS - PUBLICATIONS LIST

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FURTHER INFORMATION

TABLESTable 1: How Do You Store Your Raw Materials and Hazardous Wastes ........................ 36Table 2: Waste Minimization Option Evaluation .................................................................. 39Table 3: Evaluation of Costs and Savings .............................................................................. 52

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INTRODUCTIONThis Guide was developed by the Office ofPollution Prevention and Technology Develop-ment to assist general medical and surgicalhospitals in evaluating their operations forwaste minimization opportunities. The Guidecontains three sections. Section 1 will help youevaluate your facility for waste minimizationopportunities. Section 2 is comprised of tableslisting the waste minimization options fromSection 1 and the following four areas forevaluation:* Waste Minimization Hierarchy (WMH)* Implementation Potential (IP)* Type of Option* Cost of Option

Each of these areas have different point valueswhich will be explained in Section 2. The totalscores of the options will allow you to prioritizethe options. Section 3 is an economicsworksheet to help you decide which options arecost-effective for implementation.

Waste minimization consists of source reductionand recycling, the first two elements of thepreferred waste management hierarchy. Thewaste management hierarchy consists of sourcereduction, recycling, treatment, and residualsdisposal. Addressing waste management usingthe hierarchy can help save money by reducingthe amount of hazardous wastes you have tomanage. Waste minimization can involvesimple and easily implemented strategies, orcomplex, state-of-the-art technologies. Theextent to which you implement a hazardouswaste minimization program depends uponyour hospital’s particular operations and proce-dures.

Waste minimization can help you achievecompliance with regulatory requirements byreducing the generated wastes. In some in-stances, it might even allow generators to avoidspecific regulatory requirements. Waste minimi-zation may also help reduce the fees assessed bypublicly owned treatment works (POTWs) byreducing your loads on their treatment systems.

HAZARDOUS WASTE SOURCEREDUCTION AND MANAGEMENT REVIEWACT OF 1989 (SB 14)SB 14 required generators who produced morethan 12,000 kilograms (13.2 tons) of hazardouswaste or more than 12 kilograms (26 pounds) ofextremely hazardous waste in 1990 to haveprepared two key documents by September 1,1991. This evaluation and document prepara-tion deadline repeats every four years (Septem-ber 1, 1995, 1999, 2003, etc.) The Source Reduc-tion Evaluation Review and Plan (Plan), identi-fies all major hazardous waste streams at thegenerator’s site and evaluates options forreducing or eliminating hazardous wastegeneration at the source. The Hazardous WasteManagement Performance Report (Report)assesses the effectiveness of hazardous wastemanagement previously implemented by thegenerator, including an assessment of recyclingand treatment activities.

The intent of SB 14 is to promote hazardouswaste source reduction by requiring a wastestream audit, and source reduction evaluation.SB 14 leaves selection of both technically andeconomically feasible source reduction mea-sures up to the generator. Whenever sourcereduction is not practical, the generator isencouraged to recycle hazardous waste andtreat any residuals prior to disposal in a mannerthat will pose the least impact on both publichealth and the environment and meet appli-cable treatment standards.

It was the decision of DTSC to compile a “Pollu-tion Prevention Guide for Hospitals”. Plansand Reports were called in from those hospitalsthat fell under SB 14. This was done in order todetermine their largest waste streams and to seewhat source reduction measures were beingsuccessfully implemented by hospitals. DTSC’smanifest database was used to find those hospi-tals that needed to prepare Plans and Reports.DTSC’s Manifest Unit receives manifests thatare sent by hazardous waste generators, haul-ers, and disposal facilities during hazardous

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waste transportation and disposal. Most hospi-tals are subject to SB 14 because of CaliforniaWaste Code 541, the photochemicals/photoprocessing waste generated from X-raydevelopment. Some of the facilities respondedthat they were not covered by SB 14. To sub-stantiate their claims, they submitted a Declara-

Plans and Reports were reviewed from the following hospitals and medical facilities.

Cedars-Sinai Medical Center/Los AngelesChildren’s Hospital of Los Angeles/Los AngelesCity of Hope National Medical Center/DuarteDesert Hospital/Palm SpringsEisenhower Medical Center/Rancho MirageKaiser Permanente/FresnoKaiser Permanente/HaywardKaiser Permanente/MartinezKaiser Permanente/OaklandKaiser Permanente/Redwood CityKaiser Permanente/Sacramento (Morse Avenue)Kaiser Permanente/Sacramento (Bruceville)Kaiser Permanente/San FranciscoKaiser Permanente/San RafaelKaiser Permanente/Santa ClaraKaiser Permanente/Santa RosaKaiser Permanente/South San FranciscoKaiser Permanente/VallejoKaiser Permanente/Walnut CreekKaiser Permanente Medical Group Regional Lab/North HollywoodKaiser Permanente Medical Group Regional Lab/BerkeleyLoma Linda University Medical Center/Loma LindaLos Angeles County King-Drew Medical Center/Los AngelesNaval Medical Center/San DiegoRancho Los Amigos Medical Center/DowneyScripps Clinic and Research Foundation/La JollaSt. Mary Medical Center/Long BeachUniversity of California Davis Medical Center/SacramentoHarbor UCLA Medical Center/Torrance

Data was collected from these facilities’ Plans and Reports on successful and unsuccessful sourcereduction, recycling, and treatment measures. The reported data was formatted into abstracts andare in Section One of the Manual. The abstracts only represent those measures reported by thehospitals. Most waste minimization options available for general medical and surgical hospitalsinvolve conversion to digital imaging, recycling of fixer and developer, and recycling or substitu-tion of solvents, mercury products, and batteries.

tion of Exclusion form to DTSC. Most facilitieswere unaware of SB 14. Still others had heardof SB 14 but had not prepared the requiredsource reduction documents. These facilitieswere brought into compliance and their docu-ments were reviewed.

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Hospitals generate small quantities of a widevariety of wastes. This contrasts with industrialgenerators who typically have a few largevolume waste streams. Wastes associated withthe development of X-rays represent the largesthazardous aqueous waste stream at mosthospitals. Hospitals also generate many solventwastes, and mercury, an extremely hazardouswaste.

Major sources of hazardous waste are:* solvents used in laboratories and mainte-

nance* formaldehyde used for preserving specimens

and cleaning dialysis equipment* photographic solutions used for developing

X-rays* radioactive wastes* mercury from blood pressure instruments,

thermometers, Cantor and Miller Abbotttubes, thermisters, and fluorescent fixtures

* disinfectants and sterilants* oxidizers and caustics used for cleaning* wastes from storage areas like surplus

inventory, obsoleteinventory, and leaks orspills

* batteries* oils from engineering equipment* chemotherapy wastes

In general, a waste is hazardous if it is toxic,corrosive, ignitable, or reactive. The criteria fordetermining these hazardous properties arecomplex. You can find the criteria in Title 22,California Code of Regulations (CCR), Section66262.10. As an example, silver is consideredhazardous if its soluble threshold limit concen-tration (STLC) exceeds 5 milligrams per liter(mg/l), or if its total threshold limit concentra-tion (TTLC) exceeds 500 milligrams per kilo-gram (mg/kg). There is an address in theAppendix if you want to request a copy of theCCR. It is the generator’s responsibility to usethese criteria to find out if their wastes arehazardous. If you are not sure if your wastesare hazardous or need help understanding thecriteria, call your local Department of Toxic

Substances Control (Department) regional office(telephone numbers are listed in the Appendix).Also, be sure to check your local government orpublicly owned treatment works (seweringagency) regulations. They may be more strin-gent in their requirements.

DEFINITION OF WASTE MINIMIZATIONWaste minimization consists of waste manage-ment approaches that reduce the amount ofhazardous waste generated or requiring dis-posal. Waste minimization includes sourcereduction and recycling.

Waste minimization can reduce the amount ofhazardous wastes generated in your hospital.This benefits you by minimizing:

* disposal costs* regulatory compliance costs (recordkeeping,

reporting, tracking, etc.)* costs of future liabilities* current operating costs (i.e., raw material

costs)* transportation costs* offsite treatment costs* worker safety costs* laboratory costs (for compliance with land

disposal restrictions)* fees and taxes* insurance costs* occupational exposures (indoor air quality,

direct contact)* storage space costs* labor costs

Additionally, waste minimization can increasehospital productivity, improve environmentalprotection, and enhance community relations.These benefits may be realized by your hospitalby implementing the following waste minimiza-tion methods:

Source reduction: is any action which causes anet reduction in the generation of hazardouswaste or any action taken before the hazardouswaste is generated that results in lessening ofthe properties which cause it to be classified as

SECTION 1: GENERAL WASTE MINIMIZATION INFORMATION

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hazardous. Examples include substituting inputmaterial or changing production processes toreduce the amount of waste generated. It doesnot include any actions taken after a hazardouswaste is generated, actions that merely concen-trate the constituents of the waste to reduce itsvolume or that dilute the waste to reduce itshazardous characteristics, actions that merelyshift hazardous wastes from one environmentalmedium to another environmental medium, ortreatment.

Recycling: is the use, reuse, or reclamation ofhazardous constituents. Examples includeemploying onsite or offsite techniques to re-move contaminants from a waste stream so thatthe regenerated material can be reused.

To be successful, your waste minimizationprogram must be organized. It is not hard toorganize waste minimization, but you will needto spend a little bit of time at first to get started.Keep in mind the following principles of wasteminimization:

PRINCIPLES OF WASTE MINIMIZATIONIdentify baseline waste generation rates, currenthazardous waste management strategies, andcurrent waste management costs.

Hospital owners and managers must be com-mitted to waste minimization for it to be suc-cessful and sustainable in the long run.

Waste minimization programs should include awritten policy with specific goals, objectives,and timelines.

Train employees in hazardous waste handlingand site specific waste minimization methods.

Be aware of and keep updated on the hazardousmaterials regulations.

ASSESSING WASTE MINIMIZATIONOPPORTUNITIESThis Guide will help you perform a wasteminimization assessment. The objective of thisassessment is to identify ways to reduce oreliminate waste through a careful review ofoperations and waste streams. After you selecta specific area(s) to focus your waste minimiza-

tion efforts, a number of options should bedeveloped and evaluated. Evaluate the techni-cal and economic feasibility of the selectedoptions. Finally, select the most promisingwaste minimization options for implementa-tion.

When performing your waste minimizationassessment, the answers to the following ques-tions can help guide your efforts:

Which wastes are classified as hazardous andwhich are not? What makes them hazardous?

How much of a particular input material enterseach waste stream monthly, quarterly, annually,and from what site?

How much of a raw material can be accountedfor through fugitive losses and unplannedemissions or discharges?

How efficient is the process in terms of productuse, labor use, and space use as it relates to theoutcome?

Are unnecessary wastes generated by mixingotherwise recyclable hazardous waste withother process wastes?

What types of housekeeping practices are usedto limit the quantity of wastes generated?

What types of process controls are used toimprove process efficiency?

MANAGEMENT PRACTICESEstablish a waste minimization program withstrong management commitment. Ensure aspecific person is assigned to oversee the suc-cess of the program. This is very important forthe long term success of the program. A teamwith enthusiastic players from each departmentof the hospital will also help. Have a set wasteminimization goal, i.e., a percent reduction forspecific wastes. Waste minimization programsare more successful if they contain all of theseelements.

In order to accurately assess your waste minimi-zation efforts, you must keep track of the chemi-

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cal products that you use. This is referred to asconducting an overall material balance. Up-date your material balances at least annually, orwhenever you change your operations or thechemicals you use. (See the EPA “Guides toPollution Prevention - Selected Hospital WasteStreams” for worksheets to help quantify thisdata.)

You can reduce the amount of waste generatedby spills if you train your employees to prop-erly handle and store hazardous materials andif you instruct them in optimal spill clean up,waste will be less. Some local environmentalhealth agencies sponsor employee trainingseminars. Some consulting firms offer em-ployee training as part of their package ofservices for hazardous waste management.Employees feel committed to waste minimiza-tion when they see their suggestions imple-mented to eliminate or reduce waste at thesource. Be sure new employees are trained.

Developing an employee recognition programfor pollution prevention ideas can greatlyincrease staff interest. In addition, if you doimplement a pollution prevention concept orfeel your hospital has done exceptionally well inimplementing pollution prevention, you mayqualify for awards or recognition by some localgovernment programs.

Compliance with local, state, and federal lawsand regulations related to hazardous materialstorage, treatment, disposal, and recycling isessential to a good waste minimization pro-gram. Try to have a process in place for learn-ing which current and proposed laws andregulations may impact your hospital.

Make sure hazardous waste generating depart-ments are billed for all management, compli-ance, and disposal costs incurred by theiractivities.

Hazardous waste management costs coveredunder a general expense fund will not givespecific departments any incentive to minimizetheir wastes. Software is available that willtrack inventory so that you will know everyday,

how much waste was generated, what it cost,and whether it was appropriately handled byeach department in the hospital.

MATERIAL SAFETY DATA SHEETS(MSDSs)The Occupational Safety and Health Adminis-tration (OSHA) requires MSDSs for all hazard-ous materials. These sheets containmanufacturer’s information regarding chemical,physical, and toxicological properties of thesubstance, proper handling and storage proce-dures, and safety and emergency responseprocedures.

Consider keeping your MSDSs on a computer-based file. They can be kept up-to-date easilyand organized by use rate, toxicity, amount onhand, or whatever system best serves yourneeds. MSDSs are useful in pollution preven-tion because they let us know the hazardousconstituents of a product. With this informa-tion, hospitals can decide whether to switch tosomething less toxic, if necessary. Employeesare required to have access to MSDSs. Reviewyour MSDS library at least annually to assurethat you have one for every product that youuse, and that the MSDSs you have are the mostcurrent editions.

MATERIALS INVENTORY AND STORAGEMaterial inventories are the supplies or materi-als that are kept on hand for future use. If thesesupplies are allowed to become too old to use,they may necessitate costly hazardous wastedisposal. Obsolete stock can be minimized byproper planning, inventory control, and central-izing purchasing and dispensing.

Consider implementing the concept of having asingle point of authorization through whichhazardous materials may be requested andreceived. In addition, start an automatedtracking system that begins when a hazardousmaterial is first ordered and continues throughreceipt, issue, use, and disposition of unusedquantities. Additional information aboutsetting up such a system used by the UnitedStates Air Force, the Hazardous Material Phar-macy concept, can be obtained at http://es.inel.gov/ or by calling (800) 233-4356.

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Inventory control is best achieved with theinstallation of a computerized inventory sys-tem. By using such a system, inventory can bechecked more frequently to determine what isactually used. If more than one departmentorders the same material, make sure that order-ing and use is effectively managed. Individualdepartments ordering “outside the system” willnot allow you to control your inventory. Per-sonal computers will allow you to computerizeyour inventory and are relatively inexpensive.Contact your supplier or group purchasingorganization about getting specific software tooptimize tracking. Inventory control is espe-cially necessary for cleaning and surface prepa-ration chemicals (acids, alkalies, solvents), anddrugs and chemicals.

Employees should be trained to use the mini-mum amount of chemical necessary to performa job adequately. Provide engineering con-trolled dispensing units where applicable.

When appropriate, use the “JIT” or “Just inTime” system for ordering materials. By wait-ing to order materials until they have almostrun out, materials are not overstocked and donot become obsolete. Obsolete materials mayhave to be disposed of as hazardous waste.

Inspect raw materials before you accept them.Unacceptable or damaged materials and prod-ucts may become hazardous waste. Containersthat are damaged, have loose-fitting lids, un-sealed drum bung holes, and leaky valves maybe an indicator of damaged goods inside.

The individual responsible for inventory shouldlabel and date new material containers as theyare received. By labeling all materials clearlywith their expiration dates, you can rotate yourstock so that the earliest labeled stock is usedfirst. This is often referred to as a “first-in, first-out” (FIFO) policy. If the shelf life is not indi-cated on the label, contact the supplier. Also, besure an MSDS is available that explains theproper and safe use of each chemical.

Materials having an expired shelf-life shouldbe tested for effectiveness before being dis-carded. The material may still be usable. Mate-

rial that no longer has a useful shelf-life isconsidered a hazardous waste and must beproperly disposed.

Conducting quarterly inventories of materialsin storage will allow you to identify materialsthat are near the end of their shelf-life, and alsocheck for containers which may leak in thefuture. Assign an individual to be responsiblefor specific areas and schedule a full-scaleinventory of your raw materials at least once ayear.

Storing materials in reusable containers, al-though hard to come by, will allow you toreturn the empty container to the supplier andreduce the amount of waste you must dispose.Ensure single-trip containers and nonreusablecontainers are handled according to the regula-tions.

Storing hazardous and nonhazardous materi-als separately will reduce the risk of a hazard-ous waste being generated due to a hazardousmaterial leaking and contaminating a nonhaz-ardous material, thereby increasing disposaland clean-up costs. Maintain distance betweendifferent types of materials/chemicals (i.e.,flammables vs. oxidizers, strong acids vs. bases)to prevent cross-contamination and reactions incase of spills or leaks.

Heavy traffic through the raw material storagearea increases the potential for contaminatingraw materials with dirt or dust and for causingspilled materials to become dispersed through-out the facility.

Dust from solid stored materials may contami-nate other stored materials which will then haveto be disposed of as hazardous waste. Use adust recovery system if this is a problem in thestorage areas.

Limiting access to raw materials to designatedpersonnel and centralizing inventory controland delivery will help you reduce the amountof raw materials wasted. You may want toconsider a stockroom attendant and sign-outsheet to help control inventory. Never allowmore than one person in each department to

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order supplies independently of each other as itmay cause excess purchases. Consider install-ing vending machines that require patient and/or employee codes to secure supplies.

Minimizing the amount of stock on handmakes it easier to track your usage of materialsand keep your supplies from becoming too oldto be used. Instead of just reordering the usualquantities or random amounts, try to moreaccurately order supplies depending on realusage. With smaller containers, there may beless chemical deterioration and smaller volumesof expired materials generated. A substantialportion of laboratory waste is actually surplusreagent and chemicals.

Try to buy chemicals only from manufacturerswho will accept their return if their shelf-life isexceeded. If this is currently not available, tryto negotiate this feature into future procurementcontracts. Returning obsolete raw materialscan prevent you from having to dispose of themas wastes.

Maintain and enforce a policy of using rawmaterials only for their intended uses. Youmay generate unnecessary hazardous waste ifyou use supplies for purposes other than theirintended uses. For example, do not use equip-ment cleaning solvents to clean your floors.

Do not stack containers higher than recom-mended by the manufacturers, or in such amanner where they can tip over, tear, puncture,or break. Also, do not stack equipment againstmaterial containers to avoid damaging thecontainers.

Keep materials and/or wastes in proper storageareas. Many photoprocessing and plate devel-oping chemicals are sensitive to temperatureand light and should be kept in proper storageareas. Proper storage areas can also help youreduce wastes generated due to spills, cross-contamination, or leaks. Storage areas shouldinclude adequate lighting, insulated electricalcircuitry (checked frequently for corrosions toprevent potential sparking), and aisles clear ofobstructions. Space is often a constrainedresource in healthcare facilities. If properstorage space is not available, find out why.

Put in place inventory or other controls toassure that chemicals in a container are com-pletely used prior to opening a new container.Complete use of material in opened containerscan reduce the amount of wasted raw materialsthat adds to the total volume of waste.

Provide secondary containment for appropriatesupplies/wastes. All microbiology stainingsupplies should be stored in secondary contain-ment. All formaldehyde solutions and speci-mens stored in free solutions should be storedproperly in secondary containment, on securedshelving, and away from sinks. The secondarycontainment vessel or area (e.g. tray, cannister,or bermed area) should be impervious to theliquid being contained and large enough to holdat least 110 percent of the capacity of the pri-mary container. Secondary containment mustnot drain to any sewer.

Labs should have standards for minimumvolumes necessary for adequate preservationand fixing. Plastic bags can reduce the amountof chemical left in storage with the specimens.Both plastic bag and plastic container useeliminate breakable storage. Bags should bestored in rigid secondary containment. Formal-dehyde prepared specimen bottles should bepurchased in the smallest size that will do thejob. Doing so will minimize the amount offormaldehyde used and the waste generated.

DRUMS AND CONTAINERSStoring drums on pallets will raise them off ofthe concrete floor which will prevent corrosionof the drums through “sweating” of the con-crete. Secondary containment pallets should beused for chemical storage.

Empty containers should be returned to thesuppliers. Proper management and handling ofempty containers previously containing haz-ardous materials can reduce the volume ofhazardous waste generated.

Providing adequate space between rows ofdrums will allow for visual inspection of eachcontainer for corrosion and/or leaks.

There are two predominant patterns of drumlocation if drum storage is utilized. When

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inventory control is necessary to minimizeproduct usage, drums should be stored to-gether. The storage area should have limitedaccessibility, and should be equipped withindoor or outdoor sheds, storage lockers forflammables, or locking storage rooms.

The second pattern assumes that employees canbe trained to take individual responsibility forregulating product use. In this case, inventorycontrol would not be a problem, and it may bemore effective to separate drums and placethem at points of highest use. This alternativereduces the chance of product leaks and spillsduring transport from storage to work areas.

An “empty” container is one from which all thematerial possible has been emptied from thecontainer. If the container held a material whichcould be readily poured (i.e., cooling towertreatment chemicals, X-ray chemicals, or clean-ing and disinfection products), all material mustbe removed by any practicable means (includ-ing pumping, aspirating, and draining) by thegenerator before the container can be consid-ered empty. If the container held nonpourablematerials, no material shall remain in the con-tainer that can feasibly be removed by physicalmethods including scraping and chipping. Thisstandard applies to materials that pour slowlyor do not pour at all from the container likeviscous materials, solids that have “caked up”inside the container, and nonpourable sludges.Containers that held acute or extremely hazard-ous waste are considered empty if the containerhas been triple rinsed using a solvent capable ofremoving the material or cleaned by anothermethod that is proven to achieve equivalentremoval to triple rinsing.

Empty containers of five gallons or less incapacity can be managed by one of the follow-ing methods: 1) by disposing the container atan appropriate solid waste facility, 2) by re-claiming the container’s scrap value onsite or bysending the container to a person who reclaimsthe container’s scrap value; or 3) by recondi-tioning or remanufacturing the container onsite,or by shipping the container to a person whoreconditions or remanufactures the container.

Containers larger than five gallons in capacityshall be marked with the date they have beenemptied and shall be managed within one yearof being emptied by one of the following meth-ods: 1) by reclaiming the container’s scrapvalue onsite or by sending the container to aperson who reclaims the container’s scrapvalue; or 2) by reconditioning orremanufacturing the container onsite, or byshipping the container to a person who recondi-tions or remanufactures the container.

SPILL CONTROLSpills are inadvertent discharges that occur atvarious places in a facility. Spills include acci-dental tipping over of containers, and droppingand breaking of containers as well as spillswhich occur mainly because of splashing dur-ing manual transfer, overfilling, and leaks inprocess equipment and piping. Encourage thereporting of all spills. Educate employees onwhat hazardous wastes are so that spills can bereported. In the past, many employees did notrealize mercury was an extremely hazardouswaste and would rinse the mercury from bro-ken thermometers down the sink. Althoughyou may only have a few small spills, spillcontrol can help you reduce wastes generatedby unnecessary cleanups.

Lift drums by means of powered equipment orhand trucks. Under no circumstances shoulddrums be tipped or rolled, even when empty.Negligent handling may damage the seams,resulting in future leaks or ruptures.

Scoop spills up to the fullest extent possible.The spilled materials can then be reworked intoproduct. Spills that cannot be retrieved shouldbe cleaned up with commercially availableabsorbents and disposed of in accordance withall local, state, and federal regulations. Use asqueegee for recovery of liquid spills.

Regulations require spill containment aroundwaste and material storage areas to minimizethe spread of any spilled material. Providingspill containment like curbs, dikes, or bermsaround process storage tanks and waste storageareas can minimize the amount of cleanup

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materials needed to contain and clean up spills.Spilled hazardous materials become hazardouswaste and must be managed as such.

Periodic drills can improve the readiness andeffectiveness of employees in dealing withemergency situations. Be sure employeesknow where emergency phone numbers andclean-up kits are located. Remember, trainingyour employees is also a legal requirement.

Some spills will occur. Keep a record of largerspills (when and why they occur). Use thisinformation to identify the spill preventionoptions that might help your hospital. Many ofthese options are listed throughout the check-list. Remember, minimizing spills helps toreduce the amount of cleaning material you use,and reduces the amount of hazardous spentabsorbent and used floorwash you generate.

Prevent leaks via proper equipment mainte-nance. Increased training and closer supervi-sion can prevent overfilling and spills duringmanual transfer.

Hazardous materials and wastes should bepumped from drums to smaller containersusing spigots, pumps, piping, or funnels. Neverpour them directly from drums to smallercontainers. The potential for spills and leaks ishighest at the point of product transfer frombulk drum storage to process equipment.

Periodic inspections of tanks will detect corro-sion or deterioration before a spill occurs. Forlarge stationary tanks, hire a person qualified tomake these inspections, if necessary.

Maintaining clear and even surfaces in storageareas used by personnel when moving materialsor equipment will help decrease the incidenceof spills due to accidents.

Glassware and other containers should bestored on textured rubber mats to limit break-age when they fall. Order chemicals in plasticcoated bottles whenever possible. Use plastic orinsulated holders for solvent bottles. Neverstore chemicals above sinks on shelves or incabinets. Store in approved chemical cabinetsor on low shelves. Always latch doors onchemical storage cabinets. Install secondarycontainment trays when there is a sink in thearea to ensure spilled chemicals do not go downthe drain. Secondary containment is best for allstorage to contain leaks and spills, especially asan earthquake measure. Secure chemicalsstored on shelves or in cabinets behind barriersif secondary containment is not feasible. Barri-ers should be at least 1/5 the height of thetallest container. Segregate incompatible chemi-cals to prevent mixing in case of an accidentalspill. This can be accomplished by using sepa-rate storage cabinets and closets or physicalbarriers such as independent secondary con-tainment, berming, or trenching.

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FACILITIESAEROSOL CONTAINERSUse and StorageAerosol containers are present in the facilitymaintenance areas in health care organizations.Empty aerosol containers which did not previ-ously hold acute or extremely hazardous wasteare exempt from regulation. However, full orpartially full aerosol containers with expiredshelf-life must be disposed as hazardous waste.Aerosol containers which are not emptied to themaximum extent practical (due to a cloggednozzle, for example) will not qualify for exemp-tion and should be managed as hazardouswaste.

Discourage the use of aerosols. If aerosolpurchases seem to be large in quantity, investi-gate and identify which activities use the most.Focus your waste reduction efforts on the highvolume uses. Request products from the manu-facturer in recycleable non-aerosol pump spray-ers, pressurized or nonpressurized. Orderproducts according to demand and dispenseaerosol containers when an empty container isreturned. This process should be controlledthrough one person in one location to preventunnecessary usage.

To increase the shelf-life of aerosol containers,keep them away from moisture, sunlight, andextreme heat and cold. It is also important tokeep protective caps on the containers when notin use. This helps prevent contamination,rusting of the container top, and nozzle dam-age.

RecyclingFacilities are available that recycle aerosolcontainers. If they do not offer pick-up services,see what options are available to send youraerosol containers to them. If you generateenough aerosol container waste, investigate thepurchase of an onsite recycling unit. In thefuture, the Department may be certifyingrecycling units that allow the user to be ex-empted from the standardized permittingprocess.

BATTERIESAlkaline manganese batteries are hazardousbecause of the zinc present, but they are nowavailable in rechargeable form (1.5 volts, AA,AAA,C,D). Eight batteries can be recharged at atime. Manufacturers are working to increasethe size of the battery rechargers. These batter-ies can replace nickel-cadmium or silver-cad-mium batteries. Some uses for these batteriesare in cameras, pagers, and flashlights. Re-chargeable alkaline manganese (RAM) batteriescan be used as a replacement if you require along shelf life, frequent use, or don’t need morethan 400 milliamps of current.

Nickel-cadmium batteries are hazardousbecause of the nickel and cadmium present.Nickel-cadmium batteries are found in alarmsystems, backup power sources in medicalmonitors, and equipment. These batteries areoften rechargeable, but need eventual disposal.Silver cadmium batteries are in medical elec-tronics. These batteries contain silver andcadmium and must be disposed of as hazardouswaste.

Mercuric oxide batteries are hazardous becauseof the mercury present. These batteries aretypically used in hearing aids, smoke detectors,oxygen monitors, fetal monitors, and portableEKG monitors. They must be disposed of ashazardous waste.

Lithium batteries are hazardous and must bedisposed of as a hazardous waste. Lithiumbatteries can be recycled. This is cheaper thanhaving them manifested and disposed of ashazardous waste. Lithium batteries are foundin glocometers, cameras, and other devices.

Zinc-air batteries are hazardous because of thezinc present but they may be used to replacemercuric oxide batteries which are more hazard-ous. Mercuric oxide batteries contain zinc andmercury. These batteries are typically found inhearing aids and electronic pagers.

Careful consideration is necessary when evalu-ating the use of rechargeable batteries in health

HAZARDOUS WASTE MINIMIZATION—APPLICATIONS

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care settings. They are not appropriate in allsituations, especially those involving life savingequipment where a partially recharged batterycould result in equipment failure and death.

Collection and storageConvenient collection points will ensure thatbatteries are not inadvertently discarded in thebiohazard, solid, and other recyclable wastestreams. Lead acid automotive batteries used indiesel generators and helicopters need to beproperly stored, preferably In secondary con-tainment until sent out for recycling. Theyshould not be left outside, especially near adrain.

CONSTRUCTIONCarpet, flooring, counter top materialsBefore installing carpet, consider the treatmentarea, e.g., no carpeting in chemotherapy areas.If solvents are to be used, like in a lab, keep inmind that many flooring and counter topmaterials are not resistant to solvents. Give alist to the contractor of those chemicals to whichthe surfaces will be exposed. Remember thatonce these surfaces are contaminated, they mustbe removed and handled as hazardous waste.

Halon fire extinguishersThere is a ban on the manufacture and importa-tion of halon fire extinguishers, but not on theiruse. Substitutes are available. If your hospitalis equipped with halon extinguishers, develop areplacement plan to eliminate these devicesfrom your facility. For additional informationon halons and their substitutes, contact theUnited States Environmental Protection Agency,Office of Air and Radiation, StratosphericProtection Division, Mail Code 6205J, 401 MStreet, SW, Washington, D.C. 20469 or call theOzone Protection Hotline Toll-free (800) 296-1996 or at (202) 775-6677.

Sprinkler SystemsNew construction may require additionalsprinkler systems, especially in hazardouswaste storage. Some local fire departmentsrequire that new construction have a sprinklersystem that can hold twenty minutes of sprin-kler water plus 110 % of the chemical containedthere.

HOT WATER SYSTEMSHospitals often add extra disinfectant processesto their hot water systems. Common alterna-tives include elevated temperatures, additionalchlorine, or a copper silver electrolysis system.When using elevated temperatures, control thetemperature by only having intermittent hightemperatures rather than than keeping it con-tinuously elevated. Constant elevated tempera-tures will lead to more corrosion. If usingchlorine, be sure chlorine addition is optimizedto provide adequate controls while avoidingoverdosing. Electrolysis systems, which addcopper and silver to the waste water, may leadto an increased amount of these metals withinthe system. Other corrosion controls can in-clude reduced or protective magnesium anodes,alternate piping materials, slower recirculatingrates, pH adjustment, and chemical controlssuch as adding sodium bicarbonate.

HOUSEKEEPINGZincCheck the labels on products to verify whatchemicals they contain. Floor waxes, waxstrippers, stainless steel cleaners, brass polish,and lubricants often contain zinc and should beeliminated.

Tributyl TinTributyl tin, found in mildew controlling carpetshampoos, toilet cleaners, and germicidalsurface cleaners should also be avoided. It willbe listed as tributyl tin chloride, tributyl tinneodiconate, bis tributyltin oxide, tributyle tinbenzoate, etc.

Phenolic CompoundsIf phenolics are used, the minimum requiredconcentration should be mixed. Quaternaryamine substitutes may be suitable and are lesslikely to cause discharge problems. However,both types should be handled as hazardousmaterials. Working strength and used solutionsmay or may not be hazardous waste. Usepremeasured doses, pumps, and auto-feedsystems to minimize the use of these products.Phenolics should not be used in areas whereinfants and toddlers reside.

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LAUNDRYHazardous WasteEducate staff to recognize and separate outhazardous materials before doing the laundry.Mercury thermometers, mercury blood pressuredevices, and Miller Abbott tubes are hazardouswastes. Rags used to clean up hazardous spillsare also hazardous waste and need to be prop-erly disposed of.

Laundry ChemicalsOptimizing the use of laundry chemicals andminimizing accidental spills is achievedthrough worker training, prepackaged laundrychemicals, or the use of an automated laundrychemical feed system. While laundries mightincur initial capital costs to install an automatedsystem, the savings from optimal chemicalusage and reduction in labor costs may havelong term benefits. Receive laundry chemicalsin totes (bulk dispensers) rather than the usual 5gallon containers.

Tunnel WashersTunnel washers significantly reduce waterusage because they use the rinse water from thefinal rinse for the initial wash.

LIGHTINGReplacements and RecyclingReplace mercury vapor street lamps, fluores-cent, high intensity, and ultraviolet lights withordinary glow lights, low sodium vapor tubes(yellow), opticals, high-energy, and long-lastinglights and recycle when possible. This cangreatly reduce the amount of mercury waste.Although no effective substitute exists for highenergy fluorescent tubes, recycling systems arein place. U.S. EPA’s Green Lights Program is agood source of information about alternativeapplications in this area. The U. S. EPA Office ofAir and Radiation operates the Federal GreenLights Program. If you are using fluorescentlights, this program can help you. Many healthcare organizations have reduced costs signifi-cantly by using a combination of T-8 lamps withelectronic ballasts, compact fluorescent, andother proven lighting technologies. The internalrate of return for hospitals from lighting up-grades can be as much as 50 percent and sav-ings of up to $100,000 are typical for a 400,000square foot hospital. To participate in the Green

Lights Program, contact Manager, U. S. EPA(6202J), Washington, D.C., 20460, Fax (202) 775-6650, Phone (202) 775-6650. If you are a smallmedical building and do not have enoughfluorescent tubes to warrant pickup, perhapsyou can combine with other facilities or largeinstitutions, and establish a milkrun to deliver alarge quantity for recycling.

OFFICESLaser Jet CartridgesLaser jet cartridges can be recharged and pur-chased back for one third less of the originalcosts.

PAINTSWater-Based PaintReplacing oil-based paints with water-basedpaints in facility maintenance operations willeliminate the use of solvents and thinners ascleaners. Water-based paints must still behandled as hazardous waste. Using paintswithout metal pigments or paints with highsolid, low volatile organic compounds will alsohelp reduce hazardous waste. Include theserequirements when developing service contractbids.

Proper HandlingPaint residues or wash waters from cleaningequipment should not be washed into streetgutters or storm drains. Solvents and thinnersused with oil-based paints should be filteredand reused. Allow the solids in the solventsand thinners to settle and decant the liquidcleaning solution. Off-specification paint can beused as utility paint. Extra paints, solvents, andpaint residue that cannot be reused or recycledmust be managed as hazardous waste. Pur-chase paint only in needed quantities, do notmix more paint than is needed for a job, andstandardize paint colors used in the facility.Chemical paint-stripping waste is alwayshazardous.

Over-SprayOver-spray is the paint that does not reach thepart. Over-spray creates waste and increasesraw materials cost. To reduce over-spray, usespray system equipment with high transferefficiency. High volume, low pressure (HVLP)

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guns provide the highest transfer efficiency.Electrostatic spray guns also improve transferefficiency. Maintain proper pressure as identi-fied in the operator’s manual for specific gunsystems. Higher pressures contribute tooverspray. Replace damaged nozzles. Keep thespray gun perpendicular to the surface andmaintain a fifty percent overlap of spray pat-tern. Maintain a gun distance of six to eightinches from workpiece. Trigger the spray gunat the beginning and end of each stroke. Useheaters to reduce paint viscosity instead ofadding thinners.

PAINT GUN WASHER AND RECYCLERPaint guns are often washed manually withpaint thinner. A paint gun washer and recyclercan reduce the amount of thinner waste asshown in the following case study.

PARTS WASHINGAlternativesThere are petroleum distillates available that arenonhazardous (non-ignitable) because theproduct has been formulated so that the flashpoint is 140 degress Farenheit or greater. Hotsoap cleaners are very effective for parts wash-ing. Oil skimmers can recover oil before wateris discharged to the POTW. However, consultwith wastewater authorities to determine if anylocal limits restrict hot soap wastewater dis-charges. Evaluate whether all maintenancefunctions that require cleaning are compatiblewith ketone, ester, or aqueous-based cleaningtechnologies. (For additional information onhow to go about selecting aqueous cleaners,order a copy of publications 608 and 609 in the“Publications List” in the Appendices.)

Paint Gun Washer And Recycler Case Study

Company Name: Los Angeles County-King/Drew Medical CenterSIC Code: 8062/General Medical and Surgical HospitalsBusiness Activity: Provides personal health services to the Los Angeles County population.Waste Stream/CWC: Paint Waste/CWC 214Quantity of Waste (yr-lbs): 1994-1750 lbsProcess Generating the Waste: The paint gun in the paint shop was washed manually with thinner.Estimated Source Reduction (lbs/%): 500 lbs/28%Source Reduction Approach/Measure: Production Process ChangeBrief Description of Measure: Replace the manual method with a paint gun washer and recycler that

uses compressed air. The washer re-uses the thinner for washes, reducing the generation of thinnerwaste.

Implementation Date: A Herkules Paint Gun Washer and Recycler was installed in the paint shop in mid-1994.

Economic OverviewCapital Cost: $975Cost of Operation and Maintenance: $100/yearCost of Thinner Used: $312/yearCost of Disposal of Thinner Waste: $175/yearDischarge Impacts to Air, Water, and Land: In the manual method, thinner vapor emits into the surround-

ing work space. In contrast, the washer is covered while in operation, and the emission of thinner vaporis minimized. Practically all the used thinner is captured as liquid waste. This reduces the risk ofemployee exposure to harmful thinner vapor.

Comments: The washer cleans the paint gun very well consistently and is a technically feasible andeconomically practicable source reduction measure.

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Solvent Parts Washer StationsDo not locate solvent parts washer stations nearexhaust fans and door drafts. Pumps that arecontinuously running volatilize product into theair. Make sure parts washers are off when notin use. If the parts washers have lids, keep thelids closed when the washer is not in use.Efficient operating procedures for parts wash-ing in maintenance areas can help eliminatesome solvent wastes. For example, do not havemore parts washer stations than necessary. Donot allow unnecessary “pick-ups”. By havingmore frequent pick-ups, you may increase yourgeneration rate - the amount of hazardouswaste generated in any one calendar month.This could unnecessarily change your statusfrom small quantity generator to large quantitygenerator and increase your permitting fees andrelated requirements.

PESTICIDESPesticides in general are not hazardous wasteunless they are improperly stored or disposedof. If not used safely or appropriately, they canbecome an unnecessary hazard. The key ele-ment to ensuring good pesticide management ishaving one person in charge of all pesticides. Inaddition, a log should be kept of where andwhen pesticides are used. Even if a contractor isproviding services, a log should be required totrack the pesticides. Reduce pesticide invento-ries toward a goal of just-in-time and prepareand use only the required quantities. Segregatedry products from liquid products to preventmixing of products if spilled. Use non-chemicalpest control methods. Ensure that areas wherechildren reside and receive care have minimaland least toxic applications. Consider usingcontract services for insect control, rodentcontrol, and lawn maintenance. Specify in yourbid for services the need to use less toxic pesti-cides and require the contractor provide allpesticide products and remove all containersfrom the site. Source reduction and propermanagement of these wastes may be moreefficiently managed by a contractor. Contactyour local county agricultural commissioner,the University of California Extension office, orthe Department of Pesticide Regulation forfurther information. Additional publicationsare also listed in the Appendices.

LABORATORIESHospitals often have several types of labs. Theymay include research and teaching labs, mini-labs in outpatient care offices, chemistry, hema-tology, pathology, microbiology,immunodiagnosis, and gross pathology andnecropsy labs. There are numerous laboratoryoperations in hospitals and medical facilitiesthat are sources of hazardous wastes. So manylab waste solutions contain significant concen-trations of metals and other chemicals that itwould be practically impossible to list all of thehazardous wastes of concern.

Solvents are the predominant waste of labs.Solvents are used for fixation and preservationof specimens in histology and pathology, andfor extractions in laboratories. Halogenatedsolvents are generally more toxic and persistentthan nonhalogenated solvents. Halogenatedcompounds used in hospitals include methyl-ene chloride, chloroform, tetrachloroethylene,chlorobenzene, trichloroethylene, 1,1,1trichloroethane, and refrigerants.Nonhalogenated compounds include xylene,acetone, toluene, methanol, ethyl ether, methylethyl ketone, and pyridine.

Routine procedures for managing solventwastes at some hospitals currently includedischarge to the sewer and lab-pack disposal inlandfills. These are no longer advisable and insome situations may be illegal.

INVENTORYOnce a lab has completed its use of a chemical,it can be returned to supply. When another labrequests the chemical, supply should give themthe unused portion first. By sharing chemicalsbetween laboratories, it may reduce the amountof chemicals purchased as well as disposalcosts.

PLUMBINGSewer Lines, Traps, and SumpsMercury is often present in sewer lines, drains,traps, and sumps as it may have been discardedin this manner over the years. Caution shouldbe taken to avoid spilling the contents in casemercury is present. Non-water contents mustbe handled as hazardous waste unless provenotherwise.

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CLEANINGReplace alcohol-based disinfectants with sonicor steam cleaning. Substitute specialty deter-gents for chromic acid and sulfuric acid forcleaning laboratory glassware. Use biodegrad-able detergents and/or aqueous reagents as acleaning substitute where possible. In somecases, as with highly infectious agents, powerfulcleansers are still essential.

Conduct the initial cleaning with used solventand use fresh solvent only for the final cleaning.This is known as countercurrent cleaning anddecreases the amount of reagent solvent used.

A wide variety of solvents means there will be awide variety of waste streams to manage.Investigate the possibility of using one type ofsolvent for equipment cleaning. By switchingto one type of solvent, it may be cost effective tohave onsite distillation.

Before labware is placed in the autoclave forcleaning and sterilization, the chemicals in thelabware need to be drained out and collected inproper disposal receptacles. This can signifi-cantly reduce the amount of contaminatedwastewater entering the POTW system asshown in the following case study.

Autoclave Labware Washing Process/Laboratory Clarifier Case Study

Company Name: Childrens Hospital Los AngelesSIC Code: 8060/Acute Care Hospital (Pediatric)Business Activity: Licensed acute care pediatric hospital with school of physical therapy, medical technol-

ogy, and x-ray technology (USC affliation).Waste Stream/CWC: Lab Chemicals/CWC 551 and oil/water separations/CWC 222.Quantity of Waste (yr-lbs): 1995 - 46,451 lbsProcess Generating the Waste: Autoclave labware washing process/laboratory clarifierSource Reduction Approach/Measure: Production Process ChangeBrief Description of Measure: Prior to changing the labware cleaning process all excess waste in the

labware was put through the cleaning systems with disregard to chemicals ending up in the clarifiers,which would result in the pumping, cleaning, and bleaching of the clarifier system. This processchange is twofold:

1. Analysis and evaluation to assess how oils, lab chemicals, and solvents enter the industrial wastewaterclarifier.

A. Analysis showed chemical residues from the labware cleaning process entered the wastewatersystem. Monthly clarifier pumping and cleaning with hot water and bleach was used to reducehydrocarbon build-up prior to the implementation of this process change (in1994-95) resulting in awaste stream that needed to be kept from entering the local POTW outlet (sewer).

B. A training program was initiated to ensure chemical wastes and residues were collected inproper disposal receptacles and then labware was placed in autoclave for cleaning and sterilization.

2. In mid-year 1995, hydrocarbon-reducing enzymes were introduced into the clarifier system to reducehydrocarbon effluents and to alleviate the need for pumping and cleaning the clarifiers monthly.

Implementation Date: 1995-96 Fiscal Year

Economic OverviewCapital Cost: No capital outlays were needed.Maintenance/Recurring Costs: Reduction of pumping costs of $1950.00 per month. The enzyme product

(Neozyme’s EcoSystem Plus) costs $205.00 per quarter ($820.00/yr.)Return on Investment: Savings of $1881.67/month.Discharge Impacts to Air, Water, and Land: Reduction of 46,541 pounds per year of contaminated waste-

water entering the POTW System. Reduction of hydrocarbon VOC contaminants to the air.Barriers/Obstacles: Education and training in pre-wash procedures encountered.Comments: Childrens Hospital is also using this enzyme product in the laundry clarifier to reduce any

effluents and build-ups occurring in this waste stream also.

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MERCURYTungsten can be substituted for mercury whenGI tubes are weighted with a heavy metal for x-ray analysis in the pathology lab.

Alcohol (red) and digital thermometers areavailable as substitutes for mercury thermom-eters for equipment such as lab ovens and waterbaths.

CELL SORTING AND COUNTING INSTRUMENTSManufacturers are currently working on sys-tems that replace the cyanide in cell sorting andcounting instruments with sodium laurelsulfate. Staff should discuss these issues withvendors and be aware of less toxic reagent

systems for this and other equipment as theybecome available.

AUTOMATED SYSTEMS OR OTHERINSTRUMENTATION FOR LAB CHEMISTRYANALYSESEvaluate all lab chemistry analyses as towhether they can be run on automated systemsor other instrumentation. Advantages of suchsystems over “test tube scale” procedures arethat they use very small volumes of samplesand reagents and increase productivity. Anautomatic slide stainer can reduce the genera-tion of alcohol waste and save labor costs asshown in the following case study.

Automatic Slide Stainer Case Study

Company Name: Los Angeles County-King/Drew Medical CenterSIC Code: 8062/General Medical and Surgical HospitalsBusiness Activity: Provides personal health services to the Los Angeles County population.Waste Stream/CWC: Laboratory Waste - Alcohols/CWC 212/214Quantity of Waste (yr-lbs): 1994-4660 lbsProcess Generating the Waste: Slides with blood smear were dipped into stains by hand.Estimated Source Reduction (lbs/%): 366 lbs/7%Source Reduction Approach/Measure: Production Process ChangeBrief Description of Measure: Install an automatic slide stainer in the Hematology Laboratory. The

automatic slide stainer sprays the slides with the stains, minimizing the generation of alcohol waste.The manual process takes 12 to 15 minutes and the machine takes less than 10 minutes.

Implementation Date: A Wescor Aerospray Hematology Slide Stainer was installed in January 1995.

Economic OverviewCapital Cost: $6000Maintenance/Recurring Costs: $600/yearReturn on InvestmentSavings in Chemicals: $930/yearSavings in Waste Disposal: $50/yearSavings in Labor Cost: $9125/yearThe use of the automatic slide stainer is estimated to save a minimum of 1 person-hour per day. Since the

Hematology Laboratory operates 365 days/year, it is estimated to save at least 365 person-hours/year.The labor cost for a person-hour of a technician is estimated at $25.

Discharge Impacts to Air, Water, and Land: The automatic slide stainer reduces the emission of methanolvapor into the air and the amount of alcohol waste generated because it is covered while the staining isin operation. This also reduces the risk of employees being exposed to methanol vapor. In contrast,the containers of the staining agents are open in the manual process.

Barriers/Obstacles: The machine can replace the manual staining process for most slides with theexception of bone marrow slides, which require a longer period of time. The bone marrow slides needto be done manually.

Comments: The slides prepared from the automatic slide stainer are comparable to the manual methodand its use is a technically feasible and economically practicable source reduction measure.

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MICROANALYTICAL TECHNIQUESEvaluate whether experiments can be accom-plished using microanalytical techniques. Thiscan reduce the raw materials used and hazard-ous waste disposal costs as shown in the follow-ing case study.

Microanalytical Techniques Case Study

Company Name: City of Hope National MedicalCenter - Duarte

SIC Code: 8062Business Activity: Cancer Hospital and Medical

ResearchWaste Stream/CWC: Dichloromethanol/methanol/

CWC 214Quantity of Waste (yr-gal): 1993 - 20 gallons per

monthProcess Generating the Waste: Lab experiments

measuring DNA DamageEstimated Source Reduction (gal/%): 15 gallons/

75%Source Reduction Approach/Measure: Production

Process ChangeBrief Description of Measure: Conducted an

overall reduction in scale of, and the glasswaresize used, in experiments. Additionally, pur-chased equipment which lends itself to mi-croanalytical techniques. Thin layer chromatog-raphy equipment was replaced with gas chro-matography mass spec equipment.

Implementation Date: 1993

Economic OverviewCapital Cost: $93,000Maintenance/Recurring Costs: NoneReturn on InvestmentSavings on waste management - $1050 per yearSavings on raw materials - $3445 per monthTotal Savings: $42,390 per year. After 2.2 years

payback on capital costs.Barriers/Obstacles: Initial high cost of purchase of

new equipment.

CARBON DIOXIDE AS A LABORATORYEUTHANIZING AGENTCarbon dioxide can be substituted for ethylether as a laboratory euthanizing agent. Thiscan be successful as shown in the following casestudy.

Carbon Dioxide As A Laboratory EuthanizingAgent Case Study

Company Name: Childrens Hospital Los AngelesSIC Code: 8060/Acute Care Hospital (Pediatric)Business Activity: Licensed acute care pediatric

hospital with school of physical therapy, medi-cal technology, and x-ray technology (USCAffliation).

Waste Stream/CWC: Ethyl Ether/221Quantity of Waste (yr-gal): 1995-18 Gals.Process Generating the Waste: Laboratory

euthanizing agent.Estimated Source Reduction (%): 90% reduction

from 4 years previous. 1997 phase-out of ethylether use.

Source Reduction Approach/Measure: InputChange

Brief Description of Measure: All laboratoryeuthanizing takes place using carbon dioxide.

Implementation Date: 1995-96

Economic OverviewCapital Cost: No capital costs involved.Maintenance/Recurring Costs: Switch to carbon

dioxide from ethyl ether: 4 x 4 liter approxi-mately $150.00 vs. 2 x 80 lb. cylinders ofcarbon dioxide approximately $19.50 percylinder = Approximately $111.00 in savings inuse differential.

Return on Investment: Unknown. Substantialcost difference between chemicals. Increasedsafety and human health. A large reduction ofextremely hazardous substance reporting andenvironmental effect.

Discharge Impacts to Air, Water, and Land: NoneBarriers/Obstacles: Project implementation and

protocol changes for non-change chemicalusers.

Comments: Ethyl ether use has compoundedChildrens Hospital’s local reporting require-ments and is not that beneficial of a chemical.There are other types of hazards for carbondioxide usage, but the trade-offs are inconse-quential or very low when compared to thehealth and environmental effects of ether use.

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CYTOSPIN OR THIN PREP TECHNOLOGYSubstitute filter preparation on some fluids withcytospin or thin prep technology. This caneliminate the need to use chloroform to dissolvethe filter.

ATOMIC ABSORPTION STANDARDSProduce atomic absorption (AA) standards onlyas needed. Atomic Absorption (AA) is used todetermine copper and other trace metals inblood and other samples. Waste from heavymetal Atomic Absorption standards should becollected and disposed of as hazardous waste.Standards should be produced in small quanti-ties and only as needed.

ANALYSIS OF CHLORIDE BY ION-SELECTIVE ELECTRODE (ISE)Analysis of chloride by ISE is preferable to thecolorimetric method. Colorimetric analysis usesa mercury reagent, and generates a highly toxicwaste stream for which collection and disposalmay be difficult and expensive.

GLUCOSE TESTS WITHOUT ZINCOther types of glucose tests are available andshould be utilized whenever possible to elimi-nate zinc as a waste stream.

BOUIN’S SOLUTIONBouin’s solution, containing formaldehyde andpicric acid, is used for washing bone marrowcells and as a preservative. An alternative usingacetic acid is available.

CHLOROFORMSubstitute chloroform with dichloromethane in lab phase extractions. This can be an effectivesubstitute as shown in the following case study.

Substitute Chloroform With Dichloromethane In Lab Phase Extractions Case Study

Company Name: City of Hope National Medical Center - DuarteSIC Code: 8062Business Activity: Cancer Hospital and Medical ResearchWaste Stream/CWC: Chloroform/CWC 214Quantity of Waste (yr-liters): 1993 - 40 liters per yearProcess Generating the Waste: Lab phase extractionsEstimated Source Reduction (%): 100% for chloroformSource Reduction Approach/Measure: Input ChangeBrief Description of Measure: Substituted chloroform (OSHA PEL TWA 50 ppm) with dichloromethane

(OSHA PEL TWA 500 ppm). Also, chloroform is a CAL OSHA regulated carcinogen, dichloromethaneis not.


Economic OverviewCapital Cost: NoneMaintenance/Recurring Costs:Chloroform is $17.95 per literDichloromethane is $22.95 per liter$200 per year for the less hazardous/more expensive chemicalBarriers/Obstacles: None

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Carrier Liquid Case Study

Company Name: City of Hope National Medical Center - DuarteSIC Code: 8062Business Activity: Cancer Hospital and Medical ResearchWaste Stream/CWC: Carrier liquid/CWC 541Quantity of Waste (yr-gal): 1993 - 150 gallons a monthProcess Generating the Waste: Purification and removal of oligonucleotides from synthesized DNA.Estimated Source Reduction (%): 50%Source Reduction Approach/Measure: Production Process ChangeBrief Description of Measure: Modification of DNA purification process. Reduces the volume of chemical

necessary to purify and remove oligonucleotides from synthesized DNA. This was accomplished byreducing by 50% the amount of carrier liquid ran through the purification columns. (50% reduction fromthe amount of carrier liquid called for in the standard Millipores/Waters protocol for this process.)

Implementation Date: March 1993

Economic OverviewCapital Cost: NoneMaintenance/Recurring Costs: NoneReturn on Investment:Savings: Raw material $100.00 per month

Transportation and disposal costs - $4200 per yearTotal Savings: $5400.00 per year

Barriers/Obstacles: None

CARRIER LIQUIDThe amount of chemicals in lab processes may be reduced and still get accurate results. Sometimesthis can result in a reduction of chemicals used as shown in the following case study.

ZENKER’S SOLUTION AND MERCURY B-5Two common tissue fixatives, Zenker’s solutionand B5, are especially problematic because theycontain high levels of mercury. These solutionsare extremely hazardous and should be usedonly in the smallest possible volumes, with allwastes rinsed to hazardous waste containment -never to a sink. While Zenker’s may be thesolution of choice in a few instances, lab manag-ers should discourage its use whenever pos-sible. Expending the additional time and carenecessary to obtain excellent specimens usingother non-metallic fixatives will reduce disposalcosts. Ten percent formalin may be an effectivesubstitute as a fixative for bone marrow, kidney,and testicular biopsy specimens. Also, zincfixatives are substitutes and can reduce oreliminate mercury chloride precipitates thatrequire costly hazardous waste disposal. ThepH in zinc-formalin mixtures has to be carefullycontrolled. Zinc fixatives provide good nucleardetail but not as good as mercury fixatives.Surgical specimens, biopsies, and skin lesionsgenerally work well with zinc.

PRESERVING STOOL SAMPLESFormaldehyde/acetic acid/sodium acetatealternatives are available for concentratedcopper solutions or mercury/poly vinyl alcohol(PVA) solutions used in preserving stoolsamples. There is also zinc and copper PVA.Specimens with mercury must be disposed of ashazardous waste. The Department is consider-ing regulations in the future to allow specimenswith zinc and copper to be disposed of asmedical waste or poured down the sewer if it isallowed by your local POTW.

THIMERISOLThimerisol, which contains mercury, is used as apreservative in some buffer solutions. Alterna-tives such as sodium azide are available forsome applications in immunodiagnosis. So-dium azide should not be released down thedrains. It slowly accumulates and reacts withthe metal in cast iron pipes and forms an explo-sive material.

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GLUTARALDEHYDEActivated glutaraldehyde solutions lose theirtoxicity when held for a period of time (usually14 to 21 days). After that time they may beacceptable for discharge to your local POTW aslong as all other laws and regulations are satis-fied. First check with your local POTW toverify if this waste can be disposed of safely inyour sanitary sewer. If it cannot be disposed ofdown the sewer, it would still be a less hazard-ous waste and would be manifested out as aless hazardous waste.

FORMALDEHYDE/FORMALINFormaldehyde may be reused in autopsy andpathology laboratory specimen preservation.Direct reuse may be possible, since solutionsretain desirable properties longer than specimenholding times. Effective preservation may befeasible at concentrations less than the 10 per-cent typically used.

Properly control airborne emissions fromformaldehyde by keeping containers covered.Formaldehyde is a suspected carcinogen of theupper respiratory system. Personal solventmonitoring badges are available that record theamount of exposure to formalin, formaldehyde,and xylene. With a VOC badge, you can specifyup to three chemicals to be recorded out of achoice of six. Glutaraldehyde monitoringbadges are also available.

Using the smallest sized container offormaldehye fixative for all processes willreduce the amount of formaldehyde generation.Prefilled containers are available in many sizesand they can also be filled at the site. Staffshould be informed to use the smallest suitablecontainer. Use of prefilled containers is slightlymore expensive than use of bulk formaldehyde.Disposal costs are minimized by using lesssolution to perform the analyses.

Treatment systems are available to detoxifyformaldehyde. Some products available areFormalex, VYTAC 10F, and Scigen. (See Appen-dix C - Technology Transfer Advisories) checkwith your local POTW to verify if this waste canbe disposed safely in your sanitary sewer. If itcannot be disposed of down the sewer, it would

still be a less hazardous waste and would bemanifested out as a less hazardous waste forless cost. The treatment of formaldehyde by ahealth care facility using a technology combina-tion certified by DTSC pursuant to HSC Section25200.1.5 (as authorized by CCR Section67450.20) qualifies for a conditional exemption-specified wastestream (See Appendix D).

An onsite solvent recovery system for formal-dehyde may be cost effective. Before consider-ing any type of distillation unit, consider thefollowing:

DISTILLATION CHECKLISTFeasibility ConsiderationsDetermine if you can use the recycled productin your laboratory without compromising testquality and results.

If there is a wide range of boiling points (I.e.,numerous solvents), distillation may yield asolvent that is different from the original,required blend. Mixing solvents may requirethe use of more expensive vacuum distillationunits. Don’t mix wastes, especially nitrocellu-lose-based materials with solvents.

Safety ConsiderationsConsider fire and ignition sources, ventilationneeds, and spill containment issues beforechoosing location for the unit.

Contact the fire marshal, insurance company,electrical inspectors, and independent testinglaboratories regarding equipment safety con-cerns before you purchase a unit.

Make sure the distillation unit has automaticshut-off controls for temperature malfunction-ing. Also, make sure the unit has shut-offcontrols when all the solvent is reclaimed and arelief valve for pressure build-up.

Make sure controls are intrinsicially safe andthere are features that will prevent the openingof a distillation unit until recycling and coolingis completed.

Determine how your unit will condense and/orrecover solvent vapors.

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Economic ConsiderationsRequire equipment vendor to distill a sample ofyour waste so you can evaluate the quality andquantity of distilled product and still bottoms.Ask your vendor about the distillation unit’ssolvent recovery percentage and operationalguarantees.

Require a performance guarantee for the instal-lation and successful inspections by electricalinspectors and fire marshals.

Determine all costs of operating a distillationunit. Those costs include:Labor Costs (loading waste, monitoring distilla-

tion process, unloading still bottoms, andcleaning machine)

Electricity/Energy CostsEquipment/Maintenance Cost (e.g. fittings,

gasket replacement)Still Bottom Disposal CostsStill Liner Costs (if applicable)

Onsite Formalin Recycling Case Study

Company Name: Kaiser Permanente Medical Center, Fresno - Pathology LabSIC Code: 8062Business Activity: Provide healthcare to Kaiser Permanente membersWaste Stream/CWC: Laboratory waste - (non recoverable formalin sludge) CWC 214/135Quantity of Waste (gal/yr): 20 gallon/year (estimate)Process Generating the Waste: Processing of surgical specimensEstimated Source Reduction (%): 90%Source Reduction Approach/Measure: RecyclingBrief Description of Measure: Formalin is recycled onsite.Implementation Date: 1995

Economic OverviewCapital Cost: $15,000Maintenance/Recurring Costs: Repair costs (one time $2400), 20 gallons a year sludge to manifestReturn on Investment: $5737.20 saved (no purchase of formalin in 1996) 280 gallons per year recovered

(1996)Discharge Impacts to Air, Water, and Land: The recycler reduces the amount of formalin that is disposed

of by approximately 90%.Barriers/Obstacles: There is less than 10% volume that is unrecoverable sludge.Comments: No longer need to purchase 10% formalin which currently costs $20.49 per gallon.

Condenser Water Costs (sewer or treatmentcharges)

Facility Upgrade Costs

There must be separate ventilation and a desig-nated space for operation. There may be specialutility issues to consider.

Training Costs

If operational support is not included in theequipment purchase, still operators will requiretraining.

Regulatory ConsiderationsBe sure to consider regulatory requirements forrecycling, still bottom storage and labeling, andhazardous waste generation category determi-nation.

The following summarizes the purchase anduse of a formalin recycling unit.

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Substitutes for formalin are available. Laboratory staff need to test them thoroughly.

Formalin Substitute for Tissue Fixation Case Study

Company Name: Los Angeles County-King/Drew Medical CenterSIC Code: 8062/General Medical and Surgical HospitalsBusiness Activity: Provides personal health services to the Los Angeles County population.Waste Stream/CWC: Laboratory Waste - Formalin/CWC 214Quantity of Waste (lbs/yr): 3260 lbs in 1994Process Generating the Waste: Formalin solution (4% formaldehyde) is used in the histology laboratory for

tissue fixation.Estimated Source Reduction (lbs/%): If this had been successful, the expected reduction was estimated to

be 2120 lbs or 65%.Source Reduction Approach/Measure: Input ChangeBrief Description of Measure: A commercially available non-toxic substitute for the formalin solution,

Histo-Choice, was tested in the histology laboratory for tissue fixation.Implementation Date: Measure rejected.Barriers/Obstacles: The fixation period was very slow and time consuming.Comments: It was concluded by the laboratory staff that it is infeasible to use Histo-Choice.

OTHER SOLVENTSWaste solvent solutions (alcohol and xylene)generated from slide preparation in cytologymay be reused in a “step down” method. Thismay allow the solutions to be used for up to onemonth before being discarded. The first slidesdipped into the initial solution leave contami-nates in the alcohol or xylene. As a result eachconsecutive dipping solution thereafter is lesscontaminated. When the first dipping solutionbecomes too contaminated, it must be elimi-nated and replaced with the second dippingsolution. The last solution is then replaced withfresh alcohol or xylene.

If a solvent must be used, consider usingnonchlorinated solvents instead of chlorinatedsolvents.

Investigate the use of simple alcohols andketones instead of petroleum hydrocarbons.Toluene and xylene are examples of compoundsto replace. Terpene-based solvents and naphthaisoparaffinic hydrocarbons may be substitutedfor xylenes used for slide cleaning in someapplications. Terpene-based solvents are lesstoxic and have a higher boiling point. Xylenehas a low flashpoint and/or a low boiling pointand should be kept in a cool place, away fromopen flame, sunlight, or artificial light, and withthe lid tightly closed. Carefully evaluate citrus-based substitutes. Citrus-based alternatives

may reduce worker exposure but may producea hazardous waste because these products mayhave a flashpoint less than 140 degreesFarenheit. Cases of contact dermatitis andmigraines from the odor have also been re-ported with exposure to these products. Thesecitrus-based solvents may process samplesslower than xylene and will require temperatureand time modifications. Generally, these prod-ucts are effective on samples in the micrometerrange. However, thicker samples may bedifficult or impossible to process. Vegetable-based substitutes are also available. Evaluatehazardous waste and quality issues before usingxylene alternatives.

A scintillation fluid is used to amplify lowenergy signals generated when a low energyradioactive material decays. Low energy radio-active materials are used as “markers” in vari-ous types of research (including biomedical andpharmaceutical). Scintillation fluids containvarious levels of xylene and toluene which arehazardous chemicals and need to be handled assuch. Consider using a biodegradable scintilla-tion fluid instead of a xylene/toluene basedscintillation fluid. The waste from biodegrad-able products do not contain solvents.

Minimize extraction sample sizes to reduce thequantity of solvents used.

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Use calibrated equipment, such as pipettes andgraduated cylinders to dispense solvents. Thisequipment allows for minimal use of the solu-tion.

Evaluate routine processes such as fixation andextraction to determine if quantities of reagentsused in these processes can be minimized.Monoclonal antibodies, radioisotope-labeledimmunoassays, and ultrasensitive analyticaldevices may reduce or eliminate the need forsolvent extractions and fixation. Tests can berun to see if accuracy can be maintained withsmaller volumes. Alternative methods may notrequire the use of reagents. Use calibrateddispensers to minimize waste resulting fromoverpouring. Unitized test kits include pre-measured quantities of reagents.

With Coplin jars and slide mailers that hold theslide vertically, solutions only need to be filled

to the top of the specimen, not to the top of thejar. Select a container that minimizes solutionsused and reduces the amount of stain that mustbe purchased and discarded. Extend bath life aslong as possible. Often baths are discardedroutinely by shift or after they have been usedto process a certain number of slides. Moneyand waste can be saved by only discardingbaths when they begin to show contaminationor loss of effectiveness. Filter and cover bathsbetween uses to significantly extend bath life.

Baths are used for fixing/rinsing of microscopeslides with pathologic specimens. Considerusing an eye dropper for one slide instead ofimmersing it in a bath that can hold five slides.Both waste and contaminated rinsate volumescan be reduced if slides are stained with a fewdrops of solution rather than a dipping bath.Sometimes the bath size can be reduced asshown in the following case study.

Reduction of Slide Baths Case Study

Company Name: City of Hope National Medical Center - DuarteSIC Code: 8062Business Activity: Cancer Hospital and Medical ResearchWaste Stream/CWC: Hydrocarbon Solvents/CWC 213Quantity of Waste (yr-gal): 1992 - 40 gallons per monthProcess Generating the Waste: Baths are used for fixing and rinsing of microscope slides with pathologic

specimens.Estimated Source Reduction (%): 50%Source Reduction Approach/Measure: Operational ImprovementBrief Description of Measure: Reduced the size of slide baths from 500 ml to 250 ml.Implementation Date: 1992

Economic OverviewCapital Cost: NoneMaintenance/Recurring Costs: NoneReturn on Investment: Savings on raw material - $253 monthSavings on waste disposal - $1440 per yearTotal Savings: $4476 per year

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Substitution of Low Grade Solvents with High Grade Solvents Case Study

Company Name: City of Hope National Medical Center - DuarteSIC Code: 8062Business Activity: Cancer Hospital and Medical ResearchWaste Stream/CWC: Acetonitrile/CWC 214Quantity of Waste (yr): 1993Process Generating the Waste: Chemical synthesis of nucleocidesEstimated Source Reduction (%): 20%Source Reduction Approach/Measure: Input ChangeBrief Description of Measure: Substitution of low grade solvents with high grade solvents. In the past,

acetonitrile (ACN) was distilled from magnesium. About 20% of the raw material used in the processended up as hazardous waste. By purchasing ACN instead of distilling it from magnesium, 20% wastebyproduct is eliminated. The high cost of ACN, $79 per gallon, results in this not being a cost effectivesource reduction method. The decision to implement this measure was not based on source reduction,but rather it was based on eliminating a time consuming distillation process.


Economic OverviewCapital Cost: Although the figures were never captured, the high cost of ACN does make this a negative

figure from the single standpoint of source reduction In so far as any possible savings on person-hoursand/or other related factors, that information was not calculated and/or captured.

Different processes may have different purity requirements for fresh solvents as shown in thefollowing case study.

Separate waste solvents into containers specificto single compounds so that simple distillationis more feasible. Otherwise, more expensivefractional distillation may be needed. Batchdistillation column costs can vary greatly.Consider local ordinances, fire codes, unitreliability, and performance before installing. Ifsolvent wastes cannot be segregated, combinedquantities of waste solvents may be largeenough to warrant distillation using a fraction-ating distillation column. An example would beseparation of xylene from ethanol in histologywastes. If onsite recycling is not cost effective,consider offsite recycling or the use of a wasteexchange. If distillation is not feasible, and off-

site disposal is chosen, alcohol and xyleneshould be separated from other wastes. Thefuel value decreases when water and oxygen-ated organic compounds (alcohols) are present.Fuel blenders charge less to dispose of wasteswith high heating values. For informationabout waste exchanges, contact the CaliforniaWaste Exchange at (916) 322-4742, Fax (916) 327-4495, or on the Internet athttp://www.calepa.cahwnet.gov/dtscdocs/cawastex.txt.To reach the California Materials Exchange dial(800) 553-2962.

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The following is an example of the use of an onsite solvent distillation unit for xylene and reagentgrade alcohol.

Onsite Recycling of Xylene and Reagent Grade Alcohol Case Study

Company Name: UC Davis Health System, Sacramento Medical CenterSIC Code: 8062Business Activity: Full service clinical diagnostic laboratoryWaste Stream/CWC: Laboratory waste - Xylene/CWC 214 and Alcohol/CWC 214Quantity of Waste (yr-lbs): Xylene January-December 1996 - 3328 lbs.Alcohol October-December 1996 - 3744 lbs.Process Generating the Waste: Xylene is used to remove the paraffin wax from the tissue specimens in

histology. Xylene is also used in automatic tissue processing and staining machines. Alcohol may beused as a fixative for cells in cytology. Following fixation, alcohol solutions (in varying concentrations)are used to dehydrate (dewater) and decolorize tissue prior to staining.

Estimated Source Reduction (lbs/%): Xylene 3168 lbs/ 95%Alcohol 160 lbs/ 4% (October-December 1996)Source Reduction Approach/Measure: RecyclingBrief Description of Measure: Recycle xylene and reagent grade alcohol onsite in a solvent distillation unit.Implementation Date: Xylene - January 1996Reagent grade alcohol - October 1996

Economic OverviewCapital Cost: $18,100 ($17,800 for distillation unit, and $300 for electrical upgrades)Maintenance/Recurring CostsLabor costs Xylene:System monitoring = 40 hoursLoading and cleaning = 240 hoursDispensing and delivering = 48 hoursTotal labor costs = 328 hours x $20 = $6560Labor costs per gallon of reclaimed Xylene = $16.56Labor costs Alcohol:System monitoring = 5 hoursLoading and cleaning = 10 hoursDispensing and delivering = 2 hoursTotal labor costs = 17 hours x $20 = $340Labor costs per gallon of reclaimed Alcohol = $17.00

Cost per gallon of virgin material and its waste disposal:Xylene - approximately $10.63 ($8.04 + $2.59)Alcohol - approximately $15.70 ($8.30 + $7.40)(January - December 1996) Xylene396 reclaimed gallons X $8.04/gallon = $3,183 in reclaimed savings(October - December 1996) Alcohol20 reclaimed gallons X $8.30/gallon - $166 in reclaimed savings

Waste Disposal SavingsXylene(396 gallons X $2.59) + Alcohol(20 gallons X $7.40) = $1173.64

Overall Savings for January - December for Xylene and October - December for Alcohol($3183.84 + $166 + $1173.16) - ($6900) = $2477 net loss

Return on Investment: No actual savings at this time due to the labor costs involved in operating thedistillation unit at a remote site rather than at the point of generation. See Barriers/Obstacles below forfurther information and future strategies.

Discharge Impacts to Air, Water, and Land: Decrease in amount of waste being manifested out andreduction in purchase of new products.

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Barriers/Obstacles: Due to space constraints and staffing issues, the distillation unit is operated in thehazardous materials facility. The fact that the building is not temperature controlled hinders productionof recycled xylene and alcohol. Temperature extremes confuse the controller of the unit and makecompletion of a second run impossible. It is the intention to remedy this problem by relocating to atemperature controlled facility. The capacity of the distillation unit (2.5 gallons) limits the volume ofwaste that can be processed in a single shift. It would be more efficient to have the generators of thewaste handle the day to day operations of distillation. In addition, technical assistance is available onlyby telephone which makes it difficult to solve problems in a timely manner.

Comments: Histology and cytology departments were able to use the reclaimed xylene routinely byFebruary 1996. Still working out the obstacles to providing alcohol on a routine basis.

Several hospitals can consolidate their wastes so that sufficient waste quantities are available tomake use of a centralized recycling location. Kaiser Permanente Medical group submitted thefollowing abstract demonstrating their use of this concept.

Centralized Recycling of Xylene, Xylene Substitutes, and Alcohol Case Study

Company Name: Kaiser Permanente Medical Group, Regional Laboratory-BerkeleySIC Code: 8062/General Medical and Surgical HospitalsBusiness Activity: Full service clinical diagnostic laboratoryWaste Stream/CWC: Laboratory waste-Xylene/CWC 214a and Alcohol/CWC 2141cQuantity of Waste (yr-lbs): January-April 1994, 22,727 lbs.Process Generating the Waste: Xylene solutions are used to remove the paraffin (a wax like material used

in the slide preparation process) from the tissue specimens in Histology. Xylene solutions are alsoused in automatic tissue processing and staining machines. Alcohol may be used as a fixative for cellsin Cytology. Following fixation, alcohol solutions (including ethanol and methanol) are used to dehy-drate (de-water) and decolorize tissue prior to staining.

Estimated Source Reduction (lbs/%): 10,256 lbs/50% for Alcohol and Xylene (Jan.-April 1994 only). Totalwaste from Jan-Dec. 94 was 24,234 lbs.

Source Reduction Approach/Measure: RecyclingBrief Description of Measure: Recycle xylene, xylene substitutes, and alcohol solutions onsite in a

solvent still.Implementation Date: January 1994-April 1994

Economic OverviewCapital Cost: $29,000 ($25,000 for distiller unit, and $4,000 for additional water removal unit)Maintenance/Recurring Costs:Labor costs: (January 1994 - April 1994)System monitoring=33 hoursLoading and cleaning = 25 hoursDispensing = 41 hours Total labor costs = 99 hours X $20 = $1980Labor cost per gallon of reclaimed solvent = $2.39Cost per gallon of virgin material and its waste disposal:Alcohol = approximately $26.11 ($10.80 + $15.31)

Xylene = approximately $25.31 ($10.00 + $15.31)

( Jan - April 1994)Alcohol - 453 reclaimed gallons X $10.80/gallon = $4892 in reclaimed savingsXylene - 377 reclaimed gallons X $10.00/gallon = $3770 in reclaimed savings(453 gallons X $15.31) + (377 X $15.31) = $12,709 Avoided Waste DisposalAlcohol Reclaimed Savings ($4892) + Xylene Reclaimed Savings ($3770) + Avoided Waste Disposal

($12,709) - Labor Costs ($1980) = $19,391 Net Savings

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(Jul. - Dec. 1994)Alcohol - 853 reclaimed gallons X $10.80/gallon = $9212 in reclaimed savingsXylene - 746 reclaimed gallons X $10.00/gallon = $7460 in reclaimed savings(853 gallons X $15.31) + (746 X $15.31) = $24,480 Avoided Waste DisposalAlcohol Reclaimed Savings ($9212) + Xylene Reclaimed Savings ($7460) + Avoided Waste Disposal

($24,480) - Labor Costs (Approximately 139 hours at $20/hour ($2787) = $38,365 NetSavings

Return on Investment: Total savings in 1994 was $57,756.00

Discharge Impacts to Air, Water, and Land: Decrease in amount of waste being manifested out andreduction in purchase of new products.

Barriers/Obstacles: A 55 gallon solvent still had not been previously sold by the manufacturer to ahospital. It had only been used in commercial settings. The manufacturer was not able to providetechnical assistance so the hospital had to develop processes through trial and error.

Comments: The Histology and Cytology departments were able to use the reclaimed solvents routinelyby February 1994.

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CHEMOTHERAPY AND ANTINEOPLASTICWASTESThe greatest volume of antineoplastic wastes isgenerated from drug dispensing devices, con-taminated protective clothing, and associatedparaphernalia. Many of these items are regu-lated by the Medical Waste Management Pro-gram and should be handled accordingly. Ifyou need clarification on these regulations,contact them at (916) 327-6904.

Provide separate containers with distinctivelabels in chemotherapy drug handling areas.Chemotherapy receptables should be small todiscourage general usage.

Purchase drugs in container sizes that permitformulation of daily dosages with a minimumof leftover contents. Also, obtain pre-scoredampule containers to minimize spillage associ-ated with breaking open unscored ampulenecks. If possible, consider preparing themedication only after the patient has arrived.This will eliminate unused material beingdiscarded as hazardous waste if the patient istoo ill to receive treatment or otherwise missesan appointment.

Emphasize proper handling practices to mini-mize hood cleaning requirements. The actual

cleaning frequency required depends on drughandling volume and the amount of spillagewhich occurs in the hood. Waste generatedfrom these cleaning procedures may also bebiohazardous waste. (See Health and SafetyCode Section 117635.)

MERCURY CONTAINING EQUIPMENTSubstituting solid state electronic sensingdevices for mercury-containing devices formonitoring termperatures and blood pressure isthe primary minimization alternative for mer-cury wastes in hospitals. Digital thermometers,electronic sensors, and temperature strips areavailable alternatives to mercury thermometers.Also, mercury thermometers should not be senthome with patients. These and other items inpatient care kits that are repeatedly not used inpatient procedures and become unused wasteshould be negotiated with the purchasingalliance to exclude them from the kits. Bloodpressure cuffs with electronic sensors are avail-able and esophageal dilators, Cantor tubes, andMiller Abbot tubes can be found with tungstenweighting. If economic constraints pose abarrier, consider a multi-year plan for phase-outof mercury containing devices. Prioritize byfirst replacing mercury containing equipment incarpeted areas and mobile devices.

NURSING, PATIENT CARE, PHARMACY, PHYSICIANS

Replace Mercury Sphygmomanometers with Aneroid Sphygmomanometers Case Study

Company Name: Los Angeles County-King/Drew Medical CenterSIC Code: 8062/General Medical and Surgical HospitalsBusiness Activity: Provides personal health services to the Los Angeles County population.Waste Stream/CWC: Mercury Waste/CWC 725/181Quantity of Waste (yr-lbs): 1994-200 lbsProcess Generating the Waste: Employees used or serviced mercury sphygmomanometers daily and a

number of mercury spills had resulted from breakages.Estimated Source Reduction (lbs/%): 150 lbs/75%Source Reduction Approach/Measure: Input ChangeBrief Description of Measure: Replace mercury sphygmomanometers with aneroid sphygmomanometers

in the patient care areas.Implementation Date: The mercury sphygomanometers were replaced with TycosR Aneroid Sphygmoma-

nometers in fiscal year 1993-94.Discharge Impacts to Air, Water, and Land: Aneriod sphygmomanometers do not contain mercury so

there is no longer any hazardous waste.Comments: The accuracy of the aneroid sphygmomanometers is acceptable and it is technically feasible

to replace the mercury sphygmomanometers.

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Mercury can be recovered for reuse and con-taminated mercury turned over to a commercialmercury recycler. To get a copy of the “Califor-nia Waste Exchange” listing mercury recyclers,contact the:

Department of Toxic Substances ControlHazardous Waste Management ProgramP.O. Box 806Sacramento, CA 95812-0806(916) 322-4742, FAX (916) 327-4495For online access contacthttp://www.calepa.cahwnet.gov/dtscdocs/cawastex.txt

Specially designed mercury vacuums and spillabsorbent kits can be purchased and should beavailable in all areas where mercury-containingequipment such as thermometers and bloodpressure cuffs are used.Proper training is also needed to protect em-ployees from inhalation, skin absorption, andingestion hazards. Ensure that nitrile gloves,not latex gloves, are available for use duringcleanup.

The Anderson Tube has titanium and can be anacceptable substitute for Canter Tubes.

Zinc air batteries are now available to replacethe mercury batteries used in telemetry units.

WASTE ANESTHETIC GASESNonhazardous substitutes are not available foranesthetic gases. Waste minimization methodsfocus on reducing leaks. Generally, equipmentless than 10 years old complies with low leak-age standards.

Inspections and maintenance of anesthesiaequipment, scavenging equipment, and ventila-tion systems should be performed regularly andby qualified personnel. Proper routine mainte-nance is essential. Quarterly monitoring ofwaste anesthetic levels in operating rooms,recovery rooms, dental suites, and adjacentrooms that may receive waste gases should beperformed.

Non-mercury Thermometers, and Electronic/Chemical Piezometric Devices Case Study

Company Name: Childrens Hospital Los AngelesSIC Code: 8060/Acute Care Hospital (Pediatric)Business Activity: Licensed Acute Care Pediatric Hospital with School of Physical Therapy, Medical

Technology, and X-Ray Technology (USC Affliation).Waste Stream/CWC: Mercury Waste/121, 725, & 551Quantity of Waste (yr-lbs): 1995 - 21 lbs.

Process Generating the Waste: Thermometers, blood pressure cuffs, and related instruments/devices.Source Reduction Approach/Measure: Input changeBrief Description of Measure: Replace with non-mercury thermometers, and electronic/chemical piezo-

metric devices.Implementation Date: 1990 to present.

Economic OverviewCapital Cost: Replacement of old mercury units to new electronic devices were spread over a long

period to ensure new devices and product manufacturers gave a product that could be used in ourpediatric setting. The cost was not capital related but instead was a matter of finding the appropriatedevices for the hospital’s use.

Maintenance/Recurring Costs: Chemical thermometers are inexpensive but add to solid waste measure-ments. Electronic devices for blood pressure and thermometer reading are comparable in cost tomercury containing instruments because they do not have the high disposal costs. In addition, theelectronic devices do not pose a hazard to patients and workers.

Discharge Impacts to Air, Water, and Land: Reduction of mercury spills, vapor releases, and recyclingproblems. Increase in solid waste (trash) from chemical thermometers, i.e., single use device.

Barriers/Obstacles: Training for use of new devices.

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Before inducing anesthesia, employ the follow-ing low-leakage anesthetic practices: confirmproper connections and leak tightness of equip-ment; and avoid spillage of liquid anestheticswhile filling vaporizers. During anesthesiaadministration, anesthetists can reduce leakageby properly fitting the mask on the patient’sface before turning on anesthetic flow, and byturning off the gas supply before disconnectingthe breathing circuit during short interruptions.

HEMODIALYSIS - FORMALDEHYDEFormalin is formaldehyde in a water andmethanol solution. It is used for cleaningdialysis machines.

Consider installing reverse osmosis (RO) watersupply equipment. The use of RO units allowsa reduction in the cleaning frequency require-ments of dialysis machines.

Perform culture studies to determine the mini-mum strength of formalin required and theminimum cleaning frequency for adequatedisinfecting of dialysis machines and watersupply systems. Waste generation rates areproportional to cleaning frequency and formalinstrength.

A solution of peracetic acid, acetic acid, andhydrogen perioxide can be substituted forformaldehyde-based disinfectants. Equipmentthat can be heat-disinfected may be available inthe near future.

Dispensing formalin via a central distributionsystem with plumbing connected to eachmachine minimizes waste that may result fromspillage.

PRESCRIPTIONSEvaluate drug ingredients for metals and pre-scribe non-metallic alternatives when feasible.Selenium, an extremely toxic heavy metal, isfound in some dandruff shampoos. Wastewatertreatment does not remove enough selenium.Zinc ointments prescribed for diaper rash andother dermatology applications enter the sewerwhen babies are bathed or when the diapers arewashed.

In addition to making monitoring patient druguse more difficult, open formularies maysignificantly contribute to the volume of drugsthat must be disposed. Open formularies allowproviders to dispense samples to patients. Thisdispensing practice encourages the develop-ment of secondary storage areas. Once estab-lished, secondary storage areas and their envi-ronments cannot be controlled. When drugs areimproperly stored (e.g. improper cooling re-quirements) they may become obsolete andrequire disposal which will increase disposalcosts. The distribution of drugs samples shouldbe tracked and reduced.

Implement policies that discourage drug repre-sentatives from leaving excessive amounts ofsample medications. Medical providers (whomay have offsite offices) with hospital privi-leges accumulate samples that may become adisposal problem for pharmacies. Typically,pharmacies dispose of these drugs gratuitouslyfor the provider.

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RADIATION THERAPYRADIOACTIVE WASTERadioactive wastes are generated from nuclearmedicine and from clinical testing laboratorydepartments. Source reduction and substitutionare the primary waste minimization methodsfor radioactive wastes.

Try to use suppliers that will accept the returnof Isotope containers.

Evaluate processes for substitution of long-lived isotopes with short-lived isotopes. Forexample, use iridium-192 or cesium-137 in placeof radium-226.

Provide one hundred to 200 square meters forisolation and interim storage of short-livedradioactive wastes during decay to acceptablelevels.

Ensure radioactive wastes are kept segregated,centrally processed, and properly labelled asto form, isotope, date of calibration, and chemi-cal composition. Proper labeling and handlingare legally required and make waste manage-ment decisions easier. Radioactive and otherhazardous wastes should not be mixed. Mixedwaste must be disposed so that all regulationspertaining to chemical waste and radiologicalwastes are met. This greatly increases disposalcosts.

RADIOLOGYHospital radiology departments typicallygenerate wastewater containing silver fromspent processing solutions and other photo-graphic chemicals. The photographic develop-ing solutions used in X-ray departments consistof two parts, a fixer and a developer. The fixernormally contains ammonium thiosulfate, 1-5percent potassium hydroxide, and less than 1percent silver. The developer contains approxi-mately 45 percent glutaraldehyde and 5 to 10percent hydroquinone. Acetic acid is a compo-nent of stop baths and fixer solutions. There ischromium in developer cleaners and seleniumin toners. Other wastes include spoiled chemi-cals and scrap film.

Be sure the storage area has proper temperatureand light conditions for photoprocessing chemi-cals. Meeting recommended storage conditionswill increase the shelf life of chemicals.

Test material with expired shelf life for effec-tiveness before being returned or disposed. Theexpired material may still be usable.

Try to use suppliers that will accept unusedmaterials.

Consider consolidating X-ray processor use toreduce the number of machines that are needed.This reduces maintenance and equipment costsand makes a centralized treatment system morepractical.

A silver recovery unit recovers silver salts inphotoprocessing wastewater. Silver is a compo-nent in most photographic films and paper andis present in the wastewaters produced. It canbe precipitated from fixing baths and purchasedby a commercial recycler. Various economicalmethods of recovering silver are available suchas metallic replacement, chemical precipitation,and electrolytic recovery. Metallic replacementis the most common technology. The spentfixing bath is pumped into a cartridge contain-ing steel wool. An oxidation-reduction reactionoccurs and the iron in the wool replaces thesilver in solution. The silver settles to thebottom of the cartridge as a sludge. Checkthe cartridges frequently and replace them asrequired, using the freshest cartridge last in theseries. The remaining aqueous waste, contain-ing approximately 1.4 percent glutraraldehyde,0.3 percent hydroquinone, and 0.2 percentpotassium hydroxide, is typically discharged tothe sewer. Recovered silver is worth about 80%of its commodity price. Companies that buysilver can be located under “Gold and SilverRefiners and Dealers” in a business telephonedirectory. These firms may pick up directly ormay purchase through dealers.

You may want to install your own silver recov-ery unit. Commercial recovery units are avail-able if the level of activity is great enough to

32

justify buying or leasing one. Be sure to con-sider any permitting requirements that mayapply. The recovery of silver fromphotofinishing qualifies as a conditional exemp-tion-specified waste stream. The volume limitfor conditional exemption is 500 gallons pergenerator (at the same location) in any calendarmonth. Silver recovery from photofinishing iscompletely exempt from authorization require-ments if the quantity treated is 10 gallons or lessin any calendar month. You do not need tonotify DTSC if you qualify for this exemption.Retain documentation verifying your eligibilityfor this exemption, such as developer invoices.(See Appendix D). There are also packageddistillation and precipitation units available. A

distillation unit can reduce the amount ofhazardous waste requiring manifesting by asmuch as ninety percent. The aqueous waste canbe discharged to the sewer and the hazardouswaste is much smaller in volume.

Spent fixer may be stored as hazardous wasteand hauled away by a licensed transporter.Several hospitals can also consolidate theirwastes so that sufficient waste quantities areavailable to make use of a centralized treatmentlocation. Centralization reduces the amount ofsampling required and the number of systemsto be maintained. This offsets the increase incollection and transportation time as shown inthe following case study.

Recycling of Spent Photographic Fixer Solution Case Study

Company Name: Kaiser Foundation Hospitals - Biomedical Engineering Facility - BerkeleySIC Code: 8062Business Activity: Maintenance and asset management of Kaiser Foundation Hospitals’ equipmentWaste Stream/CWC: Spent photographic fixer solution/CWC 541Quantity of Waste (yr-lbs): 1997 - 1,092,000 lbs.

Process Generating the Waste: X-ray processing produces a wastewater of spent photographic fixersolution.

Estimated Source Reduction: Not applicableSource Reduction Approach/Measure: RecyclingBrief Description of Measure: The Kaiser Biomedical Engineering Facility picks up used film and delivers

the X-ray chemicals to 38 Kaiser hospitals and clinics in Northern California. The used film is picked upby a photowaste recycler at the biomedical facility. Once the fixer distillation unit was installed, we alsobegan to collect the spent fixer from each facility for silver recovery.

Implementation Date: 1992Economic OverviewCapital Cost: $80,000 for distiller unit, $45,000 for three silver recovery units, and $10,000 for tanks and

miscellaneous. Regulatory fees of $80,000. Total capital cost of $215,000.Maintenance/Recurring Costs: The pick-up and hauling was done by the same Kaiser employee who

already delivered the solutions. Labor cost is included should additional employees be hired, althoughwe did not need to increase our staff.

System monitoring = 100 hoursLoading and cleaning = 800 hoursDispensing = 60 hoursTotal Labor Cost = 960 hours x $18.01 = $17,29050,000 ounces of silver x average rate per ounce of silver ($5.50) = $275,000$275,000 - labor cost ($17,290) = $257,710 per yearReturn on investment after 10 months is $257,710 per year.Discharge Impacts to Air, Water, and Land: Silver bromide crystals, when discharged into the drain, have

a negative impact on the micro organisms which are used at the waste treatment plant to dissolve fecalmaterials.

Barriers/Obstacles: Going through the standardized permitting process.Number of Measures Rejected: NoneComments: If this process was not in place, it would cost Kaiser approximately $320,000 to have the

silver bromide hauled off and Kaiser Foundation would not receive the proceeds from the silver.

33

Limits for silver are frequently established bythe POTW. Waste water is hazardous if itsconcentration of silver is greater than 5 ppm.Elemental silver can be acutely toxic to aquaticlife. Free silver ions are considered to be bacte-ricides, creating conditions which disruptbiological systems. There may also be limits onbiochemical oxygen demand, pH, or otherconstituents. A permit is required from yourlocal POTW to flush fixer or other photochemi-cal waste down the drain. Very few POTWswaive this local requirement. In addition, theeffluent may have to be neutralized within a phrange of 5.0 to 9.0 prior to discharge.

Used and spoiled film can be sold to a recycler.This may be practical if operations are largeenough and recyclers are located close enoughto the hospital and will pick up your film.Although a recycler may not be listed in yourcity, one from a nearby area may pick up yourfilm. For example, recyclers from the Bay areado pick up in Sacramento County. To recycleused film, remove the film from the jacket toreceive a better rate of payment. The recyclerwill also take unprocessed film since it toocontains silver. Film is not a hazardous waste.Once the silver is removed, the remaining X-rayfilm is a recyclable polyester.

New technology exists that allows for in-process recycling of up to 50% of both thedeveloper and fixer. An in-line silver recoveryunit can also be attached. This recycling isaccomplished while still preserving the chemi-cal balance necessary for the proper develop-ment and archival quality of the film. Somehospitals have also found they can extend thelife of the developer for double emulsion film.The developer is pumped out of the processerholding tank and put through a 5 micron filterinto a container. The solution is poured backinto a tank and more developer is added. A teststrip is done and if it is acceptable, the devel-oper is reused. When bromide levels get toohigh in the developer, the film does not developcorrectly.

Cleaners without chromium for your X-rayprocessor system are now available. Chro-mium, referred to as an anti-oxidizer, is a haz-

ardous waste and must be collected for properdisposal. The solution can not be combinedwith other photo processing waste. With care-ful preventative maintenance, it may also bepossible to eliminate the need for use of anychemical.

Digital imaging and PACS, picture archivaland communications systems, or dry processfilm equipment use no liquid chemicals. Bothof these new technologies are available. Withtheir use there is no costly chemical disposal orneed for silver recovery. Efficiency and costsavings may be found in the handling,transfer,and storage of records electronically.

RESOURCE RECOVERYResource recovery involves both material reuseand recycling. Material reuse, a form of sourcereduction, occurs when the waste from oneprocess is directly used as raw material for thesame or another process. Recycling involves thepurification, separation, or concentration ofvaluable material from a waste stream beforethe waste is disposed of. The material is thenused by the originating process, or by anotherprocess at the same site. Recycling may takeplace either onsite or elsewhere through anoffsite service.

WASTE SEGREGATIONWaste segregation consists of placing differentwastes into different containers. While neither asource reduction nor a recycling practice itself,waste segregation is critical to the success of anyprogram designed to reduce or recycle wastematerials. When only a single container isprovided for all waste materials, it is commonfor nonhazardous wastes to be placed in thesame container with hazardous wastes. Thisincreases the amount of hazardous waste beinggenerated, and places additional burdens onalready overtaxed offsite treatment and disposalfacilities. By providing separate, prominentlylabeled containers for each waste type, lessnonhazardous waste will be placed in hazard-ous waste containers. Many companies havenoticed a decrease in the total amount of haz-ardous waste being sent offsite after implement-ing waste segregation. Segregating wastes alsoincreases their recyclability. Education to

34

support the rationale and procedures for wastesegreation is essential for its implementation.

RECYCLERSOther materials may also be recycled such as 55-gallon drums, plastic containers, woodenpallets, and toner cartridges. Presently, theprices paid are very low, but the recycling ofwaste to protect our environment is of sufficientmotivation to ensure continued success in thisarea. The California Materials Exchange(CALMAX), operated by the California Inte-grated Waste Management Board, is dedicatedto the reuse and recycling of excess products,materials, and waste by business and industry.To obtain a “Materials Listing Catalog” ofwanted or available materials or a listing ofrecycling centers located near you, call theCalifornia Integrated Waste Management Boardat 1-800-553-2962. The Department of ToxicSubstances Control also publishes an annuallisting of commercial hazardous waste recyclers,including facilities outside of California, titledthe “California Waste Exchange Directory”. Youmay get a copy of the Directory by contactingthe Department of Toxic Substances Control,Hazardous Waste Management Program, P.O.Box 806, Sacramento, CA, 95812-0806, (916) 422-4742, FAX (916) 327-4495, or for online accesshttp://www.calepa.cahwnet.gov/dtscdocs/cawastex.txt

TREATMENT AND PRETREATMENTThe ultimate goal of waste minimization pro-grams is to reduce the amount of hazardouswaste that is sent offsite for disposal. If thewaste can not be reduced, reused, or recycled, itmay be treated.

Treatment refers to processes that destroywastes and yield waste streams that pose littleor no environmental risk. Pretreatment isapplied to waste streams to make them moresuitable for recycling or final treatment in aPOTW. Many of the same processes can beused for treatment and pretreatment, and theterms are often used interchangeably.

PRETREATMENTConsider the feasibility of installing a pretreat-ment unit for formaldehyde and other organicsolvent wastes. Formaldehyde and solvent

discharges to sewers may be prohibited orlimited by regulations.

VOLUME REDUCTIONAn evaporation unit can remove excess waterfrom waste. A small quantity of concentratedwaste will generally cost less to treat than alarge volume of diluted waste, whether per-formed onsite or by a reclaimer. Although theabsolute quantity of metal recovered from bothmay be the same, the net value recovered isgreater from the concentrated waste. As long asthe cost of concentrating the waste stream doesnot exceed the difference, it is an economicadvantage to reduce the quantity of wastethrough some type of concentration process.Check with your local air quality board prior toinstalling an evaporation unit.

HAZARDOUS WASTE STORAGE ANDHANDLINGYou may generate additional hazardous waste ifyou store raw materials or hazardous wastesimproperly. Store them in covered containers.Covered containers will help reduce spills andevaporation, contamination of product fromdust, and corrosion of the drum top from rain.A locked, covered, indoor area with a concretefloor and curbs for spill containment would beideal for storage. A curb or dike surroundingthe storage pad will prevent spills from leavingthe storage area. A slightly sloped storage padwill help accumulate the spill in a smaller areaso it will be easier to clean up. Chemical cabi-nets and secondary containment pallets foroutdoor use can be purchased with covers ortarps. Inspect the storage area often, at leastonce a week, to look for leaky containers orimproper storage. A good time to inspect yourstorage area(s) is during your raw materialsinventory. Be sure to document the date andtime of inspections.

Waste minimization requires waste segregation.Mixed wastes cost more to manage. Be sure tosegregate infectious from hazardous waste. Allempty bags, packages, and containers thatcontained hazardous materials should be fullysegregated from those that contained nonhaz-

35

ardous materials. Keep different solvent wastesdue to equipment cleanup segregated. If youmix different kinds of wastes, you reducerecycling potential, and if the chemicals areincompatible, a violent reaction can occur, i.e.,strong acids and bases together. Keep aqueouswastes associated with equipment cleanupsegregated from the solvent wastes. Keep spentalkaline solutions segregated from therinsewater streams.

A vapor recovery system for storage tanks canhelp reduce evaporative losses. Routine moni-toring of all above and below ground storagetanks is essential to prevent major lossesthrough leaks, and is required by law.

Document individual wastes with their sourcesof origin and eventual disposal, along withincurred disposal costs. Computerized wastedocumentation and control can help track thewastes in the process and can help in undertak-ing control strategies.

Store appropriate wastes in secondary contain-ment. The manual iron-cyanide test yields aconcentrated cyanide solution that should becollected, stored in secondary containmentsegregated from all acidic solutions, and dis-posed of as hazardous waste.

STORAGE LIMITATIONSIf you generate less than 1000 kilograms ofhazardous waste per month and the quantityaccumulated onsite never exceeds 6000 kilo-grams at any one time, you may store up to6000 kilograms of hazardous waste or onekilogram of extremely hazardous waste onsitefor up to 180 days before shipping offsite. If it isto be shipped further than 200 miles away, thenyou have up to 270 days to ship it offsite.

If you generate greater quantities of hazardouswaste than explained above, you may storewhatever quantity of hazardous waste or onekilogram of extremely hazardous waste for upto 90 days.

Either of the generators above can use satelliteaccumulation, where you may store up to 55

gallons of hazardous waste or one quart ofextremely hazardous waste for each wastestream at or near the generation location for upto a year.

Storage of hazardous waste for longer thanthese specified times, requires an appropriatepermit or variance. Title 22, California Code ofRegulations (CCR), Section 66262.34 specifiesthe allowable storage times for hazardouswaste. Contact your local Department regionalduty officer for information on applying for apermit. Contact your local environmentalhealth office for more information on localrequirements.

LAB PACKSWastes from laboratories, nursing units, clinics,and storage areas are often placed in “labpacks” for disposal.

Lab packs are drums containing small bottles,vials, cans, and other containers of waste.

When preparing lab packs, wastes are segre-gated so that the lab pack contents arecompatible.

Lab packs contain absorbent cushioning toprevent breakage and to absorb leakage ofliquid contents.

Lab packs are shipped offsite to a Class 1 land-fill or to a waste treatment or incinerationfacility.

36

/ / /

Table 1: How do you store your raw materials andhazardous wastes?

Check the boxes that apply to your storage area(s).

Storage

Indoors

Outdoors

Covered

Uncovered

DikedConcretePad

DirtSurface

AsphaltSurface

Locked

Unlocked

Comments

Some fire departmentsrecommend storing flammablewastes outdoors to reduce firedanger, but remember to followthe other storage hints.

A covered storage area isimportant because rain water canincrease your waste volumes orcontaminate raw materials. Also,exposure to sunlight can changethe characteristics of raw materialsor dangerously raise the pressureinside sealed containers. Youshould keep individual containerscovered to prevent evaporationand spills. Uncovered storagerequires extensive permitting andis not recommended.

A diked concrete pad will containspills better than asphalt or dirt.

Storage of materials on dirtsurfaces should always beavoided. In addition to potentialground contamination, moisturecollecting under drums can lead tocorrosion and failure of the drum.For facilities with limited space,combination pallet/ containmentsystems are available.

Without secure storage facilities,some unscrupulous hazardouswaste generators may deposittheir wastes in your containers,increasing your disposal costs.

HazardousWaste

RawMaterials

37

After reading Section I, note your Waste Mini-mization Options in Table 2. Then use thefollowing scores to evaluate your optionsfurther. Each option will be rated and given apoint score in four areas:

1) Where does the option fit in the WasteMinimization Hierarchy?1 to 5 points

2) What is the option’s Implementation Poten-tial?0 - 4 points

3) What is the Type of Option?1 - 4 points

4) How much does the Option Cost?1 - 4 points

Add up the point scores for each option. InSection 3 you will examine more closely thosespecific waste reduction options that score thehighest. And, you can drop from further con-sideration any options that have no implemen-tation potential.

1) Waste Minimization HierarchyThe waste minimization hierarchy (WMH)consists of the following, which are listed in thepreferred order.

SR = Source Reduction = 5 pointsRR = Resource Recovery = 4 pointsRI = Recycling (in-process) = 4 points

RE = Recycling (end-of-pipe) = 3 pointsTI = Treatment (in-process) = 2 points

TE = Treatment (end-of-pipe) = 1 point

2) Implementation PotentialThe implementation potential (IP) is the chancethat you believe an option has of being used inyour hospital:

High = 4 pointsMedium = 3 points

Low = 2 pointsNone = 0 points

For options that you evaluate as “none” orhaving no potential of being implemented intoyour hospital, no further evaluation is neces-sary. However, keep track of such optionsbecause you may wish to reconsider them at alater date if circumstances at your hospital havechanged.

3) Type of Option“Type of Option”” refers to what the optionconsists of, and what level of effort is requiredto put it to use. Four classes or types of optionswere developed. You may feel that a furtherbreakdown is necessary, or may want to estab-lish your own classes. Feel free to makechanges since only you know about your indi-vidual hospital practices. The four classes are:

P/P = Policy or Procedural Change = 4 pointsPM = Process Modification = 3 pointsEM = Equipment Modification = 2 pointsNE = New Equipment = 1 point

4) Cost of Option“Cost of Option” refers to a rough idea of whatyou believe it will cost to implement each wastereduction option. Specific cost details will beestimated later in Section 3.

None or no cost = 4 pointsLow cost = 3 points

Medium cost = 2 pointsHigh cost = 1 point

Total Point ScoreEvaluate each option in the four areas, add uptheir scores, and complete the table. Review thetable to identify the options with the highestscores. A score of 17 is possible.

This is a preliminary analysis of the options toquickly identify those which are desirable forimplementating into your hospital. A moredetailed study into the costs of each optionshould be conducted in Section 3 to see exactlyhow the option will affect your hospital finan-cially and the option’s payback period.

SECTION 2: EVALUATION OF WASTE MINIMIZATION OPTIONS

38

The above classes and point values for each areaare not hard and fast rules, only guidelines. Ifyou feel you have more than four ways toevaluate options, develop your own classes andtheir respective point values.

Remember, the primary purpose of this part ofthe Guide is to stimulate your thinking aboutwhich waste minization options make the mostsense within your hospital.

39

Exa

mp

le:

Was

te M

inim

izat

ion

Op

tio

n E

valu

atio

n

Exa

mpl

e:

Eva

luat

e th

e fo

llow

ing

two

optio

ns t

o de

term

ine

the

Was

te M

inim

izat

ion

optio

n th

at w

ould

be

the

mos

t at

trac

tive.

1)

Sta

rt a

Firs

t-in

Firs

t-ou

t M

ater

ial

usag

e po

licy.

2)

Inst

all

equi

pmen

t to

rec

ycle

for

mal

in o

nsite

.

Don

e Y

et?

Cos

tW

MH

S

core

IP S

core

Opt

ion

Typ

eO

ptio

n C

ost

Tot

al

Sco

re

Was

te M

inim

izat

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Tec

hniq

ueY

es/N

o or

NA

Dol

lar

Am

ount

to

Imp

lem

en

t

SR

=5

RR

/RI=

4

RE

=3

TI=

2

T

E=

1

Hig

h=4

Med

=3

Low

=2

No

n=

0

Cha

nge

Pro

cedu

re=

4 C

hang

e P

roce

ss=

3

C

hang

e E

quip

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t=2

N

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=3

Med

=2

Hig

h=

1

1)

Firs

t-in

Firs

t-ou

t M

ater

ial

usag

e po

licy

No

$0

SR

(5)

H(4

)P

/P(4

)N

(4)

17

2)

Rec

ycle

for

mal

in o

nsite

No

$1

5,0

00

RE

(3)

H(4

)N

E(1

)M

(2)

9

Aft

er t

otal

ing

the

scor

es,

you

can

see

that

im

plem

entin

g a

first

-in

first

-out

pol

icy

shou

ld b

e im

plem

ente

d be

fore

rec

yclin

gfo

rmal

in o

nsite

. T

he n

ext

step

is

furt

her

eval

uatio

n of

the

eco

nom

ic f

easi

bilit

y an

d as

soci

ated

pay

back

per

iod

usin

g T

able

3:

Eva

luat

ion

of C

osts

and

Sav

ings

.

Tab

le 2

W

aste

Min

imiz

atio

n O

pti

on

Eva

luat

ion

40

Don

e Y

et?

Cos

tW

MH

S

core

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Sco

reO

ptio

n

Typ

eO

ptio

n C

ost

Tot

al

Sco

re

Was

te M

inim

izat

ion

Tec

hniq

ueY

es/N

o or

NA

Dol

lar

Am

ount

to

Imp

lem

en

t

SR

=5

RR

/RI=

4

RE

=3

TI=

2

T

E=

1

Hig

h=4

Med

=3

Low

=2

No

n=

0

Cha

nge

Pro

cedu

re=

4 C

hang

e P

roce

ss=

3

Cha

nge

Equ

ipm

ent=

2

New

Equ

ipm

ent=

1

Non

e=4

Low

=3

Med

=2

Hig

h=

1M

anag

emen

t P

ract

ices

* E

stab

lishe

d w

aste

min

imiz

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n pr

ogra

mN

/A*

Mat

eria

l ba

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rmed

N/A

* E

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/A*

Reg

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ory

com

plia

nce

N/A

* Lo

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dep

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Dat

a sh

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(M

SD

Ss)

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mat

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ater

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Inv

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ry a

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Inst

all

com

pute

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vent

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stor

age

SR

(5)

* W

hen

appr

opria

te,

use

"JIT

" or

"Ju

st i

n T

ime"

ord

erin

gS

R (

5)*

Insp

ect

raw

mat

eria

ls t

o en

sure

are

not

dam

aged

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(5)

* "F

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-in,

fir

st-o

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usag

e of

all

mat

eria

lsS

R (

5)*

Labe

l an

d da

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ials

whe

n re

ceiv

edS

R (

5)*

Per

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c in

spec

tions

of

mat

eria

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R (

5)*

Sto

re m

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in

reus

able

con

tain

ers

SR

(5)

* S

tore

haz

ardo

us m

ater

ials

aw

ay f

rom

non

haza

rdou

sS

R (

5)*

Seg

rega

te d

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ent

type

s of

mat

eria

ls/c

hem

ical

sS

R (

5)*

Red

uce

stor

age

area

tra

ffic

SR

(5)

* U

se a

dus

t re

cove

ry s

yste

mS

R (

5)

Pag

e 1

Tab

le 2

W

aste

Min

imiz

atio

n O

pti

on

Eva

luat

ion

41

Don

e Y

et?

Cos

tW

MH

S

core

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Sco

reO

ptio

n

Typ

eO

ptio

n C

ost

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re

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izat

ion

Tec

hniq

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NA

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lar

Am

ount

to

Imp

lem

en

t

SR

=5

RR

/RI=

4

RE

=3

TI=

2

T

E=

1

Hig

h=4

Med

=3

Low

=2

No

n=

0

Cha

nge

Pro

cedu

re=

4 C

hang

e P

roce

ss=

3

Cha

nge

Equ

ipm

ent=

2

New

Equ

ipm

ent=

1

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Low

=3

Med

=2

Hi g

h=

1M

ater

ials

Inv

ento

r y a

nd S

tora

ge (

cont

inue

d)*

Lim

it ra

w m

ater

ials

acc

ess

SR

(5)

* M

inim

ize

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k on

han

dS

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5)*

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urn

obso

lete

raw

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l to

sup

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5)*

Use

sup

plie

s on

l y f

or t

heir

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nded

pur

pose

SR

(5)

* S

tack

con

tain

ers

safe

l yS

R (

5)*

Sto

re m

ater

ials

as

dire

cted

by

man

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ture

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R (

5)*

Pro

vide

sec

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ent

as a

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R (

5)*

Use

fle

xibl

e pa

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g m

ater

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for

for

mal

dehy

de

spec

imen

sS

R (

5)* * * D

rum

s an

d C

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iner

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Sto

re d

rum

s on

pal

lets

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(5)

* R

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n em

pty

drum

s to

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R (

5)*

Pro

vide

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ace

betw

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drum

sS

R (

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pose

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pill

Con

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* Li

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s b y

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truc

ksS

R (

5)*

Con

duct

pro

per

spill

cle

anup

SR

(5)

* In

stal

l sp

ill c

onta

inm

ent

SR

(5)

Pag

e 2

2 T

able

W

aste

Min

imiz

atio

n O

pti

on

Eva

luat

ion

42

Don

e Y

et?

Cos

tW

MH

S

core

IP

Sco

reO

ptio

n

Typ

eO

ptio

n C

ost

Tot

al

Sco

re

Was

te M

inim

izat

ion

Tec

hniq

ueY

es/N

o or

NA

Dol

lar

Am

ount

to

Imp

lem

en

t

SR

=5

RR

/RI=

4

RE

=3

TI=

2

T

E=

1

Hig

h=4

Med

=3

Low

=2

No

n=

0

Cha

nge

Pro

cedu

re=

4 C

hang

e P

roce

ss=

3

Cha

nge

Equ

ipm

ent=

2

New

Equ

ipm

ent=

1

Non

e=4

Low

=3

Med

=2

Hig

h=

1S

pill

Con

trol

(co

ntin

ued)

* C

ondu

ct p

ract

ice

drill

s fo

r m

ajor

spi

llsS

R (

5)*

Insp

ect

tank

s fo

r co

rros

ion

or s

tres

sS

R (

5)*

Use

spi

gots

, pu

mps

, pi

ping

, or

fun

nels

for

dis

pens

ing

or

tran

sfer

ring

was

te m

ater

ials

SR

(5)

* K

eep

stor

age

area

s cl

ear

and

surf

aces

eve

nS

R (

5)*

Sto

re c

hem

ical

s pr

oper

lyS

R (

5)* * * H

azar

dous

Was

te M

inim

izat

ion

Fac

ilitie

s*

Pro

per

inve

ntor

y co

ntro

l fo

r ae

roso

lsS

R (

5)*

Rec

ycle

aer

osol

can

sR

E(3

)*

Rec

harg

e ba

tterie

sS

R (

5)*

Rec

ycle

bat

terie

sR

E(3

)*

Rep

lace

mer

curic

oxi

de b

atte

ries

with

zin

c ai

r ba

tterie

sS

R (

5)*

Inst

all

floor

ing

and

coun

ter

tops

res

ista

nt t

o ch

emic

als

SR

(5)

* R

epla

ce h

alon

fire

ext

ingu

ishe

rsS

R (

5)*

Con

trol

cor

rosi

on i

n ho

t w

ater

sys

tem

sS

R (

5)*

Elim

inat

e flo

or w

axes

or

wax

str

ippe

rs c

onta

inin

g zi

ncS

R (

5)*

Elim

inat

e cl

eani

ng p

rodu

cts

cont

aini

ng t

ribu

tyl

tinS

R (

5)*

Use

phe

nolic

com

poun

ds o

nly

in c

ritic

al a

reas

SR

(5)

*T

able

2

Was

te M

inim

izat

ion

Op

tio

n E

valu

atio

n

Pag

e 3

2 T

able

W

aste

Min

imiz

atio

n O

pti

on

Eva

luat

ion

43

Don

e Y

et?

Cos

tW

MH

S

core

IP

Sco

reO

ptio

n

Typ

eO

ptio

n C

ost

Tot

al

Sco

re

Was

te M

inim

izat

ion

Tec

hniq

ueY

es/N

o or

NA

Dol

lar

Am

ount

to

Imp

lem

en

t

SR

=5

RR

/RI=

4

RE

=3

TI=

2

T

E=

1

Hig

h=4

Med

=3

Low

=2

No

n=

0

Cha

nge

Pro

cedu

re=

4 C

hang

e P

roce

ss=

3

Cha

nge

Equ

ipm

ent=

2

New

Equ

ipm

ent=

1

Non

e=4

Low

=3

Med

=2

Hig

h=

1F

acili

ties

(con

tinue

d)*

Sep

arat

e th

erm

omet

ers

and

rags

use

d to

cle

an u

p ha

zard

ous

spill

s ou

t be

fore

doi

ng

laun

dry

SR

(5)

* M

anag

e la

undr

y ch

emic

als

thro

ugh

wor

ker

trai

ning

, pr

epac

kage

d la

undr

y ch

emic

als,

and

/or

an a

utom

ated

la

undr

y ch

emic

al f

eed

syst

em.

SR

(5)

* In

stal

l tu

nner

was

hers

SR

(5)

* R

ecyc

le f

luor

esce

nt t

ubes

RE

(3)

* R

epla

ce m

ercu

ry l

ight

sS

R (

5)*

Rec

harg

e la

ser

jet

cart

ridge

sS

R (

5)*

Rep

lace

oil-

base

d pa

ints

with

wat

er-b

ased

pai

nts

SR

(5)

* P

urch

ase

pain

t on

ly i

n ne

eded

qua

ntiti

esS

R (

5)*

Use

a p

aint

gun

was

her

and

recy

cler

RR

(4)

* C

ontr

ol o

vers

pray

whe

n us

ing

a pa

int

gun

SR

(5)

* U

se p

etro

leum

dis

tilla

tes

or o

ther

alte

rnat

ive

clea

ning

m

etho

ds f

or p

arts

was

hing

SR

(5)

* P

rope

rly

loca

te/m

aint

ain

solv

ent

part

s w

ashe

r st

atio

nsS

R (

5)*

Use

non

-che

mic

al p

est

cont

rol

met

hods

SR

(5)

* U

se l

ess

toxi

c pe

stic

ides

SR

(5)

* D

o no

t sp

ill c

onte

nts

of s

ewer

lin

es,

trap

s, o

r su

mps

SR

(5)

* * * *T

able

2

Was

te M

inim

izat

ion

Op

tio

n E

valu

atio

n

Pag

e 4

2 T

able

W

aste

Min

imiz

atio

n O

pti

on

Eva

luat

ion

44

Don

e Y

et?

Cos

tW

MH

S

core

IP

Sco

reO

ptio

n

Typ

eO

ptio

n C

ost

Tot

al

Sco

re

Was

te M

inim

izat

ion

Tec

hniq

ueY

es/N

o or

NA

Dol

lar

Am

ount

to

Imp

lem

en

t

SR

=5

RR

/RI=

4

RE

=3

TI=

2

T

E=

1

Hig

h=4

Med

=3

Low

=2

No

n=

0

Cha

nge

Pro

cedu

re=

4 C

hang

e P

roce

ss=

3

Cha

nge

Equ

ipm

ent=

2

New

Equ

ipm

ent=

1

Non

e=4

Low

=3

Med

=2

Hig

h=

1La

bora

tori

es*

Sha

re c

hem

ical

s be

twee

n la

bora

torie

sS

R (

5)*

Rep

lace

alc

ohol

-bas

ed d

isin

fect

ants

with

son

ic o

r st

eam

cl

eani

ngS

R (

5)*

Use

sub

situ

tes

for

chro

mic

aci

d an

d su

lfuric

aci

d fo

r gl

assw

are

clea

ning

SR

(5)

* U

se b

iode

grad

able

det

erge

nts

and/

or a

queo

us r

eage

nts

as a

cle

anin

g su

bstit

ute

SR

(5)

* U

se c

ount

ercu

rren

t cl

eani

ng w

ith s

olve

nts

SR

(5)

* S

witc

h to

one

typ

e of

sol

vent

SR

(5)

* T

rain

sta

ff in

pro

per

"pre

-was

h" p

roce

dure

s fo

r au

tocl

ave

labw

are

was

hers

SR

(5)

* S

ubst

itute

tun

gste

n fo

r m

ercu

ry i

n an

alyz

ing

GI

tube

sS

R(5

)*

Sub

stitu

te m

ercu

ry t

herm

omet

ers

in l

ab o

vens

and

wat

er

bath

s w

ith a

lcoh

ol (

red)

and

dig

ital

ther

mom

eter

sS

R(5

)*

Use

cel

l so

rtin

g an

d co

untin

g in

stru

men

ts t

hat

do n

ot u

se

cyan

ide

SR

(5)

* In

stal

l au

tom

ated

sys

tem

s or

oth

er i

nstr

umen

tatio

n fo

r la

b ch

emis

try

anal

yses

SR

(5)

* In

stal

l an

aut

omat

ic s

lide

stai

ner

SR

(5)

* U

se m

icro

anal

ytic

al t

echn

ique

sS

R (

5)* * *

Tab

le 2

W

aste

Min

imiz

atio

n O

pti

on

Eva

luat

ion

Pag

e 5

2 T

able

W

aste

Min

imiz

atio

n O

pti

on

Eva

luat

ion

45

Don

e Y

et?

Cos

tW

MH

S

core

IP

Sco

reO

ptio

n

Typ

eO

ptio

n C

ost

Tot

al

Sco

re

Was

te M

inim

izat

ion

Tec

hniq

ueY

es/N

o or

NA

Dol

lar

Am

ount

to

Imp

lem

en

t

SR

=5

RR

/RI=

4

RE

=3

TI=

2

T

E=

1

Hig

h=4

Med

=3

Low

=2

No

n=

0

Cha

nge

Pro

cedu

re=

4 C

hang

e P

roce

ss=

3

Cha

nge

Equ

ipm

ent=

2

New

Equ

ipm

ent=

1

Non

e=4

Low

=3

Med

=2

Hig

h=

1La

bora

tori

es (

cont

inue

d)*

Sub

stitu

te c

arbo

n di

oxid

e fo

r et

hyl

ethe

r as

a l

abor

ator

y eu

than

izin

g ag

ent

SR

(5)

* S

ubst

itute

chl

orof

orm

with

dic

hlor

omet

hane

in

lab

phas

e e

xtra

ctio

ns

SR

(5)

* S

ubst

itute

filt

er p

repa

ratio

n w

ith c

ytos

pin

or t

hin

prep

te

chn

olo

gy

SR

(5)

*Pro

duce

ato

mic

abs

orpt

ion

(AA

) st

anda

rds

only

as

need

edS

R(5

)*

Per

form

ana

lysi

s of

chl

orid

e by

ion

-sel

ectiv

e el

ectr

ode

SR

(5)

* U

tiliz

e gl

ucos

e te

sts

with

out

zinc

SR

(5)

* U

se a

ltern

ativ

es t

o B

ouin

s so

lutio

nS

R (

5)*

Red

uce

chem

ical

s us

ed in

lab

proc

esse

sS

R(5

)*

Min

imiz

e us

e of

Zan

ker's

sol

utio

n an

d M

ercu

ry B

-5S

R (

5)*

Pre

serv

e st

ool

sam

ples

with

alte

rnat

ives

to

mer

cury

pol

y vi

nyl

alco

hol

SR

(5)

* In

vest

igat

e al

tern

ativ

es t

o T

him

eris

olS

R(5

)*

Pro

perly

dis

pose

of

glut

aral

dehy

deT

E(1

)*

Reu

se f

orm

alde

hyde

in

auto

pysy

and

pat

holo

gy l

abR

R(4

)*

Con

trol

airb

orne

em

issi

ons

from

for

mal

dehy

deS

R(5

)*

Use

app

ropr

iate

ly s

ized

(th

e sm

alle

st)

form

alde

hyde

co

ntai

ners

for

pro

cess

esS

R(5

)* * *

Tab

le 2

W

aste

Min

imiz

atio

n O

pti

on

Eva

luat

ion

Pag

e 6

2 T

able

W

aste

Min

imiz

atio

n O

pti

on

Eva

luat

ion

46

Don

e Y

et?

Cos

tW

MH

S

core

IP

Sco

reO

ptio

n

Typ

eO

ptio

n C

ost

Tot

al

Sco

re

Was

te M

inim

izat

ion

Tec

hniq

ueY

es/N

o or

NA

Dol

lar

Am

ount

to

Imp

lem

en

t

SR

=5

RR

/RI=

4

RE

=3

TI=

2

T

E=

1

Hig

h=4

Med

=3

Low

=2

No

n=

0

Cha

nge

Pro

cedu

re=

4 C

hang

e P

roce

ss=

3

Cha

nge

Equ

ipm

ent=

2

New

Equ

ipm

ent=

1

Non

e=4

Low

=3

Med

=2

Hig

h=

1La

bora

tori

es (

cont

inue

d)*

Tre

at w

aste

for

mal

dehy

deT

E(1

)*

Rec

ycle

for

mal

dehy

deR

E(3

)*

Util

ize

form

alin

sub

stitu

tes

SR

(5)

* R

euse

was

te s

olve

nt s

olut

ions

in

a "s

tep

dow

n" m

etho

dR

I(4)

* R

epla

ce c

hlor

inat

ed s

olve

nts

with

non

chlo

rinat

ed s

olve

nts

SR

(5)

* R

epla

ce p

etro

leum

hyd

roca

rbon

s w

ith s

impl

e al

coho

ls a

nd

keto

ne

sS

R(5

)*

Use

a b

iode

grad

able

sci

ntill

atio

n flu

id i

nste

ad o

f a

xyle

ne/t

olue

ne b

ased

sci

ntill

atio

n flu

idS

R(5

)*

Min

imiz

e ex

trac

tion

sam

ple

size

sS

R (

5)*

Use

cal

ibra

ted

equi

pmen

t to

dis

pens

e so

lven

tsS

R(5

)*

Red

uce

quan

titie

s of

rea

gent

s us

ed i

n ro

utin

e pr

oces

ses

SR

(5)

* S

elec

t co

ntai

ners

tha

t m

inim

ize

solu

tions

use

dS

R(5

)*

Filt

er a

nd c

over

bat

hs b

etw

een

uses

to

exte

nd b

ath

life

SR

(5)

* S

tain

slid

es w

ith d

rops

ins

tead

of

a di

ppin

g ba

thS

R(5

)*

Red

uce

bath

siz

es f

or f

ixin

g/rin

sing

of

mic

rosc

ope

slid

esS

R (

5)*

Exp

erim

ent

with

pur

ity r

equi

rem

ents

for

sol

vent

sS

R(5

)*

Rec

ycle

sol

vent

s on

site

RE

(3)

* R

ecyc

le s

olve

nts

offs

iteR

E(3

)* * *

Tab

le 2

W

aste

Min

imiz

atio

n O

pti

on

Eva

luat

ion

Pag

e 7

2 T

able

W

aste

Min

imiz

atio

n O

pti

on

Eva

luat

ion

47

Don

e Y

et?

Cos

tW

MH

S

core

IP

Sco

reO

ptio

n

Typ

eO

ptio

n C

ost

Tot

al

Sco

re

Was

te M

inim

izat

ion

Tec

hniq

ueY

es/N

o or

NA

Dol

lar

Am

ount

to

Imp

lem

en

t

SR

=5

RR

/RI=

4

RE

=3

TI=

2

T

E=

1

Hig

h=4

Med

=3

Low

=2

No

n=

0

Cha

nge

Pro

cedu

re=

4 C

hang

e P

roce

ss=

3

Cha

nge

Equ

ipm

ent=

2

New

Equ

ipm

ent=

1

Non

e=4

Low

=3

Med

=2

Hig

h=

1N

ursi

ng,

Pat

ient

Car

e, P

harm

acy,

Phy

sici

ans

* S

egre

gate

che

mot

hera

py w

aste

s fr

om o

ther

was

tes

SR

(5)

* P

urch

ase

chem

othe

rapy

dru

gs i

n co

ntai

ner

size

s th

at

perm

it fo

rmul

atio

n of

dai

ly d

osag

es w

ith a

min

imum

of

left

ove

r co

nte

nts

SR

(5)

* M

inim

ize

hood

cle

anin

gS

R(5

)*

Sub

stitu

te e

lect

roni

c se

nsin

g de

vice

s fo

r m

ercu

ry-

cont

aini

ng d

evic

esS

R(5

)*

Rec

ycle

mer

cury

RE

(3)

* H

ave

mer

cury

spi

ll cl

eanu

p ki

ts a

vaila

ble

SR

(5)

* S

ubst

itute

And

erso

n T

ubes

for

Can

ter

Tub

es

SR

(5)

* S

ubst

itute

zin

c ai

r ba

tter

ies

for

mer

cury

bat

teri

es i

n te

lem

etr

y u

nits

SR

(5)

* U

se l

ow-le

akag

e an

esth

etic

equ

ipm

ent

SR

(5)

* R

egul

ar i

nspe

ctio

ns a

nd m

aint

enan

ce o

f an

esth

esia

eq

uipm

ent,

sca

veng

ing

equi

pmen

t, a

nd v

entil

atio

n sy

stem

sS

R(5

)*

Em

ploy

low

-leak

age

anes

thet

ic p

ract

ices

SR

(5)

* In

stal

l re

vers

e os

mos

is (

RO

) w

ater

sup

ply

equi

pmen

t fo

r di

alys

is m

achi

nes

SR

(5)

* D

eter

min

e m

inim

um s

tren

gth

of f

orm

alin

and

min

imum

cl

eani

ng f

requ

ency

of

dial

ysis

mac

hine

sS

R(5

)* * *

Tab

le 2

W

aste

Min

imiz

atio

n O

pti

on

Eva

luat

ion

Pag

e 8

2 T

able

W

aste

Min

imiz

atio

n O

pti

on

Eva

luat

ion

48

Don

e Y

et?

Cos

tW

MH

S

core

IP

Sco

reO

ptio

n

Typ

eO

ptio

n C

ost

Tot

al

Sco

re

Was

te M

inim

izat

ion

Tec

hniq

ueY

es/N

o or

NA

Dol

lar

Am

ount

to

Imp

lem

en

t

SR

=5

RR

/RI=

4

RE

=3

TI=

2

T

E=

1

Hig

h=4

Med

=3

Low

=2

No

n=

0

Cha

nge

Pro

cedu

re=

4 C

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51

Use the worksheet in this section to make roughestimates of required investments, annualsavings, and payback periods for each wastereduction option that you wish to evaluate.Compare both the investment amounts andpayback periods for the options when decidingwhich ones make the most sense for yourhospital. Photocopy the form if you needextras.

SECTION 3: EVALUATION OF COSTS AND SAVINGSThis worksheet does not take into accountamortization, depreciation, the cost of money, ortax factors. You may wish to consider theseelements for options where the capital expendi-ture is significant, or outside financing is re-quired.

52

Annual Cost Savings:

Material or ServiceUtilities

Chemicals

Operation/Maint. Labor

Repair Supplies

Waste Handling

Fees/Penalties

Misc.

Total Annual Amounts

(*Use negative numbers to indicate costs that will increase.)

/ / /

TABLE 3: Evaluation of Costs and Savings

PresentSystem

($/Year)

Payback period = = Years

Waste Reduction Technique:

Capital Investment:Equipment Costs

Freight and Handling

Installation

Shop Modification & Utilities

Construction Materials

OtherInstallation Costs:

Training CostInitial Spare PartsValue of Lost Production Time

Other Costs:Total Capital Investment:

NewSystem

($/Year)

Estimated*Savings($/Year)

Capital InvestmentTotal Annual Savings

A-1

APPENDIX ASELF-AUDIT GUIDE

HAZARDOUS WASTE INVENTORYFOR WASTE MINIMIZATIONASSESSMENT

A-2

Page ___ of ___

HAZARDOUS CHEMICAL INVENTORYComplete separate forms for each location where hazardous chemicals are used or stored.

Process step or location:

Person completing inventory:

Telephone number: Date:

Chemical1

Quantityused per

year2

Maximumquantitystored2

Hazard3 Comments

1 Indicate whether gas, liquid, or solid.2 Indicate pounds, gallons, or cubic feet.3 Indicate toxic, corrosive, ignitable, or reactive.

A-3

Page ___ of ___

HAZARDOUS WASTE GENERATION INVENTORYComplete separate forms for each process step or location where hazardous waste is generated.

Process step or location:



Hazardous waste1

Quantitygeneratedper year2

Fate3 WasteCode4

Comments

1 Indicate source and whether gas, liquid, sludge, or solid.2 Indicate whether pounds, gallons, or cubic feet.3 Indicate whether onsite or offsite reuse, recycle, or treatment; sewer; or disposal.4 California Hazardous Waste Code Number and USEPA Hazardous Waste Identification Number,as available, from the Uniform Hazardous Waste Manifest or other waste tracking documents.5 Indicate whether toxic, corrosive, ignitable, or reactive.

Hazard5

A-4

Page ___ of ___

HAZARDOUS WASTE INTERNAL MANIFESTComplete separate forms for each location where hazardous waste is accumulated.

Location:



Dategenerated

Chemical Quantity1 Phase2 Comments4

1 Indicate whether pounds, gallons, or cubic feet.2 Indicate whether gas, liquid, sludge, or solid.3 Indicate whether toxic, corrosive, ignitable, or reactive.4 Contact your waste coordinator when manifest is complete or wastes need to be picked up.

Hazard3

B-1

APPENDIX B

ADDITIONAL SB-14REQUIREMENTSIf you are completing this Self-Audit Guide for purposes of the State’s Hazardous Waste SourceReduction and Management Review Act of 1989 (SB 14), you must also include GeneratorInformation, Evaluation of Source Reduction Measures, Implementation Timetable, NumericalGoal, and Certification. For your convenience, an example of each has been taken from theHazardous Waste Source Reduction Compliance Checklist (Document No. 004, September 1997),to assist you in meeting the requirements under SB 14 of 1989. These examples are providedimmediately following this page.

B-2B-2

GENERATOR INFORMATION

Company Name:

Location Address: Mailing Address:

Generator USEPA ID Number: SIC Code:

Contact Person: Telephone:

Total quantity of hazardous waste generated in the reporting year, tons 1:

California Hazardous Waste Code Numbers or USEPA Hazardous Waste Identification Numbers 2:

Waste Description:

1 Reporting year is the calendar year immediately preceding the year in which your HazardousWaste Source Reduction Review and Plan is to be prepared.2 Alternatively, these code numbers can be listed in Appendix A, page A-3, Hazardous WasteGeneration Inventory.

B-3

EVALUATION OF SOURCEREDUCTION MEASURESAs part of completing the Hazardous WasteSource Reduction Review and Plan (Plan), youhad identified potential source reduction oppor-tunities. If you are completing this Self-AuditGuide for the purposes of meeting the require-ments of the Hazardous Waste Source Reduc-tion and Management Review Act of 1989 (SB14), you must include an evaluation of yoursource reduction options and select those youwish to implement. The listings providedbelow can guide you in determining whetheryou have met the requirements of SB 14 in yourevaluation.

Source reduction is defined in the law as anyaction which causes a net reduction of thegeneration of hazardous waste, or any actiontaken before the hazardous waste is generatedthat results in the lessening of the propertieswhich cause it to be classified as a hazardouswaste. Specific source reduction measures maybe grouped under five source reduction ap-proaches:• input change• operational improvement• production process change• product reformulation• administrative steps

However, source reduction measures are noneof the following:• any action taken after a hazardous waste is

generated• any action that concentrates the constituents

of a hazardous waste to reduce its volume orthat dilutes the hazardous waste to reduce itshazardous characteristics

• any action that shifts hazardous wastes fromone environmental medium to anotherenvironmental medium

• treatment

There are a variety of factors for evaluatingpotential source reduction measures, including:• expected change in the amount of hazardous

waste generated• technical feasibility• economic feasibility• effect on product quality• employee health and safety considerations• requirements for permits, variances, and

compliance schedules of applicable agencies• releases and discharges to all media

You are not limited to the factors listed above.You may develop additional factors that youfeel are important in developing a successfulsource reduction program at your site. Ex-amples of additional factors you may considerinclude:• reduction in the hazardous characteristic of

the waste• previous success of the measure within your

organization• previous success of the measure in other

industries• length of implementation period• ease of implementation

You can also use the additional informationprovided in the Checklist and AssessmentManual or Waste Audit Study Report specific toyour industry, to assist you in evaluating yoursource reduction options. Or, you can developyour own categories and criteria if you feel youhave better ways to evaluate your options.

B-4

IMPLEMENTATION TIMETABLE

Source reduction measures you havechosen to implement at your site

The dates when you plan to begin imple-menting each measure and the date whenthe measure will be operational

B-5

Every generator who is subject to SB 14 must prepare a four-year numerical source reduction goal.The goal is included in a generator’s Checklist and Assessment Manual, Waste Audit Study Report,or full Plan, as applicable.

The goal is not simply a reflection of your intended source reduction under SB 14, rather it is yourestimate of the source reduction that your site could optimally strive to achieve over the next fouryears. The goal, a single numerical percentage, would reflect your organization’s source reductionvision and commitment. The goal must reflect your company’s waste stream reductions due onlyto source reduction and would exclude effects due to production variation or economic influences.

For example, Source Reduction Goal(%) =

The four-year numerical source goal for this site is:

______________% for the years ________ to ________ (your four-year planning period).

CERTIFICATIONThere are two certifications required by regulations - a technical certification and a financial certifi-cation. (Section 67100.10 Title 22 California Code of Regulations.)

TECHNICAL CERTIFICATION: If the Checklist and Assessment Manual or the Waste Audit StudyReport is used to meet the requirements of SB 14, the completed document must be reviewed andcertified by any one of the following persons for technical completeness. Check the appropriatebox and provide the information below:

an engineer who is registered as a professional engineer pursuant to section 6762 of theBusiness and Professions Codean environmental assessor who is registered pursuant to section 25570 of the Health andSafety Codean individual who is responsible for the processes and operations of the site

Please print the name of the person certifying this document:

Name:

Title:

Signature: Date: / /

NUMERICAL GOAL

Total hazardous waste generation reduced by optimizing source reduction practices

Total hazardous waste generation if source reduction measures were not considered at your sitex 100%

B-6

FINANCIAL CERTIFICATION: The Checklist and Assessment Manual or Waste Audit StudyReport must be reviewed and certified that the reviewer is made aware of the document contentsand resource commitment. Financial certification shall be made by any one of the following per-sons able to commit company finances. Check the appropriate box and provide the informationbelow:

the ownerthe operatorthe responsible corporate officer of the sitean authorized individual capable of committing financial resources necessary to implementselected source reduction measures.

“I certify that this document and all attachments were prepared under my direction or supervisionin accordance with a system designed to assure that qualified personnel properly gather andevaluate the information submitted. Based on my inquiry of the person or persons who managethe system, or the persons directly responsible for gathering the information, the informationsubmitted is, to the best of my knowledge and belief, true, accurate and complete. I am aware thatthere are significant penalties for making false statements or representations to the Department,including the possibility of fines for criminal violations.

Please print the name of the person certifying this document:

Name:

Title:

Signature: Date: / /

C-1

APPENDIX C

TECHNOLOGYTRANSFERADVISORIES

C-2

Issued To:Trend Scientific, Inc.P.O. Box 120266St. Paul, Minnesota 55122Contact:Steve Dolezal(612) 633-0925

Bruce Chadderdon4803 Lago Vista CircleSan Jose, CA 95129(800) 984-4940Distrib utor:

Baxter Healthcare Corp.1450 Waukegan RoadMcGaw Park, IL 60085

Contact:Customer Service(800) 964-5227Certification No:94-01-008Effective Date:January 2, 1995Expiration Date:January 2, 2000DTSC Contact:Dr. Bruce LaBelle(916) 324-2958

Technology Description: This technology is asimple, batch treatment process for 10 percent Fomalingenerated by medical, educational, and laboratoryfacilities. It chemically treats formaldehyde waste watersin a provided 8 liter or other closed vessel with VYTAC10F in specific ratio to waste and renders it non-hazard-ous. After being tested with an aldehyde test kit, thesolution with inert polymer residues may then be dis-posed of by discharge to the sanitary sewer.

A copy of the published Certification Statement may be obtained by contactingthe Department of Toxic Substances Control at (916) 322-3670 or from theCal/EPA ACCESS computer bulletin board at (916) 322-5041.

Revision August 2, 1996

C-3

CALIFORNIA ENVIRONMENTALPROTECTION AGENCY

DEPARTMENT OF TOXICSUBSTANCES CONTROL

Final Decision to Certify Hazardous WasteEnvironmental Technologies

The California Environmental ProtectionAgency, Department of Toxic Substances Con-trol (Department) has made a final decision tocertify the following company’s hazardouswaste environmental technology listed below:• Trend Scientific, Inc., P.O. Box 120266,

St. Paul, MN 55122: VYTAC 10F, for treating10 percent Formalin generated by medical,dental, and other health care facilities.

Chapter 412, Section 25200.1.5., Health andSafety Code, enacted by Assembly Bill 2060(AB 2060), Weggeland, 1993, authorizes theDepartment to certify hazardous waste environ-mental technologies.

The purpose of the certification program isto provide an in-depth, independent review oftechnologies at the manufacturers’ level tofacilitate regulatory and end-user acceptanceand to promote and foster growth ofCalifornia’s environmental technology industry.

The Department makes no express or im-plied warranties as to the performance of themanufacturer’s product or equipment. The end-user is solely responsible for complying withthe applicable federal, state, and local regula-tory requirements. Certification does not limitthe Department’s authority to require additionalmeasures for protection of public health and theenvironment.

By accepting certification, the manufacturerassumes, for the duration of certification, re-sponsibility for maintaining the quality of themanufactured equipment and materials at alevel equal to or better than was provided toobtain certification and agrees to be subject toquality monitoring by the Department as re-quired by the statute under which certificationis granted.

The Department’s proposed decision tocertify has been previously noticed on October

14, 1994 in the California Regulatory NoticeRegister 94, Volume No. 41-Z. Written com-ments in relation to the proposed certificationreceived during the public review and commentperiod have been duly considered in the finalcertification as presented here. TheDepartment’s final certification shall be effectiveon Monday, January 2, 1995.

Additional information supporting theDepartment’s final certification decisions isavailable for review at:

California Environmental Protection Agency,Department of Toxic Substances Control,Office of Pollution Prevention and TechnologyDevelopment, P.O. Box 806, 301 Capitol Mall,1st Floor Sacramento, CA 95812-0806, Attn: Mr.Lindsee Tanimoto (916) 322-7287

A description of the technology to be certi-fied, the final certification statement and thecertification limitations for the technologies ofeach of the companies listed above follows.

CERTIFICATION PROGRAM (AB 2060) FORHAZARDOUS -WASTE ENVIRONMENTAL

TECHNOLOGIESTECHNOLOGY CERTIFICATION

VYTAC 10FTREND SCIENTIFIC, INC.

MANUFACTURER: Trend Scientific, Inc., P.O. Box 120266,

St. Paul, MN 55122Contact: Mr. Steven M. Dolezal (612) 633-0925

Technology Description:

The VYTAC 10F technology chemically treatsformaldehyde wastewaters in a batch process-ing system, which is a closed vessel, manualtreatment unit. The spent aldehyde solutionsare transferred to the collection vessel withVYTAC 10F and are treated and rendered non-hazardous. After being tested with an aldehydetest kit, the solution with inert polymer residuesmay then be disposed of as a non-hazardouswaste by discharge to the sanitary sewer. Theevaluated reagent for aldehyde waste treatment

CALIFORNIA REGULATORY NOTICE REGISTER 94. VOLUME NO. 48-Z

C-4

was VYTAC 10F. The apparatus utilized withVYTAC 10F is contained in S/P Brand VYTACDaily Disposal System Starter Kit which in-cludes:

—one 3.5 L Neutralizer—one 8 L Reservoir with cover—one measuring cup—one stirring rod—master of “Waste Treatment Log”—instruction sheet

The VYTAC NF Test Kit is available for thesemi-quantitative determination of formalinconcentration in treated waste formaldehydeaqueous solutions. TREND offers Standards of500, 300, 200, and 100 ppm that may be utilizedin the test.

Certification Statement:

VYTAC 10F is hereby certified, pursuant toCalifornia Health and Safety Code Section25200.1.5, by the California Department of ToxicSubstances Control (Department) as a Hazard-ous Waste Treatment Technology when oper-ated, monitored, and maintained according tomanufacturer’s standards and specifications.The certified technology has been determined totreat incremental amounts of 10% Formalin(aqueous solution containing approximately3.75% formaldehyde by weight). The use of theVYTAC 10F process as directed has the potentialto significantly reduce the exposure to aldehydevapors, as well as the need for expensive wastehauling, and allows safe disposal of thesetreated wastes. Based on the certification pro-cess, the Department concludes that the VYTAC10F process appears effective in reducing theconcentration of formaldehyde in 10% formalinto 0.25 ppm. Some Publicly-Owned TreatmentWorks may require a pH adjustment prior todisposal down the drain. If required, the pHmay be adjusted by adding an acid neutralizerlike VYTAC ACX or one of the following:sodium hydroxide solution or sodium carbonatecrystals.

Certification Disclaimer:

The Department believes that themanufacturer’s product and/or equipment,

when used in accordance with themanufacturer’s specifications, can achieve theperformance level set out in this Certification.Said belief is based on a review of the datasubmitted by the proponent, results of onsiteverification tests, and results of the verificationtests performed in the Department’s laboratory.The Department makes no express or impliedwarranties as to the performance of themanufacturer’s product and/or equipment. Nordoes the Department warrant that themanufacturer’s product or equipment is freefrom any defects in workmanship or materialcaused by negligence, misuse, accident or othercauses. This does not constitute an endorsementof the specific product, nor does it intend toexpand existing rights or obligations, waivelegal defenses, or otherwise affect the legalposition of the applicant companies.

Basis for Certification:

The Department reviewed data submittedby the proponent, which included copies ofletters from hospitals, satisfied customers, stateand local agencies, and test results from certi-fied laboratories. The proponent first con-ducted demonstration tests in the presence ofthe Department’s representatives at a StateLaboratory and then, further independentconfirmation/verification tests were performedby the Depart ment’s Hazardous MaterialsLaboratory. Based on the evaluation of provideddata and the results of these tests, the Depart-ment concluded that the VYTAC 10F processreduces the quantities and hazards of 10%Formalin to a fraction of the original amount,suitable for disposal to sanitary sewer.

Regulatory Considerations:

The Department intends to pursue regula-tory certification for this technology after theadoption of regulations for such action. In theinterim, the Department is addressing treatmentof specific aldehyde wastes through Compli-ance Directive (EO-94-005 MM), “Treatment ofFormaldehyde and Glutaraldehyde SterilizingSolutions at Health Care Facilities.”

Users of any 10% Formalin treatment systemmay still be subject to all local discharge limits,


C-5

including pH adjustment. Staff of the State Water Resources Control

Board, Pretreatment Program, have participatedin the certification evaluation, support itsfindings, and have determined that the use ofthis formaldehyde treatment technology pre-sents no burden to normal sewerage and waste-water treatment facilities.

Protection of Human Health and theEnvironment:

Formalin poses acute threats to the respira-tory and digestive systems and is a probablehuman carcinogen. The use of VYTAC 10F, as anintegral part of safe management practices, canprovide valuable risk control and environmen-tal protection. Existing practices in dealingwith 10% Formalin waste include:

1. Uncontrolled or illegal disposal;2. Hazardous waste hauling, followed by off-

site treatment and disposal;3. Burning the waste as a fuel supplement;4. Other treatment technologies.These practices may not reduce occupational

exposures, nor provide equivalent protection tohuman health and the environment. Addition-ally, some practices may subject responsibleparties to State or local agency enforcementactions.

Conclusions and Future Actions:

1. Duration of Certification:This Certification will remain in effect for theperiod of three years from its publication inthe California Regulatory Notice Register,unless it is revoked for cause.

2. Continuous Quality Control/QualityAssurance:By accepting this Certification, the applicantcompanies accept, for the duration of thiscertification, responsibility for maintainingthe quality of the manufactured equipmentand materials at a level equal or better thanwas provided to obtain this Certification.

3. Monitoring and Self-reporting Actions:The applicant companies have institutedappropriate internal quality control manage-ment systems and procedures, including a

generator’s waste treatment log. This log isconsidered by the Department suitablerecord for monitoring of the treatment andthe generator’s record of performance. TheDepartment may review and evaluate thisrecord of performance and compare it to thestandards and specifications provided toobtain this Certification.

4. Procedure for Modifications and Amend-ments:Modifications and amendments of thiscertification may be requested by the appli-cant companies, and will be processedaccording to the provisions of the statuteunder which this certification is granted.

5. Status as “Pilot Certification”:This Certification is issued as part of the pilotproject for the California EnvironmentalTechnology Certification Program. The pilotproject’s purpose is to delineate the practicalaspects of the program that will be adoptedin regulations which are under development.Consequently, this Certification may besubject to additional conditions which willbe required in these regulations, including,but not limited to, the duration of the certifi-cation, continuing monitoring and oversightrequirements, and certification amendmentprocedures, including decertification.


C-17

CERTIFIED ENVIRONMENTALTECHNOLOGY

TECHNOLOGY TRANSFERADVISORY

SCIGEN NEUTRALEX

D-1

APPENDIX D

TIERED PERMITTING FACTSHEET 1772B—CONDITIONALEXEMPTION FOR SPECIFIEDWASTE STREAMS

ADDITIONALPUBLICATIONS

ADDITIONAL PUBLICATIONS“American Society for Healthcare Environmen-tal Services”, Professional Development Prod-ucts Catalog, “An Ounce of Prevention: WasteReduction Strategies for Health Care Facilities”,AHA Services, Inc., P.O. Box 92683, Chicago,Illinois 60675-2683, 1-800-AHA-2626, Fax (312)280-6015

“Common Sense Pest Control”, Olkowski andDarr, Taunton Publishers, Bio-Integral ResourceCenter (BIRC), (510) 524-2567

“Environmental News - Helping Hospitals GoGreen”, “Survey of Chemical Use in ColoradoHospitals”, Colorado Hospitals for a HealthyEnvironment, 2140 South Holly Street, Denver,Colorado 80222-5607, (303) 758-1630, Fax (303)758-0047

“Facility Pollution Prevention Guide”, U.S.Environmental Protection Agency, 1992, EPA/600/R-92/088. (513) 569-7562

“General Medical and Surgical Hospitals - AnIntroduction to California’s Hazardous WasteRegulations”, Department of Toxic SubstancesControl, (916) 324-3614

“Guidebook for Hospital Waste ReductionPlanning and Program Implementation”,McRae & Shaner, American Society forHealthcare Environmental Services, AmericanHospital Association, 1996 (800) 242-2626.

“Hazardous Materials Pharmacy Fact Sheet”,PRO-ACT at (800) 233-4356, orhttp://es.inel.gov/

“Healthcare Hazardous Materials Management- The Newsletter of the Center of HealthcareEnvironmental Management”, 5200 Butler Pike,Plymouth Meeting, PA 191462-1298(610) 825-6000, Fax (610) 834-1275 (“Occupa-tional Exposure to Hazardous Drugs” - August1995, “EPA’s Green Lights Program” - Decem-ber 1994)

“Laboratory Waste Management Guide”, May1997, Librarian, Local Hazardous Waste Man-agement Program in King County, 130

Nickerson Street, Suite 100, Seattle, Washington,98109, Phone (206) 689-3051, Fax (206) 689-3070,or [email protected]

“Lighting Waste Disposal”, U.S. EnvironmentalProtection Agency Green Lights Program,January 1994. Contact a regional EPA office.

“Managing Your Medical Waste for a HealthierBottom Line” - videotape - University of Louis-ville, Kentucky Pollution Prevention Center,Louisville, Kentucky 40292, (502) 852-0965

“New and Emerging Technologies for theSterilization of Medical Devices, Emmanuel,Jorge, PhD., P.E., June 1996. Draft paper pre-pared for the EPRI Healthcare Initiative(718) 920-0849

“Pests of Landscape, Trees, and Shrubs,” “Pestsof the Garden and Small Farm”, University ofCalifornia Division of Agricultural and NaturalResources Publications, (510) 642-2431

“Pollution Prevention and Waste Minimizationin Laboratories”, Peter Reinhardt, et al., CRC/Lewis Publishers, Boca Raton, 1995.

“Pollution Prevention Tips: Water and Chemi-cals Reduction for Cooling Towers”, May, 1987North Carolina Department of Environment,Health, and Natural Resources, PollutionPrevention Program, P.O. Box 27687, Raleigh,North Carolina 27611-7687, (919) 733-7015

“Technical Support Document to ProposedEthylene Oxide Control Measure for Sterilizersand Aerators”, March 23, 1990, State of Califor-nia Air Resources Board, Emissions AssessmentBranch, 2020 L Street, Sacramento, CA 95814,(916) 322-6023

“The Practical Application of Disinfection andSterilization in Health Care Facilities”,Cokendolpher and Haukos, American Societyfor Healthcare Environmental Services andAmerican Society for Healthcare Central Ser-vices Professionals, American Hospital Associa-tion, 1995. (800) 242-2626

FURTHER INFORMATION

For more information, contact:

Department of Toxic Substances ControlOffice of Pollution Prevention and TechnologyDevelopmentP.O. Box 806Sacramento, California 95812-0806(916) 322-3670

For online access contact

Cal EPA:http://www.calepa.cahwnet.gov/

DTSC:http://www.calepa.cahwnet.gov/dtsc/dtsc.htm

OPPTD:http://www.cwo.com/opptd/

For information about your regulatoryrequirements, contact the Department’sregional office nearest you:

Region 1 - Sacramento (916) 255-3545Fresno (209) 297-3901

Region 2 - Emeryville (510) 540-2122Region 3 - Burbank (818) 551-2800Region 4 - Cypress (714) 484-5300

For information about waste exchanges,contact the:

California Waste Exchange at (916) 322-4742,FAX (916) 327-4495For online access contact http://www.calepa.cahwnet.gov/dtscdocs/cawastex.txt

California Materials Exchange at (800) 553-2962

To get an EPA ID number, call:

DTSCProgram and Administrative Support Division(916) 255-1136 or (800) 618-6942

To purchase a copy of the California Code ofRegulations, call (415) 244-6611, or write:

Barclays Law PublishersP.O. Box 3066South San Francisco, California 94083-3066(There is a charge for the regulations)

For information on registered haulers, contact:

California Highway PatrolMotor Carrier Safety Unit1551 Benicia RoadVallejo, California 94591(707) 648-4180

California Highway PatrolMotor Carrier Safety Unit437 North Vermont Ave.Los Angeles, California 90004(213) 664-1108

California Highway PatrolMotor Carrier Safety Unit11336 Trade Center DriveP.O. Box 640Rancho Cordova, California 95741-0640(916) 464-2090

For general questions about small quantitygenerators or federal regulations, call:

U.S. EPA, Small Business OmbudsmanClearinghouse Hotline(800) 368-5888

U.S. EPA, RCRA (Resource Conservation andRecovery Act) Hotline(800) 424-9346

U.S. EPA, Community Relations, Region IX,San Francisco, California(800) 231-3075

U.S. EPA, RCRA Information Line, Region IX,San Francisco, California(415) 744-2074

doc. no 413 state of california department of toxic ...“the case against mercury: rx for pollution...

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