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Safety

Hazardous/Chemical Waste

The management of chemical waste is a strictly regulated process under the EPA’s Resource Conservation and Recovery Act (RCRA). This law establishes a “cradle-to-grave” liability system, meaning the laboratory is responsible for its hazardous waste from the moment it is generated until it is confirmed destroyed, regardless of who transports it

Documentation & Handlers

  • Manifests: The legal tracking document that accompanies every shipment. It functions as a chain of custody between the Lab (Generator), the Transporter, and the Disposal Facility. The lab must receive a signed “Return Copy” from the disposal facility to prove the waste was not illegally dumped
  • Licensed Handlers: Laboratories typically outsource waste removal to third-party contractors. These handlers must be vetted to ensure they hold valid EPA/DOT permits, as the lab retains liability for their negligence

Generator Categories

The stringency of regulations depends on the volume of waste produced monthly:

  • Very Small Quantity Generator (VSQG): <100 kg/month (Least regulated)
  • Small Quantity Generator (SQG): 100-1,000 kg/month (Must inspect storage weekly; 180-day storage limit)
  • Large Quantity Generator (LQG): >1,000 kg/month (Strictest rules; 90-day storage limit; mandatory annual training and contingency plans)

Storage Locations

Waste is managed in two zones:

  • Satellite Accumulation Area (SAA): Located at the bench/point of generation. Can hold up to 55 gallons. Under the control of the operator
  • Central Accumulation Area (CAA): The main holding room where the “storage clock” (90/180 days) ticks. Requires weekly documented inspections, emergency equipment, and strict segregation of incompatible chemicals (e.g., separating oxidizers from flammables)