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Safety

Licensed Waste Handlers

Most clinical laboratories are experts in diagnostics, not chemical engineering or long-haul trucking. Therefore, the actual removal, transport, and destruction of hazardous waste are almost exclusively outsourced to third-party contractors. However, outsourcing the task does not outsource the responsibility. Under RCRA regulations, the laboratory (the Generator) is responsible for vetting and selecting Licensed Waste Handlers. If a hired contractor acts negligently (e.g., dumps chemicals illegally), the laboratory can be held financially liable for the cleanup and legally liable for the violation. This concept is often summarized as: “You can pay someone to take your waste, but you cannot pay someone to take your liability.”

Qualifications & Licensure

A waste handler is not merely a trucking company; they are a specialized environmental services provider. They must possess specific permits to operate legally

  • EPA Transporter ID: Any entity moving hazardous waste on public roads must have an EPA Identification Number. The laboratory should verify this number before handing over any waste
  • Hazmat Safety Permit: Issued by the DOT, this ensures the carrier has a satisfactory safety rating and security program
  • Insurance: The handler must carry significant liability insurance (often millions of dollars) specifically covering “Pollution Liability.” This ensures that if they cause a spill, their insurance - not the hospital’s - pays for the cleanup

The Role of the Waste Handler

Licensed handlers typically provide a range of services beyond just driving the truck. In many laboratories, they function as technical consultants

  • Lab Packing: One of the most common services. “Lab Packing” involves the contractor’s chemists coming into the lab to sort, categorize, and package small bottles of chemicals (e.g., old stains, unused reagents) into larger drums (typically 55-gallon drums) with absorbent material. This requires:
    • Chemical Compatibility Knowledge: Ensuring oxidizers are not packed in the same drum as flammables
    • Inventory Creation: Generating a detailed packing list for the drum to satisfy DOT requirements
  • Profiling: Before waste can be shipped, the handler helps the laboratory create a “Waste Profile.” This is a chemical dossier describing the properties of a specific waste stream (e.g., “Spent Xylene from Histology”). The profile is submitted to the TSDF to verify they have the technology and permit to treat that specific substance
  • Manifest Preparation: While the laboratory must sign the manifest, the licensed handler typically prepares the document, printing the complex DOT codes and UN numbers. The lab’s role is to review this for accuracy before signing

Treatment, Storage, & Disposal Facilities (TSDF)

The waste handler transports the material to a TSDF. Sometimes the hauler and the TSDF are the same company; often, the hauler is just a middleman. The laboratory must know the final destination

  • Permitted Operations: A TSDF must have a specific EPA permit (a “Part B Permit”) authorizing it to perform certain treatments (e.g., incineration, fuel blending, mercury recovery). A facility permitted only for solvent recycling cannot legally accept cyanide waste
  • The Audit: Best practice for large institutions involves periodically auditing the TSDF they use. This involves checking their compliance history (have they had major EPA fines?) and financial stability. If a TSDF goes bankrupt and abandons drums of waste, the original generators (the labs) are often billed for the site remediation under the CERCLA (Superfund) law

Common Services & Treatment Technologies

Licensed handlers route waste to different technologies based on the hazard profile:

  • Fuel Blending: High-BTU organic solvents (like xylene and ethanol from Histology) are often blended and used as alternative fuel for cement kilns. This is a form of energy recovery
  • Incineration: High-temperature destruction used for toxic organic chemicals, chemotherapy waste, and pathological waste
  • Neutralization/Stabilization: Used for corrosives (acids/bases) or sludge with heavy metals. The goal is to render the pH neutral or lock the metals in concrete so they cannot leach into groundwater
  • Mercury Retorting: Distilling mercury from waste (e.g., broken thermometers or fixatives) for recycling. Mercury is strictly regulated and discouraged from landfilling or incineration

Due Diligence

The laboratory manager or safety officer must perform due diligence when selecting a handler

  • Contract Review: Ensure the contract clearly delineates responsibilities. Does the contractor provide 24/7 emergency response? Do they provide the packing supplies (drums/vermiculite)?
  • Training Verification: Ask for proof that the drivers and chemists responding to the site have current training in DOT Hazardous Materials regulations and OSHA HAZWOPER (Hazardous Waste Operations and Emergency Response)