DO YOU WORK IN A BIOMEDICAL LABORATORY?
Would you like to:
Improve your profits?
Avoid regulatory headaches?
Do your part in protecting the environment?
If you answered yes to any of these questions, read this Code.
It is one of your finest resources!
CODE OF PRACTICE
INTRODUCTION AND CHECKLIST
Best Management Practices For Pollution Prevention and
Pollution Prevention Award Certification
Public Works Department of Wastewater Utility/Pollution Prevention Program
New Mexico Society for Clinical Laboratory Science (NMSCLS)
an affiliate of the
American Society for Clinical Laboratory Science (ASCLS)
Public Works Department
Wastewater Utility Division
4201 Second Street SW
Albuquerque, NM 87105
Dear Fellow Laboratorians:
Biomedical Laboratories have an onerous responsibility to succeeding generations to maintain
our environment. Among the benefits of good waste management practices and recycling are
cost savings, healthier workers and potentially the reduction in future regulatory burdens.
The Biomedical Laboratory Code of Practice is an excellent starting point in developing good
management practices for pollution prevention in laboratories of all sizes. The New Mexico
Society for Clinical Laboratory Science heartily endorses the efforts of the Albuquerque Public
Works Department in this regard.
This document has been prepared by the City of Albuquerque, Public Works Department,
Wastewater Utility Division, Pollution Prevention Program. Thanks goes to many
contributors (see Appendix A) and technical resources (see Appendix H) used in developing
The City of Albuquerque does not endorse any of the techniques, businesses, equipment,
or methods mentioned in the following document. This document is intended only as
advisory guidance for biomedical laboratories in developing approaches for pollution
prevention. Compliance with environmental and occupational safety and health laws is the
responsibility of each individual business and is not the focus of this document.
Code of Practice for Biomedical Laboratories
City of Albuquerque, Public Works Department, Wastewater Utility Division
Pollution Prevention Program 873-7004
City of Albuquerque, Public Works Department, Wastewater Utility Division
Pollution Prevention Program 873-7004
This Code of Practice is intended to promote a baseline of voluntary compliance
practices by businesses. Businesses participating may choose to be certified by
the City and awarded annual recognition certificates, which will be published in
local media. The Code identifies options and alternatives to achieve pollution prevention
goals according to the processes used in laboratories.
The Pollution Prevention Program is non-regulatory and is an educational and research tool
that can provide you with information concerning methods of source reduction and
pollution prevention for your business. If requested, Pollution Prevention personnel are
available for on-site consultations to’ review your processes and discuss methods of
pollution prevention and waste minimization as needed. The Program can also put you in
contact with other non-regulatory services concerning hazardous waste, air quality and
storm water, if requested.
Local and national contributors (see Appendix A) worked with the Albuquerque Public
Works Department/Pollution Prevention Program staff to identify opportunities to reduce all
types of discharges from biomedical facilities. Of particular interest is the reduction of
metals and toxic organics to the sewer system.
Code of Practice for Biomedical Laboratories Introduction Page iv
q Understanding the Code of Practice for Biomedical laboratories
The enclosed material is the Biomedical Code of Practice. The Code of
Practice is not a regulatory document. Methods and processes mentioned
herein are not required, but are included as examples of methods of pollution
prevention common to the industry. The Checklists refer to page numbers
where ‘specific information can be found in Section 4 and the appendices.
If you-find that the information you are seeking is not in the Code, please contact the
Pollution Prevention Program at (505) 873-7004 to either request additional information, or
to provide information on pollution prevention or waste management practices common to
other businesses with similar processes and equipment.
A great amount of information is provided in this Code including references to hazardous
waste issues. The hazardous waste issues are meant to inform you as to the potential
environmental liabilities your business may encounter. Much of the information provided is
to help your business reduce or eliminate hazardous waste. Your knowledge of hazardous
waste issues is your best chance to avoid potential liabilities and to reduce or remove your
wastes from the hazardous waste classification. (see Appendix D - Hazardous Waste
The Code includes:
Section 1: Pollution Prevention Checklists
Section 2: Biomedical Laboratories Information
Section 3: Laboratory Checklists
Section 4: Biomedical Laboratories Pollution Prevention Information
Code of Practice for Biomedical Laboratories Introduction Page v
q What the Code Will Not Answer
This Code will not answer specific questions concerning health and safety. Due to the
variety and number of chemicals and processes used in biomedical laboratories, the Code
would be unable to maintain a focus on pollution prevention while attempting to address all
health and safety issues. If you are concerned about facility health and safety, you should
consult OSHA or other associations (see Appendix B for listings).
q The Need for the Code of Practice
Wastewater discharged from biomedical facilities to Publicly Owned Treatment Works
(POTWs), is of interest to many municipal, state and federal agencies. POTWs must oversee
the discharges and require the removal of pollutants such as metals and toxic organics, as well
as other chemicals, to maintain compliance with their EPA permit discharge requirements. The
City must meet the discharge requirements listed in its National Pollutant Discharge Elimination
Permit (NPDES) for discharge to the Rio Grande river. In addition, there are several pollutants
that are strictly prohibited from being discharged to the sewer system. Strictly prohibited
pollutants include those that could create a fire hazard; corrosion; solid or viscous material that
could cause obstructions; and any pollutant which could interfere in the operation of the
Although significant loading can come from other industrial sources, Albuquerque is a regional
health care center with a significant number of biomedical laboratories that are of interest to
the Albuquerque POTW. Statistics for 1992 from the U.S. Department of Commerce identified
35 medical laboratories in Albuquerque.
The major areas of opportunity identified for reducing metals and chemical discharges from
biomedical facilities included the following:
Major Areas of Opportunity
1. Better understanding of the technologies and the capabilities of solvent recovery
equipment and procedures.
2. Incorporate written, standardized procedures into the Chemical Hygiene Plan for proper
disposal of chemical wastes from biomedical laboratory processes. The chemicals of
Code of Practice for Biomedical Laboratories Introduction Page vi
concern are discussed throughout this Code of Practice.
3. Elimination of mercury bearing wastes.
4. Implement material substitutions to reduce toxicity of chemicals used and disposed of.
5. Improved record keeping and use of laboratory chemical inventory.
6. Improve spill control measures and chemical storage practices
This Code of Practice identifies Best Management Practices (BMP) for biomedical laboratories.
This Code could be implemented by any POTW to assist businesses and to assure compliance
with EPA and State discharge limits. The Code can also be implemented as part of a
pretreatment program to include a pollution prevention program component. The guidelines
can then be implemented by businesses who will then be certified and given annual recognition
certificates under the Program.
Participation is voluntary, but the alternative is to face
potentially more direct regulation through permitting, Avoiding this regulatory
discharge reporting, etc. Avoiding the regulatory alternative is in
alternative is in everyone’s interest: The goal of the
Code of Practice concept is to achieve results through
voluntary compliance which will ensure that the City’s
wastewater discharge to the Rio Grande is environmentally acceptable.
Code of Practice for Biomedical Laboratories Introduction Page vii
q The Biomedical Industry
Biomedical laboratories, also called clinical laboratories, can be located in several different
settings. Some are attached to medical facilities such as hospitals and clinics. Others are
stand alone facilities that provide contract services to outside medical facilities, companies and
the general public. Still others are located at research and development institutions or private
companies. In Albuquerque, laboratories are found in a variety of settings because the city
is a regional medical center, supports a military base and has a medical school.
The biomedical laboratories industry represents a $25 million wage industry in New Mexico,
with over $12 million of those being Albuquerque wages. Most biomedical laboratories in New
Mexico have fewer than 50 employees. Many labs are trying to implement their own solutions
to pollution problems and are making strides to create a safer place to work in. Due to
increased regulation and increasingly stiffer workplace and environmental standards, solutions
to the use of safer laboratory chemicals needs to be identified and implemented to help this
industry maintain a viable and competitive advantage.
Large biomedical laboratory facilities include the hospital labs which typically offer the full
spectrum of analytical specialties. There are also the smaller labs that specialize in only a few
areas such as the drug detection and fertility services laboratories.
Many of these facilities already practice some type of pollution Prevention ranging from
distillation of solvents to substituting less hazardous chemicals. The industry is closely
regulated and inspected by different organizations ranging from OSHA to the College of
American Pathologists. Biomedical laboratories are well aware of chemicals and hazards and
these are spelled out in written plans such as the OSHA Laboratory Standard required
Chemical Hygiene Plan that is overseen by an internal Safety Committee.
Code of Practice for Biomedical Laboratories Introduction Page viii
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Pollution Prevention Checklists
Biomedical laboratories can potentially generate a variety of byproducts and recoverable
materials in their operations. Some common types may include:
u Spent clearants (xylene) u Used chromium reagents
u Waste formaldehyde u Waste Acids and Bases
u Waste alcohols u Metal bearing reagents
u Mercury fixatives u Dyes and Stains
u Cyanide lysing solutions u Obsolete/outdated stock
q Introduction to Pollution Prevention
Although it has become a catch phrase, pollution prevention is an integral facility process.
Many biomedical laboratories have been practicing pollution prevention for years. Good
housekeeping and inventory management, production optimization, recycling, recovery and
reuse are all methods of pollution prevention. Pollution prevention takes these ideas and
places them under a single heading, but this does not diminish the practices already in use by
many biomedical processing facilities.
Pollution prevention involves questioning and reviewing every facility process,
the chemicals used and the associated procedures. The ultimate questions that
should be asked are: ‘Am I doing this process this way simply because I’ve
always done it this way?’ and; ‘Is there a better, less polluting and potentially
less expensive, way of doing this process?’ The answers will often be yes.
Pollution prevention consists of waste management approaches that reduce the amount of waste
materials generated or requiring disposal. Pollution prevention can reduce the amount of
hazardous and non-hazardous wastes generated in your business.
This benefits businesses by minimizing:
u disposal costs u cost of future liabilities u transportation costs
Code of Practice for Biomedical Laboratories Section 1 Page 1.1
u off-site treatment costs u worker safety costs u fees and taxes
u insurance costs u current operating costs (e.g., raw’ material costs)
u regulatory compliance costs (record keeping, reporting, tracking, lab costs, etc.)
Additionally, pollution prevention can increase business productivity and employee safety,
improve environmental protection, and enhance community relations. These benefits may be
realized by a business by implementing the following pollution prevention methods:
Source Reduction: is an activity that prevents or reduces the generation of waste materials
that may otherwise be released to air, land or water. Examples include: substituting input
material or changing production processes to reduce the amount of waste generated. A good
example is using mercury free lab chemicals. This eliminates a highly toxic chemical in the
facility, reduces environmental liability of disposal, and may reduce waste disposal costs.
Recycling: is the use, reuse, or reclamation of materials. Examples include:
employing on-site or off-site techniques to remove contaminants from a waste
stream so that the regenerated material can be reused. A good example is
distillation of clearants and reuse of the clearant.
To be successful, a pollution prevention program must be organized. It is not hard to organize
a pollution prevention program (see Figure 1), but you will need to spend some time to get
started. While conducting your self-assessment keep in mind the following principles:
u Principles of Pollution Prevention
1. Facility owners/managers must be committed to pollution prevention for it to work.
2. A pollution prevention program should include specific written goals and objectives.
3. Identify your wastes. Are they hazardous or non-hazardous?
4. You should know how your materials and wastes are managed and the associated costs.
5. Train all employees in waste handling and pollution prevention methods.
6. Be aware and follow all waste regulations that apply to your business.
7. Make pollution prevention an integral part of all facility processes, not just a folder on your
Code of Practice for Biomedical Laboratories Section 1 Page 1.2
8. Identify all the agencies you are working with. Work in cooperation with regulatory agencies.
See the regulatory agency as a help and not as a problem.
9. Be prepared to fund pollution prevention programs. You may or may not recoup all costs.
Pollution prevention sometimes pays back in non-tangible ways such as improved employee morale.
The following chart shows the basic steps you can use in implementing a pollution prevention
program in your business.
Code of Practice for Biomedical Laboratories Section 1 Page 1.3
Code of Practice for Biomedical Laboratories Section 1 Page 1.4
Pollution prevention can be conducted in several areas of a business. These areas pose differing
levels of liability. It can be said that the more a business does to reduce the amount of wastes
generated the less liability for the business. The more wastes a business sends to disposal the
greater the business liability (see Figure 2). The different areas are:
1. Inventory Management - buy only what you need to reduce out dated stock chemicals.
Rotate stock to use chemicals in date sequence. Check delivered stock for damage to
reduce spills and to return damaged stock.
2. Process Modification - Modify laboratory processes to reduce waste. Simple changes can
significantly reduce the amount of wastes generated.
3. In-Process Recovery and Reuse - Increase the amount of materials recovered and reused
within the facility process.
4. On-Site Recovery and Reuse - Increase the amount of materials recovered and reused within
5. Interindustry Exchange - Unused materials can be exchanged between businesses. One
business’ unused material may be another’s raw material.
8. Off-Site Recovery - Sending materials for off site recycling, reclamation or as a fuel.
7. Disposal - Sending materials. off-site for disposal as waste. Due to strict regulations
hazardous waste disposal carries the greatest level of liability. Disposal is not considered a
waste reduction method, but can be an associated process when materials are disposed of
properly after waste reduction or recovery techniques have been used.
Note: Treatment is not a method of pollution prevention/waste minimization, but you can treat your
hazardous wastes on site if you follow certain regulations. These regulations cover issues
of accumulation, storage and labeling requirements, and accident prevention. See Reference
Materials - Managing Hazardous Waste.
The following chart shows the differing levels of liability by pollution prevention procedure.
Disposal carries the greatest amount of liability.
Code of Practice for Biomedical Laboratories Section 1 Page 1.5
Code of Practice for Biomedical Laboratories Section 1 Page 1.6
q Assessing Your Pollution Prevention Opportunities
These checklists will help you perform a pollution prevention assessment. The objective of this
assessment is to identify ways to reduce or eliminate waste, or recover materials, through a careful
review of your facility operations and waste streams. After selecting a specific area, or areas, to
focus on in your pollution prevention efforts, a number of options should be developed and
evaluated. Then, evaluate the technical and economic feasibility of the selected options. Select the
most promising pollution prevention options for implementation. Finally,
review the operation after implementation to modify as needed.
1. What are the recoverable materials and/or hazardous and non-
hazardous wastes, a n d f r o m w h a t p r o c e s s e s a r e t h e
materials/wastes, generated? What are the volumes generated?
2. Which wastes are hazardous and which are not? What makes
these wastes hazardous?
3. How much of a particular input material is used in the process?
4. What are the raw material process losses?
5. How efficient is the process?
6. Are unnecessary wastes generated by mixing recyclable wastes with other process wastes,
especially with hazardous wastes?
7. What housekeeping practices are used to reduce the amount of waste generated?
8. What process controls are used to improve process efficiency?
9. What are the facility’s current hazardous and non-hazardous waste disposal costs (including
disposal fees, permit fees, raw material purchases, etc.)
10. Are you mixing hazardous wastes with non-hazardous wastes? This is extremely important.
If you mix hazardous wastes with nonhazardous wastes you are increasing the amount of
hazardous waste you pay to have disposed. You should be segregating your hazardous and
non-hazardous wastes to reduce you disposal costs. This means that you should also be
familiar with your wastes and understand what constitutes a hazardous waste.
See Appendix D - Hazardous Waste Information,
for additional Information.
Code of Practice for Biomedical Laboratories Section 1 Page 1.7
Complete the following pollution prevention checklists to see if your business is maximizing
pollution prevention techniques.
q Management Practices
1. Does your facility have an established If there is enough staff available, a committee may be
pollution prevention program in place? more successful than a single person. One person is not
always available-tin necessary, could leave the
company or otherwise be absent, and may not have the
expertise in all necessary areas (See Figure 1).
Is a specific person or committee assigned
to oversee the success of the program?
Pollution prevention programs are more successful if they
contain written pollution prevention elements, especially
Does the program have set pollution when setting goals.
2. Have you characterized your wastes Biomedical laboratories generate a variety of wastes from
and formalized a strict waste type hazardous, infectious, radioactive to any combination of
definition for your facility wastes? these. The six main types of wastestreams are:
infectious, chemical, radioactive, multihazardous,
wastewater, and recyclable wastes.
Each waste is categorized at the time of discard into one
Have you implemented a Source of your wastestream categories. The waste is placed in
the appropriate container for the type of waste it is at the
time of discard. This will achieve source separation.
This Code of Practice contains information about
Have you reviewed your product
substituting less hazardous products in laboratory
processes. The best place to start is with those processes
that generate the most toxic and hazardous wastes.
Code of Practice for Biomedical Laboratories Section 1 Page 1.8
3. Are there employee education You can reduce the amount of waste generated by spills if
programs on how to avoid excessive you train employees to properly handle and store
waste generation? hazardous and other wastes. Some trade associations
and local environmental health agencies sponsor employee
training seminars and some consulting firms offer
employee training as part of their package of services.
How often are the training programs
4. Are you fully aware of the current Compliance with existing laws and regulations is helpful to
local, state, and federal regulations related a good pollution prevention program.
to hazardous material storage, treatment,
disposal, and recycling? See Reference Manual, Appendix D - Hazardous Waste
Information Manual when reviewing waste generation.
5. Has your facility conducted an Assistance is available for any concern. See City and
environmental assessment to determine State references in Appendix B, or call the City of
regulatory compliance? Albuquerque’s Pollution Prevention Program at
Code of Practice for Biomedical Laboratories Section 1 Page 1.9
q Process Management
Production management involves optimizing processes and scheduling to reduce waste
generation and dealing with management practices, such as employer/employee
relationships, that may have an influence on the amount of waste generated,
1. Are sequential operations adjacent to Sequential operations should be adjacent to avoid excess
each other? material handling. This reduces the potential for material
and precious metal losses and reduces accidental spills.
2. Are process solutions prepared by You can often minimize waste and improve the
trained personnel? consistency of process solutions by assigning a limited
number of properly trained personnel to mix chemicals.
ls there a process in place to ensure the
minimum volumes of chemicals are used
in all process?
3. Does your facility maintain fume Fume collectors and ventilation fans should be maintained
hoods, collectors and fans in proper in top working condition. Good maintenance practices
working condition? will reduce health risks and allow better collection of
airborne vapors and particulate.
4. Does your facility have a formal Regular inspections of your facility’s storage, waste
facility inspection plan? treatment, and production areas will help maintain optimal
production and identify equipment and process
malfunctions early. This will help you identify equipment
and process problems early and provide time to correct
problems before a small problem becomes a major issue.
Code of Practice for Biomedical Laboratories Section 1 Page 1.10
q Spill Control
Spill control is especially important for biomedical laboratories because of the toxicity of
some of the chemicals used in their process solutions.
1. Does your facility conduct Routine inspections of your lab’s process, storage, and
equipment inspections on a routine waste treatment areas should be conducted on a regular
basis to identify leaks or equipment basis to identify leaks and malfunctioning equipment.
malfunctions? Identifying problems at an early stage helps reduce spills
and other uncontrolled releases.
2. Do you have procedures in place to Fire departments require spill containment, and material
handle leaks or spills? segregation of reactive materials, around storage areas to
minimize the spread of any spilled material. Ensuring a
quick and proper response to leaks and spills can help you
reduce waste generated by the cleanup of spills. Keep an
emergency spill plan available and educate employees in
its use. Training your employees also satisfies legal
See Reference Manual, Appendix E - Hazardous Materials
Emergency Response Plan.
u Guidelines for a Hazardous Materials Emergency Response Plan
It is required for any business handling materials which are or may be
considered hazardous to have a Hazardous Materials Emergency Response Plan
(HMERP) in case of spills. If a business is unable to contain a spill and it is
discharged into the sanitary sewer or storm drain, released into the air, or
spilled on the ground it is very important to notify the proper authorities. By
preparing and filing your Hazardous Materials Emergency Response Plan (with
the Fire Department, see Appendix E) you will be fulfilling part of the requirements under RCRA
(Resource Conservation and Recovery Act - see Appendix D) Hazardous Waste Reporting and under
the Super-fund Amendments and Reauthorization Act (SARA) community right to know. Following
are some general spill control procedures:
1. Isolate the spill area and limit entry, evacuate area if necessary
2. Tend to any injured or contaminated personnel, seek help as necessary
3. Notify the proper authorities if needed:
Code of Practice for Biomedical Laboratories S e c t i o n 1 Page 1.11
During the work week (Mon-Fri, 8AM to 5PM) call the Industrial Waste Engineer at 873-
7004. On weekends, holidays, and after hours telephone notification can be made at
3. Equip trained personnel with PROPER personal protective equipment
4. Identify the material and quantity spilled and select an appropriate approach (see MSDS or
1994 Emergency Response Guidebook for guidance).
5. If the spill is treated on site, dispose of the spill in accordance with federal, state, and
Accidental spills happen fast and without warning so it is also important to have spill control
equipment available. Businesses have to determine what spill control method is best for them.
Following are some methods/treatments a business can use for spill control including sorbents,
treatment agents, or hazardous material vacuums for spills.
Sorbents. Are materials that soak up liquids through absorption or adsorption. Sorbents come in
particulate, sock, or pillow form. Depending on the spilled material the sorbents may be considered
hazardous after the spill has been cleaned up. Paper is combustible and shouldn’t be used on
oxidizing agents such as nitric acid.
Treatment Agents. Are usually available for acid, caustic, or solvent spills. They come in dry
powder form and are shaken, poured, or sprayed onto a spill. When used properly these agents
will neutralize and solidify spills.
Hazardous Material Vacuums. Vacuums can be used to clean up dry chemical spills or to collect
and contain virtually any dry pollutants.
Other Equipment. Plastic scoops, brooms, pails, bags, dust pans.
Protective Equipment. Personal protective equipment, warning signs, barricade tape.
General Guidelines for Some Common Spills
All Health and Safety measures should be followed in cleanups using the level of equipment
appropriate to the chemical spill. (Excerpt from Prudent Practices in the Laboratory, 1995):
l Materials of low flammability that are not volatile or that have low toxicity. This category of
hazardous substances includes inorganic acids (e.g., sulfuric and nitric acid) and caustic bases
(e.g., sodium and potassium hydroxide). For cleanup, appropriate protective apparel, including
gloves, goggles, and (if necessary) shoe coverings should be worn. Absorption of the spilled
material with an inert absorbent and appropriate disposal are recommended. The spilled
chemicals can be neutralized with materials such as sodium bisulfate (for alkalis) and sodium
carbonate or bicarbonate (for acids), absorbed on Floor-Dri® , or vermiculite, scooped up, and
Code of Practice for Biomedical Laboratories Section 1 Page 1.12
disposed of according to the procedures detailed in Chapter 7, section 7.B.8. (Refers to the
book Prudent Practices in the Laboratory, 1995).
l Flammable Solvents. Fast action is crucial when a flammable solvent of relatively low toxicity
is spilled. This category includes petroleum ether, pentane, diethyl ether, dimethoxyethane,
and tetrahydrofuran. Other workers in the laboratory should be alerted, all flames
extinguished, and any spark-producing equipment turned off. In some cases the power to the
laboratory should be shut off with the circuit breaker, but the ventilation system should be
kept running. The spilled solvent should be soaked up with spill absorbent or spill pillows as
quickly as possible. These should be sealed in containers and disposed of properly.
Nonsparking tools should be used in cleanup.
l Highly Toxic Substances. The cleanup of highly toxic substances should not be attempted
alone. Other personnel should be notified of the spill, and the appropriate safety or industrial
hygiene office should be contacted to obtain assistance in evaluating the hazards involved.
professionals will know how to clean up the material and may perform the operation.
l Dyes. Please refer to the section in the Reference Manual on Dyes! Stains and Chromogens
l 911 - Albuquerque Fire Department (Hazmat Emergency Response). Describe spill and
material to dispatcher.
l 888-8124 Fire Marshalls Office (Hazmat information)
l 843-2551 Poison Control
See Appendix B for a complete listing of phone numbers.
Code of Practice for Biomedical Laboratories Section 1 Page 1.13
1. Do you keep track of all You should maintain and keep on file all manifests, receipts and
the materials you send to tracking materials for wastes you have disposed.
disposal? To reduce the amount of paperwork and business liability you
should review your processes and material use to reduce the amount
and number of wastes you currently generate. By not generating
the waste you will not have to have it disposed.
2. Do you commingle like Commingling is the process of combining similar wastes into a
wastes prior to disposal? larger container. For commingling, wastes should not be reactive
and should be of the same hazard classification.
Compared to lab packs, commingling can be much cheaper (up
to 1/4 the cost) than using lab packs. Due to absorbent materials
and waste container space Lab packs typically can only
accommodate 14 gallons of wastes in a 55 gallon lab pack.
Commingling can accommodate the full 55 gallon drum space.
(from: “Laboratory Waste Management: A Guidebook,” ACS
Taskforce on Laboratory Waste Management, ACS, Washington,
Commingling should be done carefully and employees should be
trained in the procedures. Simple errors such as combining
incompatible wastes can endanger your business and/or generate a
mixed hazardous waste. This can make your wastes difficult to
handle and expensive to have disposed. One example is the
segregation of non-chlorinated solvents from chlorinated solvents.
Mixing a small amount of chlorinated solvent in with the
nonchlorinated solvents will cause the entire container to become a
hazardous waste and will be expensive to have handled and
3. Do you segregate wastes Segregating wastes can greatly reduce the amount of hazardous
prior to disposal? wastes you generate, thus reducing your disposal costs.
If you mix 1 pound of hazardous waste with 9 pounds of
nonhazardous waste you will have 10 pounds of a hazardous
waste. Your best option is to make sure that the 1 pound of
hazardous waste does not get mixed with the nonhazardous
For more information concerning Hazardous Waste Regulations see
Appendix D - Hazardous Waste Information
Code of Practice for Biomedical Laboratories Section 1 Page 1.14
q Purchasing & Inventory Management
1. Do you purchase When a large container is purchased, often a small quantity is used
chemicals in large volumes? and the excess is stored. Large volumes increase the possibility of
having excess chemicals in the lab that are past their expiration
dates. This results in large amounts of potentially hazardous waste.
To avoid costly surplus, purchase chemicals in small prepackaged
containers. purchases should be done to fulfill immediate lab needs;
this reduces the possibility of excess chemicals and containers.
2. Do you use all the material Do not begin new procedures with new chemicals, bypassing
in a container? previously opened containers.
Partially filled containers begin to collect around the lab.
Unused chemicals can greatly increase the amount of hazardous
wastes a lab generates.
Locking chemical storage areas and limiting, access may help your
business reduce chemical use.
3. Do you properly label The cost of having even a small quantity of unknown chemical
chemical containers? analyzed prior to disposal can exceed $1,000.00.
u Should be legible and permanent.
u All appropriate hazard warning labels (i.e. flammable, corrosive,
etc.) must be on each container.
u The name on the bottle should correspond with the name on
the Material Safety Data Sheet.
u Decreases the risk of accidents and injuries resulting from
improper use or storage.
u Allows surplus chemicals to be reused rather than having to
dispose of them.
u Reduces analysis and associated costs prior to disposal.
u Assists in regulatory compliance, such as the hazard
Code of Practice for Biomedical Laboratories Section 1 Page 1.15
4. Do you track your Tracking what the material was used for and how it was disposed
purchases from the time of of can lead to significant advances in your business’ pollution
purchase to final use or prevention efforts. Tracking a chemical from purchase to disposal
disposal? can reduce duplicate purchases. Allowing for redistribution of
surplus materials can reduce waste generated from partially filled
containers or out-of-date stock.
Whatever method you use to track purchases (i.e., computer
program, ledger books, note cards, etc.) accuracy relies on the
cooperation of all lab employees and should be incorporated in your
Common chemical tracking systems Include:
l Bar coding, such as the system approved by the Health Industry Bar Code Council
l System 39 as used by the U.S. Department of Defense
l Chemical Abstract Service (CAS) registry numbers which are universally accepted for
identifying specific chemicals and can be used in a chemical tracking system.
Code of Practice for Biomedical Laboratories Section 1 Page 1.16
BIOMEDICAL LABS INFORMATION
q Biomedical Processes
Biomedical laboratories typically have several small laboratories within a laboratory. There
are laboratories for each subspecialty. The following table 2.1 shows the types of clinical
laboratories and their subspecialties:
Table 2.1 - Types of Clinical Laboratories
Microbiology Bacteriology, Mycobacteriology, Mycology, Parasitology,
Diagnostic Immunology Syphilis serology, general immunology
Chemistry Routine chemistry, endocrinology, toxicology
Hematology Routine hematology, flow cytometry
Pathology Cytology, histology, electron microscopy
lmmunohematology ABO and D(Rho) testing, compatibility testing, unexpected
antibody detection, antibody identification
Reproduction and Transplant immunology, experimental pathology, reproductive
Research and Animal Testing
(Adapted from Morbid. Morbid. Weekly Rep., 41 (RR-2), 9, 1992.)
q Biomedical Wastes of Concern
Biomedical laboratories generate a variety of waste types. Wastes may be infectious,
hazardous, radioactive or multihazardous (any combination). Infectious wastes are defined
by the Centers for Disease Control, the U.S. Environmental Protection Agency, and the
Occupational Safety and Health Administration. In addition, there are state and local
Code of Practice for Biomedical Laboratories Section 2 Page 2.1
regulation governing infectious waste. In New Mexico, the New Mexico Solid Waste
Management Regulations define infectious waste. The definition of infectious wastes may
vary depending on the regulation or guideline given. The City’s Sewer Use and
Wastewater Control Ordinance follows the Guidelines from the Center for Disease Control
for “Safe Disposal of Solid Wastes from Hospitals”. Any wastes with toxic biological
contamination not addressed by the CDC guidelines should not be discharged to the sewer
Hazardous wastes are regulated by the State of New Mexico through it’s authority to
enforce the federal Resource Conservation and Recovery Act (RCRA) regulations. These
regulations cover a variety of areas including waste generation and minimization,
treatment, storage transportation and disposal. Wastes may be considered hazardous if
they are listed in the regulations or are regulated because of a hazardous characteristic
such as ignitability, corrosiveness, reactivity or toxicity.
Radioactive waste discharges are determined by New Mexico Radiation Protection
Regulations that are enforced by the State of New Mexico Environment Department. The
City of Albuquerque currently is initiating a voluntary Radioactive Discharge Management
Program that will include hospitals and laboratories. The City’s program is developing best
management practices for disposal of radioactive materials that businesses can use.
Heavy metals used in laboratories include chromium, copper, mercury, silver, and zinc.
Many of these heavy metals are regulated due to their potential toxicity. Metals that enter
the wastewater treatment plant are either removed and become part of solids or sludge, or
they are discharged into the Rio Grande with the City’s effluent. Heavy metals do not
biodegrade in the wastewaster treatment process. Most if not all of the metals have low
limits for aquatic toxicity and can be concentrated by the food chain. The following is a
description of certain regulated heavy metals and other materials that may be found in
biomedical materials and/or cleaners:
Chromium is present in chromic acids used for cleaning glassware and in some
laboratory reagents. Waste chromic acid is a hazardous waste if the chromium
content exceeds the threshold amount of 5 mg/L. Hexavalent chromium (VI) is
more toxic than chromium (Ill). Chromium (VI) readily crosses biological membranes
because it forms strong oxidizing chromate and dichromate ions. (From Safety in the
Chemical Laboratory, Journal of Chemical Education). Chromium may last in
insoluble form indefinitely and threatens all life in it’s hexavalent (VI) form.
Chromium (VI) poses an extreme threat (Prager, 1995, p. 476). The State has set
Stream Standards for dissolved chromium for the Rio Grande river.
Copper may be present in some laboratory reagents used by biomedical laboratories.
Copper as a metal is not a threat. Copper as a solubilized salt or as an airborne
Code of Practice for Biomedical Laboratories Section 2 Page 2.2
fume is toxic. Copper is a concentratable heavy metal with low levels for chronic
aquatic limits. The State has Stream Standards for irrigation, fisheries, and
livestock and wildlife watering for dissolved copper (Prager, 1995, p. 521) for the
Rio Grande river.
Mercury is found as a compound in biomedical laboratories in some reagents and as
a liquid metal in electrical switches, and thermometers. Mercury is highly toxic.
Methyl mercury is the organic form of mercury in the environment that
bioaccumulates, building up in the muscle tissue of living animals (Terrene, 1995,).
The State has set Stream Standards for total mercury for the Rio Grande river.
Silver may be found in some laboratory reagents. Silver is toxic to aquatic life with
bioaccumulation found only in lower levels of the food chain. The nitrate salt is a
soluble salt while chloride and carbonate salts rapidly precipitate. The major water
uses threatened are fisheries and potable water supplies (Prager 1995, p. 1037).
The City of Albuquerque’s EPA permit to discharge to the Rio Grande contains strict
limits for the discharge of silver. The EPA sampling method and analytical method
includes all forms of silver: particulate, dissolved or complexed silver.
Zinc may be present in some laboratory reagents. Zinc is toxic to aquatic life and
for fish has a 0.1 ppm acute hazard threshold level. At chronic levels zinc shows no
effects to man and only a low mortality rate has been found among aquatic life
(Prager 1995, p. 1037). New Mexico has Stream Standards levels for zinc to
protect irrigation, fisheries, livestock and wildlife watering.
Many organic chemicals and compounds are of concern to the wastewater treatment plant.
Chemicals with low flash points, that are flammable, and immiscible in water can pose a
serious explosion danger in the sewer system. Other chemicals are of concern because of
their toxicity and potential harm to the wastewater treatment plant microbial processes and
potential for bypassing treatment processes and making it into the Rio Grande River.
Xylene is the most commonly used clearant in histology laboratories. Histological
xylene typically contains a mixture of isomers of xylene and ethyl benzene.
Repeated exposures have neurotoxic effects to humans. Xylene is a flammable
liquid and has negligible solubility in water.
Formaldehdye is widely used as a fixative and preservative in biomedical laboratories
and as a disinfectant. Formaldehydes’ toxicity and health effects have caused
OSHA to develop the OSHA Formaldehdye Standard.
Code of Practice for Biomedical Laboratories Section 2 Page 2.3
Methanol, ethanol and isopropyl alcohol are used in biomedical laboratories for a
variety of purposes such as tissue processing and staining. Alcohols are flammable
and water soluble.
Cyano complexes may be present in cell lysing solutions or as potassium
ferricyanide or potassium ferrocyanide. Unlike free cyanide, ferro- and ferricyanide
ions (also known as hexacyanoferrates) have a low level of toxicity. The City’s
industrial wastewater analysis does not differentiate between complexed cyanide
compounds (such as hexacyanoferrates) and freecyanide, but rather combines the
two and analyzes for ‘total cyanide.’ Cyanide wastewaters should not exceed the
City’s Sewer Use and Wastewater Control Ordinance limits to be discharged to the
Other Solvents & Organic Chemicals
Other solvents used in biomedical laboratories that are of concern include
chloroform, acetone, gluteraldehyde, ethylene glycol, isopentane, phenol, picric acid,
tetrahydrofuran, toluene, and trichloroethane, among others.
Code of Practice for Biomedical Laboratories Section 2 Page 2.4
How To Use the Checklists:
The following checklists are provided in Section 3 in order to help identify pollution
prevention opportunities in the following areas:
Table of Contents
Each checklist contains three columns. The first column contains a question regarding an
opportunity for pollution prevention or an area of environmental concern. The second
column briefly addresses the pollution prevention opportunities that. can be considered.
The third column refers the reader by page number to the Reference Manual where detailed
information is contained on pollution prevention about the topic being addressed.
Code of Practice for Biomedical Laboratories Section 3, Checklists 3.1
q Chemistry & Hematology
Have you evaluated Most lab testing is now done on automated Refer to
alternate methods to systems that produce small volumes of Appendix
perform tests? wastes. Carefully select the test method C.5 Table
that produces the best results and generates B for list
the least amount of waste. Several methods of
are usually available for the same parameter equipment
(Reinhardt, 1996, p. 173). vendors.
Does hematology use Cyanide solutions exceeding 0.45 mg/l of
manual iron-cyanide testing total cyanide should not be disposed of
or cell lysing solution testing down the drain. Store cyanide waste in
that generates cyanides? secondary containment and separate from all
acidic solutions. Sodium lauryl sulfate is an
alternative to cyanide for automated analysis
Have you considered ways Bouin’s solution used as a preservative p. 4.8
to reduce your use of contains concentrated formaldehyde
formaldehyde? solution. Reducing preservative volumes
requires careful consideration. You may be
able to reduce the volume of Bouin’s used by
reducing the size of your specimen
Do you collect your waste Solvents are used to extract urine and blood p. 4.51
solvents from GC analysis samples for GC analysis as well as for TLC and 4.65.
and TLC analysis? analysis. Reduce the use of solvent by
minimizing extraction sample size.
Investigate using other methods and less
hazardous solvents. Try and save all
solvents for recycling or disposal.
Do you use heavy metal Adhere to the City Sewer Use Ordinance See p.
standards to calibrate your limits (Appendix F) to see if the 4.23 for
atomic absorption (AA) concentration of metals in these standards more on
equipment? can be sewered, otherwise use a hazardous metals
waste disposal firm. Prepare standards as
needed to avoid excess quantities going to
Do you use xylene for Xylene is highly flammable and toxic and p. 4.13
extractions or cleaning should not be disposed to the sewer.
slides? Consider substituting less toxic chemicals for
xylene where ever possible. Used xylene
can be recycled either at your lab or sent for
off-site recycling or disposal.
Code of Practice for Biomedical Laboratories Section 3, Checklists 3.2
Do you use mercury Mercury may be present in reagents used for p. 4.31
containing reagents? the detection of chloride with the mercuric
nitrate method. Use of an alternate method
such as ion-selective electrode (ISE) is
preferable. Mercury containing reagents or
wastes should not be sewered.
Do you use chromium Highly concentrated chromium may be p. 4.28
containing reagents? present in reagents used for albumin testing.
Refer to your MSDS sheets and if chromium
is present consider using albumin testing
with less toxic reagents.
Do you use silver containing Silver is present in some chemical reagents p. 4.26
reagents? for the analysis of chlorides. Reagents with
more than 5 mg/l of silver should not be
sewered. Investigate alternative methods or
collect your silver reagent for disposal.
Do you use copper High concentrations of copper may be 4.23
containing reagents or present in some reagents used for
preservatives? calorimetric analysis of total protein or in
some stool preservatives. Switch to
nonmetal reagents if possible.
Do you use zinc in your Zinc is found in some calorimetric glucose 4.23
testing for glucose? tests. Consider using other tests for glucose
that provide equivalent or better results
without producing wastes containing zinc.
Have you minimized your Radioimmunoassays (RIA) tests generate low
generation of low level level radioactive wastes. Careful selection
radioactive wastes? of radionuclides, liquid scintillation cocktail,
observation of holding times and proper
storage will minimize your radioactive
Do you use solvent based Xylene or toluene based scintillation fluids Appendix
scintillation fluids? can be replaced in many cases by safer C.6, Table
alternatives that are less ignitable and easier 10
to dispose of.
Have you examined waste Mixed wastes may be regulated by more
streams to ensure they are than one regulation (i.e. radioactive and
not mixed wastes? hazardous). Segregate wastes types to
avoid creating mixed wastes.
Code of Practice for Biomedical Laboratories Section 3, Checklists 3.3
Have you considered Some laboratories may want to reduce or Appendix
elimination of some RIA eliminate the handling of low level C.6, Table
tests? radioactive wastes from RIA tests. Several 10
new alternatives that produce nonradioactive
wastes have been developed for the
detection of microbial growth and various
Code of Practice for Biomedical Laboratories Section 3, Checklists 3.4
q Pathology/Histology Reference Manual
Have you explored ways to Reductions in the amount of See p. 4.8 and
reduce the amount of formaldehyde used in specimen Case Study #2 in
formaldehyde you use? containers is possible but should be Appendix G
carefully evaluated prior to making
Have you explored the Formaldehyde free substitutes are p. 4.7
substitutes to commercially available and have been
formaldehyde? successfully applied.
Have you considered the Recycling and reuse can reduce both p. 4.9 and p. 4.51
benefits of recycling costs and pollution. Commercially
formaldehyde, alcohols and available distillation units are
solvents on-site? available for recycling formaldehyde,
alcohols and solvents on-site.
Have you considered There are treatment products p. 4.11
treating your waste available that can be used to detoxify
formaldehyde to detoxify it formaldehyde prior to disposal.
prior to sewering?
Do you sewer your xylene Xylene is a toxic chemical that is p. 4.13
containing solutions? toxic, not miscible with water, and
flammable and should not be
sewered. Consider recycling, fuel
supplement burning or disposal.
Have you considered trying There are xylene substitutes p. 4.15
other clearants besides commercially available that provide
xylene? an alternative.
Do you distill your xylene or Distillation of xylene and other p. 4.17 and p.
xylene substitutes for clearants is good pollution prevention 4.51
reuse? practice and can reduce your material
Have you optimized your Consult with your distillation unit See p. 4.51 and
recovery of xylene and supplier. Other factors that may Appendix page
xylene substitutes? increase your recovery are the xylene G.4 for a Case
solvent grade used. Study
Do you use fixatives that Common fixatives such as B-5, p. 4.33
have mercury in them? Helly’s, and Zenkers contain
mercury. Mercury bearing waste
should not be sewered. There are
non-mercury fixatives available.
Code of Practice for Biomedical Laboratories Section 3, Checklists 3.5
Some mordants and Sodium iodate has successfully been p. 4.34
hematoxylins contain replaced for mercury oxide in
mercury. Have you hematoxylin stain.
considered the alternative
products and practices?
Do you know the hazards of Some stains and fixatives may p. 4.8 and p. 4.47
working with picric acid? contain picric acid. It is highly
reactive and may explode when dry
or complexed with metals. There are
safer substitutes in counterstain and
Are you disposing of high Check to see that your waste hauler p. 4.65
energy waste solvents in a is sending allowable solvents with
manner with the highest high energy content to a fuel
benefit to the environment? blending facility instead of an
incinerator if possible.
Do you know if your dyes, There are hundreds of these p. 4.45
stains and chromogens are chemicals and some are
properly disposed of? carcinogenic. Some of these can be
detoxified prior to drain disposal.
Others should be disposed of by a
licensed waste hauler.
Do you use silver stains? Silver is a metal that should not be p. 4.26
discharged into the sewer above 5
mg/L. Uranyl nitrate is used in small
quantities as a “sensitizer” in silver
stains. It is radioactive and produces
a difficult waste to manage. Zinc
formalin may be a satisfactory
Do you hold your activated Large quantities of gluteraldehyde Appendix G.5,
gluteraldehyde solutions held for 14 to 21 days will lose Case Study #4
prior to draining? toxicity and can then be discharged
to the sewer system as long as other
contaminants aren’t present. You
may want to reevaluate your use of
Code of Practice for Biomedical Laboratories Section 3, Checklists 3.6
q Microbiology Reference Manual
When purchasing new New equipment is available Appendix C.7, Table 11
equipment for testing do that uses increasingly
you take into consideration miniaturized sample
the wastes produced? volumes and produces less
Do you provide secondary All staining supplies should p. 4.45
containment and know the be stored with secondary
spill procedures for your containment to prevent
staining supplies? spills.
Have you reviewed the Some stains contain p. 4.45
MSDS sheets and hazardous materials that
understand the proper should not be sewered but
disposal of chemical stains? contained and disposed of
as hazardous wastes.
Have you tried staining Wastes from excess
slides with a few drops staining chemicals and
instead of a dipping bath? rinsing can be reduced by
using a few drops to stain
instead of a dipping bath.
Does your PVA/trichrome Investigate alternative p. 4.31
stain use mercuric chloride? chemicals less toxic than
mercury. Cupric sulfate has
been used as a substitute.
Do you use rapid screening Rapid screening tests can
tests? be used to eliminate a
specimen from further
testing. Rapid screening
often improves efficiency,
is cost effective, and
generates less waste.
Code of Practice for Biomedical Laboratories Section 3. Checklists 3.7
Do you perform various There is diagnostic equipment available Appendix C.6,
manual and semi-manual that will perform various tests Table 9
tests? simultaneously with the benefits of
waste minimization and improved
Do your buffer solutions Thimerisol contains mercury. Evaluate p. 4.31
contain thimerisol? the non-mercury alternatives available for
Do your slide preparation Some slide preparation solutions contain p. 4.23
solutions contain copper sulfate. Avoid sewering metal
metals? containing solutions by containing them
for hazardous waste disposal.
Investigate if non-metal alternatives are
available for your application.
Code of Practice for Biomedical Laboratories Section 3, Checklists 3.6
q Gross Pathology and
Do you store your specimen Store specimen containers with
in solution with formaldehyde away from sinks and floor
formaldehyde away from drains to avoid spills into the sewer.
sinks and drains?
Do you sewer waste Waste solutions such as Zenker’s and p. 4.23
solutions containing metals? from silver staining may contain high
concentrations of metals that shouldn’t
be sewered. Collect these ‘for disposal
as hazardous waste. Investigate
substituting or eliminating metal
Have you considered ways Smaller specimen containers can reduce Appendix G.5,
to reduce the amount of the volume of preservatives used. Case Study #2
formaldehyde, Large quantities of activated and Case Study
gluteraldehyde and alcohols gluteraldehyde can be held for 14 to 21 #4
used? days to lose toxicity before sewering.
Investigate reusing solutions on-site
Have you investigated the Switching to fixatives with no mercury p. 4.33
use of non-metallic or toxic metals can reduce your
fixatives? generation of hazardous wastes.
Do you cold sterilize Cold sterilization may generate spent
equipment? formaldehyde, gluteraldehyde or other
chemicals. Consider other methods
such as autoclaving, ethylene oxide, or
‘Renalin” type disinfectants.
Are your autoclaves fitted Steam sterilization with autoclaves may
to recirculate cooling water be one of the largest water users.
or minimize it? Water saving modifications may pay for
themselves in water bills.
Code of Practice for Biomedical Laboratories Section 3, Checklists 3.9
q Facility Plumbing & Reference
Do you routinely maintain Proper maintenance should be done
your neutralization sump or periodically. Limestone may be
pit? eliminated by controlling the pH of
materials before they are discharged.
Assume sump contents are hazardous if
unknown because they are a collection
point for sediments, solvents, and
Are deposits from low Sediments and mercury will tend to
points in plumbing properly collect in low points making the waste
disposed of? hazardous. Assume sediments are
hazardous if unknown.
Do you store chemicals Chemicals stored near drains and sinks
near drains and sinks? should have double containment. Install
lipped sinks if necessary. Avoid storing
chemicals above sinks.
Do you have floor drains in Protect or plug floor drains to prevent
your laboratory or in spills from entering the sewer system.
chemical storage/receiving Temporary drains can be installed at
areas? safety showers.
Do you use aspirators or Aspirators and single pass water seal
water seal vacuum pumps? pumps use a lot of water and may
entrain and discharge chemicals to the
sewer. Alternatives include
recirculating water seal pumps and
Do you dispose of your Vacuum pump oil may be contaminated
vacuumpump oil properly? with cross contact of chemicals or
radioactivity. Characterize and dispose
of it according to hazardous waste
Have you reviewed the Phenolic compounds may be present in p. 4.41
ingredients in your disinfectant cleaners. Phenols are toxic
cleaners? and some are bioaccumulative. Use
phenols only when required. The
alternative to phenols are quarternary
Code of Practice for Biomedical Laboratories Section 3, Checklists 3.10
Do you minimize use of Premeasured dose dispensers can be
cleaning products? used to ensure products like phenols are
used only to the extent needed.
Are your chemicals securely Equip chemical storage shelves with
stored? secondary containment. Never use a
sink as secondary containment. Keep
secondary containment dry at all times.
Does your distillation unit Your distillation unit should have
have secondary secondary containment to prevent any
containment? spills from entering floor drains and to
Do you keep hazardous Keep articles like thermometers and spill
wastes from entering the cleanup rags out of the laundry to
laundry? prevent discharge to sewer.
Have you considered Flow restrictors on sinks and rinse See Appendix
installing water tanks will save water. Reduce rinse G.4 - Case
conservation devices? times whenever possible. Also, water Study #3
recyclers on distillation units can save Lab Saves
tens of thousands of gallons of water 39,000 Gallons
per year. per year of
Do you develop A Code of Practice for
photographs? Photoprocessing that
describes best management
practices and equipment is
available for free from the P2
Program by calling 873-
Do you properly dispose of Used photographic fixer See Appendix C.12 and
photographic fixer? contains high concentrations C.13 for a list of
of silver that should not be desilvering product
poured down the drain. Fixer vendors and recyclers that
should be desilvered before process photographic
pouring down the drain or fixer..
can be sent to an off-site
Code of Practice for Biomedical Laboratories Section 3, Checklists 3.11
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Code of Practice for Biomedical Laboratories Section 3, Checklists 3.12