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Checklist for Biomedical Waste Management - PDF by gps13265

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                                         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)

January 22,1997

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
this document.


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
Information Manual).

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
                                                                     everyone’s interest.
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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                           Section 1:
                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
       the facility.

    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.

Useful Questions:
 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.
 prevention 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
 Separation Program?
                                               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
 substitution opportunities?
                                               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
        local regulations.

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
q Disposal

 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,
                                       D.C., 1994)
                                           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.

                                       Roper labeling:
                                         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
                                             communication plan.

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
                                      employee training.

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
                  Section 2:

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
 Specialty                          Subspecialty

 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
 Transplantation                    biology

 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

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.

Organic Materials

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
        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
        sewer system.

        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
                                 Section 3:
                            Laboratory Checklists

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
                                           For hemoglobin.

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
                                           wastes disposal.
 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
                                          any changes.

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
                                          purchasing expenses.

 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
                                          fixative applications.

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
q     Immunology
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
                                      your application.

 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
                                          containing solutions.

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
                                          whenever possible.

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
Cleaning                                                                              Manual
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
                                          mechanical pumps.

 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
                                           amine substitutes.

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
                                          protect workers.

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

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