Re: Re[2]: Phenol/ Chloroform/32p mixed waste

[jdelahunt@cc.colorado.edu (John DeLaHunt)]

>     Acetone - U002 - CAS67-64-1 pursuant to 40CFR261.33 = Hazardous 
>     Substance (EPA); Hazardous Waste (EPA); Toxic Chemical (EPA) Cited in 
>     U.S. State Regulations: 23 states (write me direct for listing)

Also ignitable, D001, but with a vapor pressure that makes it dry out nearly
instantly in small quantity conditions.  U code wastes are not regulated
unless the material is "off-spec" -- so acetone is a U code waste if the lab
cannot use it anymore b/c of age, contamination, etc, not if it used in
accordance with procedures and sitting in < ml quantities for three seconds
in/on eppendorf tubes.

>     Dichloromethane - AKA Methylene Chloride - U080 - CAS 75-09-2 pursuant 
>     to 40CFR261.33 = Cardinogen (animal positive)(human suspected);  
>     Hazardous Substance (EPA); HAzardous Waste (EPA), Priority Toxic 
>     Pollutant (EPA); Toxic Chemical (EPA); Cited in U.S. State 
>     Regulations: 31 states (write me direct for listing)

See above for commentary on U listings.  As for carcinogenicity, the
material was suggested for use in genetics labs where products like
chloroform and ethidium bromide are standard.  Therefore, adequate
occupational protection against carcinogen uptake is presumed.

>     As per 40CFR261.11 "Waste listed in accordance with these criteria 
>     will be designated Acute Hazardous Waste"

40 CFR 261.11 applies to the EPA making determinations about what materials
are wastes and what wastes are hazardous wastes.  261.11 (a)(2) defines
clearly what acutely hazardous wastes are:  

oral LD50 Rat < 50 mg/kg,
inhal LC50 Rat < 2 mg/l,
dermal LD50 Rabbit < 200 mg/kg,
or otherwise capable of causing or significantly contributing to and
increase in serious irreversible, or incapacitating reversible, illness.

The F and K lists also carry H codes (to denote Acute Hazard), but the
difference between the U and P lists is the difference between hazard and
acute hazard.  Both acetone and dicloromethane are Hazardous (U-listed), not
Acutely Hazardous (P-listed).

>     I am not sure that these two chemicals would be the best choice for 
>     removing chloroform and phenol much less to mix with P-32

The basis of the suggestion was the remove the chloroform (the
characteristic D022 waste) from the dry solids.  Use of volatile solvents,
esp acetone or some other less than toxic material (ligroine, e.g.) removes
the hazardous waste consideration from the plastic tubes and tips, and
leaves only the radioactive hazard.  

The initial concern was about mixed waste.  Removing the "mixer" -- RCRA
regulation by characterisitic content -- makes management of the resultant
dry solid materials eminently easier.

Text of orignail question and response inluded for reference:

>>Mark Dater asked:
>>     
>>>>How do or would  you handle a mixed waste stream of pippetman tips and 
>>>>eppendorf tubes containing or contaminated with Phenol/Chloroform liquid
and 
>>>>32p (created during DNA extractions). Would you satellite accumulate. Hold 
>>>>for decay(140days) then ship as Hazardous waste (both solid and liquid) or 
>>>>ship offsite within 90days as Radioactive mixed waste?
>>>>Another question I have is the clarification of the definition of a  " 
>>>>Container". Do you consider a pippetman tip (AFTER USE) a container?, or is 
>>>>a bag full of tips a container? Could you consider them "empty" by 
>>>>definition or are they in fact hazardous waste?
>>
>>I submit that a modest increase in labor and materials per tube/vial would 
>>allow one to rinse a container (say with acetone or dichloromethane) to 
>>remove the chloroform (the RCRA ingredient) and decay the now-non-RCRA-Toxic 
>>waste in storage without regard to satellite accum rules.  I say a modest 
>>increase per eppie, but perhaps the cumulative effect over hundreds or 
>>thousands of eppies would preclude this option.
>


John

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