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U.S. Department of Health and Human Services

Science & Research

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Volume III - 1.4 Environmental Health (EH)

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Other Laboratory Operations

Food and Drug Administration

DOCUMENT NO.:

III-03

VERSION NO.:1.4

Section 1 - Environmental Health & Safety

EFFECTIVE DATE:
04-19-04
REVISED: 01-29-13

Environmental health comprises aspects of human health, including quality of life, that are determined by interactions with physical, chemical, biological, and social factors in the environment. It also refers to the theory and practice of assessing, correcting, controlling and preventing those factors in the environment that may adversely affect the health of present and future generations. (from the Pew Environmental Health Commission).

Chemical releases into the environment can have an adverse effect on human health and may result in human disease, not to mention the remainder of the environment. Many of the chemicals ORA uses can have an adverse environmental effect. Two sources of pollution from the laboratories are air contamination from building exhausts and waste disposal. Laboratory exhaust is not uniformly regulated, but waste disposal is closely regulated.

Hazardous substances are used every day in the laboratory. The previous safety sections describe some of the programs designed to mitigate the hazards associated with the use of hazardous substances. What about when we are done working? The left-over chemicals, reagents, media are disposed in accordance with the various regulations designed to protect our environment from hazardous waste.

The Environmental Protection Agency is the Federal Agency most responsible for promulgating laws designed to protect the environment. Occupational Safety and Health Administration (OSHA) and the Department of Transportation (DOT) have also promulgated regulations regarding environmental health as it applies to our laboratories. Applicable EH regulations include, but are not limited to the following:

  • Code of Federal Regulations (CFR)-40 Parts 260 - 300, Protection of Environment
  • EPA Resource Conservation and Recovery Act , CFR40, Parts 124, 260-268, 270- 272,280.
  • EPA Toxic Substances Control Act , applicable regulations in Title 40, CFR, Parts 700-763, 790-799.
  • Clean Air Act (EPA), applicable regulations in Title 49, Code of Federal Regulations (CFR), Parts 25, 50-53, 60-61.
  • Clean Water Act (EPA), applicable regulations in Title 49, CFR, Parts 25, 104-117, 129, 131, 135-136.
  • Comprehensive Environmental Response, Compensation, and Liability Act (EPA), applicable regulations in Title 40, CFR, Parts 700-763, 790-799.
  • Occupational Safety and Health Act (OSHA), applicable regulations in Title 29, CFR, Part 1910.
  • Hazardous Materials Transportation Act (DOT), applicable regulations in Title 49, CFR, Parts 172-177.

The State, County or Public Utility District will likely have additional requirements for proper waste disposal. The local Hazardous Waste Manager has a hazardous waste program document providing guidance on proper waste disposal through detailed step-by step instructions.

The term hazardous waste is defined as any solid, liquid, semi-solid, or contained gaseous waste, which, because of its quantity, concentration, or physical, chemical, or infectious characteristics may:

  • Cause or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness, and
  • Pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of, or otherwise managed.

Hazardous waste results from the conduct of research and analytical testing, unused or out of date hazardous chemicals and their containers, samples, empty containers that previously held a toxic chemical, batteries, waste oils, TLC plates and packed columns, asbestos, mercury, items contaminated with hazardous chemicals, and material generated during spill clean-up operations. Prior to disposal, one must stop to determine if any waste generated is hazardous.

Definitions, critical in interpreting the waste regulations and understanding how to manage the waste on-site, can be found in 40 CFR 261 Subparts C and D. It is imperative everyone understands what chemicals are listed on EPA's "P" list; these wastes are segregated from other waste streams. Chemicals listed on EPA's "P" list of acute hazardous wastes are more highly regulated and call for additional management and expense.

Contact the Hazardous Waste Manager and the local Hazardous Waste Management Plan for any question regarding waste prior to disposal (e.g. determining if waste is hazardous). Annual hazardous waste training should be given for all waste generators.