Date: Wed, 20 Jun 2007 11:19:18 -0800
Reply-To: Brandon Wheeler <brandon.wheeler**At_Symbol_Here**CLARUSTECHNOLOGIES.COM>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Brandon Wheeler <brandon.wheeler**At_Symbol_Here**CLARUSTECHNOLOGIES.COM>
Subject: Re: "open" sharps containers


This is my first post so hopefully it goes smoothly.  I would hold the
same thoughts as Debbie and ask whether or not you actually have a
hazardous waste.  For instance if you have a P-Listed waste (hazardous)
in a syringe (container) and dispose of it, then you do have a hazardous
waste.  However, you said the syringes and sharps container do not
contain liquid.  If:


"All wastes have been removed that can be removed using the practices
commonly employed to remove materials from that type of container, e.g.,
pouring, pumping, and aspirating...." RCRA 261.7


then I would argue that you do not have a hazardous waste just sharp,
hazardous materials.  Of course if your chemicals are acutely hazardous,
then you have to perform three rinses with an appropriate solvent for it
to be considered "empty" by RCRA standards.  I am in no way an expert in
this area, but have an interest in learning more.  If other
professionals include some input, maybe we can both learn whether or not
you even have to label and dispose of your sharps as hazardous waste.






Brandon Wheeler

Project Chemist

Clarus Environmental Services, LLC

Eagle River, Alaska, 99577

(907) 694-4272 Ext. 15 

(907) 694-4271 Fax 

(907) 632-0110 Cell




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