Date: Mon, 10 Aug 2009 11:31:23 -0400
Reply-To: Michael McCormick <mmccorm**At_Symbol_Here**LEARNLINK.EMORY.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: Michael McCormick <mmccorm**At_Symbol_Here**LEARNLINK.EMORY.EDU>
Subject: Re: Disposal of butyl lithium
In-Reply-To: <4A802EB1.2030507**At_Symbol_Here**> Dear Dona,
The law only prohibits the treatment/inactivation/neutralization etc. of chemical _waste_. A substance is not waste until it's declared to be waste. Therefore, the bottles of butyllithium solution in a lab are not waste, they are merely laboratory chemicals (just don't hang a waste label on them). As a laboratory chemical, these can be treated / quenched / deactivated / made less harmful _legally_. Once so treated, then declare the quenched stuff as "waste" and dispose of it via your normal route. At first blush, this may sound like semantics, but when you consider the practical ramifications, it actually makes common sense (to the extent EPA regulations can be common sense). This assumes that your state laws are like our and like most -- based on EPA regulation.

The end user (the lab or the researcher who purchased the chemical) should be sufficiently knowledgable to properly quench butyllithium. If they are not, then these people must be prevented from purchasing the material (and we must reexamine our educational system, but that's another thread). If these chemicals were orphaned by the departure of a grad student, post-doc, etc., then the management practices of the lab and/or the policies of your EHS office are bad.

Michael F. McCormick
Senior Lecturer
Department of Chemistry
Emory University
Atlanta GA 30322

voice 404/727-6531
fax 404/727-6586

"Dona Lee Wong, Ph.D." <dona_wong**At_Symbol_Here**HMS.HARVARD.EDU> on August 10, 2009 at 10:29 AM -0400 wrote:
Responses from users in MA and other states not permitting treatment of
hazardous chemicals to inactivate prior to disposal of particular interest

One of our chemistry labs has butyl lithium that they no longer use and
are trying to safely dispose of.  Massachusetts state law does not
permit any treatment of hazardous chemicals to inactivate prior to "safe
disposal".  Our normal process is to transfer any hazardous chemicals to
an isolated and dedicated room.  We have a contract with a local
company, skilled in hazardous materials, and trained personnel from that
company then remove the chemical waste.  The PI feels that moving the
butyl lithium to the waste facility would be more, rather than less,
dangerous and has requested that we have the butyl lithium removed
directly from their laboratory.  The latter, of course, is expensive and
the hazardous waste company suggests that if the butyl lithium is still
stored as received and should be stored in water-free hexane, then it
can be brought down to the holding facility.

Any experience or recommendations?

dona wong


Dona Lee Wong, Ph.D.
Associate Professor, Department of Psychiatry
Harvard Medical School
Director, Laboratory of Molecular and Developmental Neurobiology
McLean Hospital
115 Mill Street, MRC =23116
Belmont, MA 02478
Tel:  617-855-2042
FAX:  617-855-2058
e-mail:  dona_wong**At_Symbol_Here**

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