Mark :  From my perspective here in Colorado, if it doesn't contain anythi ng infectious, i.e., "non-regulated", that can be taken out of the equation entirely.  If it contained a RCRA waste, (but not a "P-waste"), and it's RCRA empty, and no needle, regular soli d waste is fine.  If it has a needle, definitely a sharps container, but this gets tricky with RCRA stuff.  It is most likely that the company that takes the regulated waste, probably isn't licensed to handle a RC RA waste.

Jay Skarda
Director of Safety & Security
National Jewish Health

From: DCHAS-L Discussion List< /st2:PersonName> [mailto:DCHAS-L**At_Symbol_Here**list.uvm.edu] On Behalf Of Williams, Mark
Sent: Tuesday, June 15, 2010 10:07 AM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: [DCHAS-L] Syringe Disposal

Hi All,

We use syringes to deliver solvents. Some of the syringes have needles, some do not. None contain any biohazardous substance, but the solvents would be hazardous waste if disposed of.

*For syringes without needles, if the y are empty when disposed of, can we consider each syringe to be a RCRA empty container and throw them in the regular trash?

*What about empty, non-biohazardous syringes with needles?

I have done a little searching on thi s issue, but have not come up with definitive guidance.