Hello All involved:
I think Tarin Brousseau's concern about drug disposal is laudable. Thirty
years ago, when I was Environmental, Health and Safety Director for a large
chemical company, we would have been delighted when one of the chemists stepped
forward with a problem of this kind. We would have tried to find a solution
taking into account the nature of the waste as well as the quantity and the
local discharge situation.
Of course you can deal with the waste summarily, calling it hazardous, and
shelling out quite a bit of money for its disposal as hazardous waste.
The questions to be asked are:
1. How much analytical waste is generated and what would make it hazardous?
I assume we are dealing with an analytical lab working for the Dept. of Justice.
It's likely that only small samples (1 g or less) are dealt with
in the analysis.
2. To where does the lab discharge its waste? Is it a large municipal
treatment plant? If so, the ultimate dilution may render the toxicity concern
insignificant. That concern should be discussed with the operator of
wastewater treatment plant, hopefully resulting in an
appropriate discharge agreement.
3. If there is a holding tank, how fast does it fill and how often does it
need to be emptied? That will give Tarin and the facility safety officer (is
there one?) an idea about the disposal cost involved.
4. As Walter Brooks suggested, the analytical lab needs to find out more
about the local and State regulations governing hazardous waste generators. As a
hazardous waste generator a facility becomes subject to an
extensive layer of bureaucratic requirements. Just
consider that you would have a holding tank for hazardous waste on your
premises, and also that the potential for exposure from this tank operation is
greater than a direct discharge of the wastewater into a
municipal treatment plant.
I do think that Tarin Brousseau's concern can be dealt with in a low key
and rational way. Not every unclear situation requires a whistleblower to get
Good luck Tarin.
Heinz Trebitz, Ph.D.
Thetford Center, VT
Sent: Tuesday, June 17, 2014 5:42 PM
Subject: Re: [DCHAS-L] Compounds washed down the
There is no carbon filter that will get
significant amounts of the many kinds of chemicals and drugs from this
kind of lab. And a neutralization tank is a box of marble chips that
only raises the pH of strongly acidic wastes. This tank can have no effect
whatever on the chemicals you are washing down the drain. It is well-known that
many drugs can make it through the several filtering procedures in a municipal
waste treatment plant.
Even more interesting, it is your employer's job to deal with this issue,
not yours. As Walter suggested in his reply to you, you could have the
"holding tank" pumped out---IF THERE IS A HOLDING TANK. Ask your employer
where the holding tank is and how often it is pumped out. My guess is
there isn't one.
And if there isn't, I think a whistleblower call to another agency, i.e.,
the NJ Department of Environmental Protection, might bring justice to the
Monona Rossol, M.S., M.F.A., Industrial Hygienist
President: Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
181 Thompson St., #23
New York, NY 10012 212-777-0062
From: Secretary, ACS Division of Chemical Health and Safety
Sent: Tue, Jun 17, 2014 12:15 pm
[DCHAS-L] Compounds washed down the drain
From: Sylvia Tarin Brousseau <sock5108**At_Symbol_Here**aol.com>
I am a drug chemist for DOJ. We routinely use mortars, pestles, etc. in the
course of our analysis. Is there a sink filter (carbon?) to catch residual
compounds being washed down the drain? We do have a neutralization tank that
does some filtering. We have chemists that are worried about drugs (pharm and
otherwise) appearing in the food chain due to the waste water. Any insight