From: Monona Rossol <actsnyc**At_Symbol_Here**>
Subject: Re: [DCHAS-L] Compounds washed down the drain
Date: Wed, 18 Jun 2014 19:40:14 -0400
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 8D15965C99E4008-C0C-144E5**At_Symbol_Here**
In-Reply-To <9DE3D1FBFD8E40B28E65F570EB6D67F6**At_Symbol_Here**HeinzPC>

I would agree with everything you say if this were a private lab or even a university.  But this is a Department of Justice.  A chemist who was hired to do these analyses will not be allowed to spend time addressing this situation.  And I'm betting a cookie that bringing this up puts Tarin's job at risk.   My advice stands.  Tarin:  keep your head down and blow the whistle--and ask for anonymity.
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

-----Original Message-----
From: Heinz Trebitz <iht63**At_Symbol_Here**WAVECOMM.COM>
Sent: Wed, Jun 18, 2014 6:41 pm
Subject: Re: [DCHAS-L] Compounds washed down the drain

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 the  
    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 significantly
    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 resolved.
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 drain
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 DOJ. 
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

-----Original Message-----
From: Secretary, ACS Division of Chemical Health and Safety <secretary**At_Symbol_Here**DCHAS.ORG>
Sent: Tue, Jun 17, 2014 12:15 pm
Subject: [DCHAS-L] Compounds washed down the drain

From: Sylvia Tarin Brousseau <sock5108**At_Symbol_Here**>

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 

Previous post   |  Top of Page   |   Next post

The content of this page reflects the personal opinion(s) of the author(s) only, not the American Chemical Society, ILPI, Safety Emporium, or any other party. Use of any information on this page is at the reader's own risk. Unauthorized reproduction of these materials is prohibited. Send questions/comments about the archive to
The maintenance and hosting of the DCHAS-L archive is provided through the generous support of Safety Emporium.