From: James Saccardo <James.Saccardo**At_Symbol_Here**CSI.CUNY.EDU>
Subject: Re: [DCHAS-L] Proper Disposal of Carosafe solvent.
Date: Wed, 6 Jan 2016 22:56:07 +0000
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: fa4b755e5f534af4a427bbccf5ca3edd**At_Symbol_Here**MBOX-02.FLAS.CSI.CUNY.EDU

Clearly not a RCRA characteristic waste, however, Propylene glycol is regulated by the Clean Water Act Effluent Guidelines for organic chemicals, plastics, and synthetic fibers (OCPSF). It worthwhile checking to see of the other components are regulated under CWA. None are RCRA.

PG is also regulated under the CAA - (although e cig users are probably exempt).

To complicate things, Carosafe can also have traces of formaldehyde from the fixative process (does the SDS mention this?). So your purchasing it with potentially ppm levels of formaldehyde - it is not the sole active ingredient, therefore it will not carry the RCRA U122 code, however, just something else to consider when performing your waste determination. Perhaps having an analytical done (TCLP) for formaldehyde might be due diligence to give you an idea how much (if any) formaldehyde is in the waste.

You need to consider your generator status (CESQG, SQG), the volume of waste disposed in a given time period, and the environmental fate of drain disposal - what happens to your discharge in your municipality (POTW, leach field, etc.) to know how to legally dispose of it.
If your volume is significant (>1L), it is best to accumulate as nonhazardous waste and send out with a TSDF.

I am a SQG and I send this material out as non-haz to a TSDF in 5 gallon containers at a cost of ~ $100/ea (not to err on the side of caution, because we feel it is the right way to handle the disposal). I think putting it down the drain is pennywise and pound foolish. Our sanitary waste goes to a Public Owned Treatment Works that might conditionally accept this discharge in defined concentration per unit time, but the process and paperwork could be onerous with no guarantee of acceptance. I can sleep better at night knowing that I did not cause its uncontrolled release to the environment.
Do what is right, environmentally not financially, then ask yourself if you are meeting the minimum requirements of the law.
James Saccardo, MS, CHMM

-----Original Message-----
From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**] On Behalf Of Richard W. Denton
Sent: Wednesday, January 06, 2016 1:58 PM
Subject: [DCHAS-L] Proper Disposal of Carosafe solvent.

Best of the New Year to everyone.
I was bombarded with a question yesterday about the right way to dispose of gallons of Carosafe liquid. It is a liquid that is used to preserve dead pigs and our biology department has gallons of it. This mixture consist of water (89%), propylene glycol (10.01%), 2-amino-2-ethyl-1,3- propanediol (0.66%) and 2-Phenoxyethanol (0.33%), according to the SDS.
Has anyone work with this liquid before and what is the best and legal way to dispose of it within NY state?
Thank you,
Richard Denton, CHO

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