From: Rachel Harrington <safetygirl39**At_Symbol_Here**HOTMAIL.COM>
Subject: Re: [DCHAS-L] Waste storage question
Date: Thu, 5 Aug 2021 17:54:39 +0000
Reply-To: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID: CH2PR13MB4411FF63B15E3BB6436577FEC9F29**At_Symbol_Here**CH2PR13MB4411.namprd13.prod.outlook.com
In-Reply-To <7F3A6111-40EA-46E6-AAC5-384E5B2D87C5**At_Symbol_Here**keene.edu>


If you want to you could have your waste vendor profile the waste for you, this is actually an important regulatory element, characterizing your waste stream. There would be a charge for this but in the end you will be confident in how you handle it and will have identified all the associated waste characteristics of which there may be more than just flammable as mentioned by another member. 

Regards, 
Rachel Harrington, MPH

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From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU> on behalf of Ralph Stuart <ralph.stuart**At_Symbol_Here**KEENE.EDU>
Sent: Thursday, August 5, 2021 12:38:27 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Subject: Re: [DCHAS-L] Waste storage question
 
> I prefer to use the Fisher web site to look up safety and SDS information, as everything is clear and easy to understand.

Thanks for sharing that resource. I note that the Fisher SDS states that "Chemical waste generators must determine whether a discarded chemical is classified as a hazardous waste." Someone else shared a link to a 2016 EPA document that describes the regulatory process for the classification of waste solvents, assuming perfect information is available for the mixture. This guidance is at
https://www.epa.gov/sites/default/files/2016-09/documents/version_2_-_solvent_guidance_final_508_compliant_090116.pdf

Unfortunately, we don't have enough specific information available for this waste mixture to use the EPA's resource. So we will be erring on the side of caution and assuming it is flammable.

Thanks to everyone for sharing their thoughts on this question.

- Ralph

Ralph Stuart, CIH, CCHO
Environmental Safety Manager
Keene State College
603 358-2859

ralph.stuart**At_Symbol_Here**keene.edu

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