> I was curious what the DCHAS brain would say about this...when do you have to designate something (like sodium metal used in a distillation still) as waste? Do you define that point in time for your researchers?

In addition to the guidance EPA provides at the national level, various states have their own rules related to this question. For this reason, lawyers, not chemical intution, are the drivers in making this determination. With this in mind, I’m not aware of many laboratory organizations that have the resources to provide advice that point in time for its researchers.

(Much less help researchers understand the EPA’s concept of “inherently wastelike” as a regional or state inspector might interpret that phrase.)

- Ralph

Ralph Stuart, CIH, CCHO
ralph**At_Symbol_Here**rstuartcih.org

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