From:
Debbie Decker <debbie.m.decker**At_Symbol_Here**GMAIL.COM>
Subject:
Re: [DCHAS-L] Quenching n-butyllithium bottles
Date:
Jan 22, 2025 00:34 UTC
Reply-To:
ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID:
<CABNxZ9dKPab_3Xwn-OUoXQysKpRemNHK0kPoXzFf3U658n-CTg**At_Symbol_Here**mail.gmail.com>
In-Reply-To:
<CAEiU9vCmCR4W4WjqpAFe1oGUv056UOu2nZKMXvq5yv2n6VRFpg**At_Symbol_Here**mail.gmail.com>
So the favorite EH&S response applies here: It depends.
A hazardous material becomes a hazardous waste when you decide you no
longer want it. Up until that decision point, it remains a material and
you can do with it whatever you need to do. There are rules about
treatment of hazardous waste but treating a material to make it less
hazardous and safer to handle is encouraged. However, as Andrew points out, your jurisdiction will have regulations for the management of hazardous waste and reaching out to your local environmental quality department would be a good first step.
I didn't dig into the TCEQ rules very far - your institution might qualify as a small quantity or very small quantity generator which might give you some flexibility in haz waste management.
Remember, "waste" and "hazardous waste" are terms which have regulatory meaning so be cautious about willy nilly labelling "spent" materials with these terms.
Good luck
Debbie
Debbie M. Decker (she/her/hers), ACS Fellow
Chemical & Laboratory Safety Manager (ret.)
(916)616-7548
Opinions my own
Hello!
I was hoping you all would share some wisdom about when something counts as waste. I am at a small private institution with, unfortunately, little guidance in terms of chemical safety.
The questions:
When does something officially count as chemical waste?
Do you need a certification to quench or neutralize reactive chemicals, such as n-butyllithium?
The backstory:
This question came up as I discussed with my chair about n-butyllithium. She asked me about the quenching process. I told her our procedure, and she asked if we needed a certification to conduct that procedure. She pointed out that once the bottle is mostly empty that might count as chemical waste and technically we may not be allowed to neutralize it.
Since I didn't technically know the answer, I thought I would reach out to you guys.
Thank you for any advice/support you can provide.
Best,
Jonathan
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