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Subject:
[DCHAS-L] Bibulous Paper Disposal
Date:
Nov 13, 2025 23:49 UTC
Author:
Filiberto Palacios <00001f5128a5fa0b-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
From:
Ryan, Patrick <00002325d83b98ec-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
Subject:
Re: [DCHAS-L] Phenolphthalein or Replacement?
Date:
Nov 13, 2025 23:16 UTC
Reply-To:
ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
Message-ID:
<SJ2PR02MB938922DB963C03D09356DB36BCCDA**At_Symbol_Here**SJ2PR02MB9389.namprd02.prod.outlook.com>
In-Reply-To:
<48CE82CB-AE37-405E-A20B-79DC37A67C2C**At_Symbol_Here**ilpi.com>
Rob,
Drain disposal prohibitions are usually related to regional and/or municipal discharge permits that affect drain disposal requirements and may also involve “40 CFR 403.5(b) - National Pretreatment Standards:
Prohibited Discharges”. These involve drain disposal where effluent may interfere with a POTW (Publicly Owned Treatment Works).
More Information:
https://www.ecfr.gov/current/title-40/chapter-I/subchapter-N/part-403/section-403.5
40 CFR 403.5 -- National pretreatment standards: Prohibited discharges.
Your reference of 40 CFR 372.38(a) indeed involves EPCRA & TRI Reporting relates to
Toxic chemical release reporting requirements for facilities in certain industries handling a TRI-listed chemical, and
manufacturing, processing, or using that chemical above a specific threshold quantity.
https://www.epa.gov/toxics-release-inventory-tri-program
EPA regulations are vast and knowing which regulations apply to a specific situation is the key.
Patrick A. Ryan, CIH, CSP, CHMM
From: ACS Division of Chemical Health and Safety <DCHAS-L**At_Symbol_Here**Princeton.EDU>
On Behalf Of Info
Sent: Thursday, November 13, 2025 12:34 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] Phenolphthalein or Replacement?
**External Sender**
Wow, Patrick, this is getting interesting! I did find phenolphthalein listed in Table 1 of 40 CFR Part 372.65 with some other Nasty Things: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-J/part-372/subpart-D But
this is apparently TRI/SARA rather than anything to do with water or wastewater, per se.
The *D022 code specifically refers to the chemical *Chloroform, not phenolphthalein. Phenolphthalein has no D022 waste code.
Patrick A. Ryan, CIH, CSP, CHMM
**External Sender**
I see where you are coming from. I am virtually on the same page, and I brought your argument up with our EHS representative.
"Phenolphthalein should not be poured down the drain. It is classified by the EPA as a toxic hazardous waste (D022) under 40 CFR §261.24 – Toxicity Characteristic due to its potential carcinogenic properties.
Any solutions, residues, or contaminated materials containing phenolphthalein must be collected and disposed of through the hazardous waste program, not through the sanitary sewer.
Please label any waste containers as “Phenolphthalein Waste – Toxic (D022)” and store them in your designated hazardous waste accumulation area until Environmental Health & Safety can arrange
for proper disposal. Hope this helps"
I have not had any firm responses about other indicators such as bromthymol blue. I am led to believe then, this is a safe alternative to phph and we can therefore send our neutralized NaOH and HCl, down the drain with bromthymol blue.
435.767.7714 Google Voice & Text
ᐧ
I am a complete neophyte with respect to waste regulations. Can someone please explain why this conversation is even happening? I can’t see any statistically possible way pouring this down the drain poses a risk to anyone or anything. To
wit:
Phenolphthalein is normally used as a 1% by mass solution at most - usually 0.1% if titrating a dilute or weak acid. And one uses one or two drops per titration; maybe three if 0.1%.
So even if I had a full lab class of 24 students and each did 3 titrations that afternoon, that’s maybe 150 or even 200 drops - less than half an ounce.
Half an ounce is about 15 mL. At 1% by mass that’s 0.15 g of phenolphthalein, 150 mg. Figure with glassware washing and whatnot, each student is going to put at least 4 gallons down the sink so call it 100 gallons total, or 400 liters
in round numbers.
Phenolphthalein has a molar mass of 318 g/mol, so we’re talking 0.0004717 moles. In 400 liters of water. So it’s 0.00000118 molar. Which is 0.375 ppm in the waste stream. And that’s before being diluted by the rest of the building and
campus which will take that down another couple orders of magnitude.
1. I doubt any wastewater authority would be looking for, let alone be able to detect, what will ppb levels of the stuff where it hits the monitoring point.
2. Sure, phenolphthalein is a suspected human carcinogen but according to the 15th NTP Rerpot on Carcinogens “The data available from epidemiological studies are inadequate to evaluate the relationship between human cancer and exposure
specifically to phenolphthalein.” And that’s from looking at people that ingested 5-10 mg (or more) orally over long periods of time (to get a 5 mg dose from our
0.375 ppm waste stream would require drinking 13 liters of it). Even in the rodent models, it took fantastically high dosages to produce effects (hundreds or thousands of ppm daily).
3. So this clearly comes down to Regulations somewhere.
So, what specific Regulation is being applied here, is it bound by hazard (regardless of risk) vs the risk (which is based on the actual amount) or some absolute ppm level, and is this something local wastewater authorities can mandate
on their own?
When I checked a couple of SDSs for phenolphthalein solution they indicated they were mixed with ethanol and had a flashpoint below 60c, which makes the stock solution ignitable and a characteristic hazardous waste. Presumably you are
diluting it as part of a reaction. If the alcohol is diluted to less than 24% it is no longer a characteristic hazardous waste (by definition) but may still be ignitable and prohibited by the sewer authority.
I found two different SDSs for bromothymol blue solution, one of which used IPA and, again, a flashpoint less than 60C.
But, even if you use an aqueous based dye you might still be not allowed to sewer it; some sewer authorities have prohibitions from dyes being sewered.
Hence, it should be collected for waste disposal, the question is does it meet the RCRA definition of a hazardous waste (EPA code D001) or is it collected and disposed of as a nonRCRA (Liquid Industrial Byproduct in MI) waste?
Our School's EHS responded to a question that was brought up about phenolphthalein:
"I verified this with the wastewater district, and they confirmed that it [phenolphthalein] cannot be disposed of down the drain. I want to be cautious here if we start
discharging materials improperly, it could trigger a wastewater audit and potentially open Pandora’s box for the college."
What do you all do? Are you still using phenolphthalein or have you replaced phenolphthalein with something like bromthymol blue or something similar? Do you get the same results or better?
Are you still using phenolphthalein, if so how do you deal with the waste? If collecting the waste, is it worth the cost of disposal?
435.767.7714 Google Voice & Text
ᐧ
Environmental Health and Safety
Office of the General Counsel
Michigan Technological University
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