Anyone mind if I capture all of this great information into a blog for the LSI website? I’ll make sure to acknowledge everyone involved in this conversation

Stephen Taylor, Ph.D.
Executive Director

The Laboratory Safety Institute

www.labsafety.org

Stephen Taylor | LinkedIn

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On Thu, Nov 13, 2025 at 5:47 PM Saneliswa Magagula <saneliswam**At_Symbol_Here**gmail.com> wrote:

Hi-

I went through the thread and with a little digging I found that:

1. Since EHS already checked with the local wastewater treatment authority and determined that drain disposal would not be allowed, their guidance should be followed. They DO have the authority to impose prohibitions on chemical pollutants per the Clean Water Act (CWA 40 CFR 403).

2. I did not find that any EPA hazardous waste code applies to phenolphthalein (unless it is still >24% alcohol as Jeff mentioned). If dilute as we all understand it, it is not P-, F-, K-, or U-listed and does not exhibit hazard waste characteristics (Ignitable-D001, Corrosive-D002, Reactive-D003, and Toxic (D004-D043). The code D022 corresponds to chloroform as some have pointed out. 

3. Phenolphthalein falls within the definition of OSHA's "Select Carcinogen" (Listed as reasonably anticipated to to be a human carcinogen by NTP and listed as Group 2B - possibly carcinogenic to humans by IARC) and therefore qualifies as a Particularly Hazardous Substance (PHS). Dilution in this case is not considered when determining the classification. To put it simply, the EPA considers concentration in determining toxicity (determined by how much leaches into groundwater) but OSHA's PHS is based on the identity of the chemical regardless of concentration. From a regulatory stand point I would consider substitution when drawing up a policy for pregnancy in the lab. For disposal, it would be up to the local authority regulating sewer discharge.

4. Regarding substitution with bromothymol blue, I would follow the same logic in 1 and verify with the local authority whether other indicators can go down the drain. Even if a chemical is not a RCRA hazardous waste and not a PHS, under 40CFR403, Publicly Owned Treatment Works can still prohibit discharging it into the sewer system.

Regards,

Sane

_______________________________________________________

Saneliswa Magagula, CSP

On Thu, Nov 13, 2025 at 8:11 AM Samuella Sigmann <00001d2fb4580b5b-dmarc-request**At_Symbol_Here**lists.princeton.edu> wrote:

Like Rob, I am wondering about characterizing this as toxic. Seems to me that it could be considered de minimus. I would check with my local water treatment plant and have them weigh in. 

That said, I am no haz waste expert.
Sammye

On 11/12/2025 6:50 PM, David EldrEdge wrote:

Hi Rob,

I see where you are coming from. I am virtually on the same page, and I brought your argument up with our EHS representative.

This is the reply.

"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.

David EldrEdge

Co-Owner

NALTIC Industrials, LLC

de**At_Symbol_Here**naltic.com

www.naltic.com

888.891.0077 Main

435.503.4972 Cell

435.767.7714 Google Voice & Text

435.654.2727 Fax

ᐧ

On Wed, Nov 12, 2025 at 12:42 PM Info <info**At_Symbol_Here**ilpi.com> wrote:

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?

Thanks,

Rob Toreki

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On Nov 11, 2025, at 4:28 PM, Jeffrey Lewin <jclewin**At_Symbol_Here**MTU.EDU> wrote:

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?

Jeff

On Tue, Nov 11, 2025 at 9:01 AM David EldrEdge <Dave.EldrEdge**At_Symbol_Here**naltic.com> wrote:

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? 

or...

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? 

Warm regards,

David EldrEdge

Co-Owner

NALTIC Industrials, LLC

de**At_Symbol_Here**naltic.com

www.naltic.com

888.891.0077 Main

435.503.4972 Cell

435.767.7714 Google Voice & Text

435.654.2727 Fax

ᐧ

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Jeff Lewin

Chemical Safety

Environmental Health and Safety

Office of the General Counsel

Michigan Technological University

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Samuella B. Sigmann, MS, NRCC-CHO

ACS Committee on Chemical Safety, Chair 2022-2024

ACS Fellow, 2023

ACS Division of Chemical Health & Safety, Fellow & 2019 Chair,

Appalachian State University, Retired

Phone: 336 877 5147

Email: sigmannsb**At_Symbol_Here**retired.appstate.edu

 

 

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