I agree. We have to complete an EPA form for waste generated and hauled away, not purchased.
Walter Benton HT(ASCP)QIHC Histology Supervisor Chesapeake Urology Associates 806 Landmark Drive, Suite 127 Glen Burnie, MD 21061 443-471-5850 (Direct) 410-768-5961 (Lab) 410-768-5965 (Fax) ChesapeakeUrology.com Voted a Best Place to Work by Baltimore and Modern Healthcare Magazines. ________________________________________ From: histonet-boun...@lists.utsouthwestern.edu [histonet-boun...@lists.utsouthwestern.edu] On Behalf Of Elizabeth Chlipala [l...@premierlab.com] Sent: Tuesday, April 15, 2014 2:16 PM To: Teri Johnson; 'dennis.h...@cookchildrens.org' Cc: histonet@lists.utsouthwestern.edu Subject: [Histonet] RE: Waste Flammable Info Please Teri That's interesting since we need to fill out a form every year that tabulates the waste generated and not what we purchase. I thought it was based upon the amount of waste generated. That was not our experience. The state came and audited us once we started disposing of waste at a rate of 55 gallons per month. That pushed us past that 650 gallons for a conditionally exempt small quantity generator and therefore we became a small quantity generator. They never asked us how much we purchased only what the waste stream was. Just my experience. Since the states monitor for this, it may vary from State to State how the EPA regs are interpreted or if State laws override federal regarding waste and classifications. Liz Elizabeth A. Chlipala, BS, HTL(ASCP)QIHC Premier Laboratory, LLC PO Box 18592 Boulder, CO 80308 (303) 682-3949 office (303) 682-9060 fax (303) 881-0763 cell l...@premierlab.com www.premierlab.com March 10, 2014 is Histotechnology Professionals Day Ship to Address: Premier Laboratory, LLC 1567 Skyway Drive, Unit E Longmont, CO 80504 -----Original Message----- From: histonet-boun...@lists.utsouthwestern.edu [mailto:histonet-boun...@lists.utsouthwestern.edu] On Behalf Of Teri Johnson Sent: Tuesday, April 15, 2014 12:00 PM To: 'dennis.h...@cookchildrens.org' Cc: histonet@lists.utsouthwestern.edu Subject: [Histonet] Waste Flammable Info Please Hi Dennis, I don't think that recycling will fix your EPA license issue. They care about how much you GENERATE through use, not whether it is actually being disposed of or even recycled. We had an issue with the EPA regarding our xylene generation at another facility I used to work in. When I tried to point out that we were recycling it, they said that didn't make a difference. Once it goes into use, it becomes generated waste. You might want to look at changing your practices so that you generate less, i.e. changing the processors according to block numbers or alcohol dilution rather than number of runs, or using smaller containers at the staining bench. Alcohol recycling is great, but you will never get back anything more pure than about 98% so you will need to continue to purchase absolute alcohol. The biggest difficulty is making sure you keep any xylene contaminated alcohol separate and out of the recycler. Xylene will not be removed from alcohol during alcohol recycling so you will still have contaminated alcohol. Anything containing xylene must be recycled as xylene (or manifested out as waste). I hope this helps, Teri Johnson Manager, Histology Genomics Institute for Novartis Research Foundation San Diego, CA 858-332-4752 _______________________________________________ Histonet mailing list Histonet@lists.utsouthwestern.edu http://lists.utsouthwestern.edu/mailman/listinfo/histonet _______________________________________________ Histonet mailing list Histonet@lists.utsouthwestern.edu http://lists.utsouthwestern.edu/mailman/listinfo/histonet CONFIDENTIALITY NOTICE: The information contained in this electronic message is intended solely for the personal and confidential use of the designated recipient(s) named above and may contain information that is protected from disclosure under applicable law. If you are not the intended recipient, or the employee or agent responsible for delivering it to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this transmission is strictly prohibited. If you have received this transmission in error, please notify the transmitting person/department immediately by email or telephone (410) 581-5881 and delete the message without making a copy. _______________________________________________ Histonet mailing list Histonet@lists.utsouthwestern.edu http://lists.utsouthwestern.edu/mailman/listinfo/histonet
