Laboratory Chemical Waste Management
Introduction
The Environmental Health & Safety (EHS) Department manages and directs a comprehensive chemical & laboratory safety program. To ensure that environmental and work place safety regulations are being met and maintained, the EHS Department manages and oversees all hazardous chemicals and wastes used or generated at the Medical Center.
The medical center policy is zero tolerance for non-compliance with Environmental Regulations. The enclosed procedures must be followed to comply with rules from the U.S. Environmental Protection Agency (EPA) and the Massachusetts Department of Environmental Protection (DEP), which regulate the disposal of hazardous wastes. The following recommendations are provided to help ensure proper regulatory compliance and provide and safe work environment.
General Guidelines
Potentially Hazardous chemicals must be disposed of in accordance with federal and state regulations and procedures established by EHS. Your department may also have procedures that you are required to follow. Contact your supervisor, instructor or EHS before discarding of any potentially hazardous chemical.
The following guidelines will assist waste collection:
Satellite Accumulation Areas
These are locations within laboratories where chemical wastes are collected and properly stored until they are picked up by EHS.
SATELLITE ACCUMULATION AREA
Please Post
Do you know your responsibilities for proper handling of hazardous waste?
Please review the following requirements to ensure that you comply with environmental regulations and safe handling procedures.
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TRAINING: Environmental regulations require training of people who generate or handle hazardous waste. Training must take place within six months of date-of-hire; and annually thereafter. Training is offered on a regular schedule by Environmental Health & Safety (EHS). Check EHS webpage: http://home.caregroup.org/templatesnew/departments/BID/safetydepartment CONTAINER LABELING: All hazardous waste containers must have a white BIDMC hazardous waste label at the time waste is first placed into the container. Affix the “Hazardous Chemical Waste for Disposal” label to waste collection containers. The waste label must accurately identify the content of the container and be filled out completely. EHS supplies labels. Call EHS if you need labels or additional instructions. EHS does not provide waste collection containers, for assistance with finding proper waste collection containers, please call EHS office at 7-3088. CONTAINER CLOSURE: Hazardous waste containers must be closed at all times during storage, except when waste is being added or removed. Keep containers closed. Regulations do not permit open funnels in waste containers. STORAGE: For safety and environmental reasons, hazardous waste must be stored in a designated "Satellite Accumulation Area". These areas must be inspected weekly for container leakage. Containers must be removed from the Satellite Area within three days after the waste container becomes filled. Closed, properly labeled containers that are partially filled may remain in a Satellite Accumulation Area indefinitely. TO ARRANGE FOR
WASTE-PICKUP, call 7-5154
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The Environmental Health & Safety Department has a chemical waste disposal service in place that is designed to keep the Medical Center and Research Laboratories in regulatory compliance with proper disposal requirements. The Chemical Waste Collection program requires the laboratory generating chemical waste to contact Matt Teeter of Environmental Health & Safety at extension 7-5154 or pager 38820 to schedule a collection or drop off time. All chemical waste must be brought to a collection area within 3 days of filling a chemical waste container. For Chemical Spill procedures/details click here.
The following are designated as Main Accumulation areas for chemical waste
collections (waste will be collected at the location which it is generated).
· Slosberg-Landay Basement, SL-B03
· Research East Basement, RE-10
· Research North 1st floor, RN-185
· 21-27 Burlington Avenue 5th floor, 571B
Hazardous Waste Defined
Hazardous materials have hazardous characteristics such as: flammable, corrosive, reactive, toxic, radioactive, poisonous, carcinogenic or infectious. In a general sense, these materials are considered hazardous because they present a potential risk to humans and/or the environment. By law a hazardous waste is defined as a waste, or combination of wastes, that because of its quantity, concentration, or physical, chemical or infectious characteristics may cause or significantly contribute to an increase in serious irreversible, or incapacitating reversible illness or pose a substantial present or potential hazard to human health, safety or welfare or to the environment when improperly treated, stored, transported, used or disposed of or otherwise managed. Hazardous waste management plans generally separate waste into three broad groups: radioactive, chemical and biological. This guide addresses only chemical waste.
Hazardous waste includes a wide range of material such as discarded commercial
chemical products, process wastes and wastewater. Some chemicals and chemical
mixtures are hazardous wastes because they are specifically listed by the EPA.
Most of the common laboratory solvents are listed wastes. A chemical waste that
is not listed by the EPA is still a hazardous waste if it has one or more of
EPA's four hazardous characteristics: ignitablity, corrosivity, reactivity or toxicity.
Classification of Chemical Waste
A chemical waste is considered to be a hazardous waste if it is specifically listed by the EPA or DEP as a hazardous waste or if it meets any of the four hazardous characteristics below. If a chemical waste is not on the EPA list of hazardous wastes, and does not meet any of the hazardous waste characteristics, it is a nonhazardous waste. For complete definitions of hazardous characteristics of waste see the EPA regulation 40 CFR 261-Identification and Listing of Hazardous Waste.
Ignitable/Flammable
A liquid which has a flash point of less than 60°C is an ignitable waste (e. g. Acetone, Methanol). A solid is an ignitable waste if it is capable of causing fire through friction or absorption of moisture, or can undergo spontaneous chemical change which can result in vigorous and persistent burning under standard temperature and pressure (e. g. Benzoyl Peroxide). A substance which is an ignitable compressed gas or oxidizer is an ignitable waste (e. g. Propane, Hydrogen Peroxide).
Corrosive(Acid/Base)
An aqueous solution which has a pH less than or equal to 2 or greater than or equal to 12.5 (e. g. Hydrochloric Acid, Ammonium Hydroxide),or is a liquid and corrodes steel at a rate greater than 6.35 mm per year at a test temperature of 55°C, is a corrosive waste.
Reactive
A reactive waste is a material that is normally unstable and undergoes violent chemical change without detonating, can react violently with water to form potentially explosive mixtures or can generate dangerous or possibly toxic gases, vapors or fumes in a quantity sufficient to present a danger to public safety, health or welfare or to the environment; or a material that is capable of detonation or explosive decomposition or reaction at standard temperature (e. g. Picric Acid, Potassium Cyanide, Lithium Aluminum Hydride).
Toxic
A waste that contains one of the constituents in concentrations equal to or greater than the values listed in EPA regulation 40 CFR 261-Identification and Listing of Hazardous Waste is a toxic waste.
Disposal of Unknowns
All chemicals must be identified and containers properly labeled at all times. Each laboratory is responsible for seeing that this requirement is met. If an unknown chemical is discovered, label it as "unknown" and attach a note detailing any information about what the chemical may be or what experiment it may have been used for and where it was found. Contact EHS for disposal information. If you find any unlabeled chemical that has crystallized or there is any other indication that it may be unstable, DO NOT TOUCH IT! Contact EHS (617) 667-3088 immediately.
Requirements for Hazardous Waste Management in the Laboratory
Laboratories and other areas that generate hazardous waste are required to comply with the generator requirements of the Resource Conservation and Recovery Act (RCRA, CFR Title 40) and Massachusetts Hazardous Waste Management Regulations (310 CMR 30.0). Every generator site (laboratory) is subject to inspection by the EPA and DEP. The steps necessary for compliance are summarized below.
Labeling
Each container must be labeled with a BIDMC Chemical Disposal Label. When the container is full place the date when full on the label. Plan ahead and contact Matt Teeter of Environmental Health & Safety at extension 7-5154 or pager 38820 to arrange for a waste pick-up.
Room # _________________________ Fill Date
______________ Department ___________________________ Ext _____________ Contents _________________________________
% ________ _________________________________
% ________ _________________________________
% ________ _________________________________
% ________ Check the HAZARD: ____ Flammable
____ Acid ____ Base ____ Reactive ____ Toxic DATE RECEIVED IN ACCUMULATION AREA: _____________
Hazardous Waste for Disposal
Chemical Compatibility
The following chart is provided as a guide to segregating hazardous waste containers; it is not to be used for mixing chemicals. Containers of incompatible wastes must be stored in separate areas. Secondary containment tubs are available for purchase; contact EHS at 7-3088 for recommended products.
Many hazardous wastes, when mixed with other waste or material, can produce effects which are harmful to human health and the environment, such as (1) heat or pressure, (2) fire or explosion, (3) violent reaction, (4) toxic dusts; mists, fumes, or gases, or (5) flammable fumes or gases. Below are examples of potentially incompatible wastes, waste components, and materials, along with the harmful consequences that might result from mixing material in one group with material in another group. The list is intended only as a guide to indicate the need for special precautions when managing these potentially incompatible waste materials or components.
This list is not all-inclusive. In the lists below, the mixing of a Group A material with a Group B material might have the potential consequences as noted.
Chemical Compatibility Chart
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Group 1-A |
Group 1-B |
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Alkaline Liquids |
Acid Liquids |
Potential consequences: Heat generation, violent reaction
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Group 2-A |
Group 2-B |
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Aluminum |
Wastes in Group 1-A or 1-B |
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Beryllium |
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Calcium |
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Magnesium |
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Sodium |
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Other reactive metals and metal hydrides |
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Potential consequences: Fire or explosion generation of flammable hydrogen gas
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Group 3-A |
Group 3-B |
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Alcohols |
Concentrated waste in Groups 1-A or 1-B |
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Water |
Calcium |
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Lithium |
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Metal hydrides |
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Potassium |
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SO2Cl2, SOCl2, PCl3, CH3SiCl3 |
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Other water-reactive wastes |
Potential consequences: Fire, explosion, or heat generation; generation of flammable or toxic gases.
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Group 4-A |
Group 4-B |
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Alcohols |
Concentrated Group 1-A or 1-B wastes |
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Aldehydes |
Group 2-A wastes |
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Halogenated hydrocarbons |
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Nitrated hydrocarbons |
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Unsaturated hydrocarbons |
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Other reactive organic compounds and solvents |
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Potential consequences: Fire, explosion, or violent reaction.
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Group 5-A |
Group 5-B |
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Spent cyanide and sulfide solutions |
Group 1-B wastes |
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Potential consequences: Generation of toxic hydrogen cyanide or hydrogen sulfide gas
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Group 6-A |
Group 6-B |
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Chlorates |
Acetic acid and other organic acids |
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Chlorine |
Concentrated mineral acids |
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Chlorites |
Group 2-A wastes |
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Chromic acid |
Group 4-A wastes |
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Hypochlorites |
Other flammable and combustible wastes |
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Nitrates |
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Nitric acid, fuming |
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Perchlorates |
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Permanganates |
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Peroxides |
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Potential consequences: Fire, explosion, or violent reaction.
Empty Containers
Generally empty chemical containers are not considered hazardous waste. The container must be completely empty, that is all of the contents that can be removed by normal means must be removed and the residue must be less than 1%. The word "empty" must be written across the label. The container may then be disposed of in the regular trash.
An exception to the above applies to containers that held chemicals listed by the EPA and MADEP as "Acutely Hazardous Wastes". The most common laboratory chemicals found on this list are:
A complete list of the Acutely Hazardous Wastes can be found the EPA regulation 40 CFR 261-Identification and Listing of Hazardous Waste. Empty containers that formerly held any of these Acutely Hazardous Wastes in the pure unused form, not mixtures or spent material, must be disposed of as hazardous waste.
Mutagen Carcinogen Policy
Mutagens and carcinogens are used extensively in laboratories. A list of the most commonly used chemicals in this category is provided in the following table. (Remember this is not a comprehensive list). Mutagen or carcinogen waste in solid form or concentrated solution is hazardous chemical waste and must not be thrown in the trash or down the drain. Call the EHS office (7-3088) or email mteeter@bidmc.harvard.edu to arrange for pick-up of your hazardous waste or if you need more information.
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Chemical |
CAS Number |
Chemical |
CAS Number |
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1,2-Dibromo-3-chloropropane |
96-12-8 |
2-Aminofluorene |
153-78-6 |
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1,1-Dimethylethylenimine |
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Benz[a]anthracene |
56-55-3 |
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Ethylenedibromide |
106-93-4 |
Benzo[a]pyrene |
50-32-8 |
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Propylenimine |
75-55-8 |
Chlorambucil |
305-03-3 |
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Ethionine |
67-21-0 |
Cycasin |
14901-08-7 |
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3'-methyl-4-amino-azobenzene |
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Diazomethane |
334-88-3 |
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Urethane |
51-79-6 |
Dibenz[a,h]anthracene |
53-70-3 |
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Bromoethylmethanesulfonate |
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7,12-Dimethylbenz[a]anthracene |
57-97-6 |
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Chloromethylmethylether |
107-30-2 |
4-Dimethylaminazobenzene |
60-11-7 |
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Diepoxybutane |
1464-53-5 |
3-3'-Dimethylbenzidine |
612-82-8 |
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Dimethyleaminobezene |
60-11-7 |
1,4-Dinitrosopiperazine |
140-79-4 |
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1,1-Dimethylhydrazine |
57-14-7 |
N-Hydroxy-2-acetylaminofluorene |
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1,2-Dimethylhydrazine |
540-73-8 |
3-Methylcholanthrene |
56-49-5 |
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Ethidium Bromide |
1239-45-8 |
4,4'-Methylenebis(2-chloroaniline) |
101-14-4 |
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Ethylmethanesulfonate |
62-50-0 |
Methyazomethyl acetate |
5926-62-1 |
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Hydrazine |
302-01-2 |
1-Methyl-3-nitro-1-nitrosoguanidine |
70-25-7 |
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Methylhydrazine |
60-34-4 |
1-Naphthylamine |
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Methylmethanesulfonate |
66-27-3 |
N-[4-(5-Nitro-2-furyl)-2-thiazoyl]-formamide |
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N-Nitorsodiethylamine |
55-18-5 |
N-Nitroso-N-ethylurea |
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N-Nitrosodimethylamine |
62-75-9 |
N-Nitroso-N-methylurea |
684-93-5 |
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N-Nitrosodi-n-butylamine |
924-16-3 |
4-Nitroquinoline-1-oxide |
56-57-5 |
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N-Nitrosodi-n-propylamine |
621-64-7 |
Procarbazine |
366-70-1 |
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N-Nitroso-N-ethylurethane |
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1,3-Propanesultone |
1120-71-4 |
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N-Nitroso-N-methylurethane |
615-53-2 |
m-Toluenediamine |
95-80-7 |
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N-Nitrosopiperidine |
100-75-4 |
Uracil mustard |
66-75-1 |
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Polychlorinatedbiphenyls |
11141-16-5 |
4-Aminobiphenyl |
92-67-1 |
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ß-Propiolactone |
57-57-8 |
Benzidine |
92-87-5 |
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N-Acetoxy-2-acetylaminofluorene |
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3,3'-Dichlorobenzidine |
91-94-1 |
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2-Acetylaminofluorene |
53-96-3 |
3,3'-Dimethoxy-benzidine |
20325-40-0 |
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Aflatoxins- |
1162-65-8 |
2-Naphthylamine |
91-59-8 |
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Methylnitrosourea |
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17ß-estradiol |
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ø-Aminoazotoluene |
97-56-3 |
4-Nitro-biphenyl |
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The specialized handling and disposal required for hazardous chemical wastes, as well as the hazards, result in operational, economic, and safety reasons for minimizing the generation of such wastes. Listed below are several waste minimization techniques that may be put to practical use throughout the hospital. This is not a comprehensive list of all possible waste minimization methods, but those most likely to be found feasible to employ within the hospital environment. For more information, please contact the EHS Department.
All chemical users are required to consider hazardous chemical waste minimization during the planning of all chemical procedures. Waste minimization activity will be a periodic focus of safety audits in labs so that we can identify what works and build on our success throughout the rest of the organization.
Planning purchases
A substantial portion of the hazardous waste produced at this hospital consists of unused, outdated chemicals sometimes in unopened original containers.
Prior to purchase careful consideration must be given to:
· the amount of chemical required over a given period of time
· the shelf life of the chemical
· the costs of disposal.
Purchasing in bulk, in an attempt to reduce the purchase price of individual items, frequently results in needless disposal costs that far outweigh the savings in the original purchase.
Inventory practices
· Set up good inventory practices to check for and use products before expiration dates occur.
· Properly rotate all stock.
· Order only when necessary to prevent overstocking. Avoid the use of standing orders.
Substitution
Replace or substitute a toxic or hazardous chemical product with a non-toxic or less toxic substance. Check with suppliers and manufacturers for possible alternatives to the hazardous products being used. Many less hazardous substitutes are currently being developed.
Microscale procedures
Occasionally, work can be adapted to reduce the scale of experiments or procedures, thereby achieving acceptable results while using smaller quantities of chemicals and resulting in a decreased amount of waste. The use of smaller quantities of chemicals can also reduce occupational exposures to chemical hazards.
Recovery
Commercial waste processing companies recover many chemicals for reuse in the manufacture of commercial products. Silver and mercury may be recovered on site through commercially available filtration methods. The recovered material can then be reused or sold. Silver recovery is currently practiced in the Photography and Radiology departments and numerous labs. Recovery activity must be coordinated through the Safety Office to assure that proper permits are obtained and that the recovery complies with all other pertinent regulations.
Some chemicals can be reused several times in a procedure before needing to be disposed of as waste. Certain chemicals can be re-purified by distillation prior to reuse. Check with chemical manufacturers and distributors for technical information concerning chemical reuse. The Pathology department currently recycles quantities of xylene, xylene-substitutes and formalin using distillation methods. All recycling/reuse must be coordinated through the Safety Office to assure that proper permits are obtained and that the activity complies with all other pertinent regulations.