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Posted By Patrick Taylor
Due to a recent visit by the HSE i have been asked to introduce a system of evaluating the risk to users of the waste created during routine analyses, and establish controls to ensure that some substances are not mixed (i.e. due to reactivity). The composition of the waste can, and often is, highly varied. This is due to the nature of the many test methodologies utilised within the pharmaceutical industry.
The main issue i have found is due to the fact that many substances are combined to produce a reagent mix which is then disposed of after use.
For example a mixture of acetic acid, mercuric acetate and perchloric acid has several different hazard properties and therefore could be disposed of in a predominantly acid waste, a heavy metals waste or even an oxidised waste.
This means a difficult choice as to which waste route is the safest for many of the mixtures.
Any thought or suggestions, in particular from individuals within the pharmaceutical industry, would be most appreciated as to how i could resolve this.
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Rank: Guest
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Posted By Robert K Lewis
Patrick
I cannot deceipher from your message the degree of manufacturing involved on your site but would suspect that there is going to be some hazardous waste streams. You will need to fit in with these if you can as I presume that your site will already have registration for their disposal. Also look closely at the discharge consents as some wastes may be acceptable in your discharges to drain.
The next port of call is going to be any chemical drainage sytems that you have on site. The volumes you produce compared to any manufacturing is going to be relatively insignificant. The final option is then to manage the waste stream yourself but this is complex and should not be done unless you can get a grip on the Hazardous Waste regs 2005.
To be quite honest I think there is an element of overkill here but I do not know your streams in detail to be able to give a full answer - that would in any case involve more investigation.
With regard to the procedures I believe that most analysts are well able to make disposal decisions without complex procedures. I think if your incompatibles are identified and appropriate arrangements made then the worst of the problem is over.
Bob
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