Laboratory Safety and Compliance

Animal and Plant Health Inspection Service (APHIS)Federal rules require that anyone wishing to ship biological material, hazardous material, and/or dry ice must first receive shipping training. Hazardous material is defined as any material or substance that poses a risk to the health and safety of the public, property or the environment during transportation. Examples of commonly shipped material that may be regulated are: alcohols, such as ethanol solutions, formaldehyde solutions, xylene, chemical mixtures, newly synthesized compounds, solvents, lubricants, and corrosives (acids or bases which are corrosive to the skin). Regulations may also apply to some commercial products such as paints, batteries, cleaning products, etc.

DOT specifically defines the hazardous substance as any material that is listed in the 49 CFR Hazardous Materials Table which can be accessed at: CFR 49 Hazardous Materials

If you anticipate a need to ship any of these types of materials you must first submit an Intent to Ship Biological or Hazardous Material Form. To begin this process, click on the Intent to Ship link below. EH&S will contact you within one business day.

If you experience any difficulty with the form, please contact Lab Safety personnel at (248) 370-4196. 

Intent to Ship Hazardous Materials

 Please submit your Intent to Ship form two business days prior to shipping.

• Intent to Ship Hazardous Material Form (PDF)

Shipping References

Several agencies regulate the shipping of biological and hazardous materials. Regulations which apply to the packaging and shipment of such materials are as follows:

• U.S. Department of Transportation (DOT)
• 49 CFR Parts 171-180 & amendments
• International Air Transport Association (IATA), Dangerous Goods Regulations
• International Civil Aviation Organization (ICAO), Technical Instructions for the Safe Transport of Dangerous Goods by Air
• DOT Letter of interpretation – defines offeror

Importing or Exporting Animals, Insects or Plants

• Importing Drosophila (Indiana University)
• Animal and Plant Health Inspection Service (APHIS)
  • APHIS - Import and Export

It is critical that all hazardous waste generating departments on campus play an active role in hazardous waste minimization. As indicated below, we have outlined several suggestions with regard to hazardous waste minimization. It by no means lists all of the possible methods of minimization available; nor are any of the methods specified below mandatory. Generating departments on campus are requested to review these methods for applicability, identify which techniques are (or can be) used in their areas, and provide any additional methods of waste minimization that their areas currently, or intend to, employ. The following describes common waste minimization techniques:

1. Process Modification in Laboratories
   1. The use of microscale experiments and glassware.
   2. Many organic and inorganic synthesis procedures have been successfully designed so that the product of one synthesis is the starting material for the next. Chains of from two to six steps have thus been designed with a good variety of syntheses. When each step is complete, characterizing measurements are made on a few milligrams of material. The rest goes back into the process so that no product from the earlier steps is left to be disposed of or to be stored.
   3. Storing radioactive animal wastes which contain short half-life (<90 days) radionuclides in freezers and holding them till they are no longer regulated as Radioactive Wastes.
2. Waste Exchange for Laboratories
   Many laboratory materials treated as chemical wastes are actually surplus chemicals which are reusable; unused chemicals can constitute as much as 40% of the hazardous waste generated from laboratories.Therefore, as often as is possible, chemicals intended for disposal by a department should first be made available to other departments that may utilize them. When you complete the on-line Hazardous Waste Pickup form please indicate under additional “Special Handling Instructions” that the material to be picked up may be available for redistribution. Upon the waste pickup the EH&S department will determine the usefulness of the material and decide whether or not to offer the material for redistribution.
   
   Chemicals desirable for redistribution:
   
   
   1. Solvents:
      1. Acetone
      2. Chloroform
      3. Dichloromethane
      4. Ethyl Acetate
      5. Formaldehyde
      6. Glycerol
      7. Hexanes
      8. Isopropyl alcohol
      9. Methanol
      10. Methylene chloride
      11. Petroleum ether
      12. Toluene
      13. Xylenes
   2. Acids:
      1. Acetic acid (glacial)
      2. Hydrochloric acid
      3. Sulfuric acid
3. Product Substitution in Laboratories
   1. Histology Laboratory: The substitution of citric acid based AmeriClear for xylene, benzene and toluene containing reagents.
   2. Radioactive laboratories: Substitution of non-hazardous proprietary liquid scintillation cocktails for standard xylene or toluene based cocktails in radioactive tracer studies.
   3. Physical Chemistry Laboratories
      1. Isopropyl alcohol is as suitable as carbon tetrachloride in the measurement of vapor pressure-temperature relationships by isotensiscope.
      2. Determination of molecular weight by freezing point lowering methods can use cyclohexane as the solvent, rather than benzene.⁵
   4. General Academic Laboratories
      1. In the standard test for halide ions, cyclohexane can be substituted for tetrachloride to extract the halogen.
      2. Benzene or carbon tetrachloride used as reagents or solvents can be replaced by less hazardous materials
      3. Spent glassware cleaning solutions such as Chromic acid and alcoholic potassium hydroxide solution can be replaced by one of several super-surfactant laboratory detergents.
      4. Qualitative analysis schemes for heavy metals have been developed that replace sulfide ion by hydroxide ion as a central reagent.
      5. In some organic synthesis, hypochlorite ion can replace chromate ion or other oxidizers.
   5. Analytical Laboratories
      1. Extraction solvents can be selected so as to minimize hazards and increase recoverability.
      2. Sample sizes can be reduced, thus reducing the quantities of extraction solvents and or derivatization reagents.
4. Incorporating Neutralization Methods into Student Laboratory Experiments. Neutralization of waste chemicals to allow drain disposal is considered "treatment" under strict interpretation of the EPA's definition of "treatment," and requires a special Permit (See Section VII: Drain Disposal). However, since "a waste is not a waste until you call it a waste" incorporating the neutralization process as part of a "student experiment" is allowed, and in fact encouraged. Several examples of these types of experiments are available upon request from the Office of Environmental Health and Safety.
5. Product Substitution in Non-Laboratories. Substitution of non-hazardous or less toxic materials in chemical processes and experiments should be utilized as much as possible.
   
   Examples:
   1. The use of water based inks instead of solvent based inks in printing operations.
   2. The use of non-halogenated solvents in parts washers or other solvent processes.
6. Bulking (vs. "Lab-Packs") Solvents
   
   1. Definition of the "Lab Pack": The term "lab-pack" refers to placing several sealed containers of compatible hazardous wastes into a larger vessel (e.g. a 55-gallon drum) along with a packing material (such as vermiculite) in order to transport the wastes to a disposal/incineration facility. The contractor responsible to semi-annually remove this University's wastes is responsible to lab-pack the material properly prior to transport.
   2. Definition of "Bulking": "Bulking" refers to emptying smaller containers of like hazardous material into ONE accumulation vessel (e.g. a 55-gallon drum), and transporting this vessel to the disposal site.
   3. The Advantage of Bulking Solvents on Campus: A 55-gallon "lab pack" of waste solvents can hold only 15 gallons of solvents (due to the limitations of lab packing techniques and materials). This means that only about one quarter of the drum's volume is used, and yet it costs four times more than bulking the material. Therefore, since solvents are a large contributor to this University's waste stream, bulking them can easily generate large cost savings. If any generating department believes that it uses one or more solvents in large quantities throughout the year, its Hazardous Waste Coordinator should contact the Office of Environmental Health and Safety, so that the techniques of accumulating and storing these wastes can be explored. Many factors must be considered and discussed, such as removing sources of ignition in and around the bulking area, and assuring adequate ventilation during transfer of the solvent(s).
7. Reclamation. Some generating departments may reclaim precious metals and valuable chemicals from their waste streams. Successful reclamation can reduce waste treatment and chemical purchase costs. Some examples of this are:
   1. Photo fixer waste can be processed (by an outside vendor) to reclaim silver.
   2. Mercury can be collected and sold to a vendor for redistillation.
   3. Fuel grade solvents and used motor and pump oil can be reclaimed by a vendor (e.g. Safety-Kleen or Edward's Oil) for use as an energy source.
8. Segregation and Characterization
   1. Hazardous wastes should NOT be mixed. And, hazardous wastes should NEVER be mixed with nonhazardous wastes.
   2. Waste bottles should be labeled as to their exact content. Segregation and characterization allows waste to be redistributed for reuse if someone else in the University system can use the chemicals And, even if the waste cannot be redistributed, segregation and characterization simplifies waste packaging and minimizes cost.
9. Inventory Control
   1. Only the quantity of chemical required for specific projects should be purchased. In other words, lower "unit" pricing alone should not promote large quantity purchasing. This (initially attractive) method of buying chemicals often leads to surplus product, wherein the purchaser has 1) paid for product that will not be used, and 2) must additionally pay for the surplus to be disposed of.
   2. Chemicals stored in a "shared" stockroom that have been left by personnel (or students) no longer with the University should not be ignored. These chemicals should be examined, and either internally redistributed, or listed for disposal/redistribution on the Hazardous Waste Pickup form.
   3. When purchasing automated equipment, the amount of hazardous waste generated by the machine should be considered as one of the primary purchasing criteria.
10. Training. Those who purchase and work with hazardous materials should be trained in the importance of hazardous waste minimization strategies and the methods utilized in their areas.