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Lab waste disposal
Hi Everyone!
Wondering what is the correct way of disposing waste from day to day batching in a cosmetic lab? Waste being residues and failed experiments of emulsions, surfactant systems and expired raw materials. We currently collect these in drums but no one knows who to call or what documentation would be required for a company to come pick it up.
Thanks in advance!
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4 Replies
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The process would very much depend on your location and the compliance requirements in place. Surely you have someone in your organisation who is on top of this. In my case, in 2006, I co-founded two skincare manufacturing factories, which ran until 2023. And among my staff, I appointed a QC Manager who took care of this.
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Unfortunately, no one is on top of this matter in my organization, hence the need to figure this out by myself. I’m in NY metro area so any guidance in this forum would be greatly appreciated.
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I may be able to assist. mikethair@gmail.com
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I have some real-world experience in this area.
My first piece of advice is that you will get limited value in reaching out to a Consultant outside your State. The majority of your Guidance will come from your State’s Environmental Agency. Each State has an internal agency oftentimes similar to the FDA in function. While this will likely not be their primary function (they generally also regulate other Healthcare Industries as well). If you reach out however you will find the person who regulates these programs and can provide guidance.
In my case, I was called in to consult for DHEC (the South Carolina Agency). To be honest I was retained less for any specific knowledge but rather because there were very few Industry Consultants in my State. The issue was with a Cosmetic Manufacturer who had gone bankrupt and left behind over 30 drums of unlabeled/poorly labeled materials on the loading dock. The owner of the property had contacted the State for assistance. Based on the few barrels that had the original labels, we felt the majority of the materials were Sunflower Oil. However, without proper labeling and documentation (MSDS’s/COA, etc) I could not certify that the materials were indeed Sunflower Oil. In addition, they had discarded product BUT it was intermingled. Proper procedures would have been to maintain each product in separate containers with proper internal documentation.
We were able to get a Hazardous Material Disposal company to take the product but due to the poor documentation, their fee was significantly more expensive than it could have been. Had the oil been properly labeled and documented we could have diverted it to a local biodiesel company.
The takeaways were to maintain proper labeling and documents for all stored products including waste. Consult your State Environmental Agency for guidance. Do not intermingle products EVER! A drum is not your only storage option. You may want to have a documented procedure for this process in your SOP Manual and a process to place these materials in “QC/QA hold.” If properly done, it is usually affordable to retain a disposal company for these materials. They do exist. If you don’t do it right, still contact the disposal company but expect to spend more time and money to complete the process. This is truly an area where proper SOPs and Procedures will save you time and money. There should be a written document and properly monitored processes if you want to do it right.
A start (may not be the proper Agency but they can advise); https://dec.ny.gov/about
dec.ny.gov
The New York State Department of Environmental Conservation (DEC) was created on July 1, 1970 to combine all state programs designed to protect and enhance the environment into a single agency.
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