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Chemical Lifecycle Management

| By Victor Belenchia, Clean Harbors

Chemicals in production and laboratory environments alike have three distinct lifecycle phases: the first is procurement and inventory storage; the second is use in a manufacturing process or research program; and the third is post-use, including onsite handling, removal and beneficial reuse, recycle or disposal.

A number of considerations including regulations, safety, material utilization efficiency, costs and sustainability govern all of the steps in this lifecycle. The challenge for laboratory and production managers is to balance these sometimes competing forces to create an effective process that meets the organization’s overall needs.

Proper chemical handling during processing is typically emphasized in production facilities, but how to handle chemicals post-use is often given less attention. While this article examines the full chemical lifecycle, it focuses on this post-use phase.


Sustainable lifecycles

Every laboratory and chemical processor must follow environmental, health and safety (EH&S) procedures and regulations. This is often a challenge, especially for smaller operations, since implementation frequently rests on individual managers, local teams and staff who have other primary responsibilities. Regardless of size, laboratory and production managers must periodically review their policies, conduct training and audit their chemical inventories and waste materials. Requirements, processes and regulations change, and it is management’s responsibility to remain in compliance, while meeting everyday production demands.

Environmental sustainability continues to increase in importance and is embraced as a corporate goal at many manufacturing organizations. This takes chemical management beyond the traditional regulatory and safety considerations. The chemical process industries (CPI) have become even greater stewards of the materials throughout their entire lifecycles as they seek ways to further reuse or recycle materials that were historically disposed of as waste (Figure 1).


 Figure 1. Managing post-use chemicals is a vital part of chemical lifecycle management. Recycling “waste” chemicals is an option that can contribute greatly to sustainability goals


Sustainability requires the minimization of consumption and waste in order to reduce environmental impact through process optimization and reuse or recycling whenever possible. This can require additional recordkeeping and administrative steps. The challenge, when it comes to chemical lifecycle management, is to find operationally efficient and cost-effective ways to reduce the overall waste stream through process optimization, efficient material use, tolling or selling recyclable materials to a secondary market.


Purchasing and storage

Effective chemical management starts before the chemicals arrive at the site. Laboratory and operations personnel need to work carefully with purchasing staff to order the correct amounts, minimize order errors and ensure that proper receiving and storage provisions are in place. For operations personnel, it is a balance between anticipating customer orders and manufacturing volume in order to eliminate production interruptions, minimize storage and other inventory costs, and to avoid having to dispose of outdated materials. Purchasing staff can consolidate orders to lower costs, but they must have an understanding of the chemical properties and intended uses in order to ensure that materials are consumed before they begin to degrade and negatively affect chemical reactions or final product properties. Overall, the CPI have done a good job utilizing continuous improvement techniques to manage their supply chains.

Once received, the materials must be stored in accordance with local, state and provincial regulations, or the International Code Council’s (ICC) International Building and International Fire Codes, and handled in accordance with company EH&S procedures. In the U.S., handling must follow the Occupational Health & Safety Admin.’s (OSHA) Code of Federal Regulations (Title 29 CFR 1910.1200), which covers Hazard Communication Standards (HCS), the federal Risk Management Program for certain highly toxic chemical compounds regulated under the Clean Air Act, and the Chemical Hygiene Standard for laboratories (Title 29 CFR 1910.1450).


Production and laboratory use

As materials move into the second phase of the lifecycle — use in a production environment or laboratory — the potential for handling errors increases. Although industrial users and researchers are concerned with, and trained in, safe handling procedures for hazardous materials, they are less likely to focus on storage and removal. This leads to some potential problems in chemical lifecycle management.

Chemicals are generally well managed in production environments since production procedures are well-defined and engineered. Failure most often results from human error or system breakdowns. Although the results can be catastrophic, they are largely preventable through adherence to established EH&S procedures, effective maintenance practices and frequent training.

Research environments are less systematized, which presents greater opportunity for errors. Researchers often work independently on projects and they use smaller quantities of a greater number of chemicals. This presents an exponentially higher number of possible chemical reactions and storage issues.

Working alone or on small teams, researchers often neglect to properly label chemicals in secondary containers at their stations. Unlabeled or improperly labeled chemicals violate hazardous communication (Hazcom) regulations. Informal practices also lead to the potential for abandoned chemicals as researchers move on to other jobs or projects. Unidentified chemicals may require testing, special handling and expensive disposal if they cannot be verified by the researcher.

Consistency and training, supported by accurate, up-to-date labeling and recordkeeping, are key ingredients to a successful chemical management program.



Handling of solvents, catalysts and other chemicals can become much more problematic once they have been used in a production or laboratory process. They are no longer in their original containers and are often combined with other substances. In the U.S. for example, OSHA, the Environmental Protection Agency (EPA), Dept. of Transportation (DOT) and, in some cases, Drug Enforcement Admin. (DEA) regulations also come into play.

A few important fundamental facts must be kept in mind at all times: In the U.S., all chemical storage areas fall under Resource Conservation and Recovery Act (RCRA) regulations and are subject to inspection by regulators. To comply with that, a limited number of conveniently positioned and properly organized satellite accumulation areas (SAAs), under the control of the EH&S or chemical hygiene manager, should be set up near production or research areas.

There are a number of RCRA rules for SAAs. For instance, containers must be in good condition without rust, dents, or cracks; they cannot be stored near drains or other structures that could pose an environmental risk; hazardous waste containers cannot exceed 55 gal; acutely hazardous waste cannot exceed one quart; SAAs must be inspected weekly. There are additional guidelines including requirements for clear and visible labels stating “hazardous waste” and listing the container contents, as well as the “three-day rule” that requires that the containers are immediately marked with the current date when full, and removed within three days to the main storage area (MSA).

The MSA is governed by additional rules. One of the most important relates to allowed accumulation time once materials enter the MSA. Small quantity generators (SQGs) — organizations that generate more than 100 kg but less than 1,000 kg of hazardous waste per month — can accumulate materials for 180 days from the start date.1 

Large quantity generators (LQGs) — those that generate 1,000 kg or more of hazardous waste per month, or more than 1 kg per month of acutely hazardous waste — are subject to a 90-day accumulation rule.2 

Regardless of size, the MSAs must be secured against unauthorized entry; hazardous waste and container contents labeling rules must be followed; containers must be inspected weekly with reports kept on file; and preparedness and prevention equipment (for example an emergency phone, alarm, fire suppression and spill prevention equipment) is required.

There are additional regulations and exceptions to the rules noted above. For instance, peroxide formers, such as ethers and dioxane, are generally managed under a peroxide-former program that tracks the material based on the manufacture and retention dates from the day it arrives onsite until the day it is consumed or disposed of. SAA storage times and 90/180-day MSA rules are all subordinate to the peroxide-former deadlines. So, if the earliest peroxide-former retention date is 45 days in the future, that is the container’s deadline. Even the waste disposal company must track peroxide formers and follow expedited destruction schedules based on the retention date.

    Managing chemical storage areas.  A minimum number of properly trained staff should be assigned to transport materials from the SAAs to the MSA and manage the materials in all of the storage areas. Some operations are large enough to have a dedicated full-time staff, while for others it is a part-time function (that requires the same annual refresher training). Properly organizing the handling and in-house movement of chemicals removes the responsibility from researchers and substantially reduces training requirements.

Another benefit of using dedicated staff is that it puts a third party in position to regularly inspect warehouse, production and laboratory areas to ensure that chemicals are properly stored and handled in accordance with regulatory and company policies. Here are some best practices that we have seen in the field and that we practice at our own sites and for customers:

• Ensure that proper procedures (such as labeling and tracking) are being followed at each production and laboratory location, and that waste chemicals are stored only at approved sites

• Conduct periodic safety training for research and production personnel

• Establish collection schedules to efficiently move materials from SAAs to the MSA in a timely way

• Ensure that SAA containers are in good condition, properly closed and placed within secondary containers, and that incompatible materials are properly segregated

• Catalog, store and consolidate MSA materials in bulk containers and pack smaller quantities, elbow bottles, and so on, for transportation

• Identify unknowns before shipping

• Follow up on the disposal or recovery of chemicals for company and regulatory reporting

    Software.  Most large companies utilize chemical inventory management systems, while many laboratories still use spreadsheets to manage their inventories. Spreadsheets can be helpful, but they are not the answer for corporate-wide or comprehensive lifecycle-management programs. They are generally home-grown standalone applications without built-in reporting mechanisms. They do not extend beyond the department or integrate with corporate systems. They do not tie into industry resources and documentation, such as material safety data sheet (MSDS) databases, that are necessary to build chemical profiles. Perhaps, most importantly, they may not stand up to regulatory scrutiny if the need arises.

Specialized software and online chemical-waste-management systems handle all of these issues and also address many other important criteria, such as chemical movements, 90/180-day storage-time limits, chemical expiration dates and reporting. More sophisticated software and online tracking systems assign cost center allocations, and facilitate movement, inventorying and packing, as well as documenting the transfer of the material to a certified waste disposal company.


Waste disposal companies

Given the complexity of effective waste-chemical management, many companies find that it is more efficient and cost effective to turn to waste disposal companies to handle their chemical waste throughout the entire post-use lifecycle phase. Service companies manage the entire process including onsite movements, storage, packing and removal. In that way, generators do not have to invest as heavily in RCRA training and can rely on the contractor to apply its expertise, provide staff and backup staff as necessary, monitor regulatory federal, state and local developments, and implement best practices.

This allows plant and laboratory management to properly oversee the function without adding headcount. It also enables staff to focus on their core responsibilities and not be burdened with additional training or oversight of chemical management functions.Using the same outsourcer to handle materials in-house as well as for removal and disposal eliminates interorganizational hand-offs and can further reduce costs.

    Communications between waste generators and chemical disposal companies.  Before a waste disposal company can remove hazardous chemicals from a generator, all paperwork must be in order, the materials must be properly labeled and packaged and ready to go. It is important that chemical waste is properly characterized in order to avoid unnecessary expense or, in a worst case, additional transshipping to another waste disposal site. Confusion creates lost time and increased costs for chemical characterization tests and EPA and DOT documentation.

Communications with the waste disposal company are key. Direct links between the generator and the waste disposal company are efficient since any materials or paperwork that are not in compliance will be identified early, waste profiles and DOT manifests can be generated, and placards assigned before the disposal company arrives on site.

A direct link to the waste disposal company can also report containers that are ready for packing and/or pickup, enabling the removal company to cost-effectively schedule pickups. Automated procedures also help companies stay in compliance with RCRA 90/180-day rules or special handling requirements for peroxide formers and other acute hazards.

Regardless of the degree of automation and communications, understanding the chemical waste disposal process minimizes costs up front by smoothing the transition from the MSA to disposal and reuse. Communication with the waste disposal company has become even more critical over the last few years due to increased opportunities for chemical reuse, recycling and tolling.

    Reuse and recycle. Some hazardous and non-hazardous waste and byproducts with residual value can be directly reused in other processes by another manufacturer. In the past, these materials may have been landfilled or incinerated because it was less expensive and there were few disposal alternatives. Today, both environmental and financial incentives encourage materials reuse.

Beneficial reuse and recycling provide additional revenue streams, or at least the potential for cost reductions, for the generator; however, they add complexity to the removal-and-disposal process. Rather than a one-way transaction where the disposal company removes and disposes of the material, reuse and recycling may now include waste removal discounts for materials sold on the secondary market. Tolling, where reprocessed materials are returned to the generator, also results in more complex price negotiations based on fluctuating rates for virgin materials.

Recycling, where the waste disposal company reprocesses chemicals for new uses, can also substantially advance generators’ sustainability performance. The materials stay out of the waste stream and become feedstock for another company’s process, as outlined in Figure 1.

There are several other benefits that accrue from the reuse and recycling of chemical materials. In some cases reuse and recycling operations reclassify wastes, removing them from the generator’s hazardous waste manifest, which reduces the volume of materials listed in Toxics Release Inventory (TRI) reports and advances waste minimization goals. They contribute to reduced taxes and annual fees associated with RCRA regulations (see box titled TRI Chemicals) and other corporate responsibility and environmental reports.

Clearly, sustainable disposal, reuse and recycling require a more sophisticated service level from the waste disposal company. Only a few are able to analyze the waste with an eye toward potential uses and the secondary market. They also have knowledge of the underlying regulations and access to the separation and purification resources necessary to reprocess the materials (see box titled Solvent Recycle and Reuse). Companies that offer these services along with in-house processing, tolling and resale capabilities, are best suited to develop comprehensive waste management programs that fully leverage sustainable secondary uses for waste chemicals.

It makes financial and environmental sense to explore these opportunities with a waste processor.

  Edited by Dorothy Lozowski 





Victor Belenchia is vice president, chemical industry for Clean Harbors (42 Longwater Dr., Norwell, MA 02061–9149; Email: [email protected]; Phone: 781–792–5471; Website: He holds a B.S. in biology and chemistry from the University of Central Connecticut and an MBA in marketing from the University of Connecticut. He spent more than 20 years in the chemical industry with American Cyanamid and Cytec Industries in various technical and commercial positions and has been with Clean Harbors for the last six years in his current role.