Dear Hannah:
I feel your pain but let me elaborate on this a little. I have been writing Safety Data Sheets for almost 31 years now and while some areas are very straight forward, other areas are certainly not. And this definitely includes disposal! The problem is that regulations literally vary from state to state, from county to county and from city to city, within the same state and county. While there are federal guidelines such as Hazwoper (Hazardous Waste Operations and Emergency Response is a set of guidelines produced and maintained by the Occupational Safety and Health Administration which regulates hazardous waste operations and emergency services in the United States and its territories.), just like the fire code, local authorities can pass additional guidelines or regulations that go often way beyond the federal standard. This may even go down to the level of your local disposal company and their capabilities based on the landfill or disposal company they use.
In short, it is literally impossible for a chemical manufacturer to cover all guidelines and regulations in a single piece of paper, here the SDS. So, we put language in there that covers all the bases and places the responsibility on the customer. We will work with you where feasible, but it would take several full-time employees to stay on top of all these regulations.
For example, I once had an issue where the local inspector required a brewery to install a safety shower because our safety data sheet clearly stated that you should use a safety shower for first response. Since our SDS stated this, the brewery was told to either change chemicals or install a safety shower. You are seeing where this is going.
The best advice I can give anybody is to contact a local disposal company and ask for assistance. There are several national companies which can dispose of pretty much any hazardous and non-hazardous material for a nominal charge. Contact me directly for more information or assistance.
Cheers,
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Dirk Loeffler
Loeffler Hygiene & Safety Solutions
(404) 229-7583
loeffler.dirk@loefflerhygiene.com------------------------------
Original Message:
Sent: 04-19-2023 11:14
From: Hannah Johnson
Subject: Disposal of Amylo 300 Enzyme
I wanted to add onto this thread, as I feel a lot of lab specific chemicals used in brewing labs have very vague SDS as far as disposal goes. Some will even state in the Material Data sheet non-hazardous, then the disposal section will say proper, local and regional laws (seems contradictory). Does anyone have any good resources on disposing of media/various chemicals responsibly?
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Hannah Johnson
QC Specialist
Allagash Brewing Co
Portland ME
Original Message:
Sent: 04-18-2023 14:04
From: Joshua Maxson
Subject: Disposal of Amylo 300 Enzyme
Wondering if any of you have advice on proper disposal of Amylo 300 Enzyme? The Material Data Sheet isn't super helpful, encouraging me to dispose of it by all proper regional, local and national laws. Which I would love to do. It only seems to be a hazardous material due to the ability to cause allergen reactions, but it does contain glycerol, which I know I shouldn't pour down the drain.
Not sure if I can just add this to my regular outgoing garbage or if I need to do something special with it. Can anyone help me out?
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Joshua Maxson
Confluence Brewing Company
Des Moines IA
(319) 400-9678
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