I spoke with our Safety Officer about this.  She said yes, the organization must be licensed to treat the waste (via EPA).  However, if you make the neutralization part of the process you don't.  For example, after you trim in the tissue you pour the waste formalin in a carboy that has a neutralizing agent in it, you don't need to be licensed.  But if you store your formalin in a carboy and then when you get a certain quantity you pour it in the carboy with the neutralizing agent, you need to be licensed.  I don't really understand the difference but it looks like a loop-hole to me.

Jane

M. Jane Chambers, MS LAT
USDA/ARS PPRL
1150 East 1400 North
Logan, UT  84341
435-752-2941 (v)
435-753-5681 (f)
jane@cc.usu.edu


-----Original Message-----
From:	J. A. Kiernan [SMTP:jkiernan@julian.uwo.ca]
Sent:	Wednesday, March 10, 1999 11:15 AM
To:	Histonet
Subject:	Re: Licensed neutralizing (DISPOSING OF DAB WASTE)

At 09:42 AM 3/10/99 -0700, you wrote:
>... Also, my safety director will not let us neutralize anything,
>including formalin.  He states that our facility is not licensed to
>neutralize.  All our waste is shipped out.....this can be quite
expensive.  

  Can this be true? Who issues the Licence to Neutralize,
  and does it entitle the holder to a number like 007?
  One is tempted to suspect that this dafety director also
  owns the local waste disposal company ....

                                         John Kiernan
                                         London, Canada.