Liz, If they are not removing the solvent (albeit 1-2 mL), you have to manage the broken glass as hazardous waste with the RCRA code D001 and any other D or F listed solvents.
They are not RCRA empty and picking through the broken glass is not an option.
You are correct, un-cap and empty by gravity, at that point the container is RCRA empty but still contains a residue that can be considered characteristic flammable waste. If you are a SQG or lower you might leave them in the hood for a short while and then handle them as non-hazardous glass waste. They need to have a 1L waste bottle and empty the unwanted vial contents into the waste bottle each time a vial is declared a waste.
I have seen other labs not declare the sample vials as a waste, rather, keep the vials as archive samples. Use the box the empty vials are purchased and keep them labeled with the solvent system using small labels (i.e. HEX and THF - ACE/MeOH). Since they are archive samples (remember they are not discarded and therefore not waste), you can use abbreviations. Also, label the outside box well (a general description of the samples, solvents, the name of the research, dates, etc.)- It must be managed and not appear inherently waste like.
Then at some point (new grad student, change in protocol, retirement, etc) the sample boxes can be discarded as hazardous waste using the proper codes and you have 2 options - 1. Lab pack the boxes listing all solvents
2. You can pour off samples in a fume hood and send out a bulk container - assuming that you are someone you're in contact knows the arrangement you have with your end facility, you'll know what container and if you need to separate and different solvents.
At the very least, if they will not empty the vials, they need to accumulate them separately as hazardous waste, listing all the possible solvents the vials might contain. Good Luck, James
From: ACS Division of Chemical Health and Safety [mailto:DCHAS-L**At_Symbol_Here**PRINCETON.EDU]
On Behalf Of Elizabeth Curley
Sent: Wednesday, September 12, 2018 10:00 AM
Subject: [DCHAS-L] GC/MS vial disposal?
I have been CHO for about a year, so still pretty new.
One of the questions that has come up is What is the best practice for disposing of GC/MS vials after they have been used. I was thinking you would uncap them add the excess sample to a hazardous waste bottle. But the faculty members tell me they don't have to remove that leftover 1-2ml of sample and solvent and they just put the vials into broken glass even if they are still half full with solvent.
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