[PDF] [PDF] Used and Unused Formalin Management - Army Public Health Center

Formalin is a mixture of 37-40 percent formaldehyde, water, and usually 10 and therefore, does not meet the criteria stated in the RCRA regulations at 40 



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Used and Unused Formalin Management

1. BACKGROUND

. Formalin is a mixture of 37-40 percent formaldehyde, water, and usually 10 percent

methanol. Ten percent formalin (i.e., a 4 percent formaldehyde solution) is often used as a working solution for

tissue fixation, or as a preservative holding solution for fixed tissues or organ specimens in pathological

laboratories. A distinction must be made between used and unused formalin when disposal action is planned. The distinction is defined in the Resource Conservation and Recovery Act (RCRA).

2. USED FORMALIN DISPOSAL. Used 10 percent formalin (i.e., the working solution) may be poured down

the sink drain and then flushed through the trap with copious amounts of water. Disposal to the sanitary sewer

is acceptable from a regulatory perspective because the so lution has been used for its intended purpose and therefore is no longer considered a commercial chemical product. It is a spent solution which does not

possess the same constituents as the original unused solution; it is changed in nature from having been used

and therefore, does not meet the criteria stated in the RCRA regulations at 40 Code of Federal Regulations

(CFR), Part 261, Section 261.33f, Protection of Environment, Identification and Listing of Hazardous Waste.

This means that the used formalin working solution is not a hazardous waste because it is not listed and it is

not a characteristic hazardous waste. It does not have the RCRA characteristic of ignitability, corrosivity,

reactivity, or toxicity (40 CFR 261.21 - 261.24). Sewer disposal is allowed provided that approval has been obtained from either the environmental authority at

the installation or from officials at the receiving waste water treatment plant (WW

TP). Ascertain that any State

hazardous waste regulations are not violated and that the permit restrictions regarding the biochemical oxygen

demand (BOD) has not or will not be exceeded. If sewer disposal is agreed to, the preferred method is to limit

the disposal to about 1 quart per hour so as not to injure the biological treatment at the WWTP or to exceed the

BOD limits. The operators of the WWTP may impose other limits.

3. UNUSED FORMALIN DISPOSAL. Unused formalin and unused ten percent formalin solutions are both considered commercial products. Both contain formaldehyde as the sole active ingredient. The regulations

that implement RCRA identify formaldehyde as a toxic waste with the EPA hazardous waste number of U122.

This classification applies only to

unused commercial products, off-specification commercial products, and spill

residues from unused commercial products (40 CFR 261.33f). Whether in an unopened container, a partially

full container, or if it is otherwise off specification or determined not for use, this product must be managed as a

hazardous waste when a disposal decision has been made.

Army Public Health Center (Provisional)

Waste Management Program

DSN 584-3651; COMM 410-436-3651; or email usarmy.apg.medcom-phc.mbx.hmwp@mail.mil

5158 Blackhawk Road, Aberdeen Proving Ground, Maryland 21010

-5403 Approved for public release; distribution unlimited.

FACT SHEET 37-067-0915

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