MSDS/SDS for Scheduled Waste ?
Ever heard any MSDS or SDS exist for scheduled waste?
It's funny when people in this industries sometimes asked for MSDS (material safety data sheet) or SDS (Safety Data Sheet) for certain scheduled waste. Do they exist?
The answer is no. I've been doing this work for so many years, I've never came across with MSDS/SDS for scheduled waste. What we always received is the MSDS/SDS for new chemicals or oil. It is acceptable to use the "original' MSDS/SDS for contaminated empty containers such as bags, ibc or drums, if that containers still have a little residues from the original chemicals or for expired items such as chemicals or oil. But it is awkward if you use it for any waste that has been going through some process before becoming waste.
For example, Used Engine Oil always accompanied by msds from the "fresh" Engine Oil like it never been used before. There is a reason why it was called "used" engine oil. The oil, overtime will picks up a number of impurities and additional components from engine wear. These components include metal particles (iron, steel, copper, lead, zinc, etc.) and other compounds of barium, sulphur, water, dirt, burnt carbon, and ash, most of them are highly toxic in nature. Oxidation and polymerization in the oil cause the increase in the viscosity of used engine oil and fuel contamination will caused decrease the viscosity. So does with the flashpoint of used engine oil, it will decrease if it is diluted by unburned fuel contamination and increase when evaporation of light component happen.
Below is the comparative chart from experiment done on the effect of viscosity and flashpoint of engine oil follows by different methods of refining :
It is obvious that the fresh engine oil msds is not valid for used engine oil.
As for this year, DOE Malaysia has introduce WC (Waste Characteristic) for waste generator and WAC (Waste Acceptance Criteria) for recovery,recycle and disposal centre.
Waste Characteristic (WC)
Waste Acceptance Criteria (WAC)
This means, waste generator have to send sample of their scheduled waste to an accredited laboratory for testing. The parameters for testing will be determined by DOE. This doesn't mean that the sample has to be sent to laboratory every time. If the sample is from the same process and the process has not change, WC can be reused (require testing once only). This way, waste receiver, disposal centre, recycle and recovery centre will now knows the contains and characteristic of the scheduled waste they are receiving similar to MSDS.