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Trend Scientific, Inc.-VYTAC 10F for Treating 10 Percent Formalin

Final Decision to Certify Hazardous Waste Environmental Technology

Published Weekly by the Office of Administrative Law
Register 94, No. 48-Z
December 2, 1994
pp 1882-1885

The California Environmental Protection Agency, Department of Toxic Substances Control (Department) has made a final decision to certify the following company’s hazardous waste environmental technology listed below:

Trend Scientific, Inc.
P.O. Box 120266
St. Paul, MN 55122

for Treating 10 Percent Formalin
Generated by Medical, Dental,
and Other Health Care Facilities

Chapter 412, Section 25200.1.5., Health and Safety Code, enacted by Assembly Bill 2060 (AB 2060), Weggeland, 1993, authorizes the Department to certify hazardous waste environmental technologies.

The purpose of the certification program is to provide an in-depth, independent review of technologies at the manufacturers’ level to facilitate regulatory and end-user acceptance and to promote and foster growth of California’s environmental technology industry.

The Department makes no express or implied warranties as to the performance of the manufacturer’s product or equipment. The end-user is solely responsible for complying with the applicable federal, state, and local regulatory requirements. Certification does not limit the Department’s authority to require additional measures for protection of public health and the environment.

By accepting certification, the manufacturer assumes, for the duration of certification, responsibility for maintaining the quality of the manufactured equipment and materials at a level equal to or better than was provided to obtain certification and agrees to be subject to quality monitoring by the Department as required by the statute under which certification is granted.

The Department’s proposed decision to certify has been previously noticed on October 14, 1994 in the California Regulatory Notice Register 94, Volume No. 41-Z. Written comments in relation to the proposed certification received during the public review and comment period have been duly considered in the final certification as presented here. The Department’s final certification shall be effective on Monday, January 2, 1995.

Additional information supporting the Department’s final certification decisions is available for review at:

California Environmental Protection Agency
Department of Toxic Substances Control
Office of Pollution Prevention and Technology Development
P.O. Box 806
301 Capitol Mall, 1st Floor
Sacramento, California 95812-0806
(916) 322-3670

A description of the technology to be certified, the final certification statement and the certification limitations for the technology follows:

Trend Scientific, Inc.
for Treating 10 Percent Formalin

Technology Description

The VYTAC 10F technology chemically treats formaldehyde wastewaters in a batch processing system, which is a closed vessel, manual treatment unit. The spent aldehyde solutions are transferred to the collection vessel with VYTAC 10F and are treated and rendered non-hazardous. After being tested with an aldehyde test kit, the solution with inert polymer residues may then be disposed of as a non-hazardous waste by discharge to the sanitary sewer.

The evaluated reagent for aldehyde waste treatment was VYTAC 10F. The apparatus utilized with VYTAC 10F is contained in S/P Brand VYTAC Daily Disposal System Starter Kit which includes:

  • one 3.5 L Neutralizer
  • one 8 L Reservoir with cover
  • one measuring cup
  • one stirring rod
  • master of “Waste Treatment Log”
  • instruction sheet

The VYTAC NF Test Kit is available for the semi-quantitative determination of formalin concentration in treated waste formaldehyde aqueous solutions. TREND offers Standards of 500, 300, 200, and 100 ppm that may be utilized in the test.

Certification Statement

VYTAC 10F is hereby certified, pursuant to California Health and Safety Code Section 25200.1.5, by the California Department of Toxic Substances Control (Department) as a Hazardous Waste Treatment Technology when operated, monitored, and maintained according to manufacturer’s standards and specifications. The certified technology has been determined to treat incremental amounts of 10% Formalin (aqueous solution containing approximately 3.75% formaldehyde by weight). The use of the VYTAC 10F process as directed has the potential to significantly reduce the exposure to aldehyde vapors, as well as the need for expensive waste hauling, and allows safe disposal of these treated wastes. Based on the certification process, the Department concludes that the VYTAC 10F process appears effective in reducing the concentration of formaldehyde in 10% formalin to 0.25 ppm. Some Publicly-Owned Treatment Works may require a pH adjustment prior to disposal down the drain. If required, the pH may be adjusted by adding an acid neutralizer like VYTAC ACX or one of the following: sodium hydroxide solution or sodium carbonate crystals.

Certification Disclaimer

The Department believes that the manufacturer’s product and/or equipment, when used in accordance with the manufacturer’s specifications, can achieve the performance level set out in this Certification. Said belief is based on a review of the data submitted by the proponent, results of onsite verification tests, and results of the verification tests performed in the Department’s laboratory. The Department makes no express or implied warranties as to the performance of the manufacturer’s product and/or equipment. Nor does the Department warrant that the manufacturer’s product or equipment is free from any defects in workmanship or material caused by negligence, misuse, accident or other causes. This does not constitute an endorsement of the specific product, nor does it intend to expand existing rights or obligations, waive legal defenses, or otherwise affect the legal position of the applicant companies.

Basis for Certification

The Department reviewed data submitted by the proponent, which included copies of letters from hospitals, satisfied customers, state and local agencies, and test results from certified laboratories. The proponent first conducted demonstration tests in the presence of the Department’s representatives at a State Laboratory and then, further independent confirmation/verification tests were performed by the Department’s Hazardous Materials Laboratory. Based on the evaluation of provided data and the results of these tests, the Department concluded that the VYTAC 10F process reduces the quantities and hazards of 10% Formalin to a fraction of the original amount, suitable for disposal to sanitary sewer.

Regulatory Considerations

The Department intends to pursue regulatory certification for this technology after the adoption of regulations for such action. In the interim, the Department is addressing treatment of specific aldehyde wastes through Compliance Directive (EO-94-005-MM), “Treatment of Formaldehyde and Glutaraldehyde Sterilizing Solutions at Health Care Facilities.”

Users of any 10% Formalin treatment system may still be subject to all local discharge limits, including pH adjustment.

Staff of the State Water Resources Control Board, Pretreatment Program, have participated in the Certification evaluation, support its findings, and have determined that the use of this formaldehyde treatment technology presents no burden to normal sewerage and wastewater treatment facilities.

Protection of Human Health and the Environment

Formalin poses acute threats to the respiratory and digestive systems and is a probable human carcinogen. The use of VYTAC 10F, as an integral part of safe management practices, can provide valuable risk control and environmental protection.

Existing practices in dealing with 10% Formalin waste include:

  1. Uncontrolled or illegal disposal;
  2. Hazardous waste hauling, followed by off-site treatment and disposal;
  3. Burning the waste as a fuel supplement;
  4. Other treatment technologies.

These practices may not reduce occupational exposures, nor provide equivalent protection to human health and the environment. Additional; some practices may subject responsible parties to State or local agency enforcement actions.

Conclusions and Future Actions

  1. Duration of Certification – This Certification will remain in effect for the period of three years from its publication in the California Regulatory Notice Register, unless it is revoked for cause.
  2. Continuous Quality Control/Quality Assurance – By accepting this Certification, the applicant companies accept, for the duration of this Certification, responsibility for maintaining the quality of the manufactured equipment and material at a level equal or better than was provided to obtain the Certification.
  3. Monitoring and Self-reporting Actions – The applicant companies have instituted appropriate internal quality control management systems and procedures, including a generator’s waste treatment log. This log is considered by the Department suitable record for monitoring of the treatment and the generator’s record of performance. The Department may review and evaluate this record of performance and compare it to the standards and specifications provided to obtain this Certification.
  4. Procedure for Modifications and Amendments – Modifications and amendments of this Certification may be requested by the applicant companies, and will be processed according to the provisions of the statute under which this Certification is granted.
  5. Status as “Pilot Certification” – This Certification is issued as part of the pilot project for the California Environmental Technology Certification Program. The pilot project’s purpose is to delineate the practical aspects of the program that will be adopted in regulations which are under development. Consequently, this Certification may be subject to additional conditions which will be required in these regulations, including, but not limited to, the duration of the certification, continuing monitoring and oversight requirements, and certification amendments procedures, including decertification.

For more information, contact us at:

Department of Toxic Substances Control
Office of Pollution Prevention and Technology Development
P.O. Box 806
Sacramento, California 95812-0806
Phone: (916) 322-3670
Fax: (916) 327-4494