ENVIRONMENTAL HEALTH AND SAFETY
CHEMICAL WASTE MANAGEMENT GUIDE
TABLE OF CONTENTS
II. IDENTIFYING A HAZARDOUS WASTE
A. Characteristic Hazardous Wastes
B. Listed Hazardous Wastes
III. LABELING REQUIREMENTS
IV. ACCUMULATION REQUIREMENTS
V. WASTE SEGREGATION
VI. CONTAINER COMPATIBILITY
VII. SPECIAL WASTES
VIII. SPILL CLEAN-UP PROCEDURES
IX. . WASTE MINIMIZATION
Appendix A – Toxicity Characteristics
Appendix B – Listed Hazardous Wastes
Appendix C -- Waste Satellite Accumulation Area Requirements
CHEMICAL WASTE MANAGEMENT GUIDE
The Federal Resource Conservation and Recovery Act (RCRA) established the framework for hazardous waste regulation in 1976. RCRA was enacted by Congress to protect human health and the environment from improper management of hazardous waste. RCRA introduced the concept that the generator of a waste is responsible for proper waste management from “cradle-to-grave” (i.e. from laboratory to complete destruction). RCRA regulations are found in 40 CFR Parts 260-279.
There are specific regulatory requirements for individuals who generate and accumulate chemical waste: minimize and recycle, properly label and identify, and properly contain and dispose of chemical waste. The purpose of this document is to assist labs and shops with this regulatory compliance. Every lab and shop on campus is subject to unannounced inspections by both the Federal Environmental Protection Agency (EPA) and the Pennsylvania Department of Environmental Protection (DEP). Lack of compliance can result in citations and fines.
The regulatory requirements covered in this document include:
hazardous waste determination
proper labeling of a hazardous waste
requirements for accumulation of hazardous waste
Increased public concern over environmental issues led to a major expansion of the federal and state environmental laws in past years. Aggressive enforcement of these laws by regulatory agencies has also increased. The regulations were developed to control industrial waste streams and are strictly enforced by the regulatory agencies. Although academic institutions generate less than one percent of the national waste stream and are not industrial in nature, no exemptions exist for academic institutions or their employees.
The numerous environmental laws enacted have been documented in thousands of pages of regulations, creating an extremely complex scheme. Despite this complexity, liability for noncompliance with environmental regulations is not limited to major,
intentional offenses that cause significant harm to public health or the environment. In fact, sizable penalties have been imposed for relatively minor, inadvertent violations.
Regulatory agencies and the courts assume that persons working with chemicals today are knowledgeable of the potential hazards involved with their work. Therefore, civil and criminal penalties can be imposed on institutions for non-compliance.
Further, this liability can extend beyond the institution to individuals, based on the reasoning that all responsible personnel, from a lab instructor to a college president, share in the responsibility of ensuring compliance with the environmental laws.
The Environmental Protection Agency (EPA) regulates controlled waste through six major regulatory programs: RCRA, CERCLA, TSCA, FIFRA, CWA, AND CAA. The Department of Transportation (DOT) regulates the transportation of Hazardous Materials and hazardous Substances. The Occupational Safety and Health Administration (OSHA) develops and enforces safety standards for response to hazardous chemical emergencies, employee awareness and right-to-know chemical information, as well as laboratory safety standards.
Resources Conservation and Recovery Act. Defined and regulated solid and hazardous waste. (Regulations directly impact the hazardous waste generator.)
Hazardous and Solid Waste Amendments. Made RCRA more stringent. (Regulations directly impact the hazardous waste generator.)
Comprehensive Environmental Response, Compensation and Liability Act (Superfund). Provides mechanism to assign liability to corporations and individuals. (May impact the hazardous waste generator.)
Superfund Amendments and Reauthorization Act. Created Community Right-To-Know for hazardous and toxic chemical reporting.
Toxic Substances Control Act. Regulated chemical usage, including PCB usage, storage, and disposal.
Federal Insecticide, Fungicide, and Rodenticide Act. Controls the manufacture and use of pesticides intended to kill, repel, or control living organisms.
Clean Air Act. Regulates discharges to air. (Regulations directly impact the hazardous waste generator.)
Clean Air Act Amendments.
Clean Water Act, Regulates discharges to water. (Regulations directly impact the hazardous waste generator.)
Hazardous Materials Transportation Act. Regulates packaging and transportation of hazardous materials.
Hazardous Waste Operations and Emergency Response. Sets standards for employee safety.
Hazard Communication (Right-To-Know). Employers must inform employees of chemical hazards. (Regulations directly impact the hazardous waste generator.)
Laboratory Safety Standard (Occupational Exposure to Hazardous Chemicals in Laboratories). Laboratories must develop Chemical Hygiene Plans, etc. (Regulations directly impact the hazardous waste generator.)
Parts of Title 40 of the CFR Regarding Permitting and Hazardous Waste Handling and Disposal
260 Hazardous Waste Management System: General 40CFR260
261 Identification and Listing of Hazardous Waste 40CFR261
262 Standards Applicable to Generation of Hazardous Waste 40CFR262
263 Standards Applicable to Transporters of Hazardous Waste 40CFR263
264 Standards for treatment, Storage and Disposal Facilities 40CFR264
265 Interim Standards for Owners and Operators of TSD Fac. 40CFR265
266 Reserved 40CFR266
267 Interim Stds. For Owners and Operators of New TSD Fac. 40CFR267
270 EPA Hazardous Waste Permit Program 40CFR270
271 Requirements for Authorization of state Hazardous Waste 40CFR271
II. IDENTIFYING A HAZARDOUS WASTE
Waste: A material/chemical that has no intended use or reuse, including chemicals and
materials from a spill clean up. The requirements described in this guide do not apply until a material becomes a waste. All wastes generated at the University must be characterized to determine whether they are a hazardous waste. A waste is determined to be hazardous by two means: characteristic or listed.
A. Characteristic Hazardous Wastes
A waste is hazardous if it exhibits any one of the four characteristics of a hazardous waste. The following are the four characteristics and a few examples of common wastes at the University:
Any liquid waste having a flashpoint of less than 140 degrees F. is considered an ignitable hazardous waste. A flashpoint can generally be determined by reference to the container label, a material safety data sheet, a chemical reference guide, or testing. The following are examples of ignitable wastes: ethyl ether, methanol, ethanol, acetone, toluene, benzene, pentane, hexane, and xylem. Solids are also regulated as ignitable waste if the material is capable of ignition through friction, moisture absorption, or spontaneous chemical changes and burns so vigorously and persistently as to create a hazard. Many commercial products may also exhibit the characteristic of ignitability. Oxidizers are also considered ignitable hazardous wastes.
2. Corrosive Any waste with a pH less than 2.0 or greater than 12.5 or which corrodes steel at a rate greater than 6 mm per year is regulated as a corrosive waste. Wastes in this category include many acids and bases. The following are examples of corrosive wastes: sulfuric acid, ammonium hydroxide, nitric acid, sodium hydroxide, and hydrofluoric acid.
3. Reactive Any waste that is shock-sensitive, violently unstable, reacts violently with air or water, or generates cyanide or sulfide gases is regulated as a reactive waste. Some common chemicals which are classified reactive are: picric acid and other polynitroaromatics, old ethers and other peroxide forming organics, organic peroxides, ammonium perchlorate and metal perchlorate, and metal amides and azides.
4. Toxic – Any waste, which equals or exceeds a designated concentration of certain toxic compounds, is regulated as a characteristically toxic hazardous waste. The test to determine these concentrations is known as the TCLP (Toxicity Characteristic Leaching Procedure). It determines the amount of the toxic compound that leaches from the waste, simulating what could leach into the environment from an improperly disposed waste. The extraction procedure is a standardized laboratory test that requires specialized equipment. Therefore wastes with any of the TCLP compounds are assumed to be toxic. These compounds include the heavy metals such as lead, chromium, and barium as well as many organic materials and a group of pesticides. Some commercial products may exhibit the characteristic of toxicity through the TCLP testing procedure.
A selected group of eight (8) heavy metals, ten (10) pesticides, and twenty-two
(22) organic chemicals are classified as hazardous due to their toxicity characteristic.
Any detectable amount of these chemicals must be identified on a hazardous waste
Many chemicals are not considered hazardous waste using the "Listed Waste" or "Characteristic Waste" criteria described above. However, these chemicals may be at least moderately toxic, moderately corrosive or combustible and should be collected by the Environmental Health and Safety to ensure safe handling and disposal. No chemical or chemical mixture should be poured down the drain or thrown in the trash unless the user is sure that the material is inert or innocuous and has first obtained approval for the disposal from the Environmental Health and Safety.
Materials with strong odor must not be disposed of via the sewer but should be maintained in sealed containers and collected by the Environmental Health and Safety. Only solids that are inert or innocuous may be disposed of in the trash. Any containers placed in the trash must have all labels completely defaced. If the containers are damaged and are likely to break during trash collection, they should be boxed to protect custodians and labeled as trash. The determination on whether a material is inert or innocuous should be verified by consulting the material safety data sheet, container label or a reference guide. The Environmental Health and Safety will dispose of other non-regulated materials via the sewer or trash after careful review. This will allow the University to ensure compliance with the stringent sewer regulations, as well as the landfill.
C. Listed Hazardous Wastes
The EPA has published four lists identifying hazardous wastes. Appendix B is a composite of approximately 850 chemicals that are recognized by the EPA and EH&S to be hazardous.
Acute hazardous wastes, also called P-listed wastes, comprise a portion of appendix B. A
container that once held a P-listed waste must be triple rinsed before the container can be
discarded. The rinsate cannot be put down the sink.
III. LABELING REQUIREMENTS
All hazardous waste containers must be labeled correctly. One of the most important aspects of the hazardous waste management process is proper labeling of waste containers. Containers with missing or illegible labels are classified as "unknowns." Unknown chemicals requiring disposal place an unnecessary and costly burden on the University. Testing of the chemical must be performed in order to determine the appropriate hazard category of the unknown waste. Therefore, all containers holding hazardous waste must be properly labeled.
Any container with a label that is not secure or is becoming illegible must be relabeled.
Waste chemicals that are in their original containers require only the words “hazardous waste” above the chemical name. All containers used for commingling of waste must be labeled with the words "hazardous waste" and an identification of the contents. A preprinted tag or other label acceptable to the Hazardous Waste Coordinator is recommended. All labels must include an identification of the chemicals/products placed into the container. An estimate of the quantity of the each individual chemical is also recommended, particularly when mixtures of various chemicals are added. This process should occur at the time the chemicals/products are placed into the waste container. Additional tags/labels may be needed if numerous compatible wastes are placed into one container.
WASTE LABELING OPTIONS
OPTION A: Original Container
1. If a chemical is to be discarded in the original container, print “HAZARDOUS WASTE” on the label in large easily recognized letters.
2. Attach a completed EHS Chemical Waste Tag. Tags are available from EHS.
OPTION B: Container other than original container
1. If a chemical is placed in something other than the original container, mark “XXX” through the label.
2. Attach a completed EHS Chemical Waste Tag.
OPTION C: Chemically contaminated solid waste
1. Obtain a 6-quart plastic pail.
2. Line the pail with a clear plastic bag.
3. When bag is full, close bag with tape. Complete and attach an EHS Chemical Waste Tag.
NOTE: NEVER USE BLACK PLASTIC OR BIO-HAZARD BAGS TO COLLECT CHEMICAL WASTE.
OPTION D: Solvents
1. Solvents must be collected in containers identical to the original.
2. Complete and attach an EHS Chemical Waste Tag to the container. Each time you add waste to the container, note this on the waste tag. Please use pencil as ink will smudge.
3. Fill container to no more than 3/4 full. DO NOT OVERFILL!
4. Chlorinated solvents must be collected separately whenever possible!!
5. Absolutely no mercury or other heavy metals are to be mixed with solvent waste.
6. Store waste solvents away from foot traffic, heat and potential sources of ignition.
IV. ACCUMULATION REQUIREMENTS
It is the responsibility of the Principal Investigator (PI) and his/her designee to insure that waste accumulation areas are maintained in accordance with applicable rules and regulations. Waste can be accumulated in areas classified as “satellite accumulation areas.” A Waste Satellite Accumulation Area Requirements sheet (Appendix C) must be posted close to the accumulated waste. The PI must designate a Lab Waste Manager to ensure that the waste is being handled correctly on a day-to-day basis. The PI must also ensure that everyone in the lab has read and is familiar with the Waste Satellite Accumulation Area Requirements sheet and the Chemical Waste Management Guide.
Hazardous waste at a satellite accumulation area can be accumulated as long as needed, but the quantity of all wastes can never exceed 55 gallons, or 1 quart of an acutely hazardous waste (P-Listed Waste). Empty containers that once contained a P-listed waste must be triple rinsed and the rinsate must be handled as a hazardous waste. An alternative would be to have EH&S handle the unrinsed empty containers along with other chemical wastes. P-listed wastes are identified in Appendix B with an asterisk.
All waste containers must have at least one (1) inch of headspace to allow for expansion. The exterior of the container must be free of chemical contamination. Leaking containers must be repackaged before they are transported.
All waste containers must be labeled before any waste is put in the container. Refer to section III on labeling waste containers and unused products.
Incompatible chemicals are not to be placed in the same container. The Lab Safety Manual provides a list of incompatible chemicals. When placing a chemical into the waste container, consider venting to prevent any abnormal reactions or possible expansions.
A spill kit must be accessible to all lab personnel. The spill absorbent or neutralizer must be appropriate for the spilled chemical.
V. WASTE SEGREGATION
Due to the waste management methods and contracts LHU currently uses to dispose of chemical waste, the following waste streams should be kept separate when possible.
Halogenated Organic Compounds
Non-halogenated Organic Compounds
Air Reactive Materials
Water Reactive Materials
Mercury & Mercury Compounds
VI. CONTAINER COMPATIBILITY
It is vital that chemical waste be compatible with its container. If the waste is placed in an
inappropriate container, the container might disintegrate or rupture.
The following chemical wastes must be placed in glass containers.
ethyl chloride, liquid
phenol / chloroform mixtures
brominated & fluorinated solvent
You can get more comprehensive information about chemical waste disposal from the Environmental Health and Safety Office.
Certain wastes generated at the University have special handling or labeling requirements. Examples are:
A. Unknowns - Special effort should be exercised to prevent the generation of unknown wastes, since characterization of unknown wastes significantly increases the cost for of disposal. To have unknowns picked-up, place a Hazardous Waste label on the container with the word “Unknown” in the constituents column, then add the unknown to your Chemical Pick-up Request form.
B. Gas Cylinders - generators should attempt to establish accounts with suppliers who will allow the return of unused product and empty cylinders. Matheson and PCR will take back most cylinders while other manufacturers may not. EH&S will pick up Matheson lecture bottles and Aldrich Sure Seal cylinders, provided the cylinders are in good condition. If possible, the entire contents of the cylinder should be used up. Generators must ensure that aging cylinders are picked up by EH&S before the integrity of the valve and cylinder is compromised. The department may be billed directly for cylinders that require special handling and disposal procedures such as unknown or old cylinders.
C. Peroxide Formers - must be picked up by EH&S within six (6) months after date of opening or one (1) year after date of receipt. Common peroxide formers are ethyl ether, ethylene glycol dimethyl ether (glyme), vinyl ethers, isopropyl ether, potassium metal and sodium amide.
D. Ethidium bromide – Concentrated stock solutions must be handled by EH&S as a hazardous laboratory waste. The rinsate and destained gels can be placed down the sink and into the trash. EH&S will provide a 5 gallon bucket for the gels to be handled as a hazardous laboratory waste. Researchers concerned about discarding gels or solutions with lower or questionable amounts can have them handled as a hazardous laboratory waste. If a lab chooses to decontaminate their ethidium bromide, the filter and/or resin beads must be handled by EH&S
E. Reagents – The following reagents contain mercury and should be handled as hazardous waste:
Other hazardous reagents include: Flemming’s Solution (osmium, chromic acid), Folin-Dennis Solution (mercuric cyanide), Fisher’s Reagent (phenyl hydrazine), and Erlicki’s
F. Dinitro and trinitro compounds - these compounds must be picked up by EH&S before the contents have dried. Some are potentially shock sensitive when the moisture content is less than 10%. Picric acid is a common example of this type of compound.
G. Photochemical - EH&S recommends that labs which use large quantities of photo chemicals have a silver recovery unit installed. This unit treats the fixer so that it may be discharged down the drain. If a silver recovery unit is not used, EH&S must handle the fixer. No concentrated photo chemicals of any kind can be placed in the trash or sink.
H. Spilled Materials - the spilled chemical and the absorbent must be packaged and handled as hazardous waste. The Hazardous Waste label and the Chemical Waste Pickup Request form must name the chemical(s) and the absorbent used. See section IX of this document for more details on spills.
I. Used Oil – All vacuum pump oil, synthetic oil, transmission and brake fluids, lubricating greases, etc., must have the words “used oil” on the container.
J. Batteries – Alkaline batteries can be disposed of in the trash. Car batteries should be taken to the Central Recycling Facility. Other batteries which contain hazardous metals such as mercury, lead, silver and cadmium must be handled by EH&S.
K. Light bulbs - fluorescent and high-intensity discharge (HID) bulbs must be handled by EH&S.
L. Mercury Containing Devices – Many types of equipment contain elemental mercury.
Equipment must be free of mercury devices before it is recycled or discarded.
Heating and air conditioning thermostats
Tilt switches used in silent light switches, washing machine lids, chest type freezers
Pressure gauges, displacement/plunger relays
Sump pump float switches
Mercury containing devices must be disposed/recycled by EH&S.
VIII. SPILL CLEAN-UP PROCEDURES
If there is an immediate danger to life or property, EH&S and emergency personnel should be contacted immediately. For spills where there is a health risk involved in cleaning up the spill, evacuate the lab and call EH&S at 893-4428. Spills that occur after normal working hours should be reported to Law Enforcement, representative will contact EH&S if necessary.
Each laboratory should have a spill kit. Small chemical spills must be contained and cleaned up immediately. All flames should be extinguished and spark-producing equipment turned off. Non-essential personnel should be evacuated.
After cleaning up the spill, place the chemical and absorbent in a container with a Hazardous Waste label on it. A Chemical Waste Pickup Request form should be submitted, as in other waste disposal. Ensure that the Hazardous Waste label identifies the absorbent and the chemical(s).
IX. WASTE MINIMIZATION
Waste minimization is any action that reduces
the amount and/or toxicity of chemical wastes that must be shipped off-site for
disposal as hazardous waste. The success of any waste minimization program is
dependent on the conscientious participation of every individual at
The most desirable method of waste minimization is source reduction. This is any activity that reduces or eliminates the generation of chemical hazardous waste at the source. Good materials management, substitution of less hazardous materials, and good laboratory procedures, can accomplish this. Examples include:
Implement a waste minimization policy and train all employees and students.
Re-evaluate procedures to see if a less hazardous or non-hazardous reagent could be used.
Centralize purchasing of chemicals through one person in the department or laboratory.
Date chemical containers when received so that older ones will be used first.
Keep MSDS’s for chemicals on file.
Inventory chemicals and identify their location at least once a year.
Update inventory when chemicals are purchased or used up.
Purchase chemicals in the smallest quantities needed.
Label all chemical containers to prevent the generation of unknowns.
When considering a new procedure, obtain the chemicals needed from another lab or
purchase small quantities initially.
Consider the use of micro scale experiments.
Consider the use of demonstrations or video presentations as a substitute for some student experiments that generate chemical wastes.
Consider the use pre-weighed or pre-measured reagent packets where waste generation is high.
Avoid the use of reagents containing arsenic, barium, cadmium, chromium, lead, mercury, selenium and silver.
Eliminate the use of chromic acid cleaning solutions altogether. Use non-hazardous solutions such as Alconox and Pierce RBS35.
Substitute red liquid (spirit-filled), digital, or thermocouple thermometers for mercury
thermometers when it is feasible.
Consider using detergent and hot water for cleaning parts instead of solvents.
Use latex-based paints, which are typically non-hazardous. Excess latex paints should be recycled. Excess non-latex paints must be handled by EH&S as a hazardous waste.
Utilize vendors that will recycle used antifreeze. Some vendors will recycle the antifreeze on site so the antifreeze never leaves the site.
The second most desirable approach is recycling. When a waste material is used for another purpose, treated and reused in the same process, or reclaimed for another process, it is considered recycling. Examples include
When solvent is used for cleaning purposes, use contaminated solvent for initial cleaning and fresh solvent for final cleaning.
Purchase compressed gas cylinders (including lecture bottles) only from manufacturers who will accept empty cylinders.
Return excess pesticides to the distributor.
Have a silver recovery unit installed in photography laboratories. The unit removes the silver from the fixer solution.
Do not contaminate used oil with solvents because this prevents the oil from being recycled.
Increase solvent reuse through the use of solvent distillation.
Recirculate unused or excess chemicals within the department.
Collect metallic mercury for reclamation
The least preferable technique is treatment. The most common treatment is elementary
neutralization. Examples include:
Consider the possibility of including detoxification and/or neutralization steps in lab
De-stain ethidium bromide gels so they can be disposed of in the trash
8 HEAVY METALS
HEPTACHLOR (AND ITS EPOXIDE)
22 ORGANIC CHEMICALS
METHYL ETHYL KETONE
WASTE SATELLITE ACCUMULATION
1. Do not accumulate more than 55 gallons of waste or 1 quart of a P-Listed waste. P-Listed wastes are identified in the “Chemical Waste Management Guide” in Appendix B.
2. Do not put hazardous chemical waste into sinks, drains, or the trash. Also, do not allow the chemical waste to evaporate in the fume hood.
3. Hazardous chemical waste containers must have the yellow Hazardous Waste label on them. The label must list all constituents and the percentages of each with the total equaling 100%. No abbreviations are allowed on the label. The labels are available at no charge by calling EH&S at 893-4428. Hazardous waste labels are not necessary on containers holding pure, unused product as long as the original label is legible. Simply place these containers in the waste accumulation area and include them on the pick-up request form.
4. All chemical wastes shall be accumulated in sealable containers.
5. Containers shall be kept closed during accumulation except when adding waste to a container. A funnel CANNOT be left in the container.
6. Do not overfill chemical waste containers. One inch (1”) of air space from the top is required to allow for expansion. The exterior of the container must be free of chemical contamination. Leaking containers will not be collected by EH&S.
7. Keep solids and liquids separate. Separate the following classes of chemical waste from each other: acids, bases, halogenated, non-halogenated, oxidizers, reactives.
8. Date and dispose of peroxide-formers within six months after date of opening or one year after date of receipt.
9. Designate a Lab Waste Manager. This designated person is responsible for
making sure that the waste is accumulated properly in his/her own lab.
11. Keep a spill kit within easy access for all lab personnel.
LAB WASTE MANAGER: _____________________________