Environmental Health and Safety
Orphan Chemical Program Description
BGSU's Orphan Chemcial Recycling Program - A Community Effort
In most academic laboratory settings, it is common for chemicals that are still useful to remain on shelves, under hoods, and in other areas of storage, unwanted or unneeded by those who maintain them. Eventually, a majority of these "orphans" make their way into a variety of waste streams, necessitating some form of appropriate management. In addition to staff time and disposal costs associated with this management, environmental and liability issues attend the handling and disposal of chemical waste. While these chemical "orphans" remain in storage, departments within the University may be purchasing virgin chemicals identical to the orphans in other University locations.
Because of these circumstances, the Department of Environmental Health and Safety at Bowling Green State University (BGSU) began an in-house orphan chemical recycling program in the fall of 1991. This project was implemented primarily to identify and transfer unwanted chemicals between University departments as a means of minimizing hazardous waste generation. Even though this initial project was not extensively promoted, it is estimated that 700 pounds of solid materials and 50 gallons of liquids were transferred between University departments.
In the fall of 1992, BGSU began to develop a plan that would expand the existing orphan chemical program to include non-University academic institutions. Reasoning for the participation of non-University institutions centered on several factors. First of all, involvement of non-University institutions would increase the potential for the distribution of the University's orphans. It was felt that similar departments (chemistry, biology, art, etc.) from different institutions would have the same types of chemicals available, thus providing a better opportunity for distribution. Secondly, the program would provide a financial incentive to these institutions as well as BGSU because of the added potential for orphan distribution. A dual cost savings to the participating institutions and the University could be realized by keeping usable materials out of wastes streams as well as eliminating the need to purchase new materials. The expanded recycling program would have an additional benefit of enhancing the cooperative relationships between the University and non-University institutions by making assistance with other hazardous materials/waste management issues available if requested. Institutions viewed as potential participants were high schools, Jr. high schools, technical colleges, and similar facilities, primarily within Wood County, Ohio. Since the program was designed to be of service to the participating institutions, a decision was made that no fee would be charged for taking part in the program. Also, an institution would not have to submit an orphan chemical inventory (explained later) to participate.
To assure that the program would not conflict with current regulations, a draft of the program proposal was developed and submitted to the Ohio EPA and the Public Utilities Commission of Ohio for review. Representatives from both agencies accepted the concept and the procedures outlined in the proposal. Department of Transportation officials were also informed of our intentions to confirm that our planned method of chemical transfer was consistent with their requirements. Once the regulatory concerns had been addressed, the plan was presented to the University administration where it was again favorably received. Final acceptance of the program came following discussions with representatives of the Wood County Board of Education. After gaining the support of the proposal from these necessary constituency groups, a description of program parameters and recommended handling procedures for the orphans was sent to the institutions desiring to participate in the program.
Thirteen non-University academic institutions (eight high schools, two Jr. high schools, a medical college, a technical college, and a joint vocational school) were initially considered formal participants in the recycling program. In 1994, a local hazardous waste management company (Rader) began participating in the program. This cooperative relationship has resulted in the addition of other program participants. Not only have other academic institutions been added to the program, but small businesses, industries, governmental and nongovernmental agencies as well. Currently, the program has assisted participants in Ohio, Michigan, Indiana, Wisconsin, Georgia, Massachusetts, and New Jersey (on hundred and eight to this point)
Under the provisions of the program, each participating institution/facility selects an individual to serve as the contact for the facility. Generally, this person functions within the institution's department of chemistry, facilities research and development division, or similar science-related area. BGSU departments are represented by individuals who are the primary departmental contacts within the University's hazardous waste management program.
If desired, institution and facility representatives subsequently conduct an inventory of their chemical stocks, listing the available orphans on a standardized orphan inventory form. The program's hazardous waste management company is able to identify potential orphans from the materials inventoried during routine disposal activities for their clients. Requested information on the inventory include, for each chemical, the number of containers, the total quantity of the material, the manufacturer and chemical grade (if known), and whether the chemical containers are unopened or the chemical has been repacked.
As indicated earlier, the quality of the chemical is a major factor during the selection of orphans. It is the responsibility of the facility contact to assure the usability of the chemical. The quality of the orphan should not have diminished to the point where it can no longer be used. If requested, the University or hazardous waste management company may be able to assist the institution or facility in determining the chemical quality of the orphan(s).
Institutional and management company representatives submit lists of their available orphans to BGSU's Hazardous Waste Coordinator as frequently as the orphans are identified. The Hazardous Waste Coordinator then compiles the chemical data onto an alphabetized master list.
Hard copies of the master list are then sent to each facility representative who oversees its distribution within the institution, department, or facility. Updates to the list are normally sent on a quarterly basis. Hardcopy updates may be sent more frequently if a significant number of "new" orphans have been identified or numerous chemical transactions have taken place.
The orphan list is also available to any institution/facility having access to the Internet. The listings can be viewed and/or printed from this source but cannot be modified. The listings on the server are updated regularly and are therefore more current than the quarterly hard copy listings.
All orphan chemicals remain at the originating institution/facility until they are claimed or otherwise managed. This limits problems in multiple material handling and prevents questions of responsibility for disposal should the orphan(s) continue to be unclaimed. An exception to this policy involves potential orphans identified by RES during normal waste management activities. Since these wastes/orphans generally necessitate expeditious movement off site, there would be insufficient time to disseminate information on orphan availability prior to their removal. To address this potential loss of orphans, the University's hazardous waste facility is currently being used for the temporary storage of "high visibility" orphans (e.g. acids, bases, solvents). Use of the facility allows the time necessary to properly advertise orphan availability while providing a safe storage site. A formal agreement would be used to affirm Rader's responsibility for the final disposition of any unclaimed orphans.
An institution/facility desiring to obtain an orphan (or orphans) is responsible for initiating the transfer. To facilitate the movement of orphans from one location to another, the facility representative contacts the University's Hazardous Waste Coordinator or RES representative. Specific arrangements for orphan transfer are then made through their combined efforts. This procedure permits the most feasible control of orphan transport while assuring that all transfers are properly documented.
Handling procedures during the transfer of BGSU orphans primarily follow DOT shipping requirements. Containers of orphans covered by DOT regulations are packaged individually (or "lab-packed" if compatible) in DOT acceptable boxes and labeled according to DOT specifications. For orphans not covered under DOT shipping requirements, no formal packaging is performed other than securing the containers during shipment. Orphans transported by the University are moved using a capped University pickup truck. The containers of orphans are placed in a 3' X 5' X 2' wooden box located in the rear of the vehicle. The shipping box has a bottom layer of absorbent material and is equipped with removable partitions for separating containers of various sizes and compatibilities. A spill kit, cellular phone, and shipping paper(s) are also taken during BGSU's transportation of orphans.
In conjunction with each shipment, a Material Safety Data Sheet (MSDS) for each orphan is offered to the institution/facility receiving the orphan(s). A formal document on MSDS distribution has been developed for that purpose. This form will be used to indicate whether the orphan recipient needs particular data sheets or currently has them available. The form will accompany all orphan transfers and will be signed by the recipient of the orphans. These forms are kept on file along with the shipping paper.
Once a transaction has taken place, the Hazardous Waste Coordinator removes the chemical(s), in whole or in part, from the master list. Changes in the orphan inventory are reflected on the hard copies of the updated master list resubmitted quarterly to those institutions/facilities not using the Internet listing. Changes to the Internet listings are made following each transaction.
In addressing the issue of potential liability for the distribution of these chemicals, the University, together with Rader, has developed an indemnification document. The document is an attempt to protect the University and the waste management company from liability for the misuse of the orphan chemicals following their transfer. The document is to be signed by a formally designated representative of the institution/facility (principal, superintendent, facility manager, etc.).
Since April of 1993, the orphan chemical recycling program has transferred approximately 4,000 pounds of solids and 1,500 gallons of liquids to "needy" institutions and facilities. The dual cost savings associated with these transfers (for purchase and disposal) have been approximated at between $370,000 and $460,000.
In addition to the chemicals being transferred, there are also "non-chemical" items that are given away or reused as a part of the orphan chemical program. Periodically, lab glassware that is no longer wanted is distributed to other institutions/facilities that can reuse them. Empty five-gallon containers that have been cleaned are taken from one University department and delivered to others to use for storage. DOT shipping boxes used in the transportation of chemicals to the University are kept for transporting regulated orphans. Bags of vermiculite are saved for packing orphans or given to the hazardous waste management company. Cleaned 55-gallon drums can be reused as refuse containers or kept for the storage of other liquid wastes Cost savings for these storage/packaging materials are not included in the overall savings of the program.
The cooperative efforts between the University and the local hazardous waste management company have added a new dimension to the recycling program. As stated earlier, Rader is able to identify potential orphans during routine waste management activities at both academic and nonacademic facilities. Working in conjunction with facility representatives, Rader's identification of orphans not only increases the quantities of available materials within the program, but it also demonstrates appropriate waste management techniques to these facilities while reducing their waste disposal costs.
Periodic discussions with the contacts of participating institution and other facility representatives are ongoing. These informal meetings assist in resolving any misunderstandings encountered in program implementation and serve to further strengthen cooperative relationships. Also, through formal presentations to environmental colleagues and discussions with other interested parties, information about the program will be disseminated whenever possible to encourage the development of similar programs.
It is hoped that through the success of this program, more facilities will become participants, further protection of the environment will be achieved, additional monies will be saved, and cooperative relationships between the University and other non-University institutions/facilities will be strengthened. It is also hoped that other institutions and waste management companies will investigate the possibilities of implementing these or similar chemical recycling efforts. Others may then experience success in minimizing waste and preserving the environment while demonstrating financial responsibility by providing cost savings to both the "giver" and the "receiver."
Any comments or questions regarding BGSU's Orphan Chemical Recycling Program may be addressed to:
Environmental Health and Safety
Bowling Green State University
Bowling Green, Ohio 43403
(419) 372-2171 ; (419) 372-2194 FAX