Hazardous Waste Management Procedures
The following are basic guidelines for University departments in the identification, collection, and temporary storage of hazardous wastes as defined primarily under 40 CFR 261 and 3745-50 through 52 OAC (Ohio Administrative Code). These procedures should be considered as minimal and need to be used as a foundation for more detailed guidelines developed by individual departments.
Hazardous waste management procedures developed by departments should be reviewed by the University's Hazardous Waste Coordinator, in the Department of Environmental Health and Safety (EHS), to determine consistency with existing waste management standards.
An initial step in effective hazardous waste management is the proper identification of materials that require some form of final disposition. The purpose, of course, is to be able to ascertain whether these materials are considered "hazardous" or not. Realistically, all materials considered for drain disposal or landfilling should be evaluated by departmental personnel to determine its proper status.
Initial waste determination will be based on whether the material has been contaminated or "spent" during its use. All such chemicals are to be considered as waste and therefore managed accordingly. Containers of unspent or uncontaminated chemicals will not be formally identified as waste until assessed by either the University's Hazardous Waste Coordinator or the University’s hazardous waste management company. Assessment will be made following movement of these chemicals to the University's Hazardous Waste Storage Facility. These chemicals may be candidates for waste minimization efforts (e.g. orphan chemicals).
To aid in waste determination, specific chemicals/products deemed as hazardous are listed as a part of 40 CFR 261 or 3745-51-(30 to 33) OAC. General hazardous waste categories ( ignitable, corrosive, reactive, and toxic) are also defined for nonspecific chemicals and products that exhibit one or more of these hazardous characteristics. If the status of the waste material remains uncertain, the University's Hazardous Waste Coordinator is available to assist in that determination.
All locations of hazardous waste generation within the department/area must be identified to assure that the waste chemicals generated are being correctly managed. Materials that are spent and/or destined to be commingled with other compatible materials necessitate a more stringent management protocol than materials that are just no longer wanted. Determining the materials status will also dictate the form of storage and labeling procedures to be implemented. These will be explained in upcoming sections.
All pertinent waste inventory data from departmental laboratories and other building areas need to be relayed periodically to the department's designated Hazardous Waste Liaison or other departmental representative so assigned. This will permit the timely compilation of all waste chemical/product inventories generated by the department.
Regular chemical/product inventories should also be conducted to reduce the stockpiling of unwanted or unusable materials. Such assessments should be performed during periods of least interruption to ensure their accuracy and completeness. Personnel having responsibility for chemicals/products within the department should conduct these inventories. A Hazardous Waste/Orphan Chemical Inventory form is available to assist departments/areas with waste inventories and provide consistency in the reporting of waste data.
Once all points of hazardous waste generation have been identified within the department, every effort should be made to minimize the quantities of hazardous wastes being generated. As mentioned previously, waste minimization techniques need to be incorporated whenever possible to reduce the amounts of waste that require special handling procedures. Certain chemicals and/or specific quantities of chemicals may be legally disposed by means other than formal collection and removal from the department.
The EPA specifications for the identification of hazardous wastes that are included in this manual should be made available for review at strategic locations throughout the department. Any questions concerning the identification of hazardous wastes need to be directed to the applicable departmental Hazardous Waste Liaison or the University's Hazardous Waste Coordinator (372-2173).
All containers used for the collection/storage of hazardous wastes must be structurally sound. The utilization of proper containers minimizes the potential for leakage and/or other releases into the environment. Whenever possible, the original container(s) need to be used. Container determination should be based on chemical characteristics of the waste material to be stored. For example, corrosive wastes should not be placed in a metal container.
Collection sites need to be established within the laboratory or other areas where hazardous wastes are generated. Waste containers should be conveniently located at these points as well. Individuals moving wastes to temporary storage sites must be knowledgeable of the relevant waste characteristics, waste handling guidelines, and appropriate spill control measures. Safety/spill control materials should also be readily available should a spill occur during transfer.
NOTE: Safety cans and other similar storage containers are available through various commercial outlets. Recycled containers for waste storage may also be used. Information on acceptable chemical containers can be obtained through the Hazardous Waste Coordinator.
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 wastes must be properly labeled. Any container with a label that is not secure or is becoming illegible must be relabeled.
Containers of waste chemicals require the words "Hazardous Waste" above the chemical name. All containers used for commingling of wastes must be labeled with the words "Hazardous Waste" and include 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.
Locations for the temporary storage of departmental hazardous wastes need to be selected carefully. Working fume hoods, for example, would be necessary for waste materials requiring adequate ventilation. Specific waste storage areas should be separate from other "usable product" storage sites if at all possible. A sign or other appropriate means to prevent confusion over the status of the stored material should identify all waste storage areas. Additionally:
- All containers of hazardous waste must be kept closed at all times with the exception of adding or removing waste
- Funnels or other similar devices cannot be kept in containers between uses
- Containers of hazardous waste cannot be stored on the floor
Compatibility standards also apply to waste storage locations. Waste materials which are incompatible should not be stored together or in such as manner inconsistent with acceptable chemical storage practices. Separate containers must be used for incompatible wastes.
The most recent inventory of all hazardous wastes should be kept within the storage area. Departmental Hazardous Waste Liaisons or other designated individuals need to be routinely informed of the waste chemicals/products and their respective quantities being generated within their department. All hazardous wastes should remain at the temporary storage locations until transferred to central departmental storage sites, if available.
Interdepartmental Waste Transfer
Periodically, hazardous wastes from laboratories and other building storage areas may be moved to a central storage site within the department where they are consolidated. Specific transfer procedures involving the movement of hazardous wastes should be developed and implemented by each department having centralized storage.
During transfer, all hazardous waste containers must be adequately secured. Lab carts or other types of temporary storage units may be used as long as spill potentials are minimized. Since the potential of a spill increases during chemical/product movement, only individuals trained in departmental spill control protocols should transfer hazardous wastes. Spill control equipment should be within easy access to those moving hazardous wastes.
Central Departmental Storage
Consolidated storage of hazardous waste requires similar procedures as those of general chemical/product storage. Chemical compatibilities, acceptable labeling, and the structural integrity of the containers are all important storage issues which must be considered. If possible, containers of hazardous waste should be kept in a location separate from usable chemical/product storage. Any separate waste area should be marked by a sign or other means of identification.
A current and comprehensive inventory of all departmental wastes must be maintained. As in the routine inventory procedures explained previously, the "Hazardous Waste/Orphan Chemical Inventory" form should be used for this purpose. Waste data should be added to this form at the time the wastes arrive at the central storage area. The departmental Hazardous Waste Liaison or other departmental representative should have the responsibility for maintaining this inventory. Up-to-date waste information is vital in facilitating the necessary waste removal arrangements with a licensed hazardous waste management company. Copies of the hazardous waste inventory should be provided to the Hazardous Waste Coordinator upon request.
While in storage, routine inspections should be conducted by departmental personnel having responsibility for those areas. Hazardous waste containers should be observed on a regular basis for leaks and other problems such as labeling and structural integrity. Corrective actions can then proceed as necessary.
Since the storage of departmental hazardous wastes is concentrated in this central location, spill control equipment should be conveniently stored within this area. Neutralizing solutions, absorbent materials, and related safety equipment need to be easily accessible to those in charge of central storage areas or those responsible for spill response.
The removal of departmental wastes must be scheduled with the University's Hazardous Waste Coordinator. A copy of any departmental inventory form(s) will accompany the chemicals during their transfer to the University’s Hazardous Waste Facility. Containers of chemical wastes will initially be checked for structural integrity prior to being transported. Any container deemed unsound will remain at the site until the contents are repackaged.
The Hazardous Waste Coordinator and/or personnel from the University’s hazardous waste management company will move the waste materials from the appropriate building(s) to a vehicle(s) used for waste transportation. A designated University vehicle is primarily utilized for this purpose. The waste chemicals are placed either in a wooden shipping box or other protective shipping unit(s) within the transportation vehicle. The wooden shipping box is compartmentalized to protect the chemical containers from damage. The box contains an appropriate layer of absorbent material to absorb any spilled materials during movement to the facility. The vehicle will also be equipped with spill control materials (i.e. spill control pillows) and protective equipment for use in case of a spill.
All hazardous wastes received from University departments and areas are taken directly to the University's Hazardous Waste Facility. Wastes will remain at this location until a final determination is made as to the status of the material. All materials determined to be wastes will be packaged and removed from campus by a licensed hazardous waste management company. The packaging, transportation, and disposal of the University's hazardous wastes will be performed according to all state and federal regulations and in conjunction with the University’s hazardous waste management company.