Hazardous Waste Disposal
107. Hazardous Waste Disposal
Hazardous wastes may be generated by a variety of college/university activities, such as teaching, research laboratories, maintenance, and housekeeping. These wastes may cause severe illness or death or pose substantial environmental threats when improperly stored, transported, treated or disposed of. A University Waste Management Program has three basic goals:
- To dispose of hazardous waste in compliance with all applicable federal, state, and local regulations.
- To manage the wastes generated in a manner that protects students, employees, the citizenry, and the environment.
- To reduce the volume and toxicity of waste generated to the greatest degree practical.
107a. General
BMP
- Establish a centralized training and record-keeping program.
- Establish a centralized coordinator, designated as the Environmental Manager, to oversee the Hazardous Waste Disposal Program.
- Anyone who uses hazardous materials and could generate waste must undergo a comprehensive training program regarding the use, storage and disposal of hazardous waste materials. Regulatory requirements are very specific regarding this.
- Only use a state or federal permitted disposal or recycling facility for disposal of all hazardous waste materials.
- An appropriate Hazardous Waste Manifest tracking system must be used for shipments of hazardous waste materials. These records must be maintained by the generator of the waste for a minimum of three years.
- All wastes are to be processed through the Environmental Health and Safety Office.
- The Environmental Health and Safety Office will arrange for disposal through a licensed waste disposal company.
107b. Chemical
BMP
- When a chemical is no longer wanted and requires disposal, it must be labeled with the words "Hazardous Waste." Once considered a hazardous waste, there are specific regulatory guidelines regarding disposal. Contact the Environmental Health and Safety Office for disposal.
- Store chemical waste in containers that are compatible with the material they contain. Hazardous waste containers must be in good condition with no rust or leaks. If the container is failing, transfer the waste to a new container for disposal.
- The complete chemical names(s) must be labeled in English on the container. Chemical abbreviations are not acceptable. Waste containers must be labled with the words "Hazardous Waste" and a tag with the chemical content information. As waste is added to the container, add chemical contents to the tag or spreadsheet list for that tag number.
- Materials that contain toxic metals (like beryllium, and heavy metals (such as arsenic, cadmium, chromium, lead, mercury, osmium, selenium and silver), corrosive liquids and solids, flammable liquids and solids, oxidizing agents, peroxides, poison liquids and solids, organic peroxides, and flammable and non-flammable gases, are all classified as HAZMAT and must be disposed of as hazardous waste.
- Special attention should be given to land application materials such as pesticides, herbicides and fertilizers.
- All wastes are to be processed through the Environmental Health and Safety Office.
- The Environmental, Health, and Safety Office will arrange for disposal through a licensed waste disposal company.
P2-E2
- Implement micro-scale chemistry whenever possible.
- Substitute non-hazardous or low-hazardous materials whenever possible.
- Implement "Green" chemistry.
- Consult regulatory requirements regarding the specific requirements related to employees who are responsible for handling chemicals in the laboratory, MSDS access, and required training related to Hazardous Materials.
107c. Batteries
- Batteries in their various forms will contain heavy metals and acidic or caustic materials. There are six types of batteries commonly found on most campuses. These are:
- Alkaline (Alk) or Dry Cell Batteries: Traditional batteries having limited use because of the life expectancy. Most are not rechargeable. These batteries do not contain hazardous substance in sufficient amount to warrant special disposal arrangements and may be disposed of in the regular trash.
- Lead Acid Batteries: Typically used in some medical equipment, CPU, motorized vehicles such as cars, golf carts. These batteries are also used in some older cellular phones and camcorders. These batteries contain lead, which is considered hazardous. They must be disposed of as hazardous waste.
- Lithium, Lithium Ion, or Lithium Hydride (Li or LiH) Batteries: Rechargeable batteries typically used in beepers, two-way radios, laptop computers, cellular phones, camcorders and some medical equipment. These batteries contain lithium, a heavy metal, which is considered hazardous. They must be disposed of as hazardous waste.
- Mercury Batteries: Typically used to power Telemetry monitoring devices, computer motherboards and hearing aids. These batteries contain mercury, a heavy metal that is considered hazardous. They must be disposed of as hazardous waste.
- Nickel Cadmium (NiCad) or Nickel Hydride (NiH) Batteries: Rechargeable batteries typically used in beepers, two-way radios, laptop computers, cellular phones, camcorders and some medical equipment. These batteries contain cadmium, a heavy metal, which is considered hazardous. They must be disposed of as hazardous waste.
- Zinc Air Batteries: Used as an "environmentally friendly" substitute to replace mercury batteries in telemetry units and some other electronic equipment. These batteries do not contain hazardous substances and may be disposed in the regular trash.
BMP
- Batteries should be stored to prevent and/or contain leaks.
- Batteries should be stored in a properly ventilated area.
- Battery acid should be stored in a manner to prevent and contain any leakage.
- Battery acid should not be stored near any strong bases.
- Batteries should not be disposed of in a landfill or incinerator. They should be sent for recycling or reclamation.
- MSDS should be up-dated and posted at or immediately near the storage area.
- All wastes are to be processed through the Environmental Health and Safety Office.
- The Environmental Health and Safety Office will arrange for disposal through a licensed waste disposal company.
P2-E2
- Try to use rechargeable batteries.
- Use mercury free batteries.
107d. Outdated Medications
BMP
- Contact your on-site pharmacist or EH&S staff for proper disposal methods.
- Some controlled substances and drugs must be disposed of in accordance with Drug Enforcement Agency (DEA) requirements.
- Store outdated medications in locked storage areas that meet the DEA requirements for controlled substances.
107e. Fluorescent Bulbs/Tubes
BMP
- Collect and properly store all fluorescent bulbs/tubes.
- Minimize breakage of the tubes.
- All wastes are to be processed through the Environmental Health and Safety Office.
- The Environmental Health and Safety Office will arrange for disposal through a licensed waste disposal company.
P2-E2
- Replace all silver-end tubes with more environmentally friendly green-end tubes.
- Recycle fluorescent bulbs instead of disposing of them.
107f. Lead-Containing Material
BMP
- All paint residue that is determined to contain lead, cadmium or chromium shall be disposed of as hazardous waste if laboratory analysis of the residue(s) exceeds the allowable TCLP concentration(s). Paint residue samples that contain heavy metal concentrations below the allowable TCLP levels shall be disposed of as demolition or construction waste, unless it qualifies as hazardous waste for other characteristics.
- All paint residues, including chips, shall be collected by those generating the waste. If initial analysis establishes that it is free of heavy metals, continuous collection and testing may not be required.
- Waste drums shall be adequately labeled to identify the source building(s) and date(s) of paint removal.
- Paint removed using wet chemical methods shall be stored separately from dry paint residues. These containers shall also be labeled with the name of the building and dates of paint removal.
- All wastes are to be processed through the Environmental Health and Safety Office.
- The Environmental Health and Safety Office will arrange for disposal through a licensed waste disposal company.
107g. Mercury & Mercury Compounds
Mercury is a naturally occurring element with unique chemical and physical properties that is a dangerous and often unrecognized hazard. It can bioaccumulate in the environment and its persistence in that environment makes it particularly hazardous to humans and animals. Mercury is commonly used in laboratory equipment such as thermometers, manometers, pressure gauges, switches, sphygmomanometers, and mercury containing compounds (Hg Compounds).
BMP
- Do not mix together free mercury, mercury oxide, mercuric sulfide, mercury amalgams or mercury absorbed in spill kits. Place each of these types of materials in a separate, unbreakable container and label appropriately.
- Other mercury-containing materials such as mercury-contaminated labware, mercury salts and spill clean-up products must be disposed in accordance with established regulatory guidelines.
- All wastes are to be processed through the Environmental Health and Safety Office.
- The Environmental Health and Safety Office will arrange for disposal through a licensed waste disposal company.
P2-E2
- Currently there is limited or no disposal capacity at all in the USA for mercury salts and mercury containing organic compounds. Limit the volume of mercury-related waste you generate. Every attempt should be made for recycling or minimization of mercury use.
107h. Used Oils
Waste oils are generated from maintenance shops, laboratory equipment (centrifuge, diffusion pumps, vacuum pumps), landscape activities (lawn mowers), engine/vehicle maintenance (petroleum based oils used for lubrication of engines and machinery) and facility equipment (HVAC systems, elevators).
Some of the more common waste oils are pump oils, crankcase oil, gear oil, hydraulic fluid, power steering fluid, and #2 fuel oil.
BMP
- Disposal of these oils should be done using a reputable waste oil permitted facility.
- Compressor oil associated with refrigeration units may become contaminated with chlorinated materials from refrigerants and should be sampled prior to disposal.
- All wastes are to be processed through the Environmental Health and Safety Office.
- The Environmental Health and Safety Office will arrange for disposal through a licensed waste disposal company.
P2-E2
- Keep used oil separate from solvents and other waste streams to allow for proper reclamation or ultimate disposal options.
107i. Paints
Many paint-related wastes are regulated as hazardous wastes. These include used oil-based paints, turpentine, spent brush cleaning solvents, mineral spirits, paint thinners, etc.
BMP
- Some latex or water based paints may also be hazardous wastes, depending on the toxicity of the pigments (which may contain heavy metal compounds) and other constituents. Refer to waste disposal instruction on the paint containers or accompanying MSDS sheet.
- Paint containers that are dry and empty (per EPA, less than 3 percent of original content) may generally be disposed of as regular trash.
- Other solidified latex paint may be disposed of in the regular trash. Absolutely no free liquids are allowed in dumpster or in a landfill. All other paints must follow appropriate disposal guidelines for hazardous waste materials.
- Paint-associated debris (i.e. paint scrapings, stripping materials) must be disposed of as hazardous waste.
- Materials that contain toxic metals (such as beryllium, heavy metals such as arsenic, cadmium, chromium, lead, mercury, osmium, selenium and silver), corrosive liquids and solids, flammable liquids and solids, oxidizing agents, peroxides, poison liquid and solids, organic peroxides, flammable and non-flammable gases are all classified as HAZMAT and must be disposed of as hazardous waste.
- Contact EH&S for disposal of all hazardous materials.
107j. Maintenance Shop Materials
There are a number of specific types of hazardous materials that are used, stored and disposed of in maintenance shops. Many of these materials must be properly used and stored in accordance with regulations, college/university procedures and these practices.
Prior to disposal, contact the designated waste coordinator.
Materials of specific interest and that are referenced elsewhere are:
- Paints (4, 13 i.);
- Parts cleaners (solvents) (13 l., 24);
- Lubricants and Cutting Oils (13 l., 24);
- Pesticides (11); Fuels (24 a., 43, 44);
- Metal and wood shavings (14 b., 14 c., 18); and
- Contaminated rags (4, 9, 13h., 13 i., 13 l.).
Consumer products which are purchased from a variety of commercial suppliers/vendors must be handled in accordance with all regulations even though they can be used by homeowners. Once they are purchased for intended use at a college/university, they are no longer considered exempt from regulatory concerns.
For additional specific information, refer to the appropriate BMPs listed throughout this document, particularly BMP 4, 9, 10, 11, 13, 14, 30, 37, 38, 42, and 43.
107k. Equipment containing Chlorofluorocarbons (CFCs) and Hydrochlorofluorocarbons (HCFCs)
- CFCs and HCFCs are used in cooling systems and are maintained under pressure. These chemicals are known to cause damage to the ozone layer of the Earth's atmosphere when released to the air.
- Equipment containing CFCs and HCFCs must be purged before disposal can take place. Contact the equipment manufacturer to arrange for the equipment to be purged.
- It is illegal to knowingly vent CFCs and HCFCs into the atmosphere. Should an accidental release occur, contact the designated waste coordinator immediately. There are regulatory requirements for reporting the release.
P2-E2
- Consider recycling options when establishing disposal programs.
- Compressor oil associated with refrigeration units may become contaminated with chlorinated materials from refrigerants and should be sampled prior to disposal.
107l. Spent Cleaning Solvents/Oils
Solvents are used to clean and degrease parts in a wide range of activities; including maintenance shops, grounds shops, HVAC repair, electrical repair and fleet maintenance.
BMP
- MSDSs should be readily available and reviewed prior to using each product. This is in conjunction with a training program for individuals who use these products.
- All cleaning products must be properly labeled. It is suggested they be kept in their original containers.
- Follow all manufacturer recommendations for use, storage and disposal. Pay particular attention to appropriate concentrations.
- Use appropriate PPE when handling these materials.
- Do not store solvents above eye level.
- Standardize products throughout the campus to minimize training on specific materials and to ensure ease of following safety practices.
- Excess solvents must be stored in approved safety cans or UL-approved (or equivalent) flammable storage cabinets. Unless a cabinet is marked as approved for storage of flammable liquids, flammable solvents may not be stored there.
- Store flammables, combustibles and other fuels away from strong oxidizers, such as perchloric and nitric acids. It is best to store flammable liquids in an approved storage cabinet dedicated solely for that purpose.
- Parts, washers and containers with solvents, should have lids closed at all times except when being used.
- Disposal of solvents and oils should only be done using a reputable and permitted service.
P2-E2
Find and use alternatives to solvents. Alternatives include such things as aqueous parts cleaners and enzymatic parts cleaners.