The University of Louisville recognizes and accepts its responsibility to provide proper hazardous waste management for University operations such as its research, teaching and support functions that generate chemical waste. In meeting this responsibility, the University has charged the Department of Environmental Health and Safety (DEHS) with the primary responsibility for coordinating the hazardous waste management program. Hazardous waste management is not the exclusive responsibility of any one individual. Every person employed by the University must assume and demonstrate by their action primary responsibility for his or her own chemical waste.
Each employee is personally responsible for complying with the requirements contained in this Disposal Guide. Employees generating chemical waste have moral and legal obligations to see that the waste is handled and disposed of in ways that minimize both short-term and long-term harm to human health and the environment.
DEHS has defined five main goals for the University to fulfill this responsibility.
- Manage and dispose of hazardous waste in a manner which prevents harm to human health and the environment and protects the faculty, staff, and students.
- Manage and dispose of hazardous wastes in the most responsible, environmentally sound, and cost-effective manner.
- Reduce the quantity of hazardous waste generated by the University by encouraging prudent purchase of chemicals and training the University community in responsible work practices.
- Provide safe storage of hazardous waste pending disposition.
- Comply with all government regulations regarding hazardous waste management.
The primary goal in handling and disposal of hazardous waste is to do so in a manner which prevents harm to human health and the environment. Extensive federal, state, and local regulations govern hazardous waste management. The University is covered by these regulations, which are beyond the scope of this guide but, in general, they regulate the handling, transportation, storage, and disposal of waste. The regulations also require extensive record keeping and a "cradle to grave" tracking system which tracks hazardous wastes from their point of generation through disposal. This allows all waste to be accounted for at any stage between generation and disposal.
DEHS will collect hazardous wastes from each generating location at the University upon receipt of a properly completed Chemical Pickup Request Form from the generators of this waste. The wastes are transported by DEHS via a truck designed for transportation of hazardous materials to the University's Environmental Protection Services Center (EPSC). This facility has a hazardous waste permit and is engineered to meet building safety and fire codes. It is inspected annually by the Kentucky Department for Environmental Protection and the United States EPA to ensure compliance with applicable regulations.
The generating location, type, and quantity of each chemical is documented as wastes are shipped to the EPSC and this information is maintained by DEHS in a computer database. The wastes are then segregated according to compatibility groups and placed in the EPSC. Some wastes are treated to remove their hazardous waste designation and many liquid wastes such as solvents are consolidated with compatible liquids in larger containers. The wastes are stored in the EPSC and scheduled for removal and disposal to a permitted hazardous waste facility within one year of pick up.
Most colleges and universities generate hazardous waste and therefore are regulated as hazardous waste generators. Chemical use in laboratories results in the need for disposal of mixed solvents, reagents, reaction products, and excess chemicals of all types. In addition, a number of other fairly common activities at colleges and universities may result in the generation of hazardous waste. Examples include an electrical shop that uses batteries that contain heavy metals and photography labs disposing of developing solutions that contain silver compounds. Listed below are some common points of generation at the University of Louisville.
|Research & Teaching Labs||Waste solvents, reagents, experimentation residues, equipment mercury|
|Electrical Maintenance||Used light ballasts and batteries|
|Paint Shop||Waste solvents and old paint|
|Photographic Labs||Used developers and fixers|
|Buildings & Grounds Services||Pesticides, rodenticides, herbicides, fertilizers|
|Art Work||Used solvents, thinners, pigments, inks, acids, dyes, and photographic solutions|
In general hazardous waste is either:
- Listed in one of four lists that the EPA has generated, or;
- Exhibits a characteristic that the EPA has identified as making it a hazardous waste.
The initial step toward proper chemical and hazardous waste management is to determine whether the waste is hazardous. This determination is important to meet environmental regulations and to properly complete the Chemical Pickup Request Form. A brief description of the process generating the waste is also required on the DEHS forms. This helps DEHS and the generator make the determination of whether the waste is a hazardous waste.
EPA has listed specific chemicals which are hazardous and must be handled in accordance with the hazardous waste regulations. They also identified certain chemical characteristics which can cause a waste to be designated as hazardous. This chapter discusses these lists and characteristics. For the purpose of this program, chemicals that should be considered waste are those which are contaminated or are spent and can no longer be used. Outdated chemicals, and chemicals in poor containers are also to be considered waste. Chemicals which have not exceeded their shelf life, are in good containers, and could be used by someone else are not classified as a waste. These chemicals should be collected by DEHS for placement in the redistribution program.
LISTED HAZARDOUS WASTES
EPA has developed several lists of substances which have been shown to have toxic, carcinogenic, mutagenic, or teratogenic effects on humans or other life forms. Chemicals with physical characteristics such as ignitability, corrosivity, or reactivity are also listed. Because there are over 700 chemicals on these lists and the regulatory principles are not intuitive, determination whether or not a waste is hazardous using EPA lists is a complex task which requires some degree of familiarity with the regulations. Many chemicals which are at least moderately toxic, moderately corrosive or combustible do not appear on these lists. Therefore, any chemical suspected of having any toxic or hazardous properties should be handled by DEHS. Refer to the material safety data sheet, container label, or a reference book such as Merck Index to make determinations on toxicity. When in doubt about whether a material is hazardous, handle it as if it is or contact DEHS at 852-6670 for assistance.
CHARACTERISTIC HAZARDOUS WASTES
Certain wastes which are not specifically listed are regulated as hazardous because they exhibit one or more of the following characteristics: ignitability, reactivity, corrosivity, or toxicity. If wastes exhibit any of these characteristics, they are regulated as hazardous, and arrangements for disposal must be made with DEHS. Material safety data sheets (MSDS), container labels, and reference manuals can be used to identify these characteristics.
- 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 manual, or testing. The following are examples of ignitable wastes: ethyl ether, methanol, ethanol, acetone, toluene, benzene, pentane, hexane, and xylene. 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.
- 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.
- 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 perchlorates, and metal amides and azides.
TCLP TOXIC WASTES
- 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.
- 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 DEHS 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 attained approval for the disposal from DEHS.
- Materials with strong odor must not be disposed of via the sewer but should be maintained in sealed containers and collected by DEHS. 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 manual. DEHS 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.
- All wastes to be picked up by DEHS must be accurately described or they cannot be properly segregated. This greatly affects the safety hazards involved with handling and storage of these materials. From a regulatory standpoint, DEHS is prohibited from accepting unidentified wastes for transportation or storage. When an unidentified material or waste is discovered, an attempt to identify its contents should be immediately undertaken. Usually the contents can be identified by consulting individuals who work in the area where the unidentified material was found. If this fails, the material will have to be analyzed with the cost of analysis being borne by the department in which the material was found. Some common analysis performed to identify chemicals are: pH, flashpoint, reactivity screen (mix small amount of chemical with water to see if reaction occurs), specific gravity.
- Thorough maintenance of labels on chemical containers reduces the occurrence of unidentified chemicals. Periodic review of chemical stock and careful recordkeeping reduces the chance of discovering containers with missing labels. The University's Summary and Compliance Manual for Hazard Communication Standard also has specific requirements and guidelines for labeling chemical containers that must be followed by all University personnel.
How to Comply with the Hazardous Waste Regulations
Except for two areas controlled solely by the Department of Environmental Health and Safety (DEHS), all areas where hazardous waste are managed at the University of Louisville are considered satellite accumulation areas. This is a regulatory designation which allows generators in these areas to operate under the minimum of regulatory oversight. As such, the following five points are all that generators need to know to operate in compliance with the law. It is critical that generators know and understand these points and that they manage their waste in accordance with them.
Hazardous Waste Satellite Accumulation Requirements
- The container holding the hazardous waste must be marked with the words "Hazardous Waste". No variation of these words is permissible.
- The container holding the hazardous waste must be in good condition. This means no cracks, no rust, and no leaks.
- The container holding the hazardous waste must be compatible with the waste and any waste mixtures in that container must also be compatible.
- The container holding the hazardous waste must be closed at ALL TIMES. The only exception to this is when waste is being added to or removed from the container.
- Accumulation of hazardous waste in any satellite accumulation area cannot exceed 55 gallons at any time. If the area accumulates acutely hazardous waste, one quart is the maximum amount allowed to be accumulated. A list of the acutely hazardous wastes is available in Chapter 3 - CHEMICAL WASTE MANAGEMENT SYSTEM.
How to get Hazardous and Chemical Waste Picked Up
Complete and affix Container Labels to each of the containers of waste which you want picked up. Use only one label for each container and use chemical names only. No trade names, chemical formulas or chemical structures are allowed. Container labels are available through DEHS by calling 852-6670.
Complete the Chemical Pickup Request Form. Complete information is required or waste cannot be picked up. Use the label numbers that correspond to the container labels you have affixed to your containers. Please list the contact person who knows first hand about the waste being picked-up.
Your waste will usually be picked up within two weeks of DEHS' receipt of properly completed form. DEHS must have access to the area where the waste is located to pick it up. If special arrangements for gaining access need to be made, please note this on the comments section of the request form.
Five-gallon high-density polyethylene containers for accumulating waste solvents and other high volume liquid wastes are available from DEHS at no cost to University departments. These containers are distributed based on waste type and volume. Contact DEHS at 852-6670 to obtain these containers for high volume liquid wastes. Waste Solvents
Waste solvents which are accumulated for collection by DEHS are to be segregated into halogenated and non-halogenated categories. Halogenated solvents contain a halogen compound such as chlorine or fluorine to reduce flammability. Non-halogenated solvents do not contain a halogen compound and are generally more flammable. The 5-gallon containers provided by DEHS for accumulation of solvents should be clearly marked "HALOGENATED" or "NON-HALOGENATED" and strictly limited to those types of solvents. These two categories of solvents are segregated for increased safety and efficiency.
New Research, Abandoned Labs, and High Waste Volumes
- If a new research project that will generate large quantities of waste is going to begin, contact DEHS ahead of time to plan waste management.
- If an investigator or other person is leaving their employment with the University, the department chair should contact DEHS prior to that person's departure. Laboratories should not be abandoned with chemical wastes present.
- If any activity that will generate large volumes of any type waste handled by DEHS (chemical, radioactive, infectious) will be commencing, contact DEHS prior to that activity's start up so that proper planning for waste disposal can be accomplished.
Effective hazardous waste management requires not only safe, sound practices, but also requires extensive efforts to reduce the volume and toxicity of hazardous wastes. The University's waste minimization efforts must also be reported annually to the Kentucky Division of Waste Management. Waste minimization efforts reduce disposal and the hazards and environmental impact associated with chemical wastes. The success in minimizing hazardous wastes depends on a conscientious effort by each individual at the University. These are some common waste minimization strategies:
REDUCING CHEMICAL PURCHASES
- A substantial portion of hazardous waste produced at the University consists of unused, outdated chemicals. Careful planning of quantities of chemicals required can reduce costs to the laboratory and reduce waste volumes. Many chemicals may also degrade over time, so careful consideration of quantities purchased. Also, risk of accident and exposure to the chemical and space needs are less when handling the smaller container. Although it may seem less expensive to buy chemicals in larger quantities, it is in fact more expensive if the cost for disposal is taken into consideration. Some chemical manufacturers sell chemicals in smaller containers to help laboratories reduce the excess purchase of chemicals. When disposal cost are considered, it is more economical to purchase only the quantities of chemicals that will be used.
- A non-hazardous chemical can often be used in place of a hazardous chemical. For example, some academic laboratory procedures still specify benzene or carbon tetrachloride as reagents or solvents. These compounds often can be replaced by less hazardous materials. This results not only in safer procedures, but also in wastes that may be hazardous in some respects. Additionally, many commercial, non-hazardous glass cleaners are available in lieu of toxic and corrosive chromic acid. Similarly, different procedures may be available which do not require the use of hazardous chemicals. For more chemical product substitution information visit MIT’s Green Wizard.
- Keeping all of the containers in your lab labeled with their contents will result in safer work practices as well as removing the need to dispose of unidentified chemicals.
Chemical purchases can often be reduced by borrowing and sharing chemicals between laboratories. Departments are encouraged to exchange chemicals whenever possible and utilize the DEHS Chemical Redistribution Program as much as possible.
Not all the chemicals picked up by DEHS are a waste. Many are only partially used and have not exceeded their shelf life or been altered in anyway. Others are unused and still in the original sealed container. In some cases, these chemicals can be used by someone else at the University. Reusable chemicals collected by DEHS are brought to the central accumulation area, recorded, segregated, and held for redistribution instead of disposal.
The redistribution program can mean a real cost savings for the University in two ways. First, utilizing chemicals from the redistribution program decreases the amount of new chemicals purchased. Secondly, chemicals which are redistributed do not require disposal, avoiding the extremely high cost associated with that service. Each chemical may be reviewed prior to acceptance. The person who receives the chemical is responsible to determine the suitability of the chemical for their use.
LESS IS BETTER PUBLICATION
For more detailed information on the chemical waste minimization strategies outlined in this section, please read the American Chemical Society publication entitled "Less is Better" (PDF)