CHEMICAL WASTE MANAGEMENT SYSTEM
by schmidy — last modified Jan 08, 2014 11:21 AM
POLICY AND GOALS
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.
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.
WHERE IS HAZARDOUS WASTE GENERATED?
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.
WHAT IS HAZARDOUS WASTE?
In general hazardous waste is either:
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.
CHEMICAL WASTE HANDLING AND DISPOSAL
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
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 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
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:
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"