Disposal Guide
Montana State University is committed
to maintaining a safe and healthful work environment for its faculty, staff and
students. This manual contains procedures for reducing or eliminating
accidental illness, injury, death or environmental damage that can result from
the improper management and disposal of wastes produced by the University.
This
Disposal Guide has been developed to assist University personnel in the proper
handling and disposal of chemicals, or chemical products in the laboratory and
other University work areas. Although the guide was specifically written to
outline procedures for chemical wastes, it also contains valuable information
on many other types of wastes (i.e., radioactive, infectious, asbestos, PCB's,
gas cylinders, empty containers, controlled drugs, and waste oils).
Each
person in a supervisory or management capacity is responsible for providing and
maintaining proper waste management in his or her respective area and for
ensuring that all authorized and applicable guidelines contained in this manual
are followed. It is of prime importance that all supervisory personnel
understand and accept this responsibility, and take an active role in working
with faculty and staff to provide necessary training, and by setting an example
for them to follow.
Ultimately,
it is individual faculty and staff whom are responsible for implementing this
Disposal Guide, so take personal responsibility for your area. Your attitude, knowledge, and actions will
determine the success of our environmental programs.
Increased public concern over
environmental issues led to a major expansion of the federal and state
environmental laws in past years. Aggressive enforcement of these laws by
regulatory agencies has also increased.
The
numerous environmental laws enacted have been documented in thousands of pages
of regulations, creating an extremely complex scheme. Despite this complexity,
liability for noncompliance with environmental regulations is not limited to
major or intentional offenses that cause significant harm to public health or
the environment. In fact, sizable
penalties have been imposed for relatively minor, inadvertent violations.
Regulatory
agencies and the courts assume that persons working with chemicals today are
knowledgeable of the potential hazards involved with their work. Therefore,
civil and criminal penalties can be imposed on institutions for non-compliance.
Further, this liability can extend beyond the institution to individuals, based
on the reasoning that all responsible personnel, from a lab instructor to a
college president, share in the duty of ensuring compliance with the environmental
laws.
It
is quite clear that the Montana State University and its employees need to meet
the challenges posed by the environmental laws and regulations. This Disposal
Guide contains the information that will enable University personnel to meet their
responsibility for environmental compliance.
This Chapter is designed to give
users just the basics they need to know to manage Hazardous Wastes at Montana
State University. It is for quick reference only and is by no means
comprehensive. Users should read all the applicable portions of this Disposal
Guide for full explanation of the waste disposal procedures at the University.
Except for two areas controlled solely by the Safety & Risk Management division (SRM), all areas where hazardous waste is managed at Montana State University 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 six 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
Step 1
Complete
the Container Label on each of the hazardous waste containers provided by SRM. Use chemical names only. No trade
names, chemical formulas or chemical structures are allowed. Containers with labels
are available through SRM by calling 994-7803 or 994-3572.
Step
2
Call 994-3572 to schedule a waste collection or complete
the Chemical Waste Collection
form. You have the
option of doing this via the Internet on the SRM Homepage, or on a paper form.
Pick-up forms are available through SRM, and you can obtain them by calling
994-7803 or 994-3572. 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.
Step
3
Submit
the form electronically or mail it to SRM. Your waste will usually be picked up
within one week of SRM' receipt of properly completed forms. SRM 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.
Montana State University 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 division of Safety & Risk Management (SRM) 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.
SRM
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.
SRM
will collect hazardous wastes from each generating location at the University
upon receipt of a properly completed Chemical Waste Collection Form
from the generators of this waste. The wastes are transported by SRM via a
truck designed for transportation of hazardous materials to the SRM facility.
This facility has a hazardous waste permit and is engineered to meet building
safety and fire codes. The Montana Department of Environmental Quality and the
United States EPA, to ensure compliance with applicable regulations, inspect it
annually.
The
generating location, type, and quantity of each chemical is
documented as wastes are shipped to the facility and this information is
maintained by SRM in a computer database. The wastes are then segregated
according to compatibility groups and placed in the SRM storage facility. 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 facility and scheduled for removal and
disposal to a permitted hazardous waste facility within 90 to 270 days 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 lab disposing of developing
solutions that contain silver compounds. Listed below are some common points of
generation at Montana State University.
|
SOURCE |
WASTE GENERATED |
|
Research and 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 and Grounds Services |
Pesticides, rodenticides, herbicides, fertilizers |
|
Art Work |
Used solvents, thinners, pigments, inks, acids, dyes and photographic
solutions |
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 Waste Collection Form. A brief description of the process generating the waste is also required on the SRM forms. This helps SRM 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
that 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 that 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 SRM 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 that 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 SRM. 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 SRM at 994-7803 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 SRM. Material safety data sheets (MSDS), container labels,
and reference manuals can be used to identify these characteristics.
NON-REGULATED WASTES
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 SRM 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 SRM.
Refer to the Laboratory Drain Disposal
Guide for acceptable drain disposal procedures.
Materials
with strong odor must not be disposed of via the sewer but should be maintained
in sealed containers and collected by SRM. 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. SRM 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.
UNIDENTIFIED
WASTES
All
wastes to be picked up by SRM 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, SRM 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 consulting individuals who
work in the area where the unidentified material was found can identify the
contents. 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 analyses performed to identify chemicals are: pH, flashpoint, reactivity
screen (mix small amount of chemical with water to see if reaction occurs), and
specific gravity.
Thorough
maintenance of labels on chemical containers reduces the occurrence of
unidentified chemicals. Periodic review of chemical stock and careful record
keeping reduces the chance of discovering containers with missing labels.
Waste
solvents, which are accumulated for collection by SRM, 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 SRM 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 Montana Department of Environmental Quality Hazardous Waste Division. 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 costs are considered, it is
more economical to purchase only the quantities of chemicals that will be used.
SUBSTITUTION
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 less 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.
LABEL CONTAINERS
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.
Other wastes not covered in this guideline may require special handling or disposal as follows:
Pipettes, broken glassware,
microscope slides, and cover slips not considered infectious under this guide
should be regarded as injurious materials because they present a physical
hazard to custodians if placed in the regular trash. Additionally, plastic
vials, pipettes etc are also defined as injurious and should be handled as such
in the same manner indicated. These items should be boxed, sealed, and labeled
"Broken glassware disposal". Please insure the box selected for
shipping broken glass is suitable, sturdy and is taped completely closed for
shipping. Boxes needed to insure proper shipping of broken glass and plastic
can be ordered through Fisher Scientific (1-800-766-7000) or Lab Safety Supply
(1-800-356-0783) or acquired from SRM (994-7803).
Glass that is not broken may be placed
in regular trash receptacles provided that it is not done so in a manner that
can reasonably be expected to lead to its breakage. For more details on
unbroken glass, see the empty container section found later in this Disposal
Guide.
It is the responsibility of every department, unit, or laboratory generating infectious waste to provide the appropriate packaging materials (i.e., sharps container and orange or red infectious waste bags). Biohazard waste bags must be orange or red and can be obtained from Fisher Scientific (1-800-766-7000) or other laboratory supply companies.
If the presence of asbestos-containing materials is suspected, especially those in poor condition, contact SRM at 994-2711. Asbestos containing waste should be disposed of through the Chemical Pickup procedure detailed in Chapter 3.
PCBs (Polychlorinated Biphenyls) are compounds that were widely used in the past in oils and dielectric fluids due to their excellent heat exchange and insulating properties. However, because of their persistence in the environment and ecological damage from water pollution, their manufacture was discontinued in 1976. The handling, storage, transportation, and disposal of PCBs are now strictly regulated by the EPA. Some examples of items which may contain PCBs are:
o Electrical transformers
o Electrical capacitors
o Fluorescent light ballasts
o Hydraulic fluids
o Optical liquids
Anyone generating these materials at the University must handle them as a chemical waste as outlined in Chapter 3. Items such as gloves, clothing, or utensils/tools that become contaminated with PCBs shall also be handled as a chemical waste in accordance with Chapter 3.
Physical Plant employees who
repair or replace lighting fixtures throughout the University must follow the
following procedures while handling the ballasts associated with these
fixtures. Manufacturers are now required to label ballasts "Non-
PCB". Prior to handling any ballast, check to see if it is labeled
"Non-PCB". If the article is not labeled "Non-PCB", assume
it contains PCBs and precautions should be taken when handling these items. If
the article is intact and not leaking, wear a pair of rubber or plastic gloves.
Inexpensive surgical gloves will suffice if not worn for extended periods of
time. If the article is leaking, also wear a pair of goggles. Contact SRM to
coordinate any clean-up from the floor or other areas.
Do not put leaking ballast in
containers already holding non-leaking ballast. Leaking ballast must be segregated
in a small container and managed as a chemical waste as outlined in Chapter 3.
55-gallon drums for lighting
ballast can be obtained from SRM. Physical Plant must notify SRM of the
location of ballast drums to ensure that they are labeled appropriately. Only
lighting ballast should be placed in these drums, they should not be used for
general trash or other special wastes. Once the drums are full, follow the
procedures in Chapter 4 to have SRM pick them up.
Gas cylinders are widely used at the University in teaching and research laboratories and in maintenance and construction operations. University personnel using cylinders must make every attempt to return them to the supplier when finished. Suppliers will usually accept empty or partially full cylinders at no cost. The best approach is to check with the supplier before purchasing any cylinders to see if used cylinders will be picked up when new ones are delivered. If the supplier will not, try to locate one that will. It is extremely difficult and expensive to have cylinders disposed.
If cylinders cannot be returned to a supplier, they can be handled through the SRM chemical waste program. Follow the procedures in Chapter 3 to have them picked up by SRM
BATTERIES
All types of batteries can be safely disposed of through SRM by calling 994-3572. Please collect batteries in a box or other container and when full schedule a collection.
The improper handling or management of empty containers not only creates an undesirable aesthetic situation at the University but, due to their contents, may also pose an environmental and human health hazard. The University is governed by state and federal environmental agencies, which regulate the management of these containers and their contents. Improper handling can result in fines or other penalties imposed against the University.
Empty containers, ranging from
small glass bottles to 55-gallon drums, are defined as those having all
contents removed by commonly employed practices (e.g., pouring, pumping,
scraping, etc.), with no solids or free-flowing liquids remaining in the
container.
All chemical containers handled
under these procedures must be empty. That means that no material can
be poured or practicably removed from that container. If any material can
be poured from the container then it must be either used or managed under the
Chemical Waste Management Program outlined in Chapter 3. If a container held an
acutely hazardous waste it must be managed as a hazardous waste through the
procedures detailed in Chapter 3. Contact SRM for a list of the acutely
hazardous wastes.
Various controlled substances are used at the University for instructional activities or conducting research. Any person engaged in activities with controlled substances must be registered with the Drug Enforcement Administration (DEA).
To dispose of controlled
substances, contact the DEA for authority and instructions. The DEA will
require certificates of destruction in many cases. The DEA will then authorize
and instruct you to dispose of the controlled substances in one of the
following manners:
The person in possession of the substance is responsible for its disposal in accordance with the DEA regulations. SRM will only pick up controlled substances on a case-by-case basis.
USED oils from maintenance shops, pumps, equipment, machinery, etc. should be collected by SRM using the Chemical Waste Management Procedures outlined in Chapter 3. Do not mix any other material with used oils and do not allow water to enter used oil containers. Used oils can usually be transferred to a recycler at little or not cost to the university. However, used oil which has been mixed with water, solvents, heavy metals, toxics, PCB's, or other chemical substances may result in substantial costs to the university. Containers used for accumulating used oils must be clearly marked "USED OIL" will help prevent this problem.