Chapter 1 - INTRODUCTION
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.
Chapter 2 - JUST THE FACTS
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.
How to Comply with the Hazardous Waste Regulations
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
- 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 contents must be labeled and identified by name.� No variation of chemical names by using abbreviations or symbols is permissible.
- 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 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.
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.
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.
- Call 994-3572 for empty containers
- SRM has 2.5 and 5 gallon plastic jugs;also, 1 gallon plastic coated glass bottles
- The container must always be closed during storage
- All glass containers must have plastic safety coating, unless the chemical is in it's original container
- Ask SRM for a container compatable with the waste you will be producing
Chapter 3 - CHEMICAL WASTE MANAGEMENT SYSTEM
POLICY AND GOALS
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.
- 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.
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.
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 lab disposing of developing solutions that contain silver compounds. Listed below are some common points of generation at Montana State University.
Research and Teaching Labs
Waste solvents, reagents, experimentation residues, equipment mercury
Used light ballasts and batteries
Waste solvents and old paint
Used developers and fixers
Buildings and Grounds Services
Pesticides, rodenticides, herbicides, fertilizers
Used solvents, thinners, pigments, inks, acids, dyes and photographic solutions
WHAT IS A HAZARDOUS WASTE?
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 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.
- IGNITABLE WASTES
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.
- CORROSIVE 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.
- REACTIVE WASTES
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 that 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 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.
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
- If a new research project that will generate large quantities of waste is going to begin, contact SRM 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 SRM 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 SRM (chemical, radioactive, infectious) will be commencing, contact SRM 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 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.
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.
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.
Chapter 6 - MISCELLANEOUS WASTE
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:
- Electrical transformers
- Electrical capacitors
- Fluorescent light ballasts
- Hydraulic fluids
- 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
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.
To handle empty containers
- Remove completely or deface all labels on the container and remove the lid.
- Thoroughly rinse all containers and place upside down on paper towels until completely dry.
- Place containers in dumpsters not in regular trash for collection by custodians.
Any broken glass containers must be placed in a rigid box that is marked as "broken glass". These
boxes may be placed with (not in) the regular trash for collection.
- Glass that is not broken may be placed in regular trash receptacles provided that it is done in a
manner that will not lead to its breakage. For example, it is reasonable to assume that one
container placed in a trash can will not become broken. Glass containers should not be thrown
into trash cans and several glass containers should not be placed in the same trash can. If you are
in doubt, place the glass containers in a rigid box as outlined in the broken glass section above.
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:
- By delivery to the local DEA
- By destruction in the presence of an agent of the DEA
- By such other means as the DEA may determine to assure that the substance does not become available to unauthorized persons.
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.