Purpose
The purpose of this policy is to 1) prevent haphazard or indiscriminate disposal of University-generated wastes that can pose a hazard to health and the environment, and 2) to provide for the proper and legal disposal of such wastes.
Definitions
Generally, waste is defined as surplus, unneeded, or unwanted material. Lab workers have some latitude in declaring a substance as a waste, although some regulations limit this discretion. Anything that is abandoned or "inherently wastelike" (such as a spilled substance) is a waste.
The following characteristics are associated with hazardous materials:
(1) A material is ignitable (flammable) if it has any of the following characteristics:
- it has a flashpoint of less than 60 C (140 F), or some other characteristic that has the potential to cause fire;
- it is capable, under standard temperature and pressure, of causing fire through friction, absorption of moisture, or spontaneous chemical changes and, when ignited, burns vigorously and persistently so as to create a hazard;
- it is a flammable compress gas, or can form a flammable gas mixture;
- is it an oxidizer that stimulates combustion of organic materials.
(2) A material is corrosive if it is a liquid that has a pH of less than 2 or greater than 12.5 (or corrodes certain grades of steel).
(3) The material is reactive; that is, it is normally unstable, reacts violently with water, is capable of detonation if exposed to some initiating source, or produces toxic gases.
(4) The material 1) has an LD50 less than 50 mg/kg (oral, rat), an LC50 less than 2 mg/L (rat), or a dermal LD50 less than 200 mg/kg (rabbit), or is otherwise capable of causing or significantly contributing to an increase in serious, irreversible, or incapacitating reversible, illness, or 2) is listed in Appendix VIII in 40 CFR 261.
Procedures
The Wittenberg University hazardous waste management program has four basic components: waste minimization, identification, storage, and disposal.
1. Minimization
a. Only those amounts of chemicals known to be needed should be ordered. "Economy of Scale" purchases should be avoided when the immediate foreseeable use of the chemical is not obvious.
b. Procedures should be designed, where possible, to eliminate or minimize the amount of waste materials generated. This should preferably be included as part of the lab experiment for student laboratories.
c. Whenever possible, spent solvents should be recovered and recycled by distillation or chromatographic purification for reuse.
d. Aqueous solutions of acids and bases should be neutralized before flushing down the drain with large volumes of water.
e. Solutions containing toxic heavy metals such as mercury, lead, chromium, silver, etc. should be precipitated and the metal recovered in solid form for subsequent disposal as a solid waste.
f. Fume hoods should not be used as a means of disposal of volatile chemicals.
g. Liquid organic wastes should be emptied into labeled plastic containers kept in vented metal cabinets in each laboratory.
h. Highly reactive wastes such as acid chlorides should be converted to a less reactive form before disposing in the waste containers.
2. Identification
a. All wastes are to be clearly labeled with: contents, the name of the person who labeled it, and the date. Labels are to be as specific and thorough as possible. For example: "used degreaser, ARMCO-SD 70 from Geology Department" tells more than simply "used degreased" or "waste solvent." Labels should include product or chemical name, suspected contaminants, and a note about the process which produced it.
b. Every effort should be made to avoid an unlabeled waste container. If such a container is discovered, the lab supervisor should attempt to determine the most likely contents of the container by interviewing appropriate people. The substance should be analyzed only if there is a high degree of certainty that this can be done without risk. If this cannot be done, the substance must be disposed of as an "unknown" at considerable cost to the University.
3. Storage
a. Each department or generator is responsible for storing its own waste until it is transferred to a central location prior to being picked up by a disposal firm.
b. Each generator (lab) may accumulate no more than 55 gallons of hazardous waste or 1 quart of acutely hazardous waste.
c. The Code of Federal Regulations states that hazardous waste pick-ups are to occur within 90 days after the waste starts to accumulate (at the collection site) in order to avoid becoming a storage facility. All university departments and campus generators will be notified of the collection date so that wastes can be made available for pick-up.
4. Disposal
a. Certain chemical wastes are not to be treated or disposed of on campus, but are shipped off campus. Wastes sent off campus include those that require special disposal permits, those subject to regulations specifying where and how they may be disposed, and those for which no on-campus disposal system works. As noted above, these wastes can be accumulated for no more than 1 year at the generator/satellite locations. Once at the collection site, off-campus disposal must occur within 90 days.
b. A permit is received from the EPA for this disposal. The wastes are packed into fifty-five gallon drums in accordance with EPA and Department of Transportation specifications, detailing the types of wastes that may be packed together, types of packing material, and types and conditions of the drums. Labels must be affixed to the drums to indicate the types of waste contained within. Pertinent documentation is made by University personnel regarding the wastes being removed for disposal. The waste drums are then picked up by the outside firm who is responsible for transportation and the disposal of the wastes. The Wittenberg University Purchasing Department will schedule the pick-up date for the waste with an approved disposal contractor.
c. An annual written survey will be made by the Purchasing Department to determine the amount and kind of wastes to be disposed. The survey will include a definition of hazardous waste and examples of such materials. A written response will be attached to a copy of the survey request, and determination will be made of the need for disposal services based on the response.
Addendum
Samples of Hazardous Waste
MPCA - Toxic and Hazardous Wastes. Toxic and hazardous wastes are waste materials including but not limited to poisons, pesticides, herbicides, acids, caustics, pathological wastes, radioactive materials, flammable or explosive materials, and similar harmful chemicals and wastes which require special handling and must be disposed of in a manner to conserve the environment and protect the public health and safety.
Infectious Waste
1. All wastes originating from persons placed in isolation for control and treatment of an infectious disease.
2. Bandages, dressings, casts, catheters, tubing, and the like, which have been in contact with wounds, burns, or surgical incisions of a suspected, known or medically identified hazardous infectious nature.
3. Laboratory and pathology waste of an infectious nature which has not been autoclaved.
4. All anatomical waste, including human parts or tissues removed surgically or at autopsy.
5. Any other waste as defined by the State Board of Health which because of its potential infectious characteristics or hazardous nature requires handling and disposal in a manner prescribed for (1) through (4).