Lab Safety Plan - Hazardous Waste

Section 12:  Hazardous Waste Management

 

12.1 Regulatory Requirements

12.1.1. In Ohio, hazardous waste is regulated by the Ohio EPA.

12.1.2.  Federal EPA regulations also govern certain aspects of hazardous waste management, since some of our waste is treated and disposed of out of state.

12.1.3.  These hazardous waste regulations are part of the Resource Conservation and Recovery Act, or RCRA. Local enforcement authority is administered by the Kent City Health Department.

12.2 Hazardous Waste Program

12.2.1. The EHS Hazardous Waste Program manages the shipment and disposal of all hazardous waste generated on campus. 

12.2.2.  Each laboratory employee must comply with the campus Hazardous Waste Management Program requirements and all applicable regulations. Hazardous waste pick up service is provided to all hazardous waste generators in research buildings on campus, as well as to regional campuses. 

12.2.3.Laboratory personnel are responsible for identifying hazardous waste, segregating, labeling, and storing it properly in the laboratory. 

12.2.4. Laboratory clean-outs and disposal of high hazard compounds must be scheduled at least 4 weeks in advance.  The PI/Laboratory Supervisor is responsible for coordinating the disposal of all hazardous materials from his/her/their laboratories prior to closing down laboratory operations.  Review the Laboratory  Clearance document for more information.  This can be found in the Appendix.

12.3. Definition of Hazardous Waste

12.3.1. Federal and State regulations define hazardous waste as a substance which poses a hazard to human health or the environment when improperly managed. A chemical waste is considered hazardous if it is either listed on one of the lists found in Federal or State regulations or if it exhibits one or more of the four following characteristics:

  1. Ignitable - ignitable wastes generally are liquids with a flash point below 60°C or 140°F (however, just because a material has a higher flash point, it still cannot be drain disposed).
  2. Corrosive - corrosive wastes are generally aqueous wastes with a pH less than or equal to two (2) or greater than or equal to (12.5). Solutions with a pH out of this range can be hazardous. Please contact EHS for clarification.
  3. Reactive - reactive wastes are those wastes that are unstable, explosive, and capable of detonation or react violently with water.
  4. Toxic - a chemical that poses a hazard to health or the environment
    • Has an acute oral LD50 less than 2,500 mg/kg
    • Has an acute dermal LD50 less than 4,300 mg/kg
    • Has an acute inhalation LC50 less than 10,000 ppm as a gas or vapor
    • Has an acute aquatic 96-hour LC50 less than 500 mg/L
    • Has been shown through experience or testing to pose a hazard to human health or environment because of its ability to cause cancer or mutation (carcinogen, mutagen, teratogen), acute toxicity, chronic toxicity, bio-accumulative properties, or persistence in the environment

12.3.2. The EPA definition of hazardous waste also extends to the following items:

  • Abandoned chemicals
  • Unused or unwanted chemicals
  • Chemicals in deteriorating containers
  • Empty containers that have visible residues
  • Containers with conflicting labels
  • Unlabeled or unknown chemicals

12.3.3. Chemicals not in frequent use must be carefully managed to prevent them from being considered a hazardous waste.  This is especially true for certain compounds that degrade and destabilize over time and require careful management so that they do not become a safety hazard.  Be cautious of substances that are corrosive or reactive.  If there is any degradation of the bottle, disposal should occur.

12.4. Extremely Hazardous Waste

Certain compounds meet an additional definition known as “extremely hazardous waste”. This list of compounds includes carcinogens, pesticides, and reactive compounds, among others (e.g., formaldehyde, chloroform, and hydrofluoric acid). The Federal EPA refers to this waste as “acutely hazardous waste”, but EPA has published a more detailed list of extremely hazardous waste. Both the State and the Federal lists are included in the EHS list of extremely hazardous waste. NOTE: While there is some overlap with the list of Particularly Hazardous Substances, the extremely hazardous waste list is specific to hazardous waste management.

12.5 Proper Hazardous Waste Management

12.5. Training

All personnel who handle, manage, or dispose of hazardous waste must complete training prior to working with these materials. The EHS online Hazardous Materials and Waste Management training course covers the hazardous waste program requirements and includes training on container labeling. To complete the Waste Management training, log into Flashtrain. This training is required every three years.

12.6. Waste Identification

All the chemical constituents in each hazardous waste stream must be accurately identified by knowledgeable laboratory personnel. This is a critical safety issue for both laboratory employees that handle the waste once it is turned over to EHS. Mixing of incompatible waste streams has the potential to create violent reactions and is a common cause of laboratory accidents.  If there is uncertainty about the composition of a waste stream resulting from an experimental process, laboratory workers must consult the PI/Laboratory Supervisor or the Chemical Hygiene Officer.  In most cases, careful documentation and review of all chemical products used in the experimental protocol will result in accurate waste stream characterization.
   
The manufacturer’s SDS provides detailed information on each hazardous ingredient in laboratory reagents and other chemical products, and also the chemical, physical, and toxicological properties of that ingredient.  The SDS library provides an extensive library of research chemicals.  Waste streams that have a large percentage of ingredients listed as proprietary information should be discussed with EHS.

12.7. Labeling

Hazardous waste labels must be placed on the hazardous waste container upon the start of accumulation. Kent State University utilizes the CEMS system for submitting hazardous waste pickup requests.  Each label must be completed accurately and updated as the contents of the waste container change. Product names or abbreviations for waste container ingredients should not be used. Information on how to use CEMS is available on the EHS website under Hazardous Waste Pickup.

12.8. Waste Tracking System UNH CEMS

  1. Go to UNHCEMS®. Select Login button under the Welcome Guest Profile.
  2. Select KSU Single Sign On and Login with KSU Flashline Credentials.
  3. Select Hazardous Waste Dashboard and then select request waste removal
  4. Fill in the department, location, waste name, storage state,  quantity and comments (optional). Save the request.  If you want an email confirmation of the submission (select the box).

12.9. Storage

Waste generated from Smith, Science Research Building (SRB) and Williams Hall labs are to be stored in the hazardous waste storage room in the basement of Williams Hall near the loading dock.

Waste generated from Cunningham Hall and Cunningham Annex labs are to be stored in the Waste Storage Room in the Cunningham Annex (A013) basement.

Wastes from the Liquid Crystal Institute (LCI) building, Centennial Park, Lowry Hall, McGilvrey Hall and the Aeronautics and Technology Building (ATB), Center for the visual Arts (CVA) and Art Building are to be kept in the generating lab until picked up by the waste hauler.

Unknown waste presents a significant hazard due to the unknown composition and characteristics. They also cost the University additional monies to dispose of because they must be analyzed to determine their contents which is why the university emphasizes labeling of all containers with the name of the substances to avoid this situation.

12.10. Satellite Accumulation Area Requirements

A satellite accumulation area (SAA) is a term that refers to the storage location of hazardous waste at another location that is either at or near the point of hazardous waste generation which is owned and operated by the generator of the hazardous waste. Satellite accumulation areas are regulated under the Environmental Protection Agency (EPA) and the Resource Conservation and Recovery Act (RCRA) hazardous waste management program.

Satellite Accumulation Area Rules and Responsibilities

  1. All waste must be labeled with the designation “HAZARDOUS WASTE”.
  2. The Accumulation Date Field on the label must be filled in as soon as any waste is added to the container.
  3. All containers must be labeled with contents.
  4. Do not mix incompatible materials in containers. Storage containers must be separated by a partition or wall.
  5. There should never be more than 55 gallons of hazardous waste allowed to accumulate in any satellite accumulation area.
  6. Hazardous waste should never be poured down drains or sinks.
  7. Hazardous waste should never be stored over drains or in sinks.
  8. Hazardous waste must be stored in the immediate vicinity of the laboratory or work area . The hazardous waste storage location should always be clean and inspected on a routine basis.
  9. Hazardous waste should not be stored with facility chemicals. Only compatible hazardous waste is permitted to be stored together in the same containers as waste accumulates.
  10. Transfer full hazardous waste containers to permanent waste storage room.
  11. Waste from discontinued projects, experiments, cleanouts and storage areas should always be transferred to the permanent waste storage area. Note: For large scale cleanouts (ex. laboratories) prior arrangements must be made with the EHS.

The hazardous waste storage area in each laboratory is considered a Satellite Accumulation Area (SAA). According to EPA requirements, this area must remain under the control of the persons producing the waste.  This means that it should be in an area that is supervised and is not accessible to the public.  Other SAA requirements include:

  • Hazardous waste containers must be always labeled with a Waste tag.
  • Waste must be collected and stored at or near the point of generation.
  • The maximum amount of waste that can be stored in a SAA is 55 gallons of a hazardous waste or 1 quart of acutely/extremely hazardous waste. If you reach these volumes for acutely/extremely hazardous waste, you must have the waste removed within 3 days of reaching these set volumes.
  • All hazardous waste containers in the laboratory must be kept closed when not in use, unless temporary venting of a container is necessary or to prevent dangerous situations, for instance buildup of extreme pressure.       Self venting caps can also be used in this case.
  • Hazardous waste streams must have compatible constituents and must be compatible with the containers in which they are stored.
  • Hazardous waste containers should be stored in secondary containment.
  • Containers must be in good condition with leakproof lids.
  • Containers should have 1 to 2 inches of headspace in each container.   Do not overfill.
  • Dry wastes must be double-bagged in clear, 3-mil plastic bags
  • Do not dispose of chemicals by pouring them down the drain or placing them in the trash.

12.11. Segregation

All hazardous materials must be managed in a manner that prevents spills and uncontrolled reactions. Stored chemicals and waste should be segregated by hazard class. Examples of proper segregation are:

  • Segregate acids from bases
  • Segregate oxidizers from organics
  • Segregate cyanides from acids
  • Segregate solids from liquids

Segregation of waste streams should be conducted in a similar manner to segregation of chemical products.

12.12. Incompatible Waste Streams

Mixing incompatible waste streams or selecting a container that is not compatible with its contents, is a common cause of accidents in laboratories and waste storage facilities.  Reactive mixtures can rupture containers and explode, resulting in serious injury and property damage.  All chemical constituents and their waste byproducts must be compatible for each waste container generated.  Waste tags must be immediately updated when a new constituent is added to a mixed waste container, so that others in the laboratory will be aware and manage it accordingly.

Some common incompatible waste streams include:

  • Oxidizers added to any fuel can create an exothermic reaction and explode.  The most frequent is acids oxidizing flammable liquids.  For this reason, all flammable liquids are pH tested before they are consolidated.
  • Piranha etch solution is a specific waste stream that contains sulfuric acid and hydrogen peroxide, which form a reactive mixture that is often still fuming during disposal.  For this waste stream, and other reactive mixtures like it, vented caps are mandatory.
    • Use poly-coated bottles for these types of waste streams

12.13. Wastes That Require Special Handling

Unknown
Unlabeled chemical containers and unknown/unlabeled wastes are considered unknowns, and additional fees must be paid to have these materials analyzed and identified.  These containers must be labeled with the word “unknown”.  To help prevent this, label all your products and use a Waste label as soon as one drop of waste is placed into a container.

Peroxide Forming Chemicals 
Peroxide forming chemicals, or PFCs, include substances that can react with air, moisture or product impurities and undergo a change in their chemical composition during normal storage.  The peroxides that form are highly reactive and can explode upon shock or spark.  Peroxides are not particularly volatile and thus tend to precipitate out of liquid solutions. It is dangerous to allow a container of these materials to evaporate to dryness, leaving peroxide crystals on the container's surfaces.

Each container of peroxide forming chemicals should be dated with the date received and the date first opened. There are three classes of peroxide forming chemicals, with each class having different management guidelines. A review of the safety information provided by the manufacturer can be used as a guide to managing PFCs.

Ensure containers of PFCs are kept tightly sealed to avoid unnecessary evaporation, as this inhibits the stabilizers that are sometimes added.  Visually inspect containers periodically to ensure that they are free of exterior contamination or crystallization. PFC containers must be disposed of prior to expiration date. If old containers of peroxide forming chemicals are discovered in the laboratory, (greater than two years past the expiration date or if the date of the container is unknown), do not handle the container.  If crystallization is present in or on the exterior of a container, do not handle the container. Secure it and contact the EHS.

Dry Picric Acid 
Picric acid (also known as trinitrophenol) must be kept hydrated at all times, as it becomes increasingly unstable as it loses water content.  When dehydrated, it is not only explosive but also sensitive to shock, heat and friction. Picric acid is highly reactive with a wide variety of compounds (including many metals) and is extremely susceptible to the formation of picrate salts.  Be sure to label all containers that contain picric acid with the date received, and then monitor the water content every 6 months.  Add distilled water as needed to maintain a consistent liquid volume.  
If old or previously unaccounted for bottles of picric acid are discovered, do not touch the container. Depending on how long the bottle has been abandoned and the state of the product inside, even a minor disturbance could be dangerous.  Visually inspect the contents of the bottle without moving it to evaluate its water content and look for signs of crystallization inside the bottle and around the lid.  If there is even the slightest indication of crystallization, signs of evaporation, or the formation of solids in the bottle, do not handle the container and contact EHS immediately.  Secure the area and restrict access to the container until it can be evaluated by EHS personnel.  

Explosives and Compounds with Shipping Restrictions

A variety of other compounds that are classified as explosives or are water or air reactive are used in research laboratories. These compounds often have shipping restrictions and special packaging requirements.  When disposing of these compounds, employees must ensure that they are stored appropriately for transport.  Flammable metals must be completely submerged in oil before they are brought to a waste pick-up. Many pyrophoric and reactive compounds can be stabilized using a quenching procedure prior to disposal.  Chemicals classified by the Department of Transportation (DOT) as explosives (e.g., many nitro- and azo- compounds) will require special packaging and shipping and may require stabilization prior to disposal.  Consult EHS at for disposal considerations of these compounds.

12.14. Managing Empty Containers

Empty containers that held Extremely Hazardous waste must be managed as hazardous waste.  Do not rinse or reuse these containers.

All other hazardous waste containers must be empty as much as possible before disposal.   The containers can be reused or discarded as appropriate.    The labels should be completely defaced (remove it or mark it out completely).   EHS has developed a fact sheet as guidance for the handling of empty containers.

12.15. Transportation

It is a violation of DOT regulations to transport hazardous waste in personal vehicles, or to carry hazardous waste across campus streets that are open to the public.  There are two accumulation points on campus.  One is in Williams Hall and the other Cunningham Annex.  Waste can be transported on a cart to these locations.

The transportation of hazardous waste between buildings, rooms on campus or through hallways and other public spaces always poses a risk of accidental release or exposure. To minimize the risk of harm to faculty, staff, students, visitors and the environment the following guidelines listed below will be used for transporting hazardous waste by University personnel, visitors or students. Contact EHS if there are any questions.

  • ALL waste containers have a proper "HAZARDOUS WASTE".  Label with Initial Accumulation Date.
  • ALL contents are listed. List the pH on the disposal tag.
  • The bottle or jar has a cap that fits tightly.
  • There are no old or extraneous labels on the container.
  • There is at least 1" to 2" of head space in liquid containers to allow for expansion and reduce the potential for spillage.
  • The outside of the bottle is clean and dry.
  • Use secondary containers or utility service carts to transport waste to designated areas.

Note: If transporting individual waste bottles outside of the laboratory always use secondary containment (Ex. Plastic Paint or Nalgene Buckets with secure lids, Rubber Bottle Carrier or Original Shipping Containers).

If transporting multiple, large or heavy containers use a utility service cart with large wheels that are 4 to 6 inches in diameter and have a chemical resistant tray or surface and 3-inch lips on all sides to keep chemicals from sliding off the cart.

Always wear the appropriate personal protective equipment (PPE) for the chemicals being transported in the event of a spill or splash to the skin or eyes.

12.17. Accumulation and Disposal

Frequent disposal will ensure that hazardous waste accumulation areas in labs are managed properly, and that accumulation limits are not exceeded.   Hazardous chemical waste can be stored in a laboratory for up to 180 days.  Once a waste container is 80% full or it is near the 180-day time limit, it should be transported to the waste rooms in Williams Hall or Cunningham Annex.  

12.18. Hazardous Waste Minimization

Kent State University is a small  quantity generator of hazardous waste. To reduce the amount of chemicals that become waste, administrative and operational waste minimization controls can be implemented. Usage of chemicals in laboratory areas should be reviewed to identify practices which can be modified to reduce the amount of hazardous waste generated. To minimize the costs, health hazards, and environmental impacts associated with the disposal of hazardous waste, below are some guidelines regarding waste minimization:

Purchasing Control: Check the inventory UNH CEMS before new products are ordered.  When      ordering chemicals, be aware of any properties that may preclude long term storage, and order only exact volumes to be used. Using suppliers who can provide quick delivery of small   quantities can assist with reducing surplus chemical inventory.

Inventory Control: Rotate chemical stock to keep chemicals from becoming outdated. Identify surplus/unused chemicals and attempt to redistribute these to other users.

Operational Controls: Review your experimental protocol to ensure that chemical usage is  minimized. Reduce total volumes used in experiments; employ small scale procedures when  possible.  Instead of wet chemical techniques, use instrumental methods, as these generally  require smaller quantities of chemicals.  Evaluate the costs and benefits of off-site analytical services. Avoid mixing hazardous and non-hazardous waste streams.  Use less hazardous or non-hazardous substitutes when feasible.  Some examples include:

  • Specialty detergents can be substituted for sulfuric acid/chromic acid cleaning solutions  
  • Gel Green and Gel Red are recommended in place of ethidium bromide

12.19. Drain Disposal

Kent State does not permit drain disposal of chemical wastes, unless a specific dilution and/or neutralization method for a consistent waste stream has been reviewed and approved by EHS.  Drain disposal of properly disinfected infectious or biohazardous liquids is acceptable, if disinfection is conducted as specified by the EHS Biosafety Program, and the liquids disposed contain no other hazardous constituents.

12.20. Bench Top Treatment

EPA regulations allow some limited bench top treatment of certain chemical waste streams in laboratories, provided that specific procedures are followed. Due to the stringent nature of these requirements, any treatment of hazardous waste in labs must be reviewed and approved by EHS.  

 

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