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Section 2 - Hazardous Waste Compliance

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University of Minnesota Hazardous Waste Instructions

What You Need to Do to Comply

Most Common Regulatory Violations

What is Hazardous Waste?

Characteristics of Hazardous Waste
Listed Hazardous Waste
Other Criteria

Caution: If your area holds a significant amount of chemicals (greater than 300 containers or 55 gallons total), the outside door to the room should be labeled with a National Fire Protection Association "NFPA 704" sign to alert fire fighters to the dangers within. Call EHS at (612) 626-6002 for more information.

University of Minnesota Hazardous Waste Instructions

The University is required to manage hazardous wastes in a safe and environmentally sound manner by federal, state, and local regulations. As a generator of hazardous waste, you are responsible for ensuring that you and your employees follow University guidelines concerning management and disposal of hazardous waste within your laboratory, shop or service area.

The following summaries tell what steps you need to take to comply with University rules on how you should handle your hazardous waste, and how you should prepare for chemical spill emergencies. They are presented to give you a better understanding of how to manage your chemical wastes.

What You Need to Do to Comply

Use pollution prevention techniques to reduce the amount of hazardous waste generated

  1. Use microscale techniques, nonhazardous chemical substitutes, or process modification to reduce the amount of waste generated.
  2. Contact your peers, professional organizations, or vendors to learn about the latest pollution prevention techniques.
  3. Share unused chemicals within your department.
  4. Train your employees and students in pollution prevention techniques.
  5. Use the Chemical Redistribution Program to recycle unused chemicals.

Do not dispose of hazardous waste by evaporation, sewer or trash

  1. If a chemical does not have the "xxNH" nonhazardous designation in Chemical Registry (see Appendix I), then it is considered hazardous and must not be disposed of by evaporation, sewer or trash.
  2. Get written authorization from the Chemical Waste Program (612) 626-1604 for permission to sewer or trash nonhazardous chemicals (see Appendix II for a form to request permission to sewer or trash chemicals or use the online form at http://www.dehs.umn.edu/forms/). Review approvals on an annual basis. Only chemicals with a nonhazardous "xxNH" DDC designation and dilute solutions of lower toxicity chemicals (DDC "05xx") can be approved for sewering. All others must be managed as hazardous waste.

Caution: Never throw hazardous chemicals in the trash! Never pour hazardous chemicals down sinks, toilets, floor drains or on the ground! You can be held criminally liable for purposely misrepresenting the contents of your wastes and improperly disposing of your wastes!

No matter how "harmless" the chemical. NEVER throw chemicals down the drain, out in the trash, or out in the environment without the approval of the Chemical Waste Program! Remember, you will be held liable.

Properly label waste containers

  1. Label each bottle with the words "Hazardous Waste," and the exact contents of the bottle (include percentages and water content). Do not use abbreviations or chemical formulas, as emergency responders may not recognize these. Labels are available from the Chemical Waste Program hazwaste@umn.edu or (612) 624-6060, or you can make a facsimile of the label (see Figure 4-2).
  2. Add the start date and fill date.
  3. Add your name and phone number.

Keep waste in compatible containers and closed at all times

  1. Containers and lids must be compatible with the waste chemicals stored in them (refer to vendor compatibility charts or call (612) 626-1604).
  2. Keep waste containers closed at all times except when adding or removing waste.

Caution: Do not leave a solvent bottle, drum, or any bottle of waste open with a funnel in it for the sake of convenience! This is one of the most common citations from inspectors.

Note: Click here for advice on closure for waste containers for HPLC and other analytical equipment.

Segregate incompatible waste

  1. Use the drum designation code (DDC) to segregate incompatible chemicals in containers and boxes (see Appendix I). Generally, DDC numbers 05, 08 and 18 organic material can be stored together. Especially separate acids (02) from bases (01); oxidizers (16) away from organics (05, 18xx, 08); water away from any water sensitive compound (xxWS); cyanides (18CN) from acids (02); and organic acids (02OA) from oxidizing acids (nitric, fuming sulfuric, perchloric acids).

Use secondary containment for liquid waste

  1. Use containment trays or safety cabinets to store waste containers and boxes (high density polyethylene trays are available from University Stores: CX 18998 (medium): CX18999 (large).

Caution: Use compatible containers for your waste. For example, use glass jugs for organic solvents or polyethylene for strong caustic solutions! Make sure the containers and caps will not react with your waste!

Inspect waste weekly if required

  1. If waste is not stored near the point of generation, weekly inspections must be performed and documented.
  2. If more than 55 gallons of a single waste stream is stored on-site, weekly inspections must be performed and documented.
  3. \
  4. If more than one kilogram of an acute hazardous waste (EPA P-list waste) is stored on-site, weekly inspections must be performed and documented (see Appendix I).
  5. Use inspection form in this Guidebook (see Appendix II).

Have your waste collected regularly - every 90 days is a good rule of thumb; follow directions in this Guidebook.

  1. Package the waste containers (see Part 4).
  2. Fill out the waste packing forms (see Part 4).
  3. Send the appropriate copies of the waste packing form to the Chemical Waste Program (see Part 4).

CAMPUS MAIL
Chemical Waste Program

TCEM 2681

US MAIL
Chemical Waste Program
University of Minnesota
TCEM-Thompson Center for Environmental Management
501- 23rd Avenue SE
Minneapolis, MN 55455-0447

  1. Include copies of any analytical test results with your waste packing form, if available.
  2. Include pH of any solutions.
  3. Include material safety data sheets (MSDS), if available, for trade name wastes and commercial products.
  4. Phone the Chemical Waste Program at (612) 626-1604 or e-mail at hazwaste@umn.edu f you have unlabeled or shock-sensitive compounds (see Part 5).

Whether your containers are full or not, the University's standard is that you send in a waste form within 90 days of starting the waste collection. Most labs and service areas at the University of Minnesota are considered satellite accumulation points for hazardous waste and, even though technically exempt from the 90 day waste storage limit, should ship waste within 90 days.

Designate On-site Emergency Coordinators or Lab Safety Officers

Designate two people in your laboratory or service area to be on-site emergency coordinator and backup emergency coordinator. These people should know what hazards exist in your area and how to implement the spill response plan for the area. They will act as advisors to Police, Fire Department and Environmental Health and Safety personnel.

Post the Emergency Information and Phone Numbers form

Post the completed Emergency Information and Phone Numbers form with names and telephone numbers near your phone(s) (see Appendix II).

Notify Environmental Health and Safety at (612) 626-6002 or 911 in the event of a chemical spill

  1. Notify EHS or 911 for any spill that exceeds your capability to safely clean up or presents a safety hazard to personnel, property or the environment.
  2. Call 911 and EHS if a fire has occurred or is likely to occur, or if someone has been injured.
  3. Evacuate personnel from the spill area.
  4. Shut off gas lines or electrical power to equipment if possible.
  5. Get immediate medical attention for victims.
  6. Confine the spill by closing doors or roping off the area.
  7. Report the spill to Environmental Health and Safety or 911.
  8. Secure the area until emergency responders arrive.
  9. Act as a technical advisor to emergency responders.

Document training of your employees and students

  1. Train your employees when they are first hired, and annually thereafter. Training is available:
    1. Online at http://www.dehs.umn.edu/training/labsafety/waste
    2. In person by DEHS staff, sign up at https://onestop2.umn.edu/training/courseDetail.jsp?course=EH1001&category=HAZWASTE&unit=EH
    3. Through your departmental Research Safety Officer
  2. Training is documented for Online and In Person options above through the University's PeopleSoft Human Resources database. You can access your records through http://hrss.umn.edu/trainingmenu.html . For departmental training, your Research Safety Officer will provide training documents and explain how your department keeps these files.

Most Common Regulatory Violations

The following list shows which violations are most commonly cited by regulators. Please review this information and correct any problems in your area. Failure to periodically review your compliance efforts an cause health and safety concerns as well as fines from city, county, state or federal inspectors. Fines are the responsibility of the department that incurs them.

PROBLEM SOLUTION
Labeled improperly Waste containers must have:
  • the words "Hazardous Waste" on them
  • complete description of the waste.
  • the start date.
  • the fill date, when filled.

Note: Labels with the proper wording are available at no charge from the Chemical Waste Program hazwaste@umn.edu or (612) 624-6060 or you may make a facsimile of the label (see Figure 4-2).

Containers not closed Keep containers closed except when adding or removing waste.
Incompatible wastes/chemicals stored together Separate waste containers and reagent chemicals by the first two digits of the drum designation codes (DDC number) (see Appendix I), per the instructions above.
Waste not contained properly Containers of liquid waste need secondary containment. Bottles of waste should be kept in chemical storage cabinets or in chemically resistant trays (University Stores, catalog no. CX18999), and separated by hazard class (DDC number) (see Appendix I).
Lab personnel not aware of proper response in event of chemical spill, fire, explosion, or injury Train your employees and students in emergency procedures. Follow procedures in this Guidebook and in your Chemical Hygiene Plan. For chemical spill response assistance in the Twin Cities metro area, call EHS at (612) 626-6002 during work hours or call 911 for 24-hour assistance.
Note: (Twin Cities campus only) Dialing 911 from a campus phone connects you directly to campus police; do not dial an "8" first.
Chemicals disposed of improperly
  1. Do not sewer chemicals without approval of Chemical Waste Program.
  2. Do not evaporate residual solvents in fumehoods. Use condensers on all distillation and concentration procedures.
  3. Do not throw hazardous waste in trash.
Waste not compatible with hazardous waste storage container used Use containers and lids or caps that are compatible with the waste stored in them.
Hazardous waste storage areas not inspected on weekly basis If personnel store their hazardous waste in area not under direct observation of their employees, such as in a central chemical storeroom, they must perform weekly inspections of the area and document the inspections.

Inspection forms must be kept for a minimum of three years and be available upon request of Environmental Health and Safety, and city, county, state or federal regulatory inspectors.

Inspection forms must list dates of inspection, name of person performing inspection, deficiencies in labeling, storage compatibility, secondary containment, any spills and date when deficiency is corrected. Sample weekly inspection forms are included in this Guidebook (Appendix II).

There are three criteria which trigger the weekly inspection requirement (see above).
  • waste not stored near point of generation
  • greater than 55 gallons of a single waste stream
  • greater than 1 kilogram of an EPA P-listed waste acutely hazardous)
Personnel not properly trained Employees and students must be trained prior to working with chemicals and must receive annual refresher training. Training options are outlined above.

All personnel working with hazardous chemicals must review this Guidebook. Call (612) 624-6060 for hard copies or visit our web site at http://www.dehs.umn.edu

Document training and file documentation in your departmental head office. Sample training documentation forms are included in this Guidebook (Appendix II).

Review the requirements of your Chemical Hygiene Plan. Call (612) 626-2330 for a copy of the University's generic Lab Safety Plan.

Free training sessions are provided by Environmental Health and Safety. Go to
https://onestop2.umn.edu/training/courseDetail.jsp?
course=EH1001&category=HAZWASTE&unit=EH or call (612) 626-6002 to register.

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What is Hazardous Waste?

A waste or unwanted chemical must be managed as a hazardous waste if it exhibits hazardous characteristics or is specifically listed in federal or state regulations.

Characteristics of Hazardous Waste

On the basis of criteria set forth by the Environmental Protection Agency (EPA) and the Minnesota Pollution Control Agency (MPCA), chemical waste is considered hazardous if it exhibits any of the following characteristics:

Ignitability

Note: Fire safety policies at the University do not allow the sewer discharge of any alcohol, except for ethyl alcohol at concentrations of 5% or less. The amount sewered annually must be approved by and reported to the Chemical Waste Program, (612) 626-1604, or e-mail at hazwaste@umn.edu (See form to request permission to sewer or trash chemical http://www.dehs.umn.edu/forms/ or Submit copy of form from Appendix II)

Dilution of ethyl alcohol solutions at concentrations greater than 5% for disposal purposes is prohibited by federal, state, and local regulations. Evaporation of waste solutions is also prohibited by regulation.

Corrosivity

Reactivity

Dilution of ethyl alcohol solutions at concentrations greater than 5% for disposal purposes is prohibited by federal, state, and local regulations. Evaporation of waste solutions is also prohibited by regulation.

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Lethality (As defined by MN Rules 7045.0131, subpart 6)

This characteristic applies to many of the chemicals listed in the University's registry of chemicals, each of which needs to be researched against these standards. If adequate lethality testing has not been done, the University needs to apply this characteristic by default.

Toxicity Characteristic

The Toxicity Characteristic Leaching Procedure (TCLP) is a standardized test which mimics rainwater leaching through solid waste and compares the amount of toxic constituents released by the leaching action to federally established standards. If the standard is exceeded, the waste is hazardous. Liquids are analyzed directly without adding the leachate material. For a list of these chemicals (see Appendix IV).

Listed Hazardous Waste

EPA and MPCA regulations also list approximately 450 commercial or off-specification chemicals, waste streams, or their spill residues which must be handled as hazardous wastes due to their acute or chronic toxicity. For a list of these chemicals (see Appendix V). (see Appendix V). Of special interest are those chemicals with an EPA Waste Code beginning with the letter "P." When these chemicals are disposed of there are more stringent on-site storage requirements and the empty containers must be triple-rinsed before discarding as trash.

If you have any questions, call the Chemical Waste Program at (612) 626-1604.

Other Criteria

In addition, the University of Minnesota has chosen to manage as hazardous waste certain chemicals which may not technically be considered hazardous waste under the hazardous waste regulations. Such chemicals have sufficient mutagenic, teratogenic, carcinogenic, or reproductive hazards that they warrant such special handling (e.g., ethidium bromide). In general, waste streams containing greater than 1 ppm of these wastes should either be deactivated in the laboratory or sent through the Chemical Waste Program.

For more information on wastes requiring special processing, see Part 5.

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