laboratory hazardous waste management at unc-ch

LABORATORY HAZARDOUS

WASTE MANAGEMENT AT

UNC-CH

To demonstrate the proper methods of

laboratory hazardous waste management for

compliance with state and federal regulations.

Training Goal

Hazardous Waste

Waste that poses a threat to the environment or

human health if not handled or disposed of

properly

Resource Conservation and Recovery Act (RCRA)

passed in 1975

Called for the establishment of regulations

Directed by the Environmental Protection Agency (EPA)

to regulate proper management of hazardous wastes

Hazardous Waste Characteristics

Under RCRA a waste can be hazardous if it has

certain characteristics

Ignitability: if waste is a liquid with a flashpoint of

<140°F

Corrosivity: if waste has a pH below 2 and above 12.5

Reactivity: if waste reacts violently with air or water

Toxicity: if waste contains more than a certain level of

some toxic materials (as defined in 40 CFR 261.24)

“Cradle to Grave”

EPA’s comprehensive system of regulations

From the “cradle” (point of conception) to the “grave” (point of disposal)

Governs the following hazardous waste management activities:

Generation

Transportation

Treatment

Storage

Disposal

Responsibilities of UNC-CH

EPA views UNC as a hazardous waste generator

Generators are responsible for:

properly identifying hazardous waste

proper management of hazardous waste

Use

Storage

Disposal

EPA Fines for Non-compliance

The EPA does impose fines against universities and

colleges

Examples include:

Boston University - $800,000

Penn State - $1 million

UC Berkeley - $1 million

Stanford University - $1 million

Most Common EPA Violations

Most commonly cited EPA violations of hazardous

waste regulations are:

Open containers or lids not screwed on tight

Improper labels/identification

Lack of secondary containment for leaks

Hazardous waste storage location (point of

generation)

The 4L’s – Lids, Leaks, Labels and Location

Lids

Are all containers labeled as hazardous waste closed and secured with proper lids?

Lids/caps must be securely in-place except when material is being removed or added to the container

A funnel resting on the mouth of a bottle does not constitute a lid

Lids/caps on waste containers must be on tight (Note: Be sure that gas producing reactions have worked to completion before transferring the material to a hazardous waste container)

A closed container, when tipped over, won’t leak!

Example – Open Containers

A funnel is not a lid!

Lid open when not in use

Leaks

Are containers labeled as hazardous waste stored in secondary containment?

Secondary containment is to be used to minimize the potential for breakage, spillage and the comingling of incompatible materials (i.e. acids and bases)

Plastic trays, pans or tubs can be used

Without exception, secondary containment is required for the following: All glass containers of liquid hazardous waste stored on the floor

All containers with capacity ≤4 liters of liquid hazardous waste, regardless of storage location

Hazardous materials are to be segregated by hazard class and stored in separate cabinets, trays or pans

Example - Leaks

Potential spill contained by

plastic tub (secondary containment)

Labels

Are all containers labeled as hazardous waste

properly labeled?

Regulations require that the name of the chemical be

clearly identified on the label

Chemical formulas and abbreviations such as H2SO4,

HCl and EtBr are not accepted by the EPA

Hazardous waste regulations require the words

“Hazardous Waste”, or words which clearly identify the

contents such as “Acetone Waste”, be on each waste

container

Example - Labels

Chemical formulas are not allowed

If you re-use a container for collecting

waste you must deface the original label

Location

Are all containers labeled as hazardous waste

stored at or near the point of generation?

Hazardous waste regulations require that the generator

accumulate hazardous waste in containers at or near

the point of generation where waste initially

accumulates, and which is under the control of the

operator who generated the waste

Under no circumstances can waste be stored down the

hall and/or out of your control

Hazardous Waste Containers

Each laboratory must supply their own containers

The original container the chemical came in is usually the best

All containers must have securely fitting lids/caps

All containers must be compatible with their contents

For liquid waste, EHS prefers the amber 4 liter solvent bottles because they are non-recyclable and are compatible with most types of waste

For mixed hazardous waste a log of contents, quantities, dates added and initials of depositor should be located on or near the container

Liquid Hazardous Waste Containers

Leave 10% headspace (volume left at top of

container) in case of expansion due to temperature

Do not pour hot liquids into waste bottles

Do not comingle incompatible wastes (i.e. acids and

bases)

Provide secondary containment

Any containers with capacity of ≤4 liters must have

secondary containment

Solid Hazardous Waste Containers

If original containers are not available

double-bag the material

place in a sturdy cardboard box for support

Bags used should be trash bags

Absolutely no Biohazard or Radiation bags!

Gas Cylinders

Consider buying refillable returnable cylinders

Contact the supplier and make sure they will accept

the cylinder when you are finished with it

Don’t call it “empty” unless it is

Lecture bottles can not be thrown in the trash when

empty

To be considered empty, an aerosol can must

contain NO propellant and NO product, and must

be at atmospheric pressure. UNC regulates all partially empty spray cans as

Hazardous Waste because they may still contain ignitable propellants, chlorinated

solvents, flammable material, or toxic substances.

Do Not discard partially empty spray cans in the trash.

Do Not puncture any aerosol cans.

Store used Aerosol cans in a Closed container labeled as “Aerosol Cans”.

Return spray cans that malfunction (for example, the tip breaks off) to the

manufacturer or dispose of them as Hazardous Waste.

Request a pick-up of your aerosol cans by filling out the form found here at

https://itsapps.unc.edu/HazMat_Pickup/.

Contact UNC EHS at 962-5723 for questions or assistance with disposal of aerosol

cans.

Managing Aerosol

Cans

UNC-CH Hazardous Waste Disposal

Procedures

EHS has established an online chemical waste pick-up form (e510) for laboratory personnel https://itsapps.unc.edu/HazMat_Pickup/

All personnel registered as working in a lab can request waste pick-up for his/her Principal Investigator by accessing online form with ONYEN

You must have a Laboratory Worker Registration form on file at EHS and have completed the General Laboratory Environment training to be able to access the chemical waste disposal form

UNC-CH Hazardous Waste Disposal

Procedures

After completion of the online request form (e510),

it is submitted electronically to EHS for approval

If all information is correct and complete, EHS will

send the approved form back via email

This approval form must be printed out and

attached to the waste container for pickup

Example – Waste Pickup Form

Waste Pickup

Form (e510)

Bulk Laboratory Clean-out or Close-out

If you have a large

amount of chemicals in

your lab for disposal,

contact Steve Parker

(sdparker@ehs.unc.edu)

EHS can set up a direct

shipment straight from

your lab without filling

out an online e510 form

for each chemical

Unknown Chemicals

Check with all lab

personnel and try to

make a waste

determination

Contact EHS to assist with

pickup (Steve Parker,

sdparker@ehs.unc.edu)

Reactive Chemicals

Old or expired reactive chemicals can be

potentially dangerous

Peroxide formers such as ether should not be

handled

Notify EHS immediately if found in your lab (Steve

Parker, sdparker@ehs.unc.edu)

Hazardous Waste Minimization

In order to minimize the waste generated on

campus, labs should do the following:

Practice inventory control using the EHS online chemical

inventory system (https://itsapps.unc.edu/ChemInventory/)

Practice good housekeeping and safe handling

Only order the amount you intend to use

Explore the use of non-hazardous alternatives

Training Post-test

You have completed the Laboratory Hazardous

Waste Management at UNC-CH training module

If you have any questions regarding this training

please contact EHS at (919)-962-5507

In order to receive credit for this training, you must

complete the post-test