Laboratory Hazardous Waste Management at UNC-CH

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Laboratory Hazardous Waste Management at UNC-CH
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Training Goal

• To demonstrate the proper methods of laboratory
  hazardous waste management for compliance with
  state and federal regulations.

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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

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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 lt140F
• 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)

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Cradle to Grave

• EPAs 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

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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

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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

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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 4Ls Lids, Leaks, Labels and Location

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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, wont leak!

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Example Open Containers
Lid open when not in use
A funnel is not a lid!
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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

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Example - Leaks
Potential spill contained by plastic tub
(secondary containment)
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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

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Example - Labels
Chemical formulas are not allowed
If you re-use a container for collecting waste
you must deface the original label
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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

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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

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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

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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!

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Gas Cylinders

• Consider buying refillable returnable cylinders
• Contact the supplier and make sure they will
  accept the cylinder when you are finished with it
• Dont call it empty unless it is
• Lecture bottles can not be thrown in the trash
  when empty

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Managing Aerosol Cans

• 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.

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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

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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

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Example Waste Pickup Form
Waste Pickup Form (e510)
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Bulk Laboratory Clean-out or Close-out

• If you have a large amount of chemicals in your
  lab for disposal, contact Steve Parker
  (sdparker_at_ehs.unc.edu)
• EHS can set up a direct shipment straight from
  your lab without filling out an online e510 form
  for each chemical

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Unknown Chemicals

• Check with all lab personnel and try to make a
  waste determination
• Contact EHS to assist with pickup (Steve Parker,
  sdparker_at_ehs.unc.edu)

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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_at_ehs.unc.edu)

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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
  /EHSLogin/?type3appChemInventory/)
• Practice good housekeeping and safe handling
• Only order the amount you intend to use
• Explore the use of non-hazardous alternatives

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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