Tufts Environmental Health and Safety April 2010

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1 7. HAZARDOUS WASTE 7.1 Hazardous Chemical Waste The Resource Conservation and Recovery Act (RCRA) of 1976 gave the Environmental Protection Agency the authority to regulate the generation, transportation, treatment, storage and disposal of hazardous chemical waste. The Hazardous and Solid Waste Amendments of 1984 built upon this authority by restricting land disposal of hazardous chemical waste. As a research driven institution and generator of hazardous chemical waste, Tufts University not only wants to support a healthy and safe environment but is also responsible for compliance with these regulatory requirements. With the assistance of Tufts Environmental Health and Safety (TEHS) each generator (i.e. laboratory, clinic, maintenance area, etc.) is responsible for maintaining compliance per federal, state, and internal requirements. Below is a summary of requirements applicable to chemical waste. Note: different requirements are required for biological or radioactive waste. What chemicals are regulated as hazardous waste? Hazardous chemical waste is a heavily regulated topic. The primary reason for this is that there are three tiers of oversight; federal, state and internal or University requirements. In addition, other requirements such as waste water limitations restrict sink disposal of chemicals that do not fall under one of the three tiers of oversight. A summary of each tier is as follows: Federal, U.S. Environmental Protection Agency (EPA): The EPA has established five lists (D, F, K, U, P). Chemical on any one of the five lists are classified as a listed waste and must be managed as a hazardous chemical waste. In addition to listed waste, chemicals may be classified as a characteristic waste, thus making them applicable to the same requirements. Characteristic waste is a chemical that contains any one of the following; ignitable, corrosive, reactive, toxic. Below are the definitions of each. Ignitable: Liquids with a flashpoint of 60 C/140 F or less. Examples: alcohols, ethyl ether, petroleum ether and benzene Solids that may cause fire through friction or the absorption of moisture. Examples: sodium potassium metal, carbon powders, metal dusts Oxidizers, liquids and solids. Examples: chlorates, nitrates, peroxide, nitric acid >40% or fuming Corrosive: ph 2.0 or 12.5 Examples: Strong acids and bases such as hydrochloric acid, nitric acid, ammonium hydroxide, sodium hydroxide. Reactive: Toxic: Unstable. Reacts violently with water. Friction or heat may cause explosion. A cyanide or sulfide bearing waste which, when exposed to a ph between 2.0 and 12.5, can generate toxic gases. Old cans of picric acid and of ether may explode if opened or otherwise disturbed (Contact Tufts EHS for assistance). Waste containing concentrations equal to or greater than those listed in the Toxicity Characteristic Leachate Procedure (TCLP), has been named as a hazardous waste and listed or is a mixture containing a listed hazardous waste and a non-hazardous and a nonhazardous waste.

2 State, MA Department of Environmental Protection (DEP): In addition to EPA requirements, the DEP has regulated additional chemicals. Common examples are waste oils and PCBs. University Policy: In addition to EPA and DEP requirements, the University has elected to regulate additional chemicals. Reasons for this include a chemical being heavily regulated under waste water requirements. Other reasons include chemicals that present a danger to people and the environment, yet for reasons unknown they are not regulated at the federal or state levels. An example of this is ethidium bromide. Despite it not being regulated, due to its toxicity the University elects to manage this as a hazardous chemical waste. When does a chemical become a waste? Chemical stock, solutions, etc. become a waste when the generator declares it a waste. Essentially, when you determine that there is no longer a need for a particular chemical. With this said, there are a number of other qualities that may dictate when a chemical becomes a waste. They are as follows: Shelf-life expiration dates have been exceeded or are unknown. Chemicals are stored in old, bulging, badly decomposed or damaged containers. Chemicals have become obsolete because of questionable purity or discontinued usage. Chemicals have undergone visible changes (i.e. amber-colored perchloric acid). During past regulatory inspections, chemicals containing any one of these characteristics have been classified as inherently waste-like. As a result, researchers may be asked to validate the chemical is still of value. Failure to do so may result in the penalties for failing to properly manage hazardous waste. Note: Extreme caution should be used when discovering an old or damaged peroxide forming, extremely toxic or volatile chemical. Immediately contact Tufts EHS for assistance. How do I properly manage a hazardous chemical waste? Hazardous chemical waste should be placed in a satellite accumulation area (SAA). Each point of generation (i.e. laboratory, clinic, maintenance area, etc.) should have an SAA that is under the direct supervision of trained employees. SAAs at a minimum should include a secondary containment system/bin, sign designating the area as a SAA, and a weekly log book. Below are requirements for managing an SAA: Containers should have a hazardous waste label. Waste labels should at minimum contain the full chemical name (abbreviations or chemical formulas are not permitted) and have the proper statement of hazard (ignitable, corrosive, reactive toxic) noted. Note, a date full should be noted for items requiring pick up. Waste containers should be located in secondary containment bins. Waste containers should be adequate condition for transport or storage (no leaks or corrosion). Waste containers should be tightly closed (corks, parafilm, foil not permitted). Waste containers should be compatible with waste. Incompatible chemicals should be properly separated. Waste containers should be separated from virgin stock. Waste containers should meet the 3-day rule. A dated container requiring pick up must be transported to a main accumulation area (MAA) within 3 days of full date noted on the waste label. Refer to the how do I request a pick up section for additional details. There should not be multiple containers of the same waste in the SAA at one time. There can only be one full container of a certain type of waste. Waste containers should be appropriately spaced/easily accessible for inspection.

3 There should be less than or equal to 55 gallons of waste, or 1 quart of acutely toxic waste (Plisted waste) per satellite accumulation area. The WEEKLY satellite accumulation area log book should be current. Unless a SAA is new, log books must contain the last six months of inspections logs. When and how do I request a pick up? A pick up should be requested when there is no longer a need for a waste container, the container is old, or it is approximately 80-85% full. At this time the label will need to be dated full (mm/dd/yyyy) and a request for pick up submitted. Remember, waste must be transported to a main accumulation area (MAA) within 3-days, therefore immediately requesting a pick up is important. Procedures for requesting a pick up differ pending the location. Below are instructions for the various locations: Boston Campus: Online request via EHS website or contact xt /xt HNRC Building: Contact the receiving department at xt Grafton Campus: Online request via EHS website or contact xt /xt Medford Campus: Contact your department s coordinator. If you do not know who this is, contact EHS at xt When making a request for pick up, be sure to communicate the name/make-up of waste, quantity, building and room number, and principal investigator/contact name. What do I do with large quantities of unwanted stock chemicals? Laboratory relocation or cleanouts often produce large quantities of unwanted stock chemicals that are still of value. In these situations, it is recommended that colleagues within a department be contacted in the event an unwanted chemical is of value to them. All chemicals not used by colleagues must then meet hazardous chemical waste requirements as outlined above. Contact Tufts EHS for assistance. What do I do with empty chemical containers? When there is an empty container in which the previous constituent is known, the ideal scenario is to reuse the container for collection of the same waste or a compatible waste. If there is not a need, contacting colleagues for use of empty containers is recommended. In the event the container cannot be reused, it will have to be disposed. Simply note on the container empty and discard glass in glass receptacle boxes or plastics in standard trash receptacles. However, for containers that previously contained extremely toxic chemicals such as p-list waste, carcinogens, mutagens or teratogens, containers should be labeled with a hazardous waste label, placed in the SAA and a pick up requested. What is the palm pilot inspection program? EH&S has implemented a satellite accumulation area inspection program, otherwise known as the palm pilot inspection program. With the assistance of an outside vendor, unannounced inspections are conducted approximately every month. The purpose of the inspections is to assist personnel with waste management requirements and assure compliance with hazardous waste regulations promulgated by U.S. Environmental Protection Agency (EPA) and MA Department of Environmental Protection (DEP). Inspections take roughly 5-10 minutes and focus on a variety of chemical management issues. If an issue is identified, it is corrected immediately. In addition, present lab members will be notified and educated on the issue. Once inspections are complete, results are communicated to designated personnel such as department managers, principal investigators or laboratory technicians.

4 If I generate or oversee hazardous waste, do I need training? Initial and annual refresher training is required for individuals who generate or participate in hazardous waste management activities. This includes most personnel working in laboratories. Offering of trainings differ pending the location. Trainings are offered via traditional classroom lectures and by computer based programs. 7.2 Medical and Biological Wastes The objective of medical and biological waste regulations is to mandate the treatment of all potentially infectious materials and thereby minimize the risk of infection and injury from the mishandling of these wastes to staff, students, solid waste handlers and the public. Massachusetts regulations classify the following materials as medical and biological waste and require specific types of processing as well as documentation of that processing: Human blood and blood products Note: excludes feminine hygiene products Animals and animal wastes: if treated with or contaminated with an infectious disease agent presenting a risk to human health or infected with an agent that causes zoonotic diseases as listed in 105 CMR ; Pathological wastes: human organs, tissues and body fluids from diagnostic procedures including specimens of such materials; Cultures of infectious agents: including live or attenuated human or animal vaccines Sharps: any object that can cause skin cuts or punctures including: Needles, syringes, lancets, Pasteur pipettes, broken glassware, broken plastic ware, scalpels, blades, suture needles, and dental wires. Biotechnology effluent materials: any waste materials made from microbes or their products including microbes and their products made from genetically altered living microbes (recombinant DNA) Responsibilities Individuals generating medical and biological wastes at Tufts University must identify such wastes, collect such wastes in a proper container, disinfect liquid wastes before discharge into the sink and sewer and arrange for the proper disposal of such wastes. Sink and sewer discharge of specific medical and biological wastes The Massachusetts State Plumbing Code 248 CMR 10 defines any waste containing recombinant DNA as a special waste. Liquid wastes containing recombinant DNA molecules shall be sterilized or (otherwise) treated (decontaminated) at the point of generation before discharge into the sewer system. On the Boston and Medford campuses, the Massachusetts Water Resources Authority restricts the release of pathogenic agents into the sewer. Hence, any liquids containing these agents must be collected and autoclaved or treated with a chemical agent effective at deactivating all pathogenic microbial agents, before discharge into the sink and sewer.

5 Collection of medical and biological wastes There are two procedures for disposing of solid medical and biological waste: on-site autoclaving of medical and biological waste and off -site treatment using a commercial disposal site, usually using incineration. The method of collection of waste will vary depending on the final disposal method chosen. Sharps are processed in a separate procedure. A. On site treatment in an autoclave Medical and biological waste must be placed in a clear autoclave bag with no biohazard lettering or symbols. This bag must be placed in a red plastic container with a lid (preferably using a hands free step pedal mechanism). The bag should not be moved through the hallway to the disposal area unless transported in the red container or other secondary container to prevent spilled liquids or loss of control in the event of bag failure. Note: The use of clear bags permits the treated waste to be placed in the dumpster as trash; red bags indicate that the waste could be infectious hence should not be placed in the dumpster. B. Off site treatment via incineration or other approved method Medical and biological waste destined for incineration must be placed in a 3 mil red bag in a cardboard box displaying the phrase biohazard and the biological safety symbol. C. Sharps Sharps are collected in 2, 3 and 8 gallon recyclable containers with a closed top. When these containers are 80% filled, the lid should be closed and sealed and prepared for transport to the Storage Room. Sharps are processed in a commercial facility and the container is disinfected and returned for reuse. Procedures for off-site disposal of medical and biological wastes are campus and school specific as follows: Boston Human Nutrition Research Center - Laboratory staff set up containers and when filled to 80% of capacity, close and seal cardboard box and transport to a Storage Room where the boxes are shipped via the waste contractor. School of Dental Medicine - Red bag waste is collected by TMC Environmental Health and Safety staff for on-site treatment via autoclave. School of Medicine - Medical and biological waste are generally treated on site with the exception of the Department of Laboratory Medicine (DLAM). Animals and animal wastes are placed in red bags and cardboard boxes for off site incineration. Grafton Red bag waste and sharps containers are stored in a Storage Room and transported to off-site disposal facilities. Medford Note: Sharps are collected in 2, 3 or 8 gallon recyclable containers. When 80% filled, these containers are transported off site by a contractor. Biology Department - Autoclave bags are treated on site using autoclaves. Hooper Health Center - Red bag are placed in cardboard boxes and sharp are collected in recyclable sharps containers.these are placed in Storage Rooms until removed by off site disposal contractors.

6 Chemistry Department - Sharps are placed in recyclable sharps containers until filled. When filled each container is removed for off site disposal by contractors. Psychology - Sharps containers are closed and sealed and placed in Storage Room for off site disposal by contractors. Biomedical Engineering - Medical and biological wastes are placed in clear autoclave bags which are contained in plastic containers. When filled, these containers are transported to the autoclave for treatment. Final disposal of treated waste is into the trash dumpster. Chemical Engineering - Medical and biological wastes are placed in clear autoclave bags which are contained in plastic containers. When filled, these containers are transported to the autoclave for treatment. Final disposal of treated waste is into the trash dumpster. Signing medical and biological waste manifests Manifests listing medical and biological wastes must accompany any off site shipment of waste. These manifests are legal documents and must be signed by authorized persons ONLY. To become authorized, you must attend a hazardous waste shipping course offered regularly by Tufts Environmental Health and Safety. Autoclave operations All individuals who are or plan to operate an autoclave to treat medical and biological waste on site must receive training covering the operation of the autoclave, the routine testing of the autoclave using biological tests (bacterial spore strips) and maintaining a bound log book of all items autoclaved. Tufts Environmental Health and Safety provides training for autoclave operators. In Massachusetts, medical and biological wastes are regulated by the Department of Public Health (105 CMR 480), the Massachusetts Water Resources Authority (Boston and Medford) and the Massachusetts plumbing code. 7.3 Radioactive Waste Refer to the Radiation Safety Manual for requirements surrounding radioactive waste.

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