Hazardous Chemical Waste Management Plan

Transcription

1 Hazardous Chemical Waste Management Plan TUFTS ENVIRONMENTAL HEALTH AND SAFETY REVISED MARCH 2015

2 HAZARDOUS CHEMICAL WASTE COMPLIANCE EXECUTIVE SUMMARY OVERVIEW Tufts University s hazardous chemical waste management program is managed by Tufts Environmental Health and Safety (TEHS) staff who assist each hazardous waste generator (i.e. laboratory, clinic, maintenance area, construction site, etc.) maintain compliance with federal and state regulations. Chemicals are essential to support research and teaching and their use and disposal is regulated by the EPA who implements the Resource Recovery and Conservation Act. RCRA regulates chemical waste from the cradle-tograve including waste generation, transportation, treatment, storage, and disposal. MassDEP is authorized by EPA to enforce more rigorous hazardous waste regulations. TEHS is a team of experts in the areas of occupational safety and health, environmental management and public and environmental health that provides training, expert advice, auditing, and investigative services to all members of the Tufts community. Your Campus EHS Manager is your first point of contact to provide assistance. WHAT IS HAZARDOUS CHEMICAL WASTE Chemical stock, solutions, etc. become a waste when the generator declares it a waste. Characteristic waste is a chemical that is any one of the following; ignitable, corrosive, reactive, toxic. ESSENTIAL COMPLIANCE RULES 1. Train anyone who will work with hazardous waste: Complete required training initially and annually thereafter on the correct handling and storing of hazardous chemical waste. 2. Prepare Waste Area: designate a waste collection area close to the point of generation: at a minimum they should include a secondary containment system/bin and sign designating the area as a SAA. 3. Accumulate Waste: collect, identify and store chemical waste in closed containers. A weekly SAA inspection must be completed. 4. Request Pickup: Waste service requests are made by staff to campus EHS managers. Requests are made as needed or based on regular waste streams. 5. Work Safely: Wear the correct protective clothing, eye, face and hand protection when handling hazardous chemical wastes and promptly report unsafe conditions and accidents to the PI/Supervisor. 6. Respond to Spills: Assure that all chemical spills are immediately reported to the Tufts Police and contained or picked up to the fullest extent possible without compromising personal safety. COMPLIANCE TASKS Compliance Tasks 1. Establish satellite accumulation area at point of generation Generator & TEHS 2. Identify and characterize wastes Generator 3. Maintain satellite accumulation area and perform weekly inspection Generator 4. Collect waste from SAA and move to main accumulation areas TEHS 5. Record waste entering the MAA on a log form TEHS 6. Complete weekly MAA inspections TEHS 7. Schedule and supervise transportation from Tufts for disposal TEHS 8. Manage documentation related to hazardous chemical waste TEHS

3 TABLE OF CONTENTS 1. Introduction Responsibilities 4 3. Identification of Hazardous Chemical Waste Storage of Hazardous Chemical Waste Disposal of Hazardous Chemical Waste Managing Spills Training Requirements Waste Minimization Universal Waste Management P age

4 1. INTRODUCTION 1.1 Purpose of the Hazardous Chemical Waste Management Plan The purpose of this plan is to describe how Tufts University maintains compliance with all laws and regulations related to the management of hazardous chemical waste. Tufts University policy is to provide for the protection of its students, faculty, staff, visitors, facilities and surrounding environment through the development and implementation of a comprehensive safety, health and environmental protection program. The Resource Conservation and Recovery Act (RCRA) of 1976 gave the United States Environmental Protection Agency (EPA) the authority to regulate the generation, transportation, treatment, storage and disposal of hazardous chemical waste. The controlling of hazardous waste from point of generation to actual disposal is commonly referred to as the cradle to grave and holds Tufts liable for the disposal of hazardous chemical waste. The Massachusetts Department of Environmental Protection (MassDEP) is authorized by EPA to enforce more rigorous hazardous waste regulations beyond RCRA. As a research driven institution and generator of hazardous chemical waste, Tufts 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, construction site etc.) is responsible for maintaining compliance per federal (40 CFR Part 260), state (310 CMR ), and Tufts Policies as outlined in this Plan. 1.2 Ownership Information This Plan covers hazardous chemical wastes generated at properties owned and/or operated by the Trustees of Tufts College primarily located at 200 Harrison Avenue and 711 Washington Street in Boston, 200 Westboro Road in North Grafton, 419 and 200 Boston Avenue in Medford, Massachusetts as well as smaller satellite properties located in Massachusetts, New Hampshire and Connecticut; and at other locations operated periodically to support University activities. 2. RESPONSIBILITIES Overall responsibility for providing for the health and safety of Tufts personnel and the protection of the environment rests with the departments that purchase and use chemicals. The responsibilities are as follows: 2.1 Department Chairs/Principal Investigators/Facilities and Laboratory Supervisors/Construction Project Managers Department chairs, principal investigators, facilities and laboratory supervisors and construction project managers are ultimately responsible for the proper management of hazardous chemical waste generated and/or stored in areas under their oversight. This responsibility includes the following activities: 1. Be aware of applicable hazardous waste regulations and procedures. 2. Establish hazardous waste accumulation areas with assistance from TEHS 3. Ensure that all personnel receive the requisite initial and annual refresher training. 4. Provide the necessary supplies for proper hazardous waste management. 5. Submit requests for transportation and disposal of wastes to the TEHS. 6. Ensure that weekly SAA self-inspections are being completed. 7. Reinforce the importance of hazardous waste management by communicating expectations, and assuring that department objectives are not in conflict with regulatory compliance. 4 P age

5 2.2 Personnel / Generators: Individuals generating (producing) hazardous wastes The most important person responsible for achieving successful waste management objectives is the individual generating hazardous chemical waste. The responsibilities of each individual are as follows: 1. Complete the approved training initially and annually thereafter on the management of hazardous chemical waste. Records of training should be maintained. 2. Oversee the collection, identification and satellite accumulation area storage of hazardous chemical waste as outlined in this plan. 3. Wear the correct personal protective equipment when handling hazardous chemical wastes. 4. Promptly report unsafe conditions and accidents to the PI/Supervisor. 5. Assure that hazardous spills are immediately 1) contained or picked up to the fullest extent possible, without compromising personal safety; 2) reported to the Tufts Police. 6. Respond to audits of satellite accumulation areas and make corrective actions. 7. Understand all requirements to maintain a safe and compliant satellite accumulation area. 8. Complete weekly SAA self-inspection. 2.3 Tufts University Environmental Health & Safety (TEHS) The responsibilities of TEHS include: 1. Act to implement emergency response procedures in a timely and compliant manner. 2. Assure that hazardous chemical waste spills are 1) contained to the fullest extent possible, without threatening personal safety; 2) reported to the Tufts Police; and 3) cleaned up using appropriate safety measures and procedures. 3. Investigate accidents/spills of hazardous waste materials and revise programs and policies to avoid repeat incidents. 4. Provide technical and regulatory advice and support to generators of hazardous chemical waste. 5. Provide guidance to senior University officials on regulations and changes in management procedures. 6. Act as the liaison with regulatory agencies. 7. Maintain documentation that each hazardous waste employee has received proper training for handling and storage of hazardous chemical waste. 8. Document and generate reports on institutional hazardous waste management, off-site movement of hazardous chemical waste and waste minimization activities. 9. Review and approve hazardous chemical waste transporters and disposal facilities, maintain records for all transporters and disposal facilities used by Tufts and verify and keep on file current certificates of insurance for all vendors. 10. Ensure waste being offered for shipment is appropriately profiled with the waste vendor and that the profile is up to date. 11. Ensure all waste packaging complies with United States Department of Transportation standards. 12. Complete and review all hazardous waste manifest information and accompanying documentation for accuracy and completeness. 13. Arrange for the transport of hazardous chemical waste from central/main accumulation areas before storage time limits are exceeded. 14. Oversee the transport of filled containers of hazardous chemical waste from satellite accumulation areas (SAA) to central/main accumulation areas within 3 days (72-hrs) of being full or unwanted. 15. Assure Central/Main Accumulation Areas are inspected weekly; audit overall hazardous waste program annually. 16. Coordinate and approve new hazardous waste accumulation areas and satellite accumulation areas. 5 P age

6 17. Receive and mail designate facility to generator notice to MassDEP within 45 days. 18. Organize and schedule laboratory cleanouts. 19. Supervise supply delivery. 2.4 Additional Sources of Information Handling chemical waste can present hazards, hence all personnel generating, handling or working around hazardous chemical waste should review the Tufts Chemical Hygiene Plan, Personal Protective Plan and Research and Safety Guide. 3. IDENTIFICATION OF HAZARDOUS CHEMICAL WASTE As a generator of many types of hazardous chemical waste, Tufts is required to determine whether or not the chemical wastes generated are hazardous. Correctly classifying waste as non-hazardous, hazardous, acutely hazardous or as a universal waste is one of the most important aspects of waste management. When handling any hazardous chemical waste it is critical to understand the hazardous materials you are using. Review Safety Data Sheets (SDS), container labels and chemical inventories to locate and classify material as non-hazardous, hazardous, or acutely hazardous. 3.1 The Identification Process In determining whether a given waste is to be regulated as hazardous waste, individuals should determine the following: Is the material a waste? The first step in the identification process is determining when a given material becomes a waste. Chemical stock, solutions, etc. become a waste when the generator declares it a waste. In addition, there are a number of other qualities which are often referred to as inherently waste-like qualities that will also dictate when a chemical becomes a waste. These are as follows: 1. Shelf-life expiration dates have been exceeded or are unknown. 2. Chemicals are stored in old, bulging, badly decomposed or damaged containers. 3. Chemicals have become obsolete because of questionable purity or discontinued usage. 4. Chemicals have undergone visible change (i.e. amber-colored perchloric acid) that would prevent the chemical from being used. Note: Extreme caution should be used when discovering an old or damaged peroxide forming, extremely toxic or volatile chemical. Immediately contact TEHS for assistance. Is the waste defined as hazardous? Once you have determined that a given material is a waste, the next step in the decision-making process is to determine whether or not that waste is defined as hazardous. 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: 6 P age

7 Federal (EPA): The EPA has established four lists (F, K, U, P) which are available on its website. Chemicals on any one of the lists are classified as a listed waste and must be managed as a hazardous chemical waste. The F list: These wastes from non-specific sources, described in 310 CMR , may be generated as a part of several different industrial applications. The K list: These wastes from specific sources, described in 310 CMR , are typically wastewaters or sludges from a particular industry or process. Wastes from this list are not common at Tufts. The U list: These are specific commercial chemical products, described in 310 CMR , that are either discarded or off-spec. Spill residues or debris from these products is also considered a hazardous waste. Many of the laboratory chemicals found at Tufts fall under this category. The P list: This list of commercial chemical products, described in 310 CMR , is similar to the U list in that it includes specific discarded or off-spec. chemical products. However, the items on the P list have been deemed acutely hazardous. As with the U list, residues or debris containing the P list substances are also considered as 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 Examples: chlorates, nitrates, peroxide, nitric acid >40% or fuming Ignitable compressed gas. Corrosive: ph 2.0 or 12.5 Examples: Strong acids and bases such as hydrochloric acid, nitric acid, ammonium hydroxide, sodium hydroxide. Reactive: Unstable. Reacts violently with water. Friction or heat may cause an explosion. A cyanide or sulfide bearing waste which, when exposed to a ph between 2.0 and 12.5, can generate toxic gases. Old bottles of picric acid and cans of ether may explode if opened or otherwise disturbed (Contact TEHS for assistance). Toxic: Waste containing concentrations equal to or greater than the maximum listed concentrations in the Toxicity Characteristic Leachate Procedure (TCLP). MAXIMUM CONCENTRATION OF CONTAMINANTS FOR TOXICITY CHARACTERISTICS EPA Contaminant Level (mg/l) EPA Contaminant Level (mg/l) D004 Arsenic 5.0 D025 p-cresol D005 Barium D026 Cresol P age

8 D006 Cadmium 1.0 D027 1, 4 Dichlorobenzene 7.5 D007 Chromium 5.0 D028 1, 2 Dichloroethane 0.5 D008 Lead 5.0 D029 1, 1 Dichloroethylene 0.7 D009 Mercury 0.2 D030 2, 4 Dinitrotoluene 0.13 D010 Selenium 1.0 D011 Silver 5.0 D031 Heptachlor D012 Endrin 0.02 D032 Hexachlorobenzene 0.13 D013 Lindane 0.4 D033 Hexachlorobutadiene 0.5 D014 Methoxychlor 10.0 D034 Hexachloroethane 3.0 D015 Toxaphene 0.5 D016 2, 4 D 10.0 D040 Trichloroethylene 0.5 D017 2, 4, 5-TP (Silvex) 1.0 D041 2, 4, 5,-Trichlorophenol D018 Benzene 0.5 D039 Tetrachloroethylene 0.7 D019 Carbon Tetrachloride 0.5 D035 Methyl ethyl ketone D020 Chlordane 0.03 D036 Nitrobenzene 2.0 D021 Chlorobenzene D037 Pentachlorophenol D022 Chloroform 6.0 D038 Pyridine 5.0 D023 o-cresol D042 2, 4, 6,-Trichlorophenol 2.0 D024 m-cresol D043 Vinyl chloride 0.2 State (MassDEP): MassDEP also regulates both Waste Oil and PCB s (waste codes MA01 and MA02, respectively). Massachusetts has been approved by EPA to manage and enforce their hazardous waste program; Massachusetts hazardous waste regulations should be referenced when determining whether or not a given waste is hazardous. Examples: Antifreeze, Photo Processing Chemicals, Refrigerants University Policy: In addition to EPA and MassDEP requirements, Tufts has elected to regulate additional chemicals. One reason for this includes wastewater discharge prohibitions. Another reason is that some chemicals present a hazard to people and the environment, yet due to limited or contradicting literature on these hazards, are not regulated at the federal or state levels. An example of this is ethidium bromide and DEA exempt pharmaceuticals. 3.2 Classifying Empty Containers Any container that previously held a hazardous chemical waste is considered a hazardous waste unless the container meets the regulatory definition of empty. The definition of empty also changes when the waste involved is an acutely toxic hazardous waste (P-list). The definitions of an empty container for listed and characteristic wastes (except acutely hazardous wastes) include: All waste has been removed using practices commonly used to remove the contents from that type of container. No more than 1 inch of residue remains on the bottom of the container or liner. When the pressure in the container has reached atmospheric pressure (compressed gas cylinders). 3.3 Identification Protocol 8 P age

9 If you have chemical waste and you are unsure how it should be classified, contact TEHS. TEHS will assist you in the determination process and/or arrange for a waste analysis. TEHS will maintain a file of each waste analysis profile and make it available during the off-site shipment and disposal of the waste. Note: Except for a limited number of situations, the onsite treatment of regulated hazardous waste that renders it non-regulated waste is prohibited without additional approval by regulatory agencies. Contact TEHS to review these protocols. 4. STORAGE OF HAZARDOUS CHEMICAL WASTE The following section is a summary of the requirements regarding the on-site accumulation and storage of hazardous wastes. There are two types of storage areas with specific requirements. The two areas are Satellite Accumulation Areas (SAA) and Central/Main Accumulation Areas (MAA). 4.1 Satellite Accumulation Area Requirements Hazardous chemical waste should be placed in a satellite accumulation area (SAA). Each point of generation (i.e. laboratory, clinic, maintenance area, etc.) must have an SAA that is under the direct supervision of trained employees. Every SAA must be inspected weekly to assure compliance with applicable regulations. Inspections are performed by personnel using and/or who has responsibilities for the area. Listed below are the requirements for managing an SAA: Satellite Accumulation Area Requirements 9 P age

10 Satellite Accumulation Area Inspection Checklist (use of this form is optional) 4.2 Central/Main Accumulation Area Requirements These areas consist of free-standing buildings, designated rooms and select flammable cabinets. The purpose of such areas to provide a secure and contained area for the interim storage of hazardous waste until it is prepared and shipped for off-site disposal. Unlike SAAs, there is no limit to the volume of waste that can be stored in an MAA, as long as applicable requirements are met. Weekly inspections must be made of the area to verify compliance with the MAA management requirements. Documentation of inspections must be completed and kept at the location for a period of three years. Inspections are performed and documented by TEHS staff or authorized contractors. All logs documenting inspections must be kept for at the areas for a period of three years. Below are requirements for managing an MAA: 10 P age

11 Main Accumulation Area Requirements (use of this form is mandatory) 11 P age

12 4.3 Protocol for Establishing Satellite Accumulation Areas TEHS is required to maintain an accurate list of waste storage areas and must review and approve any new hazardous waste accumulation area requests. All personnel must reference the following steps when determining the need for an SAA. Step 1: A formal request must be made to TEHS that includes the following information: 1. Name of supervising employee responsible for the management of the hazardous chemical waste. 2. Identification of the hazardous chemical waste that will be accumulated at the site. 3. Description of activity generating the hazardous chemical waste. 4. Purpose of the action that causes generation of hazardous chemical waste. 5. Estimated annual quantities of hazardous chemical waste that will be generated at the site. Step 2: Upon receipt of the formal request, TEHS will review the information with relevant personnel, decide whether a satellite accumulation area or a central/main accumulation area is appropriate, and inspect proposed locations. Step 3: If the new accumulation area is approved, TEHS will: 1. Provide supplies or the information on obtaining supplies. This includes hazardous chemical waste labels, secondary containment and signage; 2. Provide information on training in hazardous chemical waste handling, inspection, and recordkeeping; 3. Add the new waste accumulation areas to University records; and 4. Add the new waste accumulation area to the TEHS routine waste service. 5. DISPOSAL OF HAZARDOUS CHEMICAL WASTE Requests for chemical waste pickup are made by phone or directly to the campus EHS manager. Once a waste request is submitted, a TEHS environmental specialist will complete it during the next scheduled service to comply with RCRA three day rule. Waste pickups completed by request or a regular schedule can be made for routine wastes. Tufts contracts with firms that have expertise in transporting and disposing hazardous chemical wastes in academic settings to pick up chemical waste from labs and maintenance areas and move it to MAAs. This provides an opportunity for trained experts to answer generator questions, increases safety and compliance and allow generators to focus on research and teaching once waste is transported the SAA. All generators are encouraged but not required to participate in this program based on consultation with TEHS. All contractors must follow Tufts Contractor Hazardous Waste Operations Guide. 5.1 On-site Pickup and Disposal from Satellite Accumulation Areas 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 (shown on next page) will need to be dated full (mm/dd/yyyy) and a request for pick up submitted. Remember, waste must be transported from an SAA to an MAA within 3-days; therefore please immediately request a pick up when a container is full. When making a request for pick up please communicate the name/make-up of waste, quantity, building and room number, and principal investigator/contact name. 12 P age

13 5.2 Pick-up and Disposal 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 the department be contacted in to determine if anyone has a use for the chemical. If there is no department interest, colleagues from neighboring departments should be contacted. All chemicals that cannot be use must then meet hazardous chemical waste requirements as outlined above. Contact TEHS when a pickup of hazardous chemical waste resulting from a lab move or closure is needed. Prior to relocation, as part of Tufts Laboratory Close-out Policy, chemicals must be inspected by TEHS to assure they are properly labeled and disposed. 5.3 Disposal of Empty Containers When there is an empty container in which the previous constituent is known, the container may be reused for collection of the same waste or a compatible waste. In the event the container cannot be reused, it will have to be disposed. Place a 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. Empty gas cylinders should be returned to the vendor who supplied them to the user. 5.4 Disposal of Chemical Contaminated Animal Waste Chemical contaminated animal waste such as cages, bedding and associated equipment generated when working with animals and select chemicals will be managed as a hazardous chemical waste. Direction on which chemicals and procedures require collection will be noted on the approved Safety Plan. Personnel 13 P age

14 must notify TEHS in advance to coordinate delivery of supplies, review hazardous chemical waste requirements and to designate a satellite accumulation area. 5.5 Disposal of Controlled Substance and Drugs The Drug Enforcement Agency (DEA) requires strict protocols for the purchase, use, and disposal of controlled substances. It is imperative that disposal of controlled drugs is coordinated with TEHS by following these instructions: TEHS is not permitted to take control of controlled substances prior to disposal and does not maintain a central accumulation area. Personnel will be required to be present the day of the shipment to provide access to the drug and to confirm the drug being removed correlates with information provided on the disposal form. It is important to note that up until the point the drug is picked up for disposal it must remain under lock and key. Personnel will be asked to complete a disposal form which requires listing the type, volume and location of the drug along with the applicable license number (an active DEA license number held by the researcher is required). Submittal of a completed form will undergo review by TEHS and pending approval, be included in the next disposal shipment. Shipments are scheduled upon request and are typically made quarterly. Personnel will be notified in advance of the shipment date. Records of controlled drug shipment and disposal will be documented. Documentation will be stored with TEHS. 5.6 Off-site Shipments Tufts has liability for all hazardous chemical waste that it generates, regardless of the ultimate destination or disposal method therefore only TEHS schedules off-site disposal. TEHS evaluates and approves hazardous waste disposal contractors and disposal facilities in accordance with University policies. This will ensure that a contractor and disposal facility are properly insured, that they are handling the waste correctly, and that they are in good standing with regulatory agencies. This will also provide greater assurance that the manifests are correct, complete, and reach their proper destination. 5.7 Hazardous Waste Shipment Documentation Tufts University must comply with regulations pertaining to the hazardous waste paperwork tracking system. All hazardous waste transported off-site for treatment or disposal must be accompanied by a Hazardous Waste Manifest. The Uniform Hazardous Waste Manifest is a multiple (8) copy document that is used to track waste from generation to ultimate disposal at the treatment, storage, or disposal facility. Disposal can mean incineration, recycling, treatment, or landfill. The purpose of the manifest system is to provide a tracking mechanism for all hazards waste to assuring proper disposal. One of these requirements is to have a central storage/filing location for the manifests and associated paperwork. All manifests and land disposal restriction certificates are kept on file in each campus s TEHS Office. 14 P age

15 6. MANAGING SPILLS MassDEP requires Tufts as a Large Quantity Generator of hazardous waste on the Boston and Medford/Somerville Campuses to maintain facility specific Hazardous Waste Contingency Plans. The contingency plan s objective is minimize hazards to human health and the environment from fires, explosions, or any unplanned releases of hazardous waste or hazardous waste constituents to the air, soil, or surface water. Tufts Contingency Plan that is routinely reviewed and updated as necessary. 6.1 Spill Prevention, Control and Countermeasure (SPCC) Plan In addition to the contingency plan requirements for waste generators, there are regulations pertaining to the management of oil containing vessels and the procedures needed in the event of a release. Tufts University has a SPCC Plan that is routinely reviewed and updated as necessary. 6.2 Spill Response Each person or area generating hazardous waste is responsible for the cleanup or the notification of Tufts University Police to initiate clean-up of any spills. In the event of a spill, personnel should reference Hazardous Material Spills in the Tufts Emergency Response Guide. 7. TRAINING REQUIREMENTS 7.1 Hazardous Waste Personnel Training Both federal and state regulations require initial and annual training for those employees and students whose job description involves the handling or management of hazardous materials and wastes. Tufts Hazardous Waste Personnel Training Program is directed by Tufts Environmental Manager. The manager is trained in hazardous waste management procedures. The program includes instruction which teaches Tufts personnel hazardous waste management procedures, including contingency plan implementation, relevant to the position in which they are employed. Any new Tufts student or employee is not permitted to work in unsupervised positions until they have successfully completed Tufts Hazardous Waste Personnel Training Program. All personnel working with hazardous waste are required to receive and satisfactorily complete introductory and annual continuing training that will be given to each individual filling a position listed. Training records on current personnel shall be maintained permanently. Training records of former personnel shall be kept for at least three years from the date such personnel last worked at the facility. Personnel will be familiarized with the properties and hazardous nature of the hazardous waste at the facility by direct training by their supervisor. All personnel shall refer to Tufts Emergency Response Guide in any emergency. Tufts EHS staff shall refer to Tufts Hazardous Waste Contingency Plan. The job title for each position at Tufts related to hazardous waste management is recorded in annual laboratory safety training. A written job description for each position listed shall include the requisite skill, education, or other qualifications, and duties, of employees assigned to each such position. 15 P age

16 The form shown below serves as the hazardous waste management personnel training record. This form is filled out during new employee orientation safety training and is maintained by TEHS. 8. WASTE MINIMIZATION EPA and MassDEP regulations require waste minimization and toxic use reduction efforts. Waste minimization means reducing the amount of hazardous waste that is generated, treated, stored or disposed. Waste minimization can include any source reduction or recycling activity undertaken by a waste generator that results in either; 1) the reduction of total volume or quantity of hazardous chemical waste generated; or 2) the reduction of toxicity of the hazardous chemical waste generated, or both, as 16 P age

17 long as such reduction is consistent with the goal of minimizing present and future threats to human health and the environment. 8.1 Toxic Use Reduction Techniques Both EPA and MassDEP list desirable methods for reducing toxics in production processes. The following list of action provides the most desirable toxic use reduction techniques. The most desirable methods center on reducing or eliminating the use of toxics altogether. Substitution with a less toxic chemical. Reformulation of a product/chemical resulting in it becoming less toxic. Production units process redesign or modification. Production unit modernization resulting in less waste. Improvements in operation and maintenance procedures resulting in less waste. In-process recycling resulting in less waste. Chemical exchange. 9. UNIVERSAL WASTE MANAGMENT Universal waste consists of material that generally pose little hazard to humans and the environment and are generated by many activities or universally. Universal waste includes pesticides, batteries, mercury containing lamps/bulbs, mercury containing thermostats and mercury containing devices. While a majority of hazardous waste is generated in research laboratories, universal waste is generated in almost all areas throughout the University. Due to the low level of hazard constituents in universal waste, regulatory requirements are much less stringent than hazardous chemical waste. Tufts University is classified as a Small Quantity Generator/Handler (SQG) of universal waste. As a SQG, onsite accumulation of universal waste must not exceed 5,000 kilograms or 11,000 pounds at one time. To assure these limits are not exceeded, routine shipments and the coordination of construction and renovation projects is performed. 9.1 The Identification Process In determining whether a given waste is to be regulated as universal waste, individuals should determine the following: Is the waste defined as universal waste? Not all pesticides, batteries and lamps are universal waste, and therefore, do not all qualify as universal wastes. Such wastes may instead be managed as non-hazardous solid wastes. Please contact TEHS for guidance on determining which wastes can be managed as non-hazardous solid waste. Pesticide: A pesticide is a substance or mixture of substances intended for preventing, destroying, repelling or mitigating any pest, and any substance or mixture of substances intended for use as a plant regulator, defoliant, or desiccant. Battery: A battery is a device consisting of one or more electrically connected electrochemical cells which are designed to receive, store, and deliver electric energy. There are multiple battery types with different chemistries. Please note that alkaline batteries are not regulated as universal waste in Massachusetts. 17 P age

18 Mercury Containing Lamps/Bulb: A mercury containing lamp is any bulb or tube portion of an electric lighting device specifically designed to produce radiant energy, including, but not limited to incandescent, fluorescent, high intensity discharge, and neon lamps in which mercury is purposely introduced by the manufacturer for the operation of the lamp. Mercury Containing Thermostat: A thermostat is a temperature control device that contains metallic mercury in an ampoule attached to a bimetal sensing element. All Other Mercury Containing Devices: A mercury containing device is any electrical product or component (excluding batteries, lamps and thermostats) which contains elemental mercury that is necessary for its operation and is housed within an outer metal, glass or plastic casing. Mercurycontaining devices include, but are not limited to, thermocouples, thermometers, manometers, barometers, sphygmomanometers, electrical switches and relays, as well as certain gas flow regulators and water meters. Lamp Ballast: A ballast is a device intended to limit the amount of current in an electrical circuit. Though Polychlorinated biphenyl (PCB s) are regulated under the Toxic Substance Control Act (TSCA), 9.2 Universal Waste Accumulation Areas Tufts has established several accumulation areas for the storage of universal waste. Accumulation areas are protected from weather, secure, and clearly designated by a sign reading Universal Waste Accumulation Area. The requirements for managing universal waste can be found on the next page. 8.3 Breaks, Leaks, Spill Management Storage of universal waste at accumulation areas must be conducted in a manner that limits the risk for breaks, leaks or spills. If a lamps/bulb or mercury device breaks or a ballast, pesticide container or battery leaks, the material is no longer a universal waste and now must be managed as a chemical waste as outlined in this plan. 8.4 Training As a Small Quantity Generator/Handler of universal waste Tufts must inform all employees who handle or have responsibility for managing universal waste of proper handling and emergency procedures. Initial awareness training is provided to personnel during orientation. In addition, personnel in the Facility Services Department who handle universal waste will be provided detailed initial and annual refresher training. 18 P age

19 Universal Waste Management Requirements 19 P age