Berea College Chemical waste/product Management Guide. October 2014

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1 Berea College Chemical waste/product Management Guide October 2014

2 Chemical Waste Chemical waste is generated in many locations across campus. Chemical waste is generated in laboratories, from painting and maintenance activities, water treatment systems, printing and photo development, use of spray cans, cleaning products, the clean out of old chemical products and from the creation and study of art. How we choose to dispose of chemical waste is important not only to the environment and our health and safety, but also mishandling of chemical waste can result in violations of environmental regulations with the potential for fines. It is important that all Berea College employees understand the methods and procedures that must be followed to assure chemical waste is handled properly and in compliance with all applicable local, state and federal regulations. It is important to understand that some household waste chemicals and items that can be discarded at ones home without regulatory oversight, are regulated at the College because of how EPA (Environmental Protection Agency) defines a Hazardous Waste Generator and how discarded chemical materials are defined as hazardous. Based on the amount and type of waste generated, Berea College is regulated by EPA as a hazardous waste generator. This management guide will cover specific waste materials that are generated by campus activities and the recommended management practices required by regulation and by general safety protocols for chemical management. Questions concerning the content of this management guide can be directed to the Environmental Health and Safety Department at extension 3350 (on campus) or (off campus) The following areas will be addressed: When is a chemical waste considered hazardous Ordering Chemical products Appropriate containers for chemical waste Labeling and handling waste containers Satellite accumulation and designated storage areas for chemical waste Mixing chemical waste Segregation of chemical waste Drain disposal of chemical waste Aerosol can disposal Universal waste materials Who to contact about waste classification and pick up

3 When is a Chemical Waste Considered Hazardous The process for determining how a specific chemical waste is regulated as hazardous waste is found in the Federal Regulation 40 CFR Part 261. These regulations do not offer a simple definition that would apply to every waste material but more a protocol to follow to help make that determination. To make a correct determination requires knowledge of the process and/or activity that is generating the waste. If the waste falls within a specific defined regulated activity as outlined in 40 CFR such as those solvents and chemicals listed from non-specific sources, the waste will be considered hazardous and identified as F-code waste. If the waste is generated from a specific source as defined in 40 CFR , it will be considered a K-code hazardous waste. If the waste is a commercial chemical product that is being discarded because of age or no longer needed, it will be classified as either a P-code waste for acutely toxic materials or a U-code waste for all other discarded chemical materials. The list of regulated constituents to determine P or U code status is found in 40 CFR If the waste does not meet any of the definitions described above, the generator of the waste can use knowledge of the materials that make up the waste or use specific defined laboratory test procedures to determine if it has the following characteristics: Corrosive Hazard-The waste will have a ph reading that is equal or lower than 2 and equal to or higher than It is a liquid and can corrode steel at a rate greater than inches per year at a temperature of 55 degrees C (130 degrees F). (see ) Ignitability Hazard- (see ) it is a liquid with a flash point less than 60 degrees C (140 degree F). Also, a waste is considered ignitable if under standard temperature and pressure it is capable of causing fire through friction, absorption of moisture, spontaneous chemical change, or if it catches fire and is very difficult to extinguish. Oxidizers overlap this category because of their potential to react and cause fire. Reactive Hazard (see )-This is a broad category. The following is a guide to help determine if waste meets this definition : 1. It is normally unstable and readily undergoes violent change without detonation 2. It reacts violently with water 3. It forms potentially explosive mixtures with water or when mixed with water, it generates toxic gases, vapor, or fumes. 4. It is a cyanide or sulfide bearing chemical waste 5. It is readily capable of detonation or explosive reaction if it subjected to a strong initiating source or is heated under confinement. 6. It is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure 7. It is defined as a forbidden explosive under the Department of Transportation (DOT)regulations

4 Toxic Characteristic Hazard-(see ) This is a specific list of chemical constituents that if present at or above the defined regulatory levels of concentration (mg/l) based on the Toxicity Constituent leaching Procedure (TCLP test) the waste will be considered hazardous. A chemical waste that meets any of the characteristics listed above will carry a D-code. Please contact the Department of Environmental Health and Safety if you have any questions concerning how to classify your waste materials. Ordering Chemical and Chemical Products 1. The campus purchase policy requires any department who plans to bring a new chemical or chemical product to the work or study area to first consult with the Department of Environmental Health and Safety. Always obtain the Safety Data Sheet (SDS) for the chemical or product before introducing the chemical or chemical product to the work or study environment. Please maintain a copy of this safety information in the Departmental SDS file and send a copy to the EHS Department. Always inform employee and students of any new hazards being introduced to the work or study area before use. 2. Laboratory chemical purchases-order the smallest quantity needed for the project/experiment. This will reduce the storage risk and reduce the amount of waste that may be generated if the chemical or chemical product has to be removed from inventory. 3. When possible scale down the experiment to reduce the amount of chemical needed. 4. When possible substitute less hazardous materials in experiments to reduce risk and disposal cost. 5. Do not accept or donate chemicals or chemical products unless first approved by the Department of Environmental Health and Safety. Appropriate Containers for Chemical waste It is very important to use a container to collect hazardous waste that is compatible with the waste. Always choose a container that is in good condition and has a screw top cap, or larger drum cover that is designed to fit on the container being used. Proper fitting caps or lids will provide a complete seal to prevent spills and accidental contact while handling, storing, or shipping hazardous waste. Never use the following containers: Containers designed for food or beverage Containers with no tops or only cork or glass stoppers. They do not provide an adequate seal for the waste. Avoid metal containers unless you know it is compatible with the waste material.

5 Containers with visible flaws or weak spots, rust, or old and damaged plastic containers. If using a recycled container, make sure all old product residue is completely removed (recommend triple rinsing with appropriate cleaning solvent/soap) and old labels removed before use. When using 55 to 30 gallons containers for hazardous waste collection, make sure they have the proper DOT UN markings applicable for the material being collected and shipped. If a proper DOT container is not used, it will have to be over-packed before shipment at a significant increase in cost for shipment and disposal. The Environmental Health and Safety Department (EHS) stocks both new and recycled containers to use for laboratory waste and larger metal and poly 30 to 55 gallon containers. Please contact EHS if you need a special type of container, a larger container than what is normally stocked or an over-pack container. Labeling and handling waste containers All chemical waste containers that meet the definition of hazardous waste as discussed in an earlier section must: 1. Be clearly labeled with the exact wording Hazardous Waste (this is a regulatory requirement) For laboratory and small container waste, please use the standardized yellow waste label card, larger containers will use the preprinted Hazardous Waste Label. Labels are available from the EHS Department. 2. Put the complete chemical name (s) on the label. Do not use abbreviations, codes, or formulas. Please list all chemicals and approximate percentage of content on the container label. (the standardized yellow lab waste label has the space for this information) 3. The accumulation start date should be marked on the container if the container has been moved from a satellite collection station (see Satellite accumulation and designated storage areas) to the final storage area awaiting shipment off site. 4. EHS cannot process containers that are not labeled. Please remember unlabeled waste containers violate EPA waste regulations and may be subject to monetary penalties Satellite accumulation and designated storage areas for chemical waste Laboratories and some work areas generate waste on a daily or weekly basis during normal operation. EPA regulations allow the collection of up to 55 gallons of a specific hazardous waste at the point of generation under the control of the operator or lab manager without placing the actual date the waste started accumulating in the container. This is important because when a container is dated, it must be shipped off site within a

6 limited number of days based on the generator designation. Berea College, at this time, is a small quantity generator and is allowed to store on site for 180 days. Large quantity generators must ship their waste off site within 90 days. To maintain compliance with the regulations addressing satellite and final designated storage prior to shipment, the following requirements must be met: 1. Laboratory waste- every laboratory generating hazardous chemical waste should be stored in designated waste collection areas in the lab. Hoods can be used for this purpose if clearly designated by signage so that no other chemical activity is allowed in the hood(s). 2. All containers must be labeled Hazardous Waste with the container contents clearly identified. 3. All containers must be closed unless adding or removing waste. 4. When the container is full it should be delivered to the EHS Department, Hall Science Building or the EHS Department contacted for pick up at ext The EHS Department will complete the container marking requirements and add the date of accumulation and place it in designated final storage area for Laboratory waste 5. All chemical waste should be delivered to the EHS department at the end of each semester or research project. 6. Other areas that generate hazardous waste on campus in satellite storage areas will be monitored on a monthly basis to determine if they need to be moved to a designated storage area. The following campus locations are designated final storage areas for hazardous waste: Chemical Storage bunker-science building room 13C Hazardous Material storage building Facilities Mgt. Handling Chemical Mixtures and Waste Segregation Most all mixing of chemical waste occurs in the laboratory collection containers. While mixing of waste is not prohibited, it does present some hazards that all laboratory staff and students need to be aware of to maintain a safe work environment. The following guidelines need to be followed: 1. Never mix incompatible materials together in the same container. It can result in a reaction that could cause serious injury. 2. Always consult with your lab instructor before mixing chemical waste in the same container. 3. Always identify all chemicals present in the mixture on the waste label with an estimate of the percentage by volume of the various components. 4. When in doubt, use separate waste containers for each waste generated. 5. It is recommended that Lab Manager/ Instructors set up the waste containers in advance. The Instructors should clearly identify which containers to use for each

7 waste generated during the experiment to prevent accidental mixing of incompatible chemicals. 6. Incompatible chemical waste containers should be stored either in separate locations or at an adequate distance from each other to assure that co-mixing does not occur if the containers leaked or are accidently broken. Drain Disposal of Chemical Waste Hazardous chemicals must not be poured down sinks or drains. A hazardous chemical is any substance that can cause physical harm to health or the environment. In addition, any substance which might cause a hazardous situation if it reacts with substances or by products of sewage treatment is prohibited from drain disposal. Only chemical materials that are considered inert and water soluble can be considered for drain disposal. Aerosol can disposal Aerosol cans (even when empty) are often considered hazardous waste either because they contain a listed hazardous waste, exhibit a defined hazard characteristic or if they are still pressurized. To reduce the disposal cost and more effectively manage aerosol cans, the following collection stations have been set up around campus: 1. Technology building 2. Traylor Art building 3. Facilities Paint shop 4. Or bring cans to the EHS Department-Hall Science building Room 13 The cans are periodically collected by the EHS Department. An AEROSOLV can puncturing station is used to release the pressure and drain the contents into an approved collection container. The empty metal container can now be managed as scrap metal and recycled. Not all aerosol containers can be punctured (i.e. spray foam insulation). Please consult with the EHS Department to determine if your aerosol container can be punctured and recycled. Universal Waste Universal wastes are specific materials that EPA has selectively allowed the generator to manage under less stringent regulations as long as the generator is sending these materials for recycling and/or reclamation. The College generates the following universal waste materials: 1. Used Batteries

8 2. Fluorescent Light bulbs (broken blubs are managed as hazardous waste) To manage this type of waste under less stringent requirements the following regulations apply: 1. The battery or the container holding the battery must be labeled either as Universal Waste Battery, Waste Batteries, or Used Batteries. 2. Spent Fluorescent lamps must be labeled either as Universal Waste-Lamps, Waste Lamps, or Used Lamps. 3. Spent fluorescent lamps must be contained in boxes or other sealed containers to prevent breakage 4. Accumulation time must be documented to demonstrate the amount of time the waste has been on site either by labeling each battery or container or maintaining a log. 5. All universal waste must be shipped off site within one year of the receive date to a designated universal waste handler/recycler. Who to contact if you need help with the disposal of chemical waste Please contact the Environmental Health and Safety Department (EHS) at ext or 3246 if help is needed with waste classification, pick up, and disposal. The department is open from 8:00am until 5:00pm Monday through Friday.

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