14.0 Hazardous Chemical Waste Management

Transcription

1 14.0 Hazardous Chemical Waste Management 14.1 Responsibilities. The hazardous waste management program at the UTHSCSA is designed to provide safe, effective and economical disposal of chemical waste generated by the institution in compliance with the Resource Conservation and Recovery Act (RCRA), Clean Water Act (CWA) and Clean Air Act (CAA). The following sections cover the basis for the program, the legal definitions of hazardous chemical waste and the system developed to manage hazardous waste on campus. The Environmental Health & Safety Office staff is responsible for overseeing the day to day operations of the hazardous waste program. This includes supervising the Environmental Health & Safety staff, procedures and facilities; conducting inspections of campus laboratories and work areas; and evaluating the methods used for hazardous waste management. Principal Investigators are responsible for all activities in their laboratories. They train their staff and ensure that hazardous materials are identified, collected and stored properly and that appropriate records are kept. Individual laboratory workers are responsible for the day-to-day activities in the program. They follow the directions of the principal investigator, collect waste and keep records. Facilities Management workers are responsible for proper collection and storage of the wastes created in their operations. They are also responsible for performing the necessary maintenance on systems vital to the safe operation of the waste handling facilities. The campus police provide security and ensure that access to the hazardous waste facilities is controlled. They also serve a central role in emergency situations Legislative Background and Requirements. The Resource Conservation and Recovery Act of 1976 (RCRA) and the Hazardous and Solid Waste Amendments of 1984 (HSWA) were passed by Congress to provide the legislative basis for resource and hazardous waste management in the United States. The Environmental Protection Agency (EPA) is the federal agency responsible for the administration and enforcement of RCRA. In Texas, EPA has delegated authority for administrating and enforcing RCRA regulations to the Texas Commission on Environmental Quality (TCEQ). This delegation does not exclude the EPA from interceding with its own enforcement should it find that TCEQ is not properly carrying out the implementation of the regulations. RCRA and the TCEQ regulations provide for the cradle-to-grave management of hazardous waste and regulate the operation of waste disposal operations. The regulations are designed to provide for the protection of public health and the environment. They set forth very stringent requirements for generators, transporters and processors of hazardous waste. The UTHSCSA is subject to regular inspections by TCEQ, San Antonio Water System (SAWS), and EPA to ensure that the program is operating under the conditions of the permit. As part of these inspections, waste generating areas on campus including laboratories and shops are subject to inspection by these agencies Definitions of Hazardous Waste. For regulatory purposes a hazardous chemical is one that poses a danger to human health or the environment because of physical or toxicological properties. The RCRA regulations define hazardous waste in terms of four specific hazard characteristics, ignitability, corrosivity, reactivity and toxicity. In addition, the EPA has compiled two lists, one of acutely hazardous material (the P list) and one of toxic waste (the U list). To determine if a waste is hazardous, it should be first checked against the EPA lists. P and U listed waste are indicated in lists provided at the end of this chapter. If the chemical is not on the P or U lists, it must then be examined to determine if it meets any of the criteria indicated below: 59

2 1. Ignitability a. Liquids with a flash point of less that 60 o C (140 o F). b. Solids that may ignite readily through friction, absorption of moisture or spontaneous chemical change. c. Ignitable compressed gases. d. Oxidizers. e. 2. Corrosivity any aqueous solution with a ph less than or equal to 2 or greater than or equal to 12.5 or any material that will corrode steel (1/4 per year). 3. Reactivity this includes material with any one of the following characteristics: a. Normally unstable and undergoes violent change without detonating. b. Reacts violently with water, or forms a potentially explosive mixture with water. c. Forms toxic gases, vapors or fumes when mixed with water. d. May explode upon heating, or by physical shock, or from decomposition. 4. Toxic Characteristic Leaching Procedure (TCLP) any waste which contains any of the elements or compounds in concentrations equal to or greater than the maximum concentrations given in the list for toxic characteristic constituents and regulatory levels provided at the end of this chapter. Compliance must also be maintained with San Antonio Water System (SAWS). The UTHSCSA Industrial Wastewater Permit specifies what cannot be put down the sanitary sewer. It prohibits the introduction of wastes with a ph less than 5.5 or greater than 10.5 or wastewater having any other corrosive property capable of causing damage or hazard to structures, equipment, and/or personnel of the water treatment facility. It is most important that toxic or reactive materials not be put into the sanitary sewer system. This includes materials such as sodium azide, chromic acid and perchloric acid. Many laboratory chemicals used at UTHSCSA are known to be toxic but are not on the EPA-regulated hazardous waste lists nor do they meet the other guidelines stipulated. Chemicals that are known or suspected of being toxic, carcinogenic, mutagenic or teratogenic should be handled as hazardous waste. In these cases, the principal investigator must assess the risk associated with the material and determine an acceptable disposal method. Information on toxicity can be found in the Registry of Toxic Effects of Chemical Substances (RTECS), published by the National Institute for Occupational Safety and Health (NIOSH) Pharmaceutical Waste. Some pharmaceutical items can be characterized as non- RCRA hazardous materials. RCRA listed or characteristic hazardous pharmaceutical waste cannot be disposed of through sewers, landfills, or through regulated medical waste. It must be treated as hazardous chemicals and shipped to a RCRA facility Controlled Substances. Controlled substances are regulated through the Drug Enforcement Agency (DEA) and users must register with that agency. Controlled substances cannot be treated as hazardous chemicals with respect to disposal, and therefore must not be discarded as hazardous waste. Disposal of all expired or unused controlled substances must be done through University Police. A DEA Form 41, Registrant s Inventory of Drugs Surrendered must be filled out to surrender Schedule I, II, III, IV or V controlled substances for disposal. UTPD retains all documentation for disposal of controlled substances and scheduling information. 60

3 Chemotherapy or Antineoplastic Drugs. Chemotherapeutic/antineoplastic wastes include spent or excess cytotoxic compounds, liquid and solid waste from cell cultures treated with such agents, expended personal protective equipment, and spill cleanup materials. Some examples of chemotherapy/antineoplastic agents include Adriamycin (doxorubicin), bleomycin, cisplatin, cyclophosphamide, etoposide, fluorouracil, and mitomycin C. Chemotherapeutic wastes that are mingled with regulated medical (biohazardous) wastes are classified as chemotherapeutic wastes (RCRA) and must be managed as such. Chemotherapeutic/antineoplastic wastes must be disposed separately from regulated medical or regular municipal waste according to federal and state regulations. See instructions on disposal of chemical (RCRA) hazardous waste. Solid chemotherapeutic wastes cannot be disposed in the regular trash or in biohazard bags. Liquid chemotherapeutic wastes cannot be disposed down the drain or sanitary sewer Disposal Methods Sanitary Sewer. The only acceptable amounts of hazardous waste to be put down the drain are those commonly associated with washing of laboratory glassware. Never pour any chemicals down the drains Ordinary Trash. Under no circumstances can any chemical be discarded in the regular trash. Containers that are empty and no more that 2.5 cm of residue remain on the bottom of the container can be triple rinsed, original label marked out and placed outside the laboratory for disposal by the Housekeeping staff. Empty containers of acutely hazardous chemicals must be triple rinsed with an appropriate solvent prior to disposal. The waste solvent must be disposed of as hazardous waste. An alternative is to dispose of the container as hazardous waste. Please contact the Environmental Protection Division for help in handling this waste. When work is to be done with highly toxic materials which pose a significant threat to human health or the environment contact the Environmental Health & Safety office prior to beginning the work so that appropriate disposal plan can be arranged. Disposal of hazardous chemical waste that meets any of the definitions of hazardous will be picked up by Environmental Health & Safety for disposal by incineration or other treatment. Guidelines for proper collection, labeling, and storing waste prior to pick-up are given later in this chapter. For the safety of both laboratory personnel and safety staff it is vital that the guidelines be stringently enforced and strictly followed Selection of Waste Containers and Packaging. It is the responsibility of each laboratory to provide suitable containers for the collection of its waste. If there are any questions please consult with Environmental Health & Safety to prevent costly errors. If outdated reagents are to be discarded it is appropriate to leave them in their original containers. This is especially true for solid chemicals and small quantities of toxic chemicals. In selecting a waste container, the compatibility of the waste with the container should be the primary concern. Unbreakable containers should be used whenever feasible. Large quantities of flammable liquids should be collected in 2.5 or 5 gallon safety cans. Polyethylene cans are best because of their high resistance to many types of chemicals. It is best not to fill these containers more than 2/3 full. This allows for easier transfer. The five gallon plastic jugs and metal cans in which some solvents are purchased are suitable for one time collection of waste. Use these containers only for the same solvents which they originally held. Continued re-use of these containers is discouraged because they tend to develop leaks with time. Except for safety cans purchased for the collection of solvent waste suitable for bulk disposal, waste containers cannot 61

4 be returned to the laboratories. Do not mix chemicals unless they are mixed in the experiment. Always provide secondary containment when storing chemical waste. All laboratories must adhere to the following statements regarding hazardous chemical waste: a) All containers must be tightly closed with an appropriate cap. Aluminum foil or parafilm are not acceptable caps. b) Evaporation of chemical waste inside of a chemical fume hood is not permitted. c) All containers must be clean on the outside with no evidence of spills or leaks. Dirty or leaking containers may not be picked up. d) Chemically contaminated lab waste (paper towels, diaper pads, etc.) will be treated as hazardous waste. The material should be double bagged and tightly sealed preferably with a knot and labeled appropriately. Do not put broken glass or other sharp items into plastic bags. These must be placed in a sharps container for disposal. e) Waste chemicals must be collected and stored according to compatibility. f) Liquid waste containers stored in laboratory work areas must not exceed 20 Liters (5 gallons). g) Waste quantities will be subject to the maximum container sizes and type as illustrated in the table below: Flammable Liquids Combustible Liquids Container Type IA IB IC II IIIA Glass 0.5 L 1L 4L 4L 20L Metal or approved plastic 4L 20L 20L 20L 20L Safety cans 10L 20L 20L 20L 20L Metal container (DOT) 4L 20L 20L 227L 227L Polyethylene (DOT) 4L 20L 20L 227L 227L Pressurized liquid dispensing 20L 227L 227L 227L 227L container This table is based on Table Maximum Allowable Container Capacity, NFPA 45 Standard on Fire Protection for Laboratories Using Chemicals (2011 edition) Labeling Hazardous Waste Containers. All containers must be appropriately labeled. The label should include the chemical name(s), and the approximate % of each listed component. The words hazardous waste must be placed on containers used to collect waste in the laboratories. Incorrect labels must be defaced. See figure 14-1 for an example of an acceptable label: 62

5 Figure 14-1: Hazardous Waste Labels Campus Collection System. Environmental Health & Safety oversees the collection and disposal of hazardous chemical waste on campus. Waste collected in the laboratories is transported to the appropriate storage facility. Decisions on how to best manage the waste are made based on the type and quantity of waste involved. Information is supplied on the Hazardous Waste for Disposal tags (see Figure 14-2 below) by the generating laboratory. These peel and stick tags must be affixed to all chemical waste containers at the time the chemical waste pick-up is requested. The start date shall be indicated on the tag. The start date reflects the date the request was submitted to Environmental Health & Safety. The Hazardous Waste for Disposal tags must be completely filled out and attached to each container prior to collection by Environmental Health & Safety. All chemicals present in measurable quantities must be listed, even if the substance is not a hazardous waste. For example, water, while not hazardous, is an important constituent of the waste since it may determine the flammability of the mixture. In order to be able to safely dispose of mixtures, all components must be identified. The picture below shows the areas on the tag that must filled out: Investigator Name Start Date (date of request) Lab # Chemical Name Chemical Characteristics Total Quantities Disposed % (approximate) Components Figure 14-2: New Hazardous Waste for Disposal Tags 63

6 Filling out a Chemical Waste Pickup Request. One Hazardous Waste for Disposal tag should be affixed to each container. Disposal tags provided by Environmental Health & Safety have a peel and stick backing for easy use. Submit your request for chemical waste pick-up by visiting the EH&S website, All requests should be submitted prior to Tuesdays. Step 1: Click on the Chemical Waste Pickup icon (Under Quick Links). Step 2: Fill out the requested information. A verification code (displayed on the screen) will appear. Please enter this code to continue with the request. 64

7 Step 3: Submit form. An is generated and sent to the Environmental Protection Division. Waste is collected on Tuesday for the UTHSCSA main campus, and Thursday or Friday for other satellite campuses (North Campus, Texas Research Park). All waste will be picked up from the laboratories. Do not place any chemical waste in corridors. Special pickups for laboratory cleanouts may be arranged with Environmental Health & Safety Source Reduction / Recycling Hazardous Materials. Hazardous waste generation and disposal is regulated under the Resource Conservation and Recover Act (RCRA). Under these regulations, the UT Health Science Center has a cradle to grave responsibility for all hazardous materials generated on our campuses. As a result, the university s responsibility for these materials begins from the time of delivery to our campuses, and continues even after it has been removed as waste. Disposal of these materials is costly in terms of money, time, and resources. Therefore, reducing, re-using, and recycling hazardous materials is strongly encouraged. Ideally, waste production should be reduced or eliminated. Eliminating the creation of hazardous waste in particular avoids both the management and disposal costs of waste. Reducing waste can reduce or eliminate chemical procurement costs, training requirements, staff and environmental exposure and use of personal protective equipment. When this is not practical or possible, many waste types can be reused or recycled. Environmental Health & Safety currently recycles many wastes generated from laboratory and facilities activities. Below is a list of these efforts: Mercury Mercury capture system - enables mercury to be removed from waste generated in dental clinics before it goes into the public waste system. Thermometer replacement program we will replace thermometers containing mercury with safer alternatives. Circuit boards, color monitors - small amounts of mercury are recovered from circuit boards and color monitors through the state prison system. Batteries all types of batteries are collected for proper recycling. Please submit a Chemical Waste Pick-Up request online at Oil, oil filters, antifreeze used oil from state vehicles, pumps, and other laboratory equipment. PCB ballasts and capacitors Silver recovered from fixer and developer waste and x-ray film through a silver recovery machine. Solvents materials are bulked and used as secondary fuel. Chemical Exchange Program - labs can exchange excess chemical rather than dispose of them. Please visit the Chemical Exchange Program. at the Environmental Health & Safety website. More information on this program is discussed in section 14.6 below Chemical Exchange Program. The Chemical Exchange Program is a free service provided by Environmental Health and Safety which allows laboratory personnel to remove new, unused chemicals 65

8 which are no longer in use in their lab. The advantage of this program is to reduce purchasing and disposal costs and to be good environmental stewards. This program is one of many ways in which UTHSCSA can support the Campus Green Initiative and be a strong proponent of environmental best management practices through waste minimization. Once a chemical exchange form has been submitted, it will be logged into a database for researchers and lab personnel to view. If there is a chemical you need, call for delivery. Chemical(s) will only be delivered on Tuesdays. Below are the steps to take to participate in this program: 1. Review your chemical inventory and identify any chemicals you would like to dispose. Containers must be new, never opened, contains the original packaging seal, and meets EH&S requirements listed below. 2. The Chemical Exchange Program will NOT accept the following: Controlled substance Peroxide Formers (e.g. Ethyl ether [diethyl ether], Cyclohexane, Sodium amide) P-Listed Chemicals (e.g. Sodium Azide, Osmium Tetroxide, Epinepehrine, or anything containing Arsenic or Cyanide) Pyrophorics (e.g. Phosphorus [white], tert-butyllithium, or any reactive materials) Mercury in any form Expired chemicals Open or broken sealed containers Radioactive materials Materials requiring refrigeration or special handling Rusted or deteriorated containers 3. If all requirements are met, click on the Chemical Exchange Program icon (Under Quick Links on the EHS website). 66

9 Complete the information and submit to Environmental Health & Safety. 67