A. WHAT IS HAZARDOUS CHEMICAL WASTE? In order to determine proper handling procedures and disposal, a decision must be made regarding whether the chemical waste is hazardous. Federal (EPA 40 CFR 261) and Massachusetts (DEP 310 CMR 30.100) regulations define various categories of hazardous chemical waste. Additionally, the college holds a pretreatment permit from the Town of South Hadley that regulates discharge to the sewer system. A summary of waste typically generated in academic laboratories is included in Appendix A. Regulatory lists for the following waste categories are available at the DEP website referenced below. hazardous chemicals (specific list of chemicals) - U wastes acutely hazardous chemicals - P wastes solvent waste - F wastes characteristic wastes - D wastes ignitable corrosive reactive toxic (includes metals, pesticides, and various organics) waste oil and PCBs - M wastes Faculty are responsible for determining whether laboratory waste generated is a hazardous waste. The Laboratory Hazardous Waste Determination checklist found in Appendix B can be used to evaluate laboratory waste. Departments will keep the checklist or other documentation for teaching laboratories, faculty will keep documentation for their research laboratories. Faculty will review the determination when changes in the laboratory experiment could change the classification of the waste. The checklist does not apply to evaluation of unused chemicals, or spill clean-up materials. The Chemical Hygiene Officer can assist with evaluation of these materials, as well as laboratory waste. There are other chemicals that have not been defined as hazardous by EPA or the Massachusetts DEP that should be handled using the procedure for hazardous waste. These include: * carcinogens that have not been deactivated (see Section V(i) Select Carcinogens), * reproductive toxins, e.g., ethidium bromide, that have not been deactivated (see Section V(j) Reproductive Toxins), and * acute toxins (see Section V(h)). Faculty or staff may designate other chemical wastes to be handled as hazardous based on their knowledge of the hazards of the waste. XI(a) - 1
DEP, 310 CMR 30.100 Identification and Listing of Hazardous Waste at http://www.mass.gov/dep/service/regulations/310cmr30.pdf B. DISPOSAL OF NON-HAZARDOUS CHEMICAL WASTE Once a waste determination concludes that waste is not a hazardous waste, it may be disposed of as a non-hazardous waste. Liquid wastes that are non-hazardous and water-soluble may be flushed to the sewer with copious amounts of water. Liquids, which are not water-soluble, must be solidified (absorbed) and disposed of as a solid. Non-hazardous solid waste must be labeled "non-hazardous" and can then be put in the laboratory trash. C. HAZARDOUS WASTE COLLECTION AND LAB ACCUMULATION All hazardous waste must be collected for disposal by an EPA approved method at a licensed facility. Hazardous waste should be collected in each laboratory in screw top containers, which are compatible with the waste. Each container should be labeled with a red and white "Hazardous Waste" label at the time waste is first put into the container. The label must contain: waste components; each chemical present must be identified (no chemical formulas, structures or abbreviations may be used) hazards (e.g., flammable, oxidizer, corrosive, toxic, reactive) Additional space on the label may be used to list a generic waste name such as chlorinated solvents. The "Date Full or Moved to Storage" should be completed when the container is full or, if not full but the waste is no longer being generated, when it is moved to storage. Indelible markers should be used for labeling and abbreviations cannot be used. Containers must be closed except when waste is being added. A poster describing laboratory waste collection requirements is included in Appendix C. To minimize the hazard of incompatible chemical reactions, wastes should not be mixed in the laboratory. It is also important to separate chlorinated from non-chlorinated solvents whenever possible, as non-chlorinated solvents can be processed for reuse and chlorinated solvents must be incinerated. Waste containers must be kept near the point of generation and all liquid waste must be in secondary containment. The secondary containment must provide for separation of wastes which are incompatible. The amount of waste accumulated in the laboratory at any time should be minimized. Only one bottle of a particular type of waste is allowed in the laboratory. XI(a) - 2
D. LABORATORY WASTE REMOVAL When a waste container is full or the waste will no longer be generated in the laboratory, the waste must be moved to the storage area within 3 days. Check the containers to make sure they are properly closed and that the labels are complete and legible. Request a pick-up immediately upon filling a container, or ahead of time if you anticipate filling a container in the next day or two. For waste pick-up, the Chemistry Department should contact the Director of Chemical Laboratories, all other departments should contact the Chemical Hygiene Officer. E. WASTE STORAGE AND DISPOSAL Upon receipt at the waste storage room all waste is separated and stored by hazard category. To minimize the potential for releases all waste containers are placed in trays or other secondary containers. Wastes are shipped off-site using a licensed hazardous waste transporter. All hazardous waste is taken to licensed facilities who treat, recycle, incinerate, or otherwise dispose of the materials using EPA approved methods for the particular waste type. F. DISPOSAL OF EMPTY CONTAINERS AND SHARP WASTE The hazardous waste regulations define an empty container as a container from which all hazardous chemical which can be poured has been removed and no more than one inch of chemical remains. Most empty containers can be safely and legally disposed of as laboratory trash with the exception of "Acutely Hazardous Waste" containers. Empty containers which contained P listed, acutely hazardous, chemicals should be handled as hazardous waste (Appendix XI(a)-C). As an alternate, these containers can be triple rinsed with an appropriate solvent, with the solvent disposed of as hazardous waste, the label defaced, and the container discarded in the laboratory trash. Empty containers should be placed next to (not mixed in with) laboratory trash. Broken glass and other sharp waste, except needles should be placed in cardboard containers designated for that purpose. The custodians will discard these containers in such a manner as to avoid injury. Needles must be collected in plastic needle boxes and sent off-site for incineration as biomedical waste. XI(a) - 3
G. DISPOSAL OF UNKNOWNS It is extremely difficult and costly to identify the content and hazards of unlabeled materials. As discussed in Section V(c), it is crucial that maintaining labels be a standard laboratory practice. If you do have unknowns, please contact the Chemical Hygiene Officer immediately upon their discovery. H. DISPOSAL OF EQUIPMENT All hazardous materials (e.g., mercury switches, PCB capacitors, oil) must be removed from equipment before it is discarded. The faculty member or department is responsible for removal of these materials and management of them as hazardous waste. Electronic equipment should be collected for recycling. Contact the Chemical Hygiene Officer for instructions. I. WASTE INSPECTION The Chemical Hygiene Officer inspects the waste storage area and satellite accumulation areas in the labs weekly when waste is present. Deficiencies that could result in a release of waste are corrected immediately, other deficiencies are referred to the responsible faculty member for correction. The Chemical Hygiene Officer then confirms that the correction has been completed. J. WORKING CONTAINERS DEP Working Container provisions allow more than one container of a particular waste in the laboratory for immediate use at the bench top. The Working Container must be: emptied into the satellite container in the laboratory at the end of each laboratory period or day, or when full whichever comes first closed except during active use located on an impervious surface and managed to prevent spills labeled as hazardous waste with words describing the hazard located at or near the point of generation under the control of faculty of staff responsible for the laboratory XI(a) - 4
APPENDIX XI (a) - A HAZARDOUS WASTE IDENTIFICATION XI(a) - 5
HAZARDOUS WASTE IDENTIFICATION The following is a summary of the typical wastes generated in laboratories. References cited are to the subsequent sections of this Appendix. The following categories are the regulatory definition of hazardous waste, there may well be other materials which do not meet the regulatory definition that you determine should be handled as hazardous waste because of their toxicity. For a more detailed description of waste definitions refer to: http://www.mass.gov/dep/service/regulations/310cmr30.pdf Definition of Waste To be a hazardous waste the material must first meet the definition of a waste: a waste is any material that is no longer useful and is therefore destined for disposal (or storage or treatment in lieu of disposal). Once a material becomes a waste it must be properly classified, labeled and stored. Typically, the end products of an experiment are a waste unless they are going to be used in a future experiment. Unused Chemicals Unused laboratory chemicals that are of questionable quality and can no longer be used are hazardous waste if they are listed on the "U" list) or "P" list (see web site referenced in section A), or if they meet the definition of a characteristic waste as described below. Solvents The following solvents are specifically listed as "F" waste (see web site referenced in section A). This not only applies to pure solvents but to any mixtures containing the solvents where the total quantity of listed solvents was greater than 10% by volume before use. Materials contaminated with these solvents (e.g., rags, drying agents) are included. tetrachloroethylene trichloroethylene chlorobenzene 1,1,2-trichloro-1,2,2-trifluoroethane 1,1,2-trichloroethane methylene chloride 1,1,1-trichloroethane ortho-dichlorobenzene trichlorofluoromethane
xylene ethyl acetate ethyl ether n-butyl alcohol methanol cresylic acid toluene carbon disulfide pyridine 2-ethoxyethanol acetone ethyl benzene methyl isobutyl ketone cyclohexanone cresols nitrobenzene methyl ethyl ketone isobutanol benzene 2-nitropropane Characteristic Waste When a waste is not specifically listed, it must be evaluated to determine if it meets the definitions for ignitable, corrosive, reactive, or toxic waste (see web site referenced in section A). Characteristic wastes cannot be intentionally diluted to make them nonhazardous. Ignitable Waste 1. Liquids with flash points of less than 60 o C (approx. 140 o F) with the exception of aqueous solutions of ethyl alcohol which contain less than 24 percent alcohol by volume. 2. Flammable solids. 3. Ignitable compressed gases. 4. Oxidizers. Corrosive Waste 1. Liquids with a ph less than or equal to 2 or greater than or equal to 12.5. 2. Corrodes steel as specified rate. Reactive 1. Normally unstable and undergoes violent changes. 2. Reacts violently, forms potentially explosive mixtures, or generated toxic fumes when mixed with water. 3. Cyanide or sulfide bearing wastes. 4. Explosives.
Toxic Toxic chemicals are defined based on the concentration of certain contaminants in solutions, or, for solids, the concentration in the extract when subject to a TCLP (Toxicity Characteristic Leaching Procedure). Specific concentration limits are listed in the web site referenced in section A. You should use your knowledge of the waste to determine if it may exceed the listed limits. The chemicals for which there are limits are: arsenic cadmium copper (town sewer discharge restriction) lead selenium benzene chlorobenzene o-cresol p-cresol 1,4-dichlorobenzene 1,1-dichloroethylene hexachlorobutadiene hexachlorobenzene nitrobenzene tetrachloroethylene vinyl chloride chlordane endrin lindane pentachlorophenol 2,4,5-trichlorophenol 2,4,5-TP (Silvex) barium chromium mercury silver carbon tetrachloride chloroform m-cresol cresol 1,2-dichloroethane 2,4-dinitrotoluene hexachloroethane methyl ethyl ketone pyridine trichloroethylene 2,4-D heptachlor methoxychlor toxaphene 2,4,6-trichlorophenol Oil and PCBs In Massachusetts, waste oil, including oil/water mixtures, and PCBs, concentrations greater than or equal to 50 ppm, are hazardous waste, "M" wastes (see web site referenced in section A).
Spill Clean-Up Debris Clean-up debris from a spill of any "U", "P", "F" or "M" waste is a hazardous waste. Debris from a clean-up of characteristic waste is a hazardous waste if it still meets the definitions for ignitable, corrosive, reactive or toxic wastes. Empty Containers The regulations define an empty container as a container from which all material has been removed using common practices (e.g., pouring) and contains no more than one inch of residue in the bottom. If the material is on the "P" list of acutely hazardous waste the container must also be triple rinsed. Containers meeting this "empty" definition are not hazardous waste and can be discarded in the trash. Particular precautions should be taken in disposing of empty ether cans. Once empty, the can should be allowed to evaporate in a hood overnight, it should then be rinsed several times with water and put in the trash. If is very important that empty ether cans be disposed of immediately after use to prevent the formation of peroxides. Treatment of Waste In Massachusetts, a special permit is required to treat hazardous waste. The most common example of laboratory treatment is neutralization of acids or bases. It is not acceptable to collect corrosive materials, neutralize them and discharge to the sewer. Some institutions allow neutralization as part of the experimental procedure performed by each student as an educational activity. Their interpretation is that the material is not yet a waste. The regulations do not address this interpretation. Treatment as part of the experiment can be justified based on safety concerns if the material is reactive and can be deactivated. Universal Waste Universal Waste is a special category of materials defined by the EPA that would be hazardous waste if disposed of but are defines as Universal Waste if recycled. They include batteries (lead acid, nickel/cadmium, silver, lithium, mercury) and mercury containing lamps (e.g., fluorescent light bulbs). Other Regulated Materials Antifreeze is a regulated waste and must be collected for shipment off-site. Latex paints, while not hazardous waste, can not be put in the trash in liquid form. Dried paints can be put in the regular trash. Liquid latex that can no longer be used is shipped off-site as a non-hazardous waste.
Non-Hazardous Waste There are other chemicals that have not been defined as hazardous by EPA or the Massachusetts DEP that should be handled using the procedure for hazardous waste. These include: * carcinogens that have not been deactivated (see Section V(i) Select Carcinogens), * reproductive toxins, e.g., ethidium bromide, that have not been deactivated (see Section V(j) Reproductive Toxins), and * acute toxins (see Section V(h)). Faculty or staff may designate other chemical wastes to be handled as hazardous based on their knowledge of the hazards of the waste.
APPENDIX XI (a) - B HAZARDOUS WASTE DETERMINATION
Hazardous Waste Determination Applies to waste generated as the result of chemical use. Does not apply to evaluation of unused chemicals, or spill clean-up materials. (contact Nancy Apple with questions about these items). To determine if a waste is a hazardous waste, answer the following questions. If the answer to any question is yes, then the waste is a hazardous waste. Answer all the questions for each waste to identify all the hazards associated with the waste and required on the label. Information on the characteristics (e.g., flash point) of chemicals can be found on the Material Safety Data Sheet (MSDS). Area: Faculty/Staff: Date: Waste Description: Waste Evaluation Yes/No If yes, LABEL Contains Flammable solvents (flash point < 140 o F) Flammable Exception: aqueous solutions of < 24% ethyl alcohol Contains halogenated compounds Is Reactive (unstable materials, reacts with water to form potentially explosive mixtures or toxic gases, contains cyanides or sulfides, explosives) Is an Oxidizer (materials that readily yields oxygen, or accepts electrons, to stimulate combustion) Is a Flammable Solid (capable of catching fire through friction, adsorption of moisture or spontaneous changes) Has a ph < 2 or > 12.5 Contains any of the following metals at or above the conc. in mg/l. Arsenic 5 Barium 100 Cadmium 1 Chromium 5 Copper 1 Lead 5 Mercury 0.2 Selenium 1 Silver 5 Contains any of the following pesticides at or above the conc. in mg/l Chlordane 0.03 Heptachlor 0.008 Endrin 0.02 Methoxychlor 10 Lindane 0.4 Toxaphene 0.5 Pentachlorophenol 100 2,4,5-Trichlorophenol 400.0 2,4.6-Trichlorophenol 2.0 2,4,5-TP (Silvex) 1.0 2,4 D 10 Contains any of the following organics at or above the conc. in mg/l Benzene 0.5 Carbon tetrachloride 0.5 Chlorobenzene 100 Chloroform 6 Cresol, o-, p-, m- 200 1,4-Dichlorobenzene 7.5 1,2-Dichloroethane 0.5 1,1-Dichloroethylene 0.7 2,4-Dinitrotoluene 0.13 Hexachlorobenzene 0.13 Hexachlorobutadiene 0.5 Hexachloroethane 3 Methyl ethyl ketone 200 Nitrobenzene 2 Pyridine 5 Tetrachloroethylene 0.7 Vinyl Chloride 0.2 Contains petroleum oil or polychlorinated biphenyls Toxic Reactive Oxidizer Flammable Corrosive Toxic Toxic Toxic Toxic Comments:
APPENDIX XI (a) C HAZARDOUS WASTE COLLECTION POSTER
Mount Holyoke College Hazardous Waste Collection 1. Collect waste in a screw cap container and keep the cap on except when waste is being added. 2. Do not mix incompatible materials and keep halogenated solvents separated whenever possible. 3. Put on and fill in a hazardous waste label when you start collecting the waste. Add to the label as necessary as more waste is added. A. A generic waste name (e.g. chlorinated solvents) -- optional B. Each chemical present required (no chemical formulas, structures or abbreviations) C. The hazard of the waste (flammable, oxidizer, corrosive, toxic, reactive) required -- If the waste is not flammable (flash point <140 o F), an oxidizer, corrosive (ph < 2 or > 12.5) or reactive, check toxic. D. When the container is full, write in the date (month, day, and year). A HAZARDOUS WASTE WASTE NAME: CHEMICAL CONTENT HAZARD FLAMMABLE OXIDIZER B CORROSIVE C TOXIC REACTIVE Describe Date Full or Moved to Storage: D 4. Keep all waste bottles in secondary containment. The waste containment tray should only contain waste. 5. Do not let multiple bottles of waste accumulate in the laboratory. Only one bottle of a particular type of waste is allowed. 6. Request a pick-up when the container is nearly full, or on the same day the container is filled and dated. Contact Lori Smith (email: lbsmith, ext. 3554) for pick-up. 7. For more information, contact Nancy Apple (email: neapple, ext. 2529). EH&S 6/2010