CHAPTER 10 HAZARDOUS MATERIAL DISPOSAL

CHAPTER 10 HAZARDOUS MATERIAL DISPOSAL 1.0 HAZARDOUS MATERIAL DISPOSAL... 3 1.1 Introduction... 3 1.2 Environmental Health and Safety... 3 1.3 Department Management... 4 1.4 Staff/Students... 4 2.0 IDENTIFICATION OF REGULATED WASTES... 5 2.1 Chemical Wastes... 5 2.2 Generator Knowledge... 9 2.3 Analytical Testing... 9 2.4 Apply Generator Knowledge of the Process or Materials that Produced the Waste... 9 2.5 Biological Wastes (Medical Waste)... 10 2.6 Radioactive Waste... 12 2.7 Multi-Hazardous Waste... 12 2.8 Chemotherapy Waste... 13 2.9 RCRA Pharmaceutical Waste... 13 2.10 Disposal of Controlled Substances... 20 3.0 HAZARDOUS CHEMICAL WASTE CONTAINERS... 22 3.1 Introduction - Labeling Hazardous Chemical Containers... 22 3.2 Container Use... 23 3.3 Flammable Safety Cans / Carboys... 23 3.4 Satellite Accumulation Area... 23 4.0 DISPOSAL OF HAZARDOUS CHEMICAL WASTE... 25 4.1 Introduction... 25 4.2 Liquid Chemical Waste Streams... 25 4.3 Chemicals That Require Special Handling... 25 4.4 Outdated or "Inherently Waste-Like" Chemicals... 28 4.5 Mercury... 28 4.6 Chemicals and the Sanitary Sewer... 28 4.7 Select Agent Toxins... 29 4.8 Pressurized Cylinders... 29 4.9 Anesthetic Gas... 30 4.10 Universal Waste... 30 4.11 Used Batteries... 31 4.13 Electronic Wastes... 32 Page 1 of 46

4.14 Procedure for Chemical Pick-Ups... 32 4.15 Laboratory Clean Out... 34 5.0 DISPOSAL OF BIOHAZARDOUS MATERIAL/MEDICAL WASTE... 35 5.1 Introduction... 35 5.2 Methods... 35 5.3 Procedures for Disposing of Biohazardous Medical Waste... 35 5.4 Off Site Clinics... 36 5.5 DOT Training... 36 5.6 Contaminated Glass... 37 5.7 Non-Contaminated Glass... 37 5.8 Mixed Waste.... 38 6.0 DISPOSAL OF RADIOACTIVE MATERIAL... 39 7.0 ENVIRONMENTAL POLICY STATEMENT... 40 8.0 SOURCE REDUCTION/WASTE MINIMIZATION... 41 8.1 Introduction... 41 8.2 Source Reduction/Waste Minimization Policy... 41 8.3 Source Reduction Principles... 42 8.4 Waste Minimization Principles... 43 9.0 APPENDIX A SAMPLE ONLINE CHEMICAL SUBMITTAL REQUEST FORM... 44 10.0 REFERENCES... 45 10.0 References... 45 Page 2 of 46

CHAPTER 10 1.0 HAZARDOUS MATERIAL DISPOSAL 1.1 Introduction Environmental preservation concerns everyone but it is especially important for higher education, which is often viewed as a leader and as a resource to society. Environmental Health and Safety is designated to facilitate the safe storage, pick up, and disposal of hazardous chemical and radioactive wastes produced at the University of Texas Medical Branch (UTMB). In order to succeed, EHS needs the cooperation of all University staff and students. The disposal of hazardous material at UTMB is subject to regulation by: Environmental Protection Agency (EPA) Department of Transportation (DOT) Health and Human Services (HHS), Centers for Disease Control and Prevention (CDC) Texas Department of State Health Services (TDSHS) Texas Commission on Environmental Quality (TCEQ) City of Galveston (COG) 1.2 Environmental Health and Safety Environmental Health and Safety (EHS) will: Implement federal, state, and local regulations pertaining to the handling, storage, transportation, and disposal of hazardous waste. Prepare, submit, and maintain applicable records, reports, and manifests. Identify and advise of appropriate treatment or disposal methods for wastes. Page 3 of 46

Arrange for licensed contractors to transport and dispose of hazardous waste. Designate and audit universal waste and satellite accumulation areas on campus. Assist and encourage UTMB personnel working with processes that generate hazardous waste to examine and apply pollution prevention principles. 1.3 Department Management Principal Investigators and Healthcare Managers have the primary responsibility for ensuring that staff and students follow policies and guidelines established in this manual. 1.4 Staff/Students Laboratory Staff and Students have critical hands-on, day-to-day responsibilities that include: Wearing required personal protective equipment when handling hazardous waste (e.g. eye protection, apron, lab coat, gloves and closed-toe shoes). Managing and disposing of hazardous waste in accordance with established procedures. Seek advice, when necessary, from EHS, their supervisor or instructor about the proper handling and disposal of hazardous waste. Being involved and responsible for hazardous waste minimization. Recording proper chemical identification information on the Online Chemical Pickup Submittal request. (http://www.utmb.edu/bof/epm/input.asp) Page 4 of 46

2.0 IDENTIFICATION OF REGULATED WASTES 2.1 Chemical Wastes Chemical waste includes unused chemicals, material to be discarded from an experiment, and characteristic material (hazardous waste by definition). A regulated chemical waste is defined as a waste with strict regulations due to its quantity, concentration, or characteristics and may cause or significantly contribute to threatening human health or the environment when improperly treated, stored, transported, disposed of, or otherwise managed. The U.S. Environmental Protection Agency (EPA) and the Texas Commission on Environmental Quality (TCEQ) regulate the disposal of hazardous waste and unwanted chemicals in Texas. The purpose of this section is to assist you in designating a waste as hazardous and provide a disposal manner consistent with legal requirements. The Resource Conservation and Recovery Act (RCRA) found in the Code of Federal Regulations (40 CFR 261.20 261.24) defines the four fundamental characteristics of regulated chemical waste. 2.1.1 Ignitability Solid waste exhibits ignitability if a representative sample of the waste has any of the following properties: It is a liquid, other than an aqueous solution containing less than 24 percent alcohol by volume and has a flash point less than 60ºC (140ºF). Material is not a liquid and is capable, under standard temperature and pressure, of causing fire through friction, absorption of moisture or spontaneous chemical changes and, when ignited, burns so vigorously and persistently that it creates a hazard. Ignitable compressed gases and oxidizers. Examples of ignitable chemical waste include ethanol, ether, acetone, xylene, and most non-halogenated solvents. 2.1.2 Corrosivity Page 5 of 46

Corrosivity applies to highly acidic (ph less than, or equal to 2) or highly basic (ph greater than, or equal to 12.5) aqueous solutions. UTMB sanitary sewer system is discharged to the City of Galveston Wastewater Treatment plant; the University is regulated by city pretreatment permits. An aqueous solution that has a ph less than or equal to 2 or greater than or equal to 12.5 will be collected and managed as hazardous waste. Any aqueous solution that has a ph less than or equal to 5.0 or greater than or equal to 9.5 will need to be neutralized to (6 9) ph or collected for disposal. Examples of corrosives include hydrochloric acid and sodium hydroxide or mixtures that meet the above criteria. 2.1.3 Reactivity Chemicals that are normally unstable and readily undergoes violent change without detonating. Reacts violently with water, potentially forms explosive mixtures with water. It is a cyanide or sulfide bearing waste which, when exposed to ph conditions between 2 and 12.5, can generate toxic gases. Materials which are capable of detonation or explosive decomposition at standard temperature and pressure. Examples of reactive chemical waste include metallic sodium and picric acid. 2.1.4 Toxicity Waste is considered to exhibit the characteristic of toxicity if it is in solution in amounts greater than the regulatory levels listed in Table 1 or, if the leachate using Toxicity Characteristics Leaching Procedure (TCLP) meets or exceeds these regulatory levels. For liquids, the TCLP result is approximately the same as the actual mass concentration. 2.1.5 Listed Chemical Wastes In addition to defining the characteristics of regulated waste, RCRA also defines (or lists) certain specific waste materials as being regulated. These materials are listed in 40 CFR sections 261.31 (the F List), 261.32 (the K list), and 261.33 (the P and U lists). Should you have questions about identifying listed chemical wastes contact EHS at 747-0515. Page 6 of 46

F list addresses wastes from nonspecific sources such as spent solvents and their mixtures. An example is a spent solvent mixture which contained, before use, a total of ten percent or more (by volume) of one or more of the following non-halogenated solvents: xylene, ethyl acetate, ethyl ether, n-butyl alcohol, methanol, acetone, ethyl benzene, methyl isobutyl ketone or cyclohexanone. K list addresses wastes from specific sources and is generally not applicable to wastes generated in laboratories. P list addresses unused acutely hazardous materials (e.g., laboratory chemicals having an LD50 of less than 50 mg/kg (oral-rat). It is applicable to many surplus chemicals that are disposed of by research laboratories. Some examples are nickel tetracarbonyl, phosphine, and osmium tetroxide. U list addresses unused hazardous materials (e.g., toxic laboratory chemicals). Like the P list, this is applicable to many surplus chemicals that are disposed of by research laboratories. Some examples are pharmaceuticals, aniline, benzene, and acetone. Page 7 of 46

2.1.6 Table 1 - Maximum Concentration of Contaminants for the Toxicity Characteristic ------------------------------------------------------------------------------ EPA HW No. Contaminant CAS No. Regulatory Level (mg/l) ------------------------------------------------------------------------------ D004 Arsenic... 7440-38-2 5.0 D005 Barium... 7440-39-3 100.0 D018 Benzene... 71-43-2 0.5 D006 Cadmium... 7440-43-9 1.0 D019 Carbon tetrachloride... 56-23-5 0.5 D020 Chlordane... 57-74-9 0.03 D021 Chlorobenzene... 108-90-7 100.0 D022 Chloroform... 67-66-3 6.0 D007 Chromium... 7440-47-3 5.0 D023 o-cresol... 95-48-7 200.0 D024 m-cresol... 108-39-4 200.0 D025 p-cresol... 106-44-5 200.0 D026 Cresol... 200.0 D016 2,4-D... 94-75-7 10.0 D027 1,4-Dichlorobenzene... 106-46-7 7.5 D028 1,2-Dichloroethane... 107-06-2 0.5 D029 1,1-Dichloroethylene... 75-35-4 0.7 D030 2,4-Dinitrotoluene... 121-14-2 0.13 D012 Endrin... 72-20-8 0.02 D031 Heptachlor (epoxide). 76-44-8 0.008 D032 Hexachlorobenzene... 118-74-1 0.13 D033 Hexachlorobutadiene... 87-68-3 0.5 D034 Hexachloroethane... 67-72-1 3.0 D008 Lead... 7439-92-1 5.0 D013 Lindane... 58-89-9 0.4 D009 Mercury... 7439-97-6 0.2 D014 Methoxychlor... 72-43-5 10.0 D035 Methyl ethyl ketone... 78-93-3 200.0 D036 Nitrobenzene... 98-95-3 2.0 D037 Pentrachlorophenol... 87-86-5 100.0 D038 Pyridine... 110-86-1 \3\ 5.0 D010 Selenium... 7782-49-2 1.0 D011 Silver... 7440-22-4 5.0 D039 Tetrachloroethylene... 127-18-4 0.7 D015 Toxaphene... 8001-35-2 0.5 D040 Trichloroethylene... 79-01-6 0.5 D041 2,4,5-Trichlorophenol... 95-95-4 400.0 D042 2,4,6-Trichlorophenol... 88-06-2 2.0 D017 2,4,5-TP (Silvex)... 93-72-1 1.0 D043 Vinyl chloride... 75-01-4 0.2 ------------------------------------------------------------------------------------------------------------------------------- Page 8 of 46

2.2 Generator Knowledge Generator knowledge is a hazardous waste evaluation method commonly accepted and defined by the EPA and TCEQ to determine how wastes should be managed. A generator of hazardous chemical waste may use their knowledge of processes and materials to determine whether a waste must be managed as hazardous waste. This is referred to as using "generator" knowledge to characterize a waste. The generator is in the best position to know all the chemicals used in the process of generating the waste, as well as the quantities and concentrations of chemicals used in the process. Generators should obtain information to identify the concentrations and types of ingredients that are used in their processes. Information from safety data sheets are available from chemical manufacturers and on-line sources. 2.3 Analytical Testing Generators may also use analytical testing to classify waste as hazardous or non-hazardous. The more information that generators have about the materials used in their processes, the more information they can use to limit the amount of analytical testing and costs. 2.4 Apply Generator Knowledge of the Process or Materials that Produced the Waste Generator knowledge can be used to meet all or part of the waste analysis requirements and can be defined broadly to include "process knowledge." Process knowledge may be information on the wastes obtained from existing published or documented waste analysis data or studies conducted on hazardous wastes generated by processes similar to that which generated the waste. For example, listed wastes are identified by comparing the specific process that generated a specific waste to those processes described in the listings rather than conducting a chemical/physical analysis of the waste. If existing or historical records are used for generator knowledge, an evaluation must be performed to ensure the information reflects the current processes and materials being used and that no differences exist between the process in the documented data and waste being considered. If you use generator knowledge alone or in conjunction with sampling and analysis, you must maintain detailed documentation that clearly demonstrates the information is sufficient to identify the waste. Documenting both the generator knowledge and any analytical data is essential. Documentation used to support generator knowledge may include, but is not limited to: Safety data sheets or similar documents, A thorough process description, including data on all raw materials used in the process, and or Other forms of detailed documentation. Page 9 of 46

2.5 Biological Wastes (Medical Waste) UTMB owns and operates a medical waste processing facility; procedures are implemented under the requirements of the Medical Waste Permit MSW-2232A for a Type V solid waste processing facility, the operational staffing component and also the day-to-day operational items such as general operating structure, waste handling and tracking, general plant procedures and maintenance, and safety. Operation and maintenance of the UTMB medical waste processing facility is regulated by the TCEQ and the EPA. Accordingly, plant operators and supervisors must be trained and certified to operate the processing systems in accordance with the training and certification requirements of 40 CFR 60 Subpart Ce. Also, as defined in 30 TAC 330.5(a), this Type V MSW facility (i.e., a separate solid waste processing facility encompassing processing plants that transfer, incinerate, and/or provide other processing of solid waste) must comply with the Operational Standards for Solid Waste Processing prescribed in 30 TAC 330.201-330.249. Certain regulations enforced by the Occupational Safety and Health Administration (OSHA) also apply. Biological (medical waste) waste has been identified by the Texas Department of State Health Services (TDSHS) as waste which requires special handling to protect human health or the environment. It is further defined as a solid waste which if improperly treated or handled may serve to transmit an infectious disease(s). Biological waste is regulated by the TCEQ and the TDSHS and includes pharmaceutical, microbiological, pathological, sharps, and animal waste. 2.5.1 Pharmaceutical waste includes unused medications not deemed as hazardous by RCRA definitions: All medications dispensed to inpatient areas and clinics utilize the unit does system as a primary method of drug distribution and must be properly labeled in accordance with state and federal regulations. Pharmaceuticals and trace chemotherapy are treated by incineration. 2.5.2 Microbiological waste as listed unless deactivated: Cultures and stock of infectious agents and associated biologicals. Cultures of specimens from medical, pathology, research, and clinical laboratories. Discarded live, and attenuated vaccines. Page 10 of 46

Disposable culture dishes and devices used to transfer, inoculate, and mix cultures. Microbiological waste is treated by sterilization and maceration with final disposal in the landfill. 2.5.3 Pathological waste includes but is not limited to, human materials removed during surgery, labor and delivery, autopsy, or biopsy including: Organs, bulk human blood and body fluids removed during surgery, labor and delivery, autopsy, or biopsy (100ml or more). Products of spontaneous or induced abortion regardless of age of gestation. Laboratory specimens of blood and/or tissues after completion of examination. Pathological waste is treated by incineration. 2.5.4 Sharps wastes include, but are not limited to, the following materials, when contaminated: Hypodermic needles Hypodermic syringes with attached needles Scalpel blades Razor blades and disposable razors used in surgery, labor and delivery, or other medical procedures Glass pasteur pipettes Broken glass from laboratories 2.5.4.1 Sharps wastes also include, but are not limited to, the following material, regardless of contamination: Hypodermic needles Hypodermic syringes with attached needles Sharps are treated by sterilization and maceration with ultimate disposal in the landfill with the exception if placed inside of a yellow bag it will be treated by incineration. Page 11 of 46

2.5.5 Animal waste: when animals are intentionally exposed to pathogens, animal waste includes the following materials: Carcasses of animals Body parts Bulk whole blood, serum, plasma, and/or blood components from animals Bedding, saliva, urine and feces of animals Animal waste is treated by incineration. 2.6 Radioactive Waste Radioactive waste is considered to be any waste product that contains or is contaminated with radionuclides. Texas Regulations for Control of Radiation sets forth the guidelines for handling and disposal of such materials. Please refer to the Radiation Safety Manual and Basic Radiation Safety in the Laboratory for more information on radioactive materials and waste. 2.7 Multi-Hazardous Waste Multi-hazardous waste contains any combination of chemical, biological, or radioactive hazard. These wastes require special consideration because the treatment method for one of the hazards may be inappropriate for the treatment of another. In general, if all the hazards cannot be removed by eliminating or substituting the materials that generate the mixed waste, then the goal is to reduce the multi-hazard waste to a waste that presents a single hazard. Chemical-Radioactive (mixed) waste is defined by the Environmental Protection Agency as "wastes that contain a chemically hazardous waste component regulated under the Resource Conservation and Recovery Act and a radioactive component consisting of source, special nuclear, or byproduct material regulated under the Atomic Energy Act." Examples of laboratory mixed wastes include: Used flammable liquid scintillation cocktail. Phenol-chloroform mixtures from extraction of nucleic acids from radiolabelled cell components. Certain gel electrophoresis waste (e.g., methanol or acetic acid containing radionuclides). Uranium compounds used in electron microscopy. Page 12 of 46

Mixed waste is typically a mixture of a low-level radioactive waste and chemically hazardous waste. Disposal options for mixed waste are expensive. For many types of mixed waste, there are no management options other than indefinite storage on site. If you plan to generate multi-hazardous wastes, please contact EHS Environmental Protection Management (EPM) at ext. 70515 to review potential management options. 2.8 Chemotherapy Waste Chemotherapy is the therapeutic chemical treatment of cancer with drugs that can destroy cancer cells by impeding their growth and reproduction. These drugs often are called "antineoplastic or cytotoxic" drugs. Chemotherapy drugs are given intravenously, by injection or by mouth. All empty vials, syringes, IV bags and tubing, gloves, wipes and other material associated with routine handling, preparation, and administration of chemotherapy, are managed as trace chemotherapy waste. Trace chemotherapy items are disposed of in a yellow bag, which is designated as Regulated Medical Waste for incineration. Chemotherapy treatment, such as unused or partially used IV bags are managed as hazardous chemical waste. Chemo medicines and medicine prepared for patient care or research that has not been used (partially used IV bags) are considered listed RCRA waste. Any materials used to clean up hazardous waste spill, such as the contents of chemotherapy, must be managed as hazardous waste in designated containers for disposal through EHS. 2.9 RCRA Pharmaceutical Waste The Federal Resource Conservation and Recovery Act (RCRA) require special handling for specific waste materials, including some medication wastes. Pharmaceuticals that are regulated under the RCRA regulations are found on the P and U lists or meet the criteria used to define characteristic wastes. Hazardous pharmaceuticals are not discarded through the sanitary sewer or placed in biohazard waste containers. Environmental Protection Management (EPM) is responsible for chemical waste pick up and disposal services. On-line pick up request is available at: http://www.utmb.edu/bof/epm/input.asp 2.9.1 RCRA P-Listed Wastes There are two necessary conditions for determining acutely toxic P- listed medications: if the discarded medication contains a sole active ingredient that appears on the P list and; the Page 13 of 46

medication has not been used for its intended purpose. Also there are no concentration limits or dilution exclusions for P-listed wastes. Ingredients that serve ancillary functions, such as mobilizing or preserving the active ingredient, are not considered when determining the sole active ingredient. If saline or another solvent is added to a P-listed chemical, additional P-listed waste is generated. The phrase has not been used for its intended purpose refers to medication and their associated containers or dispensing instruments that have not been given to a patient and need to be discarded. Containers that once held P-listed wastes are treated as hazardous waste. RCRA P-Listed medications (Chemical and RCRA waste number) Arsenic trioxide, P012 Nicotine, P075 Nitroglycerine, P081 (Nitroglycerine patches, pills, tablets, capsules, creams, and inhalers are now exempted.) Phentermine (CIV), P046 Physostigmine, P204 Physostigmine salicylate, P188 Sodium Azide, P105 Strychnine, P108 Warfarin >.3%, P001 Page 14 of 46

2.9.2 RCRA U-Listed Wastes The U- list chemicals are listed for their toxicity and are similar to a P- listed waste, when a drug containing one of these chemicals is discarded, it must be managed as hazardous waste if the following two conditions apply: the discarded drug waste contains a sole active ingredient that is U-listed, and; it has not been used for its intended purpose. There is no concentration limit or dilution exclusion. The difference between the P and U listed wastes; if a container that held a U-listed waste is emptied by normal means, such as drawing liquid out with a syringe and no more than 3% by weight remains then the container itself is not considered hazardous. If both of these criteria are not met, the container itself is considered hazardous waste. RCRA U-Listed medications (Chemical and RCRA waste number) Acetone, U002 Chloral Hydrate (CIV), U304 Chlorambucil, U035 Chloroform, U044 Cyclophosphamide, U058 Daunomycin, U059 Dichlorodifluoromethane, U075 Diethylstilbestrol, U089 Formaldehyde, U122 Hexachlorophene, U132 Lindane, U129 Melphalan, U150 Mercury, U151 Mitomycin C, U010 Page 15 of 46

Paraldehyde, U182 Phenacetin, U187 Phenol, U188 Reserpine, U200 Resorcinol, U201 Saccharin, U202 Selenium sulfide, U205 Streptozotocin, U206 Trichloromonofluoromethane, U121 Uracil mustard, U237 Warfarin <.3% (Coumadin), U248 2.9.3 RCRA Characteristic Drug Formulations Medication formulations containing the following D- listed chemicals or heavy metals and exceed a regulatory level concentration are managed as hazardous waste. 2.9.3.1 Ignitable Aqueous drug formulation containing 24% or more alcohol by volume and having a flashpoint of less than 140 F must be managed as ignitable hazardous waste. Examples of ignitable classified medications, D001 Rubbing Alcohol Cleocin T Topical Solution Retin A Gel Listerine Mouthwash Erythromycin Topical Solution Potassium Permanganate (oxidizer) Silver Nitrate (oxidizer) Page 16 of 46

Collodion Based Preparations Topical Preparation Some wart-removal medications Come cough syrups Some inhalers, aerosols, and compressed gasses with flammable propellants 2.9.4 Corrosivity Generation of corrosive (includes liquids with a ph 2, or ph 12.5) pharmaceutical waste is generally limited to compounding chemicals in the pharmacy (e.g., glacial acetic acid, sodium hydroxide) 2.9.5 Reactivity Reactive wastes are unstable under "normal" conditions. They can cause explosions, toxic fumes, gases, or vapors when heated, compressed, or mixed with water. Medications are not classified as reactive. 2.9.6 Toxicity Medication formulations containing the following D-listed chemicals or heavy metals and exceed a regulatory level concentration are managed as hazardous waste. Chemical, regulatory concentration, RCRA waste number Arsenic, extract 5.0 ppm, D004 Barium, extract 100 ppm, D005 Cadmium, extract 1 ppm, D006 Chloroform, extract 6 ppm, D022 Chromium, extract 5 ppm, D007 Lead, extract 5 ppm, D008 Lindane, extract 0.4 ppm, D013 m-cresol, extract 200 ppm, D024 Mercury, extract 0.2 ppm, D009 Page 17 of 46

Selenium, extract 1 ppm, D010 Silver, extract 5 ppm, D011 Examples of RCRA Metal and Toxic medication wastes Solutions preserved with Thimerosal or other forms of mercury (such as nose-, eye-, and eardrops, contact lens solution, eye ointments, topical medications, antiseptic sprays, vaccines, antitoxins, tuberculin tests, some homeopathic remedies, and desensitization solutions) M-Cresol is used as a preservative in human insulins phenylmercuric acetate mercurochrome Silver sulfadiazine (or Silvadene) barium sulfate (unused or un-administered barium enemas) Some pills and tablets containing chromium, selenium and cadmium A container that has held a characteristic waste is defined as empty in the same manner as a U-listed waste, if all of the contents have been removed as possible through normal means and no more than 3% by weight remains. 2.9.7 Hazardous Waste Combinations This section provides guidance on how to manage combinations of hazardous waste and: Personal Protective Equipment (PPE) and spill materials Regulated Medical Waste (RMW), Sharps, and Controlled substances Page 18 of 46

2.9.7.1 Contaminated Personal Protective Equipment and Spill Materials Listed Waste PPE worn to protect employees from exposure to hazardous chemicals, materials used to perform routine cleaning or decontamination of Biological Safety Cabinets and glove boxes, and spill cleanup materials may become contaminated with hazardous waste. According to EPA, the resulting waste has the same regulatory status as the original listed component. For example, personal protective equipment such as gloves and gowns that are known to be or suspected of having been contaminated with P- or U-listed hazardous waste must be managed as hazardous waste. If PPE is routinely worn but does not appear to have come into contact with listed waste, it is acceptable for it to be discarded either as trace chemotherapy waste, if its use involved chemotherapy agents, or in the trash as solid waste. Any materials used to clean up a hazardous waste spill, such as the contents of an IV bag of Cytoxan (cyclophosphamide), must be managed as hazardous waste and cannot be discarded in a trace chemotherapy or solid waste container. For characteristic wastes, PPE and spill material that is contaminated with flammable waste or a highly corrosive waste is managed as hazardous waste. 2.9.7.2 Regulated Medical Waste Regulated Medical Waste refers to infectious or potentially infectious waste. UTMB s Medical Waste Processing Facility permit specifically refers to regulated medical wastes to be treated by incineration only in accordance with the TCEQ and UTMB Policy. Regulated Medical Waste includes pharmaceutical wastes, trace chemotherapy wastes, pathological wastes consisting of human body parts, tissues, fetuses, and organs and human anatomical remains. In the event that the chemotherapy is not administered to the patient and needs to be discarded it is classified as hazardous waste. In many cases, luerlock fittings enable the safe disconnection of the tubing or sharps from the IV bag. Disconnecting the tubing or sharps from the IV bag avoids the generation of a waste that is both RMW and hazardous waste and instead enables the management of the tubing or sharps and IV bag individually as RMW and hazardous waste, respectively. 2.9.7.3 Sharps Page 19 of 46

As a safety consideration, UTMB Pharmacy Policy requires uncapped or used needles to be discarded in the nearest Sharps container. As a rule needles shall not be discarded into a RCRA Pharmaceutical container. Any unused and unopened pharmaceuticals purchased/issued by campus pharmacy shall be returned to Pharmacy for disposal. 2.10 Disposal of Controlled Substances Expired controlled substance disposal is coordinated through the EHS office in accordance with DEA requirements for reverse distribution. Disposal logistics such as chain-of-custody and complete destruction of the material must be carried out between the DEA Registrant and an approved reverse distribution company. EHS is not permitted to take possession, handle or destroy controlled substances. EHS will facilitate the required paperwork between the DEA Registrant and disposal company which includes payment of disposal fees. DEA Registrants may submit an online request to initiate the paperwork for reverse distribution of expired controlled substance through the EHS online chemical pickup request system at: http://www.utmb.edu/bof/epm/input.asp EHS will initiate an account for reverse distribution which includes obtaining appropriate disposal forms and payment of the destruction fees. The Registrant is responsible for providing an account number with either Fed Ex or UPS for shipment of the controlled substance. EHS and the Registrant will package the controlled substance and complete shipping manifest together. The reverse distribution company will provide Proof of Destruction and/or a disposal manifest to EHS upon receipt of the controlled substance. EHS will maintain copies of the destruction documentation as well as provide copies to each Registrant. EHS will maintain all records for period of five years. In situations when orphaned or abandoned DEA substances are discovered, a collaborative effort should be is made within the department to determine who is responsible for the controlled substance disposal and associated record keeping. All non-registered personnel in possession of a controlled substance may request assistance by submitting a letter to the DEA Special Agent in Charge of the Administration in the area in which the person is located for authority and instructions to dispose such controlled substances. The Special Agent in Charge can be determined by contacting the local area DEA Office. The locations can be found at: http://www.deadiversion.usdoj.gov/ Please remember the Special Agent in Charge can only authorize disposal. The Department of Environmental Health and Safety is not permitted to take possession, handle or destroy controlled substances. Page 20 of 46

The Drug Enforcement Agency s (DEA) Office of Diversion Control in accordance to 21 CFR 1304, (www.deadiversion.usdoj.gov) regulates the disposal of DEA controlled substances. UTMB researchers follow DEA s registration process in conformance with UTMB institutional policy 10.02 Controlled Substances for Animal Research Areas. This registration grants the Principal Investigator (PI) or Department the authority to purchase and use, for research purposes, DEA controlled substances. Once a PI or Department obtains a controlled substance, they have the responsibility to track, secure, and dispose of these substances in accordance with all state and federal regulations. The Department of Pharmacy maintains a Reverse Distribution Registrant on contract services for the disposal controlled substances according to UTMB Policy 6.45 Controlled Substance Destruction. In situations when orphaned or abandoned controlled substances are discovered in a patient care area. EHS will notify Pharmacy to ensure appropriate measures are taken for final destruction. Page 21 of 46

3.0 HAZARDOUS CHEMICAL WASTE CONTAINERS 3.1 Introduction - Labeling Hazardous Chemical Containers The Texas Hazard Communication Act (THCA) requires that all hazardous chemicals be properly labeled. A Hazardous Chemical according to the THCA means an element, compound, or mixture of elements or compounds that is a physical or health hazard, or as a hazardous substance as defined in OSHA 29 CFR 1910, Subpart Z, Toxic or Hazardous Substances, or by the ACGIH, Threshold limits for Chemical Substances. Basically, any compound or chemical that is known to cause a health hazard or physical hazard is a hazardous chemical. Original (Primary) Container Labels Must Be Maintained (Normally, the original manufacturer s label in good condition will satisfy this requirement) The supervisors of every University work area where containers of hazardous chemicals are present are responsible for assuring that the manufacturer or suppliers label is not removed or defaced, unless it is illegible or inaccurate. If re-labeling is required, the label must include, at a minimum, the following items found on the material s MSDS; name of the chemical, the pertinent physical and health hazards, including the organs that would be affected and the manufacturer s name and address. Secondary Containers Must Be Labeled by Department When a chemical is transferred from its original container into another container for other than immediate use, it is called a secondary container. The supervisors of every University work area are responsible for assuring that all secondary containers are labeled with at least the name of the chemical as it appears on the MSDS and the appropriate hazard warnings. Limited Exceptions to Labeling Requirement A container may be unlabeled if it is a portable container intended for the immediate use (same work shift) of the employee who transferred the chemical from a properly labeled container. There are no other exceptions under the THCA. Reuse of Empty Chemical Containers Empty chemical containers are considered to be hazardous if they are contaminated with any of the hazardous chemical that they previously contained. BEFORE putting containers in the trash: Triple rinse container with detergent, Page 22 of 46

Collect the rinsate for appropriate chemical disposal, and Obliterate the labels. 3.2 Container Use If you plan to use an empty container to collect hazardous chemical waste for disposal, ensure: The chemical or mixture is compatible with the former contents of the container and the actual container material. All collection vessels must have leak-proof seals with usable closures. Deface the original container label and replace with appropriate content label. If container is used to collect hazardous chemical waste the words Hazardous Waste need to be used with the chemical identity. Hazardous chemical waste containers must be kept closed at all times except when in direct use. 3.3 Flammable Safety Cans / Carboys In some cases, EPM will provide flammable safety cans for collecting hazardous solvent wastes. Note: All waste containers will be maintained closed except when in direct use to reduce volatile vapor exposure and meet state and federal regulation for safe handling of hazardous wastes. 3.4 Satellite Accumulation Area All the laboratories and other facilities that generate hazardous waste are considered to be satellite accumulation areas. Satellite accumulation area is defined as any area, system or structure being used to store and accumulate hazardous waste temporarily. The hazardous waste generator is responsible for abiding by the following rules: Page 23 of 46

A satellite accumulation area must be in close proximity of the waste generation location. Removing the waste to another laboratory or across the hall for accumulation is unacceptable. The waste container should always be closed except when waste is actually being poured into container. To protect from spills or leaks from the waste container, the use of secondary containment is recommended. Labeling Hazardous waste containers need to be properly identified. The label should be affixed on the container and be clearly visible with the following items: List the chemical constituents and composition (including water). Must be labeled with the words Hazardous Waste. If the waste is being collected in a used bottle or container, ensure the original label is defaced. Limits on Time and Quantity Hazardous waste may be accumulated indefinitely in satellite accumulation up to 55 gallons or 1 quart of acutely toxic hazardous waste. Once the limits (55 gallons hazardous waste or 1 quart acutely hazardous waste) are met the laboratory staff is required to have the waste removed by EPM within 3 days. Generally, laboratories do not generate large volumes as described above; it is recommended that once a container (e.g. 4 Liter bottle) is full the generator should schedule a chemical pickup on-line at http://www.utmb.edu/bof/epm/default.asp. Page 24 of 46

4.0 DISPOSAL OF HAZARDOUS CHEMICAL WASTE 4.1 Introduction It is important to provide accurate information when submitting on-line request for chemical wastes. The following section gives an overview on how to segregate and manage chemical waste streams. 4.2 Liquid Chemical Waste Streams When collecting liquid hazardous chemical streams for disposal, make sure that any chemicals to be mixed are compatible. The chemicals are segregated into separate containers for the following categories: Halogenated solvents Non- halogenated solvents Aqueous acid solutions Aqueous basic solutions A record is kept of the volume and contents of each addition to the container. The complete mixture including water is accounted for in solution. When the container is to be disposed of, the volume and concentrations of each chemical are totaled. Submit an Online Chemical Pickup Request Form: http://www.utmb.edu/bof/epm/default.asp An example of the online Chemical Transfer Form is in Appendix A of this chapter. 4.3 Chemicals That Require Special Handling Chemicals that require special handling include peroxide forming compounds, shock sensitive compounds, reactive materials, and strong oxidizing/reducing agents. Peroxide forming compounds are sensitive to light and heat, this class of compounds reacts with air and light to form unstable peroxides. Once opened, stocks of these peroxide forming compounds should be used within the specified time frame. It is essential to indicate the date at the time of opening and dispose of within an acceptable period of time. These compounds can be tested for the presence of peroxides easily with inexpensive test strips. Table 2 lists shock -sensitive compounds from Prudent Practices in the Laboratory: Handling and Disposal of Chemicals by the National Academy of Sciences, Washington, D.C. 1995. Page 25 of 46

Reactive and strong oxidizing/reducing agents may cause severe reactions when mixed or stored with incompatible materials. These compounds must be handled carefully. Examples of reactive materials include anhydrous aluminum chloride, cyanide compounds, and metal hydrides. Strong oxidizing compounds include perchloric acid, metallic chlorates and nitrates. Strong reducing agents include metallic sulfides and sodium hydride. Page 26 of 46

4.3.1 Table 2 Shock-Sensitive Compounds Classes of Chemicals That Can Form Peroxides Upon Aging Class I: Unsaturated materials, especially those of low molecular weight, may polymerize violently and hazardously due to peroxide initiation. Acrylic acid Tetrafluoroethylene * Acrylonitrile Vinyl acetate Butadiene * Vinyl acetylene Chlorobutadiene (chloroprene) * Vinyl chloride Chlorotrifluoroethylene Vinyl pyridine Methyl methacrylate Vinylidene chloride Styrene Discard at 12 Months Class II: The following chemicals are a peroxide hazard upon concentration (distillation/evaporation). A test for peroxide should be performed if concentration is intended or suspected. Acetal Dioxane (p-dioxane) Cumene Ethylene glycol dimethyl ether (glyme) Cyclohexene Furan Cyclooctene Methyl acetylene Cyclopentene Methyl cyclopentane Diacetylene Methyl-i-butyl ketone Dicyclopentadiene Tetrahydrofuran Diethylene glycol dimethyl ether Tetrahydronaphthalene Diethyl ether Vinyl ethers Discard at 12 Months Class III: Peroxides derived from the following compounds may explode without concentration. Organic Inorganic Divinyl ether Potassium metal Divinyl acetylene Potassium amide Isopropyl ether Sodium amide (sodamide) Vinylidene chloride Discard at 3 Months * When stored as a liquid, the peroxide-forming potential increases and the chemical should then be considered a Class III. Page 27 of 46

4.4 Outdated or "Inherently Waste-Like" Chemicals Chemical containers with obvious signs of degradation such as split caps, accumulation of crystal deposits on the inside or outside of bottles or on shelf surfaces in the storage area; formation of two phases or change in physical state or formation of crystalline structures within liquids, are considered by the U.S. EPA as being inherently waste-like, and should be addressed immediately by discarding the chemical. Some changes are subtle, and not readily noticeable. Become familiar with the chemical and its physical and chemical hazards before using or storing it, and examine your stock occasionally. Chemicals with no labels, abbreviations that are not commonly recognized are unacceptable and should be addressed immediately. 4.5 Mercury Metallic mercury may be found in manometers, thermometers, switches, thermostats, and pressure equipment. Liquid mercury is considered to be hazardous, and cannot be discarded in regular trash. When equipment containing mercury is broken, place contaminated items in a plastic bag and schedule a chemical pickup online. If mercury is spilled, contact EHS at 772-21781 for spill cleanup. 4.5.1 Hazardous Chemical Spill The specific procedures for cleaning up chemical spills are explained in Chapter 8 Chemical Safety. The yellow card attached to all UTMB badges also contains the emergency guidelines to follow in case of a hazardous chemical spill. 4.6 Chemicals and the Sanitary Sewer Campus interior drains are connected to the sanitary sewer system, and their effluent drains to the City of Galveston Municipal Wastewater Treatment Plant. Generally disposal of chemicals down the drain is prohibited by Federal, State, and local laws and regulations. The range of substances that can be considered hazardous waste is enormous, if you are unsure how to manage a chemical contact EHS at ext. 70515. There are some chemicals that are water-soluble, moderate ph, of low toxicity, and may be safely discarded in the sanitary sewer. Materials appropriate for sewer disposal in limited quantities have to be easily biodegradable or amenable to treatment by the waste water treatment process. Sanitary sewer disposal activities must have prior approval from EHS in the form of documentation otherwise the action of drain disposal of chemical waste is considered illegal. Materials appropriate for sewer disposal in limited quantities must meet the following criteria: Page 28 of 46

Simple salt solutions of low toxicity inorganic substances with a ph range between 6 to 9, Non pathological biological compounds and cellular constituents such as proteins, nucleic acids, carbohydrates, sugars, amino acids, surfactants and many metabolic intermediates, and Other compounds include soluble salt combinations of low toxicity and dilute (less than 10%) aqueous solutions of low molecular weight biodegradable organic chemicals such as alcohols, aldehydes, and carboxylic acids. Do not put the following hazardous materials down a drain: Solutions of ph less than 5.0 or greater than 9.5. Solutions containing heavy metals [e.g., lead, mercury, etc.]. Flammable liquids, halogenated solutions. Aqueous solutions containing 24 percent or more alcohol and having a flash point of less than 60 degrees Celsius (140 degrees Fahrenheit). Anything not miscible with water. Pathogenic tissue specimens (deactivation procedures are listed in Biological Safety section of the Safety Manual), contact EHS prior to disposal to find out if the material is suitable for drain disposal). When in doubt, call Environmental Protection Management at extension 70515. 4.7 Select Agent Toxins Use of select agent toxins require special procedures developed as part of the laboratory high risk plans which are approved through the Chemical Safety Committee. There is more information available in the Chemical Safety Chapter 8. 4.8 Pressurized Cylinders Aerosol containers may be disposed of in regular trash but not allowed as medical waste. Submit Online Chemical Pickup Request disposal of ethylene oxide cartridges; thin walled cartridges, lecture bottles, and disposable propane cylinders. Page 29 of 46

4.9 Anesthetic Gas Commonly used anesthetic gases: 4.9.1 Halogenated solvent Isoflurane (most frequently used anesthetic) Nonflammable liquid at room temperature; when vaporized is 5 to 7 times heavier than air and easily distinguished by its pungent odor. Halothane No longer being manufactured in the U.S. Desflurane Sevoflurane Enflurane 4.9.2 Non-halogenated solvent Nitrous oxide Nonflammable gas at room temperature; colorless, sweet tasting, and heavier than air. Ether Colorless and highly flammable liquid with a low boiling point and a characteristic odor. Use of ether as an anesthetic is not approved on campus. 4.9.3 Disposal Method Saturated canisters (i.e., F/Air, Sodalime or other carbon filters) used in anesthetic gas scavenging systems and charcoal filters placed in laboratory vacuum lines are considered hazardous chemical waste. Place saturated canister into a clear plastic bag with a label anesthetic gas filter hazardous waste. Go online to schedule a chemical pick-up: http://www.utmb.edu/bof/epm/input.asp Because of the volatility of liquid anesthetics, rapid removal by suctioning is the preferred method for cleaning up spills. If absorbed, the waste material should be placed in a clear plastic bag and sealed, properly labeled, and disposed of with other chemical wastes through EPM. Empty anesthetic bottles are not considered regulated waste and may be discarded with ordinary trash. Empty chemical container labels should be obliterated. If you have questions concerning types of chemical waste, please contact EPM at extension 70515. 4.10 Universal Waste Page 30 of 46

Universal wastes are certain hazardous wastes that are so common that the possession is widespread. It is extremely difficult to regulate them as hazardous waste. These substances have a separate set of rules to follow, but are much less complicated. The regulation for universal waste can be found in 40 CFR 273. The following listed substances are considered to be universal waste. Batteries Pesticides Paint and paint related waste Mercury-containing equipment Mercury-containing Fluorescent Lamps It is very important to remember that universal waste is still harmful to the environment. Care must be taken to dispose of them properly. They cannot be thrown away in the trash dumpster. 4.11 Used Batteries Used batteries are commonly generated throughout UTMB. Please follow the procedures below when batteries are collected: Used batteries are to be collected separately by category with terminal ends taped to prevent contact. Collection bins may be a plastic container or cardboard box for each of the following categories: Nickel Cadmium - battery terminals must be taped. (Examples: rechargeable power tool, radio, and camera batteries) Nickel Metal Halide - battery terminals must be taped. (Examples: rechargeable power tool, radio, and camera batteries) Lithium - battery terminals must be taped. (Examples: cell phone, watch, and medical monitoring equipment batteries) Lead Acid - battery terminals must be taped. (Examples: vehicle and computer batteries) Alkaline - battery terminals do not have to be taped. (Examples: pagers and medical equipment batteries) Label all battery collection boxes by specific category, for example "Universal Waste Used Lithium Batteries and include the start date when collection began. Once container is full, please schedule an online chemical pick up request at http://www.utmb.edu/bof/epm/input.asp. 4.12 Used Oil Used oil and filters are collected in the universal waste areas; however they are not considered a universal waste. Oil spill prevention regulations are part of the Clean Water Act and require UTMB to have a plan in Page 31 of 46

place identifying responsibilities and control measures to minimize the possibility of spills or releases to Galveston Bay. Used oil containers that are 42 gallons or greater require secondary containment for storage. 4.13 Electronic Wastes Electronic devices such as computers, cell phones, fax machines, wireless devices, and other electronics contain heavy metals such as lead, mercury, and cadmium. These items should be handled in an environmentally responsible manner. UTMB has an asset-management program in place for capital electronic items. The information below is provided for how electronic wastes are managed. 1. Any item with a UTMB identification tag must be returned to Inventory through Material Management Warehouse Useable computers are donated to other state entities 2. Broken computers and other electrical equipment are collected by Materials Management Warehouse staff for recycling http://www.utmb.edu/logistics/surplus/default.asp 3. If your Area generates e-waste and is not managed in the above processes, please collect for recycle through EHS 4. Schedule e-waste pick up requests on-line at: http://www.utmb.edu/bof/epm/default.asp click on the Chemical Waste Pick-up Request and follow the prompts for information needed on the form. 4.14 Procedure for Chemical Pick-Ups Chemical pick-up arrangements are made on-line: http://www.utmb.edu/bof/epm/input.asp Once you complete the required information, this web based form will be submitted to the Environmental Protection Management program and the request will be processed into the next pick-up day. Chemical pick-up days are Wednesday and Friday of each week. Radioactive pick-up days are Tuesday and Thursday. Once submitted, you will receive electronic confirmation of your request. You must have a Radioactive form filled out Page 32 of 46

for each item to be picked up (e.g. one form for <300 day dry solids; on form for stock vials; you may have up to eight stock vials on one form) and signed with an authorized signature for a Radioactive pick up. Page 33 of 46

1. 2. 3. Online Waste Pick-up Request Instructions Complete the required contact information (name, room number, phone number, and building name) Comments section may be used for special request (i.e., return safety can) Chemical pick-ups of <20 items should be entered as a Lab clean out request. At least one item must be listed using TAB key to move between fields. List the chemical identity of the material. No abbreviations or trademark names unless the MSDS is provided. 4. Chemical Waste For chemical mixtures in one container: - List all chemicals in the mixture by percent - List the solvent if a solution including water - List the total quantity of the mixture Radioactive Waste For chemical mixtures in one container: - # Bag D s - # SV - # LS Bags 5. Each chemical container must be labeled to identify the contents 6. All chemicals must be in a tight, sealed container, no glass stopper or bottles, etc. 7. 8. A radioactive form must be filled out for each box to be picked up and be signed by an authorized person. The person completing the pick-up request is legally responsible for the accuracy of the information provided. 4.15 Laboratory Clean Out A laboratory clean out can occur when relocating a laboratory, closing a laboratory permanently or simply down sizing the chemical inventory. Contact EHS prior to clean out begins for assistance in the process. A two-week or more notice, if possible, would be appreciated. Specific instructions for relocation and closure of laboratories can be found in the Chemical Safety Chapter 8 and the Biological Safety Chapter 9 of this manual. Off Site Clinics: EHS is responsible for providing assistance to off site clinics personnel with disposal arrangements for hazardous chemicals. The Clinics will be responsible for ensuring hazardous materials are stored appropriately, coordinating disposal arrangements through EHS, and assuming the disposal costs. Page 34 of 46

5.0 DISPOSAL OF BIOHAZARDOUS MATERIAL/MEDICAL WASTE 5.1 Introduction Biohazardous waste, just like chemical waste, can be harmful to the environment and needs to be properly disposed of. Most of the biohazardous waste goes to the on-site autoclave treatment. It is important to follow the proper method and guidelines for the disposal of medical waste. 5.2 Methods Biologically hazardous material/medical waste can be disposed of in one of three ways: Chemical disinfection Autoclave (Steam Sterilization) Incineration 5.3 Procedures for Disposing of Biohazardous Medical Waste 5.3.1 Chemical Disinfection Chemical disinfection of liquid waste is accomplished by the addition of a disinfecting agent such as bleach to the liquid in the proper proportions. Solutions must stand a minimum time per protocol/sop. Once disinfected, the liquid may be poured into the sanitary sewer system followed by a water rinse. Please note that the liquid cannot have been mixed with other hazardous material that is not suitable for drain disposal. 5.3.2 Liquid Infectious Materials Regulated wastes (liquid or semi-liquid blood or other potentially infectious liquids) must be placed in closeable containers i.e., buckets, bins, jars, in the appropriate color coded biohazard bag. If the bag contains free liquids (bulk blood and/or bodily fluids >20ml) absorbent material (diapers, litter, etc.) must be added to absorb the free liquids. Absorbent material must be capable of absorbing 150% of the liquid volume placed in the bag per Texas medical waste rules. Use of excessive amounts of heavy litter is discouraged as it may cause tearing of bags and leakage. Page 35 of 46

5.3.3 Autoclave (Red Bags) Medical waste collected in Red Bags is treated by steam sterilization and maceration with final disposal in the landfill. Waste designated for steam sterilization include medical wastes TCEQ describes as blood and blood products, microbiological wastes (i.e., cultures and vaccines), body fluids, sharps, other soiled disposable medical paraphernalia (i.e., gowns, gloves, bandages, tubes, bags, etc.). These wastes are disposed of in a Red Bag with the exception of sharps which are required to be disposed of in an approved hard plastic red sharps container. Sharps containers are red leak proof containers. 5.3.4 Steam Sterilization (Research laboratory) Biohazardous waste to be steam sterilized in the laboratory must be placed in appropriate autoclave bags. Autoclave bags must not be red. Orange or clear autoclave bags are appropriate. Once sterilized the bag must state non-infectious or treated waste. Bags are placed into the regular trash for disposal. 5.3.5 Incineration (Yellow Bags) Yellow bags identify medical waste that will be treated by incineration. Waste streams designated for incineration include trace amounts of chemotherapy medications (e.g., empty IV bags, gloves, tubing, no common wipes), pharmaceutical wastes, and pathological wastes consisting of animal and human body parts, tissues, fetuses, organs and human anatomical remains. Medical waste incineration is identified by specific regulations and must have prior EHS approval. Sharps containers are yellow leak proof containers. Environmental Services (housekeeping staff) are responsible for picking up closed biohazard (medical waste) boxes generated from laboratory areas and on the patient care unit that are ready for disposal. Medical waste includes both red and yellow bag wastes, the waste are segregated at the Medical Waste Processing Facility. Boxes are transported to designated docks for pick up by personnel who manage medical waste. Patient care has area specific standard procedures for the collection and removal of medical waste. 5.4 Off Site Clinics Off Site Clinics personnel are responsible for medical waste disposal arrangements available through the UTMB Medical Waste Service Center. UTMB patient care staff is responsible for ensuring medical wastes are segregated and stored according to UTMB policy. Clinics are to arrange for medical waste transportation and disposal services through the UTMB Office of the Sustainability Manager at (409) 747-2948. Contact EHS for disposal questions or issues with medical waste. 5.5 DOT Training Page 36 of 46

U.S. Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA) amended the Hazardous Materials Regulations (HMR) (Miscellaneous Amendments, effective May 10, 2013) to require employers who handle hazardous materials to make hazardous material employee training records available upon request to an authorized official of the DOT or an entity explicitly granted authority to enforce the HMR. UTMB Clinic representative is responsible for providing a signature on the medical waste shipping manifest. By signing this documentation, the employee is certifying that the medical waste is packaged properly and is ready for transportation in commerce. This training will be required for new employees replacing clinic personnel with responsibility for signing medical waste shipping papers. Refresher training is required every three years. Contact EHS for information regarding Offsite Clinic DOT for Shipping Medical Waste online training assignment. 5.6 Contaminated Glass All biologically or chemically contaminated broken glass, pasteur pipettes, and capillary tubes shall be placed in a sharps container. Sharps containers are placed inside a red bag for disposal in a cardboard biohazard box. 5.7 Non-Contaminated Glass All decontaminated (autoclaved, chemically disinfected) broken glass and slides shall be placed into an unbreakable, leak proof, primary container and labeled BROKEN GLASS before being placed into the regular trash. 5.8 Mixed Waste Mixed waste requires more attention; all the procedural guidelines for hazardous waste apply following either a deactivation or deregulation criteria. Mixed waste labels must contain all the constituents of the waste: Page 37 of 46

5.8.1 Biological-Chemical For a mixed waste that contains both biological and chemical waste, the biological agents must first be deactivated using disinfection processes or autoclaving tissues and removed (nothing to remain). The chemical left will then be treated as chemical waste and disposed of according to the guideline. 5.8.2 Chemical-Radioactive For a mixed waste that contains both chemical and radioactive waste, the radioactivity must first be determined. If the radionuclides are not completely spent, they need to be deregulated. After the radionuclides have been deregulated, the chemical waste is handled according to the chemical waste disposal procedures. 5.8.3 Biological-Radioactive For a mixed waste that contains both biological and radioactive waste, it has to be disinfected or autoclaved to destroy the biological waste. The waste then must be deregulated over the time required to fit the radioactive waste criteria and be disposed of accordingly. 5.8.4 Biological-Chemical-Radioactive - This kind of waste is somewhat rare. But to dispose of it, the waste must first be disinfected or autoclaved to destroy the biological agents. It must then be deregulated to take care of the radioactive waste. After the waste has gone through these processes, it will be treated as a chemical waste and disposed of accordingly. Page 38 of 46

6.0 DISPOSAL OF RADIOACTIVE MATERIAL 6.0 Disposal of Radioactive Material See the UTMB Radiation Safety Manual for radioactive material disposal instructions. Page 39 of 46

7.0 ENVIRONMENTAL POLICY STATEMENT 7.0 Environmental Policy Statement The mission of UTMB is to provide scholarly teaching, innovative scientific investigation and state of the art patient care in a learning environment to better the health of society. Proper management of the environmental impacts of our operations and facilities is essential to support our mission. UTMB is environmentally conscientious, operating in a fashion that minimizes negative impact on the environment and natural resources. The Environmental Management System is a continuous quality improvement tool directed towards UTMB s activities to reduce significant impacts on the environment and execute efficiencies as needed. Our Environmental Management System is designed to meet the following goals: Ensure compliance by meeting or exceeding all applicable environmental requirements; Strive to continuously improve environmental performance to achieve the goals set out in the UTMB Source Reduction/Waste Minimization Plan; Establish processes to consider environmental factors with planning, purchasing and operating decisions to reduce environmental impact; and Maintain a positive and proactive role in communicating with the surrounding community regarding our environmental activities and performance. Page 40 of 46

8.0 SOURCE REDUCTION/WASTE MINIMIZATION 8.1 Introduction UTMB personnel working with processes that generate hazardous chemicals or wastes are encouraged to examine and apply pollution prevention principles. These concepts are based on efficient use of resources. Source reduction is any practice that reduces the amount of waste or any hazardous substance by either replacing it with non-hazardous substances or refraining from using the hazardous material. Waste minimization is any practice that reduces the amount of hazardous wastes entering the waste stream. Texas state law requires those industries that generate hazardous waste prepare a Source Reduction/Waste Minimization Plan with annual progress reports. Hazardous materials regulatory compliance and disposal responsibilities are within the purview of EHS and the university community that uses the hazardous materials. 8.2 Source Reduction/Waste Minimization Policy Scope This policy applies to all UTMB faculty, employees, and students who purchase and use hazardous chemicals. Purpose The purpose of this Policy is to reduce the volume of hazardous materials purchased and minimize the volume of hazardous waste generated. Program Reduce to a minimum the number of different hazardous material products that serve the same function. Buy chemicals in container sizes appropriate to the actual use or the amount that would be used within a oneyear period. Substitute less hazardous chemicals as an alternative whenever possible. Reuse and recycle chemical resources when possible. Page 41 of 46

Neutralize elemental acid and base chemical waste when applicable, ph range for sanitary sewer drain disposal is 6-9. Include final steps in experiment to destroy or inactivate hazardous substances when possible or when required. Reduce volume of hazardous material used (e.g. smaller conicles). 8.3 Source Reduction Principles Source reduction principles are practices that reduce the amount of a hazardous chemical before it is declared a waste product. Material Management Good material management includes: Better housekeeping Regular inventory of chemicals Centralized purchasing Purchasing only quantities needed Centralized waste management Good waste segregation Laboratory Practices Good Laboratory Practices (GLP) includes: Procedural changes Page 42 of 46

Process modification Scaling down experiments (microscale) Solid phase extraction s (instead of column chromatography) Review techniques for waste generated Substitution Substitution includes: Use of citrus based solvents in place of xylene Use resins for DNA preparation Use biodegradable scintillation cocktail Zinc compounds in place of mercury Replace mercury containing devices with alcohol or electronic devices 8.4 Waste Minimization Principles Research and teaching activities can result in the generation of relatively small quantities of a wide variety of waste and surplus chemicals. The small-scale treatment and deactivation of chemical products and by-products as part of the experimental plan (i.e., as part of the routine procedure) is one approach that can be used to address the problem of waste minimization at the laboratory level. Excellent example texts that have been published include: 1. George Lunn and Eric Sansone. 1994. Destruction of Hazardous Chemicals in the Laboratory, 2nd Edition. Frederick, Maryland: Wiley-Interscience Publications. 2. Margaret A. Armour. 1991. Hazardous Laboratory Chemicals A Disposal Guide. Edmonton, Alberta, Canada: CRC Press. Page 43 of 46

9.0 APPENDIX A SAMPLE ONLINE CHEMICAL SUBMITTAL REQUEST FORM 9.0 Appendix A Sample Online Chemical Submittal Request Form Page 44 of 46

10.0 REFERENCES 10.0 References Industrial Waste Pre-Treatment Permit. City of Galveston Ordinance #0000100, #0000101, #0000104, #0000106, #000109 United States. Office of Federal Register National Archives and Records Administration. Hazardous Waste Regulations. Title 40 Code of Federal Regulations, Parts 260-265. Washington: GPO, 1998. United States. Office of the Federal Register National Archives and Records Administration. Municipal Solid Waste Management Regulations. Title 31 Texas Administrative Code, Part 330. Washington: GPO, 1998. United States. Centers for Disease Control and Prevention and National Institutes of Health. Biosafety in Microbiological and Biomedical Laboratories. 4 th ed. Washington: GPO, 1999. United States. Office of the Federal Register National Archives and Records Administration. Industrial Solid Waste and Municipal Hazardous Waste. Title 31 Texas Administrative Code, Chapter 335. Washington: GPO, 1998. Pollution Prevention Act, 42 United Sates Code 13101 and 13102, s/s et seg. (1990) Pollution Prevention Rules: Source Reduction and Waste Minimization 30 TAC, Chapter 335, Subchapter Q (1995) Waste Reduction Policy Act (Senate Bill 1099) Section 2.01, Chapter 361, Health and Safety Code Subchapter N. Pollution Prevention National Research Council. Prudent Practices in the Laboratory Handling and Disposal of Chemicals Washington D C: National Academy Press, 1995. Lunn, G. & Sansone, E. (Eds.). (1994). Destruction of hazardous chemicals in the laboratory. Page 45 of 46

Frederick, MD: Wiley-Interscience Publications. Armour, M. A. (1991). Hazardous laboratory chemicals: A disposal guide. Alberta, CN. CRC Press. Pines, E. & Smith, C. (2006, April 15) Hospitals for a healthy environment. Retrieved from http://www.hercenter.org/hazmat/tenstepblueprint.pdf. Page 46 of 46