CHEMICAL/HAZARDOUS WASTE CHECKLIST
FOR COMPLIANCE

• Is your laboratory or area of responsibility neat and orderly?

When things look messy, EPA considers this a "visual clue of possible non-compliance warranting further inquiry."

• Do you have a designated area in your laboratory or room for storage of waste? (These are called Satellite Accumulation Areas)  Is your designated area posted with a sign?

Look for an area in your laboratory or room that can be designated as your waste storage area.  (More than one designated area is allowed). 

The EHRS sign with a list of reminder procedures must be posted.  (Call the Environmental Health and Radiation Safety (EHRS) Department if you need a sign).

• Is your waste labeled with the "Chemical/Hazardous Waste" tag and labeled with the name of the chemical(s) and approximate percentages, if a mixture? Put the name of the chemical(s) on the tag when the waste is first placed into the container.

The Griffith Hall and McNeil Science and Technology Center Central Stockrooms have these pre-printed tags available.
[Leave date field on tag blank until just before transfer to the stockrooms.]

Also, hazardous waste must be labeled with the words "hazardous waste." Therefore, use the tags.

No abbreviations or formulas are allowed.
(i.e., unacceptable: waste HCL
              required:  hazardous waste - hydrochloric acid)

• Are waste containers kept closed at all times unless adding or removing waste? (This includes biohazard waste)

No open containers are allowed anywhere (i.e., laboratory, fume hood, storage area).  Do not store waste in open beakers or flasks.  Open funnels must be removed from the bottles unless actively pouring waste. However, the sealable funnels attached to bottles are acceptable, if closed. 

Parafilm is also not allowed. 

The EPA considers an open and improperly labeled waste container a serious violation.

• Do waste bottles that have collection tubes in place (i.e., from lab instruments) have a hole in the bottle cap JUST large enough for the effluent tube?

This will allow you to keep the collection tube in place, even if the instrument is not running.

Also, store this waste container in a tub.

If there is not a small hole in the cap, make sure the tubing is removed and then the container sealed with the cap as soon as you are no longer adding waste to the container. (Special caps with holes are available in the Griffith Hall Central Stockroom.)

• Do you ensure that full hazardous waste containers do not sit around in the laboratory or your area of responsibility too long? Three days is the limit for full containers.

When the hazardous waste container is full, date the tag and then move the waste to the Griffith Hall or McNeil Science and Technology Central Stockrooms immediately or within three days of that date. However, make sure that once it is dated, it gets moved to the stockroom within the three days.

Call the stockroom to let EHRS know (Griffith Hall at X8843) (STC at X3141) or bring it down to the stockrooms if you have documented training on how to transport properly or if you completed EHRS's annual laboratory safety training.

If the hazardous waste container is not full, it may remain in your satellite accumulation area, as long as you have not accumulated too much waste in the laboratory and it is closed, stored and labeled properly. However, waste must never be stored for a year or longer.

Also, if the waste is moved to a nearby room, (separate from the point of generation) then it is not considered in satellite accumulation and is subject to more stringent requirements. Do not do this.

• Is the date field on the chemical/hazardous waste tag blank?

Again, do not date the tag until the container is full. Once dated, then move the waste to the Griffith Hall or McNeil Science and Technology Central Stockrooms immediately or within 3 days of that date.

• Is your chemically incompatible waste separated?

Use tubs that are available from the stockrooms to keep containers of incompatibles separated. Separate the containers, but also remember to never mix incompatible wastes in one container.
e.g., separate acids from bases, separate oxidizers from flammables

• Are hazardous waste containers in secondary containment?

Always store your liquid waste containers in leak-proof plastic tubs. This is important to contain leaks or spills, to separate incompatible wastes, and especially when chemicals are stored near a drain or sink. (Tubs are available in the stockrooms.)

• Are waste containers in good condition, free of deterioration, and not leaking?

• Are waste containers compatible with the hazardous waste stored within them?

Never put corrosives in metal containers or ethers in clear bottles. Also, always try to store waste in plastic containers rather than glass, if compatible.

• Never put hazardous waste down the drain.

Unless approved by EHRS (and the City), disposal of hazardous chemicals by way of the sanitary sewer system is not permitted.

• Are your sinks clear of beakers, flasks, bottles, etc. that contain chemicals, or look as if they contain chemicals?

EPA will assume that hazardous chemicals are going down the drain.

• Are you sure that there are no dusty, rusty, crusty, expired, unclaimed, or abandoned chemicals, or old peroxide-former and reactive chemicals in your area?

These will be considered waste-like by the EPA and if not tagged, labeled, sealed and stored as waste, they will be in violation of the regulations. These are also a potential hazard.

• Are beakers and flasks which contain residual materials, cleaned out or labeled properly with chemical names?

  These will also be considered waste-like by the EPA if not cleaned out or tagged, labeled and sealed properly.

• Did you check that your shelving and storage areas are not crowded, unsafe or corroded (including shelving clips)?

• Are all chemicals/substances in your laboratory labeled properly with full chemical names?

• Do you separate hazardous wastes from non-hazardous wastes?

Never place these in the same container.
Volumes of hazardous waste will increase subjecting us to increased regulatory requirements and costs. To determine if the chemical is a regulated hazardous waste, contact the EHRS Department or consult EPA regulation 40 CFR 261. You may also visit the EHRS Department's web site for the EPA hazardous waste list by clicking on the link below.

See EPA's Hazardous Waste List.

• Is everyone in your laboratory or area of responsibility thoroughly aware of emergency procedures and have Supervisors provided and documented laboratory or area-specific waste handling training relevant to their responsibilities?

For example, procedures on how to move chemicals around campus safely. Link to Transportation of Hazardous chemicals. (http://www.usciences.edu/safety/lmanual/LSchemstor.htm) Also, examples of emergency procedures include spills or leaks, injuries or illnesses, fire and accidental chemical exposure.  (The EPA will conduct interviews with faculty, staff and students during their inspections of the University).

• Has everyone who is responsible for generating or handling hazardous waste or transporting hazardous waste to our stockrooms completed EHRS's annual general laboratory safety training (for laboratories) or Hazard Communication training (for other areas)?

We have classroom training, safety discussion guides and web-based training modules to meet these requirements.  Laboratory Directors, Principal Investigators and Supervisors must make sure that employees and student workers in their laboratories complete required trainings and comply with these hazardous waste policies in their daily operations.

Examples of Questions that EPA/DEP Inspectors May Ask Personnel and Students (You may keep your answers very simple.):

• What type of waste do you generate?  Simply name the chemicals or classes of wastes.  (i.e., hydrochloric acid or corrosives)
  
  
• What are you doing with your hazardous waste? EPA is determining if you are handling and disposing of it properly.  (e.g., ensuring that you are disposing of the waste through the EHRS Department, and not disposing of it down the drain or in the trash, you are aware that waste must be stored in compatible containers and separated from other incompatible wastes.)
  
  
• Where are you storing your hazardous waste? Show your designated waste storage area(s).
  
  
• How do you dispose of hazardous waste?  Bringing it to the EHRS Department Stockrooms in a secondary container or on a cart. At a minimum, wear a lab coat, (coveralls for Facilities), gloves and safety glasses.
  
  
• What do you do in an emergency? i.e., spill:

1)  contain it, so it does not go into a drain, if possible.
2)  leave and secure area to prevent anyone from walking through or near it
3)  call Supervisor, and
4)  call EHRS and/or Public Safety.

• Be prepared, have spill control materials near your work area to suppress flammable vapors quickly or to neutralize corrosives.
  
  
• Where are your SDS's (formerly called MSDS's)? Know the locations in your area. Also, a master set of all University SDS's is stored in the Griffith Hall Central Stockroom, room #B-10. Further, University of the Science's web-based SDS (MSDS) program and other SDS (MSDS) websites are available on the EHRS site (http://usp.edu/safety/msds.shtml).

If you have any questions regarding hazardous waste handling procedures or emergency procedures, please do not hesitate to call the EHRS Department. (X8925, X8843 or X3141)