CHEMICAL/HAZARDOUS WASTE CHECKLIST
When things look messy, EPA considers this a "visual clue of possible non-compliance warranting further inquiry."
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).
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)
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 acceptable to seal your waste containers.
The EPA considers an open and improperly labeled waste container a serious violation.
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.)
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 have completed EHRS's laboratory safety training within the last 2 years.
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.
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.
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
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.)
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.
Unless approved by EHRS (and the City), disposal of hazardous chemicals by way of the sanitary sewer system is not permitted.
EPA will assume that hazardous chemicals are going down the drain.
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.
These will also be considered waste-like by the EPA if not cleaned out or tagged, labeled and sealed properly.
Never place these in the same container.
Volumes of hazardous waste will increase subjecting the University to increased costs and regulatory requirements. 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.
For example, procedures on how to move chemicals around campus safely. Link to Transportation of Hazardous chemicals. http://www.usciences.edu/safety/policies/transportation.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).
We have classroom training 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.):
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.
If you have any questions regarding hazardous waste handling, storage and disposal procedures, please do not hesitate to call the EHRS Department. (X8925, X8843 or X3141)
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