1.   General Procedures
Satellite Accumulation Areas
Storage and Disposal
Waste Reduction
Definition of Hazardous Waste
Biohazardous Waste
Radioactive Waste

1.    General Procedures

The University policy is zero tolerance for non-compliance with environmental regulations. The following procedures must be followed to comply with rules from the U.S. Environmental Protection Agency (EPA) and the Pennsylvania Department of Environmental Protection (DEP) which regulate the disposal of hazardous wastes in a cradle-to-grave fashion.

Potentially hazardous chemicals must be disposed of in accordance with Federal and State regulations and procedures established by the EHRS Department. Your department may also have procedures that you are required to follow. Check with your supervisor or the EHRS Department before disposing of any potentially hazardous chemical.

Laboratory Supervisors and Department Supervisors have the primary responsibility of ensuring that anyone who is responsible for generating, handling, or transporting hazardous waste has had training relevant to their responsibilities and ensures everyone complies with the hazardous waste policies in their daily operations.

Unless approved by the EHRS Department, disposal of chemicals by way of the sanitary sewer system is not permitted.

All laboratory personnel must be familiar with the location and composition of all wastes produced in the laboratory.

Waste containers must remain closed except when actually adding waste. Open containers and open funnels left in containers violate state and federal waste regulations.

2.     Satellite Accumulation Areas

These are locations within laboratories where chemical wastes are collected and properly stored until they are moved to the Griffith Hall or STC Central Stockroom's waste storage areas. Each area must be posted designating it with EHRS's waste storage area sign.

3.     Storage and Disposal

If you are generating liquid wastes in volumes large enough to warrant the use of 5 gallon containers, please contact the Central Stockrooms in order to obtain a polyethylene container.  Use of many glass bottles for the same waste stream results in costly disposal and presents an increased risk of release of the waste via broken containers. 
Prior to consolidation/mixing of liquid waste streams, it is your responsibility to ensure that all waste components are compatible.  Severe reactions, including explosions, may occur if certain chemical materials are mixed improperly.
Review and follow waste storage and disposal procedures required in your laboratory or area of responsibility. View EHRS's Chemical/Hazardous Waste Checklist for Compliance in Section VI or you may read the following procedures.
  • 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.) Post the EHRS Waste Area Signs that contains the list of reminder procedures to designate the area(s). (Call the EHRS Department at X8925 if you need a sign.)

  • All containers of wastes must be labeled with the full chemical name(s) as soon as any waste enters the container. No abbreviations or chemical formulas are allowed. Pre-printed tags designating the container as "chemical/hazardous waste" should be affixed to each container of waste. This is because EPA requires that hazardous waste be labeled with the words "hazardous waste." Tags are available from the Central Stockrooms. The generator must identify all components of the waste, and if a mixture, the approximate percent by volume. (When the percent by volume information is available.)

  • Descriptions such as "organic waste" alone are not acceptable.

  • Do not date the tag until the waste container is full. Once full, the tag should be dated and then the container moved to a Central Stockroom immediately or within 3 days of the date. Make sure that full waste containers do not stay in the laboratory or work area longer than 3 days. Also, make sure that once it is dated, it gets moved within the three days. Call the Central Stockrooms at X8843 or 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 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 or work area and it is closed, stored, and labeled properly. However, waste must never be kept in a laboratory or work area for a year or longer. Waste must never be generated in one room and taken to another room for storage. This is not considered in satellite accumulation and is subject to more stringent requirements. Do not do this.

  • Waste containers must be 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 not an acceptable practice to seal your waste containers. The EPA considers an open or improperly labeled waste container a serious violation.

  • If waste bottles have collection tubes in place (i.e., from laboratory instruments) place 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.

  • Separate your chemically incompatible waste. Use tubs that are available from the Central Stockrooms to keep containers of incompatibles separated.

  • Store your waste containers in secondary containment (tubs). This is important to contain leaks or spills, to separate incompatible wastes, and especially when chemicals are stored near a drain or sink.

  • Containers must be compatible with the waste stored within them. (i.e., Never put corrosives or halogenated solvents in metal containers or place ethers in clear bottles.)

  • Check containers regularly to make sure that they are in good condition, free of deterioration, and not leaking.

  • Never put hazardous waste down the drain.

  • Always separate hazardous wastes from non-hazardous wastes. Volumes of hazardous waste will increase subjecting the University to increased regulatory requirements and costs. To determine if the chemical is a regulated hazardous waste, contact the EHRS Department or consult EPA regulation 40CFR 261 - Identification and Listing of Hazardous Waste. View EPA's Hazardous Waste List in Section VI.

  • Make sure there are no dusty, rusty, crusty, expired, unclaimed, or abandoned chemicals, or old peroxide-former and reactive chemicals in your area(s). These will be considered waste-like by the EPA and if not labeled with the chemical/hazardous waste tag and full chemical name(s), and sealed and stored properly as waste, they will be in violation of the regulations.

  • Make sure beakers and flasks in your laboratories that contain residual materials are cleaned out or sealed and labeled properly with the chemical/hazardous waste tag and full chemical name(s). These will also be considered waste-like by the EPA.

  • Keep sinks clear of beakers, flasks, bottles, etc. that contain chemicals, or look as if they contain chemicals. EPA will also consider these to be waste-like if not cleaned out and will assume that hazardous chemicals are going down the drain.

  • Make sure shelving and storage areas are not crowded, unsafe or corroded (including shelving clips).

  • Laboratory and Department Supervisors must provide and document laboratory or area-specific waste handling training relevant to their responsibilities, including emergency procedures. 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.)

  • Make sure that everyone who is responsible for generating, handling, or transporting hazardous waste to our Central Stockrooms completes EHRS laboratory safety training and has had training relevant to their responsibilities by their supervisor. EHRS has classroom or web-based training modules to meet these requirements. Laboratory and Department Supervisors must ensure that employees and students in their laboratories/areas comply with these hazardous waste procedures in their daily operations.
Separate halogenated waste from non-halogenated waste solvents.   Solvent mixtures with more than 5% halogenated solvent by volume should be placed in the halogenated waste containers.

Many hazardous wastes, when mixed with other waste or material, can produce effects which are harmful to human health and the environment, such as; heat or pressure, fire or explosion, violent reaction, toxic gases, fumes or mists, flammable vapors or gases.

Laboratory Supervisors shall, as regulations require, adequately analyze his or her wastes to prevent creating uncontrolled substances or reactions.

4.     Your Role in Waste Reduction

a. The following guidelines are presented to assist you in reducing the amount of waste generated in your laboratory:
Order the smallest quantity of chemical materials required for your research/lab/area.  The cost of transportation and disposal of unused chemicals is far greater than the amount of money saved by ordering chemicals in bulk.
2) Seek ways that will minimize the quantity of waste generated.
Do not mix small quantities of hazardous chemicals with non-hazardous waste, as this may cause the entire waste to be listed as hazardous.
Do not mix waste that is expensive to dispose of with large quantities of more common waste streams.  (ex., reactive chemicals and heavy metals should not be mixed with your 5 gallon container of organic wastes).
Substitute materials which are less hazardous or toxic whenever possible.
6) Reduce the scale of laboratory experiments to reduce the volume of waste being produced, whenever possible.
Check with other laboratories in your department or the Central Stockrooms to see if they may be able to use chemicals that you have in surplus or you no longer need.
8) Purchase mercury-free instruments.
Peroxide forming chemicals must not be kept in your lab for longer than six months after they have been opened.  View Safe Handling of Reactive and Peroxide Forming Chemicals in Section VII.  If you have peroxide forming chemicals which have been opened for longer than six months, contact the Central Stockroom (X8843).  View a list of chemicals which may form peroxides in Section VII.
When planning experiments, consider the disposal of leftover starting materials and of the products and by-products which will be generated.  Consider the following questions in your planning;
1) Can any material be recovered for reuse?
2) Will the experiment generate any chemical that should be destroyed by a laboratory procedure?
3) Can any unusual disposal problems be anticipated?  If so, contact the EHRS Department before you start the research.
4) Is there a possibility of replacing a hazardous reagent or solvent with one that is less hazardous and easier to dispose of?

5.     Definition of Hazardous Waste

A chemical waste is considered to be hazardous waste if it is specifically listed by the EPA or DEP as a hazardous waste (Link to EPA's Hazardous Waste List) or if it exhibits any of the following 4 hazardous characteristics:

a. Ignitability - liquid with a flash point of less than 60C.   (140F)  Some examples are:
acetone ethanol petroleum ethers methylethyl ketone
benzene ethyl acetate toluene pentane
dioxane hexane xylene methanol

This is only a small list of ignitable wastes. Check the chemical label, the Safety Data Sheet, or call the EHRS Department for more information.

Corrosivity - aqueous solution with a pH of less than or equal to 2, or greater than or equal to 12.5.  However, under local regulations, materials of pH less than 5.5 and greater than 12 is considered corrosive and cannot be discharged to the sewer.  Small quantities of acids and bases may be neutralized in the laboratory only when it is written as the last step in the experimental procedure.  "Chromerge" glass cleaning solution and base baths are considered corrosive wastes.  Corrosive materials also include thionyl chloride, sodium hydroxide and some other aqueous acids or bases.
Reactivity - Chemicals in this category are either inherently unstable, or upon contact with other materials may react violently or release toxic gases.   Examples are:  cyanide compounds, strong oxidizers such as potassium permanganate and perchloric acid, metallic sodium and potassium, picric acid, butyl lithium, old ethers which may have formed peroxides, benzoyl peroxide, sodium borohydride, and explosive salts such as sodium azide.

Reactive materials must be treated with extreme caution to protect not only the personnel in the laboratory, but also those who handle the material for its disposal process.  Because of the considerable cost associated with disposal of reactive wastes, purchase volumes should be minimized.   Laboratories generating a reactive chemical waste stream must have these materials collected regularly to prevent large quantities from accumulating.

Extraction Procedure Toxicity - chemicals characterized as EP toxic are those that may leach hazardous constituents into the groundwater if their wastes are improperly managed.  This category includes toxic metals such as:
arsenic chromium selenium
barium lead silver
cadmium mercury

Pesticides and carcinogens are also included in this category.

e. Listed Compounds
In addition to compounds which fall into the above categories, the Environmental Protection Agency (EPA) and the Pa. Department of Environmental Protection (DEP) has included as hazardous waste a list of substances which have been shown in scientific studies to have toxic, carcinogenic, mutagenic or teratogenic effects on humans or other life forms, or they may be an environmental hazard, or the chemical may have a special hazard.
There are currently hundreds of substances included on these lists. (Link to list)  Below are some examples of substances commonly used at the University which appear on the lists.  This list is not all inclusive.
acetaldehyde chloroform osmium tetroxide
acetonitrile cyanides phenol
acrylonitrile carbon tetrachloride pyridine
acrolein diaminobenzoic acid sodium azide
bromoform (DAB) tetrachloroethylene
cacodylic acid ethidium bromide tetrahydrofuran

Materials which fall into any of the four categories described above or which are included in the Environmental Protection Agency 's or the Pa. DEP’s list are to be considered hazardous waste. If you think a material may not be considered hazardous due to its dilute concentration or limited quantity, please contact the EHRS Department for proper disposal procedures. In any case, if you are unsure as to whether a material is hazardous, contact the EHRS Department.

View the procedures for the disposal of biohazardous waste in the Biosafety Manual.

View the procedures for the disposal of radioactive waste in the Radiation Safety Manual.

University of the Sciences in Philadelphia • 600 South Forty-third Street • Philadelphia, PA 19104-4495 • phone: 215-596-8800 • email: safety@usip.edu