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CHAPTER 3 -- HAZARDOUS WASTE HANDLING AND DISPOSAL REQUIREMENTS
The University of Kentucky is inspected annually by state and federal agencies for compliance with hazardous waste regulations. Failure to meet all of these regulations can lead to a Notice of Violation (and fines) from these agencies. The most commonly cited violations at universities involve failure to properly label hazardous waste containers, failure to properly identify the contents of the waste containers, and failure to maintain closed containers in laboratories and work areas.
 Labeling All hazardous waste containers must have a label that states HAZARDOUS WASTE, and must list the constituents of the waste. This labeling must be done at the time waste is first placed into the container. When naming the waste be specific (e.g., xylene instead of non-halogenated solvents and ethanol instead of alcohol). Do not use abbreviations or chemical formulas. Hazardous waste labels are available from the Hazardous Materials Management office, or you can use laboratory tape, etc. as long as it states HAZARDOUS WASTE and has the specific names of the waste constituents. Proper Containers and Storage Proper containers for accumulating and storing hazardous waste must be provided by the person who generates the waste. Generally, the best containers for hazardous waste are the ones that the materials came in. Other containers, such as 5 gallon jugs, are acceptable as long as the container and any residue left inside are compatible with the waste. All containers must have tight-fitting lids. Corks, ground-glass stoppers or parafilm are not proper substitutes for a tight-fitting lid. Unacceptable containers or containers without tight-fitting lids will not be picked up by EM personnel and it will be the responsibility of the generator to transfer the material to another container or to provide a proper lid for the container. EM personnel can provide guidance in selecting proper containers. When not actually pouring waste into or out of the container the top must be securely fastened. You must not leave a funnel sitting in the container. The only exception to this rule is for processes, such as HPLC, which run and add waste to the container continuously. However, when the process is not running the top must be on the container. By state and federal regulations, at no time can more than 50 gallons of waste be allowed to accumulate in any lab or storage area prior to pick up by EM. When the generator has a full container, a waste ticket should be filled out and sent in. The waste will be removed by EM as soon as possible. Waste must not be stored over drains, in sinks, or in an area where a spill would contaminate any soils or outside areas. Waste must be stored in a secure place where it is always under the control of the generator. Waste stored outside of labs must be kept under lock and key at all times and inspected regularly. Incompatible materials, whether wastes or unused chemicals, should never be mixed. Incompatible materials when mixed together may cause explosions, fires or may generate flammable or toxic gases resulting in serious health hazards. If in doubt do not mix! Caution must be exercised in any area where chemicals or wastes are stored to insure incompatible materials are segregated appropriately. Segregate by hazard class, not by alphabet. If possible do not store waste with "good" chemicals (products). Flammable waste should be kept away from heating sources and should be stored in accordance with the University's safety manual. The University Fire Marshal's office can provide information on proper storage of flammable and combustible materials. The pairs below are examples of incompatible materials:
This list is not all inclusive. For a more detailed list, see "Incompatible Chemicals" in Appendix VII of the Chemical Hygiene Plan. You should always consult a Material Safety Data Sheet (MSDS) or other chemical information sources such as Bretherick's Handbook or the Merck Index for compatibility information. Halogenated waste materials (those containing halogen compounds such as chlorine or fluorine) should be separated from non-halogenated compounds, unless unavoidable. This is for both economic and safety reasons. The halogenated wastes, while much less flammable, are generally more toxic than non-halogenated waste materials. The disposal cost of non-halogenated solvents is approximately one third that of halogenated solvents. Where possible, mercury compounds should be eliminated from the laboratory. It is very important not to mix mercury with other materials due to the difficulty (and cost) of disposing of mercury and mercury compounds. HMM will not pick up containers with dangerous or incompatible materials. These situations will be handled on a case by case basis by the director of HMM and the principle investigator. Waste Tickets To dispose of any hazardous waste you must completely fill out a hazardous waste ticket (see Figure 1) for each container. Tickets must be filled out by the person who generates the waste, not a staff assistant or student employee who does not have knowledge of chemicals or has not been through the hazardous waste class. Tickets should be filled out as completely as possible.
One ticket should be filled out for each container. If you have a box of vials or small containers that are all of the same chemicals, then only one ticket is needed for the box. For different chemicals, one ticket will be needed for each container. For animal carcasses, one ticket is needed for each bag or box with the total weight listed for the container. Mail or bring the top or white copy of the hazardous waste ticket to the EM office. Attach the other two copies (yellow and pink) by securely taping the pink copy to each container. Once the ticket is received it will be entered into the computer tracking system and EM personnel will come to your area and pick up the waste. No waste materials will be picked up without a properly filled out hazardous waste ticket. The University is required by law to track its hazardous waste from the point it becomes a waste to its point of ultimate destruction. These tickets are our means of fulfilling this requirement.
Hazardous Waste Ticket Pharmaceuticals and Controlled Medications Pharmaceuticals, chemotherapy agents and other controlled medications should be managed in the same manner as any other hazardous waste. When filling out the hazardous waste disposal ticket be sure to list both the common trade name and the more definitive chemical name. Any additional information available about the substance should be stapled to the waste disposal ticket. Ethers and Peroxide-forming Materials Some chemicals such as old ethers (not petroleum ether), picric acid, and organic peroxides tend to form unstable (explosive) compounds. Over time they can become extremely unstable. These materials should be restricted to that which is necessary to perform ongoing research. If peroxide formation is suspected, the containers should be isolated and EM immediately notified. Under no circumstances should researchers attempt to open containers if crystal formations are visible in the container or around the cap. Most of these substances have expiration labels attached to the container. It is recommended that researchers mark their containers with the date that the container was received and opened. Peroxide-forming materials that will not be used up or are not needed should be disposed of six months prior to the expiration date on the containers. Animal Carcasses Animals that have been contaminated with carcinogens or other highly toxic materials are considered to be hazardous waste and must be disposed of by EM. Technically, animals are hazardous waste if they meet the toxic characteristic (see Table 1) or are contaminated with a listed hazardous waste. If you have any questions about the chemicals you are using, contact the EM office. Non-contaminated animal carcasses will be handled per Department of Laboratory Animal Resources guidelines. |
