|No./Title: Hazardous Waste Management Plan||Resp. Office: Campus Safety and Emergency Management||Effective Date: 3/16/2021|
|Category: Hazardous Materials||Last Review: New||Next Review: 6/30/2022|
|Contact: Tim Barton, Chief Safety Officer||🕿901.448.6114||🖂 firstname.lastname@example.org|
Policies: SA0400 – Hazardous Material Safety
The purpose of this procedure is to provide a framework for those individuals on campus who generate or handle hazardous waste. Consult Title 40 Code of Federal Regulations or Environmental Health and Safety for additional information regarding hazardous waste.
This shall apply to all students, staff and faculty on the Memphis campus of the University of Tennessee Health Science Center.
This standard applies to all hazardous waste as defined below.
DOT-Department of Transportation
HAZWOPER-Hazardous Waste Operations and Emergency Response Standard IATA- International Air Transportation Agency
RCRA-Resource Conservation and Recovery Act SAA-Satellite Accumulation Area
TDEC-Tennessee Department of Environment and Conservation
Hazardous Waste – The EPA defines hazardous waste as a material that no longer has an intended value with properties that make it dangerous or potentially harmful to human health or the environment. Hazardous wastes can exist as liquids, solids, contained gases, or sludges. They can be the by-products of manufacturing processes or simply discarded commercial products, like cleaning fluids or pesticides.
In regulatory terms, a RCRA hazardous waste is either a listed waste that appears on one of the four hazardous wastes lists (F-list, K-list, P-list, or U-list), and/or exhibits at least one of four characteristics-ignitability, corrosivity, reactivity, or toxicity. Hazardous waste is regulated under the Resource Conservation and Recovery Act (RCRA) Subtitle C, which is enforced by the EPA on a federal level, and TDEC on a state level.
ROLES AND RESPONSIBILITIES
The management of hazardous chemical waste at the University consists of the coordination and direction of the waste generated in hundreds of laboratories and other campus facilities. To manage this large volume effectively, it is necessary to use the services and technical expertise of Campus Safety, Research Safety Affairs, contractors, research faculty and staff members. This section briefly describes the function of each group and its role in the hazardous chemical waste plan.
The Chancellor of the University is responsible for the administration of policy pertaining to institutional safety and health-‘related matters. The chancellor oversees the administration of safety policies through the chain of authority within the institution, delegating to deans, department heads, principal investigators and supervisors the responsibility for ensuring safe work practices of those under their supervision and adherence to established policy and guidelines. Campus Safety/Research Safety Affairs is responsible for surveillance of all laboratory activities involving the use of toxic agents and all additional chemical and biological problem areas within the confines of the University. Specific duties of the department include:
- Monitor the implementation of the safety and health policies of the University.
- Design and improve disposal procedures for chemical waste materials.
- Prepare, submit, and maintain records, reports and manifests as required by government regulations.
- Prepare applications for state and federal permits to generate and properly dispose of hazardous chemical waste.
- Schedule and co-ordinate the activities of the hazardous waste contractors on campus.
- Ensure the university’s compliance with all applicable federal (EPA) and state (TDEC) environmental regulations concerning hazardous waste.
- Ensure the university is making an effort to minimize the amount of hazardous waste generated on campus.
- Represent the university during EPA and TDEC regulatory inspections.
Principal Investigator, Classroom Instructor or Supervisor
The principal investigator, classroom instructor, or supervisor has the direct responsibility for assuring that the policy and guidelines established herein are followed by all personnel, including other researchers under their jurisdiction. This includes the completion of appropriate training by personnel under their oversight. The supervisors of individuals who generate hazardous waste are required under federal and state law to ensure these individuals have been trained and that training must be documented. Training is available from Campus Safety in the form of traditional classroom, or online formats. Training must be completed annually for individuals who generate and manage hazardous waste. For training information, refer to the lab safety website or 448-6114.
Laboratory Workers, Employees, Students, and Other Individuals
The success of the hazardous chemical waste management program at the University is dependent on the conscientious efforts of the individual laboratory worker and staff employee. Because the laboratory workers frequently ·handles hazardous chemicals, it is essential that they follow the advice, policies, and procedures pertaining to hazardous materials handling. The individual staff members are expected to:
- Manage and dispose of all chemical waste in accordance with established procedures set forth in this disposal policy.
- Maintain the identity of all chemicals with which they work.
- Package and label surplus and waste chemicals in accordance with established procedures set forth in this disposal policy.
- Seek the advice, when necessary, of Safety Affairs concerning the proper handling and disposal of hazardous chemicals.
Ensure they are properly trained on hazardous waste management, and that this documented training is refreshed on an annual basis.
- All containers must be leak-proof and chemically compatible with their contents. Lids should fit properly so that the container is leak proof.
- When selecting a waste container, pay attention to the original container material to ensure waste added to the container is not incompatible with residues of the original material. Make sure empty containers once used to hold product are clean and does not contain any remaining product residue.
- Bags may be used only for dry solids. Needles (capped or uncapped), pipettes, broken glass or other sharp-edged materials that are chemically contaminated are not acceptable in bags. All “sharps” must be placed in puncture-resistant containers.
- Containers which show signs of contamination on their exterior are not acceptable regardless of their contents.
- Containers and bags marked with biohazard or radioactive warnings are not acceptable for chemical waste disposal. If a waste has biological and/ or radiological and chemical hazards, please contact Campus Safety for guidance before packaging.
- When adding hazardous waste to a container, only the constituents that are specifically listed on the waste label should be added and care must be taken not to mix incompatible materials.
- All containers must be closed with a tight-fitting lid unless waste is being added or removed from the container. It is illegal to store waste in an open container.
In order to comply with state and federal regulations and University policy, the following information must appear on each container of hazardous waste.
- Hazardous Waste State and federal regulations require that each container must be clearly marked with the words, “Hazardous Waste”. Campus Safety requires that all hazardous waste must be labeled with a UTHSC hazardous waste label. Labels can be obtained from UTHSC webpage.
- Generator’s Name: The individual who is responsible for the area or process from which the waste originated and contact information (including name, phone# and room#) for the best person to contact if further information about the material is needed.
- Chemical Constituents: Write all constituents, whether hazardous or non-hazardous, on the waste label. Formulas, trade names, abbreviations, and general names and nomenclature are not acceptable. The proper chemical name must be written out in its entirety. Provide percentage of constituents, if known. Estimates are acceptable.
- Do not add an accumulation start date; this will be completed by Campus Safety.
- Any container used for disposal and storage of waste must be marked with the information specified in the Labeling section upon placing the first drop of waste into the container.
- Whenever possible, store flammable waste liquids and waste corrosive liquids in cabinets designed for these materials.
- Maximum amount that can accumulate in the lab is 55 gallons hazardous waste or 1 kilogram of acutely toxic waste (Appendix A). If you accumulate more than the maximum amount, the waste needs to be removed from your lab no later than 3 days after these maximum amounts are reached.
- All waste must be stored in secondary containment (i.e. cabinets and trays) and should be segregated according to hazard class (i.e. flammables, toxics, etc.).
Contact the Campus Safety to coordinate a pickup at email@example.com or 448-6115. Waste must never be left unattended outside the labs. It must be accepted by a Safety representative.
- Hazardous waste must never be disposed of down the sanitary sewer, the storm sewer, placed in the regular trash, by evaporation (a container without a lid implies evaporation for volatile substances), mixing with a biohazard, or mixing with a non-hazardous substance (i.e. dilution).
- The following items are not classified as hazardous waste and are not included in this policy: sewage; regular trash; universal waste (fluorescent bulbs, batteries); radioactive and biohazard.
- The burden of hazardous waste determination lies with the waste generator. If unsure whether a waste is hazardous, reviewing the safety data sheet (SDS) or original container labels are good starting points. When in doubt, assume the waste is hazardous and manage as a hazardous waste. Campus Safety should be consulted with any questions concerning hazardous waste determinations.
- Every effort must be made to minimize and reduce the volumes of hazardous waste generated on campus. Please refer to UTHSC Hazardous Waste Minimization Plan for ideas on waste reduction.
- Empty containers of material EPA P-List or U-List must be collected for disposal as hazardous waste unless triple-rinsed with a suitable solvent. The rinsate must be collected and handled as hazardous waste.
The supervisors of individuals who generate hazardous waste are required under federal and state law to ensure these individuals have been trained and that training must be documented. Training is available from Campus Safety in the form of traditional classroom, or online formats. Training must be completed annually for individuals who generate and manage hazardous waste. For training information, refer to the lab safety website or 448-6114.
The Chief Safety Officer shall ensure that select staff members are adequately trained in the following subjects:
- Hazardous substances
- DOT shipping requirements
- Hazardous waste management (RCRA regulations)
- Personal protective equipment
- OSHA HAZWOPER
- Procedure for submitting the annual report to the Tennessee Department of Environment and Conservation
The Campus Safety shall serve as the primary location for records related to hazardous waste. Records shall be maintained on the following:
- Hazardous waste manifests
- Annual reports
- Land disposal restrictions
- Waste stream profile
- Waste determinations
- Disposal certificates
- Waste Minimization Plan
- Emergency Contingency Plan
- DOT Hazardous Material Shipping
- IATA Hazardous Materials Shipping
- OSHA Hazardous Waste Operations
- Communication from and to:
- Regulatory agencies
- Hazardous waste vendors
- Generators of hazardous waste
- University administration
Most of these records must be maintained for three years to meet regulatory requirements. Training records shall be maintained by the individual department to whom the employee or student reports. Training records for employees may also be kept in IRIS.
Appendix A: List of Acutely Hazardous Substances
- OSHA 29 CFR 1910.120 (Hazardous Waste)
- EPA 40 CFR 260-270 (Hazardous Waste)
- Tennessee Code Annotated (1200-01-11)
List of Acutely Hazardous Chemicals and Waste Codes
|Chemical Name||Federal P-Code||CAS Registry Number|
|Arsonous dichloride, phenyl-||P036||696-28-6|
|Benzene, (chloromethy 1)-||P028||100-44-7|
|1,2-Benzenediol,- 4-[ 1-hydroxy-2-(methylamino)ethyl]-,||P042||/51-43-4|
|Benzeneethanamine, alpha,alpha- dimethy1-||P046||122-09-8|
|7-Benzofuranol, 2,3-dihydro-2,2-dimethyl-, methy lcarbamate.||P127||1563-66-2|
|Benzoic acid, 2-hydroxy-, compd. With (3aS-cis)-1,2,3,3a,8,8a-hexahydro- 1,3a,8-
trimethylpyrrolo[2,3-b]indol-5-yl methylcarbamate ester (1:1).
|2H-1-Benzopyran-2-one, 4-hydroxy-3-(3- oxo-1-phenylbutyl)-, & salts, when present
at concentrations greater than 0.3%
|2-Butanone, 3,3-dimethyl-l(methylthio)-, O-[methylamino)carbonyl] oxime||P045||39196-18-4|
|Calcium cyanide||P021||592-01-8 –|
|Carbamic acid, [(dibutylamino)- thio]methyl-, 2,3-dihydro-2,2- dimethyl- 7-
|Carbamic acid, dimethyl- 1-((dimethyl- amino) carbonyl]- 5-methyl-lH-
|Carbamic acid, dimethyl-, 3-methyl-1-(1-methylethyl)-lH- pyrazol-5-yl ester.||P192||119-38-0|
|Carbamic acid, methyl-, 3-Tl?-eth ylphenyl ester.||P190||1129-41-5|
|Cyanides (soluble cyanide salts), not otherwise specified||P030|
|Dichlorome th yl etl1er||P016||542-88-1|
|O,O-Diethyl O-pyrazinyl phosphorothioate||P040||297-97-2|
|1,4,5,8-Dimethanonaphthalene, 1,2,3,4,10,10-hexa- chloro-1,4,4a,5,8,8a,- hexahydro-
|1,4,5,8-Dimethanonaphthalene, 1,2,3,4,10,10-hexa- chloro-l ,4,4a,5,8,8a- hexahydro-
,(1alpha,4a lpha,4abeta ,5beta,8beta ,8ab eta)-
|1a,2,2a,3,6,6a;7,7a- octal1ydro-,alph a,7beta, 7aalpha)-b]oxirene, 3,4,5,6,9,9-|
|,(laalpha,2beta,2abeta,3alpha,6alpha,6abeta,7beta, 7aalpha)-, & metabolites||.|
|4,6-Dinitro-o-cresol , & salts||Po47||534-52-1|
|Diphosphoric acid, tetraethyl ester||Pll 1||107-49-3|
|1,3-Dithiolane-2-carboxaldehyde, 2,4-dimethy1-, 0- [(methylamino )- carbony l]oxime.||P185||26419-73-8|
|Endrin, & metabolites||Po51||72-20-8|
|Ethanimidothioc acid, 2-( dimethylamino)-N-[[(methylamino)carbouyl]oA’Y]- 2-oxo-, methyl ester.||Pl94||23135-22-0|
|Ethanimidothioic acid,N-[[(methylamino)carbonyl]oxy]-,methyl ester||Po66||16752-77-5|
|Fluoroacetic acid, sodium salt||Po58||62-74-8|
|Fulminic acid, mercury(2+) salt||Po65||628-86-4|
|3(2H)-Isoxazolone, 5-(aminomethyl )-||Poo7||2763-96-4|
|Mercury fulminate (R,T)||Po65||628-86-4|
|Methane, tetranitro- (R)||Pll2||509-14-8|
|Methanimidamide,N ,N-dimethyl-N’-[3-[[(methylamino)- carbonyl }oxy]phenyl]-, monohydrochloride.||Pl98||23422-53-9|
|Methanimidamide, N,N-dimethyl-N’-[2-methyl-4- [[(methylamino)carbonyl]oxy ]phenyl]-||P197||17702-57-7|
|6,9-Methano-2,4,3-benzodioxathiepin, 6,7,8,9, Io, IO- hexachloro-
l ,5,5a,6;9,9a- hexahydro-, 3-oxide
|4,7-Methano- l H-indene, 1,4,5,6,7,8,8-heptachloro-3a,4,7,7a-tetrahydro-||Po59||76-44-8|
|Nicotine , & salts||Po75||54-11-5|
|Nitrogen oxide NO||Po76||10102-43-9|
|Phenol, 2-cyclohexy 1-4,6-dinitro-||Po34||131-89-5|
|Phenol, 2-meth yl-4,6-dinitro-, & salts||Po47||534-52-1|
|Phenol, 2,4,6-trinitro-, ammonium salt®||Poo9||131-74-8|
|Phenol, 4-(dimethylamino)-3,5-dimethyl-, methylcarbamate (ester).||P128||315-18-4|
|Phenol, (3,5-dimethy1-4-(methy lthio)-,methy lcarbamate||Pl99||2032-65-7|
|Phenol, 3-(1-methylethyl)-, methylcarbamate.||P202||64-00-6|
|Phenol, 3-methyl-5-(1-rneth yleth yl)-,metb yl carbamate.||P201||2631-37-0|
|Phosphoric acid, diethyl 4-nitrophenylester||Po41||311-45-5|
|Phosphorodithioic acid, O,O-di ethyl S-[2-(ethylthio)ethyl] ester||Po39||298-04-4|
|Phosphorodithioic acid, O,O-diethyl S-[2-(ethylthio)methyl] ester||Po94||298-02-2|
|Phosphorodithioic acid, O,O-dimethyl S-[2-(methylamino)-2-oxoethyl] ester||Po44||60-51-5|
|Phosphorofluori<iic acid, bls(l-methylethyl) ester||Po43||55-91-4|
|Phosphorothioic acid, O,O-diethyl O-(4-nitrophenyl) ester||Po89||56-38-2|
|Phosphorothioic acid, O,O-diethyl O-pyrazinyl ester||Po40||’97-97-2|
|Phosphorothioic acid,O.:.[4-[(dimethylamino)sulfonyl]phenyl] O,O-dimethyl ester||Po97||52-85-7|
|Phosphorothioic acid, O,O,-dimethyl O(4-nitrophenyl) ester||Po71||298-00-0|
|Potassium cyanide K(CN)||Po98||151-50-8|
|Potassium silver cyanide||Po99||506-61-6|
|Propanal, 2-methyl-2-(methylthio)-,0-[ (methylamino )carbonyl]oxime||Po70||116-06-3|
|Propanal, 2-methy1-2-(methyl-sulfonyl)-, 0-[ (methylamino)carbonyl] oxime.||P203||1646-88-4|
|1,2,3-Propanetriol, trinit rate||Po81||55-63-0|
|Pyridine, 3-(1-methyl-2-pyrrolidinyl)-, (S)-, & salts||Po75||54-11-5|
|Pyrrolo[2,3-h]indol-5-ol,1,2,3,3a,8,8a-hexahydro-1,3a,8- trimethyl-, methylcarbamate (ester), (3aS-cis)-.||P204||U -47-6 · —–|
|Selenious acid, dithallium(l+) salt||Pl 14||39-52-o|
|Silver cyanide Ag(CN)||P104||506-64-9|
|Sodium cyanide Na(CN)||P106||143″’33-9|
|Strychnidin-10-one, & salts||P108||57-24-9|
|Strychnine, & salts||P108||57-24-9|
|Sulfuric acid, dithallium(l +) salt||P115||7446-18-6|
|Tetraphosphoric acid, hexaethyl ester||Po62||757-58-4|
|Thiodiphosphoric acid, tetraethylester||P109||36a9-24-5|
|Thiourea ; phenyl-||P093||103-85-5|
|Vanadic acid, ammonium salt||P119||7803-55-6|
|Warfarin, & salts, when present at concentrations greater than 0.3%||Pd0l||81-81-2|
|Zinc, bis(dimethylcarbamodithioato- S,S’)-,||P205||137-30-4|