Table of Contents
1.0) Hazardous Materials Waste Management - General Information
Hazardous materials must be disposed of properly to protect human health,
safety and the environment. Many materials being used at the University
present some type of hazard (biological, chemical, physical, or radiation)
and specific disposal procedures are required. Therefore, all materials
being used by a laboratory or laboratory-related unit shall be disposed
in accordance with the University of Kansas Hazardous Materials Waste Management
1.2) Hazardous Materials Waste Management Program
Policy -- Revised 12/16/2005
The hazardous materials waste management procedures contained within
this manual are an integral part of the University's Environmental Health
& Safety Management Program. They have been instituted so that the
University's educational mission may be conducted safely and so that its
commitment towards providing a safer, more healthful environment for all
employees, students, and visitors can be realized.
These procedures have been established for the proper management of
the collection and disposal of hazardous materials generated by the University.
Adherence to these procedures is necessary in order to reduce environmental
hazards and contribute to the enhanced safety of the total educational
and working environments; and to facilitate University compliance with
all applicable Federal and State and Local Laws and Regulations governing
the disposal of hazardous materials waste.
All faculty, staff, and students shall be aware of their responsibilities
as identified in this manual and comply with its requirements. Failure
to do so shall be a violation of University Policy, disciplinable through
established procedures which may be found in the KU Laboratory Safety Manual in
Part 1 - Section 3.8.3. and as established in Faculty, Staff and Student
Regulatory non-compliance may be a violation of State and/or
Federal Laws punishable by fines and/or imprisonment. A Department or
School of the University shall be held liable by the Provost Office for any fee
or penalty imposed by a regulatory agency upon the KU Lawrence Campus for
improper storage, labeling or disposal of hazardous waste, tot he extent that
the fee or penalty imposed arises out of the activities of the Department of
1.3) Hazardous Materials Waste Management
1.3.1) Responsibilities of Users of Hazardous
184.108.40.206) Comply with all requirements set forth in this program and,
as applicable, with procedures given in sections of other campus safety
manuals as referenced.
1.3.2) Responsibilities of Supervisors
220.127.116.11) Keep the generation of waste with the philosophy of "As
low as reasonably achievable" as a goal.
18.104.22.168) Provide the space and storage facilities for their units as
needed to meet the requirements of this hazardous materials waste management
1.3.3) Responsibilities of Environment Health
and Safety (EHS)
22.214.171.124) Require that all users under their supervision know and follow
the requirements of this program.
126.96.36.199) Administer this campus hazardous materials waste management
188.8.131.52) Develop, update, and maintain this written program, ensuring
that it is made available to all campus units.
184.108.40.206) Provide training concerning this program, as necessary.
220.127.116.11) Provide appropriate containers for collection of Hazardous
18.104.22.168) Collect unwanted, spent, used, excess or surplus hazardous
chemicals or radioactive materials from users and see that they are properly
reused or disposed.
22.214.171.124) Provide assistance to supervisors in establishing procedures
for managing the disposal of hazardous biological agents (biohazard waste).
126.96.36.199) Require that the procedures for the disposal of hazardous materials
comply with all applicable local, state and federal regulations.
1.4) Hazardous Materials Waste Management Program
The philosophy of this program is based upon the concepts of the Waste
Management Hierarchy developed by the United States Environmental Protection
Agency. This hierarchy provides a framework for systematic thinking about
solutions to waste management. The hierarchy is a series of decision-making
steps to be used sequentially in decreasing order of desirability. The
first step is the most favorable option, while the last step is the least
favorable. The following principles of the EPA Waste Management Hierarchy
have been incorporated into the KU Hazardous Materials Waste Management
1.4.1) Keep the generation of waste Hazardous Materials at a level 'As
low as reasonably achievable (ALARA)'.
1.4.2) Minimize the proportion of unavoidable Hazardous Materials waste.
1.4.3) Segregate Hazardous Materials waste streams to make further management
activities more feasible and economical.
1.4.4) Reuse Hazardous Materials within the laboratory in accordance
with applicable federal, state and local regulations, if feasible.
1.4.5) Recycle or reclaim Hazardous Materials of value either in the
lab or through the services of EHS, if feasible.
1.4.6) Maintain unavoidable and non-reclaimable Hazardous Materials
wastes in a form amenable to treatment (e.g. incineration, neutralization,
detoxification, etc.) by EHS permitted waste disposal contractors.
Note: If this is not possible, contact EHS on what steps are to be taken
with respect to the potential waste before the material is generated or
used. Specific procedures will then have to be created.
1.4.7) In the unit, where allowed by EHS and regulations, treat
waste to reduce the volume and degree of hazard. Check with EHS first.
1.4.8) Manage remaining hazardous materials wastes and treatment residues
by secure disposal methods as approved by EHS.
1.5) Hazardous Materials Identification
The following procedures are to be used in the identification of a spent,
used, unwanted, waste, or surplus Hazardous Materials in order to determine
if it should be collected by the user for special disposal by EHS. It is
recommended that users of Hazardous Materials contact EHS prior to performing
experimentation, research, or work in order to determine whether or not
the materials being used need to be collected for special disposal or redistribution.
1.5.1) Non-Hazardous Materials
Although every material should be evaluated as to its potential reuse,
redistribution, recycling or reclamation, the following substances, when
in excess, spent, used, considered waste, or no longer wanted, are not
considered hazardous and DO NOT need to be collected for special
188.8.131.52) When feasible, recycle or reuse Normal Solid Waste:
paper, cardboard, plastics, metals, dirt, sand, food, etc., free of any
hazardous components or residue. If not feasible, they may be disposed
of into normal trash baskets or dumpsters.
184.108.40.206) NOT PLACE empty "potentially contaminated" Hazardous Materials
Containers (Metal, Plastic, or Glass) into normal trash baskets.
1.5.2) Prohibitions for Disposal into the Sanitary
220.127.116.11) Reuse or recycle emptied containers when feasible or, if not,
dispose of them as follows:
a) Remove (or, if this is not possible, thoroughly deface) all labels
before containers are reused, recycled, or disposed.
b) Remove all lids of containers before disposal into a dumpster.
c) Collect empty containers (metal, plastic, or glass) smaller than
2.5 liters in size into an appropriate temporary holding/collection vessel
(box, bucket, etc. but not normal trash basket).
Note: EHS recommends that glass containers 1 liter or smaller in size
be collected into a glass disposal box (See Non-Contaminated Sharps below)
for disposal. Once the temporary holding/collection vessel is full, or
reasonably heavy (50 lbs or less), it shall then be taken by user to the
appropriate building dumpster for emptying or disposal. Housekeeping personnel
are not responsible for removing these empty-container-collection vessels
from the space, but may be willing to do so if contacted.
d) Set empty containers (metal, plastic, or glass) 2.5 liter or greater
in size in a safe area. (A holding vessel is not required). User shall
take the containers to the appropriate building dumpster for disposal.
Housekeeping personnel are not responsible for removing these empty containers,
but may be willing to do so if contacted.
Any material(s) identified or classified below are specifically prohibited
from disposal into the sanitary sewer system in accordance with the City
of Lawrence Wastewater Discharge Pretreatment Ordinance. POTW - Public
Owned Treatment Works
Users shall not discharge any of the following materials into the
18.104.22.168) Any flammable or explosive liquids, solids, or gases which
might be injurious to the POTW or to its operation. Prohibited flammable
or explosive materials include, but are not limited to: Gasoline, Kerosene,
Naphtha, Acetone, Benzene, Toluene, Xylene, Ethers, Alcohols, Ketones,
Aldehydes, Peroxides, Chlorates, Perchlorates, Bromates, Carbides, Hydrides,
and Sulfides. Additionally, any waste material with a flash point of less
than 140oF or 60oC, and all aqueous alcohol solutions
with > 24% alcohol by volume.
1.5.3) Hazardous Materials Requiring Special
22.214.171.124) Any noxious or malodorous liquids, solids, or gases which are
singly or by interaction with other wastes are sufficient to create a public
nuisance or hazard to life or are sufficient to prevent entry into the
sewers for maintenance or repair. Examples: Thiols (Mercaptans), Pyridine,
Sulfides, Cyanides, Phenols, etc.
126.96.36.199) Solid or viscous substances which may cause obstruction to
the flow in the sewer, or other interferences with the operation of the
188.8.131.52) Any Wastewater having a pH <5.0 or >10.0, or having corrosive
properties capable of causing damage or hazard to structures, equipment,
and/or personnel of the POTW.
184.108.40.206) Any wastewater containing toxic pollutants in sufficient quantity
to injure or interfere with the POTW's process, constitute a hazard to
humans or animals, or create a toxic effect in the receiving stream.
220.127.116.11) Any wastewater with objectionable color not capable of being
removed by the POTW's treatment process. Example: inks, dye wastes, food
and pet food colorings, and vegetable tanning solutions.
18.104.22.168) Any waste water containing fats, wax, grease, or oils whether
emulsified or not, in excess of 100 mg/l or containing substances which
may solidify or become viscous at temperatures between 32 and 150 degrees
22.214.171.124) Any wastewater containing contaminants above the City's specified
pollutant limitations. This list includes: Antimony, Arsenic, Beryllium,
Cadmium, Copper, Cyanide, Lead, Mercury, Nickel, Selenium, Silver, Total
Chromium, Thallium, Zinc, Organic Priority Pollutants, Total Organic Halogens,
and Phenolic Compounds. Contact EHS for specific pollutant limitations.
126.96.36.199) Any radioactive materials - See section 4.0.
188.8.131.52) Any untreated hazardous biological materials/agents - See
The Authorized User shall collect any hazardous materials which are
spent, used, unwanted or surplus for special disposal as specified
in section 1.5.3 below unless the conditions of section 1.5.1 are met and
special disposal is not required. Materials that cannot be placed into
the sanitary sewer (see 1.5.2 above) or meet any of the criteria of this
section require special disposal. These materials include:
184.108.40.206) Hazardous Chemicals -- Any materials which meet the
definition of a hazardous chemical as defined in the OSHA Hazard Communication
Standard (29 CFR 1910.1200). This includes: Chemicals which are Physical
Hazards - Combustible liquids, explosives, flammable liquids, flammable
solids, oxidizers, organic peroxides, pyrophorics, water reactives, and
unstable reactives; Chemicals which are Health Hazards - Carcinogens,
toxic agents, reproductive toxins, irritants, corrosives, sensitizers,
hepatotoxins, nephrotoxins, neurotoxins, hematopoietic system agents, and
agents which can damage the lungs, skin, eyes, or mucous membranes.
220.127.116.11) Hazardous Wastes -- Any materials which exhibit the
characteristics of hazardous waste as identified in 40 CFR 261 Subpart
C or are listed as Hazardous Waste in 40 CFR 261 Subpart D under the Federal
Resource Conservation and Recovery Act.
Hazardous Waste Characteristics
- Ignitability, Corrosivity, Reactivity, Toxicity.
Hazardous Wastes Lists - U List, P List, F List, K List.
18.104.22.168) Biohazard Waste -- Any materials meeting the definition
of a biohazard.
22.214.171.124) Radioactive Materials Waste -- Any materials meeting
the definition of a radioactive material.
126.96.36.199) Lasers and Associated Waste -- Any materials meeting
definition of Laser/Associated Waste..
188.8.131.52) Any other materials which are not identified above,
but which are believed by the User/Supervisor to pose some danger to human
health, safety, or the environment. Contact EHS Dept. for directions and
1.6) Hazardous Materials Collection & Disposal
The User shall:
1.6.1) Collect and dispose of any material which is identified as a
hazardous chemical in accordance with the procedures identified in Section
2.0 -- Safe Disposal of Hazardous Chemicals Waste
1.6.2) Collect and dispose of any material which is identified as a
hazardous waste in accordance with the procedures identified in Section
2.0 -- Safe Disposal of Hazardous Chemicals Waste
1.6.3) Collect, process and dispose of any material which is identified
as a biohazard waste in accordance with the procedures identified in Section
3.0 -- Safe Disposal of Hazardous Biological Waste.
1.6.4) Collect and dispose of any material which is identified as a
radioactive waste in accordance with the procedures identified in Section
4.0 -- Safe Disposal of Radioactive Waste.
1.6.5) Collect and dispose of any material which is identified as a
laser or assocaiteed waste in accordance with the procedures identified
in Section 5.0 -- Safe Disposal of Lasers and Associated Waste.
1.7) Pollution Prevention, Waste Minimization
Federal and State Laws require the University to certify that it has
a program in place to prevent, minimize and reduce the amount of hazardous
waste it generates. We can not meet this mandate without the assistance
of everyone who uses hazardous chemicals or materials. Pollution prevention,
waste minimization and reduction have numerous advantages: conservation
of material usage, savings both in material purchase and disposal costs,
reduces the need for disposal, protects the environment from potential
contamination, and protects the health and safety of personnel from potential
hazards. All users of materials shall actively engage in these activities
and follow prudent safe practices in the handling and disposal of Hazardous
Materials. Contact EHS if you need assistance in implementing pollution
prevention, waste minimization & reduction activities or would like
further specific information.
1.7.1) Materials Redistribution & Reuse
184.108.40.206) Return unused chemicals to unit stockrooms or make them available
for others to use. Users are encouraged to check with all campus departmental
stockrooms for available materials before purchasing new items. EHS routinely
picks up chemicals from across campus and attempts to redistribute them
at no cost. Most of the chemicals eligible for redistribution are free
and available on a first come, first served basis.
1.7.2) Source Reduction
220.127.116.11) Substitute non-hazardous or less-hazardous materials
for Hazardous Materials whenever possible.
Supervisors and Users should:
18.104.22.168) Actively seek and adopt modifications in the procedures
which minimize the amount of hazardous materials used and/or minimizes
waste generation. Examples: Micro scale techniques should be pursued wherever
possible. The use of instrumentation or scaled-down analytical techniques
is preferred over traditional wet chemistry techniques. Newer models of
equipment produce less waste and are more efficient than older models.
22.214.171.124) Implement a thorough Inventory Management Program.
Stringent purchasing and inventory controls are the best way to minimize
excess materials or waste. Hazardous Materials should only be purchased
in the quantities needed and not in large volumes. Units should maintain
up-to-date inventories of materials available in order to avoid duplicate
stock. Excess or surplus materials should be returned to departmental stockrooms
or EHS for redistribution.
Supervisors and Users are encouraged to:
126.96.36.199) Implement a Reclamation Program. Units are encouraged
to investigate and implement processes to reclaim their spent, used, or
waste materials. Any material which can be reclaimed and reused provides
a substantial cost savings both in materials purchasing and disposal to
the University. Segregation of waste streams is the key to implementing
successful reclamation processes. Examples would be: solvent redistillation
and precious metals reclamation, etc.
1.7.3) Waste Reduction
Supervisors and Users are encouraged to:
188.8.131.52) Establish and implement Treatment Procedures which
render Hazardous Materials less or non-hazardous. There are various reactions
which can be incorporated into the experiment or process to render materials
non-hazardous, de-toxify or destroy the waste. Some examples of acceptable
treatment at the unit level are: Neutralization, Heavy Metals Precipitation,
Solidification, Oxidation, or Reduction.
Special Notice #1: Incineration, evaporation, or dilution
NOT acceptable treatment methods. However, evaporation or dilution
which is part of a standard process or laboratory procedure is permitted.
Special Notice #2: Treatment should only be performed
by competent individuals utilizing proper safety precautions. It is important
for the individual to be knowledgeable in the chosen destruction procedure
and aware of potential adverse reactions which may present a risk to health
& safety. EHS has several references which identify potential and acceptable