Table of Contents
2.0) Safe Disposal of Hazardous Chemical Waste
2.1) Introduction
Hazardous chemicals must be properly disposed in order to protect human
health, safety and the environment. A vast number of the chemicals being
used at the University present some type of physical or health hazard (Ignitability,
Corrosivity, Reactivity, Toxicity) and require specific disposal procedures
to be implemented. Therefore, all chemicals being used by a unit shall
be disposed in accordance with the University of Kansas Hazardous Materials
Waste Management Program. The applicable portions of Section 1.0 shall
be followed by all personnel in the handling of Hazardous Chemical waste.
The conditions and requirements of this Section 2.0 are in addition to
the previously mentioned reference and are specific for chemicals.
2.2) Hazardous Chemical Waste Management Program
Policy
All supervisors and personnel using chemicals shall:
2.2.1) Be familiar with and uphold the hazardous materials waste management
program policy stated in Section 1.2.
2.3) Hazardous Chemical Waste Management Program
Responsibilities
All supervisors and personnel using chemicals shall:
2.3.1) Fulfill their hazardous materials waste management program responsibilities
as identified in Section 1.3.
2.4) Hazardous Chemical Waste Management Program
Philosophy
All supervisors and personnel using chemicals shall:
2.4.1) Adhere to the hazardous materials waste management program philosophy
presented in Section 1.4.
2.5) Pollution Prevention, Waste Minimization
& Reduction
All supervisors and personnel using chemicals shall:
2.5.1) Where feasible, make pollution prevention, waste minimization
and reduction an integral part of the chemical process, experiment, or
activities being conducted in or by their unit in accordance with the procedures
provided in Section 1.7.
2.6) Hazardous Chemical Waste Identification
The following procedures are to be used in the identification of a spent,
used, unwanted, waste, or surplus chemical in order to determine if it
should be collected by the user for special disposal by EHS. It is recommended
that users of chemicals contact EHS prior to performing experimentation,
research, or work in order to determine the proper disposal method for
the chemicals being used.
2.6.1) Non-Hazardous Chemical Disposal
All personnel using chemicals shall:
2.6.1.1) Refer to Section 1.5.1 for procedures identifying the requirements
for disposal of non-hazardous materials such as normal solid waste, empty
containers, sharps, broken glass, etc.
2.6.1.2) (May) dispose of Non-Hazardous Chemical Solids by collecting
them into an appropriate secondary container (trash bag or box), sealing
the container, and delivering it to the nearest building dumpster.
NOTE: Non-Hazardous Chemical Solid is one which does not meet
the definition of a hazardous chemical and the waste material is not defined
as a hazardous waste.
2.6.1.3) (May) dispose of Non-Hazardous Chemical Liquids by discharging
down a sink drain with water.
NOTE: Non-Hazardous Chemical Liquid is one which does not meet
the definition of a hazardous chemical, the waste solution is not defined
as a hazardous waste, and the material is not prohibited from discharge
into the sanitary sewer system.
2.6.1.4) Not place Non-Hazardous Chemical Solids or Liquids in a normal
trash wastebasket. For safety reasons, it is not housekeeping's responsibility
to remove and dispose of any (non-hazardous or hazardous) chemicals.
2.6.2) Chemicals Prohibited From Disposal Into
The Sanitary Sewer System
All personnel using chemicals shall:
2.6.2.1) Refer to Section 1.5.2 to determine what materials (chemicals)
are prohibited from being discharged into the sanitary sewer system by
the City of Lawrence Wastewater Discharge Pretreatment Ordinance. Below
is a brief summary for types of chemicals prohibited from Sanitary Sewer
Disposal:
a) Any combustible, flammable, or explosive liquids, solids, or gases.
b) Any noxious or malodorous liquids, solids, or gases.
c) Any solid or viscous substance which may cause obstruction to the
flow in the sewer system.
d) Any wastewater having pH<5 or >10, or having corrosive properties
capable of causing damage.
e) Any wastewater containing toxic pollutants in sufficient quantity
to injure or interfere with the POTW's process.
f) Any wastewater having objectionable color not capable of being removed
by the POTW.
g) Any wastewater containing fats, wax, grease, or oils in excess of
100 mg/l, or containing substances which may solidify.
h) Any wastewater containing contaminants above the City's specified
pollutant limitations. This 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 limits.
i) Any radioactive chemicals must be disposed in accordance with section
4.0.
2.6.3) Hazardous Chemicals Requiring Special
Disposal By EHS
All personnel using chemicals shall collect for special disposal
by EHS any spent, used, unwanted, waste, or surplus chemicals which:
1) cannot be disposed as non-hazardous materials (see Section 2.6.1 above),
2) are prohibited from disposal into the sanitary sewer system (Section
2.6.2 above), or 3) meet any of the criteria below:
2.6.3.1) Hazardous Chemicals -- Any chemicals/materials which
meet the definition of a hazardous chemical (see glossary) require special
disposal by EHS. This includes: Chemicals which are/present physical
hazards - Combustible liquids, explosives, flammable liquids, flammable
solids, oxidizers, organic peroxides, pyrophorics (air reactives), water
reactives, and unstable reactives. Chemicals which are/present health
hazards - Carcinogens, corrosives, irritants, hepatotoxins, nephrotoxins,
neurotoxins, reproductive toxins, hematopoietic system agents, sensitizers,
toxic or poisonous agents, and any agent which can damage the lungs, skin,
eyes, or mucous membranes.
2.6.3.2) Hazardous Waste -- Any chemicals/materials which exhibit
the characteristics of a hazardous waste as identified in 40 CFR 261 Subpart
C or are listed as a hazardous waste in 40 CFR 261 Subpart D. This includes:
Characteristic
Hazardous Waste and Listed Hazardous Waste .
2.6.3.3) Biohazard Materials/Waste Disposal -- Refer to Section
3.0
2.6.3.4) Radioactive Materials/Waste Disposal -- Refer to Section
4.0
2.6.3.5) Lasers and Associated Waste -- Refer to Section 5.0
2.6.3.6) Any other materials/chemicals which may not be identified previously,
but which the user believes pose some danger to human health, safety or
the environment.
2.7) Collection Procedures
The proper collection of excess, spent, used, unwanted, waste or surplus
chemicals/materials by individuals and units is the most critical part
of the KU Hazardous Materials Waste Management Program. All chemicals/materials
identified as hazardous in Section 2.6.3 must be collected and given to
EHS for evaluation as to their potential reuse, redistribution, reclamation,
recycling, or need for off-campus hazardous waste disposal.
2.7.1) General Collection Procedures for
Hazardous Chemicals/Materials Waste
All personnel shall collect chemicals/materials identified as
needing special disposal by EHS in accordance with the procedures
provided in this section:
2.7.1.1) Containers should have all previous labels removed before
they are used for collection of waste materials.
2.7.1.2) Containers used for collection shall be compatible with the
waste materials being collected.
2.7.1.3) There shall be only one waste collection container per wastestream
per generation point (K.A.R. 28-31-4(j)(1)).
2.7.1.4) Collection containers shall be labeled in English as to its
specific chemical content and specific chemical volume, weight, or percentage.
Structural formulas or abbreviations are not acceptable. An example
of the required chemical waste container label
can be found at:
http://www.ehs.ku.edu/documents/ehs_forms/hazardous_materials_waste_labels.aspx
2.7.1.5) Containers shall be kept tightly closed at all times, except
when filling with waste materials.
2.7.1.6) It is important to collect different or incompatible waste
chemicals into separate containers. The mixing of incompatible substances
could cause a serious hazard to lab personnel. Use the following protocols:
a) Collect separately, where possible, waste organic materials from
waste inorganic materials.
b) Collect separately, waste peroxidizable materials from other waste
materials.
c) Collect separately, where possible, all known or suspected carcinogenic
wastes.
d) Where possible, do not mix waste aqueous material with waste organic
material.
e) Collect waste solvents separately, where possible, as either halogenated
or non-halogenated.
2.7.1.7) A waste collection container shall be dated (marked with the date)
by the user when the container becomes full.
2.7.1.8) The user must notify EHS immediately when the waste collection
container becomes full so that the waste can be removed from the generation
point within three days of the fill date.
2.7.1.9) Acids or bases should be neutralized to a pH of 5-10 so they
can be disposed into the sanitary sewer as long as they contain no other
toxic materials. Corrosive materials that may generate dangerous fumes
or products when neutralized, and for which the lab does not have the appropriate
safety devices or capability to perform the neutralization, should be left
corrosive and placed into glass or plastic containers for pickup by EHS.
2.7.1.10) Waste chemicals/materials containing any of the following heavy
metals should be collected separately, where possible:
a) Arsenic, Barium, Cadmium, Chromium, Lead, Mercury, Selenium, Silver.
2.7.2) Specific Wastestream Collection Procedures
2.7.2.1) Waste Solvents - Waste solvents (from HPLC, LC, Peptide
Synthesis, and other processes utilizing solvents) shall be collected into
EHS-approved waste containers in accordance with the following requirements:
a) The laboratory is responsible for contacting EHS to obtain the appropriate
waste solvent collection container(s).
b) The waste solvent collection container(s) shall be marked with the
words "Hazardous Waste" before collection begins.
c) Glass containers are not acceptable for collection of waste solvents
unless special arrangements have been made with EHS.
d) Waste solvent collection container(s) shall be kept closed at all
times, except when being added to.
e) There may be only one waste solvent collection container per wastestream
(non-halogenated and halogenated) per generation point.
f) A waste solvent collection container shall be dated (marked with
the date) by the user when the container becomes full.
g) The user must notifiy EHS immediately when the container becomes
full so that the waste can be removed from the generation point within
three days of the fill date.
2.7.2.2) Waste Chemical Mixtures - Chemical mixtures are
those that are prepared by the user, and are not considered to be original
chemical products.
a) The laboratory shall contact EHS to ascertain the appropriate waste
collection container(s).
b) Containers of waste chemical mixtures shall be marked with the words
"Hazardous Waste."
c) Containers of waste chemical mixtures shall be dated (marked with
the date) by the user when the container becomes full.
d) The user must notify EHS immediately so that the waste can be removed
from the generation point within three days of the fill date.
2.7.2.3) Unknowns - All containers are required by University policy
and procedures to be labeled as to their contents and hazards; however,
should a user discover containers of unknown contents, the user must either
identify the contents immediately or notify EHS for their removal.
Containers of unknown contents are considered to be hazardous waste and
must be marked with the words "Hazardous Waste." Note that the unit
may be held responsible for payment of any necessary analytical costs to
identify the material.
2.7.2.4) Used Oil - Used Oils (pump, lubricating, etc.) shall
be collected separately, marked with the words "Used Oil," and given to
EHS for recycling or disposal.
2.7.2.5) Metallic Mercury - Dirty metallic mercury should be
collected by the unit for temporary storage and shipment for redistillation,
or it may be given to EHS for handling.
2.7.2.6) Gas Cylinders - It is the users responsibility to ship
unwanted or empty cylinders of compressed or liquefied gases back to the
supplier with the screw-on shipping cap in place. Small leaking cylinders
should be placed into a functioning lab hood and EHS should be contacted
for handling and disposal assistance. Cylinders which cannot be sent back
to the manufacturer may have to go for special waste disposal. Contact
EHS.
2.7.2.7) Batteries - (Alkaline, lead-acid, nickel/cadmium, lithium
ion, etc.) shall be collected and given to EHS for recycling or disposal.
2.7.2.8) Used photographic fixer - Used photographic fixer shall
be collected separately and given to EHS for silver recovery.
2.7.2.9) Pesticides - Pesticides and/or pesticide products shall
be collected separately and given to EHS for disposal.
2.7.2.10) Exhaust Filters from Paint Spray Booths -- These filters
often contain metals in the paint solids which may make them be considered
hazardous waste. Therefore, arrangements must be made with EHS to have
exhaust filters from paint spray booths tested. If the filters are
shown to be a hazardous waste, they shall be collected separately and given
to EHS for disposal. If the filters are shown to be not a hazardous
waste, the filters may be disposed of in the normal trash; however, if
there is a change of process change within the spray booth, EHS must be
notified at that time to ascertain the continued non-hazardous status of
the filters.
2.7.2.11) Used/Waste Silica Gel and Other Contaminated Absorbents or Adsorbents --
Concern for silica gel and other absorbents/adsorbents that have come in contact with solvents and toxic compounds.
Depending on what it is, the used silica gel or absorbent/adsorbent may be regulated as a hazardous waste.
Do not dispose of these items into normal trash without EHS approval.
Collect into a container, properly label, and when full, users must date container and immediately notify EHS for pickup.
We have a special or unique label for Waste Silica Gel and other contaminated ad/absorbents.
This label is to be used for containers of Waste Silica Gel and/or other chemically contaminated adsorbents or absorbents. This label helps complete a toxicity characteristic screen of the contaminated material to determine if it is a hazardous waste. Print out the label, complete all fields, attach to container and contact EHS for pickup. The label may be found here: Waste Silica Gel Label
2.7.3) Surplus Chemicals
2.7.3.1) Chemicals that are considered to be in good
condition and are suitable for redistribution for use elsewhere on campus
will be culled out by EHS. EHS maintains a listing of surplus chemicals
that are available for use. Go to the EHS website at
WWW.EHS.KU.EDU
and click on "Hazardous Materials/Environmental Protection Office" and
select the Surplus Chemicals link to view and request items from the list.
Users may also request that EHS keep a watch out for items not currently
on the list.
2.8) Pickup & Removal Procedures
All excess, spent, used, unwanted, waste, or surplus chemicals/materials
which have been collected by a unit in accordance with the procedures identified
in Section 2.7.1 & 2.7.2 & 2.7.3 above, are to be picked up and
removed by the EHS. These materials will be taken back to Burt Hall
for evaluation as to their potential reuse, redistribution, reclamation,
recycling, or need for off-campus hazardous waste disposal.
All personnel shall comply with the following procedures for
pickup and removal of hazardous chemicals/materials from their lab by EHS.
2.8.1) Contact For Pickup
2.8.1.1) To arrange for pickup of hazardous materials or hazardous
waste, contact EHS at 4-2853 and be prepared to provide the following information:
-
Contact Person
-
Contact Person Phone #
-
Building & Room #
-
Department
-
Type of chemicals to be picked up
-
Number & size of Containers.
2.8.1.2) You may also request pickups by Email. Go to the EHS website
at www.ehs.ku.edu and click on
"Hazardous Materials/Environmental Protection Office" and follow directions
for requesting chemical pickups.
2.8.1.3) Information will be placed onto EHS Pickup Schedule List which
is organized first requested, first served. Priority is usually given to
solvent materials, but emergency situations, types of chemicals, and availability
of EHS personnel are also considered.
2.8.2) Container Preparations
2.8.2.1) Containers shall have been prepared in accordance with the
proper collection procedures as identified in Section 2.7.1 & 2.7.2
(labeling, dating, etc).
2.8.3) Removal Exceptions
2.8.3.1) Any containers found to be unsuitable in the judgment of EHS
personnel, or that have not been prepared, labeled, or packaged in accordance
with the previous procedures, shall not be removed from the users location
until compliance is achieved.
2.8.4) Laboratory or Inventory Clean-out Procedures
It is important that prior planning and a cooperative effort be established
between personnel and EHS in order to facilitate the clean-out/close-out
of areas containing large numbers of hazardous chemicals/materials.
2.8.4.1) A typewritten or computerized inventory list of chemicals/materials
to be removed shall be provided by the supervisor to EHS at least 30 days
in advance of close-out/clean-out deadline. Once the inventory list has
been received and reviewed by EHS, a pickup date will be scheduled. The
inventory list shall include the following minimum information:
a) Chemical Name, Container Size & Chemical Quantity.
b) This information is necessary so that EHS personnel can review the
list to identify appropriate safety precautions, potential items for redistribution
or reuse, and schedule sufficient time for the clean-out.
2.8.4.2) All containers shall be in accordance with the collection procedures
as identified in Section 2.7.1 & 2.7.2.
2.8.4.3) The Container Removal Exceptions identified in Section 2.8.3
are applicable for all close-outs and inventory clean-outs.
2.9) Chemical Pollution Prevention, Waste Minimization
& Reduction
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 that it generates. This especially includes hazardous chemical waste.
All supervisors and personnel using chemicals shall:
2.9.1) Chemical Waste Minimization &
Reduction
2.9.1.1) Where feasible, make pollution prevention, waste minimization
and reduction an integral part of the chemical process, experiment, or
activities being conducted in their unit in accordance with the procedures
provided in Section 1.7. This includes:
a) Chemical Redistribution & Reuse
b) Source Reduction through substitutions or process modifications
c) Source Reduction through Chemical Inventory Management
d) Waste Reduction through Chemical Reclamation
e) Waste Reduction through Chemical Treatment Procedures
2.9.2) Contact EHS - for assistance in developing
and implementing pollution prevention, waste minimization and reduction
activities in the lab
