Central Accumulation Area Research Teaching Support SAA S Process SAA S S Under the control of a department laboratory supervisor Org. Chem I Org. Chem II Inorg. Chem Biology SSS S S A A B B C A RCRA- Trained Personnel Alternate SAAs & Waste Movement Chemistry Dept Stock Room

2 Main Options: 1.CAA in or near the building where wastes are generated Generator may move waste from SAA to CAA (ONLY IF RCRA trained), or E,H&S may move the waste (i.e., on-site pickup) 2.CAA at a distant location on campus E,H&S picks up waste from SAAs and transports it to CAA When notified or On a set schedule Central Accumulation Area (CAA) C SAA B CAA Locations & Waste Movement 1 st Fl. Dock SAA No unattended stops in between!

Labels and Labeling see – “Hazardous Waste Determinations” – below left

1.You MUST destroy or deface any original label(s) on containers used for waste. 2.When waste is first added, you MUST label each new container with the specific waste contents and optionally the words "Hazardous Waste," using one of the following two formats. 3.PRINT LEGIBLY. DO NOT fill in the accumulation start date. Labels and Labeling

Using string, attach a completed Hazardous Waste tag (also write tag # on container in indelible ink), or For large containers, attach a completed, adhesive-backed Hazardous Waste label or attach adhesive, clear- plastic pouch to container and insert completed Hazardous Waste tag. Labels and Labeling

Reverse Side of Tag  Space for additional contents  Labeling instructions  Compliance reminders Tags are available in an Excel file so that you can:  Mass print blank tags  Fill out the waste log and tag on-screen and print one tag at a time

 To ready a container for pickup Tag it (if not already tagged), Tear off bottom of tag, and Call ( ), or mail tag bottom to E,H&S NRC Suite Labels and Labeling

A Special Note on Empty Containers Before disposing ANY empty container (e.g., reagents, samples, apparatus, syringes or wastes) in the trash Completely DRAIN / REMOVE any contents (i.e., USE or TRANSFER to another container), ELIMINATE RESIDUES from container, but avoid generating a new or larger volume hazardous waste (e.g., triple rinsing, REQUIRED to decontaminate acute hazardous waste containers, increases waste volume) Deface or completely REMOVE LABELS REMOVE LIDS PUNCTURE cans or plastic containers

Who Makes Hazardous Waste Determinations? Why not just the Environmental, Health & Safety Office? EPA says any an entity is a “person,” so any employee may make the determination, including the person generating the waste and/or E,H&S Office personnel, BUT Small quantity (>100 – <1,000 kg/mo) and conditionally exempt small quantity (≤100 kg/mo) generators must calculate monthly waste generation (40 CFR §262.10(b)), including wastes in SAAs (40 CFR §261.5(c) & (d)), to determine their generator status.

Is It A Waste? Even if you no longer desire to keep a material, it is NOT a waste if it is a usable substance that has value. If you have usable chemicals or commercial products that you no longer want, such as: –Products in aerosol cans - Reagents –Compressed gases (lecture bottles)- Stock solutions –Paints and paint related products Attempt to find a user for the product or contact E,H&S.

Usable materials – “It’s not waste until we say it is” – applies to reagents, stock solutions, aerosols, etc. that could be used for some purpose. Certain reactive or polymerizing chemicals (e.g., ethers, picric acid) – Manage carefully to keep them from becoming (1) a hazard and/or (2) a waste Samples – Reserved samples or leftover samples are considered research material (not waste) until completion of the research or a determination is affirmatively made that the sample is of no further use Spent chemicals, solvents, solutions and mixtures –If not directly useable, these would be classed as “waste” at the time they are generated from the laboratory process, or, alternatively, –Certain spent materials may be treated (e.g., neutralization of acids or bases) or recovered (e.g., solvent distillation) Is It A Waste?

“Listed” hazardous wastes (F, K, P, U) – watch the Ps “Characteristic” hazardous wastes –Ignitable, corrosive, reactive, toxic (toxic is a misnomer) Hazardous Waste Determinations

 Maintain a list of wastes commonly generated in this locale and accumulated in the SAA along with their respective EPA hazardous waste codes. If you do not know which codes apply, ask for assistance from E,H&S.  For wastes not previously generated at this locale, use E,H&S's "Hazardous Waste Determination" worksheet to determine hazard(s) and EPA waste codes, if applicable, or ask E,H&S to make the determination for you.

Hazardous Waste Determinations

Home or Business? In your Texas household, you can legally put almost anything in the regular trash, except –Lead acid batteries –Used oil and oil filters –Scrap tires –Appliances that contain CFCs (refrigerants) –PCB wastes (e.g., some older lighting ballasts) –Radioactive materials (sorry, you can’t dump that old plutonium stashed in your sock drawer) –General duty clause: Anything that may threaten water quality, create a nuisance, or endanger humans or the environment 30 TAC §330.15

Prohibited from Municipal Landfills CFCs PCBs

Home or Business?

In our business, the same prohibitions apply …... plus liquid wastes (other than household-sized containers) and “hazardous wastes” So think before you toss it in Home or Business?

Inspections and Records Required by Regulations Required by E,H&S Dept Rolling Monthly Record Monthly Waste Log Corrective Action Records

Emergency Preparedness

Two Options: Before printing poster –Insert CAD or other drawing file into Excel spreadsheet After poster is laminated –Tape a paper map onto the poster

Emergency Preparedness Departmental Contact Information Non-Emergency information such as campus health clinic and hospitals

Emergency Preparedness

Examples of “Off-the-Shelf” Spill Kits

Spill Response