LABORATORY HAZARDOUS WASTE MANAGEMENT AT UNC-CH

To demonstrate the proper methods of laboratory hazardous waste management for compliance with state and federal regulations. Training Goal

Hazardous Waste  Waste that poses a threat to the environment or human health if not handled or disposed of properly  Resource Conservation and Recovery Act (RCRA) passed in 1975  Called for the establishment of regulations  Directed by the Environmental Protection Agency (EPA) to regulate proper management of hazardous wastes

Hazardous Waste Characteristics  Under RCRA a waste can be hazardous if it has certain characteristics  Ignitability: if waste is a liquid with a flashpoint of <140°F  Corrosivity: if waste has a pH below 2 and above 12.5  Reactivity: if waste reacts violently with air or water  Toxicity: if waste contains more than a certain level of some toxic materials (as defined in 40 CFR )

“Cradle to Grave”  EPA’s comprehensive system of regulations  From the “cradle” (point of conception) to the “grave” (point of disposal)  Governs the following hazardous waste management activities:  Generation  Transportation  Treatment  Storage  Disposal

Responsibilities of UNC-CH  EPA views UNC as a hazardous waste generator  Generators are responsible for:  properly identifying hazardous waste  proper management of hazardous waste Use Storage Disposal

EPA Fines for Non-compliance  The EPA does impose fines against universities and colleges  Examples include:  Boston University - $800,000  Penn State - $1 million  UC Berkeley - $1 million  Stanford University - $1 million

Most Common EPA Violations  Most commonly cited EPA violations of hazardous waste regulations are:  Open containers or lids not screwed on tight  Improper labels/identification  Lack of secondary containment for leaks  Hazardous waste storage location (point of generation)  The 4L’s – Lids, Leaks, Labels and Location

Lids  Are all containers labeled as hazardous waste closed and secured with proper lids?  Lids/caps must be securely in-place except when material is being removed or added to the container  A funnel resting on the mouth of a bottle does not constitute a lid  Lids/caps on waste containers must be on tight (Note: Be sure that gas producing reactions have worked to completion before transferring the material to a hazardous waste container)  A closed container, when tipped over, won’t leak!

Example – Open Containers A funnel is not a lid! Lid open when not in use

Leaks  Are containers labeled as hazardous waste stored in secondary containment?  Secondary containment is to be used to minimize the potential for breakage, spillage and the comingling of incompatible materials (i.e. acids and bases)  Plastic trays, pans or tubs can be used  Without exception, secondary containment is required for the following: All glass containers of liquid hazardous waste stored on the floor All containers with capacity ≤4 liters of liquid hazardous waste, regardless of storage location  Hazardous materials are to be segregated by hazard class and stored in separate cabinets, trays or pans

Example - Leaks Potential spill contained by plastic tub (secondary containment)

Labels  Are all containers labeled as hazardous waste properly labeled?  Regulations require that the name of the chemical be clearly identified on the label  Chemical formulas and abbreviations such as H 2 SO 4, HCl and EtBr are not accepted by the EPA  Hazardous waste regulations require the words “Hazardous Waste”, or words which clearly identify the contents such as “Acetone Waste”, be on each waste container

Example - Labels Chemical formulas are not allowed If you re-use a container for collecting waste you must deface the original label

Location  Are all containers labeled as hazardous waste stored at or near the point of generation?  Hazardous waste regulations require that the generator accumulate hazardous waste in containers at or near the point of generation where waste initially accumulates, and which is under the control of the operator who generated the waste  Under no circumstances can waste be stored down the hall and/or out of your control

Hazardous Waste Containers  Each laboratory must supply their own containers  The original container the chemical came in is usually the best  All containers must have securely fitting lids/caps  All containers must be compatible with their contents  For liquid waste, EHS prefers the amber 4 liter solvent bottles because they are non-recyclable and are compatible with most types of waste  For mixed hazardous waste a log of contents, quantities, dates added and initials of depositor should be located on or near the container

Liquid Hazardous Waste Containers  Leave 10% headspace (volume left at top of container) in case of expansion due to temperature  Do not pour hot liquids into waste bottles  Do not comingle incompatible wastes (i.e. acids and bases)  Provide secondary containment  Any containers with capacity of ≤4 liters must have secondary containment

Solid Hazardous Waste Containers  If original containers are not available  double-bag the material  place in a sturdy cardboard box for support  Bags used should be trash bags  Absolutely no Biohazard or Radiation bags!

Gas Cylinders  Consider buying refillable returnable cylinders  Contact the supplier and make sure they will accept the cylinder when you are finished with it  Don’t call it “empty” unless it is  Lecture bottles can not be thrown in the trash when empty

 To be considered empty, an aerosol can must contain NO propellant and NO product, and must be at atmospheric pressure. UNC regulates all partially empty spray cans as Hazardous Waste because they may still contain ignitable propellants, chlorinated solvents, flammable material, or toxic substances.  Do Not discard partially empty spray cans in the trash.  Do Not puncture any aerosol cans.  Store used Aerosol cans in a Closed container labeled as “Aerosol Cans”.  Return spray cans that malfunction (for example, the tip breaks off) to the manufacturer or dispose of them as Hazardous Waste.  Request a pick-up of your aerosol cans by filling out the form found here at  Contact UNC EHS at for questions or assistance with disposal of aerosol cans. Managing Aerosol Cans

UNC-CH Hazardous Waste Disposal Procedures  EHS has established an online chemical waste pick- up form (e510) for laboratory personnel  All personnel registered as working in a lab can request waste pick-up for his/her Principal Investigator by accessing online form with ONYEN  You must have a Laboratory Worker Registration form on file at EHS and have completed the General Laboratory Environment training to be able to access the chemical waste disposal form

UNC-CH Hazardous Waste Disposal Procedures  After completion of the online request form (e510), it is submitted electronically to EHS for approval  If all information is correct and complete, EHS will send the approved form back via  This approval form must be printed out and attached to the waste container for pickup

Example – Waste Pickup Form Waste Pickup Form (e510)

Bulk Laboratory Clean-out or Close-out  If you have a large amount of chemicals in your lab for disposal, contact Steve Parker  EHS can set up a direct shipment straight from your lab without filling out an online e510 form for each chemical

Unknown Chemicals  Check with all lab personnel and try to make a waste determination  Contact EHS to assist with pickup (Steve Parker,

Reactive Chemicals  Old or expired reactive chemicals can be potentially dangerous  Peroxide formers such as ether should not be handled  Notify EHS immediately if found in your lab (Steve Parker,

Hazardous Waste Minimization  In order to minimize the waste generated on campus, labs should do the following:  Practice inventory control using the EHS online chemical inventory system (  Practice good housekeeping and safe handling  Only order the amount you intend to use  Explore the use of non-hazardous alternatives

Training Post-test  You have completed the Laboratory Hazardous Waste Management at UNC-CH training module  If you have any questions regarding this training please contact EHS at (919)  In order to receive credit for this training, you must complete the post-testpost-test