1. Module 2 – Managing Hazardous Waste On-site University of Wisconsin Oshkosh Hazardous Waste Management

2. Basic Components for proper hazardous waste management University of Wisconsin Three basic components Accurate waste determination Proper handling of waste on site Safe transportation and disposal This module will focus on proper management of waste on site. Keep in mind: Proper management of hazardous waste is not only good science but also it’s the law. EPA and WI DNR have been actively enforcing RCRA rules in academic institutions in recent years.

3. Proper handling of hazardous waste University of Wisconsin Once you have determined you have generated hazardous waste you must then manage that waste properly. Hazardous waste management requirements are partially dependent on your generator status. Therefore, we are going to start this module by learning how to determine generator status.

4. Hazardous Waste Generator Status University of Wisconsin Generators of hazardous waste are divided into three categories in Wisconsin Very small quantity generator (VSQG) Small quantity generator (SQG) Large quantity generator (LQG)

5. Generator Status University of Wisconsin Your hazardous waste generator status depends on three factors: How much hazardous waste you generate in a calendar month How much hazardous waste you accumulate on site How much acute hazardous waste you generate per month All acute hazardous waste carries a “P” code (with the exception of F- listed waste with an “H” designation which are also considered acute hazardous waste). The next slide contains a table which summarizes criteria used to determine generator status.

6. Determining Generator Status University of Wisconsin Note: HW refers to hazardous waste LQGSQGVSQG HW per month >2,205 lbs <2,205 lbs <220 lbs HW accumulated No limit<13,230 lbs <2,205 lbs Acute HW Accumulated > 2.2 lbs< 2.2 lbs

7. Generator Status University of Wisconsin In general, the amount of waste generated and accumulated on site will determine our generator status It is preferable to be a very small quantity generator (VSQG) rather than a large quantity generator (LQG) Large quantity generators have more compliance requirements for managing hazardous waste. There is a cost associated with managing hazardous waste. The more waste generated, the greater the cost. UW- Oshkosh is currently a Small Quantity Generator.

8. Impact of acute hazardous waste The amount of acute hazardous waste (those with a P or some F codes) generated or accumulated can significantly impact generator status. Anyone generating or accumulating over 2.2 lbs of acute hazardous waste at one time automatically becomes a LQG. University of Wisconsin

9. Waste Management University of Wisconsin All generators of hazardous waste must do certain things – although the requirements vary a bit depending on generator status. Obtain an EPA ID number – EPA monitors and tracks generator activity by assigning EPA ID numbers. UW- Oshkosh has a campus-wide EPA number. Determine if waste is hazardous Manage hazardous waste properly on site Treat, store, dispose or recycle waste at an approved facility. Track shipping papers to ensure delivery All UW campuses use an approved hazardous waste vendor for treatment and disposal. Responsibility of person generating waste.

10. Additional requirements depending on generator status University of Wisconsin The Environmental Health and Safety Department is responsible for meeting additional requirements including: Designate an emergency coordinator Annual DNR reporting (LQG and SQG) Training program for personnel handling hazardous waste Emergency preparedness and response plans Records maintenance

11. Managing hazardous waste in the lab University of Wisconsin Proper management of hazardous waste starts in the lab where it is generated. Your first priority is to consider ways of eliminating or minimizing waste generated. This will be addressed later in this module. Once you have generated waste you are responsible for Ensuring waste is placed in appropriate containers Stored properly until removed from the laboratory

12. Place Waste in Proper Containers University of Wisconsin Good condition - no leaks, etc. Container is compatible with contents Contents compatible with each other Closed at all times (except when adding or removing contents) Labeled with the words “Hazardous Waste”, identity of contents and hazard of contents

13. Waste Labels University of Wisconsin All containers of hazardous waste must have a proper label.

14. Satellite Accumulation Areas (SAAs) University of Wisconsin Satellite accumulation allows you to accumulate small amounts (< 55 gallons) of waste in your lab. Main reasons for using SAAs You can conveniently accumulate waste in the area from which it is generated. You can accumulate waste over a longer period of time without having to ship within the accumulation period (the storage time limit does not start until the container has been transferred to the campus hazardous waste storage site). To qualify as a satellite accumulation area, waste stored must be near point of generation and under the control of the person generating the waste

15. Satellite Accumulation at UW- University of Wisconsin The Environmental Health and Safety Department can provide five-gallon carboys for collection of waste organic solvents. Organic solvents should be segregated into two carboys: Non-halogenated solvents – these are suitable for fuel blending. Fuel blended solvents provide an alternative fuel source for some industrial applications and provide a considerable savings in waste disposal costs. Examples; acetonitrile, hexane, methyl alcohol, toluene Halogenated solvents – must be commercially incinerated. Examples: chloroform, methylene chloride It is important to properly segregate halogenated from non- halogenated solvents to allow for fuel blending and disposal cost savings.

16. Satellite Accumulation University of Wisconsin Waste containers in SAAs must Be properly labeled (“hazardous waste”, identity and hazard) In good condition Closed when transfers are not occurring Notify Environmental Health and Safety if you are using satellite accumulation since this waste stream must be included in monthly waste generation totals when determining generator status. If more than 55 gallons of hazardous waste is accumulated, container holding excess amount must be marked with the date the excess amount began accumulating and excess amount must be removed to campus hazardous waste storage site within 3 days. (Contact Environmental Health and Safety for assistance.)

17. Hazardous Waste “Container” Storage University of Wisconsin Not all hazardous waste generated in a laboratory may qualify for satellite accumulation. For example: There may not be sufficient area in the lab to store large volumes of hazardous waste near the point of generation, or Person generating waste may not be in control e.g. person may no longer be doing research in the area. We will refer to hazardous waste that does not qualify for satellite accumulation as “container” waste.

18. “Container” Storage Requirements University of Wisconsin For all hazardous waste containers (not in satellite accumulation) kept in your area: Date container label when the first drop of waste is added. Make sure container is stored within secondary containment (something that will capture waste if container fails) Inspect area where container(s) is/are stored weekly looking for leaking containers and for deterioration of containers and the containment system. Document the weekly inspections.

19. “Container” storage University of Wisconsin Generators of hazardous waste are encouraged to limit container storage of hazardous waste in their laboratories and arrange for removal as soon as containers are full or a hazardous waste stream is no longer generated. This will minimize your responsibilities for meeting storage requirements and improves safety in the laboratory by Minimizing impact of potential spills Minimizing potential occupant exposures Limiting container storage of hazardous waste in laboratories and moving waste to the campus storage site as soon as possible also allows the environmental manager to track waste generation to ensure accurate determination of generator status ensures waste is shipped within allotted storage time limits. Contact the Environmental Health and Safety Office for assistance with moving hazardous waste from your laboratory.

20. Common Violations University of Wisconsin Both EPA and WI DNR audit universities for compliance with RCRA rules. Common violations found include: Not marking containers as hazardous waste Open hazardous waste containers Improper hazardous waste containers – containers in poor condition, over full, leaking, etc. Mixing incompatible wastes, e.g. mixing acids in an organic solvents carboy. Storing incompatible wastes together, e.g. storing waste acids next to waste bases or oxidizers with flammables

21. Shipping and Disposal University of Wisconsin Up to this point we have considered Identifying hazardous waste Proper management of hazardous waste on site University must also properly ship and dispose of all hazardous waste generated by the University. Important to remember that “cradle to grave” makes the generator liable for hazardous waste generated until it is destroyed – even if you hire someone else to ship and dispose of that waste. The Environmental Health and Safety Department coordinates shipment of all hazardous waste generated through a State approved vendor. Keep in mind that the information you provide on your waste labels and through waste determination process is essential for safe and legal shipment of the waste.

22. Waste Minimization University of Wisconsin Eliminating or minimizing the hazardous waste generated in your lab has several benefits: It eliminates or minimizes environmental pollution It decreases waste disposal costs It reduces the risk of chemical exposures and accidents. Several waste minimization options are considered in the next slides Reducing or eliminating waste at the source Less is Better philosophy Surplus chemical redistribution Chemical inventory management

23. Waste minimization – reducing at the source University of Wisconsin Modify your laboratory procedures Substitute with a less hazardous or non-hazardous substance if possible E.g. consider computer simulations and modeling to eliminate some wet chemistry procedures Reduce the scale E.g. microscale equipment and techniques reduce quantities used and waste generated Improve laboratory operations Careful and neat operations reduce waste Minimize amount of chemicals used Keep volatile chemicals capped and sealed

24. Less is Better Philosophy University of Wisconsin Buy less Purchase only the chemicals and amounts you need in the immediate future. If you need only a small amount, consider borrowing from another lab if available. Don’t purchase chemicals speculatively. Store less – storing excess chemicals increases chemical risks (exposure, spill and fire) and takes up valuable lab space. Use less – safer for you and the environment.

25. Redistribution of Surplus Chemicals University of Wisconsin Before sending excess chemicals for hazardous waste disposal, check with other laboratories on your campus area to see if they can use your excess. The Environmental Health and Safety Department will also assist with surplus chemical distribution if product is In original manufacturer’s container In good condition Has not exceeded its recommended shelf life

26. Inventory management University of Wisconsin A significant amount of laboratory waste is the result of poor chemical inventory management. Do Maintain an accurate and up-to-date chemical inventory Avoids duplicate purchases, besides it is a regulatory requirement. Monitor expiration dates and chemical stocks – some chemicals become unstable, reactive and explosive with age. Make sure all bottles are in good condition, capped and properly labeled – unlabeled bottles create unknowns which are expensive to analyze and dispose. Regularly review inventory for unwanted and unused chemicals. Consider redistribution before they become outdated.

27. Waste Disposal Priorities University of Wisconsin Disposal options should be considered in the following order: Reuse, reclaim, or recycle (e.g. lamps, ballasts, mercury devices) Elementary neutralization Fuel blending (Keep in mind that careful segregation of non- halogenated solvents allows this waste stream to be treated in a more beneficial manner.) Recovery (e.g. silver reclamation units) Destruction via incineration (significant amount of hazardous waste is managed this way) License permitted landfills (limited options, e.g. asbestos)

28. Additional waste issues University of Wisconsin The focus of the unit has been on chemical hazardous waste. Laboratory workers should also know proper handling procedures for two other potential waste streams in the laboratory: Infectious waste Batteries

29. Infectious Waste University of Wisconsin Infectious waste – solid waste that contains pathogens with sufficient virulence and in sufficient quantity that exposure of a susceptible human or animal could cause the human or animal to contract an infectious disease.

30. Infectious Waste Described University of Wisconsin Sharps Needles, lancets, etc., including sterile syringes Bulk amounts of blood and body fluids OSHA’s drippable, pourable, squeezable, flakeable applies to absorbents Microbiological laboratory waste Human tissue Zoonotic infectious waste Diseases that can be transmitted from animals to humans

31. Waste disposal – needles and other sharps University of Wisconsin Sharps are items that are either designed to cut or puncture skin or are sharp enough to break the skin and are contaminated with human blood and body fluids. Examples: Needles (new and used) Syringes with needles (new and used) Lancets (new and used) Scalpels and razor blades (new and used) Contaminated broken vials, hematocrit tubes, Pasteur pipettes and laboratory slides All sharps must be placed in a sharps container for disposal.

32. Broken Glassware University of Wisconsin Broken glassware is not an infectious waste unless it is contaminated with blood or other infectious material. However, broken glassware and other sharp objects (that are not infectious) should not be placed in the regular trash for disposal. Place in a designated broken glass container for disposal. This will protect waste handlers from accidental cuts and punctures.

33. Batteries University of Wisconsin All batteries must be recycled or managed as hazardous waste. Do not throw batteries in the normal trash. The only current exception is alkaline batteries which can be placed in the normal trash for disposal. UW-Oshkosh has an active battery recycling program. Contact Environmental Health and Safety for additional information.

34. Example 1 University of Wisconsin You work in a lab where the only hazardous waste generated is spent COD waste – a mix of dilute sulfuric acid and aqueous mercury. You generate approximately 10 gallons of this waste per month. What is your generator status?

35. Example 1 - Answer University of Wisconsin You generate ~ 80 lbs of waste per month assuming one gallon of aqueous liquid = 8 lbs. If this is the only campus hazardous waste stream, you are a very small quantity generator. Note: Hazardous waste generated in one laboratory on campus is only one of several waste streams that must be considered when determining UW-Oshkosh generator status.

36. Example 2 University of Wisconsin Consider again the waste COD mentioned in the previous example. Can you legally precipitate the mercury out of solution minimizing the amount of mercury waste generated?

37. Example 2 - Answer University of Wisconsin Both EPA and WI DNR require a specific permit for treating hazardous waste. In most situations, precipitation is considered waste treatment. UW-Oshkosh does not have a waste treatment permit. Consult with Environmental Health and Safety before considering precipitation as a treatment option. Note: EPA and WI DNR also consider evaporation a treatment procedure subject to permit. Open containers of hazardous waste (resulting in evaporation of contents)could be viewed as treatment of waste and result in a citation and fine not to mention a possible violation of the EPA Clean Air Act. Note: Elementary neutralization and silver reclamation are two treatment options that currently do not require a specific treatment permit from EPA or DNR.

38. Example 3 University of Wisconsin You generate two liters of a waste concentrated acid solution (pH = 1). Can you legally neutralize the acid and dispose of the waste down the sanitary sewer?

39. Example 3 - Answer University of Wisconsin EPA and WI DNR require a specific license for treatment of hazardous waste. One exception to this requirement is elementary neutralization. One can legally neutralize an acid or base solution and then pour down the sanitary sewer for disposal. However, do not attempt to do this unless: You have experience with the process. Call Environmental Health and Safety with questions. Have appropriate facilities (you may need a fume hood for some neutralizations). Neutralization may generate significant heat and fumes creating safety hazards. Wear appropriate personal protective equipment. Keep a log of quantities neutralized and report to Oshkosh Environmental Health and Safety.

40. Example 4 University of Wisconsin You generate some solvent soaked rags. The solvent has a flash point of 85 o F. Must this be treated as hazardous waste?

41. Example 4 - Answer University of Wisconsin These solvent soaked rags must be handled as hazardous waste. Consider the following to eliminate this hazardous waste stream: Eliminate use of the solvent Substitute a solvent with a higher flash point (a solvent with a flash point > 140 o F Contract with a vendor to launder and re-use the rags. (Do not do this in your home or campus washing machine.)

42. Example 5 University of Wisconsin You are the hazardous waste manager for a small university and have maintained SQG status for 5 years. An art professor calls you and says that, for safety reasons, she will no longer be using cyanide plating solutions in her studio and has 3 one-pint bottles of unused cyanide solution to get rid of. Will this change your generator status?

43. Example 5- answer University of Wisconsin Unused cyanide plating solution is an acute hazardous waste and will be assigned a “P” waste code. Let’s assume the weight of the three bottles exceeds 2.2 lbs. This puts the entire campus in a large quantity generator category. Notify Environmental Health and Safety immediately. They will need to schedule a waste pickup sooner than planned, ensure the campus follows the additional rules for large quantity generators, and work with WI DNR staff to ensure transition back to a simpler small quantity generator status after the waste leaves campus.

44. Example 6 University of Wisconsin A research laboratory at your college regularly generates waste formalin which you have determined is a hazardous waste. How often must this waste be moved from the lab to the campus central hazardous waste storage site? Answer Satellite accumulation (SAA) provisions allow generators to accumulate up to 55 gallons of hazardous waste ( or 1 quart of acute hazardous waste) in containers that are: At or near any point of generation, and Under the control of the researcher This situation qualifies for SAA. Use UW-Oshkosh hazardous waste label for container. Once 55 gallons is accumulated, date the container and move excess over 55 gallons to the campus central hazardous waste storage area within three days. Call Environmental Health and Safety for assistance.

45. Example 7 University of Wisconsin What is wrong with this picture?

46. Example 7 - answer University of Wisconsin Hazardous waste containers must be closed at all times except when adding or removing contents. In this picture, it appears that the funnel has been left in place for convenient additions – but this violates the requirement of keeping the container closed at all times.

47. Conclusion University of Wisconsin This concludes Hazardous Waste Management Module 2. Proper hazardous waste management is one part of a compliant laboratory safety program. Contact Environmental Health and Safety Department for additional information and assistance with hazardous waste and lab safety issues.