Learn more about the correct way to dispose of regulated waste.
Our Science Laboratory Chemical Hygiene Plan (hereafter referred to as the Chemical
Hygiene Plan or CHP) provides written policies as required primarily by OSHA (PESH2)
but it also provides guidance on regulations promulgated by other agencies such as
EPA. While laboratory accidents such as spills cannot be completely avoided, taking
a safety conscious approach (SCA) will serve to limit the severity of an accident
and will greatly reduce the risk of an accident resulting in serious damage to property
or injury to staff, students, visitors and/or volunteers.
No hazardous, regulated, or industrial wastes may be dumped down or discharged to
any sanitary or storm drain/sewer.
Only trained personnel or those working under the supervision of trained personnel
may manage waste. Waste Management Training is required if an employee has the responsibility
for:
Determining what is a hazardous waste
Adding hazardous waste into accumulation containers
Transporting hazardous waste from accumulation points to permanent storage
Inspecting hazardous waste storage areas or responding to spills involving hazardous
wastes
New employees may not manage or handle hazardous waste unless supervised.
Hazardous wastes may be accumulated in areas close to the point of generation (accumulation
area) and that are under the control of the area supervisor.
The waste container must be in good condition. If the waste container holding the
hazardous waste is not in good condition, or if it begins to leak, bulge, rust or
is otherwise damaged, the hazardous waste from this container must be transferred
to a container that is in good condition.
Shelves used to hold waste containers must be in good condition and have a lip.
Flammable storage cabinets must be used for any room having in excess of 25 gallons
of flammable material.
A container must be used that is made with or lined with materials, which will not
react with, and are otherwise compatible with, the hazardous waste to be stored, so
that the ability of the container to contain the waste is not impaired.
Containers of incompatible materials must be segregated. (Refer to attached Incompatibility
Chart)
A container holding hazardous waste must always be closed during storage, except when
it is necessary to add or remove waste.
A container holding hazardous waste must not be opened, handled, or stored in a manner,
which may rupture the container or cause it to leak.
In general, store materials and equipment in cabinets and on shelving provided for
such storage. Avoid storing materials and equipment on top of cabinets, and never
within 18 inches of the ceiling in sprinklered areas. Label all chemical containers
appropriately. Avoid storing chemicals on bench tops or in fume hoods. Store flammable
materials in a flammable storage cabinet. Separate chemicals into their organic and
inorganic families and then related and compatible groups. Separation of chemical
groups can be by different shelves within the same cabinet if spill containers are
used. Do not store chemicals alphabetically as a general group. This may result in incompatibles appearing together on a shelf.
All containers/liners that held acutely hazardous material must be triple rinsed with
an appropriate solvent to ensure that the container has been properly decontaminated
before disposal. Depending on the nature of the materials, the rinse solvent may have
to be disposed of as chemical waste.
After the containers/liners have been triple rinsed, deface the original label with
an indelible marker or by placing a "Triple Rinsed" sticker over it. Drums can be
marked as empty by writing “EMPTY” with an indelible marker in a color that will be
visible over the original label. Place a “Triple Rinsed” label on all containers.
Replace bungs, caps or other sealing devices and tighten. Remove grease, oil and chemical
residues from the exterior of all containers.
All containers/liners that held hazardous material other than acutely hazardous material
must be triple rinsed with an appropriate solvent to ensure that the container has
been properly decontaminated before disposal or empty the container so that no more
than one inch of material remains in the container or liner. Depending on the nature
of the materials, the rinse solvent may have to be disposed of as chemical waste.
One gallon or smaller decontaminated glass and plastic bottles should be recycled
whenever possible.
Under no circumstances may a container labeled with the international radioactive
symbol or the words “Hazardous Waste” be disposed of in the regular trash.
Do not discard bungs or make holes in drums. Incomplete or damaged drums are difficult
to transport safely, cannot be recycled and require costly disposal procedures.
Metal 5-gallon drums, that cannot be reused, should be triple rinsed and Environmental
Health and Safety should be contacted for disposal.
Metal 55-gallon drums, that cannot be reused, should be triple rinsed and Environmental
Health and Safety should be contacted for disposal.
Before putting non-regulated waste that might be mistaken for a laboratory chemical
in the trash, label the bag with the contents and the words "non-hazardous" and put
a note on the bag reading: "For questions, contact: (Your name here)."
Contaminated Equipment
When equipment has been contaminated, the generator should attempt to decontaminate
equipment prior to requesting disposal as chemical waste. If a contractor performs
decontamination, equipment will be certified as clean before disposal. Contact the
Department of Environmental Health and Safety for information on decontamination methods
and assistance.
Equipment may intrinsically contain toxic chemicals (e.g., electrical transformers
and capacitor units may contain PCBs) requiring special handling procedures, testing
and disposal as chemical waste if the toxic chemicals cannot be removed. Contact the
Department of Environmental Health and Safety for assistance prior to moving units
or handling such equipment.
Gases
Close cylinder valves and tighten and replace safety caps on cylinders.
If the container is empty and not pressurized, write “Empty” on the container label.
Identify the gas that was previously held in the container.
Contact the supplier for pickup of empty cylinders.
Contact EH&S for removal of orphaned cylinders.
Always use a hand truck to move large, compressed gas cylinders.
Paint
Cans of oil/solvent-based paints still containing liquids must be disposed of as chemical
waste if they do not meet the requirements of “empty” as described above under the
Empty Container Management Section. Waste paint may be accumulated at the Paint Shop
in the Service Building and managed as a flammable liquid as described above. Waste
Paint may not be left open to dry. This is an EPA Air Quality Violation.
Photographic Wastes
All photographic wastes and unused photographic chemicals should be handled according
to the characteristics exhibited by the material. Be aware that some of these wastes
may meet the definition of hazardous waste and must be managed as such.
If a silver recovery system is in use, see manufacturers instructions.
Surplus Chemicals
At the beginning and end of each semester, laboratories should inventory chemicals
and make arrangements for removal of any chemicals no longer of use or outdated.
Surplus chemicals should be properly sealed, labeled and packaged for transfer to
the Hazardous Waste Disposal Room.
Temperature Sensitive
Wastes containing chemicals that require a special temperature range must be stored
at the appropriate required temperature.
Advise EH&S concerning the storage locations and quantities of temperature sensitive
waste on-hand.
Water Reactive
Make sure all containers are tightly closed. Seal caps on with a parafilm or filament
tape. Certain water reactive chemicals, such as sodium and potassium, should be stored
in mineral oil.
Used Oil & Other Combustible Petroleum-Based Products
Used pump oil, automotive oils and oil filters, or used oil from a known origin will
be handle as non-hazardous, non-DOT-regulated waste. Contact EH&S for disposal of
this material and the Garage.
Containers of waste oil with unknown origin will be tested for the presence of polychlorinated
biphenyls (PCBs) by an outside NYS certified Laboratory. Oils that indicate the presence
of PCBs will be sent out as hazardous waste PCB oil.
Miscellaneous
Any items contaminated with a hazardous chemical are assumed to have the same hazardous
properties as the chemical, unless the items can be decontaminated or testing demonstrates
that the items are not hazardous. This includes items used to clean up hazardous chemical
spills. The type of decontamination or testing that has to be performed depends on
the nature of the hazardous material. Contact EH&S for information on decontamination
procedures and testing requirements. If the items cannot be decontaminated and testing
is not performed, the contaminated items must be treated as chemical waste.
Discarded chemical products, off-specification chemicals, container residue and spill
residues from acute hazardous wastes are assumed to have the same chemical properties
as the chemical and cannot be decontaminated. These wastes must be dispose of as acutely
hazardous wastes (40 CFR part 261.22 Acute Hazardous Wastes - P listed wastes)
Wastes of Unknown Composition
Wastes of unknown or incorrectly described composition present difficult handling
and disposal problems, and can be expensive. “Orphan” reaction mixtures and unidentified
chemicals left by departed laboratory workers are the most frequent source of unknowns.
All stored reaction mixtures should be labeled with the name (not chemical formula)
and chemical concentration of the chemical compound, date they were formed, and the
name of the person who mixed it. Laboratories are encouraged to institute a checkout
procedure that requires departing workers to identify all reaction mixtures and unlabeled
chemicals that they have not discarded before leaving at the end of each semester.
In the case of a vacated department worker, the responsibility for the proper disposal
of abandoned chemicals, identifiable and unidentifiable, lies with the worker's department.
SUNY Plattsburgh's waste disposal contractor will perform limited field screening
of unknown chemicals contained in small lab size containers, less than 1 gallon or
1 pound solid, to determine proper disposal classification.
Unknown chemicals present within containers greater than lab-pack size will require
analytical testing for the following parameters:
pH
flashpoint
reactivity
corrosivity
priority pollutant metals
volatile organic compounds
semi-volatile organic compounds
pesticides
herbicides
polychlorinated biphenyls (PCBs)
Mixed Wastes
Any wastes that exhibit multiple hazardous properties will be considered mixed wastes.
Due to increasingly restrictive environmental initiatives and regulations concerning
the acceptance and disposal of wastes contaminated with mixed hazardous materials,
these wastes may warrant assessment by the EH&S Department.
Asbestos Wastes
Any discarded material that contains greater than 1% asbestos by weight. Examples
of asbestos contaminated waste items encountered at SUNY Plattsburgh are:
Thermal insulation such as pipe fittings, boiler and duct insulation.