Hazardous Waste Management & Waste Minimization Training

April Case Sr. Environmental Specialist Environmental Health and Safety Phone #: 974-5084 acase3@utk.edu

Learning Objectives

Individuals who generate or handle hazardous waste will be able to: 1. Identify hazardous waste 2. Ensure it is properly managed

Training Requirements

The US Environmental Protection Agency (EPA) and the Tennessee Department of Environment and Conservation (TDEC) require documented training for individuals who handle and/or generate hazardous waste. There is initial training, followed by annual refresher training. Please contact EHS for training information.

Proper Waste Management

Proper Waste management is Essential: Maintain Healthy Work Environment Ensure compliance Reduced costs (proper I.D., generation reduction, and disposal procedures) Promotes efficiency in research Sets good example for community

Definition: Hazardous Waste

Hazardous Waste is defined by the EPA as:

A material that no longer has an intended value. Exhibits properties that make it dangerous or potentially harmful to human health or the environment. Can be in the form of liquid, solid, gas or sludge.

Definition: Hazardous Waste

Hazardous Waste can

be the by-products of manufacturing processes or simply discarded commercial products, like cleaning fluids or pesticides.

Sources of Hazardous Waste in Laboratories:

Spent solvents and non-empty solvent containers. Testing Samples Unused Reagents Reaction Products Absorbents and spill cleanup Contaminated materials (i.e. glassware, gloves; pipet tips) Used Chromatography vials Gas Cylinders

Hazardous Waste Exclusions

The following categories of waste are not considered hazardous waste for this program:
1. Sewage 2. Regular trash 3. Universal waste (fluorescent bulbs, batteries) 4. Radioactive and biohazard

Improper Disposal Methods

Hazardous waste must not be discarded by: Sanitary Sewer Storm Sewer Regular Trash Mixed with Biohazard Evaporation (a container without a lid implies evaporation for volatile substances) Mixing With Nonhazardous Waste

Waste is Hazardous if
It is listed as a hazardous waste in the Title 40 Code of Federal Regulations (CFR), which is enforced by the EPA. It exhibits one or more of the characteristics described on the next slide.

4 Categories of Hazardous Waste:

Corrosive (pH less than 2.0 or greater than 12.5) Ignitable also known as flammable; oxidizers Reactive (i.e. shock sensitive, water reactive) Toxic very broad category; includes metals (Mercury), organics (Methylene Chloride)

4 Categories of Hazardous Waste: Corrosives

Corrosive (pH less than 2.0 or greater than 12.5) Examples include: Hydrochloric acid, Sulfuric Acid, Sodium Hydroxide

4 Categories of Hazardous Waste: Ignitables

Ignitable also known as flammables; Examples include: Acetone, Toluene, Xylene Any waste material with a flashpoint < 140 F. Includes oxidizers (Sodium nitrate, potassium permanganate)

4 Categories of Hazardous Waste: Reactives

Reactive: Includes shock sensitive (lithium and sodium, water reactive (calcium carbide, spontaneously combustible, peroxideforming (ethyl ether) and potentially explosive chemicals (dry picric acid).

4 Categories of Hazardous Waste: Toxics

Toxic very broad category; Includes metals, such as mercury, lead and compounds such as Methylene Chloride, Chloroform. Includes acutely toxic chemicals, which are very dangerous (i.e. Sodium Azide, arsenic and cyanide compounds. See EHS web-site for list of acutely toxic hazardous waste chemicals.

How do you know if a material is considered a hazardous waste?

The burden of proof is on the generator, not the disposal contractor. The material safety data sheet (MSDS) or original container labeling are good starting points. Unlabeled containers present a number of problems When in doubt, assume worst case and manage as a hazardous waste. Contact EHS for guidance.

Proper Labeling
Containers must be labeled to include all hazardous components, as soon as waste is added to the container. Labels are available from EHS. Tags are also available for small containers. Do not complete the accumulation start date section of the label this will be done when the waste is brought to the waste room.

Proper Labeling
When labeling, do not use abbreviations Do not use general terms or nomenclature such as: Waste Solvent Formula Trade names Containers must be labeled to include all hazardous components.

Example of Completed UT Hazardous Waste Label:

Bad Example:

Do not use formulas, or draw molecular structure of the chemical. Make sure the label is legible and easy to read.

Bad Example:

When labeling, do not use chemical formulas. Write out the chemical name in its entirety on the label.

Hazardous Waste

Hazardous Waste

Hazardous Waste

HPLC Waste Bottles

Several TDEC violations were cited for HPLC bottles as open containers on campus. Make sure to use secondary containment.

Unknowns:
Unknowns cost up to 10x more to dispose than the original purchase price of the chemical. In 2001, UT Knoxville spent over $70,000 to identify unknowns (does not include disposal costs).

Containers
Contents must be compatible with container material Problems:

Certain solvents placed in plastic containers Hydrofluoric acid in glass containers

Containers-Adding Waste

When adding hazardous waste to a container, only add the constituents that are specifically listed on the waste label. Be careful not to mix incompatibles Minimize void space in containers by assuring that collection containers should be filled to capacity (with a little head room for expansion) before requesting disposal or combining two containers of identical material into one.
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Containers

For container selection - look at original container material The container must be closed Must be in good condition (no cracks or rust) Clean on outside Must be leakproof

Containers
Maximum amount that can accumulate in the lab is 55 gallons of hazardous waste or 1 kilogram of acutely toxic waste. If you accumulate more than the maximum amount, the waste needs to be removed from your lab no later than 3 days after these maximum amounts are reached.

PROBLEM: Open Waste Container. Waste stored in readily recognizable food container. No UT hazardous waste label.

SOLUTION: Place in appropriate waste container that is closed and properly labeled.

Dry Solids
Bags are ok for dry solids, as long as the bags are sealed closed and labeled properly and there are no free-flowing liquids. Sharps (needles) must go in puncture-resistant containers. Do not place dry solids cont. with chemicals in red or orange biohaz bags. If the waste is both chemically and biologically contaminated, please contact EHS or Office of Biosafety with questions.

Bad Example:
Make sure dry waste is stored in a closed waste container. This was discovered by TDEC and was written as an NOV (Notice of Violation).

Waste Sharps
Two Types of Sharps: Biohazard Chemical Biohazard sharps: You must supply your own containers (red boxes) Bring Containers to Waste Room for collection

Waste Sharps
Chemical sharps: No biohazard symbols or red

boxes for these sharps, or biohazard bags All hazardous waste labeling requirements are applicable for the chemicals contaminating these sharps (keep compatible)

Good Example:

These chemically contaminated sharps are labeled properly and being stored in an appropriate waste container.

Ethidium Bromide Gels

EPA does not consider ethidium bromide hazardous waste, but UTK handles as special waste. UTK requires Ethidium Bromide waste to be labeled with UT waste label. Ethidium Bromide waste can be stored in bags as long as there are no free flowing liquids. You can dry gels in fume hood before bringing to waste room.

Ethidium Bromide Gels

Best container for storage and disposal of Ethidium Bromide gel waste: Sealable plastic containers Next best option: Large mouth containers

Ethidium Bromide Liquids

Dilute aqueous solutions containing <0.5 mg/ml ethidium bromide can be filtered or deactivated using either charcoal filtration (EHS preferred method), or chemical deactivation. Please see EHS web-site for more guidance. Concentrated solutions (>0.5 mg/ml) should be collected for disposal as hazardous waste. Any solutions that also contain heavy metals, organics, cyanides or sulfides should be collected and disposed of as hazardous waste.

Waste Segregation

Segregate by Hazard Categories: Flammables Oxidizers Acids Bases Toxic Combination (i.e. Nitric Acid; Glacial Acetic Acid)

Waste Segregation: Common Examples

Cyanide salts and acid Hydrogen Cyanide and Sulfuric Acid Flammables and Oxidizers: Acetone and Sodium Nitrate Acids and Bases Hydrochloric Acid and Sodium Hydroxide Mercury and mercury compounds Unstable just from long shelf life Ethers, Sodium Azide, Picric Acid Check EHS web-site for partial list of incompatible hazardous chemicals.

Waste Segregation:

Segregate Use Cabinets This is ideal-flammable and corrosive waste. Use Dish pans or Tubs Space is premium, so in the event of spills this prevents reaction and allows time to clean it

Waste Segregation:

What NOT to do: Separate by shelf one on top of the other Opposite side of fume hood without catch basin Alphabetical chemical storage systems It is best to segregate, then alphabetize.

Items of Concern:

What NOT to do: Separate by shelf one on top of the other Opposite side of fume hood without catch basin Alphabetical chemical storage systems Segregate then alphabetize

Ether
All Ethers MUST be dated when opened Use within 1 year

Ether is one of the dirty dozen responsible for more than its share of accidents, due to extreme flammability. Handle in fume hood, and pay attention to heat and flame sources.

List of Chemicals with Peroxide Hazards

Peroxide Hazard on Storage Discard After Three (3) Months Isopropyl ether Vinylidene chloride Sodium amide Peroxide Hazard on Concentration Discard After One (1) Year Ethyl ether Dioxane Methyl isobutyl ketone (glyme) Vinyl ethers Diacetylene Cumene Cyclohexane Hazardous to Peroxide Initiation of Polymerization Discard After One (1) Year Styrene Tetrafluoroethylene Vinyl acetylene Vinyl chloride Chlorobutadiene (Chloroprene) Indene Butadiene Chlorotrifluoroethylene Vinyl acetate Vinyl pyridine 9,10-Dihydroanthracene Dibenzocyclopentadiene Tetrahydrofuran Acetal Ethylene glycol dimethyl ether Dicyclopentadiene Metal acetylene Tetrahydronaphthalene t-Butyl alcohol Divinyl acetylene Potassium metal

Definition of Empty Container:

An empty container is defined by the EPA as one where: All product has been emptied using common practice No more than 1 inch of product residue remains in container No more than 3% by weight of the product remains (containers <110 gallons)

Empty Containers

Empty containers (bottles, cans, jars, bags, etc) that once held a hazardous substance may be discarded in the regular trash and are not considered hazardous waste Exception Empty Containers that held acutely hazardous materials are regulated as hazardous waste, unless they are triplerinsed (see EHS web-site for list of acutely hazardous chemicals). Examples include: sodium azide, cyanides, arsenic compounds, some pesticides, and acrolein.

Empty Containers

Make sure you deface any markings, such as DOT diamonds, and labels from empty containers.

Broken Glass

Place Broken Glass into a box, seal it, and discard it into a dumpster This ensures that housekeeping or anyone else downstream does not get hurt.

Satellite Accumulation Area

Satellite Accumulation Area: area in the lab where waste chemicals are stored. Must be designated with signs available from EHS

Sign to Identify Hazardous Storage Area:

Criteria for SAA:

Away from heat and sparks Close to waste generation area Away from incompatible materials Doesnt interfere with use of fume hood Out of the way, so wont get knocked over Easily cleaned and or secondary containment

Transporting Chemicals Safely on Campus

Be aware of the chemicals hazards. Hazardous chemicals must be attended at all times during transport. Wear appropriate PPE. Use Secondary Containment. Avoid using passenger elevators. Use a cart if needed. Avoid transporting chemicals in vehicles.

Spills & Emergencies

For minor spills, call EHS at 974-5084 if you feel you cannot handle the situation (during regular work hours). For major spills and other safety emergencies after hours, please call 974-9586 (Safety on-call number) or 911 if needed. Remember that any waste generated from a spill cleanup of a hazardous waste or chemical must be managed as a hazardous waste.
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Shipping Hazardous Materials

If you need to ship hazardous materials (dangerous goods) by land sea, or air (i.e. Fedex or UPS), please contact EHS. You must be IATA trained before shipping hazardous material.

Waste can be brought to the following locations:

Walters Waste Room (WLS) Room M-209 Wednesdays 1:00-2:00 p.m. SERF Waste Room @ loading dock on 2nd Floor: Wednesdays 2:00-3:00 p.m. EHS does not accept DEA Controlled Substances. Do not leave waste unattended!!!!

Hazardous Waste Violations

Violation of hazardous waste regulations can result in substantial fines to the university Waste generators can be fined as much as $50,000/violation/day, depending on the violation. TDEC and EPA conduct unannounced inspections on campus.

Top Hazardous Waste Violations found on campus by TDEC:

Open Containers lid not in place Hazardous Waste Labels missing, or incomplete 3. Hazardous Waste Determination waste has not been characterized 4. Personnel Training no documentation 5. Satellite Accumulation Area no sign
1. 2.

UTKs Hazardous Waste Reduction and Waste Minimization Policy

State regulations require the university write and implement a hazardous waste reduction and waste minimization plan. In 2007, UT Knoxville disposed of approximately 60,000 pounds of hazardous waste at a cost of $230,042.05.

Why should we reduce hazardous waste generation?

Lowers waste disposal costs and compliance costs Reduces long term liability for disposal Reduces costs of chemical purchases Reduces health hazards Promotes environmental awareness Prevents pollution and conserves resources

Hazardous Waste Reduction Ideas

Substitution with a non-hazardous substance Water-based solvents Alcohol thermometers instead of mercury-containing Detergent glass cleaner instead of chromic acid Microchemistry or reduced volumes Avoid mixing or contamination with non-hazardous substances Distillation of solvents

More Hazardous Waste Reduction Ideas.

Elementary neutralization acid/base Administrative Controls

inventory management spill prevention

Phase separation (example one liquid floats and wont readily mix with another in the same vessel)

Chemical Exchange
No longer needed by the user Still usable or has value Often in their original containers and unused The chemical has not expired and has factory seal in place Has no visible signs of degradation UT Chemical Exchange is found at: http://www.pp.utk.edu

Hazardous Waste Reduction Activities:

Contact EHS (x5084) to discuss hazardous waste reduction activities even activities that have occurred in the past We need to demonstrate and document hazardous waste reduction for compliance purposes. UTKs Hazardous waste minimization plan can be found on the EHS website in the Safety Manual.

Summary

Hazardous waste containers must be kept closed, properly labeled, in good condition, acceptable for the contents and properly stored. Labels and regulatory guidance are available from EHS (x5084) Strive for hazardous waste reduction and waste minimization If you have any questions, please contact EHS, or check the EHS web-site.

Quiz Time
To complete the Hazardous Waste Management and Minimization Training Module, please click here for the quiz