INTRODUCTION TO

HAZARDOUS
WASTE
MANAGEMENT
University of Alaska Fairbanks
Environmental, Health, Safety, and Risk Management
May 2013

COURSE OUTLINE
Overview of hazardous materials

regulations
Hazardous waste at UAF
What is hazardous waste?
What do I do with my hazardous waste?
Emergency response

OVERVIEW OF
HAZARDOUS
MATERIALS
REGULATIONS

HAZARDOUS MATERIALS
REGULATIONS
Hazardous materials are regulated by three
primary government agencies:
Department of Transportation (DOT)
Title 49, Code of Federal Regulations (49 CFR)
Occupational Safety and Health Administration (OSHA)
Title 29, Code of Federal Regulations (29 CFR)
Environmental Protection Agency (EPA)
Title 40, Code of Federal Regulations (40 CFR)

The International Fire and Building Codes also regulate hazardous materials

HAZARDOUS MATERIALS
REGULATIONS (CONT.)
DOT regulations direct us how to properly package,

identify, and label hazardous materials and hazardous

wastes for transportation
OSHA regulations tell us how to protect ourselves from the
effects of hazardous materials in the workplace
EPA regulations tell us how to protect our environment

DOT REGULATIONS
DOT classifies hazardous materials into 9 primary hazard
classes which are subdivided into multiple subsidiary risk
groups. You dont need to memorize these, but the
primary hazard classes are: Class 1: Explosives
Class
Class
Class
Class
Class
Class
Class
Class

2: Compressed Gases
3: Flammable Liquids
4: Flammable Solids
5: Oxidizers
6: Poisons and Toxics
7: Radioactive materials
8: Corrosives
9: Miscellaneous hazardous
materials that dont fit any other
hazard class (i.e. dry ice)

OSHA REGULATIONS
OSHA regulations include the following standards:
Hazard Communication Standard (Hazcom, Right-to-Know)
Occupational Exposure to Hazardous Chemicals in Labs,

including requirements for Chemical Hygiene Plans

Respiratory Protection Standard
Confined Space Entry Requirements
Asbestos Standard
Lead (Pb) Standard
Bloodborne Pathogen Standard
Formaldehyde, Benzene, and Methylene Chloride standards

OSHA also establishes Permissible Exposure Levels (PELs) for hazardous chemicals

EPA REGULATIONS
Congress placed into law several acts that the
EPA uses to establish regulation to protect our
environment:
Resource Conservation Recovery Act (RCRA)
Clean Air Act
Clean Water Act
Toxic Substances Control Act (TSCA)
Emergency Planning & Community Right-to-Know Act

(EPCRA)
Comprehensive Environmental Response,
Compensation and Liability Act (CERCLA)

HAZARDOUS WASTE REGULATIONS

EPA regulates hazardous waste in Alaska by
authority of the Resource Conservation
Recovery Act. RCRA controls include:
Identification of hazardous wastes
Tracking wastes from cradle to grave
Setting standards for generators of wastes,

transporters of wastes, and Treatment, Storage &

Disposal Facilities

PRIMARY RCRA REQUIREMENTS

RCRA requires that you:
Label containers with a description of their contents
Store only the permissible volume of waste in your lab
Ensure lids and caps are securely fastened at all times,

except when putting wastes into the containers

Ensure all materials are properly segregated
Use containers that are compatible with your waste
Use intact containers (no cracks, holes, etc.)
Ensure that spills and overfills do not occur
Ensure that mismanagement does not occur

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RCRA REQUIREMENT FOR

The
purpose of this training is to comply with
TRAINING

requirements set forth by the EPA under 40 CFR

265.16 (Personnel Training)
The scope of the training is to ensure that UAF
personnel who use chemicals:
1. Understand how to identify hazardous wastes
2. Understand how to package and label hazardous
wastes
3. Understand how to have their hazardous materials
disposed
4. Know how to respond effectively to emergencies

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RCRA REGULATORY INSPECTIONS

EPA conducts unannounced Compliance

Evaluation Inspections
In the past, UAF facilities have been
inspected annually
Our goal is to comply with all regulations

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HAZARDOUS
WASTE AT UAF
An overview of sources of
hazardous waste at UAF, and
its ultimate fate

13

SOURCES OF HAZARDOUS WASTE

AT UAF
Sources of hazardous wastes (HW) at UAF
include:
Research and academic laboratories
Shops and repair facilities
Art and theater departments
Facility maintenance and grounds
Power Plant operations
Experimental Farm operations

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HAZARDOUS WASTE
GENERATORS
The RCRA definition of a HW generator is:
Any person, by site, whose act or process produces
hazardous waste identified or listed in 40 CFR 261.3.

Generators are classified by the volume of HW

that they produce per month:
CESQG = Conditionally Exempt Small Quantity
Generator
SQG
= Small Quantity Generator
LQG
= Large Quantity Generator > 1000 kg/month or
>1 qt. of acutely hazardous waste/month

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UAFS WASTE GENERATOR

STATUS
The UAF main campus is regulated as a

Large Quantity Generator

UAFs extended sites are regulated as
Conditionally Exempt Small Quantity
Generators
Examples: Toolik Field Station, Palmer

Research Farm, Kodiak Seafood & Marine

Science Center, Seward Marine Center, Lena
Point Fisheries Facility (Juneau)

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HAZARDOUS WASTE
MANAGEMENT AT UAF
EHSRM assists UAF waste generators with

waste disposal needs

Hazardous Materials Facility (HMF) stores waste
and serves as UAFs Central Accumulation Area
(CAA)
RCRA-regulated hazardous wastes are shipped
Every 90 days from the HMF
By EPA-permitted transporters to EPA-permitted treatment,

storage, and disposal facilities

Annual costs: $125,000 for disposal; $400,000 total cost

of hazmat program at UAF

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WHAT IS
HAZARDOUS
WASTE?

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EPA DEFINITION OF A SOLID

WASTE
EPA begins by defining all waste as a solid waste
(including solids, liquids, gases, and semi-solids)
40 CFR 261.2 provides the definition of solid
waste:

(a)(1) A solid waste is any discarded material that is not

excluded by 261.4(a) or that is not excluded by

variance granted under 260.30 and 260.31.
(2) A discarded material is any material which is:

(i) Abandoned, as explained in paragraph (b) of this section; or

(ii) Recycled, as explained in paragraph (c) of this section; or
(iii) Considered inherently waste-like, as explained in

paragraph (d) of this section; or

(iv) A military munition identified as a solid waste in 40 CFR
266.202.

No need to memorize that!

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EPA DEFINITION OF A HAZARDOUS

WASTE (CONT.)
If the waste material meets certain criteria,

and is not somehow exempted or excluded

from regulation, it may be a RCRA-regulated
HW
The legal definition of HW is found in 40 CFR
261.3
(a) A solid waste, as defined in 261.2, is a

hazardous waste if:

(1) It is not excluded from regulation as a hazardous waste

under 261.4(b); and

(2) It meets any of the following criteria: (continue to next

slide)
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EPA DEFINITION OF A HAZARDOUS

WASTE (CONT.)
(i) It exhibits any of the characteristics of hazardous waste

identified in subpart C of this part. However, any mixture of

a waste from the extraction, beneficiation, and processing of
ores and minerals excluded under 261.4(b)(7) and any
other solid waste exhibiting a characteristic of hazardous
waste under subpart C is a hazardous waste only if it
exhibits a characteristic that would not have been exhibited
by the excluded waste alone if such mixture had not
occurred, or if it continues to exhibit any of the
characteristics exhibited by the non-excluded wastes prior
to mixture. Further,
(Continue to next slide)

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EPA DEFINITION OF A HAZARDOUS

WASTE (CONT.)
for the purposes of applying the Toxicity Characteristic to

such mixtures, the mixture is also a hazardous waste if it

exceeds the maximum concentration for any contaminant
listed in table I to 261.24 that would not have been
exceeded by the excluded waste alone if the mixture had
not occurred or if it continues to exceed the maximum
concentration for any contaminant exceeded by the
nonexempt waste prior to mixture.
(Continue to next slide)

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EPA DEFINITION OF A HAZARDOUS

WASTE (CONT.)
(ii) It is listed in subpart D of this part and has not been

excluded from the lists in subpart D of this part under

260.20 and 260.22 of this chapter.
You dont need to memorize the definition of
a hazardous waste either!

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SO, IS YOUR WASTE A

HAZARDOUS
WASTE?
EPA regulations (40 CFR 261.2) require that a

hazardous waste determination be made on a solid

waste which has been generated
Even though you must manage your waste
appropriately, you dont have to decide what to
call your waste
UAF EHSRM Hazmat team will make final
hazardous waste determinations as outlined in
40 CFR 262.11
Lets look at the different categories as defined by the EPA

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CATEGORIES OF HAZARDOUS WASTE

Hazardous waste determinations are based
upon whether the material is a:
Characteristic waste

Listed on the D-list or TCLP (Toxicity Characteristic Leaching Procedure)

Listed waste

Materials specifically identified on one of the following lists: F, K, U or P

lists

Universal waste

Batteries, lamps, pesticides, mercury from thermometers

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CHARACTERISTIC WASTES
D001 Ignitable Wastes (flashpoint is less than

140 F) includes oxidizers

D002 Corrosive Wastes (pH less than or equal to
2 or greater than or equal to 12.5)
D003 Reactive Wastes (water reactive,
normally unstable materials, cyanides &
sulfides, etc)
D004 TCLP Wastes

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LISTED WASTES
F-listed wastes are from non-specific sources
Example: halogenated solvents used to degrease

equipment

K-listed wastes are from specific sources

Example: petroleum refining or pesticide manufacturing

U-listed wastes are toxic wastes

P-listed wastes are acutely hazardous wastes

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EXAMPLES OF U-LISTED WASTES

Acetaldehyde

1,4-Dioxane

Acetone

Ethyl acetate

Acetonitrile

Ethyl ether

Aniline

Formaldehyde

Benzene

Methyl alcohol

Bromoform

Methylene chloride

1-Butanol

Phenol

Chloroform

Toluene

U-listed chemicals are commonly found in UAF labs

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EXAMPLES OF P-LISTED WASTES

Allyl alcohol

Osmium tetroxide

Ammonium vanadate

Phenylthiourea

Arsenic acid

Potassium cyanide

Arsenic trioxide

Sodium azide

Carbon disulfide

Sodium cyanide

2,4-Dinitrophenol

Thiosemicarbazide

Fluorine

Vanadium oxide

Nitric oxide

Vanadium pentoxide

P-listed chemicals are also fairly common in UAF labs

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UNIVERSAL WASTES
Universal wastes include the following

materials that are commonly found in the

workplace
Batteries
Fluorescent lamps
Pesticides
Thermometers (containing mercury)

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UNIVERSAL WASTES:
BATTERIES
Used Battery collection containers (white

5-gallon buckets) are available at many

locations on campus
Contact your Lab Manager, CHO, Shop
Supervisor or EHSRM for more
information

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UNIVERSAL WASTES:
FLUORESCENT LAMPS
UAF recycles fluorescent and other lamps
Lamp shipments are made periodically to EcoLights

Northwest

The Facilities Services Electric Shop does the

vast majority of lamp replacement on campus

EHSRM can provide lamp collection boxes and
labels to you
Boxes must be labeled with the words, Universal Waste

Lamps, Waste Lamps, or Used Lamps to identify the

contents

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UNIVERSAL WASTES: PESTICIDES

If you have waste pesticides:
Fill out an online UAF Non-radioactive
Hazardous Materials Transfer Request.
Dont know how? Go to slide #41.

33

UNIVERSAL WASTES:
MERCURY THERMOMETERS
If you break a mercury thermometer:
DO NOT try to clean it up yourself ---- Call UAF Hazmat at

474-5617 immediately for assistance

Evacuate the area and keep traffic from walking through the

spill site
NEVER throw the material in the trash or dump it down the

drain

Dont need your mercury thermometers or wish to

exchange unbroken thermometers for similar, nonmercury thermometers, free of charge? Call EHSRM at
474-5197 to get more information.

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OTHER WASTE: AEROSOL CANS

Aerosol cans are considered hazardous waste under the

definition of Characteristic Reactivity

40 CFR Part 261.23: .capable of detonation or explosive
reaction if it is subjected to a strong initiating source or if heated
under confinement.

Often contain hazardous materials, either as the product

or as the propellant
Most aerosol cans, regardless of contents, can never be
completely emptied of propellant
Aerosol cans become a waste when
their contents are used up,
malfunction (i.e. fail to spray), or
when the contents are no longer needed

35

OTHER WASTES: USED OIL

Used oil means:
any oil that has been refined from crude oil, or any synthetic
oil, that
has been used and as a result of such use, is
contaminated by physical or chemical impurities (40 CFR
279.1)

Used oil must be:

Collected in clean containers in good condition (no leakers)
Storage and transfer containers must be marked with the

words Used Oil

Never add solvents, part washer fluids, carb cleaners, or
glycol to your used oil

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OTHER WASTES: USED OIL

(CONT.)

Keep the used oil container closed (lid in

place and secured) except when adding or
removing used oil
If you use a funnel for transfers, the
funnel must be removed when not in use
and the container capped
See slide #41 to make on online request
to have your used oil removed

37

WASTE IN YOUR
LAB
What do I do with my wastes
and unwanted chemicals?

38

SATELLITE ACCUMULATION
AREAS
Each lab that generates waste is referred

to as a Satellite Accumulation Area

(SAA)
When EHSRM removes the waste from a
SAA, it is transferred to the UAF Hazmat
Facility or Central Accumulation Area

39

WASTE STORAGE LIMITS FOR

SAAS
For SAAs, the waste storage limits are:
Up to 55 gallons of a hazardous waste
Up to 1 quart (1 liter) of a P-listed waste
50 gallons of waste at a SAA will likely be in
violation of Fire & Building Codes

Note: you do not need to accumulate 55 gallons or

1 quart of
P-listed waste before requesting waste removal!

40

TO MAKE A WASTE REMOVAL

REQUEST
As of April 2012, the Division of Hazardous Waste at

EHSRM is using an online hazardous waste pick up

request. Please discontinue using the old triplicate paper
hazardous waste transfer request forms.
If you have not been trained in the use of the online

request, call 474-5197 to schedule a training session. Or

go to the EHSRM website for more information:
http://www.uaf.edu/safety/laboratory-safety/chemical-inventory/

Remember: There is no charge to your lab for chemical

waste disposal

41

TAKE-HOME
MESSAGES
What you need to
remember

42

WASTES: CONTAINERS AND STORAGE

Only use containers that are compatible with the materials

to be collected
Always label containers with a description of their contents
Dont store incompatible materials together
Do not store wastes in the fume hood. Store in the

appropriate storage cabinet (e.g., flammable, acid)

Provide secondary containment for liquid wastes
Always keep the container closed (lid firmly secured)
A funnel in an open bottle is NOT a lid

Check waste storage areas regularly (weekly).

Inspect containers to make sure they arent getting brittle

or starting to crack

43

BEFORE YOU START A PROJECT

Plan ahead
Is there a product or procedure available that will

accomplish the task w/o generating a hazardous waste?

Strive for waste minimization
Only make as much solution as you need
Substitute less hazardous chemicals if possible
Use microscale chemistry techniques

Before purchasing chemicals, log onto your EHS

Assistant online inventory and click on the Surplus

Chemicals button at the top of the main page. Contact
EHSRM at 474-5617 to request transfer of surplus
chemicals.

44

OTHER THINGS TO THINK ABOUT

Check the P-list - if you plan to generate a

P-listed waste, contact your Chemical

Hygiene Officer, Lab Manager or EHSRM
Never combine wastes
If you dont generate them together as part of a

procedure, then do not mix them.

May create hazardous reactions in the bottle (worst-case

scenario), or make it more expensive for us to dispose of

it (not a good scenario, but at least it didnt blow up)

45

EMERGENCY
RESPONSE
Chemical spills, release of
hazardous materials, fires,
and evacuation

46

CHEMICAL SPILLS
Report all spills to UAF Dispatch (474-7721) or call

911 if there is an immediate threat of harm to life

or property
Dispatch will call EHSRM Hazmat Section or the
FNSB Hazmat Team, if necessary, to request
assistance with spill cleanup
Depending on the nature of the spill, you may be
asked to complete the UAF Oil and Hazardous
Substance Spill Reporting Form (available from
EHSRM)

47

CHEMICAL SPILLS (CONT.)

If you have not been trained and/or do not have

the appropriate personnel protective

equipment, please call for assistance!
Never put yourself or others at risk to cleanup a
spill!

If you dont knowdont go

48

EMERGENCY PROCEDURES:
FIRE
Activate the nearest fire alarm pull station and

call 911
Evacuate the building and go to the Evacuation
Assembly Point or designated area of safe
refuge
Advise emergency personnel of anyone still
inside the building
Do not re-enter the building until authorized by
emergency personnel

49

EMERGENCY PROCEDURES: RELEASE

OF HAZARDOUS MATERIALS
Call 911 in the event of an emergency or if

anyone is in danger
Move away from the site of the hazard to a safe
location
Follow the instructions of emergency personnel
Alert others to stay clear of the area
Notify emergency personnel if you have been
exposed or have information regarding the
release

50

EMERGENCY PROCEDURES:
EVACUATION
Know the evacuation procedures and evacuation route

information for your area

Evacuate the building using the nearest safe exit
Do not use elevators!
Take personnel belongings (keys, purses etc., but dont put
yourself or others at risk by delaying evacuation)
If possible, secure any hazardous materials or equipment
Follow the directions given by emergency personnel
Go to Evacuation Assembly Points (EAPs) designated on the
emergency evacuation sign for the building
Assist persons with disabilities
Do not leave the area/campus until your status has been
reported to your supervisor or instructor

51

FOR MORE INFORMATION

Environmental, Health, Safety, and Risk
Management
Visit our website at: www.uaf.edu/safety
Or call us at 474-5413

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