Section 1 Hazardous Materials Waste Management - General Information

1.1) Introduction

Hazardous materials must be disposed of properly to protect human health, safety and the environment. Many materials being used at the University present some type of hazard (biological, chemical, physical, or radiation) and specific disposal procedures are required. Therefore, all materials being used by a laboratory or laboratory-related unit shall be disposed in accordance with the University of Kansas Hazardous Materials Waste Management Program.

1.2) Hazardous Materials Waste Management Program Policy -- Revised 12/16/2005

The hazardous materials waste management procedures contained within this manual are an integral part of the University's Environmental Health & Safety Management Program. They have been instituted so that the University's educational mission may be conducted safely and so that its commitment towards providing a safer, more healthful environment for all employees, students, and visitors can be realized.

These procedures have been established for the proper management of the collection and disposal of hazardous materials generated by the University. Adherence to these procedures is necessary in order to reduce environmental hazards and contribute to the enhanced safety of the total educational and working environments; and to facilitate University compliance with all applicable Federal and State and Local Laws and Regulations governing the disposal of hazardous materials waste.

All faculty, staff, and students shall be aware of their responsibilities as identified in this manual and comply with its requirements. Failure to do so shall be a violation of University Policy, disciplinable through established procedures which may be found in the KU Laboratory Safety Manual in Part 1 - Section 3.8.3. and as established in Faculty, Staff and Student Handbooks.

Regulatory non-compliance may be a violation of State and/or Federal Laws punishable by fines and/or imprisonment.  A Department or School of the University shall be held liable by the Provost Office for any fee or penalty imposed by a regulatory agency upon the KU Lawrence Campus for improper storage, labeling or disposal of hazardous waste, to the extent that the fee or penalty imposed arises out of the activities of the Department of School.

1.3) Hazardous Materials Waste Management Program Responsibilities

1.3.1) Responsibilities of Users of Hazardous Materials

Users shall:

  • Comply with all requirements set forth in this program and, as applicable, with procedures given in sections of other campus safety manuals as referenced. Keep the generation of waste with the philosophy of "As low as reasonably achievable" as a goal.

1.3.2) Responsibilities of Supervisors

Supervisors shall:

  • Provide the space and storage facilities for their units as needed to meet the requirements of this hazardous materials waste management program. Require that all users under their supervision know and follow the requirements of this program.

1.3.3) Responsibilities of Environment Health and Safety (EHS)

EHS shall:

  • Administer this campus hazardous materials waste management program. Develop, update, and maintain this written program, ensuring that it is made available to all campus units. Provide training concerning this program, as necessary. Provide appropriate containers for collection of Hazardous Waste. Collect unwanted, spent, used, excess or surplus hazardous chemicals or radioactive materials from users and see that they are properly reused or disposed. Provide assistance to supervisors in establishing procedures for managing the disposal of hazardous biological agents (biohazard waste). Require that the procedures for the disposal of hazardous materials comply with all applicable local, state and federal regulations.

1.4) Hazardous Materials Waste Management Program Philosophy

The philosophy of this program is based upon the concepts of the Waste Management Hierarchy developed by the United States Environmental Protection Agency. This hierarchy provides a framework for systematic thinking about solutions to waste management. The hierarchy is a series of decision-making steps to be used sequentially in decreasing order of desirability. The first step is the most favorable option, while the last step is the least favorable. The following principles of the EPA Waste Management Hierarchy have been incorporated into the KU Hazardous Materials Waste Management Program

Users shall:

1.4.1) Keep the generation of waste Hazardous Materials at a level 'As low as reasonably achievable (ALARA)'.

1.4.2) Minimize the proportion of unavoidable Hazardous Materials waste.

1.4.3) Segregate Hazardous Materials waste streams to make further management activities more feasible and economical.

1.4.4) Reuse Hazardous Materials within the laboratory in accordance with applicable federal, state and local regulations, if feasible.

1.4.5) Recycle or reclaim Hazardous Materials of value either in the lab or through the services of EHS, if feasible.

1.4.6) Maintain unavoidable and non-reclaimable Hazardous Materials wastes in a form amenable to treatment (e.g. incineration, neutralization, detoxification, etc.) by EHS permitted waste disposal contractors.

Note: If this is not possible, contact EHS on what steps are to be taken with respect to the potential waste before the material is generated or used. Specific procedures will then have to be created.

1.4.7) In the unit, where allowed by EHS and regulations, treat waste to reduce the volume and degree of hazard. Check with EHS first.

1.4.8) Manage remaining hazardous materials wastes and treatment residues by secure disposal methods as approved by EHS.

1.5) Hazardous Materials Identification

The following procedures are to be used in the identification of a spent, used, unwanted, waste, or surplus Hazardous Materials in order to determine if it should be collected by the user for special disposal by EHS. It is recommended that users of Hazardous Materials contact EHS prior to performing experimentation, research, or work in order to determine whether or not the materials being used need to be collected for special disposal or redistribution.

1.5.1) Non-Hazardous Materials

Although every material should be evaluated as to its potential reuse, redistribution, recycling or reclamation, the following substances, when in excess, spent, used, considered waste, or no longer wanted, are not considered hazardous and DO NOT need to be collected for special disposal.

Users should:

  • When feasible, recycle or reuse Normal Solid Waste: paper, cardboard, plastics, metals, dirt, sand, food, etc., free of any hazardous components or residue. If not feasible, they may be disposed of into normal trash baskets or dumpsters.

Users shall:

  •  NOT PLACE empty "potentially contaminated" Hazardous Materials Containers (Metal, Plastic, or Glass) into normal trash baskets. Reuse or recycle emptied containers when feasible or, if not, dispose of them as follows:

    • a) Remove (or, if this is not possible, thoroughly deface) all labels before containers are reused, recycled, or disposed.

      b) Remove all lids of containers before disposal into a dumpster.

      c) Collect empty containers (metal, plastic, or glass) smaller than 2.5 liters in size into an appropriate temporary holding/collection vessel (box, bucket, etc. but not normal trash basket).

      Note: EHS recommends that glass containers 1 liter or smaller in size be collected into a glass disposal box (See Non-Contaminated Sharps below) for disposal. Once the temporary holding/collection vessel is full, or reasonably heavy (50 lbs or less), it shall then be taken by user to the appropriate building dumpster for emptying or disposal. Housekeeping personnel are not responsible for removing these empty-container-collection vessels from the space, but may be willing to do so if contacted.

      d) Set empty containers (metal, plastic, or glass) 2.5 liter or greater in size in a safe area. (A holding vessel is not required). User shall take the containers to the appropriate building dumpster for disposal. Housekeeping personnel are not responsible for removing these empty containers, but may be willing to do so if contacted.

Users shall:

  • place Sharps into any normal trash receptacles unless packaged as follows:

    • a) Place Non-Contaminated Sharps into a plastic-lined heavy cardboard box (Glass Disposal Box) or an impermeable plastic sharps container, such as those sold by Fisher, or available in: Chemistry Department Storeroom (B007 Malott), Biology Division Bio-Store (3027 Haworth), or Higuchi Biosciences Storeroom (107 McCollum Labs).

      • i) When full or reasonably heavy (<50 lbs), the box shall be sealed with tape and plainly marked as being broken glass or non-contaminated sharps for disposal.

        ii) Take the box or container of non-contaminated sharps to the appropriate building dumpster for disposal . Housekeeping personnel are not responsible for removing these containers or boxes from the lab, but may do so if contacted.

        Note: Non-contaminated sharps consists of broken glass, slides, capillary tubes, needles, or other sharp objects which are not hazardous because of contamination with any hazardous chemicals, bio-hazards, or radioactive materials but which have the ability to puncture or cut people handling them.

      b) Infectious Sharps must be handled in accordance with the procedures identified in Section 3.0 for biohazardous waste.

1.5.2) Prohibitions for Disposal into the Sanitary Sewer System

Any material(s) identified or classified below are specifically prohibited from disposal into the sanitary sewer system in accordance with the City of Lawrence Wastewater Discharge Pretreatment Ordinance. POTW - Public Owned Treatment Works

Users shall not discharge any of the following materials into the sewer system:

  • Any flammable or explosive liquids, solids, or gases which might be injurious to the POTW or to its operation. Prohibited flammable or explosive materials include, but are not limited to: Gasoline, Kerosene, Naphtha, Acetone, Benzene, Toluene, Xylene, Ethers, Alcohols, Ketones, Aldehydes, Peroxides, Chlorates, Perchlorates, Bromates, Carbides, Hydrides, and Sulfides. Additionally, any waste material with a flash point of less than 140oF or 60oC, and all aqueous alcohol solutions with > 24% alcohol by volume. Any noxious or malodorous liquids, solids, or gases which are singly or by interaction with other wastes are sufficient to create a public nuisance or hazard to life or are sufficient to prevent entry into the sewers for maintenance or repair. Examples: Thiols (Mercaptans), Pyridine, Sulfides, Cyanides, Phenols, etc. Solid or viscous substances which may cause obstruction to the flow in the sewer, or other interferences with the operation of the POTW. Any Wastewater having a pH <5.0 or >10.0, or having corrosive properties capable of causing damage or hazard to structures, equipment, and/or personnel of the POTW. Any wastewater containing toxic pollutants in sufficient quantity to injure or interfere with the POTW's process, constitute a hazard to humans or animals, or create a toxic effect in the receiving stream. Any wastewater with objectionable color not capable of being removed by the POTW's treatment process. Example: inks, dye wastes, food and pet food colorings, and vegetable tanning solutions. Any waste water containing fats, wax, grease, or oils whether emulsified or not, in excess of 100 mg/l or containing substances which may solidify or become viscous at temperatures between 32 and 150 degrees F. Any wastewater containing contaminants above the City's specified pollutant limitations. This list includes: Antimony, Arsenic, Beryllium, Cadmium, Copper, Cyanide, Lead, Mercury, Nickel, Selenium, Silver, Total Chromium, Thallium, Zinc, Organic Priority Pollutants, Total Organic Halogens, and Phenolic Compounds. Contact EHS for specific pollutant limitations. Any radioactive materials - See section 4.0. Any untreated hazardous biological materials/agents - See section 3.0.

1.5.3) Hazardous Materials Requiring Special Disposal

The Authorized User shall collect any hazardous materials which are spent, used, unwanted or surplus for special disposal as specified in section 1.5.3 below unless the conditions of section 1.5.1 are met and special disposal is not required. Materials that cannot be placed into the sanitary sewer (see 1.5.2 above) or meet any of the criteria of this section require special disposal. These materials include:

  • Hazardous Chemicals -- Any materials which meet the definition of a hazardous chemical as defined in the OSHA Hazard Communication Standard (29 CFR 1910.1200). This includes: Chemicals which are Physical Hazards - Combustible liquids, explosives, flammable liquids, flammable solids, oxidizers, organic peroxides, pyrophorics, water reactives, and unstable reactives; Chemicals which are Health Hazards - Carcinogens, toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins, hematopoietic system agents, and agents which can damage the lungs, skin, eyes, or mucous membranes. Hazardous Wastes -- Any materials which exhibit the characteristics of hazardous waste as identified in 40 CFR 261 Subpart C or are listed as Hazardous Waste in 40 CFR 261 Subpart D under the Federal Resource Conservation and Recovery Act.

    Hazardous Waste Characteristics - Ignitability, Corrosivity, Reactivity, Toxicity.

    Hazardous Wastes Lists - U List, P List, F List, K List. Biohazard Waste -- Any materials meeting the definition of a biohazard. Radioactive Materials Waste -- Any materials meeting the definition of a radioactive material. Lasers and Associated Waste -- Any materials meeting definition of Laser/Associated Waste.. other materials which are not identified above, but which are believed by the User/Supervisor to pose some danger to human health, safety, or the environment. Contact EHS Dept. for directions and assistance.

1.6) Hazardous Materials Collection & Disposal Procedures

The User shall:

1.6.1) Collect and dispose of any material which is identified as a hazardous chemical in accordance with the procedures identified in Section 2.0 -- Safe Disposal of Hazardous Chemicals Waste

1.6.2) Collect and dispose of any material which is identified as a hazardous waste in accordance with the procedures identified in Section 2.0 -- Safe Disposal of Hazardous Chemicals Waste

1.6.3) Collect, process and dispose of any material which is identified as a biohazard waste in accordance with the procedures identified in Section 3.0 -- Safe Disposal of Hazardous Biological Waste.

1.6.4) Collect and dispose of any material which is identified as a radioactive waste in accordance with the procedures identified in Section 4.0 -- Safe Disposal of Radioactive Waste.

1.6.5) Collect and dispose of any material which is identified as a laser or assocaiteed waste in accordance with the procedures identified in Section 5.0 -- Safe Disposal of Lasers and Associated Waste.

1.7) Pollution Prevention, Waste Minimization & Reduction

Federal and State Laws require the University to certify that it has a program in place to prevent, minimize and reduce the amount of hazardous waste it generates. We can not meet this mandate without the assistance of everyone who uses hazardous chemicals or materials. Pollution prevention, waste minimization and reduction have numerous advantages: conservation of material usage, savings both in material purchase and disposal costs, reduces the need for disposal, protects the environment from potential contamination, and protects the health and safety of personnel from potential hazards. All users of materials shall actively engage in these activities and follow prudent safe practices in the handling and disposal of Hazardous Materials. Contact EHS if you need assistance in implementing pollution prevention, waste minimization & reduction activities or would like further specific information.

1.7.1) Materials Redistribution & Reuse

Users should:

  • Return unused chemicals to unit stockrooms or make them available for others to use. Users are encouraged to check with all campus departmental stockrooms for available materials before purchasing new items. EHS routinely picks up chemicals from across campus and attempts to redistribute them at no cost. Most of the chemicals eligible for redistribution are free and available on a first come, first served basis.

    1.7.2) Source Reduction

    Users should:

    • non-hazardous or less-hazardous materials for Hazardous Materials whenever possible. Actively seek and adopt modifications in the procedures which minimize the amount of hazardous materials used and/or minimizes waste generation. Examples: Micro scale techniques should be pursued wherever possible. The use of instrumentation or scaled-down analytical techniques is preferred over traditional wet chemistry techniques. Newer models of equipment produce less waste and are more efficient than older models.

    Supervisors and Users should:

    • Implement a thorough Inventory Management Program. Stringent purchasing and inventory controls are the best way to minimize excess materials or waste. Hazardous Materials should only be purchased in the quantities needed and not in large volumes. Units should maintain up-to-date inventories of materials available in order to avoid duplicate stock. Excess or surplus materials should be returned to departmental stockrooms or EHS for redistribution.

    Supervisors and Users are encouraged to:

    • Implement a Reclamation Program. Units are encouraged to investigate and implement processes to reclaim their spent, used, or waste materials. Any material which can be reclaimed and reused provides a substantial cost savings both in materials purchasing and disposal to the University. Segregation of waste streams is the key to implementing successful reclamation processes. Examples would be: solvent redistillation and precious metals reclamation, etc.

    1.7.3) Waste Reduction

    Supervisors and Users are encouraged to:

    • Establish and implement Treatment Procedures which render Hazardous Materials less or non-hazardous. There are various reactions which can be incorporated into the experiment or process to render materials non-hazardous, de-toxify or destroy the waste. Some examples of acceptable treatment at the unit level are: Neutralization, Heavy Metals Precipitation, Solidification, Oxidation, or Reduction.

      Special Notice #1: Incineration, evaporation, or dilution ARE NOT acceptable treatment methods. However, evaporation or dilution which is part of a standard process or laboratory procedure is permitted.

      Special Notice #2: Treatment should only be performed by competent individuals utilizing proper safety precautions. It is important for the individual to be knowledgeable in the chosen destruction procedure and aware of potential adverse reactions which may present a risk to health & safety. EHS has several references which identify potential and acceptable treatment reactions.