Section 2.0 Safe Disposal of Hazardous Chemical Waste



2.1) Introduction

Hazardous chemicals must be properly disposed in order to protect human health, safety and the environment. A vast number of the chemicals being used at the University present some type of physical or health hazard (Ignitability, Corrosivity, Reactivity, Toxicity) and require specific disposal procedures to be implemented. Therefore, all chemicals being used by a unit shall be disposed in accordance with the University of Kansas Hazardous Materials Waste Management Program. The applicable portions of Section 1.0 shall be followed by all personnel in the handling of Hazardous Chemical waste. The conditions and requirements of this Section 2.0 are in addition to the previously mentioned reference and are specific for chemicals.

2.2) Hazardous Chemical Waste Management Program Policy

All supervisors and personnel using chemicals shall:

2.2.1) Be familiar with and uphold the hazardous materials waste management program policy stated in Section 1.2.

2.3) Hazardous Chemical Waste Management Program Responsibilities

All supervisors and personnel using chemicals shall:

2.3.1) Fulfill their hazardous materials waste management program responsibilities as identified in Section 1.3.

2.4) Hazardous Chemical Waste Management Program Philosophy

All supervisors and personnel using chemicals shall:

2.4.1) Adhere to the hazardous materials waste management program philosophy presented in Section 1.4.

2.5) Pollution Prevention, Waste Minimization & Reduction

All supervisors and personnel using chemicals shall:

2.5.1) Where feasible, make pollution prevention, waste minimization and reduction an integral part of the chemical process, experiment, or activities being conducted in or by their unit in accordance with the procedures provided in Section 1.7.

2.6) Hazardous Chemical Waste Identification

The following procedures are to be used in the identification of a spent, used, unwanted, waste, or surplus chemical in order to determine if it should be collected by the user for special disposal by EHS. It is recommended that users of chemicals contact EHS prior to performing experimentation, research, or work in order to determine the proper disposal method for the chemicals being used.

2.6.1) Non-Hazardous Chemical Disposal

All personnel using chemicals shall:

  • 2.6.1.1) Refer to Section 1.5.1 for procedures identifying the requirements for disposal of non-hazardous materials such as normal solid waste, empty containers, sharps, broken glass, etc.

    2.6.1.2) (May) dispose of Non-Hazardous Chemical Solids by collecting them into an appropriate secondary container (trash bag or box), sealing the container, and delivering it to the nearest building dumpster.

    NOTE: Non-Hazardous Chemical Solid is one which does not meet the definition of a hazardous chemical and the waste material is not defined as a hazardous waste.

    2.6.1.3) (May) dispose of Non-Hazardous Chemical Liquids by discharging down a sink drain with water.

    NOTE: Non-Hazardous Chemical Liquid is one which does not meet the definition of a hazardous chemical, the waste solution is not defined as a hazardous waste, and the material is not prohibited from discharge into the sanitary sewer system.

    2.6.1.4) Not place Non-Hazardous Chemical Solids or Liquids in a normal trash wastebasket. For safety reasons, it is not housekeeping's responsibility to remove and dispose of any (non-hazardous or hazardous) chemicals.

2.6.2) Chemicals Prohibited From Disposal Into The Sanitary Sewer System

All personnel using chemicals shall:

  • 2.6.2.1) Refer to Section 1.5.2 to determine what materials (chemicals) are prohibited from being discharged into the sanitary sewer system by the City of Lawrence Wastewater Discharge Pretreatment Ordinance. Below is a brief summary for types of chemicals prohibited from Sanitary Sewer Disposal:
    • a) Any combustible, flammable, or explosive liquids, solids, or gases.

      b) Any noxious or malodorous liquids, solids, or gases.

      c) Any solid or viscous substance which may cause obstruction to the flow in the sewer system.

      d) Any wastewater having pH<5 or >10, or having corrosive properties capable of causing damage.

      e) Any wastewater containing toxic pollutants in sufficient quantity to injure or interfere with the POTW's process.

      f) Any wastewater having objectionable color not capable of being removed by the POTW.

      g) Any wastewater containing fats, wax, grease, or oils in excess of 100 mg/l, or containing substances which may solidify.

      h) Any wastewater containing contaminants above the City's specified pollutant limitations. This 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 limits.

      i) Any radioactive chemicals must be disposed in accordance with section 4.0.

2.6.3) Hazardous Chemicals Requiring Special Disposal By EHS

All personnel using chemicals shall collect for special disposal by EHS any spent, used, unwanted, waste, or surplus chemicals which: 1) cannot be disposed as non-hazardous materials (see Section 2.6.1 above), 2) are prohibited from disposal into the sanitary sewer system (Section 2.6.2 above), or 3) meet any of the criteria below:

  • 2.6.3.1)Hazardous Chemicals -- Any chemicals/materials which meet the definition of a hazardous chemical (see glossary) require special disposal by EHS. This includes: Chemicals which are/present physical hazards - Combustible liquids, explosives, flammable liquids, flammable solids, oxidizers, organic peroxides, pyrophorics (air reactives), water reactives, and unstable reactives. Chemicals which are/present health hazards - Carcinogens, corrosives, irritants, hepatotoxins, nephrotoxins, neurotoxins, reproductive toxins, hematopoietic system agents, sensitizers, toxic or poisonous agents, and any agent which can damage the lungs, skin, eyes, or mucous membranes.

    2.6.3.2)Hazardous Waste -- Any chemicals/materials which exhibit the characteristics of a hazardous waste as identified in 40 CFR 261 Subpart C or are listed as a hazardous waste in 40 CFR 261 Subpart D. This includes: Characteristic Hazardous Waste and Listed Hazardous Waste .

    2.6.3.3)Biohazard Materials/Waste Disposal -- Refer to Section 3.0

    2.6.3.4)Radioactive Materials/Waste Disposal -- Refer to Section 4.0

    2.6.3.5)Lasers and Associated Waste -- Refer to Section 5.0

    2.6.3.6) Any other materials/chemicals which may not be identified previously, but which the user believes pose some danger to human health, safety or the environment.

2.7) Collection Procedures

The proper collection of excess, spent, used, unwanted, waste or surplus chemicals/materials by individuals and units is the most critical part of the KU Hazardous Materials Waste Management Program. All chemicals/materials identified as hazardous in Section 2.6.3 must be collected and given to EHS for evaluation as to their potential reuse, redistribution, reclamation, recycling, or need for off-campus hazardous waste disposal.

2.7.1) General Collection Procedures for Hazardous Chemicals/Materials Waste

All personnel shall collect chemicals/materials identified as needing special disposal by EHS in accordance with the procedures provided in this section:

  • 2.7.1.1) Containers should have all previous labels removed before they are used for collection of waste materials.

    2.7.1.2) Containers used for collection shall be compatible with the waste materials being collected.

    2.7.1.3) There shall be only one waste collection container per wastestream per generation point (K.A.R. 28-31-4(j)(1)).

    2.7.1.4) Collection containers shall be labeled in English as to its specific chemical content and specific chemical volume, weight, or percentage.  Structural formulas or abbreviations are not acceptable.  An example of the required chemical waste container label can be found by clicking Label (pdf).

    2.7.1.5) Containers shall be kept tightly closed at all times, except when filling with waste materials.

    2.7.1.6) It is important to collect different or incompatible waste chemicals into separate containers.  The mixing of incompatible substances could cause a serious hazard to lab personnel. Use the following protocols:

     

    • a) Collect separately, where possible, waste organic materials from waste inorganic materials.

      b) Collect separately, waste peroxidizable materials from other waste materials.

      c) Collect separately, where possible, all known or suspected carcinogenic wastes.

      d) Where possible, do not mix waste aqueous material with waste organic material.

      e) Collect waste solvents separately, where possible, as either halogenated or non-halogenated.

       

    2.7.1.7) A waste collection container shall be dated (marked with the date) by the user when the container becomes full.

    2.7.1.8) The user must notify EHS immediately when the waste collection container becomes full so that the waste can be removed from the generation point within three days of the fill date.

    2.7.1.9) Acids or bases should be neutralized to a pH of 5-10 so they can be disposed into the sanitary sewer as long as they contain no other toxic materials. Corrosive materials that may generate dangerous fumes or products when neutralized, and for which the lab does not have the appropriate safety devices or capability to perform the neutralization, should be left corrosive and placed into glass or plastic containers for pickup by EHS.

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      a) Any precipitates which are generated during neutralization which are or may be hazardous shall be filtered out and collected for disposal by EHS.

      b) Do not collect highly acidic or alkaline materials into metal containers.

       

    2.7.1.10) Waste chemicals/materials containing any of the following heavy metals should be collected separately, where possible:

    •  

      a) Arsenic, Barium, Cadmium, Chromium, Lead, Mercury, Selenium, Silver.

2.7.2) Specific Wastestream Collection Procedures

  • 2.7.2.1)Waste Solvents - Waste solvents (from HPLC, LC, Peptide Synthesis, and other processes utilizing solvents) shall be collected into EHS-approved waste containers in accordance with the following requirements:
    •  

      a) The laboratory is responsible for contacting EHS to obtain the appropriate waste solvent collection container(s).

      b) The waste solvent collection container(s) shall be marked with the words "Hazardous Waste" before collection begins.

      c) Glass containers are not acceptable for collection of waste solvents unless special arrangements have been made with EHS.

      d) Waste solvent collection container(s) shall be kept closed at all times, except when being added to.

      e) There may be only one waste solvent collection container per wastestream (non-halogenated and halogenated) per generation point.

      f) A waste solvent collection container shall be dated (marked with the date) by the user when the container becomes full.

      g) The user must notifiy EHS immediately when the container becomes full so that the waste can be removed from the generation point within three days of the fill date.



    2.7.2.2) Waste Chemical Mixtures - Chemical mixtures are those that are prepared by the user, and are not considered to be original chemical products.

    •  

      a) The laboratory shall contact EHS to ascertain the appropriate waste collection container(s).

      b) Containers of waste chemical mixtures shall be marked with the words "Hazardous Waste."

      c) Containers of waste chemical mixtures shall be dated (marked with the date) by the user when the container becomes full.

      d) The user must notify EHS immediately so that the waste can be removed from the generation point within three days of the fill date.

       

    2.7.2.3)Unknowns - All containers are required by University policy and procedures to be labeled as to their contents and hazards; however, should a user discover containers of unknown contents, the user must either identify the contents immediately or notify EHS for their removal.  Containers of unknown contents are considered to be hazardous waste and must be marked with the words "Hazardous Waste."  Note that the unit may be held responsible for payment of any necessary analytical costs to identify the material.

    2.7.2.4)Used Oil - Used Oils (pump, lubricating, etc.) shall be collected separately, marked with the words "Used Oil," and given to EHS for recycling or disposal.

    2.7.2.5)Metallic Mercury - Dirty metallic mercury should be collected by the unit for temporary storage and shipment for redistillation, or it may be given to EHS for handling.

    2.7.2.6)Gas Cylinders - It is the users responsibility to ship unwanted or empty cylinders of compressed or liquefied gases back to the supplier with the screw-on shipping cap in place. Small leaking cylinders should be placed into a functioning lab hood and EHS should be contacted for handling and disposal assistance. Cylinders which cannot be sent back to the manufacturer may have to go for special waste disposal. Contact EHS.

    2.7.2.7)Batteries - (Alkaline, lead-acid, nickel/cadmium, lithium ion, etc.) shall be collected and given to EHS for recycling or disposal.

    2.7.2.8)Used photographic fixer - Used photographic fixer shall be collected separately and given to EHS for silver recovery.

    2.7.2.9)Pesticides - Pesticides and/or pesticide products shall be collected separately and given to EHS for disposal.

    2.7.2.10)Exhaust Filters from Paint Spray Booths -- These filters often contain metals in the paint solids which may make them be considered hazardous waste. Therefore, arrangements must be made with EHS to have exhaust filters from paint spray booths tested.  If the filters are shown to be a hazardous waste, they shall be collected separately and given to EHS for disposal.  If the filters are shown to be not a hazardous waste, the filters may be disposed of in the normal trash; however, if there is a change of process change within the spray booth, EHS must be notified at that time to ascertain the continued non-hazardous status of the filters.

    2.7.2.11)Used/Waste Silica Gel and Other Contaminated Absorbents or Adsorbents -- Concern for silica gel and other absorbents/adsorbents that have come in contact with solvents and toxic compounds.  Depending on what it is, the used silica gel or absorbent/adsorbent may be regulated as a hazardous waste. Do not dispose of these items into normal trash without EHS approval.

    Collect into a container, properly label, and when full, users must date container and immediately notify EHS for pickup.

    We have a special or unique label for Waste Silica Gel and other contaminated ad/absorbents. This label is to be used for containers of Waste Silica Gel and/or other chemically contaminated adsorbents or absorbents.  This label helps complete a toxicity characteristic screen of the contaminated material to determine if it is a hazardous waste.  Print out the label, complete all fields, attach to container and contact EHS for pickup. Download: Silica Gel Label (xls) or Silica Gel Label (pdf).

2.7.3) Surplus Chemicals

2.7.3.1) Chemicals that are considered  to be in good condition and are suitable for redistribution for use elsewhere on campus will be culled out by EHS.  EHS maintains a listing of surplus chemicals that are available for use.  To view the list, visit the KU-EHS website to view or download the latest redistribution inventory list. You can request items by submitting a request here.  Users may also request that EHS keep a watch out for items not currently on the list.

2.8) Pickup & Removal Procedures

All excess, spent, used, unwanted, waste, or surplus chemicals/materials which have been collected by a unit in accordance with the procedures identified in Section 2.7.1 & 2.7.2 & 2.7.3 above, are to be picked up and removed by the EHS.  These materials will be taken back to Burt Hall for evaluation as to their potential reuse, redistribution, reclamation, recycling, or need for off-campus hazardous waste disposal.

All personnel shall comply with the following procedures for pickup and removal of hazardous chemicals/materials from their lab by EHS.

      2.8.1) Contact For Pickup

      • 2.8.1.1) To arrange for pickup of hazardous materials or hazardous waste, contact EHS at 785-864-2853 and be prepared to provide the following information:
          • Contact Person
          • Contact Person Phone #
          • Building & Room #
          • Department
          • Type of chemicals to be picked up
          • Number & size of Containers.

        2.8.1.2) You may also request pickups by Email.  Go to the EHS website, click service requests, then select Hazardous Chemicals/Materials/Waste Disposal-Pickup Request, follow directions to submit a request for a chemical pickup.

        2.8.1.3) Information will be placed onto EHS Pickup Schedule List which is organized first requested, first served. Priority is usually given to solvent materials, but emergency situations, types of chemicals, and availability of EHS personnel are also considered.

      2.8.2) Container Preparations

      • 2.8.2.1) Containers shall have been prepared in accordance with the proper collection procedures as identified in Section 2.7.1 & 2.7.2 (labeling, dating, etc).

      2.8.3) Removal Exceptions

      • 2.8.3.1) Any containers found to be unsuitable in the judgment of EHS personnel, or that have not been prepared, labeled, or packaged in accordance with the previous procedures, shall not be removed from the users location until compliance is achieved.

      2.8.4) Laboratory or Inventory Clean-out Procedures

      It is important that prior planning and a cooperative effort be established between personnel and EHS in order to facilitate the clean-out/close-out of areas containing large numbers of hazardous chemicals/materials.

      • 2.8.4.1) A typewritten or computerized inventory list of chemicals/materials to be removed shall be provided by the supervisor to EHS at least 30 days in advance of close-out/clean-out deadline. Once the inventory list has been received and reviewed by EHS, a pickup date will be scheduled. The inventory list shall include the following minimum information:
        • a) Chemical Name, Container Size & Chemical Quantity.

          b) This information is necessary so that EHS personnel can review the list to identify appropriate safety precautions, potential items for redistribution or reuse, and schedule sufficient time for the clean-out.

        2.8.4.2) All containers shall be in accordance with the collection procedures as identified in Section 2.7.1 & 2.7.2.

        2.8.4.3) The Container Removal Exceptions identified in Section 2.8.3 are applicable for all close-outs and inventory clean-outs.

      2.9) Chemical 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 that it generates. This especially includes hazardous chemical waste.

      All supervisors and personnel using chemicals shall:

      2.9.1) Chemical Waste Minimization & Reduction

      • 2.9.1.1) Where feasible, make pollution prevention, waste minimization and reduction an integral part of the chemical process, experiment, or activities being conducted in their unit in accordance with the procedures provided in Section 1.7. This includes:
        • a) Chemical Redistribution & Reuse

          b) Source Reduction through substitutions or process modifications

          c) Source Reduction through Chemical Inventory Management

          d) Waste Reduction through Chemical Reclamation

          e) Waste Reduction through Chemical Treatment Procedures

      2.9.2) Contact EHS

      Contact EHS for assistance in developing and implementing pollution prevention, waste minimization and reduction activities in the lab.