Environmental Health and Safety

Policy Statement 16: Hazardous Waste

General

The Environmental Protection Agency Hazardous Waste Regulations 40 CFR, parts 261 through 265, dated May 18, 1980, are very specific in the disposal, storage, and treatment of "Hazardous Waste." The University employs a Hazardous Waste Manager to assist in compliance with these regulations.

Regulations

The regulations require among other things, that all hazardous waste (as defined later) be labeled, dated, and stored in proper containers. An inventory of material in storage, a record of material shipped, and other means of disposal is required. A yearly report is also required that indicates the amount, the type of material, and what was done with the material (shipped, incinerated, etc.) during the year.

It is required that all departments that have or generate hazardous materials label all the containers identifying the contents, the date the material was declared waste, and also ensure safe containment. The regulations not only apply to the University but also to the individuals that are responsible for the material. A person ignoring or defying the regulations are subject to a civil penalty of up to $25,000 per day until corrective action is taken.

The indiscriminate flushing of materials into the sanitary sewer is prohibited if they meet the classifications of a hazardous waste. Some of the materials may be neutralized and flushed into the sewer but not into the storm sewer. Some of those that are toxic and flammable may have the toxicity neutralized so they can be incinerated. There will be some materials that cannot be neutralized or incinerated and will have to be packaged in accordance with Department of Transportation regulations and shipped to a hazardous waste disposal site. (See policy for discharge to the sanitary sewer.)

Definitions

The following is a brief definition of hazardous waste as defined by E.P.A. For a more complete definition, see 40 CFR, part 261. A waste is classified as a hazardous waste if it meets any of the following characteristics:

1. A liquid with a flash point of less than 140_F, (closed cup test)

2. Is not a liquid and is capable under standard temperature and pressure of causing fire through friction, absorption of moisture or spontaneous chemical changes and burns vigorously when ignited,

3. Ignitable compressed gas,

4. Is an oxidizer,

5. It is aqueous and has a pH of 2 or less or 12.5 or greater,

6. Is a liquid and corrodes steel (SAE 1020) at a rate of greater than 6.35 mm per year at a test temperature of 130_F,

7. Is normally unstable and readily undergoes violent change without detonation,

8. Reacts violently with water,

9. Forms potentially explosive mixtures with water,

10. Generates toxic gases, vapors or fumes when mixed with water in quantities to present a danger to human health or the environment,

11. Is a cyanide or sulfide bearing waste which, when exposed to pH conditions between 2 and 12.5, can generate toxic gases in sufficient quantities to be a danger to human health or the environment,

12. Is capable of detonation or explosion if subjected to strong initiating source, or heated under confinement,

13. Is capable of detonation, explosion or reaction at standard temperature and pressure.

References

For a listing of the hazardous wastes the E.P.A. has assigned a number, see 40 CFR 261.30, 31, 32, and 33. (This list does not include all materials that meet the definition of a hazardous waste.) This includes materials that are old or contaminated and are to be discarded. If they meet the hazardous waste definition, they have to be declared as such, and will require labels, dates, contents, and etc., the same as other hazardous waste material.