This program description provides information on requirements for the management of hazardous materials, including the disposal of hazardous waste, at Windward Community College (WCC). These requirements are based on federal, state and county regulations. Failure to comply with these requirements may subject WCC and/or individuals to fines, and civil or criminal prosecution. In addition, the management of hazardous materials is necessary to reduce disposal costs. While the disposal of all material as hazardous waste is expensive, there are certain materials that require special attention to minimize the difficulty and expense of their disposal.
MANAGEMENT OF HAZARDOUS MATERIAL
Compliance with the following requirements will assist the Vice Chancellor for Administrative Services (VCAS) in ensuring the proper management of certain types of hazardous chemicals. The following personnel are designated as responsible for the implementation of this program in their areas:
Chemistry Lab - Chemistry Instructor
Biology Lab - Biology Instructor
Art Lab - Art Instructor
Photography Lab - Photography Instructor
Operations and Maintenance (O&M) Shop - O & M Supervisor
Agriculture Building - Agriculture Instructor
Ceramics - Ceramics Instructor
WCC, Coordinator - Vice Chancellor for Administrative Services
All above personnel are required to attend the annual hazardous waste generator training.
Approval to Purchase Hazardous Chemicals
VCAS approval is required for the purchase or requisition of all hazardous chemicals. The Procurement Authorization for Hazardous Material Form, Attachment 1, must be completed and submitted to VCAS for approval prior to initiating a purchase order for any hazardous materials. If approved, a copy of the form will be provided to you for attachment to your purchase order or requisition. The purpose of VCAS approval is to enable us to assist you in ensuring the safe storage, handling and eventual disposal of the material while minimizing cost to WCC.
Approval to Use Hazardous Materials
As part of the grant approval process (ORS Form 5, item 4 under PI certification) a specific form for the use of certain hazardous materials has been developed. See Attachment 2. This form is similar to those already in place for the use of radioactive and biohazard materials.
a. Inventory of Hazardous Chemicals
WCC programs that store hazardous materials are required to submit annual inventories to the VCAS. The annual hazardous material inventory form, Attachment 3, will help us deal with certain types of hazardous materials already on hand, monitor on-going usage, and to prevent unnecessary accumulation of hazardous materials. As part of the inventory procedure, WCC programs are required to inspect the condition of all hazardous material containers to ensure that hazardous materials are stored in containers which are in good condition and which are properly labeled.
b. Inventory of Hazardous Wastes
WCC programs that generate hazardous wastes are required to submit monthly inventories to the VCAS. Waste inventories shall be submitted to the VCAS on or before the first Friday of every month. The hazardous waste inventory form, Attachment 4, will help us monitor campus-wide hazardous waste accumulation. As part of the inventory procedure, WCC programs are required to inspect the condition of all hazardous material containers to ensure that hazardous materials are stored in containers which are in good condition and which are properly labeled.
VCAS has established an audit program to assist in maintaining laboratories and facilities which are safe and protective of the environment. VCAS and/or the Environmental Health and Safety Office will conduct periodic random audits of laboratories and facilities to review the implementation of applicable safety, health and environmental policies and requirements. The following issues will be reviewed: hazardous material storage, hazardous and acutely hazardous waste accumulation, Material Safety Data Sheet availability, hazardous waste accumulation areas, and emergency plans. A report indicating any corrective actions that are necessary and suggesting any improvements will be provided by the VCAS.
HAZARDOUS WASTE IDENTIFICATION
- Waste Identification and Classification
- All waste streams generated throughout the WCC must be identified and then classified as hazardous or non-hazardous according to EPA and State definitions. If you need assistance in determining whether a waste is hazardous, you should contact the Environmental Health and Safety Office at UH Manoa for assistance.
- The first step in meeting the requirement is to identify the waste streams. A waste is:
- A useless by-product of an operation,
- A material which is to be disposed,
- Any material which can no longer be used,
- A manufacturing by-product.
- All wastes must be screened to determine whether they are hazardous. A hazardous waste is one which because of its quantity, concentration, or physical, chemical, or infectious characteristics may cause, or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness; or pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed. The EPA has determined that the following meet the definition of a hazardous waste:
- A waste which is listed as hazardous in the regulations (40 CFR 261);
- A mixture that includes a listed hazardous waste; or
- A waste which exhibits any of the four following characteristics; ignitability, corrosivity, reactivity, or toxicity.
- The following procedures should be used to determine if a waste is hazardous. If it is, the procedures will identify the appropriate EPA hazardous waste number for each waste, which will in turn determine disposal requirements:
- Determine the proper name of the waste and its specific source.
- Check the EPA’s hazardous waste lists in the following order:
- “U” list of toxic wastes (40 CFR 261.33f) . See Attachment 5.
- “P” List of acutely hazardous waste (40 CFR 261.33e). See Attachment 6.
- “K” List of hazardous wastes from specific sources (40 CFR 261.32). See Attachment 7.
- “F” List (40 CFR 261.31) for a non-specific source of waste. See Attachment 8.
- If the waste is not one the “U” List, the “P” List, the “K” List or the “F” List, you must determine whether the waste exhibits any of following four characteristics:
- Ignitability. A waste that exhibits the characteristic of ignitability has the EPA hazardous waste number of D001. See 40 CFR §261.20, Attachment 9, for instructions on how to determine whether a waste exhibits the characteristic of ignitability.
- Corrosivity. A waste that exhibits the characteristic of corrosivity has the EPA hazardous waste number of D002. See 40 CFR §261.22, Attachment 9, for instructions on how to determine whether a waste exhibits the characteristic of corrosivity.
- Reactivity. A waste that exhibits the characteristic of reactivity has the EPA hazardous waste number of D003. See 40 CFR §261.23, Attachment 9, for instructions on how to determine whether a waste exhibits the characteristic of reactivity.
- Toxicity. A waste that exhibits the characteristic of reactivity will have and the EPA hazardous waste number of D004 through D043. See 40 CFR §261.24, Attachment 9, for instructions on how to determine whether a waste exhibits the characteristic of reactivity.
- Most facilities produce wastes consistent in character; therefore, what is often the most confusing aspect of the regulations – characterization and classification – becomes a periodic verification function.
Material Safety Data Sheets
Material Safety Data Sheets (MSDSs) will help you determine whether a product is a hazardous material. MSDSs are prepared by the manufacturer, distributor or importer of products containing hazardous substances. The MSDSs provide the following detailed information about the product:
- Chemical composition
- Physical characteristics and chemical properties
- Fire, explosion and reactivity hazards
- Health hazard information and symptoms of overexposure
- Protective equipment recommendations
- Handling and storage precautions
- Cleanup and disposal procedures
- Emergency first aid procedures
All chemical manufacturers and suppliers of hazardous chemicals must furnish an MSDS with each initial shipment and furnish new MSDS information upon request.
- Location and Accessibility of MSDSs
Copies of all MSDSs must be kept in proximity to the area where products are stored and must be readily available to all employees at any time. MSDSs must also be available for medical personnel, State and Federal occupational safety and health officials, EPA and Hawaii Department of Health personnel. It is the responsibility of the supervisor in each area to ensure that all MSDSs are kept in an accessible storage area and are updated. Employees are encouraged to refer to the MSDSs for information on products in their work area.
If an MSDS is missing or incomplete, you must fax a letter to the product manufacturer immediately, with a follow-up copy of the letter by mail.
HAZARDOUS WASTE DISPOSAL REQUIREMENTS
The following requirements apply to all generators of hazardous waste.
- Waste generators must:
a. Become familiar with the hazardous materials in their area and with this WCC policy on hazardous material and hazardous waste management.
b. Provide an annual inventory of all hazardous materials used (Attachment 3), and monthly inventory of hazardous wastes (Attachment 4).
c. Comply with waste requirements. Store and label waste properly.
d. Contact the Environmental Health and Safety Office at the UH Manoa campus (808-956-8660), if in doubt about requirements or how to properly to dispose of waste.
- Waste Accumulation
- Limits on Waste Generation
To retain the favorable status of being a conditionally exempt small quantity generator, and to prevent WCC from becoming subject to more stringent regulations, WCC may not generate more than 100 kilograms (approximately one half of a 55-gallon drum, 27 gallons or 220 pounds) of hazardous waste or 1 kilogram (2.2 pounds) of acute hazardous waste in one month. Acute hazardous waste is identified on the attached “P” List (40 CFR 261.33e).
- Limits on Waste Accumulation
To retain the favorable status of being a conditionally exempt small quantity generator, and to prevent WCC from becoming subject to more stringent regulations, WCC may not have more than 1000 kilograms (approximately five 55-gallon drums, or 275 gallons, or 2200 pounds) of total accumulated hazardous waste and no more than 1 kilogram (2.2 pounds) of accumulated acute hazardous waste at any time.
- WCC programs generating hazardous waste should establish a safe area near the point of generation for the temporary storage of that waste before disposal by a licensed contractor. The VCAS will annually, or more frequently if necessary, hire a licensed hazardous waste contractor to transport the waste to a permitted hazardous waste treatment, storage and disposal facility.
- All hazardous waste containers must be labeled with the words “Hazardous Waste,” an accurate description of the contents of the container and marked with the accumulation start date.
- All hazardous waste containers must remain closed except when waste is being added to them.
- Waste Containers
Containers used for wastes must be in good condition (i.e. no rusting, cracks or structural defects). If a container is broken or begins to leak, the material must be transferred to a container in good condition. The material composition must be compatible with the material to be stored and incompatible materials must not be stored in proximity to one another. Package materials in sturdy cardboard boxes or plastic waste containers. Cushion the material in the containers to prevent breakage. If cardboard boxes are used which originally held other chemicals, the name of the chemical must be covered over or defaced. Failure to do so constitutes improper marking as to contents and is an EPA regulation violation.
a. Separate Incompatible Materials.
Incompatible materials shall be segregated in separate boxes for quantity greater than 1/4 lb/100 grams for solids and 4 ounces/100 ml for liquids. Examples of incompatible materials are: acids/bases, organics/oxidizers, and flammable liquids/oxidizers. Unknowns and high hazard materials such as cyanides, organic peroxides, pyrophorics, water reactives and explosives shall be packaged separately regardless of quantity.
5. Labeling and Containment
Waste material shall be labeled with the word "waste" and the chemical name(s) (e.g., "waste methyl alcohol" or "waste ethidium bromide"). Generic names can be used if a separate list is maintained to indicate the chemical names and the approximate amounts (e.g., "waste chlorinated solvent bottle no 1" with a separate list "Bottle no. 1 Chloroform 50%, Methyl Chloroform 40%, Methylene Chloride 10%). The manufacturers label or a label giving the chemical name and specific hazards (e.g., flammable, corrosive or poison) is acceptable. Containments are not required for containers of liquid waste that is less than 55 gallons. However, a plan for handling spills must be in place. Consult with the Environmental Health and Safety Office at the UH Manoa campus (808-956-8660a) regarding appropriate containment when a 55 gallon drum is used to collect waste.
6. Drain Disposal Prohibited
No hazardous materials may be disposed of down the drain. This specifically includes but it not limited to:
- Pollutants that create a fire or explosive hazard.
- Any liquids having a pH less than 6.0 or more than 9.0, or otherwise causing corrosive structural damage.
- Any wastewater containing in excess of the following limits:
0.078 mg/l arsenic
1.23 mg/l cadmium
2.8 mg/l chromium
3.4 mg/l copper
1.2 mg/l cyanide
0.68 mg/l lead
0.095 mg/l mercury
0.95 mg/l molybdenum
3.84 mg/l nickel
3.03 mg/l selenium
1.0 mg/l silver
2.6 mg/l zinc
6. Emergency Plans for Spills
You must have a specific spill emergency plan and provide information and training to individuals working in your area regarding the plan. It is a good idea to post the emergency procedures and emergency phone numbers in the work area. Personnel working with hazardous chemicals should be able to answer the question: "What would I do if this material spilled?"
Spill kits with instructions, absorbents, reactants, and protective equipment should be available to clean up minor spills. A minor spill is one that does not spread rapidly, does not endanger people or property except by direct contact, does not endanger the environment, and the workers in the area are capable of handling safely without the assistance of safety and emergency personnel. All other chemical spills are considered major. The following are general procedures for the handling of spills.
a. Attend to anyone who may have been contaminated or hurt, if it can be done without endangering yourself.
b. Turn on the fume hood(s) and open windows where this can be done without endangering yourself. If flammable materials are spilled, de-energize electrical devices if it can be done without endangering yourself.
c. If the spill is major contact the Environmental Health and Safety Office at the UH Manoa Campus (808-956-8660), the Honolulu Fire Department (911), and the VCAS at 235-7405. If the spill is minor clean up can be performed as follows:
(i.) Ensure protective apparel is resistant to the spilled material. Neutralize acids and bases, if possible using neutralizing agents such as sodium carbonate or sodium bisulfate.
(ii.) Control the spread of liquids by containing the spill.
(iii.) Absorb liquids by adding appropriate absorbent materials, such as vermiculite or sand, from the spill's outer edges toward the center. Paper towels and sponges may also be used as absorbent material, but this should be done cautiously considering the character of the spilled material. If you have any questions regarding spill clean up requirements, please contact the Environmental Health and Safety Office at the UH Manoa campus (808-956-8660).
(iv.) Collect and contain the cleanup residue and any materials used to clean up the spill by scooping them into a plastic bucket or other appropriate container and properly disposing of the waste as hazardous waste.
(v.) Decontaminate the area and affected equipment. Ventilating the spill area may be necessary.
(vi.) Document what happened, why, what was done, and what was learned. Such documentation can be used to avoid similar instances in the future. Major incidents are almost always preceded by numerous near misses.
Specific Information on the Disposal of Various Materials
The individual possessing or generating the material retains the primary responsibility for the material. The Environmental Health and Safety Office at the UH Manoa campus (808-956-8660) provides information on requirements and assistance in handling the materials. Specific information on various types of materials is given below.
BATTERIES: Lithium, nickel/cadmium or mercury batteries shall be stored at the hazardous waste accumulation site for contract disposal. Vehicle batteries are recyclable and arrangements with local vendors can be made. Operations and Maintenance handle disposal of batteries from State vehicles.
BIOLOGICAL MATERIALS: For biohazardous wastes, refer to the published University biohazardous waste disposal guidelines or contact the EHSO Biological Safety Officer 808-956-3197 for information concerning the handling and disposal of biological materials.
COMPRESSED GASES: Compressed gas cylinders should be returned to the vendor. A return agreement with the vendor should be included in the contract. Without such an agreement the return or disposal of the cylinders is difficult and very costly, contact the Environmental Health and Safety Office at the UH Manoa campus (808-956-8660) for assistance.
CONTROLLED SUBSTANCES: The handling and disposal of controlled substances (i.e. drugs and other substances listed in 21 CFR 1308) are the responsibility of the permit holder.
FLUORESCENT LIGHT BALLASTS: The Operations and Maintenance Department (x444) removes non-leaking ballast. Ballast which may contains PCBs, are believed to have already been removed from WCC light fixtures. Contact the Environmental Health and Safety Office at the UH Manoa campus (808-956-8660) for assistance concerning leaking ballast or any ballast known to contain PCBs.
FLUORESCENT LIGHT TUBES: The Operations and Maintenance Department (x444), removes and disposes of fluorescent light tubes.
HAZARDOUS CHEMICALS AND HAZARDOUS WASTE: The VCAS will annually hire a contractor to dispose of hazardous wastes. Efforts should be made to determine if others could use excess hazardous chemicals in the department or facility prior to submitting for contract disposal. Chemicals considered non-hazardous waste (see "Non-hazardous Waste" below) could be disposed of in the municipal sanitary landfill or sanitary sewer.
MERCURY: Items containing functional mercury (e.g. light switches, barometers and thermometers) shall be stored at a hazardous waste accumulation site for contract disposal.
MIXED WASTE: Mixed waste is defined as materials that possess a radioactive or biological hazard as well as an unrelated chemical hazard (e.g. potassium dichromate solution contaminated with Carbon-14). Contact the Environmental Health and Safety Office at the UH Manoa campus (808-956-8660) as applicable for assistance in the proper disposal of these materials.
NON-HAZARDOUS WASTE: Listed below are typical laboratory chemicals which are not considered hazardous wastes by the U.S. Environmental Protection Agency. Chemicals with an LD50 (oral rat) greater than 500 mg/kg are considered non-hazardous unless they are suspect carcinogens, mutagens, or teratogens. Non-hazardous waste can be disposed of in the municipal sanitary landfill if solid and down the drain if liquid. Contact the Environmental Health and Safety Office at the UH Manoa Campus (808-956-8660) if you are unfamiliar with interpreting toxicity data or cannot find LD50 information.
a. ORGANIC CHEMICALS
Sugars and sugar alcohols
Naturally occurring alpha-amino acids and salts
Citric acid and salts: Na, K, Mg, Ca, NH4
Lactic acid and salts: Na, K, Mg, Ca, NH4
b. INORGANIC CHEMICALS
Sulfates: Na, K, Mg, Ca, Sr, Ba, NH4
Phosphates: Na, K, Mg, Ca, Sr, NH4
Carbonates: Na, K, Mg, Ca, Sr, Ba, NH4
Oxides: B, Mg, Ca, Sr, Al, Si, Ti, Mn, Fe, Co, Cu, Zn
Chlorides: Na, K, Mg
Borates: Na, K, Mg, Ca
OILS AND TRANSFORMER FLUID: VCAS will assist with disposal of waste pump oil. Used motor oil is recyclable through local vendors. Operations and Maintenance handle used motor oil from University vehicles. Transformer fluid will be handled on a case by case basis, contact the Environmental Health and Safety Office at the UH Manoa campus (808-956-8660) for assistance. The following requirements apply to used oil:
- Used oil may only be stored in containers that are in good condition and not leaking.
- Containers, aboveground storage tanks, and fill pipes must be labeled or marked clearly with the words “used oil.”
- Upon detection of a release of used oil, a generator must stop the release, contain the used oil, clean up and manage properly the used oil and other materials, and if necessary, repair or replace any leaking used oil storage containers. If a release of used oil occurs, contact the Environmental Health and Safety Office at the UH Manoa campus (808-956-8660) for information regarding cleanup, and special government reporting requirements which may apply.
PAINT WASTE (Autobody): Paint waste generated by the Autobody Program will be stored in a marked container labeled, “Paint Waste for Recycling”. On a regular basis, the paint waste will be processed through the paint solvent recycler. After recycling, the remaining paint sludge will be carefully dried out and can be disposed in the municipal sanitary landfill. Thinner solvent extract can be used as product.
PHOTOGRAPHIC CHEMICALS: Photographic fixer will must be stored in capped container and labeled, “Fixer for Recycling”. On a regular basis, the fixer will be transported to a local photographer who will process it for silver recovery.
RADIOACTIVE MATERIALS: Refer to the University Radiation Safety Manual or contact the UH Manoa campus (808-956-8660) for information concerning the proper handling and disposal of radioactive material.
SHARPS AND GLASSWARE: Glassware not contaminated with radiological, biological or hazardous chemical material shall be placed in a puncture resistant container labeled "glass" or "broken glass". It will be picked up by the Operations and Maintenance staff and disposed of. Refer to the published University biohazardous waste disposal guidelines or contact the Environmental Health and Safety Office at the UH Manoa campus (808-956-8660) for information on the handling and disposal of sharps or glassware contaminated with biological or infectious material. Refer to the University Radiation Safety Manual or contact the Environmental Health and Safety Office at the UH Manoa campus (808-956-8660) for information on the proper handling and disposal of sharps or glassware contaminated with radioactive material. Glassware or sharps contaminated with hazardous chemicals should be rinsed to decontaminate them and then disposed of as non-contaminated glassware or sharps (i.e. placed in a sharps container). Broken glassware contaminated with hazardous chemicals should be placed in a puncture resistant container (e.g. bottle, plastic container or can overpack), labeled with the name of the chemical and disposed of as hazardous chemical waste.
N. HAZARDOUS WASTE MINIMIZATION
- Buying Chemicals in Smaller Amounts
The "large economy size" may cost less to buy, but disposal costs, in most cases, are several times the initial cost of the material. Many of the bottles of excess or waste chemicals returned for disposal are full or 3/4 full. Everyone needs to try to accurately estimate the amount of a chemical they expect to use.
- Recycling and Redistribution
Efforts should be made to find someone in the laboratory or department who can use the hazardous material before it is submitted to the VCAS as waste for contract disposal.
- Use of Less Hazardous or Non-hazardous Materials
The following provides some examples of the use of less hazardous or non-hazardous materials, everyone is encouraged to think of some others which may be applicable to their research or instructional materials.
Cleaning Solutions: Chromerge, chromic acid and dichromate cleaning solutions are not desirable from a waste disposal prospective as they cannot be made non-hazardous and are expensive to dispose of. There are many non-toxic biodegradable cleaning solutions that can be used instead of chromic acid. For extremely dirty glassware a product called Nochromix, which uses sulfuric acid and an organic oxidizer in place of chromium can be used. While this requires neutralization of the acid for ordinary disposal, it is far less costly to dispose of than chromium solutions. A number of alternative cleaning solutions are listed below. These are all available from Fisher Scientific, who has the University contract for laboratory supplies. NoChromix, Alconox, Liquinox liquid detergent, Citranox, Fisherbrand sparkleen, and FL-70 Concentrate.
Drying Agents: The safest common drying agents are calcium chloride, silica gel, molecular sieves and calcium sulfate (Drierite). These are recommended because of their low toxicity and stability. Drying agents that pose varying degrees of hazard and disposal problems include:
Phosphorus pentoxide, which generates highly corrosive phosphoric acid and heat on contact with water. This material also has to be disposed of as a hazardous.
Magnesium perchlorate (Dehydrite), which is a strong oxidizer and may cause fires or explosions on contact with organic materials. This material has to be disposed of as a hazardous waste.
Water Reactive Chemicals, (materials such as sodium metal, potassium metal, calcium metal, calcium carbide, calcium hydride, lithium hydride, lithium aluminum hydride, sodium hydride and potassium hydride) are not recommended for use as general purpose drying agents because they form flammable gases on contact with water and are both dangerous and expensive to dispose of. Small amounts of these materials, can be safely disposed of by reacting them with water under controlled conditions by knowledgeable personnel to create non-hazardous or less hazardous materials. If a bottle of solvent contains a water reactive drying agent, this information must be clearly marked on the bottle. This is necessary for the safety of personnel handling the material during disposal.
Thermometers: Mercury thermometers should be replaced with non-mercury thermometers whenever possible. Broken mercury thermometers create spills which are a potential health hazard, time consuming to clean up, and one of the most expensive hazardous wastes we handle. Non mercury thermometers with equivalent accuracy are available for temperature ranges of -20 to 250 degrees Centigrade. Check your laboratory supply catalog for more information.
- Conversion to non-hazardous material
As part of instruction or research operations, hazardous materials can be converted into non-hazardous wastes. The neutralization of acids or bases is an example of this. Experiments can be designed to convert residual or produced hazardous materials into non-hazardous wastes. In some cases this can have instructional value as well as reducing the amount of hazardous waste and its disposal cost.