As a generator of small amounts of Hazardous Waste the University is required to comply with Federal Standards promulgated under the Resource Conservation and Recovery Act (RCRA). These regulations cover the storage, handling and documentation of transfer of hazardous waste from the point of generation to final disposal.
Hazardous waste is a solid material, chemical, fuel or compressed gas which is harmful to human health or the environment and is no longer useful and is intended to be discarded. It may be identified by name in chemical lists in the Federal Code, 40 Part 261, or if not specifically listed, by the characteristic of the waste material. Essentially if the waste material is ignitable, corrosive, reactive or toxic, it is subject to hazardous waste regulation. A second more limited category of hazardous waste is acutely hazardous waste which are all listed materials.
Some common items which are not ordinarily thought of as harmful when handled are included as hazardous waste because they “leach” small quantities of toxic material when disposed of in a landfill for long periods of time. These items must not be placed in the ordinary trash, instead they must be collected for recycling. The Facilities Management or surplus property collects these items:
The most significant impact that individual departments can have on hazardous waste costs is to reduce the volume of waste required to be handled. Faculty and supervisors are encouraged to consider ways of reducing the volume of waste or preserving the reuse of the materials through the redesign of experiments and work processes. Recyclable materials should be kept separate from other waste. Efforts should be made to decontaminate, detoxify, neutralize, or otherwise render the waste non-hazardous. Different waste materials should be kept segregated whenever possible.
Hazardous waste materials must be handled by means of one of the following:
It is unlawful to discharge any chemical product or oil into storm sewers, creeks or on the ground or to discharge hazardous chemicals such as strong corrosives, reactives, oils, varnishes, kerosene, gasoline insecticides etc. into the sanitary sewer. Also hazardous chemicals should not be placed in the ordinary trash for pick-up by Facilities Management.
An essential step in the processing of hazardous waste materials is to develop and maintain an inventory list of stored hazardous waste materials. This list must include the chemical identity, quantity, container type and originator for each substance. Also, the chemical identity and originator must be affixed to each container. Without this information the material cannot be picked-up for disposal.
Each inventory list should be forwarded to the Safety Officer semi-annually so that the current aggregate amount and type of stored waste can be determined for the University and commercial pick-up can be arranged when necessary.
The University is currently classified by the EPA a "conditionally exempt small quantity" generator which allows it to be excluded from some of the more cumbersome record keeping and training aspects of the law. To maintain this classification, the university must never generate more than 100 kg (220 lbs.) of hazardous waste in a month and never store more than 1000 kg (2,200) lbs.