1. INTRODUCTION

1.1. Purpose
This manual presents policies, responsibilities and procedures for disposal of hazardous waste generated at Syracuse University. The information is given to assist University personnel in safely and efficiently managing hazardous waste they generate. The Syracuse University Hazardous Waste Management Manual is applicable to all Syracuse University hazardous waste generators. Additional procedures apply to activities by Syracuse University personnel who are responsible for moving, storing or manifesting hazardous waste.

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1.2. Inside This Manual
As laboratories produce the majority of hazardous waste at the University, the manual focuses special attention on laboratory generated waste. The manual also contains information on art and photography waste, regulated medical waste, battery recycling, fluorescent lamp disposal, and office waste under the section on special waste streams. Although some of these wastes are not regulated as hazardous waste, they are included because there are restrictions on disposal, or special procedures involved in their management. This manual does not cover management of radioactive wastes. Consult the Syracuse University Radiation Protection Handbook for specific information.

This Manual Covers:
Laboratory generated waste
Compressed gas cylinder disposal
Mercury waste
Art and photography waste
Regulated medical waste
Battery recycling
Fluorescent lamp disposal
Office waste
Physical Plant generated waste

Not Covered in this Manual:
Regular trash disposal and campus recycling. Consult Materials Distribution at x -1940 for information.
Radioactive waste. Consult the Syracuse University Radiation Protection Handbook or call x - 4132 for information.

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1.3. Environmental Health Office - EHO
EHO staff members coordinate the Hazardous Waste Management Program on campus. Hazardous materials generated in laboratories, art studios, shops or other workplaces on campus are collected, labeled and stored according to specific procedures detailed in this manual. Hazardous materials are then picked up by EHO and shipped off campus by a licensed disposal firm. EHO is responsible for maintaining contracts with disposal firms and maintaining documentation of disposal activity.

EHO specialists in hazardous waste management can provide telephone consultation or arrange a site visit to review individual waste management concerns. Assistance related to hazardous waste minimization and disposal is available by calling EHO (x-4132). Additional information on personnel and operations in the EHO Hazardous Waste Management Program is available through the World Wide Web, outlined in this manual under electronic resources.

Hazardous Waste Assistance from EHO:
Telephone consultation
Site visit
Hazardous waste minimization assistance
Call extension 4132
Go to the EHO home page on the web: http://sumweb.syr.edu/summon/env_hlth/public/web/index.htm

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2. POLICIES AND GOALS

2.1. Hazardous Waste Management Policy
Syracuse University is committed to protecting the environment as well as the health and safety of our staff, faculty and students. Our objective is to promote the safe handling and disposal of all waste in an environmentally sound manner consistent with local, state and federal regulations. Syracuse University will provide the resources to ensure that the handling of hazardous waste is conducted according to this policy. Generators are required to coordinate management of all hazardous waste at Syracuse University with the Environmental Health Office. EHO will assure hazardous waste management will be performed by properly trained personnel.

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2.2. Waste Minimization Policy
Syracuse University is committed to protecting the environment and our facilities. Our objective is to reduce hazardous waste generated to the lowest practical amount. By reducing the volume and toxicity of hazardous waste, adverse impacts on the air, water, land and our facilities are minimized. By successfully reducing hazardous waste we achieve cost savings, increase operational efficiencies and improve the quality of our services. Effective waste minimization enhances health and safety for all of us on campus - faculty, staff, students and visitors.

The Syracuse University Hazardous Waste Management Program goals are:
To reduce the amount of hazardous waste to the lowest practical quantity
To dispose of wastes in an environmentally and economically responsible manner consistent with all applicable regulations
To conduct all waste management operations using safe and professional methodology, and
To implement effective waste minimization procedures (including recycling, reuse, product substitution, and treatment) in all operations.

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3. HAZARDOUS WASTE REGULATIONS

There are comprehensive federal, state and local regulations for the management of hazardous waste. These rules apply to all Syracuse University personnel; from those who initially generate the hazardous waste to those who arrange for waste disposal. Syracuse University is regulated as a hazardous waste generator. Strict regulatory requirements apply to labeling, handling, storing and disposing of hazardous wastes. Regulatory compliance is incorporated into the Hazardous Waste Management Program.

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3.1. What is Hazardous Waste?
Broadly speaking, a waste is something unwanted or no longer useful: it can be a solid, liquid or contained gas. Not all materials regulated as hazardous waste are in fact "dangerous". Despite this, if a material is regulated as hazardous waste it must be handled in compliance with the hazardous waste regulations and this Manual. Until determined otherwise, most chemicals that are intended for disposal should be considered hazardous. It is the responsibility of the waste generating institution to determine if the waste is regulated as hazardous waste. At Syracuse University, the Environmental Health Office makes that determination according to specific criteria. A waste is hazardous according to New York State law if it is (1) a listed waste or (2) a characteristic waste.

(1) Listed waste - Hazardous wastes are identified on lists of hazardous wastes and spent materials. These lists are prepared by the New York State Department of Environmental Conservation and/or the US Environmental Protection Agency (EPA). Listed wastes may be spent materials, unused discarded chemicals, and specific process wastes. Wastes that fall within the listing descriptions are regulated as hazardous wastes regardless of the actual hazard they may present.

(2) Characteristic waste - Hazardous wastes may exhibit one or more of the following characteristics: ignitability, corrosivity, reactivity or toxicity. Each of these characteristics has a specific definition based on chemical and physical properties.

See Appendices A and B of this Manual for more discussion of waste identification and definition.

All wastes generated at the University that are regulated as hazardous waste must be disposed of through the Environmental Health Office's Hazardous Waste Management Program. Sometimes wastes that are not regulated as hazardous waste could cause significant harm to people or the environment if disposed of improperly. Although not legally required, as a matter of policy, these materials must also be handled through the Hazardous Waste Management Program.

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3.2. The Regulatory Environment
EHO provides waste disposal services on campus such as waste pickup, accumulation, treatment and shipment in order to meet the requirements of federal, state, and local regulations. Federal regulations include the Resource Conservation and Recovery Act (RCRA), the Department of Transportation Hazardous Material Transportation Act (HMTA), the Toxic Substances Control Act (TSCA), the Clean Water Act (CWA), Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and Superfund Amendments and Reauthorization Act (SARA). Examples of State and local regulations include New York Environmental Conservation Law, Onondaga County Solid Waste Disposal Authority rules and the Onondaga County Department of Drainage and Sanitation Rules and Regulations.

The University is both ethically and legally responsible for the proper management of hazardous waste at University facilities. Under federal and state laws, generators of hazardous waste are accountable for the management of these wastes from "cradle to grave" and serious civil and criminal penalties may result from failure to comply with legal requirements. Although the University is responsible for maintaining compliance, a student, an employee, supervisor or department manager could have individual liability in cases of violation of environmental laws. Federal, state and local environmental authorities may come to inspect laboratories and worksites for hazardous waste compliance at anytime.

Regulations Summary
In general, until determined otherwise, consider most chemicals intended for disposal as hazardous.
Hazardous waste is defined as waste that has certain hazardous characteristics, or waste that appears on lists of hazardous wastes.
Trained specialists at EHO make the final determination whether a waste is hazardous according to specific regulatory criteria.
Federal state and local laws strictly regulate hazardous waste collection, labeling, storage, transport and disposal. Universities have been a target of inspection.
Failure to comply with regulations can result in fines and penalties against the University and individuals.

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4. RESPONSIBILITIES AND REQUIREMENTS

Each University employee who handles or generates hazardous waste is required to properly handle, store and label hazardous wastes and to comply with applicable federal, state and local regulations. It is the responsibility of all University employees who use or handle hazardous materials to follow the guidelines set forth in this Hazardous Waste Management Manual. It is the collective responsibility of individual employees, supervisors and the Environmental Health Office to see that hazardous waste is managed safely and appropriately at the University.

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4.1. Responsibilities - For Hazardous Material Users/Waste Generators

Responsibilities For Individuals Who Use or Generate Hazardous Materials:

Understand the properties, health risks, and precautions required for handling each hazardous material. Become familiar with available data concerning the chemicals; use reference books, articles, MSDSs and the University's Chemical Hygiene Plan (CHP) and Standard Operating Procedures (SOPs).
Select and use all appropriate personal protective equipment (PPE - gloves, goggles, labcoat, etc.) and other safety equipment required to safely work with hazardous materials.
Plan the activity/experiment to consume, to the extent feasible, all hazardous materials and to minimize the amount and toxicity of waste materials produced.
Learn and follow guidelines for:

1. waste segregation and waste container selection
2. accurate and complete labeling
3. waste minimization from purchase through disposal

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4.2. Responsibilities - For Principal Investigators, Supervisors, Or Managers
It is each Principal Investigator (PI) /Supervisor's responsibility to ensure that waste generated by any individual in the work area is properly handled and disposed of through the Hazardous Waste Management Program. If staff, faculty, or students leave the University, the P.I. or department head must assure that any waste materials left behind are properly labeled, handled and disposed.

Responsibilities for Principal Investigators, Supervisors, Managers:

• Provide and document appropriate training for workers, ensure that all applicable safety rules and hazardous waste management procedures are followed and that appropriate PPE is available, in working order, and appropriately used.
• Act as or appoint a Waste Coordinator. The Waste Coordinator manages the proper storage, labeling and disposal of hazardous waste in the work area, and serves as EHO contact person for waste matters.
• Conduct regular inspections of the area to ensure proper management of hazardous waste and to prevent accumulation of old, unused, and abandoned chemicals. Weekly inspections are recommended.
• Understand the current legal requirements concerning regulated waste disposal and contact EHO when questions arise.
• Perform all operations in accordance with applicable University Hazardous Waste Minimization Guidelines (see Section 5).

Laboratory personnel leaving Syracuse University must ensure that all research samples, solutions and hazardous materials under their control and custody have been properly disposed or transferred to other appropriately trained and informed personnel.

An effective process for transferring accountability for hazardous materials used by individuals leaving the University encourages efficient chemical usage, minimizes potential hazards to others, and preserves University resources.

Preventing "Orphan" Chemicals:

Clean Up Before You Leave! When staff, faculty, or students leave the University, a facility clean-out is required. Abandoned, "unknown" chemicals present a major hazard and expense to the University. Unknowns are easily prevented by simply making sure that departing staff clean up and accurately label their materials before leaving. A departmental exit interview along with a walkthrough inspection of the laboratory must take place. A review of the facility, chemical inventory, equipment and hazardous waste disposal status is recommended as the way to prevent unknown orphan chemicals.

• Follow all the procedures in Appendix G "Waste Chemical Clearance for Laboratory Personnel Leaving Syracuse University".
• Hold a departmental exit interview for departing faculty, staff, students.
• Check to make sure they have cleaned out their laboratory work area.
• Walk through the laboratory and inspect chemical inventory, container labels, hazardous waste - everything must have a complete, accurate label.

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4.3. Responsibilities - For Waste Coordinators
Specific duties of the Waste Coordinator are listed below. The Waste Coordinator has direct oversight of daily waste operations in the work area, and serves as the primary contact for EHO staff.

Responsibilities for Waste Coordinators:

• Conduct ongoing, onsite training for faculty, staff and students to ensure that hazardous waste disposal guidelines in this Manual are followed.
• Provide regular inspections of the area to ensure that hazardous waste has been properly identified, labeled, segregated and stored for collection and disposal by EHO.
• Understand the current legal disposal requirements and procedures for regulated materials generated under their purview.
• Arrange hazardous waste pickups for the area and work in cooperation with EHO to ensure that disposal is safely and completely performed.
• Immediately notify Supervisor if problems with proper waste management develop.

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4.4. EHO Responsibilities
The Environmental Health Office (EHO) will maintain storage, shipping and other related records; ensure compliance with reporting requirements; provide consultation on hazardous waste issues and coordinate the disposal of all hazardous waste generated at the University.

It is the responsibility of the EHO to coordinate disposal services for University generated hazardous waste in order to meet federal, state, and local regulations. These requirements include documented and informed decision-making to ensure that proper waste classification and disposal procedures are followed. Procedures have been developed to fulfill these obligations and have been incorporated into the Hazardous Waste Management Program. All University contracts pertaining to hazardous waste disposal must be reviewed and approved by the Director of EHO.

It is the responsibility of EHO staff to:

1. Work with campus hazardous waste generators to develop and implement appropriate hazardous waste disposal procedures and waste minimization strategies for their specific areas.
2. Consult and provide training on proper practices for the purchase, storage and disposal of chemicals and identified hazardous waste.
3. Coordinate and manage the disposal activities associated with hazardous waste generated at the University.
4. Understand the legal requirements regarding all regulated waste streams and provide training and consultation on these regulations to University waste generators.
5. Ensure that the University Hazardous Waste Management Program is reviewed periodically and that the Hazardous Waste Management Manual is revised and updated as necessary.

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4.5. Training Requirements

4.5.1. General
Syracuse University personnel who generate hazardous waste require initial and periodic training appropriate to their level of responsibility. For many individual waste generators on campus, this training is included as part of the University Chemical Hygiene presentations. Special training will also be provided by EHO upon request to areas with unusual hazardous waste management requirements. Training for hazardous waste management on campus will be updated to reflect the most current regulatory requirements.

4.5.2. Special Training
Individuals with specialized duties, and anyone with oversight responsibility for packaging and transportation of hazardous materials, are required by law to have additional training. Individuals who supervise or prepare hazardous materials for transport and/or sign manifest documents must complete course work which meets Department of Transportation (DOT) regulations. No University personnel may arrange for disposal, transport, shipment or sign hazardous waste manifest documents without completing the DOT training class. If material needs to be shipped using a manifest, contact EHO for information on training. If no one is available in the department with the appropriate training, EHO staff must review the operation and sign the manifest.

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5. WASTE MINIMIZATION AND VOLUME REDUCTION

In keeping with the University waste minimization policy, every effort must be made to reduce the volume and toxicity of waste generated at Syracuse University. Hazardous waste disposal is extremely expensive, but by implementing waste minimization concepts into your work area you can significantly reduce the operational cost for your department and the University. A good waste minimization program combines prudent purchasing, source reduction, recycling and treatment.

Why Should I Care?
It is no secret that as a world community we are generating wastes of all types (hazardous and non-hazardous) at a pace that outstrips our current abilities to cope. The problem has approached crisis proportions. Such limitations as space, facility siting, and lack of technology have driven direct disposal costs of hazardous waste to new heights. When other hidden costs such as regulatory overhead, training, insurance and paperwork management are added in, the cost becomes even more astronomical. The bottom line is that all our budgets are affected by the overhead of waste disposal.

How Much Does Disposal Cost?
The cost of waste disposal is, of course, dependent upon the method(s) used to deal with waste. Disposal options in turn are dependent upon the nature of the waste.

Prior to 1986, land disposal was the least expensive option and therefore, the most widely used. However, after 1986, Federal restrictions were set in place that all but eliminated this practice for most solvent wastes. Since then, further restrictions have been imposed to cover virtually all other hazardous wastes.

Most waste from the University is disposed of in "lab packs". A lab pack is simply a 55-gallon drum containing individual bottles of compatible chemicals. Vermiculite is added to cushion the contents, as well as to absorb any liquid from breakage. A lab pack can only contain 15 gallons of liquid waste.

The approximate price of disposal for a "normal" lab pack is currently $400 per drum plus $70 apiece for transportation, another $100 per stop for the "dock fee" plus additional costs such as labor, insurance, permits, Superfund tax and more. Since each 55-gallon lab pack only contains 15 gallons of waste, the per gallon cost becomes $24.66. This calculation does not include the cost of the drum ($23), labor, compliance fees, paperwork management, the $100 dock fee or other costs.

Special wastes cost even more. For instance, picric acid and other reactives have disposal costs that run as high as $100 per pound. Unreturnable lecture bottles have disposal costs starting at $150 per bottle. Mercury recovery facilities are currently charging about $1,500 for processing each 55-gallon drum containing waste from mercury spills. Typical analysis for an unknown runs about $200 - $300 per sample before it can be disposed. It is becoming obvious that the University cannot afford to be without an effective waste minimization program at the laboratory (generating) level.

The best way to lower disposal costs is to lower the need for disposal.

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5.1. Purchasing to Minimize Waste
Good purchasing decisions are the first steps in minimizing hazardous waste. Every effort must be made to keep purchase quantities to a minimum. Remember the slogan "LESS IS BEST" when planning work and ordering chemicals. Stockpiling products for future use or to take advantage of unit cost savings doesn't work. This is because any net savings in purchase are lost during disposal if the chemical is not completely used. The average cost to dispose of unused hazardous materials may be two to three times the original purchase cost. Purchase only the quantity of material that will be completely used within a reasonable time frame.

• Limit the amount you order.
• Do not stockpile chemicals.
• Avoid duplication - Check your inventory to avoid ordering chemicals that are already in stock. Keep up to date inventories.
• Rotate chemical stocks to use up chemicals before their shelf lives expire.
• Before you order, consult the University Excess Chemical Exchange Program to determine if a material is available - at no cost (see below for details).
• Laboratories should investigate pre-weighed packaging options now available from chemical vendors. Particularly with highly toxic materials (e.g. carcinogens, teratogens, etc.), the purchase of pre-weighed materials avoids unnecessary handling, storage and disposal of excess toxic materials. Micro-scale packing is also available.
• Be wary of offers of "free" research materials or chemicals from outside the University. All too often "freebies" are inadequately labeled, or are packaged in large, industrial quantities that will not be used up. Research scale quantities, complete labels and material safety data sheets are required for any free materials. Do not accept excess chemicals or inventories from another institution. Usually these are materials nobody wants - often degraded and poorly labeled - and they become waste disposal problems.

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5.2. Source Reduction
Source reduction refers to practices that reduce, avoid or eliminate hazardous waste at the point of generation.

• Use smaller quantities of chemicals in your experiment or process. Use "micro glassware".
• Substitute less toxic or non-hazardous chemicals for their toxic counterparts.
• Plan the activity/experiment to consume hazardous materials to the extent feasible, and to minimize the amount and toxicity of waste materials produced.
• Limit the use of chromic acid solution for glassware cleaning. Chromic acid is very corrosive and a strong oxidizer which can react violently or explosively with oxidizable materials. It contains Chromium (VI) a known human carcinogen and toxin. Try an ultrasonic cleaning bath. Try commercial cleaning agents such as Nochromix, Alconox, Liqui-Nox, Lift-Away or "Micro" liquid lab cleaner as alternatives. A potassium hydroxide solution in an alcohol or a dilute hydrochloric acid solution may also be effective. Use chromic acid solution only if none of these alternatives work.
• Do not dispose of chemicals as hazardous waste when they can be recycled or reused. If you have no further need of a hazardous material, determine whether your colleagues can use it. If you have an excess material, which could be included in the Excess Chemical Exchange Program, call EHO (x 4132).
• Do not mix chemical wastes. Mixing reduces the likelihood that materials may be reused or redistributed and often increases disposal costs. If at all possible, do not combine other chemicals with organic solvents. Acids, bases, heavy metals, carcinogens, oxidizers, cyanides, sulfides, pesticides, non-halogenated solvents, and especially halogenated organic solvents (chloroform, methylene chloride, etc.) must be collected in separate, labeled, and dated waste containers. (See section 6 for details.)

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5.3. Treatment
Under state and federal hazardous waste regulations, it is permissible for generators to use chemical or physical treatment methods to minimize the amount and toxicity of hazardous material end products. The primary way this can be accomplished is if the hazardous material is treated as it is produced within the experiment, before it becomes "hazardous waste". This type of treatment generally applies then only to laboratory situations where small amounts of materials are handled. Regulations are restrictive about treatment of hazardous waste, so consult EHO before undertaking a treatment program.

5.3.1. Plan Experiment to Eliminate Hazardous Waste Generation
The experimental design and final steps of an experimental procedure should be planned to eliminate or minimize hazardous waste generation. Teaching and research laboratories can perform operations within the experimental process that cannot legally be performed once the experiment is terminated and the end products are identified as hazardous waste.

Safety is the primary consideration prior to undertaking treatment or deactivation within an experiment. In addition, a significant reduction in hazard of the waste must result. Operations performed within the experiment to deactivate or treat materials to prevent formation of hazardous waste end products must be done (or directly supervised) by a qualified scientist with experience and thorough knowledge of the chemistry and hazards of the procedure.

5.3.2. Resources Available for Designing Experiments to Reduce or Eliminate Hazardous Waste
A standard reference on laboratory safety, "Prudent Practices in the Laboratory" (available at EHO) details effective experimental design, and provides protocols to minimize production of end products which require disposal as hazardous waste. "Prudent Practices" is available at the EHO and in each research group in the Chemistry Department. Wastes that can be eliminated include the following:

• Thiols and Sulfides
• Acyl Halides and Anhydrides
• Aldehydes
• Organic Peroxides and Hydroperoxides
• Inorganic Cyanides
• Alkali Metals
• Metal Catalysts
• Water reactive metal halides

Newer chemical journal articles and laboratory teaching texts include increasingly more procedures for eliminating hazardous waste end products.

5.3.3. References Available in Carnegie Science and Technology Library
For further information, you may wish to consult the following resources:

Armour, M. A. Hazardous Laboratory Chemicals: Disposal Guide; CRC Press: Boca Raton, FL, 1991. (Call Number QD64 ..A76 1991 located in Reference room 103; also in Moon library)

National Research Council. Prudent Practices for Disposal of Chemicals; Laboratories National Academy Press: Washington DC, 1983. (First edition of the Prudent Practices series, the regulatory information is dated, but the chemistry is still good).

National Research Council. Prudent Practices in the Laboratory: Handling and Disposal of Chemicals; National Academy Press: Washington, DC, 1995. (Call Number T55.3.H3 P78 1995)

World Health Organization. Series: Laboratory Decontamination of...Aflatoxins, Aromatic Amines, Hydrazines, N-Nitrosamines, N-Nitrosamides, Polycyclic Aromatic Hydrocarbons.

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5.4. Sanitary Sewer Disposal
The sanitary sewer is the system of sinks, toilets, drains and associated pipes that send wastewater to the Onondaga County Sewer System and the Metro treatment plant where it is biologically and chemically treated before discharge into the environment. Some materials can be safely discharged into the sanitary sewer and others can cause damage to health, the environment or the functioning of the wastewater plant.

General Guidelines for Drain Disposal of Chemicals

• What - Drain disposal of chemicals listed in the following list is permissible. Materials listed are water soluble, have low toxicity and are readily biodegradable organic materials. If in doubt about whether something can be drain disposed call EHO at x4132.
• Where - Use only sinks with good flow. Do not use floor drains.
• How Much - In general, limit drain disposal to a few hundred grams or milliliters per day per investigator.
• How - Use goggles, gloves, labcoat. Pour slowly into a stream of running water. Follow disposal by flushing with excess water.
• What else - Strong acids and bases must be neutralized prior to drain disposal.

Chemicals Suitable for Drain Disposal

• Readily Soluble
• Organic sugars
• Nucleotides
• Vitamins
• Surfactants
• Strongly acidic or basic solutions must be neutralized before drain disposal

Chemicals That Are Not Suitable For Drain Disposal

• Halogenated hydrocarbons
• Nitro compounds
• Mercaptans
• Malodorous chemicals
• Flammables
• Water soluble polymers that could form gels in the sewer system
• Water reactive materials
• Toxic chemicals such as carcinogens, mutagens, acutely toxic substances
• Chemicals that boil below 50 deg C (120 deg F)
• Phenolic compounds

Other materials that are not suitable include: ashes, cinders, sand, mud, straw, shavings, metal, glass, rags, tar, plastics, wood, hair, entrails, paint residues, spent lime, stone or marble dust, solid or viscous substances capable of causing obstruction to the flow of sewers.

Soluble Salt Combinations of These Ions Are Suitable for Drain Disposal

Neutralize strongly acidic or basic solutions before drain disposal.

Note: This should be done in compliance with acid-base neutralization procedures.

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5.5. Acid - Base Neutralization Procedures
This is an optional procedure which is to be done as part of the experimental process. Use it only if you have training, experience and your supervisor's OK. EHO will collect acids and bases and do the neutralization at the EHO lab.

Concentrated acids and bases should never be poured directly down a sink, even in a stream of water. Small quantities of strong acids and bases (with the EXCEPTION of chromic acid, barium hydroxide, and any material containing the elements or compounds listed in Appendix A or B) must be neutralized as part of the experimental process in small batches prior to sink disposal.

General Procedures

• Get authorization and training from your supervisor before doing neutralizations.
• Neutralize only small quantities (less than 1 liter) of acids or bases; call EHO for disposal of large volumes.
• Use chemical splash goggles, gloves, apron or labcoat.
• Work in the fume hood; use the sash or a safety shield for protection. Neutralization can be a vigorous reaction with fumes and heat generated.
• Use a 5 gallon bucket for the neutralization - you need room for the solutions, ice and to stir safely.
• Keep containers cool during the process.
• Work slowly.
• After neutralization, flush with excess water.

Acid Neutralization

• While stirring, slowly add acids to large amounts (10 liters or so) of an ice water solution.
• Slowly add 6 M sodium hydroxide or other suitable base; continue stirring. If heat builds up, add more ice.
• Allow the solution to cool and check the pH.
• When a pH of at least 5.5 is achieved, dispose of the solution down the drain, followed by excess water.

Base Neutralization

• While stirring, slowly add the base to a large amount of an ice water solution (10 liters or so).
• Slowly add a 6 M solution of HCl or other suitable acid; continue stirring.
• Allow the solutions to cool and check the pH.
• When a pH of 9 or less is achieved, dispose of solution down the drain, followed by excess water.

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5.6. Reuse and Recycling
Reuse and recycling includes any practice employed to extend the useful life of a substance. Whenever possible, laboratories should perform in house operations to recover, re-distill and reuse organic solvents. When cleaning with solvents, reuse the spent solvent for the initial rinsing and use fresh solvent only for the final rinse. Recycle and share chemicals within a lab group or department. Investigate whether unused and unopened reagent chemicals and compressed gas cylinders can be returned to the vendor.

Excess Chemical Exchange Program
EHO operates the University Excess Chemical Exchange Program. Chemicals that are no longer needed, are in good condition and are suitable for use are eligible for the program. On the first of each month, a list of these materials is posted electronically on the Web (see Section 17). Supervisors may review the list and request the chemicals from EHO. EHO staff operates window hours on a regular basis and all excess chemical pickups must be made during this time. A signed requisition form is required for all transactions. See the Web information for more details, or call EHO at x 4132. All chemicals must be transported within appropriate secondary containment. There is no charge for either the chemicals or the service.

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5.7. Excess Chemical Example Listing

See Excess Chemical Inventory (on the EHO web site).

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5.8. Excess Chemical Example Requisition Form

See Excess Chemical Request Form (on the EHO web site).

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6. LABORATORY WASTE MANAGEMENT

The Principal Investigator (PI) or Supervisor has the ultimate responsibility for laboratory safety including chemical safety and management of waste chemicals. The PI/Supervisor must follow the procedures presented in this manual and provide instruction to personnel they supervise.

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6.1. Waste Identification and Hazard Determination
As described in Section 3, regulations require identification of hazardous wastes according to specific criteria. Laboratory personnel declare when a material is waste, but trained EHO staff makes the final determination as to whether a waste is classified hazardous. In order for EHO staff to make this determination, it is absolutely critical that the chemical components of the waste are clearly and accurately listed on the container label.

Knowing which waste chemicals are regulated is important for planning within the laboratory and for preventing waste disposal problems.

According to EPA and NY State law, waste is classified as hazardous in two ways:
(1) if it shows certain hazardous characteristics such as ignitability, corrosivity, reactivity or toxicity; OR
(2) if it appears on certain lists of chemicals developed by the EPA.

"Characteristic wastes" and "listed wastes" have detailed regulatory definitions. These are provided in Appendices A and B along with examples of common laboratory chemicals, which are classified as hazardous waste.

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6.2. Waste Containers and Storage
Collection and storage of waste within the laboratory directly involves each laboratory worker. Following the guidelines for container selection and storage assures that the waste disposal process will proceed safely and efficiently.

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6.3. Summary of Key Requirements for Laboratory Hazardous Waste Collection, Storage and Labeling
Containers must be labeled with a description of the waste material and the words "Hazardous Waste" - Use EHO label and fill them out completely using full chemical names. Keep containers tightly closed except when you fill them.

Think about compatibility. Use the Chemical Incompatibility Chart in Appendix C:

• Store waste in clean containers, free of residue. Use glass or plastic compatible with the waste. Use original containers when possible, less than 1 gallon size is best.
• Collect only compatible wastes within a container. Use separate containers for each of the following types of waste: Halogenated Organic Solvents, Non-halogenated Organic Solvents, Corrosives-acid, Corrosives-bases, Heavy metals, Elemental Mercury, Reactives, Oxidizers, Toxic(poisins), Acutely Hazardous Wastes. Refer to the original chemical MSDS or label to determine the category of waste; look it up using safety references or contact EHO for help.
• Segregate containers according to chemical compatibility.

Use secondary containment for waste containers. Inspect regularly for leaking or damaged containers. Do not fill containers completely full, leave headspace. Contact EHO at x-4132 when containers are full, or within six months, even if the container is not completely full.

Refer to the following sections for complete details on container selection, segregation of wastes, collecting and storing waste and labeling containers.

6.3.1. Waste Containers
The first step in the waste disposal process involves obtaining a suitable container for the waste. Safety is the primary consideration in container selection. Follow all the guidelines given.

How to Select Waste Containers

• Use plastic or glass containers compatible with the waste.
• Containers must have a screw on cap (or other equivalent secure closure).
• Whenever possible, use containers that hold less than 1 gallon.
• Empty containers in which the chemicals were supplied are usually adequate. Liquids must be in small-necked containers designed for liquids. Solids must be in wide-mouthed containers designed for solids.
• Containers must be clean and free of residue which might react with waste.
• Rusted, dented or degraded containers are not acceptable.
• 5 gallon or larger containers, and specialized containers such as those with flame arrest or pressure release mechanisms must be approved by EHO.
• Do not use beakers, or other labware, coffee cans, plastic milk jugs or soda bottles.
• Do not use rubber stoppers, corks, parafilm, or glass stoppers
• EHO will provide assistance with container selection for new waste streams.

How to Segregate Waste
Not all wastes can be stored in the same container. Wastes that could react together to cause explosions, fires, leaks, fumes, heat or other releases must be collected and stored in separate containers. The correct segregation of waste allows the best disposal options - both economically and environmentally.

Use separate containers for each of the following types of waste:

• Halogenated Organic Solvents
• Non-halogenated Organic Solvents
• Corrosives - Acids
• Corrosives - Bases
• Heavy Metals
• Elemental Mercury
• Mercury- Other
• Reactives
• Oxidizers
• Toxic (Poisons)
• "Acutely" hazardous

Don't know what category your waste fits in? Not sure if you should mix wastes? LOOK IT UP:

• In This Manual see Appendix C "Incompatible Chemical Combinations".
• Check the original chemical Material Safety Data Sheet, look in the "reactivity" or "incompatibles" section.
• Check the original chemical label.
• Look in your laboratory's copy of the SU Chemical Hygiene Plan.
• Still don't know? Call EHO at x-4132.

If there is any suspicion that combined waste materials may generate gases, or are incompatible in any way, these materials should not be combined, and should be kept separate until an EHO waste pickup removes them from the area.

Collecting and Storing Waste

• Keep containers TIGHTLY CLOSED except when you fill them. This is to prevent spills, leaks, fires and your exposure to fumes - it's also the law!
• Do not fill liquid containers completely full. For a 1 gallon container, leave about 2" of headspace to prevent buildup of pressure.
• A funnel may help prevent spills when adding waste to containers; make sure it is clean and free of residues. Do not leave funnels on containers.
• Wear goggles, gloves and labcoat when adding waste to containers.
• Keep containers in good condition, handle them carefully, replace any leaking ones immediately, and make sure the outside is clean.
• Inspect regularly for leaking or damaged containers and tightly closed lids. Weekly inspections are recommended.
• Separate and protect reactive or ignitable waste from sources of ignition or reaction.
• Segregate waste containers according to chemical compatibility just as you would unused chemicals - flammables, oxidizers, reactives, corrosive acids and bases must be stored separately. Do not store all waste containers in the same place just because it is convenient!
• Use secondary containment for liquid waste. Secondary containment may be a tray, pan, bucket or other container capable of holding the contents of the primary container. Secondary containment aids in separating incompatible waste and in cleanup of leaks and spills.

Accidents Happen - Waste Container Explodes at Bowne Hall
At the end of fall semester 1996, a waste container from a University laboratory spontaneously exploded while in storage in the waste accumulation area in EHO's Bowne Hall facility. Thankfully, the facility was unoccupied and no one was injured. The potential for injury was significant - the force of the explosion destroyed the container, the heavy plastic bag overpack and blew glass shards 15 feet away! The subsequent cleanup was itself hazardous and time consuming.

Only care and constant attention to details can prevent similar accidents in the future:

• Collect only compatible wastes within a container.
• Make sure waste containers are clean and free of residues before you begin using them.
• Make sure the container itself is compatible with the waste.
• Do not fill containers completely full - leave headspace for pressure relief.
• Think about others - the safety of those who handle your waste. Follow all the guidelines on container selection and storage.

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6.4. Active Use Container Labels
When containers have inaccurate, incomplete or missing labels, they are on their way to becoming unknown chemical waste. Dealing with unknown chemicals is expensive, time consuming, dangerous and a waste of precious resources. It is easily prevented by simply making sure that all containers in a laboratory have labels. It's also the law; labels are legally required by OSHA's Laboratory Standard and the University's Chemical Hygiene Plan as well.

Don't Let Them Become Unknowns
Chemical containers in active use need labels with the following minimum information:

• Contents - The substance's common name, and manufacturer's name. Notebook reference numbers are not acceptable. Abbreviations, acronyms and formulas are not acceptable for written identification.
• Relative proportions of contents.
• Preparer's Name - Individual who prepared the container.
• Investigator Name - PI / Supervisor in charge of lab / area.
• Date - Date opened or prepared.

Replace labels, which are defaced, deteriorated or difficult to read. Keeping labels accurate and readable prevents the accumulation of unknown chemicals.

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6.5. Hazardous Waste Container Labels
Waste materials which have been identified as hazardous waste or are suspected to be hazardous waste must be held in containers and clearly labeled. The label must describe the container's contents and the words "Hazardous Waste" must appear on the label.

Labeling Hazardous Waste Containers
As soon as waste containers are put into use, they must be labeled. Contact EHO to obtain standard labels - use only these labels to make sure information is complete. The following information must be on the label:

• The words "HAZARDOUS WASTE" must appear on the label.
• Person to contact about the waste.
• The month and year in which the first waste was placed in the container.
• The complete chemical names of all waste in the container must be listed. Full chemical names must be written out. Chemical formulas, acronyms, trade names and abbreviations are not acceptable.
• Relative proportions of contents - concentration or volume %.
• Hazard category - check off whether the material is known to be flammable, air/water reactive, toxic, oxidizer, corrosive - pH. List any other specific hazards.

Waste Mixtures With Numerous Components
Only the most abundant 5 to 10 components present need to be listed with the following exception. If the mixture contains any of the elements or compounds listed below, they must be shown on the label along with an accurate indication of the concentration.

These Substances and Concentrations Must Be Listed on Labels:

Waste containers should not be left indefinitely in the laboratory. Even if a container is not yet full, call for a waste pickup at six months after collection in the container begins or if the waste stream is not expected to reoccur.

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6.6. Original Container Waste Label Requirements
When chemicals in original containers are to be discarded, the original labels on these manufacturers' products serve as acceptable waste labels (if the chemical content is clearly listed.) However, if a trade name is the only information on the label, and chemical contents are not indicated, you will need to consult the MSDS (located in your Custodial Binder) for chemical makeup of the waste. Contact the EHO (x-4132) for assistance with obtaining more information regarding trade name products.

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6.7. Empty Chemical Containers
It is good practice for all empty chemical containers to be triple-rinsed with water or another solvent capable of removing the original material. In some cases, such triple rinsing is required or else the container itself is hazardous waste. Follow the specific procedures below depending on whether the container is to be reused or disposed of.

Reusing Empty Chemical Containers

• Triple rinse the container with water or an appropriate solvent. Rinse solvent (rinsate) may require collection as hazardous waste - contact EHO for guidance. (Whenever possible, reuse the rinse solvent for cleaning until it is spent; use fresh solvent only for the final rinse).
• Remove or mark over the old label.
• Reuse the container only with compatible new materials or waste.
• Clearly re-label the container with the full chemical name of the contents. Include a hazard warning if appropriate (e.g. corrosive, flammable, etc.)

Disposal of Empty Chemical Containers

• Triple rinse the container with water or an appropriate solvent. Rinse solvent (rinsate) may require collection as hazardous waste. (Whenever possible, reuse the rinse solvent for cleaning until it is spent; use fresh solvent only for the final rinse).
• Remove or mark over the label.
• Mark the container with the words "This Container is Triple Rinsed and Safe for Disposal".
• Place five (5) gallon or smaller containers into the regular trash.

Call EHO to arrange for disposal of large containers, containers contaminated with highly toxic or acutely toxic materials, and other containers you have questions about.

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6.8. Chemical Waste Pickup
Before requesting a chemical waste pickup, make sure you have followed the procedures above for container selection, labeling, handling and storage of hazardous waste. Make sure containers are clean on the outside and have caps that are tightly closed.

Requesting a Chemical Waste Pickup
Call EHO (x-4132) with your chemical waste pickup request. Be ready to give the following information:

• your name
• phone number
• department name
• building
• room number
• material(s) name(s) - content of the waste
• quantity
• size of containers to be picked up
• physical state of the material

A chemical pickup may also be requested electronically on the web http://sumweb.syr.edu/summon/env_hlth/public/web/index.htm

How A Chemical Waste Pickup Works

• Follow the directions above and call beforehand to schedule.
• The caller or other knowledgeable person must be present for the pickup.
• During pickup, EHO confirms all the details about your hazardous waste. The information is entered directly into a database and a "receipt" is printed for EHO internal use.
• Your signature on the receipt is required. This is certification that all hazardous properties of the waste have been identified and the information is correct.
• Waste is prepared for transport and is removed to EHO's accumulation area for appropriate disposal.
• Waste will not be removed without a signed receipt.

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6.9. Managing Unknowns

Partial Identification
Before calling EHO for pickup of a container with unidentified contents, "unknowns", a laboratory must gather all relevant information on the material. Identification and disposal of chemical unknowns is an expensive, time consuming and dangerous process. The primary concern in safety: if there is no information on the contents, unknown containers cannot be handled by EHO staff. Costs are significant as well; identification of a single unknown material can cost from $200 - $1500.

Often personnel in a research group can, by process of elimination, and knowledge of lab operations, provide valuable information on the chemical constituents or rule out hazardous constituents in an "unknown". A phone call or e-mail to a former lab occupant is well worth the time.

Worksheet for Unknown Identification
EHO provides a Worksheet for Unknown Waste Identification in Appendix D. The worksheet should be used to provide all information available. Laboratories must manage unknowns with great care. Containers must not be opened when there is any question as to the safety of such an operation. This is because some materials are friction or shock sensitive and even the act of opening the cap can cause a violent reaction.

Rule Out Explosive/Reactive Components
At the minimum, it is necessary for the laboratory to certify that certain highly reactive or explosive components are not present in a container. This is so the container can be handled by EHO staff or the University's waste disposal vendor.

The laboratory will be asked to certify that none of the following components are present in an "unknown":

• Any azide compounds/ hydrozoic acid
• Any peroxidizeable compounds
• Picric acid
• Multi-nitrated compounds
• Organic peroxides
• Class 4 oxidizers
• Explosives
• Forbidden to transport materials (DOT definition)

EHO staff will provide consultation on this identification process, but generators must provide background research, information and contact previous laboratory occupants. As hazardous waste disposal regulations become more stringent, this process is essential to operating a safe and cost controlled waste management program.

Reasonable attempts to identify unknowns must be made by the laboratory occupants. If highly reactive materials cannot be ruled out, the University must utilize a specialty waste management "reactives team" to handle and stabilize these unknown containers. This is extremely expensive, and potentially dangerous.

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7. COMPRESSED GAS CYLINDER DISPOSAL

Compressed gases include those contained in large cylinders, lecture bottles, propane and butane fuel bottles, and aerosol cans. Most compressed gas cylinders used at the University are leased from the vendor and are returned for reuse or disposal. Cylinder purchases are strongly discouraged because of the expense and difficulty associated with disposing of unused gases and cylinders. Prior to ordering a compressed gas cylinder, a disposal or return plan should be agreed upon in writing with the vendor. This plan should spell out all procedures necessary for returning the cylinder to the vendor. If no arrangements were made prior to purchase, attempts to return unwanted cylinders to the distributor or the manufacturer must still be made by the University purchaser.

Disposal

• Large cylinders and lecture bottles must be returned to the vendor for reuse or disposal. This is a departmental responsibility.
• If a vendor does not accept a gas cylinder for return, it may be necessary to treat the cylinder and contents as hazardous waste.
• EHO can accept and dispose of most empty gas cylinders and those containing atmospheric gases if vendor's arrangements can't be made.

Shipping a compressed gas cylinder

• Ask for and follow instructions from the vendor.
• Gas cylinders are generally shipped by common carrier - follow any additional instructions provided by the carrier.
• A valve cover must be present on the gas cylinder
• The correct DOT description for the contents must be on the cylinder - the shipping name, hazard class and identification number.

Cylinder Labels

• Gas cylinder contents must be clearly identified with stamps, adhesive labels, or stencils.
• An unlabeled cylinder must not be used. Contact the vendor for assistance

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7.1. Transporting Compressed Gases
Ask for and follow the instructions provided by the distributor or manufacturer to return the gas cylinder. The return of purchased cylinders is generally done via common carrier. The transportation cost is the responsibility of the laboratory or the area's administrative department. When cylinders are being returned, the applicable US Department of Transportation (DOT) regulations must be adhered to before and after the cylinder is placed on the common carrier's vehicle. Additionally, the carrier may have its own requirements that must be followed.

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7.2. "Unknown" Compressed Gas Cylinders
A gas cylinder with unknown contents must be handled as a hazardous waste through EHO. Every attempt must be made by the user to identify the vendor and contents of an unknown cylinder. Search purchase records and contact all previous users. Disposal fees for cylinders with unknown contents can be extremely expensive; as much as $2000 or more for one cylinder! Analytical procedures for identifying cylinder contents are also burdensome and expensive. It is well worth the cost of a phone call to previous personnel to help identify cylinder contents.

Unknown content cylinders must be handled with extreme care and caution. For more information on handling of compressed gas cylinders, consult the University Chemical Hygiene Plan, the vendor, or call EHO (x- 4132).

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8. MERCURY WASTE

Mercury spills occur frequently, primarily due to the common use of mercury thermometers, pressure measurement and similar devices. Elemental mercury can be recycled; EHO manages that operation for the University through normal waste pickup procedures. Mixtures of mercury compounds and other wastes are difficult waste streams to dispose of currently. Every effort must be made to minimize mercury waste mixtures.

Managing Mercury Waste

• Replace thermometers and measuring instruments containing mercury with equipment that uses non-hazardous fluids or electronic devices.
• Contact EHO if a mercury spill occurs. EHO has a special mercury vacuum, which provides the safest, most efficient means of mercury recovery and minimizes employee exposure to mercury vapors.
• Mercury mixed with other wastes is very difficult to dispose of. Mercury compounds are also difficult to dispose of. Consult EHO prior to generating mercury waste mixtures in order to develop a strategy for waste minimization and disposal.

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9. ART / PHOTOGRAPHIC WASTE

A number of art materials are hazardous both to the user and the environment. When these materials are discarded, they are subject to federal, state and local laws. Personnel handling these hazardous wastes must follow hazardous waste regulations. Art materials are often labeled with information indicating whether hazardous components are present. Material safety data sheets list detailed information about hazardous content, safe use and disposal. Users must take the time to read labels, data sheets and heed hazard warnings. At all times, select and use the least hazardous art materials available.

Following is a list of common art materials which must be carefully collected for pickup and disposal by EHO.

Flammable and Combustible Waste - Use Safety Cans Only

• Flammable and combustible liquids include linseed oil, turpentine, mineral spirits, naphtha, "solvent", petroleum distillates, pigment, oil based paint, adhesives, fixative and others.
• Check labels or material safety data sheets to find out if a material is flammable.
• Collect liquid wastes of flammable liquids only in a designated, approved flammable liquids waste can. These are special safety cans designed to prevent fires, leaks, and exposure to fumes. Do not substitute any other container for flammable liquid collection. Call EHO for questions about waste cans.
• Oily rags and rags/paper soaked with flammable liquids must be collected in designated flammable solid waste disposal cans. OILY RAGS CAN SPONTANEOUSLY IGNITE. Again, the flammable solids waste cans are safety devices designed to prevent fires - no substitutes can be made.
• Never dispose of flammable liquids down the drain. Vapors can travel through the sewer system and ignite.
• Notify EHO (x-4132) for a waste pickup when containers are full or need attention.

Aerosol Cans

• Non-functional, partly full aerosol cans should be returned to the vendor for credit and disposal whenever possible.
• Empty cans that contained non-hazardous substances, such as air freshener, should be RECYCLED in the appropriate recycling bin.
• Call EHO (x -4132) for a pickup of full or empty aerosol cans that contain or contained hazardous substances such as paints, solvents, or other chemicals.

Paint, Pigment and Finishes Paint, varnish, stain, finish or sealant may be flammable or contain heavy metals such as lead, chromium, arsenic or cadmium. Paint and pigment containing hazardous materials must not be put in the regular trash.

• Call EHO (x-4132) to arrange for a waste pickup for expired or unwanted paint, pigment, varnish, stain, finish and sealant which are flammable or contain heavy metals. Check labels for content.
• Empty paint and pigment containers of oil based paints may be placed in the regular trash.
• Dry, water based paint and pigments including latex, acrylic or vinyl acrylic, may be placed in the regular trash. Be sure there are no metal containing pigments present. Contact EHO for assistance with checking labels for hazardous materials. Only these water based materials go in the regular trash. Call EHO for disposal of all other paints, wash solutions and solvents.

Ceramics
Clay and glazes may contain heavy metals such as lead, arsenic, barium, cadmium, chromium, selenium and nickel. When clay or glaze containing these materials are discarded, they must be handled as hazardous waste; regular trash disposal is prohibited.

• Check labels to determine if clay or glaze contains hazardous materials.
• Call EHO (x 4132) to arrange for a waste pickup.
• Use lead free clay and heavy metal free glazes.

Etching
Acids and bases used in etching are corrosive materials; they must not be poured down the drain. Waste acids such as nitric acid and ferric chloride solution may also contain metals such as zinc and copper. Heavy metal disposal is regulated.

• Collect and store waste acids using the original containers in which they were supplied.
• Obtain hazardous waste labels from EHO. Fill out the label with the requested information.
• Do not fill containers completely; leave about 2" of headspace to prevent buildup of pressure.
• Call EHO (x -4132) to arrange for pickup as needed.

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10. PHOTOGRAPHY AND DARKROOMS

Fixer Waste
Fixer waste may contain silver, a valuable metal which must not be poured down the drain. Fixer waste is collected separately and the silver is reclaimed.

• Watson Community Darkrooms: Collect fixer waste in existing labeled containers. Call EHO when containers are full. Silver is reclaimed by EHO personnel using a silver reclamation unit.
• Newhouse I: Collect fixer waste in existing labeled containers. Silver is reclaimed by the photography lab staff at Newhouse I.
• All other areas which generate fixer waste must collect waste in labeled containers and contact EHO for disposal of fixer.

Stop Baths and Developer
Stop baths [and developers] may contain diluted acetic acid or potassium chrome alum; these solutions should not be poured down the drain. Check labels and MSDS's to assure there are no metals in the solutions, or ask EHO for help with determining whether hazardous materials are present. Although most of these materials are not considered hazardous waste, they must be at a neutral pH prior to drain disposal. EHO will pickup these solutions and neutralize them at the EHO facility prior to drain disposal.

• Collect stop bath and developer solutions using containers in which they were originally supplied.
• Obtain hazardous waste labels from EHO. Fill out the label with the requested information.
• Do not fill containers completely full; leave about 2" of headspace to prevent buildup of pressure.
• Call EHO (x- 4132) to arrange for disposal as needed.

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11. BATTERY RECYCLING AND DISPOSAL

Batteries contain hazardous components that must not be disposed of in the regular trash. In dormitories and other student housing, battery collection is managed by the Residence and Dining Support Services (RDSS). In those facilities, battery collection containers are provided at the main desk or RDSS office.

In non-residential areas on campus, EHO facilitates the battery collection program for the University. Each department must use specially designed battery collection containers which are available through EHO. Containers which remain in good condition are reusable. A container should be placed in a central location such as a department's main office. Contact EHO (x- 4132) for waste battery pickup when the containers are full.

Battery Disposal

• Use battery collection containers available through EHO.
• Keep containers in a central location within the department.
• Call EHO (x- 4132) when battery containers are full.

Collect Only These Batteries in Battery Collection Containers:

• Alkaline and Non-alkaline household type batteries (AA, AAA, C, D, 9 volt)
• Rechargeable batteries such as nickel-cadmium type
• "Button" batteries found in watches, calculators, pagers, cameras

DO NOT Place In Battery Collection Containers:

• Leaking batteries - these should be attended to immediately. Call EHO for assistance.
• Batteries containing liquids, such as car batteries
• Large batteries such as rechargeable camcorder and cellular phone batteries
• Other batteries not listed above

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12. FLUORESCENT LAMP DISPOSAL PROGRAM

There is a fluorescent lamp disposal program for the correct disposal of fluorescent bulbs on campus. In academic buildings, most used fluorescent lamps are classified as hazardous waste. The inside of a fluorescent tube is coated with chemicals and the tube contains a small amount of mercury vapor. Fluorescent lamps should not be placed in the regular trash. They are successfully included in a recycling program on campus. Lamps must be disposed of by contacting Physical Plant (x -1234) for lamp replacement or disposal of used fluorescent lamps.

NOTE: Regulations governing fluorescent lamp disposal in residential buildings allow alternate disposal; consult EHO for details on lamp disposal in residential areas.

Fluorescent Lamp Disposal

• Call Physical Plant (x -1234) for fluorescent lamp replacement and disposal of used lamps.
• Do not place used fluorescent lamps in the regular trash.

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13. OFFICE WASTE

Office areas may occasionally generate hazardous waste in the form of cleaning products or specialty items. Copier materials such as toner may also require special handling.

Copier Toner Cartridges - Recycle Programs
Some manufacturers have programs for returning spent toner cartridges so they can be recycled. Follow the packing and shipping instructions for toner recycle programs offered by vendors. Instructions are often found with the original packing materials.

Disposing of Dry Copier Toner
Containers of dry toner are not regulated as hazardous waste; they may be placed in the regular trash as long as several precautions are taken. Regular trash is handled roughly; if a fine powder like dry toner is released it can create a cloud of nuisance dust and a substantial mess. Follow the procedures below:

• Seal the containers well, whether partially full or full.
• If no container is available, place the spent toner in a plastic bag and seal tightly with a twist tie or knot to prevent leakage.
• Double bag and dispose of in the regular trash.

Liquid Toner - Copier Fluid
Some office equipment uses liquid toners or other fluids. Some of the fluids are considered hazardous waste and must not be put in the regular trash. Contact EHO (x-4132) for pickup of liquid toners and other copier fluids.

Laser Printer Toner Cartridges - On Campus Recharging Program
Materials Distribution has implemented a recharging program for laser printer toner cartridges. Call Materials Distribution (x-2741) for pickup of spent laser printer toner cartridges and container ordering information.

Other Office Waste
An office may occasionally generate hazardous waste in the form of cleaning items or specialty products. If waste materials or products contain solvents, petroleum distillates, toxic materials, paints, or have corrosive properties, they must not be placed in the regular trash.

• Check labels or material safety data sheets of products/waste to determine content.
• Call EHO for evaluation and instruction on proper disposal. Hazardous wastes will be picked up by EHO for disposal.

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14. REGULATED MEDICAL WASTE

The New York State Department of Health defines certain materials as Regulated Medical Waste. By law, this material must be disposed of according to procedures discussed below. These regulations resulted from the public outcry about hospital wastes and hypodermic needles found in public places. At the University, we collect and dispose of Regulated Medical Waste as well as other non-regulated biological materials that might cause public concern.

Regulated Medical Waste (RMW) is solid waste that includes infectious and non-infectious materials generated in the diagnosis, treatment, or immunization of human beings or animals in research, or in the production and testing of biological materials. RMW includes the following categories:

• Cultures and stocks. This waste includes cultures and stocks of agents infectious to humans, and associated biologicals, cultures from medical or pathological laboratories, cultures and stocks of infectious agents from research and industrial laboratories, wastes from the production of biologicals, discarded live or attenuated vaccines, or culture dishes and devices used to transfer, inoculate or mix cultures.
• Human pathological wastes. This waste includes tissue, organs, and other human specimens, or body fluids that are removed during surgery, autopsy, or other medical procedures. Also, specimens of body fluids and their containers, and discarded material saturated with such body fluids, other than urine.
• Animal waste. This waste includes discarded materials, including carcasses, body parts, body fluids, blood, or bedding originating from animals known to be contaminated with infectious agents or from animals inoculated during research, production of biologicals, or pharmaceutical testing with infectious agents.
• Human blood and blood products. This waste includes discarded waste human blood, discarded blood components (e.g. serum and plasma), containers with blood or blood components and discarded saturated material containing liquid blood or blood components. Note: Liquid blood or other body fluids may be legally disposed of via sanitary sewer in some cases- consult the Biosafety Officer, x- 4132.
• Sharps. This waste includes but is not limited to discarded unused sharps and sharps used in animal or human patient care, medical research, or clinical or pharmaceutical laboratories. It also includes hypodermic, intravenous, or other medical needles, hypodermic or intravenous syringes to which a needle is still attached, Pasteur pipettes, scalpel blades, or blood vials. This waste also includes other types of broken or unbroken glass (including slides and cover slips) in contact with infectious agents.

Management of Sharps
"Sharps" As defined above, require special handling and disposal.

• Use red plastic sharps containers for disposal of all sharps.
• Order sharps containers from Materials Distribution (x-2278). These rigid red plastic containers are specially designed for sharps and meet regulatory and safety requirements. Do not substitute other containers. These containers are identified as Product Type: Waste Collector, Product Name: Disposable Needle Collector in the University system. The following ordering information is provided:
  **Large (8 Qt.) sharps containers: CS11-0022
  **Small (4 Qt.) sharps containers: CS11-0044
  
• All other broken glass or sharp metal items should be disposed of in the broken glassware disposal container, not the regular trash.
• Broken glassware collection containers are plastic lined boxes or bags generally supplied through the department. These containers are for the safety of custodial personnel who transport these materials for trash disposal.

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14.1. Regulated Medical Waste Management Procedures
It is the responsibility of each Principal Investigator / Supervisor to set up a packaging, storage and pickup system prior to generating RMW. EHO will assist in development of a workable system. Principal investigators, area supervisors or other employees generating Regulated Medical Waste are responsible for compliance with applicable regulations and disposal program requirements. Procedures below apply to the campus with the exception of the Health Center, where some procedures vary.

Storage and Disposal of Regulated Medical Waste (RMW)

• All red bagged waste must be placed in secure, leak-proof boxes and stored to prevent decomposition or deterioration during storage, and in a manner which limits exposure to the public. The boxes are supplied by EHO.
• All RMW non-liquid materials, except for sharps must be contained in red bags which are impervious to moisture and will not tear under normal conditions. These bags are supplied by EHO.
• Use only RMW collection boxes and red plastic bags provided by EHO. These boxes and bags meet regulatory and safety requirements and are marked with biohazard warnings. Do not substitute other containers.
• Mixtures of biological specimens and hazardous chemicals, including specimens preserved in alcohol or formaldehyde, may need to be handled as hazardous waste. Contact EHO on procedures for mixtures of RMW and hazardous chemicals.
• Liquid blood or other body fluids may be legally disposed of via sanitary sewer in many cases- consult the Biosafety Officer with questions (x 4132).
• Call EHO (x- 4132) for a medical waste pickup. RMW will then be packaged for transport by EHO staff for incineration at a permitted RMW facility.
• Think of others. Materials that look like human pathological waste and red bags with biohazard warnings create a high level of concern among the public. Handle RMW according to planned procedures.
• Biological waste with the appearance of having human origin and waste that would pose a sanitary concern at the county solid waste facility should be disposed of as medical waste. For example, a non-infectious biological specimen should be disposed of as medical waste.
• Collection boxes with biohazard warnings and red bags must never be disposed of in the regular trash or used for any other purpose. Each box must be accounted for - they are numbered and assigned to an investigator.
• Contact the University's Biosafety Officer (x-4132) with questions on identification, handling, storage or disposal of RMW.
• The pickup procedure for RMW is similar to the chemical waste pickup procedure. Accurate identification of contents is required.

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14.2. Radioactive Waste
The requirements for handling and disposing of radioactive waste at the University are outlined in the University's Radiation Protection Program Handbook. For questions regarding radioactive waste, call the Radiation Protection staff at x -9130. Copies of this handbook are available at the Carnegie Library (Science and Technology Library).

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15. PHYSICAL PLANT / PRODUCTION FACILITY WASTES

The information contained in the laboratory section of the manual also applies to Physical Plant and at other production scale facilities such as the Chilled Water Plant and the Printing Plant. Zone management operations should encourage redistribution and reuse of materials between Zones. Effective and responsible waste management requires coordination between Zones. The Environmental Shop of the Central Physical Plant works with EHO to provide assistance with hazardous waste management.

Chemical Wastes
Spent, unusable, or excess chemicals produced in all zones are removed by contacting the Environmental Shop at the Central Physical Plant. Materials must have an accurate, complete, readable label identifying the contents. At the Environmental Shop, items are evaluated and redistributed when possible. Hazardous waste items are identified and tagged at this time. Thbr>

• Call the Environmental Shop (x -1120) to arrange for pickup of chemical waste. Describe the type, quantity and location of the material. Containers must have a complete, readable label. Waste will be picked up and transported back to the Environmental Shop.
• Please do not "drop off" chemicals at the Environmental Shop. Shop personnel need accurate, complete information on container contents and where the item came from. Environmental Shop personnel also have the training and spill equipment for dealing with chemicals - let them do it!
• Service agreements and contracts which may require hazardous waste removal, transport, treatment or disposal must be reviewed and approved prior to shipment by EHO. Do not make arrangements for collecting hazardous waste/spent chemicals without first contacting EHO (x-4132).

Latex Paint

• Dry latex paint may be disposed of in the regular trash.
• If a small quantity of liquid paint remains, remove the lid, allow the contents to dry and dispose of in the regular trash.
• Call the Environmental Shop for large quantities of unwanted latex paint.

Oil Based Paint, Varnish, Stain and Finishes

• Small quantities of unused or unwanted oil based paint, stain or finishes may be taken directly to the Physical Plant Paint shop where a collection drum is located.
• Call the Environmental Shop to remove large quantities of oil based paint.

Solvent Cleaning Stations
Solvent cleaning stations (e.g. "Safety Kleen") for brush washing or parts cleaning require regular service by the vendor to replace the solvent. When the solvent is transported off campus, it requires a signed hazardous waste manifest. Only personnel with the required DOT training may sign the manifest.

• Departments with solvent cleaning service must have trained personnel to sign transport manifests.
• Contracts or service agreements for solvent cleaning systems must not be made without prior approval from EHO.

Unknown Chemicals or Waste Materials
Unlabeled containers, those with unknown contents or other potentially hazardous products found in areas managed by Physical Plant must be managed as hazardous waste. Do not handle unknown containers. The contents may be reactive or hazardous. Contact EHO (x-4132) for assistance.

Flammables and Oily Rags
Rags soaked with flammable materials can spontaneously ignite. The garage at the Central Physical Plant has a drum which should be used for disposal of oily rags.

PCB Waste
Most chemical wastes are regulated under the Resource Conservation Recovery Act (RCRA) and most of the procedures in this manual relate to RCRA rules. PCB's are regulated separately under the Toxic Substances Control Act (TSCA), but are also regulated as hazardous waste under state law. There are special rules for PCB disposal. Currently, not all PCB wastes must be incinerated. Materials that contain less than 500 ppm PCB's, light ballasts and small capacitors (less than 3 pounds of PCB laden oil) can be disposed of through the Environmental Shop.

• PCB-free light ballasts are labeled as such. Ballasts without these labels are assumed to contain PCB's. Ballasts should be brought to the Environmental Shop and deposited in the bin for ballasts.
• With prior approval of Design & Construction and the Environmental Shop Supervisor, the Environmental Shop may pick up ballasts that are removed by contractors.
• Articles or equipment, including transformers, large capacitors, or old oil containing machinery, that is suspected of containing PCB's or PCB contaminated oil must be evaluated by EHO to determine the proper disposal method. Call Physical Plant for assistance (x-4132).

Pesticides
Refer to the University Pesticide Manual for detailed instruction on cleaning and disposing of pesticide containers and pesticide waste.

• Pesticides must never be placed in the trash or poured down the drain.
• To dispose of empty containers, triple rinse the container (follow instructions in the Pesticide Manual for handling rinsate), remove labels and render the container unusable. Then dispose of in the regular trash.
• Call EHO (x-4132) for disposal of waste, unwanted or excess pesticides.

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16. ELECTRONIC RESOURCES

The Environmental Health Office Home Page on the world wide web provides an overview of operations in EHO, including a description of the Hazardous Waste Management Program.

Resources
EHO Home Page

Forms Available Electronically:

• Excess Chemical Exchange Form
• Chemical Waste Pickup Request Form
• Radioactive Waste Pickup Request Form

E-Mail: EHO's staff may be contacted by e-mail. See EHO's Contacts page (on the EHO web site).

CD-ROM: The CD-ROM, Laboratory Waste Management Training / Lab Safety Procedures, covers hazardous waste regulations and procedures in greater depth than this manual. It is available for use in the EHO, through the Industrial Hygiene Supervisor (x-2447.)

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17. APPENDIX A: CHARACTERISTICS OF HAZARDOUS WASTE

According to EPA and NY State law, waste is classified as hazardous in two ways:
(1) if it shows the hazardous characteristics of ignitability, corrosivity, reactivity or toxicity;
(2) if it appears on certain lists of wastes developed by the EPA

Ignitability
Ignitable materials have one or more of these characteristics:
a) Most liquids that have a flash point of less than 60 deg C (140 deg F)
b) Materials other than liquids that are capable of burning vigorously and persistently; cause fire through friction, adsorption of moisture, or spontaneous chemical changes under standard temperature and pressure, and when ignited.
c) Flammable compressed gases, including those that form flammable mixtures.
d) Oxidizers that stimulate combustion of organic materials.

Ignitable chemicals include many common laboratory solvents such as acetone, toluene, xylene, hexane, methyl ethyl ketone, ethyl acetate, ethyl ether; gases such as hydrogen, acetylene, methane; substances such as phosphorus, lithium aluminum hydride, and benzoyl peroxide.

Corrosivity
A liquid is corrosive if it has a pH of less than 2 or greater than 12.5, or if it corrodes certain grades of steel. Only liquids can be corrosive hazardous wastes. Most of the common laboratory acids and bases are corrosive including hydrochloric, nitric, sulfur acids, ammonium hydroxide, and sodium hydroxide solutions.

Reactivity
A solid waste is reactive if:
1) It is normally unstable and undergoes violent change without detonating;
2) It reacts violently with water;
3) It forms potentially explosive mixtures with water;
4) generates toxic gases, vapors or fumes dangerous to human health when mixed with water;
5) It is a cyanide- or sulfide-bearing waste which when exposed to pH conditions between 2 and 12.5 can generate toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health;
6) It detonates or explodes when subjected to a strong initiating source or heating under confinement or at standard temperature and pressure.

Reactive chemicals include sodium metal, lithium metal, sodium cyanide, potassium cyanide.

Toxicity
A solid waste exhibits the characteristic of toxicity if it, or an extract, exceeds specified regulatory thresholds for metals, pesticides and other organic ch