Office and Facility Chemical Waste Management Procedures

INTRODUCTION

Proper chemical management is necessary to protect the health and safety of the University and surrounding communities and the environment. There are federal and state regulations that require all generators of chemical waste to receive training and follow proper waste management and disposal procedures. These regulations have severe monetary and civil penalties associated with them. In recent inspections, the United States Environmental Protection Agency (USEPA) determined that colleges and universities are receiving a failing grade in environmental programs such as waste management. Between 1990 and 2004, over twelve million dollars in fines have been levied against universities and colleges for hazardous waste and other environmental violations.

DEFINITION OF CHEMICAL WASTE, Step 1

Chemical waste is defined by the United States Environmental Protection Agency and by the Delaware Department of Natural Resources and Environmental Control. Definitions, management practices and compliance are outlined in 40 Code of Federal Regulations and the Delaware Rules Governing Hazardous Waste. All policies and practices developed by the University of Delaware are designed to meet or exceed these regulations and assure compliance.

University Policy 7-18 states that all University of Delaware personnel must manage all chemical and hazardous waste in compliance with these federal and state regulations and in accordance with procedures set up by the Department of Environmental Health & Safety.

Chemical waste is a broad term and encompasses many types of materials. Consult your Material Safety Data Sheet (MSDS), Product Data Sheet or Label for a list of constituents. These sources will tell you if you have a chemical waste that needs special disposal. To reduce its long-term liability, the University is proactive in managing all of its chemical waste in an environmentally sound manner. If there are any questions on whether a material must be managed through the chemical waste management program, contact EHS or call 831-8475.

Examples of Chemical Waste include, but are not limited to:

  • Unused and surplus cleaners
    • Bleach, Windex, Ammonia, Carpet Cleaners, Disinfectants, Drain Cleaners, Oven Cleaners, Floor Wax, Floor and Wood Polishes, etc.
  • Ni-CD, Lead Acid and Vehicle Batteries
  • Mercury Thermostats and Thermometers
  • Pesticides, Fungicides, Herbicides and Fertilizers
  • Full/Partially Full Aerosol Cans and Propane Cylinders
  • Latex and Oil Based Paints
  • Smoke Detectors
  • Pool Chemicals
  • Antifreeze (Ethylene and Propylene Glycol)
  • Used and Unused Oils
  • Degreasers
  • Waste Fuels, such as Gasoline, Kerosene, Diesel Fuel and Fuel Oil
  • Solvents, Stains, Strippers, Thinners, Varnish and Wood Preservatives
  • Brake/Transmission/Power Steering Fluids
  • Finely Divided Powders
  • Syringes, Needles and Razor Blades
  • Light Ballasts
  • Any Container Labeled with Warning, Hazardous, Flammable, Poisonous, Corrosive, Toxic and/or Explosive
  • Computer/Electronic Equipment (includes cell phones and PDAs)
  • Fluorescent Light Bulbs
  • Alkaline 9 Volt, AA, AAA, C, D or other small Alkaline Batteries
  • Used Toner, Toner Cartridges and Printer/Ink Cartridges
  • Empty Aerosol Cans (e.g.: Air Fresheners, Paint, Cleaners, etc)

SELECTING A CONTAINER, Step 2

Liquid Chemical Waste

Once it is determined that chemical waste will be generated, a container must be selected prior to waste generation. For bulk solvent and aqueous liquid waste streams use a Low Density Polyethylene Nalgene container. These containers will be returned within a week to the lab and are available from most laboratory supply companies and the campus storerooms. Nalgene containers are compatible with most chemical wastes, but there are a few waste streams that should not be accumulated in these containers.

DO Not Use glass, plastic-coated glass or other re-used reagent chemical bottles to store or accumulate bulk liquid chemical waste.

Examples of chemical that should not be stored in Nalgene containers:

  • Amyl Chloride
  • Bromine
  • Butyric Acid
  • Carbon disulfide
  • Nitrobenzene
  • Sulfur Dioxide
  • Thionyl Chloride
  • Vinylidene Chloride

Certain types of Nalgene containers work best for DEHS' operations. Please try to purchase containers that meet the following requirements:

  • Low density polyethylene
  • Either a 53B or 83B screw cap
  • Containers with a large handle
  • Capacity no larger than 5 gallons

If Nalgene containers are not available you can also purchase gasoline containers from local hardware stores to store chemical wastes or you can reuse containers that the chemical was shipped in. Check the cap and container to assure that they are in good condition. Do not use containers that are old, dented, damaged, leaking or cracked. The container must be able to be capped, sealed or closed. The container must be compatible with the waste streams that will be placed in it. For example, do not use a metal container to store acids, do not use a glass container to store hydrofluoric acid, do not use glass or metal containers to store organic peroxides and do not use metal containers to store picric acid and solutions of picric acid. Do not use containers that can be confused with consumer commodities like soda bottles or milk jugs. Do not use metal containers for flammable liquid waste, unless proper bonding and grounding precautions are taken. If the operation will generate a large amount (more than 5 gallons) of waste at one time, contact DEHS to determine and supply the best type of container.

For bulk corrosive liquid waste streams, use the Justrite Safety Containers for Waste Disposal. These containers are specially designed for corrosive chemical waste and vent under emergency conditions. DO NOT store or accumulate bulk liquid corrosive chemical waste in any other container. Go to Liquid Corrosive Chemical Waste Management for more information on managing corrosive waste streams.

Do Not use containers that are old, dented, damaged, leaking or cracked. The container must be able to be capped, sealed or closed. The container must be compatible with the waste streams that will be placed in it. For example, do not use a metal container to store acids, do not use a glass container to store hydrofluoric acid, do not use glass or metal containers to store organic peroxides and do not use metal containers to store picric acid and solutions of picric acid. Do not use containers that can be confused with consumer commodities like soda bottles or milk jugs. Do not use metal containers for flammable liquid waste, unless proper bonding and grounding precautions are taken.

Clean Out of Chemicals, Cleaners, Paints, etc.

All areas should, on a periodic basis, inspect all of their stored chemicals. Look for chemicals that are no longer needed, old and out of date or unusable. Try to redistribute unneeded chemicals around the department or building. If no one else needs the chemical or if they are out of date or unusable, then package them as follows for disposal through DEHS:

  • Package by hazard class in sturdy cardboard boxes. Go to Chemical Storage for guidance on packaging by hazard class.
  • Use sufficient packing material to prevent container damage en route.
  • Place a completed chemical waste label and packing slip on the outside of the box.

Solid Waste Streams

Solid waste includes any material that has come in contact with a chemical or is potentially contaminated with a chemical. Examples include gloves, pads, papers, paper towels, clean up material, permanently contaminated glassware and plasticware, oil dry and oil contaminated debris. Review the Solid Waste Disposal Procedures for a flow chart that helps decide if a material requires management as chemical waste or if it can be placed in the normal trash. If the operation will generate a large amount (more than 5 gallons) of waste at one time contact DEHS to determine and supply the best type of container. Use the following procedures to manage solid chemical waste:

  • Use cardboard boxes, five-gallon poly pails or other sturdy container.
  • All containers must have lids.
  • Apply a completed chemical waste label on the outside of the container.
  • Line the container with a 7-mil polyethylene bag or three standard trash bags.
  • Only add compatible waste in one container.
  • Bag must be sealed unless personnel are actively adding waste. Seal the bag with a bag closure tie or a large binder clip.
  • When the container is full, seal the bag with tape. If the container is in a cardboard box, secure the box with tape as well.
  • It is important not to make these containers too heavy. Do not use overly large boxes. Only fill boxes two-thirds full if they contain broken glass.

Chemically Contaminated Sharps

Anything that is capable of cutting or puncturing must be managed in a sharps container. Examples of sharps include needles, syringes, razor blades, slides, scalpels, pipettes, broken plastic or glassware, micropipettes and pipette tips. Sharps containers are available free of charge from DEHS. Review Sharp and Piercing Object Disposal for more information about sharps management. If a sharp is chemically contaminated, simply place it in a sharps container that is labeled with a properly filled out Orange Chemical Waste Label.

Empty Chemical Containers

Empty chemical containers are still hazardous to University personnel and the environment until they are properly managed. Review the Glass Only Disposal/Empty Chemical Container Disposal Procedures for complete information on empty container management. Below is a summary of the steps required to make empty chemical containers safe for disposal:

  • Triple rinse with copious amounts of water. Collect the first rinseate as chemical waste. Rinse two and three can go down the sanitary sewer.
  • Place label over original container label or deface the label.
  • Do not replace cap on container.
  • Place empty/triple rinsed container in glass only box, recycling container or directly into the dumpster.

Waste Aerosol Cans

Aerosol cans, whether they are empty or not, can be extremely dangerous if they are improperly disposed. They can become a projectile if they are compacted in the back of a trash truck and can spray University personnel with hazardous materials. Empty aerosol cans may be recycled at any of the various campus recycling areas. Review Campus Computer, Electronic Equipment and Office Supplies Recycling for complete information on recycling. Use the following procedures for disposing of full or partially full aerosol cans:

  • Obtain a sturdy cardboard box
  • Apply a completed chemical waste label to the side of the box
  • Place the empty or waste aerosol cans in the box
  • Contact DEHS to remove with the box is full

Lead Acid and Sealed Batteries (excluding small alkaline batteries)

  • Tape over the contacts with electrical or duct tape
  • Place in a plastic bin or container if they are leaking
  • Contact DEHS for removal

Recycling and Chemical Wastes

Certain materials such as alkaline batteries, computer and electronic equipment and toner cartridges can be recycled. Review the Recycling and Waste Minimization Resources for complete information on recycling.

Labeling Chemical Waste, Step 3

After you have determined what waste you are going to generate and have obtained the appropriate containers, you must properly fill out a chemical waste label and attach it to the containers. Chemical waste labels are available from DEHS, free of charge. There are directions on the back side and they must be applied on all chemical waste containers as soon as waste is added. These labels are designed to meet the regulatory requirements, so every piece of information on the label is critical and must be completed.

How to Label:

  • The generator is the person who is filling out the waste label, not the lab group or Principal Investigator (PI) unless the PI is filling out the waste label.
  • Date the label with the date that the waste is first added.
  • Fill in building, room number and telephone number where the person who is filling out the waste label can be reached.
  • Circle the appropriate waste steam(s) or write it in.
  • List each waste constituent down to 1%; heavy metals must be listed down to the parts per million range. Label contents must add up to 100%. Volumes are acceptable.
  • Use only common chemical names or IUPAC nomenclature when listing the chemical constituents on the label.
  • Do not use:
    • Abbreviations
    • Chemical symbols
    • Trade names
  • Check the appropriate boxes for the waste stream.
  • If this waste is being moved to a Central Accumulation Area such as the Brown Solvent Shed, Colburn Solvent Shed or the McKinly Waste Storage Area, fill in the date that it is moved on the line at the bottom of the waste label.

ADDING WASTE TO A CONTAINER, Step 4

Waste can be added only after you choose the proper container and it is labeled. All personal working with chemical waste must wear the following:

  • Safety glasses
  • Splash goggles if working with liquid waste
  • Lab coat
  • Gloves specific for the compounds in use

Procedure for liquid chemical waste management:

  • Perform liquid chemical waste management in a fume hood. Mixing of liquid waste may generate toxic or corrosive aerosols.
  • Check the container label to assure that waste is being added to the correct container.
  • The container must be in secondary containment, i.e. large plastic bin or bucket.
  • Uncap the container.
  • Use a funnel sufficient for the size or the container and volume of waste being added.
  • Slowly add the waste, watching for any unintended reactions. If you observe a reaction, immediately stop adding the waste, close the fume hood sash and contact DEHS.
  • After the waste has been added, remove the funnel and seal the container with the cap.
  • Another option for liquid waste management is to use a specially designed waste funnel called ECO-Funnel. Go to Safety Ecological Funnels for more information.

Procedures for solid waste management:

STORING YOUR WASTE, Step 5

Proper storage of chemical waste is extremely important. Explosions have occurred on campus that are attributed to improper storage of chemical waste. If you improperly label a container, other laboratory personnel unknowingly may add incompatible material to the container. For example, if an organic solvent solution is added to a container that is not labeled or labeled as an aqueous inorganic acid, and a fellow researcher may generate an inorganic nitric acid solution and add it to the container. Nitric acid and organic solvents are extremely incompatible and the container over a short period of time generates pressure and explodes. Go to Chemical Storage for guidance. Adhere to the following procedures on chemical waste storage to protect the health and safety of others, protect the University's facilities and to keep the University in compliance with all federal, state and local regulations:

  • Waste containers must remain closed or sealed at all times, except when waste is being added or removed from the container.
  • Liquid waste containers must be stored in secondary containment systems according to hazard class.
  • Do not allow excess accumulation of chemical waste to build up in your lab. Review Hazardous Waste Definitions for more information on the storage quantity limitations.
  • Containers can only be filled to a maximum 90% full. Head space is needed for expansion or ease of dispensing.

Inspecting Your Waste Accumulation Areas, Step 6

All satellite chemical waste accumulation areas must be inspected on a weekly basis. This inspection does not have to be a formal inspection with documentation but laboratory personnel must inspect all chemical waste stored in their laboratories to assure the following:

  • There are no leaking containers of chemical waste.
  • All containers holding chemical waste are labeled with a completed orange chemical waste label.
  • All containers are sealed and closed. This includes waste containers holding solid chemical waste.
  • All liquid chemical wastes are stored in secondary containment bins.
  • Incompatible wastes are stored away from each other and in separate containment bins.
  • There is not an excessive accumulation of waste stored in the laboratory. Immediately correct any of the above if they are encountered during the course of the weekly inspection.

HOW TO HAVE CHEMICAL WASTE REMOVED, Step 7

Certain departments and buildings have a Central Accumulation Area (CAA) set up in close proximity to their building. Laboratories in Brown, Lammot DuPont, and Drake Hall should take their waste to the CAA. Go to Chemical Waste Removal Process for complete information on the CAA's.

Once a chemical waste container is full, DEHS should be contacted to remove the container or it should be moved to the CAA. In addition, if a chemical waste container has been in a laboratory for more than a year, it should be removed. If your building does not have a CAA, follow the procedure below:

  • You can request a chemical waste pick-up via the DEHS Web Page. Go to Chemical Waste Pick-Up Form and complete the web form. If you do not have access to a computer or if the web form does not work, contact EHS at 831-8475. We strongly encourage everyone to use the web form. This assists DEHS with complying with certain federal and state regulations and tracking programs.
  • DEHS will only remove waste that is properly labeled and in a satisfactory container. If the container is not labeled or satisfactory, an attempt will be made to find the laboratory personnel to correct the problems. If no one can be located, the container will be left and DEHS will notify the responsible parties that the container was not removed.
  • Contact EHS directly or 831-8475 if you have a large or non-routine chemical waste pick-up.

Common Violations Found in Laboratories

DEHS routinely encounter a group of common problems and issues with chemical waste. These common problems are listed below with suggestions to prevent them from occurring. The EPA has fined universities and colleges for the problems listed below. Your support in eliminating these problems will greatly reduce the University's liability.

  • Unknown / Unlabeled chemical waste is very difficult and expensive to dispose of and poses an unnecessary risk to laboratory personnel as well as University personnel handling the waste. Unlabeled containers are a direct violation of the Federal and State hazardous waste regulations. Typically, DEHS covers the cost of all wastes generated by academic departments and programs. Departments generating unknown wastes may be charged for its disposal because of the extreme costs.
    • Prevention - Label all chemical waste with an orange chemical waste label. Update the constituents on the label every time waste is added. Inspect waste on a weekly basis to assure that containers are labeled and that the labels are in good condition. Inspect your chemical reagents to assure that the labels are still attached. Tape or replace as necessary.
  • Mixing or storage of incompatible chemicals may result in an explosion, fire or generation of toxic aerosols, vapor or fumes.
    • Prevention - Having an accurate, up-to-date waste label on each container will greatly reduce the possibility of mixing incompatible materials. Store incompatibles away from each other and in separate secondary containment bins.
  • Chemical containers that are left uncapped / open - This is a direct violation of Federal and State chemical waste and air permitting regulations and must not occur
    • Prevention - Seal all containers immediately after waste is added. Inspect accumulation areas to assure all containers are sealed. Purchase and use ECO-Funnels.
  • Laboratory personnel that are inadequately trained in the proper management of chemical waste - This is a direct violation of Federal and State chemical waste regulations. Additionally a lack of training places University Personnel, facilities and the environment at risk.
  • Liquid containers stored outside of secondary containers - If container(s) fail, the contents may migrate and commingle with incompatible chemicals or migrate to floor or sink drains. This is a direct violation of the Federal and State chemical waste regulations.
    • Prevention - Store all liquid chemical waste in secondary containment.
  • Waste Containers Stored In and/or Near Sink Areas and Floor Drains - If containers leak the contents could discharge down the drain. If this occurs, it is a direct violation of the Federal and State chemical waste and safe drinking water regulations.
    • Prevention - Store all liquid chemical waste in secondary containment and away from all floor and sink drains.

Conclusion

Proper chemical waste management protects the health and safety of everyone and prevents or minimizes pollution. All generators of chemical waste should do their best to minimize the amounts or chemical waste they generate and recycle whenever possible. Please contact EHS or call 831-8475 with any questions regarding chemical waste.

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