COMMONWEALTH OF MASSACHUSETTS
MASSACHUSETTS DEPARTMENT OF TRANSPORTATION
HIGHWAY DIVISION
STANDARD OPERATING PROCEDURES
SUBJECT: ROADSIDE UNKNOWN WASTE HANDLING
EFFECTIVE:
11/23/10
ISSUED:
11/23/10
S.O.P.NO. ENV-01-25-1-000
PAGE 1 OF 4
DISTRIBUTION:
A
SUPERSEDES: ENV-01-25-1-000,
Dated 8/13/08
AUTHORIZED:Signature
on original
PURPOSE
To ensure MassDOT Highway worker health and safety and to comply with appropriate Department of
Environmental Protection and Environmental Protection Agency regulations (reference 310 CMR 30, 310
CMR 40).
OVERVIEW
All pertinent definitions for this discussion can be found at the end of this document.
In order to ensure worker health and safety, all wastes encountered on MassDOT highways, rights-of-way,
not from MassDOT activities, must be classified as unknown until attempts to identify the waste or threat
associated with the waste have been concluded. Unknowns may be further classified as hazardous, toxic,
explosive, ignitable, radioactive, carcinogenic, or infectious. All medical waste is to be considered
infectious at all times. The Local Board of Health or the Massachusetts Department of Public Health may
be contacted and attempts made to identify the origin of the waste.
PROCEDURE
Before any work is completed all attempts will be made to identify the source of the waste in order to have
the proper responsible party respond. In the event MassDOT is required to respond, a qualified MassDOT
contractor(s) will be called to test, remove, transport, and dispose of the waste.
The following steps must be taken:
1. Roadside unknowns will be treated as hazardous waste unless their composition can be verified through
chemical analysis or other acceptable means.
2. The presence and location of roadside unknowns will be reported by District Maintenance Personnel (as
designated by the District Highway Director or District Maintenance Engineer) to the District Radio
Room then to the District Safety Inspector.
3. The Safety Inspector will conduct a reconnaissance of the scene to attempt to identify the material and
assess the scene for safety considerations.
4. If necessary the Safety Inspector shall notify the EMS Compliance Coordinator (ECC) and request to
have the waste assessed and removed by a licensed contractor.
5. The Safety Inspector will notify the ECC of actions taken in order to evaluate for compliance with
applicable laws and regulations.
6. No roadside unknown waste will be transported to any MassDOT Highway Facility without prior
COMMONWEALTH OF MASSACHUSETTS
MASSACHUSETTS DEPARTMENT OF TRANSPORTATION
HIGHWAY DIVISION
STANDARD OPERATING PROCEDURES
SUBJECT: ROADSIDE UNKNOWN WASTE HANDLING
EFFECTIVE:
11/23/10
ISSUED:
11/23/10
S.O.P.NO. ENV-01-25-1-000
PAGE 2 OF 4
DISTRIBUTION:
A
SUPERSEDES: ENV-01-25-1-000,
Dated 8/13/08
AUTHORIZED:Signature
on original
coordination and approval by the ECC.
APPLICABILITY
This SOP is effective for all wastes that are classified as “unknown.” Unknowns may be further classified
as hazardous, toxic, explosive, ignitable, radioactive, carcinogenic, or infectious.
All potentially unidentifiable hazardous wastes encountered on MassDOT highways or rights-of-way are
classified as unknown until attempts to identify the waste or threat associated with the waste have been
conducted by a hazardous waste contractor.
All medical waste is to be considered infectious. The Department of Public Health (617 624-6000) should
be notified or a qualified contractor should be called in immediately to conduct a removal. If applicable, the
responsible ambulance company will be notified to return to the scene of an accident to clean up and
remove of medical waste left at the side of the road.
Hazardous waste that meets the threshold limits of DEP is exempt from this SOP and requires immediate
notification of DEP. Likewise any incident which poses an imminent hazard shall be reported immediately
to the proper local and state authorities.
DEP notification criteria are broken down into two categories: Release and Threats to Release.
Releases which require immediate DEP notification include:




The material is above the Reportable Quantity.
The quantity of the material is unknown.
A water supply is in danger.
The release is/or may affect a water body or storm water system.
Threats of Release that require an immediate DEP notification include:


A release greater than or equal to the reportable quantity is about to occur.
A release may pose an imminent hazard.
Attempts should be made to contact the Potentially Responsible Party for any wastes which carry
identification as to the company, manufacture, transporter, or disposal facility.
This SOP does not supersede policies, directives, or standard operating procedures for handling roadside
spills, accidents, or emergency situations.
COMMONWEALTH OF MASSACHUSETTS
MASSACHUSETTS DEPARTMENT OF TRANSPORTATION
HIGHWAY DIVISION
STANDARD OPERATING PROCEDURES
SUBJECT: ROADSIDE UNKNOWN WASTE HANDLING
EFFECTIVE:
11/23/10
ISSUED:
11/23/10
S.O.P.NO. ENV-01-25-1-000
PAGE 3 OF 4
DISTRIBUTION:
A
SUPERSEDES: ENV-01-25-1-000,
Dated 8/13/08
AUTHORIZED:Signature
on original
RESPONSIBILITY
As outlined above it is the responsibility of the Safety Inspectors to provide expertise in determining a
course of action for responding to an incident involving a roadside unknown and to report steps taken to
secure the roadside unknown. It is also the responsibility of MassDOT Highway road crews to report any
unknown material to the Safety Inspector as soon as possible.
It is the responsibility of the MassDOT Highway Safety Division to ensure that all Safety Inspectors are
trained for the duties outlined in this SOP.
DEFINITIONS
For the purposes of this SOP the following definitions shall apply:
Hazardous Waste - A waste, or combination of wastes, which because of its quantity, concentration, or
physical, chemical or infectious characteristics may cause, or significantly contribute to an increase in
serious irreversible, or incapacitating reversible illness or pose a substantial present or potential hazard to
human health, safety, public welfare or the environment when improperly treated, stored, transported, used
or disposed of, or otherwise managed.
Infectious Waste - Any and all medical waste.
Imminent Hazard - A hazard which would pose a significant risk of harm to health, safety, public welfare
or the environment if it were present for even a short period of time.
Management - The act, manner or practice of managing, handling or controlling unknowns and/or
hazardous waste at or from MassDOT roadsides and rights-of-way, including, but not limited to, any
pouring, containment, dumping, emptying, discarding, displacement, collection, transportation, withdrawal,
storage, treatment, detoxification, immobilization, solidification, incineration, encapsulation, removal,
recycling, or disposal of such additives, waste, or wastewater.
Medical Waste - Any material of a biological nature such as:
 Blood,
 Body Fluids,
 Sharps,
 Body Parts, and
 Red Bag Waste.
Potentially Responsible Party - A person who is potentially liable pursuant to M.G.L. c. 21E for accidental
disposal or intentional dumping or disposal of unknowns or hazardous waste along MassDOT’s roadsides or
COMMONWEALTH OF MASSACHUSETTS
MASSACHUSETTS DEPARTMENT OF TRANSPORTATION
HIGHWAY DIVISION
STANDARD OPERATING PROCEDURES
SUBJECT: ROADSIDE UNKNOWN WASTE HANDLING
EFFECTIVE:
11/23/10
ISSUED:
11/23/10
S.O.P.NO. ENV-01-25-1-000
PAGE 4 OF 4
DISTRIBUTION:
A
SUPERSEDES: ENV-01-25-1-000,
Dated 8/13/08
AUTHORIZED:Signature
on original
rights-of way.
Reportable Quantity - The quantity of oil or hazardous material, for which the release or threat of release
requires notification to DEP. For the purposes of MassDOT’s response, this quantity shall be defined as
greater than or equal to 10 gallons of fluid or 10 pounds of material classified as unknown or hazardous.
Threat of Release - A substantial likelihood of a release of oil and/or hazardous material which requires
action to prevent or mitigate damage to health, safety, public welfare or the environment which may result
from the release. Circumstances which represent a threat of release include, but are not limited to, locations
containing or conducting an amount of oil and/or hazardous material in excess of the Reportable Quantity,
or of an unknown quantity, where no release has occurred but where a person suspects conditions that are
likely to result in a release.
Unknown - Any material, or container with contents, that are not known, unfamiliar, or the nature of which
has not been ascertained.