HAZARDOUS WASTE INSPECTIONS
Revised July 2013
EH&S performs inspections to identify, mitigate and correct non-compliance issues related to the
management of hazardous materials and waste. Information obtained is used to assist persons
responsible for these areas to comply with waste regulations.
The inspection forms provide documentation of the use of the room, the presence or absence of hazardous
materials and waste, and basic hazardous waste compliance concerns. The “Hazardous Waste
Assessment” form addresses most of the issues that state and federal inspectors look for when inspecting
University labs and shops.
Appearance or perception issues have some basis in regulatory interpretation and applicability, and may
include housekeeping practices and operational indicators such as:
• General appearance of lab or shop;
• General appearance and presence of equipment and/or chemicals;
• Contaminated surfaces, including containers, countertops, and containment systems, are indicative of
a release (spill or leak) that has not been cleaned and may therefore pose an unnecessary risk to
persons or the environment;
• Stained sinks are indicative of waste discharges;
• Residues in buckets, glassware, or other containers may be regarded as wastes, possibly leading to
open container and identification issues; and
• Inherent wastes, such as abandoned materials (e.g., professor leaves and no one assumes immediate
responsibility for materials) or old chemicals in deteriorating condition or containers.
The following is an explanation of each item reviewed during campus waste inspections.
Orderly Work Area
Safe and clean work areas are necessary for quality assurance and minimizing exposures, whether in a
lab, warehouse, or shop. Good laboratory practices are designed to protect the quality of the research,
including reagents and products, and should incorporate waste management procedures. Shops and other
non-laboratory areas should have similar procedures in place.
Subjective: There is a “reasonable” amount of clear work space where chemicals are dispensed, handled,
and used, including reactions/equipment in fume hoods and initial waste accumulation areas. Combustible
materials (e.g., paper, chemicals) are away from electrical outlets, ventilation panels on equipment, etc.
Work areas appear to use good housekeeping practices.
Corrective actions: Remove excessive clutter (papers, dirty glassware, and assorted “junk”) to allow for a
safer and more accessible work area.
Aisle Space
Under EPA regulations, aisle space must be sufficient to allow unobstructed movement of emergency
personnel and equipment to any area to contain or control fires or spills. EH&S and OSHA guidelines
have established this to be a minimum of approximately 30 inches, with 36 inches required for means of
egress (exit doors and hallways).
Definitive: Although estimation is acceptable, floor tiles or measuring tools (ruler, yardstick, tape
measure) may be used to confirm the recommended 30 inches for aisle space. Consider furniture,
movable equipment, gas cylinders, and other obstructions as subject to this rule.
Corrective actions: Although 30 inches is the recommended standard, areas cited generally had less than
24 inches of aisle space. Some areas by design cannot meet the aisle space requirements, and may
warrant special protective measures. Remove obstructions to ensure aisle space requirements are met.
Spills
Contaminated surfaces, such as containers, countertops, or containment systems, are indicative of a
release (spill or leak) that has not been cleaned and may therefore pose an unnecessary risk to persons or
the environment. The simple act of pouring liquids into a funnel may create a splash, resulting in drops of
liquid contaminating surfaces. Contaminants are generally considered to expose several thousand people,
as they are presumed to be spread from the work area.
Spilled materials are often found in secondary containment units, at weighing or dispensing stations, in
fume hoods, in storage units (shelves or cabinets) and other areas where materials are handled. Spilled
materials are considered by EPA to be “waste.” As such, the material must be identified and immediately
placed in containers. Although stains may be indicative of a spill, residues are of more concern due to the
greater potential for spreading contaminants.
Definitive: All spills regardless of size must be promptly collected and managed in accordance with waste
regulations. Materials must be identified, placed in containers, and not intentionally evaporated.
Residues should not be readily removable (discoloration may not be removed as easily as “crust” or film).
Corrective actions: Areas cited had spilled materials and/or removable residues that were not placed in
containers.
Chemicals and Hazardous Materials
EPA includes storage as a process, thereby placing specific emphasis on continuing responsibility for
material management. Departments must have provisions for assuming control of materials and wastes
resulting from retirement, resignation, or other departure of personnel responsible for material
management. Chemicals that are no longer intended for use must be redistributed or disposed.
Contaminated or deteriorating reagent bottles raise concern over product quality. Age, shelf life, and
storage conditions are factors affecting the quality of the reagent, which in turn affects the quality and
safety of research and education.
Presence of hazardous materials indicates a potential for waste generation. Processes will generate wastes
at some time, which must be accumulated and evaluated for compliance with disposal requirements. EPA
considers chemicals that are improperly stored, degraded, or in degraded or contaminated containers to be
waste (abandoned by neglect).
a. Note the presence of chemicals or other hazardous materials. Hazardous materials of concern
include hazardous articles in storage (e.g., fluorescent lamps, capacitors, ballasts, and batteries
that are not in use).
b. Chemicals and their containers must be appropriately marked or labeled, and both the container
and the contents must be in good condition. Broken caps, faded or damaged labels, rusting or
deteriorating containers, and outside contamination are examples of containers in unsatisfactory
condition. The product name and/or hazard information is required for hazard communication.
Materials that have deteriorated may include those that have discolored, solidified (including
crystals that become a solid non-dispensable mass), or have otherwise become unsuitable for the
intended use. Containers with a film or other residue on the outside, or in poor condition, are
indicative of materials being managed as if they have no value, warranting a waste determination.
Definitive: Chemical (not just waste) containers and their contents must be managed in a manner that
demonstrates they have value. Labels must be legible and specify the name of the material. Containers
must be clean and free of outside contamination.
Corrective actions: Verify materials are actually needed for the work area. Dispose of materials that are
in poor condition or no longer needed. Replace defective caps or closures. Ensure all materials are
properly labeled and containers are in good condition.
Room Description
Wastes must be managed:
• in the shop or lab where they are generated, or
• in an adjacent or adjoining lab or shop, which is directly connected to the laboratory or shop of origin,
access is easily monitored from the lab or shop, and under the direct control of the same waste
generator.
“Directly connected” means the rooms are connected by an interior doorway and wastes do not pass
through hallways or other common areas. Discussions with NCDENR indicated that waste could be
accumulated in an adjoining room as described, resulting in a “one door rule” whereby wastes can only
pass through one door or doorway. Each situation must be evaluated to ensure waste areas remain visible
to personnel and verify the need for storage in the adjacent room.
Waste must be under the control of the control of the person who generated the waste. This involves
attendance and security issues, and is reflected in the examples of “directly connected” areas. Attendance
(ability to directly observe) is reduced as distance and number of partitions increase, or as access points to
the waste storage area increase.
The waste area must be under the control of an individual, and not the broad control of a department. NO
ONE is permitted to accumulate hazardous wastes in areas not under their control. Safety Plans may be
used to identify areas under an individual’s control.
Central Accumulation is when wastes are placed in a separate location from the shop or lab where they
are generated, which is not directly connected or adjacent to the laboratory or shop where the waste was
generated, regardless of whether it is under control of the same person. This also includes a satellite
accumulation area that exceeds quantity limitations (55 gallons of hazardous waste or 1 quart of acutely
hazardous) for more than three days. Because most generators are on the Main and Centennial
Campuses, and any other site may become a large quantity generator, central accumulation areas may
accumulate waste for only 90 days. Central accumulation is allowed only for EH&S facilities and
prohibited for labs and shops.
Definitive: Chemicals and wastes appear to be managed in the same room as generated.
Corrective actions: Ensure wastes are accumulated in the room where generated. Minimize any transfers
of waste between rooms. Select containers of an appropriate size and ensure wastes are submitted for
collection as containers are filled.
Presence of Waste in Lab/Shop
Wastes of concern are chemical, radioactive, and biological wastes, including contaminated debris (e.g.,
broken glass, sharps, used absorbents, etc.), deteriorated chemicals/containers, chemicals for recycling or
reclamation (distillation, treatment) and articles such as used batteries and lamps. This is not intended to
involve the normal trash or office recycling.
Most wastes are accumulated in fume hoods, in proximity to benches or other work areas, or in chemical
storage cabinets. Stained sinks are indicative of potentially improper waste disposal.
Beakers, flasks, buckets, and other containers may have material in them. Verify the status of the
containers as waste or product.
Definitive: Chemicals or containers in poor condition, unidentified materials, containers marked as
waste, other containers described as waste or otherwise managed as if their contents had no value are all
waste materials.
Corrective actions: Determine compliance with waste management rules (remaining topics of
inspection).
Generator Control
Areas inspected must be under the control of the Principal Investigator. Wastes generated in shared
spaces (multiple PIs) should be maintained in separate containers. Consider waste may pass through only
one doorway from point of generation to point of accumulation or storage. EPA may consider chemicals
that are improperly stored, appear to be in poor condition, or in degraded or contaminated containers to be
waste (abandoned by neglect).
Wastes are initially collected at the process where they are generated, and may be transferred to
appropriate containers in an area that can be observed by the person(s) generating the waste. All
recycling and reclamation activities must also be conducted in the same room as waste accumulation.
Subjective: Waste is accumulated in the lab or shop where generated. Waste does not appear to be
coming from another room. Note: Hazardous waste personnel will determine if accumulation of wastes
from other rooms is acceptable based on conditions specific to the room.
Definitive: Abandoned materials include materials “inherited” by the PI, such as those left behind by
previous researchers (PIs or students) and construction/finishing materials (e.g., paint) after a project is
completed. Materials that a PI has determined he has no further use for should be redistributed (typically
through the department) or disposed through the waste program.
Corrective actions: It must be clear who is responsible for work areas, or where wastes are coming from.
Implement appropriate controls to ensure areas and wastes are under control of the Principal Investigator,
and wastes are accumulated in the room where generated. Ensure materials present are necessary for the
work conducted, and unwanted materials are redistributed or disposed. Waste program personnel will
evaluate the area to determine whether the area is subject to rules for satellite or central accumulation
areas.
Container Selection
Containers must be in good condition, physically and chemically compatible with their contents, and fully
capable of containing the waste under normal handling conditions. Liquids are accumulated in narrowneck screw-capped bottles, carboys, or drums. Collapsible containers for liquids must be in rigid outer
packaging. Solids may be accumulated in wide-mouth screw-capped bottles, sturdy bags, boxes, or
drums. Staining of boxes is indicative of a leak (from an inside container) or potential defect (got wet in
storage). Corrosives should be in plastic or glass (hydrofluoric acid in plastic only, nitric acid in glass
only).
Flasks, beakers, and other lab glassware may be used for initial accumulation of waste only while
attended (person must be in close proximity to the container, with container in plain view, and not
conducting extensive activities that would distract his/her attention from the waste container). These are
inappropriate for unattended waste accumulation because they cannot be properly closed or have rounded
bottoms (cannot stand without support). Food or beverage containers are not appropriate for use as waste
containers.
Definitive: Containers must include secure closures and be appropriate for their contents. Beverage
containers and containers with cork, rubber, or ground glass stoppers are not appropriate for waste.
Corrective actions: Ensure containers and their closures are appropriate, in good condition, and
compatible with the chemical and physical properties of the wastes.
Closed Containers
Containers must be sufficiently closed to minimize leaks, spills, evaporation, or other releases.
Definitive:
• Containers must be closed except when adding or removing waste. Some processes warrant keeping
the container open for an extended period, which may be acceptable only if attended (person must be
in close proximity to the container, with container in plain view, and not conducting extensive
activities that would distract his/her attention from the waste container).
• Although empty bottles may be allowed to dry, it is not acceptable to minimize wastes by evaporation.
• Waste containers connected to equipment, such as HPLC’s or GC’s, must be disconnected and closed
or have the drain line securely fitted to the bottle whereby spills will not occur if the collection bottle is
tipped over. Any non-contact water condensate line may be isolated and continually drained to a
separate container.
• Funnels with latching covers are acceptable closures only if the lid is latched and the funnel is secured
(threaded) to the container.
• Unacceptable closures for waste containers include stoppers (e.g., ground glass, rubber, or cork), illfitting screw caps, damaged spouts (usually on 5-gal. cans), damaged or stretched gaskets (drums),
cracked caps, foil, and parafilm when used by itself or in any combination of the above.
Corrective actions: Ensure containers are kept closed with appropriate closures (caps, bungs, etc.),
opening them only when adding or removing wastes. Some processes warrant keeping the container open
for an extended period, which may be acceptable only if attended (person must be in close proximity to
the container, with container in plain view, and not conducting extensive activities that would distract
his/her attention from the waste container). Funnels must be of a specific design if they are to remain in
an otherwise “closed” container. Although empty bottles may be allowed to dry, it is not acceptable to
minimize wastes by evaporating in a fume hood.
Filling of Containers
Containers of liquid wastes require adequate headspace (10%) to allow for thermal expansion. Containers
must not be filled whereby they cannot be closed. Containers must be able to handle the weight and other
physical hazards of the waste.
Definitive: Do not fill above “shoulder” of bottle, (where the curvature starts to become more horizontal).
Allow at least one inch of headspace for five-gallon containers, and three inches for 55-gallon drums.
Debris and articles (lamps, pipettes, tubing, etc.) must be fully enclosed in the container.
Corrective actions: Ensure containers of liquid wastes have sufficient headspace. Transfer excess to
another container. Ensure debris and other solid wastes are fully contained.
Container Handling
Containers, including hazardous articles such as fluorescent lamps, must be managed in a manner that
minimizes the potential for breakage, spills, or leaks. Lamps must be in boxes that meet container
management requirements (closed, properly marked, and dated). Containers shall not be stacked when
filling. Containers shall not be stored in such a way that a release may go down a drain. Processes must
not be designed for disposal to drains or trash without a documented hazardous waste determination.
Definitive: Chemicals/wastes are not used or stored in sinks. Containers that appear to be in use
(collecting waste or dispensing product) are not stacked or otherwise stored in an unsafe manner. Fragile
hazardous articles, such as fluorescent lamps, are protected and managed in closed, labeled boxes.
Corrective actions: Ensure containers and hazardous articles are stored safely, and potential spills do not
go down drains.
Secondary Containment
Secondary containment is the use of a device to minimize the uncontrolled release of material. This may
be a tray or pan, dike or berm, or similar open containment system where waste is initially accumulated
(poured into a container). All materials in a secondary containment unit should be compatible with the
containment unit and chemicals present. Materials that may react and pose a risk of fire, explosion, or
generation of toxic gas shall not be placed in the same secondary containment unit.
Evaluate waste accumulation areas for potential release routes (discharges). This should focus on
location of drains and potential for spills. Many fume hoods have small sinks, and would only require
preventive measure protecting the drain from spills (e.g., dike, berm, capped drain line). Some fume
hoods may have cabinets vented to the hood, leaving a small hole in the working surface which will also
need to be protected from spills. Ideally, any loss of material should be contained to the smallest area to
accommodate cleanup and/or recovery and minimize potential damages. The presence of floor drains,
and potential seepage through floors, warrants secondary containment for containers stored on the floor.
For accumulation where waste is generated, the presence and use of secondary containment is of more
concern than the capacity of the secondary containment. We do not require secondary containment where
labs/shops accumulate closed containers in storage (typically in a cabinet, not to be opened, no wastes
added or removed). Also, we are not looking at capacities being the greater of 100% of the largest or
10% of all containers; rather a simple system to collect incidental spills that may occur while adding
waste based on the presumption that small containers will have small volumes added at a time, while
large containers will have relatively large volumes added at a time. Minimum requirements should be
considered as:
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
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Containers up to 4 liters capacity may use a shallow tray (cafeteria-type), without regard to cumulative
capacity (not practical to have more than four 4-liter bottles on a tray).
Containers up to 15 gallons capacity may be in a shallow pan (sides typically 1-4 inches high,
depending on size of pan relative to size of container). The larger the container, the greater the
recommended containment capacity.
A dike, curbing, or berm of sufficient height to minimize the potential for liquids to enter a sink or
drain.
Laboratory reaction vessels (e.g., beakers, flasks, similar small containers) do not require secondary
containment until removed from the process and determined to be waste. Areas where liquid wastes are
first accumulated must have secondary containment for collecting incidental spills while adding waste to
containers (e.g., pouring from flask or beaker into bottle). Secondary containment is typically an open
container, and must be maintained free of cracks and gaps, with spills promptly cleaned up.
Definitive: Secondary containment requirements may be satisfied when the lab/shop uses appropriate
containment trays or pans, or has taken measures to protect drains and other openings from potential spills
or leaks.
Corrective actions: Secondary containment needs to be provided for liquid wastes, especially in areas
where wastes are poured into containers. EH&S may assist with evaluating options. EH&S may provide
a limited number of trays or pans for containers up to 5 gallons capacity where they are not currently
available.
Clean Containers
Containers, including secondary containment systems, should be reasonably clean with no visible outside
contamination. Indicators may include inks that have bled, stains, or residual contaminants or films.
Definitive: Clean container requirements apply to both containers and secondary containment units.
Containers and containment units should be clean, with no visible outside contamination (oily residues,
dried solids, etc.). Stains, ink runs, and other indicators of “wastes not getting into the container” may
attract attention, and the PI or supervisor should be prepared to describe the materials that caused the
problem and what was done to clean or remove the hazard.
Corrective actions: Containers were contaminated by spills that occurred while adding wastes. Clean
outside of containers and/or secondary containment units. Review filling procedures, and ensure
appropriate equipment and material are available for this activity.
Container Markings
Container markings should clearly indicate the container contents. Many containers in use were
previously labeled, whether by the manufacturer or the user. Old labels must be defaced prior to the
container being reused for another material or waste. Chemical formulas and abbreviations are
inappropriate for identifying materials. It is not acceptable to simply mark a location designated for a
particular type of waste without also marking the container.
Containers are labeled as “Hazardous Waste” or “Waste (chemical name)” and identified with a chemical
or product name. Hazard communication and right-to-know requires chemical names and/or constituents
to be associated with waste containers. EPA encourages descriptions (e.g., “waste solvent” is preferred
over “hazardous waste”, “waste non-halogenated solvent” is preferred over “waste solvent”, etc.) that
provide greater communication of potential hazards for area and emergency personnel. Descriptions must
be relevant to the hazard (e.g., “waste vials” does not indicate contents or contaminants of the vials).
Small items may be placed in a larger container (bag or box) to allow sufficient labels.
Containers of oil for disposal or recycling are labeled “Used Oil” and not “Waste”.
Batteries, fluorescent lamps, and other universal wastes are labeled “Universal Waste” and the
accumulation start date is recorded on the box or individual item.
Definitive:
 Oil is the only material for discard that requires the term “used”; the term “waste” is not to be used on
any container of oil.
 All other containers accumulating waste must have the word “waste” clearly marked, regardless of
whether it is disposed of through EH&S or accumulated for recycling (e.g., distillation). General
descriptions on containers must be supplemented by specific chemical information attached to or
associated with the container (e.g., log sheet referencing container number and chemical contents).
 Chemical formulas or abbreviations are not acceptable as sole identifiers (chemical names required).
 Waste containers are often reused reagent bottles. Labels must be defaced before waste is added to
avoid confusion as to contents. It may be necessary to ask lab or shop personnel what is in some
containers.
Subjective: Dates when wastes are generated or taken out of service should be recorded on the container
when wastes are first added.
Corrective actions: Ensure oils for discard are marked “used oil.” Ensure all other containers are clearly
marked with the words “Hazardous Waste” or “Waste (chemical/process name)” and all previous
markings or labels are defaced. Specific chemical names must be associated with the container. Ensure
markings are legible.
Quantity Limits
Areas must not exceed the limit of 55 gallons total of hazardous waste, or 1 quart of acute hazardous
waste. Note this requirement is by volume and not by weight. Typically, acute hazardous waste involves
certain unused products that are outdated, physically mixed with other wastes or materials, or abandoned.
Areas that exceed the hazardous waste accumulation limits will be evaluated by waste program personnel.
Definitive/Subjective: Some shops are likely to exceed the 55-gallon limit, particularly for used oil and
paints. Latex paint and most oils are not regulated as hazardous wastes (but require proper management
and disposal), while oil- or lead-based paints, fuel oils, and some refrigeration oils are hazardous waste.
Labs are restricted to 30-gallon drums, but some may have more than one in use. Bags of debris may be
difficult to evaluate, but should be included with the estimated volume limit.
Corrective actions:
(1) Ensure appropriate container sizes and timely removal of waste materials. Excess waste must be
removed within 3 calendar days. Submitting chemical waste forms over the internet informs EHSC of the
type and quantity of waste materials in an area. Wastes are scheduled for pickup based on location
(building), and consideration of quantity or significant hazard.
(2) If it is necessary to store more than 55 gallons of hazardous waste in a single room, coordinate options
with EH&S. It may be feasible to designate (by signs or other means) accumulation areas for specific
wastes. For example, a 55-gallon drum is likely to be associated with a specific process and/or disposal
option and placed in one area of the lab/shop, while various small containers may result from other steps
or processes in the same room and placed in a designated area nearby (but still in the same room, i.e.,
“near the point of generation and under the control of the process operator”). Each designated area would
have a 55-gallon limit. Note that this is not an option for areas where wastes are accumulated or stored in
an adjacent room (see guidance with Room Description and Generator Control).
Emergency Preparedness
All areas where hazardous materials are used or stored, or where hazardous processes may be conducted,
are required to be covered by current Safety Plans, which outline chemical inventories, standard and
emergency procedures, and availability of equipment. The Principal Investigator is responsible for
providing a complete inventory of hazardous materials, including chemicals, biological and radioactive
materials, and compressed gases. Work areas should have ready access to telephones, and emergency
numbers should be posted. Emergency equipment (fire extinguishers, spill supplies) should be available,
and authorized or designated personnel should be familiar with their use.
Definitive: A current Safety Plan is present in the work area. Emergency equipment and supplies are
present to the extent area personnel are authorized to use.
Corrective actions: Ensure safety plans are prepared for all areas where hazardous materials are used or
stored. Ensure safety plans are updated on an annual basis, and when significant changes are made to
processes or inventories. Notify EHSC of area reassignments, and provide updated plans as soon as
possible. Ensure access to emergency and communication equipment and emergency numbers are posted.
Ensure personnel are familiar with means of protecting themselves in the event of an emergency.