University of Alaska Fairbanks
Environmental, Health, Safety, and Risk Management
May 2013

 Overview of hazardous materials regulations
 Hazardous waste at UAF
 What is hazardous waste?
 What do I do with my hazardous waste?
 Emergency response
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Hazardous materials are regulated by three primary government agencies:
 Department of Transportation (DOT)
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 Title 49, Code of Federal Regulations (49 CFR)
Occupational Safety and Health Administration (OSHA)
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 Title 29, Code of Federal Regulations (29 CFR)
Environmental Protection Agency (EPA)
 Title 40, Code of Federal Regulations (40 CFR)
The International Fire and Building Codes also regulate hazardous materials
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 DOT regulations direct us how to properly package, identify, and label hazardous materials and hazardous wastes for transportation
 OSHA regulations tell us how to protect ourselves from the effects of hazardous materials in the workplace
 EPA regulations tell us how to protect our environment
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DOT classifies hazardous materials into 9 primary hazard classes which are subdivided into multiple subsidiary risk groups. You don’t need to memorize these, but the primary hazard classes are:
Class 1 : Explosives
Class 2 : Compressed Gases
Class 3 : Flammable Liquids
Class 4 : Flammable Solids
Class 5 : Oxidizers
Class 6 : Poisons and Toxics
Class 7 : Radioactive materials
Class 8 : Corrosives
Class 9 : Miscellaneous hazardous materials that don’t fit any other hazard class… (i.e. dry ice)
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OSHA regulations include the following standards:
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Hazard Communication Standard (Hazcom, Right-to-Know)
Occupational Exposure to Hazardous Chemicals in Labs, including requirements for Chemical Hygiene Plans
Respiratory Protection Standard
Confined Space Entry Requirements
Asbestos Standard
Lead (Pb) Standard
Bloodborne Pathogen Standard
Formaldehyde, Benzene, and Methylene Chloride standards
OSHA also establishes Permissible Exposure Levels (PELs) for hazardous chemicals
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Congress placed into law several acts that the EPA uses to establish regulation to protect our environment:
 Resource Conservation Recovery Act (RCRA)
 Clean Air Act
 Clean Water Act
 Toxic Substances Control Act (TSCA)
 Emergency Planning & Community Right-to-Know Act
(EPCRA)
 Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA)
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EPA regulates hazardous waste in Alaska by authority of the Resource Conservation Recovery Act. RCRA controls include:
 Identification of hazardous wastes
 Tracking wastes from “cradle to grave”
 Setting standards for generators of wastes, transporters of wastes, and Treatment, Storage & Disposal Facilities
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RCRA requires that you:
 Label containers with a description of their contents
 Store only the permissible volume of waste in your lab
 Ensure lids and caps are securely fastened at all times, except when putting wastes into the containers
 Ensure all materials are properly segregated
 Use containers that are compatible with your waste
 Use intact containers (no cracks, holes, etc.)
 Ensure that spills and overfills do not occur
 Ensure that mismanagement does not occur
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The purpose of this training is to comply with requirements set forth by the EPA under 40 CFR 265.16
(Personnel Training)
The scope of the training is to ensure that UAF personnel who use chemicals:
1. Understand how to identify hazardous wastes
2. Understand how to package and label hazardous wastes
3. Understand how to have their hazardous materials disposed
4. Know how to respond effectively to emergencies
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 EPA conducts unannounced Compliance Evaluation
Inspections
 In the past, UAF facilities have been inspected annually
 Our goal is to comply with all regulations
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An overview of sources of hazardous waste at UAF, and its ultimate fate…
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Sources of hazardous wastes (HW) at UAF include:
 Research and academic laboratories
 Shops and repair facilities
 Art and theater departments
 Facility maintenance and grounds
 Power Plant operations
 Experimental Farm operations
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The RCRA definition of a HW generator is:
Any person, by site, whose act or process produces hazardous waste identified or listed in 40 CFR 261.3.
Generators are classified by the volume of HW that they produce per month:
CESQG = Conditionally Exempt Small Quantity Generator
SQG = Small Quantity Generator
LQG = Large Quantity Generator > 1000 kg/month or
>1 qt. of acutely hazardous waste/month
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 The UAF main campus is regulated as a Large
Quantity Generator
 UAF’s extended sites are regulated as Conditionally
Exempt Small Quantity Generators
 Examples: Toolik Field Station, Palmer Research Farm,
Kodiak Seafood & Marine Science Center, Seward Marine
Center, Lena Point Fisheries Facility (Juneau)
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 EHSRM assists UAF waste generators with waste disposal needs
 Hazardous Materials Facility (HMF) stores waste and serves as UAF’s Central Accumulation Area (CAA)
 RCRA-regulated hazardous wastes are shipped
 Every 90 days from the HMF
 By EPA-permitted transporters to EPA-permitted treatment, storage, and disposal facilities
 Annual costs: $125,000 for disposal; $400,000 total cost of hazmat program at UAF
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 EPA begins by defining all waste as a “solid” waste
(including solids, liquids, gases, and semi-solids)
 40 CFR 261.2 provides the definition of “solid waste:”
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(a)(1) A solid waste is any discarded material that is not excluded by § 261.4(a) or that is not excluded by variance granted under §§ 260.30 and 260.31.
(2) A discarded material is any material which is:
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(i) Abandoned, as explained in paragraph (b) of this section; or
(ii) Recycled, as explained in paragraph (c) of this section; or
(iii) Considered inherently waste-like, as explained in paragraph (d) of this section; or
(iv) A military munition identified as a solid waste in 40 CFR 266.202.
No need to memorize that!
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 If the waste material meets certain criteria, and is not somehow exempted or excluded from regulation, it may be a RCRA-regulated HW
 The legal definition of HW is found in 40 CFR 261.3
 (a) A solid waste, as defined in § 261.2, is a hazardous waste if:
 (1) It is not excluded from regulation as a hazardous waste under
§ 261.4(b); and
 (2) It meets any of the following criteria: (continue to next slide)
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 (i) It exhibits any of the characteristics of hazardous waste identified in subpart C of this part. However, any mixture of a waste from the extraction, beneficiation, and processing of ores and minerals excluded under § 261.4(b)(7) and any other solid waste exhibiting a characteristic of hazardous waste under subpart C is a hazardous waste only if it exhibits a characteristic that would not have been exhibited by the excluded waste alone if such mixture had not occurred, or if it continues to exhibit any of the characteristics exhibited by the non-excluded wastes prior to mixture.
Further,
 (Continue to next slide)
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 for the purposes of applying the Toxicity Characteristic to such mixtures, the mixture is also a hazardous waste if it exceeds the maximum concentration for any contaminant listed in table I to § 261.24 that would not have been exceeded by the excluded waste alone if the mixture had not occurred or if it continues to exceed the maximum concentration for any contaminant exceeded by the nonexempt waste prior to mixture.
 ( Continue to next slide)
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 (ii) It is listed in subpart D of this part and has not been excluded from the lists in subpart D of this part under §§ 260.20 and 260.22 of this chapter.
You don’t need to memorize the definition of a hazardous waste either!
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 EPA regulations (40 CFR 261.2) require that a hazardous waste determination be made on a solid waste which has been generated
 Even though you must manage your waste appropriately, you don’t have to decide what to call your waste
 UAF EHSRM Hazmat team will make final hazardous waste determinations as outlined in
40 CFR 262.11
Let’s look at the different categories as defined by the EPA
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Hazardous waste determinations are based upon whether the material is a:
 Characteristic waste
 Listed on the D-list or TCLP (Toxicity Characteristic Leaching Procedure)
 Listed waste
 Materials specifically identified on one of the following lists: F, K, U or P lists
 Universal waste
 Batteries, lamps, pesticides, mercury from thermometers
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 D001 – Ignitable Wastes (flashpoint is less than
140º F) includes oxidizers
 D002 – Corrosive Wastes (pH less than or equal to
2 or greater than or equal to 12.5)
 D003 – Reactive Wastes (water reactive, normally unstable materials, cyanides & sulfides, etc)
 D004 – TCLP Wastes
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 F-listed wastes are from non-specific sources
 Example: halogenated solvents used to degrease equipment
 K-listed wastes are from specific sources
 Example: petroleum refining or pesticide manufacturing
 U-listed wastes are toxic wastes
 P-listed wastes are acutely hazardous wastes
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Acetaldehyde
Acetone
Acetonitrile
Aniline
Benzene
Bromoform
1-Butanol
Chloroform
1,4-Dioxane
Ethyl acetate
Ethyl ether
Formaldehyde
Methyl alcohol
Methylene chloride
Phenol
Toluene
U-listed chemicals are commonly found in UAF labs
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Allyl alcohol
Ammonium vanadate
Arsenic acid
Arsenic trioxide
Carbon disulfide
2,4-Dinitrophenol
Fluorine
Nitric oxide
Osmium tetroxide
Phenylthiourea
Potassium cyanide
Sodium azide
Sodium cyanide
Thiosemicarbazide
Vanadium oxide
Vanadium pentoxide
P-listed chemicals are also fairly common in UAF labs
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 Universal wastes include the following materials that are commonly found in the workplace
 Batteries
 Fluorescent lamps
 Pesticides
 Thermometers (containing mercury)
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 Used Battery collection containers (white 5-gallon buckets) are available at many locations on campus
 Contact your Lab Manager, CHO, Shop Supervisor or EHSRM for more information
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 UAF recycles fluorescent and other lamps
 Lamp shipments are made periodically to EcoLights Northwest
 The Facilities Services Electric Shop does the vast majority of lamp replacement on campus
 EHSRM can provide lamp collection boxes and labels to you
 Boxes must be labeled with the words, “Universal Waste Lamps”,
“Waste Lamps”, or “Used Lamps” to identify the contents
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 Fill out an online UAF Non-radioactive Hazardous
Materials Transfer Request. Don’t know how? Go to slide #41.
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 If you break a mercury thermometer:
 DO NOT try to clean it up yourself ---- Call UAF Hazmat at 474-
5617 immediately for assistance
 Evacuate the area and keep traffic from walking through the spill site
 NEVER throw the material in the trash or dump it down the drain
 Don’t need your mercury thermometers or wish to exchange unbroken thermometers for similar, non-mercury thermometers, free of charge? Call EHSRM at 474-5197 to get more information.
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 Aerosol cans are considered hazardous waste under the definition of
“Characteristic Reactivity”
40 CFR Part 261.23: “….capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under confinement.”
 Often contain hazardous materials, either as the product or as the propellant
 Most aerosol cans, regardless of contents, can never be completely emptied of propellant
 Aerosol cans become a waste when…
 their contents are used up,
 malfunction (i.e. fail to spray), or
 when the contents are no longer needed
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 Used oil means: any oil that has been refined from crude oil, or any synthetic oil, that has been used and as a result of such use, is contaminated by physical or chemical impurities (40 CFR 279.1)
 Used oil must be:
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Collected in clean containers in good condition (no leakers)
Storage and transfer containers must be marked with the words
“Used Oil”
Never add solvents, part washer fluids, carb cleaners, or glycol to your used oil
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 Keep the “used oil” container closed (lid in place and secured) except when adding or removing used oil
 If you use a funnel for transfers, the funnel must be removed when not in use and the container capped
 See slide #41 to make on online request to have your used oil removed
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What do I do with my wastes and unwanted chemicals?
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 Each lab that generates waste is referred to as a
“Satellite Accumulation Area” (SAA)
 When EHSRM removes the waste from a SAA, it is transferred to the UAF Hazmat Facility or “Central
Accumulation Area”
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 For SAAs, the waste storage limits are:
 Up to 55 gallons of a hazardous waste
 Up to 1 quart (1 liter) of a P-listed waste
 50 gallons of waste at a SAA will likely be in violation of Fire
& Building Codes
Note: you do not need to accumulate 55 gallons or 1 quart of
P-listed waste before requesting waste removal!
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 As of April 2012, the Division of Hazardous Waste at EHSRM is using an online hazardous waste pick up request. Please discontinue using the old triplicate paper hazardous waste transfer request forms.
 If you have not been trained in the use of the online request, call
474-5197 to schedule a training session. Or go to the EHSRM website for more information: http://www.uaf.edu/safety/laboratory-safety/chemical-inventory/
Remember: There is no charge to your lab for chemical waste disposal
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What you need to remember…
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 Only use containers that are compatible with the materials to be collected
 Always label containers with a description of their contents
 Don’t store incompatible materials together
 Do not store wastes in the fume hood. Store in the appropriate storage cabinet (e.g., flammable, acid)
 Provide secondary containment for liquid wastes
 Always keep the container closed (lid firmly secured)
 A funnel in an open bottle is NOT a lid
 Check waste storage areas regularly (weekly).
 Inspect containers to make sure they aren’t getting brittle or starting to crack
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 Plan ahead
 Is there a product or procedure available that will accomplish the task w/o generating a hazardous waste?
 Strive for waste minimization
 Only make as much solution as you need
 Substitute less hazardous chemicals if possible
 Use microscale chemistry techniques
 Before purchasing chemicals, log onto your EHS Assistant online inventory and click on the “Surplus Chemicals” button at the top of the main page. Contact EHSRM at 474-5617 to request transfer of surplus chemicals.
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 Check the P-list - if you plan to generate a P-listed waste, contact your Chemical Hygiene Officer, Lab
Manager or EHSRM
 Never combine wastes
 If you don’t generate them together as part of a procedure, then do not mix them.
 May create hazardous reactions in the bottle (worst-case scenario), or make it more expensive for us to dispose of it (not a good scenario, but at least it didn’t blow up)
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Chemical spills, release of hazardous materials, fires, and evacuation
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 Report all spills to UAF Dispatch (474-7721) or call 911 if there is an immediate threat of harm to life or property
 Dispatch will call EHSRM Hazmat Section or the FNSB
Hazmat Team, if necessary, to request assistance with spill cleanup
 Depending on the nature of the spill, you may be asked to complete the UAF Oil and Hazardous Substance Spill
Reporting Form (available from EHSRM)
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 If you have not been trained and/or do not have the appropriate personnel protective equipment, please call for assistance!
 Never put yourself or others at risk to cleanup a spill!
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 Activate the nearest fire alarm pull station and call 911
 Evacuate the building and go to the Evacuation Assembly
Point or designated area of safe refuge
 Advise emergency personnel of anyone still inside the building
 Do not re-enter the building until authorized by emergency personnel
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 Call 911 in the event of an emergency or if anyone is in danger
 Move away from the site of the hazard to a safe location
 Follow the instructions of emergency personnel
 Alert others to stay clear of the area
 Notify emergency personnel if you have been exposed or have information regarding the release
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Know the evacuation procedures and evacuation route information for your area
Evacuate the building using the nearest safe exit
Do not use elevators!
Take personnel belongings (keys, purses etc., but don’t put yourself or others at risk by delaying evacuation)
If possible, secure any hazardous materials or equipment
Follow the directions given by emergency personnel
Go to Evacuation Assembly Points (EAPs) designated on the emergency evacuation sign for the building
Assist persons with disabilities
Do not leave the area/campus until your status has been reported to your supervisor or instructor
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Environmental, Health, Safety, and Risk Management
Visit our website at: www.uaf.edu/safety
Or call us at 474-5413
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