HAZARDOUS WASTE
MANAGEMENT
Required Annual Training
for Employees of Tulane University that Generate
Hazardous Waste
May 2012
Tulane University - Office of Environmental Health & Safety (OEHS)
Objectives
•
To become familiar with Tulane University’s Policies
& Procedures concerning “Hazardous Waste”
•
To define “Hazardous Waste” (characteristic vs. listed
wastes)
•
To learn how to properly accumulate, store, label, and
dispose of “Hazardous Waste”
•
To learn methods for minimizing the amount of
“Hazardous Waste” generated.
Tulane University - Office of Environmental Health & Safety (OEHS)
Tulane University Policies and Procedures
• Tulane’s Policies and Procedures for hazardous
materials/waste are located in Section 29 of the Tulane
University Environmental Health & Safety Policies and
Procedures Manual
(http://tulane.edu/oehs/upload/PPMFullWebA.pdf )
• The policies are designed to meet all current federal, state and
local regulations concerning the management of hazardous
materials and waste.
• These procedures are designed to assist people who generate
“Hazardous Waste” at the university to safely and
appropriately manage their waste.
Tulane University - Office of Environmental Health & Safety (OEHS)
What is a Hazardous Waste?
Characteristic Waste: A substance that meets the
EPA classification(s) for any or all of the following
characteristics (40 CFR §261 Subpart C);
• Ignitability
• Corrosivity
• Reactivity
• Toxicity
Tulane University - Office of Environmental Health & Safety (OEHS)
Ignitability Characteristic
• A liquid with a flash point < 140º F
• A non-liquid that “causes fire through friction,
absorption of moisture, or spontaneous chemical
changes and burns vigorously and persistently”
• An ignitable compressed gas
• An oxidizer
Tulane University - Office of Environmental Health & Safety (OEHS)
Corrosivity Characteristic
• An aqueous solution with a pH of ≤ 2 or ≥
12.5
• A liquid that corrodes steel > 0.25 inches
(6.35mm) per year
Tulane University - Office of Environmental Health & Safety (OEHS)
Reactivity Characteristic
A material is considered reactive if it;
• Is normally unstable and undergoes violent change
without detonating
• Reacts violently with water
• Forms potentially explosive mixtures with water
• Produces toxic gases or fumes when mixed with
water
Tulane University - Office of Environmental Health & Safety (OEHS)
Reactivity Characteristic (cont’d)
• Is a cyanide or sulfide-containing material that
releases toxic gases when exposed to a pH
between 2 and 12.5
• It is capable of detonation if struck or heated
• Is readily capable of detonation at standard
temperature and pressure
• Is an explosive
Tulane University - Office of Environmental Health & Safety (OEHS)
Toxicity Characteristic
• The toxicity characteristic is applied to 39 different
chemicals (40 CFR §261.24)
• The Toxicity Characteristic Leaching Procedure
(TCLP) is performed on waste that contains one or
more these chemicals
• The TCLP simulates landfill conditions to
determine how much of the chemical(s) will leach
out into environment if disposed in a landfill
Tulane University - Office of Environmental Health & Safety (OEHS)
Toxicity Characteristic (cont’d)
• If the concentration of chemical(s) that leached
out (during testing) are equal to or greater than the
regulatory level for that particular chemical, then
the waste is consider “hazardous” by the toxicity
characteristic
• If the concentration of chemical(s) that leached
out are less than the regulatory level for that
particular chemical, then the waste can be
disposed of as regular solid waste
Tulane University - Office of Environmental Health & Safety (OEHS)
What Is A Hazardous Waste?
Listed Waste: Waste that the EPA has listed as
“hazardous” regardless of its physical
characteristics.
• Commercial Chemical Products ( P and U Lists)
– P- List (40 CFR §261.33(e)): “acutely hazardous” wastes (e.g.
physostigmine, sodium azide, strychnine)
– U-List (40 CFR §261.33(f)): “non-acutely hazardous” wastes
(e.g. formaldehyde, xylene, toluene)
Tulane University - Office of Environmental Health & Safety (OEHS)
P and U Lists
• P-Listed wastes are highly toxic; could be or are
fatal to humans and animals in low doses
• U-Listed wastes are toxic, but not considered
acutely toxic; carcinogens, mutagens, materials
that bioaccumulate
– Chemicals on the P and U lists are generally “toxic” but
can also be ignitable, corrosive, and reactive
Tulane University - Office of Environmental Health & Safety (OEHS)
What is a Hazardous Waste?
Listed Waste Cont’d:
• Process Wastes: Wastes from various sources that
EPA has determined should be regulated as
“hazardous.” ( F and K lists)
– F- List (40 CFR §261.31) : wastes from non-specific
sources (e.g. spent solvents)
– K-List (40 CFR §261.32) : industry specific wastes
Tulane University - Office of Environmental Health & Safety (OEHS)
How Do I Know if my Waste is
“Hazardous?”
• Properly characterizing waste streams can be a
complicated process, and must be done accurately
to ensure that waste is properly treated and
disposed.
• Please contact Hazardous Waste Specialist,
Michael Kopaigorodsky (504) 988-2865, for
questions regarding whether or not your waste is
“hazardous.”
Tulane University - Office of Environmental Health & Safety (OEHS)
Empty Container Disposal
Generally speaking,
empty containers are not
considered “Hazardous
Waste” and may thrown
away with regular solid
waste, or in a glass
disposal box after the
label has been removed
or defaced.
Tulane University - Office of Environmental Health & Safety (OEHS)
Rinsing Empty Containers
However, empty containers that previously
held “acutely hazardous waste” (P-listed
waste) must be triple-rinsed with an
appropriate solvent before disposal.
The solvent must then be disposed of as a
“Hazardous Waste.” Contact the OEHS (504)
988-2865, to determine if you are working
with any “acutely hazardous” materials.
Tulane University - Office of Environmental Health & Safety (OEHS)
Disposing of Empty Containers at the
TNPRC
• At the Primate Research Center, ALL containers that
previously contained hazardous materials must be rinsed, and
the first rinse must be collected and then disposed of as
“Hazardous Waste”. The container’s label must then be
removed or defaced before disposal.
• As with all campuses, empty containers that previously held
“acutely hazardous waste” (P-listed waste) must be triplerinsed with an appropriate solvent before disposal and the
solvent must be disposed of as a hazardous waste.
Tulane University - Office of Environmental Health & Safety (OEHS)
Accumulating “Hazardous
Waste”
• Capture waste in rigid containers that
are compatible with the waste.
•
Keep all containers closed (capped)
except when hazardous waste is being
added to them.
• Do not store incompatible wastes
together.
• Properly label containers once waste
has been added.
Tulane University - Office of Environmental Health & Safety (OEHS)
Accumulating “Hazardous
Waste”
Use secondary containment such as a tray or a tub to
contain hazardous waste in the event that the primary
container should leak.
Tulane University - Office of Environmental Health & Safety (OEHS)
Containerize “Hazardous Waste”
• Cans of paint without lids,
broken thermometers, and
chemically contaminated
items must be overpacked
into another container
which is free of leaks so
they can be disposed of
safely.
• The OEHS will not accept
waste that is not properly
containerized
Tulane University - Office of Environmental Health & Safety (OEHS)
To Help Minimize Costs
DO NOT MIX WASTES
• Only compatible waste solvents should be mixed
together in appropriate waste containers
• Do not mix acids and flammable materials
together
• Do not mix biological and chemical waste
• Do not mix radiological and chemical waste
These practices can greatly reduce the cost of
hazardous waste disposal.
Tulane University - Office of Environmental Health & Safety (OEHS)
Labeling Waste Containers
The following information
must be on the label:
• The words “Hazardous
Waste”
• The full name of the
chemical(s) being placed in
the container (no
abbreviations or symbols)
• Associated hazards (such as
flammable, corrosive,
reactive, toxic)
Tulane University - Office of Environmental Health & Safety (OEHS)
Labeling Waste Containers
(cont’d)
Do not rely on the Hazardous Waste Specialist
picking up your waste to label your containers for
you.
It is the waste generator’s responsibility to
properly identify and label waste and waste
containers.
The OEHS provides “Hazardous Waste” labels
upon request.
The OEHS does not accept unlabeled waste for
disposal
Tulane University - Office of Environmental Health & Safety (OEHS)
“Hazardous Waste” Disposal
Procedures
• Maintain waste in your area until collected by the OEHS
or brought to the OEHS storage facility.
• To schedule a waste pickup, submit an online “Hazardous
Waste Pickup Request Form;”
http://tulane.edu/oehs/hazard/hazwastepickuprequest.cfm.
•Please allow ~ 1 week from the time of form submission
to have your waste picked up.
Tulane University - Office of Environmental Health & Safety (OEHS)
“Hazardous Waste” Disposal
Procedures
• Tulane is not a licensed disposal facility, NEVER
dispose of “Hazardous Waste” by pouring it down
the drain or placing it in the trash.
• Do not use evaporation as a disposal method.
• Under no circumstances may anyone place chemicals
in the OEHS waste storage areas unless directed by
the Hazardous Waste Specialist or other OEHS
personnel.
Tulane University - Office of Environmental Health & Safety (OEHS)
Disposal Costs
• The OEHS is responsible for the cost of disposal
associated with chemical waste from laboratories
and other areas that is generated through normal
research and work activities.
• The OEHS is not responsible for the cost for
disposing of unwanted/old chemicals from
principle investigators/researchers/others
separating from the University.
Tulane University - Office of Environmental Health & Safety (OEHS)
“Unknown” Waste
• The OEHS can not legally transport or dispose of an
“unknown” waste.
• Unknown waste must be analyzed prior to disposal, and
the cost of analyzing such samples is the responsibility of
the department in possession of the waste.
• To avoid this, please keep all chemical containers properly
labeled and ensure that people who will separate from the
university properly identify all waste(s) prior to their
departure.
Tulane University - Office of Environmental Health & Safety (OEHS)
Lab Cleanouts
• Any department which needs disposal of chemicals that are
generated due to a lab or other area closing down or being
renovated must bear the cost for disposal of those
chemicals.
• The OEHS must receive a signed IT before it makes any
arrangements with a commercial disposal company for
removal and disposal of such chemicals.
• You must go through the OEHS for disposal of all
“Hazardous Waste”. Contact OEHS for estimates if
needed.
Tulane University - Office of Environmental Health & Safety (OEHS)
Minimizing “Hazardous Waste”
By law, a Waste minimization program is required. Waste
minimization is accomplished by:
• Source reduction (ordering less & only what is
needed)
• Surplus chemical redistribution
• Redistilling solvents
• Using mercury-free instruments
• Substituting hazardous chemicals with nonhazardous or less hazardous chemicals
• Reducing the scale of experiments
Tulane University - Office of Environmental Health & Safety (OEHS)
Chemical Waste Handling Procedures
• For a poster on chemical waste handling
procedures which can be placed in your lab or
other area for convenient reference, please go
to the following link:
http://tulane.edu/oehs/hazard/upload/ChemWasteProce.pdf
Tulane University - Office of Environmental Health & Safety (OEHS)
Radioactive Waste
Radioactive waste is regulated separately
from “Hazardous Waste” by the Nuclear
Regulatory Committee (NRC).
For questions regarding radioactive waste,
contact the Radiation Safety Officer (RSO),
Charles Reindl, at 988-2867 or email
creindl@tulane.edu.
Tulane University - Office of Environmental Health & Safety (OEHS)
Medical Waste
Medical waste is regulated by the EPA, but
collection and disposal of medical waste is
coordinated through Facilities Services.
Please contact Facilities Services on your
campus for questions regarding medical
waste and to schedule pick-ups.
Tulane University - Office of Environmental Health & Safety (OEHS)
Summary
•
Those who generate “Hazardous Waste” must adhere
to Tulane University’s Policies & Procedures
concerning hazardous waste.
•
All “Hazardous Waste” must be properly accumulated,
labeled, and disposed.
•
“Hazardous Waste” generation can be minimized by
using less toxic materials, substituting the hazardous
material with non-toxic material, or recycling the
material.
Tulane University - Office of Environmental Health & Safety (OEHS)
Questions?
• The OEHS’ role in Hazardous Waste Management is to
assist you in compliance with all applicable rules and
regulations.
• If you have questions regarding any portion of this
presentation (or any other questions) please don’t hesitate
contact us (Hazardous Waste Specialist, Michael
Kopaigorodsky; mkopaigo@tulane.edu office: (504) 9882865; cell: (504) 234-6964.
• THANK YOU!
Tulane University
Office of Environmental Health & Safety (OEHS)
Pam Fatland pfatlan@tulane.edu
Manager, Chemical Safety (504)988-2800
Michael Kopaigorodsky mkopaigo@tulane.edu
Hazardous Waste Specialist (504)988-2865
http://tulane.edu/oehs
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