OBJECTIVE:
AUTHORITY:
This policy is established to protect human health and the environment through proper management of hazardous waste that is generated on the CUC campus.
Vice President for Administration
INTRODUCTION: The Federal Resource Conservation and Recovery Act (RCRA) created the framework for hazardous waste regulation in 1976 and introduced the concept that the generator of a waste is responsible for the proper waste management from purchase to disposal + 30 years. RCRA regulations are found in 40 CFR 260 – 279.
DEFINITIONS: A hazardous waste is one that:

Causes, or significantly contributes to an increase in mortality or an increase in serious irreversible or incapacitating illness.
1


Poses a substantial present or potential hazard to human health or the environment when it is improperly treated, stored, transported, disposed of, or otherwise mismanaged.
The EPA defines hazardous waste by two different methods:

Characteristic wastes

Listed wastes
Characteristic wastes are defined by exhibiting of the four characteristics listed below:

Ignitability – A liquid with a flash point less than 140ᵒ.

Corrosivity – A waste with a pH of less than 2 (acidic) or greater than 12.5 (base).
 Reactivity – A waste with a potential for a dangerous reaction when exposed to atmospheric changes, air, water, or impact.
 Toxicity – A waste determined to be toxic through TCLP testing.
Listed wastes are identified on four lists where the material is listed as hazardous waste by definition:
 F waste codes – Non-source specific
 K waste codes – Source specific

U waste codes – Discarded commercial waste products

P waste codes – Acutely hazardous discarded commercial chemical products
Satellite accumulation:

A hazardous waste accumulation storage area which is near the point of generation and is under the control of the person responsible for the waste. There is no time limit for waste accumulated in this way; however there is a maximum quantity restriction of 55 gallons of hazardous waste or 1 quart of acutely hazardous waste. When this limit is reached it must be transported to the Main Hazardous Waste Storage
Area within 72 hours of reaching that limit or a direct pick-up by the designated Certified Hazardous Waste Disposal
2

EXPLANATION:
Company. The satellite storage area must be identified with a sign.
Main Hazardous Waste Storage Area:
 The area in which all hazardous waste is brought for storage until it is picked-up by a Certified Hazardous Waste Disposal
Company. The hazardous waste in this area must be pickedup and removed from the facility within 180 days of its delivery to this storage area.
Certified Hazardous Waste Disposal Company:

A company that is licensed by the IEPA to transport and properly manage the disposal of hazardous wastes.
All CUC generated hazardous waste disposal is under the direction of the Director of Physical Plant. Chemicals are not allowed to be disposed of in drains, in the trash, or by evaporation. All hazardous waste is required to be held in the generating department, at a posted satellite area, for subsequent pick-up and removal to the Main Hazardous Waste
Storage Area or by direct pick-up by the designated Certified Hazardous
Waste Disposal Company (See Flow Chart on page 7).
There are specific regulatory requirements for individuals who generate and are responsible for the accumulation and temporary storage of hazardous waste. They must minimize and recycle, properly label and identify, and properly contain the generated hazardous waste.
The purpose of this document is to assist the persons who generate and store hazardous waste with regulatory compliance. Any lab, classroom, or shop that generates hazardous waste is subject to unannounced inspections by the Federal Environmental Protection Agency (EPA), the
Illinois Environmental Protection Agency (IEPA), and/or the local
Authority Having Jurisdiction (AHJ). Lack of compliance can result in citation(s) and/or fines by any of these agencies.
3

CUC is classified as a Conditionally Exempt Small Quantity Generator
(CESQG). A CESQG is considered to generate 100 kilograms or less per month of hazardous waste, or 1 kilogram or less per month of acutely hazardous waste. Requirements for a CESQG include:

Must identify all hazardous waste generated.

May not accumulate more than 1,000 kilograms of hazardous waste at any time.
 Must ensure that hazardous waste is delivered to a person or facility that is certified to properly manage it.
PROCEDURE: Any CUC department that generates hazardous waste (i.e. Art
Departments, Science Departments, Housekeeping, Physical Plant,
Athletic Trainers, etc.) shall establish one or more satellite areas for the accumulation of their hazardous waste materials. A person or persons from that department will be assigned to monitor the satellite area(s).
The assigned person(s) will be responsible for maintaining an inventory of all hazardous waste stored in the satellite area, ensure proper labeling and storage to comply with EPA standards.
All chemical containers must be properly labeled before waste is put into the container. Hazardous waste containers must be marked with the words HAZARDOUS WASTE and the chemical(s) in question. The date that the first waste was placed in the container must be on the label.
For those containers with mixtures, a breakdown of the substances by percentage or volume is required.
Prevention of UNKNOWN CHEMICALS is very important. They can be a serious safety hazard and are very expensive to identify and properly dispose of. Therefore it is important that containers are properly labeled and inventory information is accurate.
All hazardous wastes shall be collected in sealable containers.
Foil or film closures are not acceptable. DO NOT put hazardous waste into sinks, drains, or in the trash. The exterior of the
4

container must be free of chemical contamination. Also, make sure that waste containers are kept at a safe temperature.
Waste containers shall be kept closed during accumulation except when adding waste to the container.
Do not overfill hazardous waste containers. Allow at least two inches of headspace for expansion.
All hazardous waste accumulation points (satellite storage areas) are required to follow proper container management practices while accumulating hazardous wastes. Proper practices are outlined below:

Use containers compatible with the waste collected.
 Place only compatible wastes in the same container. Label all containers with the words “HAZARDOUS WASTE” and include the contents, and identify components if a mixture.

Containers must be kept closed when not being filled.
 Keep incompatible wastes separated; use secondary containment as required.

Leave at least two inches of headspace in the waste container to allow for expansion while waste is in storage.
 Choose a central storage area at or near the point of waste generation and mark with a sign saying “Satellite
Accumulation Area”. All waste should be stored in this area.

Perform and document weekly inspections of containers for leaks, corrosion buildup, bulging of the container, and proper labeling.

Transfer waste from leaking containers to new containers.
Use appropriate PPE when handling hazardous waste and chemicals, such as:
 Chemical resistant apron
 Google’s or face shield
 Chemical resistant gloves
Special precautions need to be taken when dealing with water or air reactive and explosive materials that are being disposed of. Consult the
SDS for proper handling.
5

Used motor oil, machine oil, vacuum pump oil, air compressor oil, transmission or brake fluids, lubricating greases, etc. must have the words “Used Oil” on the container.
When the maximum limit of material has been reached or when a hazardous waste pick-up is announced, the person(s) overseeing the satellite storage area will contact the Director of Physical Plant (DPP) in order to have the accumulated hazardous waste transferred to the
Main Hazardous Waste Storage Area. A copy of the current inventory must accompany the transferred waste.
Using the supplied inventory sheets the DPP will coordinate with the selected Certified Hazardous Waste Disposal Company to make arrangements for pick-up and proper disposal of our accumulated hazardous waste within the 180 day limit. The DPP will maintain a file of all documentation related to hazardous waste activities.
All areas generating hazardous waste must have spill control measures in place to deal with minor non-emergency type spills. Spill kits should be readily accessible to those working in the area. Only minor non- emergency spills may be cleaned up by those working in the area.
Minor non-emergency spills are limited to those spills of non-acutely hazardous materials of less than 500 milliliters by volume or 1 pound by weight. If a minor spill occurs, use the following procedures:
 Secure area, and notify supervisor and others in the area.
 Consult the SDS, and determine if the spill meets the definition for a minor spill. If it does continue and if not see note below.
 Assemble spill control equipment.
 Absorb and containerize the spilled material.

Label the container with material, the words “Hazardous
Waste”, and the accumulated start date.
 Store spill container with other compatible hazardous waste.
NOTE: If the spill is larger than 500 milliliters, evacuate and secure the area, call 911 from a house phone, which will also automatically inform
DPS, report the spill, naming the university, the building name and room number, and if there are any injuries.
6

Review of this policy shall be performed annually.
ADOPTED: July 29,2013 LATEST REVIEW: September 26, 2014
Eifrig
Science
Dept’s
Questions regarding this policy may be directed to:
Director of Physical Plant – x3168
Campus Safety Officer – x3608
Department of Public Safety – x3039
Krentzmann
& Krentz
Art Dept’s
Satellite Accumulation Areas
Brohm Hall
Housekeeping
Service Bldg
Physical
Plant
Geisemann
Athletic
Trainers
OR
Main Hazardous Waste Storage Area
Service Bldg
Certified
Hazardous
Waste
Disposal
Company
7