HARVARD INSTITUTES OF
MEDICINE/NEW RESEARCH
BUILDING
HAZARDOUS WASTE TRAINING
For Laboratory Personnel
ENVIRONMENTAL, HEALTH, &
SAFETY (EH&S) OFFICE
Office information:
617-432-2762 phone
617-432-6186 fax
STAFF:
Christopher Neal
Jessica Sgrignuoli
Daniel Colasante
WEBPAGE:
http://www.himnrbehs.com/himnrbehs/
TRAINING AGENDA
Regulatory Requirements
 Hazardous Waste Definition
 Container Requirements
 Labeling Requirements
 Satellite Accumulation Area
 SAA Contact Responsibilities
 Waste Removal
 MWRA Requirements
 Summary
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REGULATORY REQUIREMENTS
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40 Code of Federal Regulations (CFR) 260-272
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310 Code of Massachusetts Regulations (CMR) 30.000
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Chemical Waste Management
Emergency Response
Definition of Hazardous Waste
Labeling Requirements
Satellite Accumulation Areas
Training
Emergency Response
Governing Agencies
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Environmental Protection Agency (EPA)
Massachusetts Department of Environmental Protection (DEP)
REGULATORY
REQUIREMENTS (continued)
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Resource Conservation and Recovery Act (RCRA)
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Required to maintain records from generation to disposal
(“Cradle to Grave”)
Covers collection, storage, transportation, and disposal
EPA has the responsibility for the creation and
enforcement of the regulations
Unannounced Inspections:
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Harvard University (EPA Spring 1999)
MGH (EPA May 1998, DEP)
BWH (DEP Summer 1999)
HIM/NRB BIDMC (DEP November 2005)
REGULATORY
REQUIREMENTS (continued)
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Inspectors consider containers with the
following as hazardous waste:
Displaying word “Hazardous Waste”
 Showing signs of aging
 Are rusted
 Are expired
 Are no longer in use by the laboratory
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REGULATORY
REQUIREMENTS (continued)
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Fines are extensive but dependent on
extent of deviation and potential for harm
EXTENT OF DEVIATION FROM REQUIREMENT
POTENTIAL
FOR HARM
MAJOR
MODERATE
MINOR
MAJOR
$22,000 to
$27,500
$16,500 to
$21,999
$12,100 to
$16,499
MODERATE
$8,800 to
$12,099
$5,500 to
$8,799
$3,300 to
$5,499
MINOR
$1,650 to
$3,299
$550 to
$1,649
$110 to
$549
HAZARDOUS WASTE
DEFINITION
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Waste can be divided into five categories:
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Ignitable
– Liquids with a flash point of 140°F (60°C) or less
– Solids that may cause fire through friction or the
adsorption of moisture
– Oxidizers: Liquids and Solids
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Corrosive
– Strong acids and bases with a pH less than or equal to 2.0
or greater than or equal to 12.5
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Reactive
– Unstable, reacts violently with water, explosive, or
products toxic gases when mixed with water or acid
HAZARDOUS WASTE
DEFINITION (continued)
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Waste categories (continued):
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Toxic
– Can leach toxic chemicals as determined by a special
laboratory test
– Listed on EPA’s P-list
Non-Hazardous
– Does not meet the definition of the other four
categories
A mixture is hazardous waste if any part of
the mixture is considered hazardous waste
HAZARDOUS WASTE
DEFINITION (continued)
Ways to determine the hazard category
for a chemical:
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See if chemical is listed on:
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EPA’s U-List: Hazardous Waste
EPA’s P-List: Acutely Hazardous Waste
Refer to “Hazards Associated with Commonly
Collected Chemicals at HIM/NRB”
Material Safety Data Sheet
NFPA Diamond for Chemical
Conduct a pH Test
Call HIM/NRB EH&S Office at 617-432-2762
CONTAINER REQUIREMENTS
Hazardous Waste Containers MUST:
 Be compatible with waste
 Have original label defaced
 Remain sealed when not adding
waste
 Stored in secondary containment
bin
 Have a completed hazardous waste
label
 Have only one container per waste
stream
LABELING REQUIREMENTS
Chemical Waste must be
labeled with a tag as the
waste is being collected.
Waste tags must:
1. Declare “Hazardous Waste”
2. Have contents listed with
no abbreviations including
chemical abbreviations
3. Have applicable hazards
checked off
4. Dated only when full
LABELING REQUIREMENTS
What specific problems can
you find with this waste
label?
SATELLITE ACCUMULATION
AREA (SAA)
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SAAs should be:
In a low traffic area
 At or near a point of generation of the
waste
 Away from sinks and floor drains
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NOTE: We recommend placing it in fume hood
SAA (continued)
SAA Requirements:
All waste must be in
secondary containment
 A red SAA sign with the SAA
contact information on it
 A telephone in the vicinity
 The SAA Must be
inspected on a weekly
basis
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SAA CONTACT
RESPONSIBILITIES
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Know the applicable rules and
regulations. Refer to the EH&S
web page under Waste Disposal tab
and Fact Sheets tab
Work in the laboratory
Be familiar with:
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Characteristics of the waste
The operations generating the
waste
Inspect SAA on a weekly basis
NOTE: REFER TO THE RED SIGN
POSTED AT SAA FOR
INSTRUCTIONS
WASTE REMOVAL
For Full Containers
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Date label when container becomes full, or no longer used by
laboratory
Go to Hazardous Waste Work Order Webpage. Here is the
information:
http://www.himnrbehs.com/himnrbehs/hazwaste.asp
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Username: EH&S
Password: HazWaste1
Call 617-432-6184 to request a chemical waste pickup. Call
before noon the day before the pickup.
Include name, building, room number, quantity of containers or
bottles, and type of waste (ethanol, acetone etc.)
Waste is picked up on Mondays and Thursdays
NOTE: NEVER MARK A CONTAINER UNKNOWN
WASTE REMOVAL (continued)
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Waste from the SAA is transported
to the Main Accumulation Area
(MAA) within HIM/NRB
The hazardous waste subcontractor
picks up the hazardous waste from
the MAA
The waste is transported to an offsite facility for one of the following
disposal methods:
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Fuels blending
Incineration
Landfill
WASTE REMOVAL (continued)
The waste hauler WILL NOT
accept the following:
 Biohazardous Waste
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Infectious Waste
Waste packaged in Red
Biohazardous Bags
Waste displaying the Biohazardous
Symbol
Radioactive Waste
 Radioactive and Chemical
Waste
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WASTE REMOVAL (continued)
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For chemical and radioactive waste:
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Please contact Harvard University’s
Radiation Safety Office at 617-495-2060.
For biological and chemical waste:
Render the biological component noninfectious (add 10% bleach)
 Dispose of as chemical waste
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MWRA REQUIREMENTS
The Massachusetts Water Resource Authority
(MWRA) issued the facility a Sewer Use Discharge
Permit to enable the HIM/NRB facility to discharge
into Boston’s sanitary sewer.
 In order to ensure compliance with the permit, the
following are prohibited from being dumped down
the drain:
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Volatile Organic Compounds (solvents, formaldehyde, alcohols)
Strong Acids and Bases
Heavy Metals – Mercury-containing materials
Oils – Fuel, lubricating, cruel
Waste water with pH lower than 5.5 or higher than 12.0
NOTE: NEVER PUT ANY CHEMICALS DOWN THE DRAIN
SUMMARY OF TOPICS
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Know the waste in your laboratory’s SAA
Conduct weekly inspections
Check the labels
Ensure that full containers are dated then
removed within three (3) days
Ensure that there is only one container per
waste stream or chemical
Ensure containers remain sealed unless
adding waste to the container