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Our Mission

Your Responsibility

Safe Disposal of Chemical Waste

Generators Classification

How to report a chemical spill?

How to schedule a pi ck up?

How to contact Risk Management?

How to respond to a chemical spill?

The mission of the Hazardous Materials Management (HMM) section of the Office of Risk Management and Safety (RMS) is to work with the campus community to develop and implement an efficient, convenient, comprehensive, and forward-looking chemical waste management program. Our priorities include:

· Protect the health and well-being of the students, faculty, staff and visitors at Auburn University.

· Develop and implement programs to minimize the amount and toxicity of chemical wastes produced.

· Dispose of chemical wastes in an environmentally sound and cost-effective manner.

The success of the hazardous waste management program depends not only on RMS but also on the conscientious efforts of you, the individual. In order for this program to be successful, you are expected to:

· Package, label and store waste solvents, unwanted chemical products and waste laboratory chemicals according to the procedures listed in Chapters 2 and 3 until this office can pick them up for subsequent storage and off-campus disposal.

· Seek the advice of Safety and Environmental Health whenever you are in doubt regarding handling and disposal of any chemical product.

· Make every effort to minimize the amount of hazardous waste that you generate, therefore reducing cost.

This Chemical Waste Management guide provides the campus community (generators) who work with hazardous materials an updated description of the program and information on how to minimize, store, handle, and package chemical wastes. An understanding of the enclosed procedures is necessary in order for generators to comply with new rules from the regulatory agencies governing hazardous materials. This manual also contains information specific to Auburn University’s philosophy on disposal and waste minimization. This guide does NOT contain specific information about the disposal of radioactive, medical, or normal solid wastes or on laboratory safety. This manual must be available to all workers in your laboratory. For information on disposal guidelines for radioactive, medical, normal solid wastes or on lab safety, please visit our website (…..) and look under …. programs. Contact Risk Management and Safety office (4-4805) for any further assistance.

All generators of chemical wastes should complete the online manifest form to schedule a waste pick-up. In addition, employees should download and print the “Waste Chemical” cards and “Recycle Material” cards. In the event that online resources are temporarily unavailable, the generator should refer to the “Quick Guide to Hazardous Waste Management” available at the end of this document. To schedule a waste pick-up using the online/paper-based waste manifest, please refer to section __ of this booklet for the proper procedures.

The “Quick Guide to Hazardous Waste Management” provides detailed instructions for completing the waste tag card and the Internal Waste Manifest as well as a blank Internal Waste Manifest. You should not write on these “master” Internal Manifests, but use them to photocopy blank forms in-house as needed. Should you ever need a replacement master copy, you can request one from this office or download one from our web site. Also included in the pocket folder is a starter pack of Waste Chemical tags.

Occasionally, you may need to contact us for additional information, or for clarification in applying the information to your specific situation. You can call us at (334) 844-4805 [on campus: 4-4805] (unless another number is specifically listed with the section in question).

Whenever the text says, “give us a call” it is referring to the telephone number for the Hazardous Materials Management Facility [web site lists address as “Camp Auburn Safety Annex”, CASA], located at 971 Camp Auburn Road. To report a chemical spill, please dial 911 and contact the main office of Risk Management and Safety (RMS), located at 316 Leach Science Center, at 4-4870.

All generators (faculty, staff and students) are responsible for proper handling and management of wastes in their areas and for ensuring that all University requirements for hazardous wastes, detailed in this manual, are followed. Principal investigators/Generators are responsible for ensuring that all personnel in their respective areas who handle hazardous wastes have been trained and know how to handle waste in their individual laboratory or work area.

Ultimately, it is the individual using these materials who is responsible for following the guidelines contained in this manual. With your cooperation, knowledge, professionalism and responsible actions, Auburn University can continue to safely and responsibly manage its hazardous waste.

If you have any comments or questions concerning these chemical waste handling procedures, please give us a call at 334-844-4917.

Hazardous Waste Determination

A solid waste is any discarded material that is not excluded by Title 40 of the Code of Federal Regulations. Certain materials are not solid waste if they are recycled in an industrial process as a substitute for raw principle feedstock. Other materials, such as domestic sewage and industrial waste water discharged under Section 402 of the Clean Water Act, are also not considered to be solid wastes. A discarded material is any material that is abandoned, recycled or considered inherently waste-like.

The EPA established a hierarchy for making waste determinations. First, one must determine if the material is excluded from the definition of a solid waste. If the material is not excluded from the solid waste classification, the generator must then determine if the material meets the criteria for being a hazardous waste. If the material exhibits a characteristic of a hazardous waste or is listed as a waste, then the material must be managed under the RCRA regulations.

Characteristic Hazardous Waste

The characteristic hazards are ignitability, corrosivity, reactivity, and toxicity. Those chemicals that exhibit a characteristic hazard are assigned an EPA code that begins with “D.”

A liquid that has a flashpoint of less than 60⁰C (140⁰F) is an ignitable waste. A solid is an ignitable waste if it is capable of causing fire through friction or absorption of moisture, or if it can undergo spontaneous chemical change that can result in vigorous and persistent burning. A substance that is an ignitable compressed gas or oxidizer is an ignitable waste.

An aqueous solution that has a pH less than, or equal to 2 or greater than or equal to 12.5 is a corrosive waste. Also, a liquid is a corrosive waste if it corrodes steel at a rate greater than 6.35 mm (0.25 inches) per year at 55⁰C (130⁰F).

A reactive waste is a material that is normally unstable and undergoes violent chemical change without detonating, can react violently with water to form potentially explosive mixtures, or can generate dangerous or possibly lethal gas. Also, any material that is capable of detonation or explosive reaction is a reactive waste.

A waste that contains one of the constituents listed in Table 1-1 is a toxic waste. A Toxic Characteristic Leaching Procedure (TCLP) is used to simulate how the material would react in a landfill if untreated. A material fails the TCLP test if it contains any listed constituent above the regulatory concentration established by EPA and is assigned the appropriate D-Code for that constituent.

Listed Hazardous Waste

About 400 chemicals and chemical wastes, some from specific industrial processes, are listed as hazardous wastes. Listed wastes have EPA codes that begin with “P”, “U”, “F” or “K”.

Examples of commercial chemical product hazardous wastes (expiration dated or unused reagents intended for disposal) include products with the generic names listed on the P and U lists from research laboratories, photography laboratories, and analytical laboratories. These items become hazardous when a decision has been made that they must be discarded or disposed. The expiration date on a product is not necessarily indicative of the end of the material’s useful life. The expiration date for some products may be extended by testing or other means. If there is another beneficial use for the material, either on-campus or off-campus, the material can be used for its intended purpose without being classified as a hazardous waste.

The P and U lists refer to discarded commercial chemical products, offspecification species, container residues, and spill residues. After these materials are used for their intended purpose, the U and P codes no longer apply. These materials can be counted as solid wastes instead of RCRA hazardous wastes if no other waste codes apply. Solid wastes are not used to determine the University’s generation status (see “Generator Classification” section on page ___). This is why the Internal Manifest asks if the material is used or unused.

The P-code and U-code list of materials is available online on our website (provide the link). The generation of P-Code waste can dramatically alter the compliance status of the university or an off-campus unit.

F-code wastes are solid wastes listed from non-specific sources. In general, these wastes are those that EPA has determined to be hazardous, but are not generated by a particular industry or manufacturing process. This category includes chemicals such as certain blends of spent halogenated solvents containing certain percentages of specific compounds, discarded unused formulations, etc. Please click here to learn more about various classes of F-code waste. The list also provides the various F-code wastes are generated at the University.

K-code wastes are solid wastes listed from specific sources involving industry. Because they are industry specific and not generated at the University, only a few examples are provided.

As a rule, persons who generate chemical wastes should not pour them down the sink or put them in the regular trash unless they are certain that the wastes are non-hazardous to humans or the environment. University personnel should consult Material Safety Data Sheets (MSDS’s), the manufacturer's container labels, reference manuals, or call us for guidance on how to dispose of these materials. Only non-hazardous solids should be disposed of in the regular trash. Non-hazardous free liquids that are water soluble may be disposed of down the sink. Free liquids that are not water soluble and materials with strong or unpleasant odors should be managed as a regulated waste. The materials listed below are suitable for sink or trash disposal in quantities less than a quart or 2 pounds.

(Provide a link to following chemicals on the website) For a more detailed list of non-hazardous chemicals that can be disposed of via the sink or solid waste receptacles, see [provide non-haz list link].

GENERATORS CLASSIFICATION

The generator status for the University is determined by this office every month. All of the waste generated and collected from the various departments on campus is individually weighed and tallied as it is received. The EPA has developed four classifications for facilities that manage hazardous waste:

These classifications, except for treatment, storage and disposal facilities, do not require an approved permit before the facility can operate. Following is an abstract description of the above mentioned categories. For details, please visit our website (___).

A facility is considered a CESQG if it generates no more than 220 lbs (100 kg) of hazardous waste and less than 2.2 lbs (1 kg) of acute hazardous waste per month. Please refer to RMS website (____) for additional requirements and criteria’s to meet various category requirements

A facility is considered a SQG if it generates between 220 and 2,200 lbs (100 and 1,000 kg) per month of hazardous waste and less than 2.2 lbs (1 kg) of acute hazardous waste per month. Please refer to RMS website (____) for additional requirements and criteria to meet various category requirements.

A facility is considered a LQG if it generates more than 2,200 lbs (1,000 kg) per month of hazardous waste or more than 2.2 lbs (1 kg) of acute hazardous waste per month. LQGs must comply with more extensive hazardous waste rules. Please refer to RMS website (____) for additional requirements and criteria to meet various category requirements.

Auburn University is usually classified as a Large Quantity Generator producing more than 2200lb (1000 Kg) per month of hazardous waste or more than 2.2 lb (1Kg) of acute hazardous waste per month. However, diligent attention paid to the quantities of waste generated by each lab or work area could conceivably aid in reclassifying the University from a LQG to a SQG, thereby saving the University significant amounts of transportation and disposal fees.

Hazardous Waste Accumulation Areas

Auburn University is inspected annually by state and federal agencies for compliance with hazardous waste regulations. When government officials inspect the Campus for compliance, they examine laboratories and other locations where waste chemicals are produced. Failure to meet hazardous waste accumulation area regulations can lead to a Notice of Violation (and possible fines) from these agencies. These are violations caused by improper laboratory procedures.

Each laboratory generating hazardous waste on campus is considered a Hazardous Waste Accumulation Area (HWAA). This is the point of generation for hazardous waste. This area is a designated place in the laboratory or work area where hazardous wastes are stored until they are ready for pickup. There must be less than 15 gallons of hazardous waste (10 gallons of flammable waste) at any one time in the hazardous waste accumulation area.

The various controls which generators must implement while handling and storing Hazardous wastes are:

1. Do not store more than 15 gallons of waste (10 gallons of waste flammable liquids) or one quart of acutely hazardous waste in the area. Please visit our website (www.auburn.edu/rms) and schedule a pick up. In case of unavailability of internet access, please call 4-4805 to schedule for a pick-up.

2. Store chemical waste in designated area. All chemical waste containers must be stored in your laboratory’s designated HWAA. A standardized HWAA sign, provided by this office, must be posted in this area. This will allow for easy inspection by regulatory authorities and clearly separates waste materials from products in use.

3. Keep containers closed. All chemical waste containers must be closed except when actually being used for the addition or removal of wastes. The most common problems found are funnels left in containers and waste containers left open in fume hoods.

4. Label all containers. You must secure either completed “Waste Chemical” or “Recycle IT™” tags on all containers for disposal by this office. Labeling all chemical containers is good laboratory practice and is required under state and federal regulations. Also by regulation, all hazardous waste containers must have the word “waste” in the descriptive label. General labels such as “Waste”, “Organic Waste”, and “Toxic Waste” are not acceptable. See Chapter 5 regarding “Unknowns.”

5. Inspect your area. Generators must inspect their accumulation areas to make sure that collection containers are clean, closed, properly labeled, segregated, not leaking and stored within secondary containment.

6. Post a copy of the Chemical Waste Management guide. Notify all personnel of the location of the Chemical Waste Management guide, Internal Manifests and Waste Chemical/Recycle It™ tags. Hazardous waste may not be moved to a different room or work area for storage.

7. Good housekeeping. Good housekeeping is the most important thing you can do to improve safety and minimize wastes. It also makes a good impression on inspectors. Do not store or leave chemicals, empty containers or cylinders in the hallways. Clean up all chemical spills immediately or call us for assistance.

For printable summary of "Requirements for Temporary Laboratory Storage of Hazardous Waste", click here.

This office maintains a list of all known Hazardous Waste Accumulation Areas at the University. These areas are inspected by this office on a regular basis to ensure compliance with basic environmental regulations. Laboratories which request a chemical pickup and are not on this list are added for future inspections. Inspections are conducted in a manner similar to those conducted by the regulatory agencies. A standard checklist is used and the person(s) in the laboratory at the time of inspection are asked questions. Upon completion of the inspection, a copy of the checklist is given to the person in the laboratory along with any necessary materials needed for laboratory compliance (i.e. labels, internal manifests, guides, etc.).

If there are any noted deficiencies, an inspection report which includes the green copy of the inspection checklist and an information sheet which explains the citation and how to correct it (them) is sent to the Principal Investigator. The majority of deficiencies can be handled within a few minutes. The requirements may seem trivial but the regulators view a one gallon waste container in the laboratory in much the same way as a 10,000 gallon tank at an industrial site.

An open container of waste is in violation of 40 CFR 173(a). Laboratories with deficiencies are re inspected within 30 days of the initial audit. For uncorrected items found during follow-up inspections, a Notice of Deficiency report is sent to the Department Head, with a copy to the Principal Investigator, noting the continuing deficiencies. If requested, these inspection forms are available for state and federal agencies to review.

Safety and Environmental Health is only responsible for aiding in laboratory compliance. Ultimately, each laboratory is responsible for their compliance. Laboratory personnel should take time during inspections to ask questions. It is also an opportunity to request compliance materials (i.e. additional tags, Internal Manifests, MSDS etc.).

Container Requirements

Generators are suggested to read the following recommendations when using containers for storage and handling of hazardous materials/waste.

1. Hazardous waste should be collected in a container that is in sound condition and appropriate for the waste type. Select the smallest container available that will properly hold the material. This makes for economy and efficiency.

2. Do not store discarded materials/hazardous waste in containers of more than one gallon. Remember that Auburn University policies do not allow generators to store more than 15 gallons of a chemical waste in work areas.

3. All containers must be compatible with the specific chemical waste stored in them.

5. All waste chemical containers must be capped with a tight-fitting, screw-on cap. Beakers, Flasks, Tubes, etc. with corks and stoppers are unacceptable. Please take extra care when matching glass bottles and screw on caps. There are many similar designs which are not interchangeable. Do not leave funnels sitting in containers.

6. Containers that are improperly sealed, cracked or leaking can not be collected.

9. Do not overfill containers. Leave 2 inches of headspace in all containers greater than 1 quart holding liquid waste. Overfilled containers cannot be accepted.

Labeling

The University provides two types of tags for labeling waste chemicals. These tags have been specially designed to ensure that the University complies with the container labeling regulations established by EPA/ADEM. Only materials with these tags can be accepted for disposal. The Two types of tags are:

“RecycleIT™” tags are to be placed on chemicals that are good quality, in original containers and have the original manufacturer’s label, which could be used by someone else on-campus. Do not place “RecycleIT™” tags on obvious waste containers. In order to learn about how to complete a “RecycleIT™” tag, please click here.

If a chemical cannot be used/ recycled and can only be disposed, a “Waste Chemical” tag should be provided/placed on the container. Only materials with these tags will be accepted for disposal. While scheduling a pick-up, please ensure that all the particulars in waste chemical/recycle tags are filled completely and match the information on the internal manifest. In order to learn about how to complete a Waste Chemical tag, please click here.