The University of the Virgin Islands
Draft LABORATORY WASTE MANAGEMENT PLAN
The purpose of laboratory waste management program is
to ensure that UVI is in compliance with all federal, state, and local regulations
pertaining to the handling, storage, and disposal of solid (hazardous),
radioactive, and biological (medical) wastes.
Chemical waste may be disposed of in several different
ways. Flammable and reactive liquids and solids are usually incinerated. This
is the preferred disposal option, because it destroys the chemical and its
associated hazards. Water based solutions can be treated at wastewater
treatment plants designed for this purpose. Some materials may be land-filled,
but not many, this operation has been declared illegal by the EPA for most
chemical wastes. This "landban" has
significantly increased costs for incineration of chemicals as demand for
incinerator use has risen and few new incinerators are permitted (there is
currently a ban on new incinerator permits). Consequently, nearly all of the
hazardous waste generated at UVI must be sent to a commercial hazardous waste
incinerator or permitted fuel-blending facility. The cost of disposal ranges
from about $1 to more than $5 per pound in the
The University is classified by the DPNR and the EPA
as a Small Quantity Generator meaning that we generate less than 100 kg/month
of hazardous waste and less than 1 kg/month of acute waste (P-listed waste).
Therefore, if we contract for disposal on a yearly cycle, we can never store
more than 6000 kg of waste or 1 kg of acute hazardous waste. If we exceed these
quantities, our classification will change bringing more stringent
requirements. It is up to each individual using hazardous materials to minimize
or eliminate hazardous waste generation. The use of alternative chemicals,
which do not have to be treated as hazardous waste when they are discarded and
reducing the size and scope of laboratory experiments to control the amount of
waste produced, are effective options.
Biological hazards are naturally occurring substances
such as bacteria, fungi and moulds. In many cases, these hazards are not as
visible or well known as chemical hazards or physical hazards, such as from
fires and electrical shock. As a
precautionary measure, laboratory coats, gloves and, if necessary, masks over
the mouth, should be used in order to avoid personal contact with biological
agents. Disinfections and sterilization
procedures should be written out and applied.
Disposal methods must follow to prevent contamination of the surrounding
environment. Practicing good biological
safety or biosafety
procedures is a must for the University of the
As the front line generators of hazardous waste,
laboratory supervisors have a legal and moral responsibility to properly manage
the wastes generated as part of their laboratory operations.
SECTIONS:
I.
LABORATORY WASTE
MINIMIZATION
II.
CONTAMINATED
WASTE REMOVAL/DISPOSAL
III.
HAZARDOUS WASTE
DISPOSAL INFORMATION
Planning and Purchases
Recovery and Recycling
Hazard Determination
Listed Wastes
Characteristic Wastes
Ignitability
Reactivity
Corrosivity
Toxicity
Accumulation and Storage
Hazardous Waste Identification Tag
Point of
Generation Hazardous Waste Accumulation Area and Central Hazardous Waste
Accumulation Area Guidelines
Storage of
Waste Guidelines
Special Wastes examples: Broken Glassware, Sharps,
and Ethidium Bromide
Hazardous Waste Pickup Service
Sink Disposal
Sink Disposal Procedures
Trash Disposal
IV.
MEDICAL WASTE
(RMW) HANDLING AND DISPOSAL PROCEDURES
What
is Regulated Medical Waste? examples: Culture Media, Bio-Sharps, Animal Waste, and
Medical Waste
Segregation Requirements
Procedure for Sterilizing or Autoclaving Biohazardous Waste
V.
IMPORTANT RESPONSE AGENCIES ADDRESSES AND PHONE
NUMBERS
I. LABORATORY WASTE MINIMIZATION
1. Planning and Purchases
It is your responsibility as generators of hazardous
waste to make every attempt possible to minimize the amount produced. To the extent
that chemicals can be recovered, recycled, or reused safely, there is obvious
economic incentive to do so. In addition, materials that are recovered,
recycled, or reused do not become a liability problem or a problem for the
environment. The planning of every experiment must include the consideration of
the disposal of leftover starting materials and of the products and by products
that will be generated. Faculty, researchers, and students must incorporate
these steps when starting a project where hazardous materials will be used:
A.
When designing
your experiment, activity or project:
·
Micro-scale
whenever possible, to reduce amount of hazardous materials used.
·
Substitute less
hazardous materials where possible (i.e., latex for oil-based paint, biodegradable
cleaner for solvent).
·
Include bench-top
neutralization as part of experimental protocol, where possible.
·
Consider
recycling, re-use or reclamation of hazardous materials as part of your work;
contact EHS Coordinator for assistance.
·
Eliminate
arsenic, barium, cadmium, chromium, lead, mercury, selenium or silver.
B. When
obtaining your chemicals:
·
Check your
inventory first, to see if you have the material already.
·
Contact Lab
Supervisor or EHS Coordinator to use the campus inventory to locate and borrow
chemicals for first time or one time use.
·
Purchase the
smallest quantity of chemicals needed; the cost savings when buying larger
quantities is lost if disposal costs are added for unused material.
·
Investigate the
possibility of returning of unneeded and unopened material to the supplier.
C. When
handling or storing your chemicals:
·
Store chemicals
properly; poor storage may allow a chemical to deteriorate, become unstable, to
leak or to spill, increasing the amount of waste and cost of disposal.
·
Segregate waste
materials properly; mixing of waste types (such as chlorinated wastes and
organic wastes) increases the amount of waste and the cost of disposal.
·
Check your
chemical inventory regularly; use older material before newer to prevent an
expiration date from passing before the item can be used.
·
Ensure that
containers are in good condition and properly labeled; damaged containers
and unknowns are expensive and difficult to dispose of.
2. Recovery and Recycling
The recycling process is exempt from hazardous waste
regulation except that waste accumulated prior to recycling must be managed
according to accumulation requirements. Distillation is an example of a viable
recovery option. All residues such as still bottoms from the recycling process
are regulated and must be managed as hazardous waste.
Hazardous waste regulations now require that wastes
containing mercury be sent to a facility where mercury can be recovered in a
retort or roasting thermal process unit. These recovery methods are very
expensive ($30/kg). Most mercury waste at UVI is the result of broken
thermometers or instruments. The remainder is from surplus reagents or
experiments.
Waste minimization is the best way to reduce the
disposal problems related to mercury. Liquid metallic mercury should be
collected for shipment to a reclamation facility. Small quantities can be made
relatively free of insoluble contaminants by filtering a few times through conical
filter paper with a small hole at the bottom of the cone.
Alcohol or mineral spirit thermometers will be
substituted for mercury thermometers whenever possible. In most cases, these
can meet accuracy and range requirements. If mercury thermometers must be
purchased, use only teflon coated. Stainless steel
thermometers can be used in heating and cooling units.
Many substitutes are available for mercury reagents as
well. Some alternatives to mercuric chloride as a biocide are solutions such as
5-10% methylene chloride, 1% formalin, 1 N
hydrochloric acid, sodium azide, and sodium
hypochlorite. If mercury compounds are used as catalysts, an alternative is to
simply eliminate the catalyst and let the reaction run longer. Mercury free
catalysts such as CuSO4, TiO2 , or K2SO4 can be used in Kjedahl
digests.
Mercury spills can be collected in a flask equipped
with a pipette and rubber hose connected to a vacuum source. Small droplets of
mercury can be amalgamated with zinc dust and the resulting solids swept up.
Droplets in crevices can be converted to mercuric sulfide by dusting with
sulfur powder.
Photographic fixer solutions cannot be discharged to
the sink and will be collected for silver recovery.
Other candidates for recycling include precious
metals, scrap metals, waste oil, and formaldehyde. Every effort must be made to
determine if other materials can be reused, recovered, or recycled.
3. Treatment
In-lab treatment of small quantities of hazardous
waste is an effective way of minimizing off site treatment and disposal costs.
Elementary neutralization of corrosive wastes and treatment in accumulation
containers is exempt from permitting requirements for hazardous waste
treatment. Ideally, these treatment steps should be written into every laboratory
procedure. Potential treatment methods include phase separation of
organics/aqueous solutions and liquids/solids; acid/base neutralization;
precipitation of toxic metals and inorganic salts; oxidation of inorganic
cyanides and sulfides. Many procedures for the neutralization or destruction of
laboratory wastes are available in the following reference books:
·
Hazardous
Chemicals Information and Disposal Guide, by Dr. Margaret Ann Amour. CRC Press,
·
Prudent Practices
for Disposal of Chemicals from Laboratories, by the National Research Council.
·
Destruction of
Hazardous Chemicals in the Laboratory, by George Lunn.
Wiley,
TREATMENT OF HAZARDOUS WASTE SHOULD BE DONE VERY CAREFULLY
AND IN ACCORDANCE WITH WRITTEN PROCEDURES TO AVOID INJURY.
II. CONTAMINATED WASTE REMOVAL/DISPOSAL
To assure that minimal harm to people, other
organisms, and the environment will result from the disposal of waste laboratory
chemicals, the waste disposal program, located in Physical Plant (693-1500),
specifies how waste is to be collected, segregated, stored, and transported and
includes consideration of what materials can be incinerated. All disposal is
done in accordance with the Environmental Protection Agency (EPA), the
Department of National Resources in the U.S. Virgin Islands and the Department
of Transportation (DOT).
The laboratory on UVI campus is considered a small
quantity generator according to the EPA.
University of the
§
Waste paint and
solvent materials from artisan work, drama set production and teaching
activities
§
Unneeded, expired
or unusable chemical reagents, solvents and coatings
§
Solvent soaked
rags
§
Acid baths and
other solutions used in printmaking and intaglio activities
§
Spill response
debris and related items
§
Paints and
aerosol containers
§
Photographic
processing wastes (heavy metals and mild acids)
§
Fluorescent light
tubes, mercury switches and related materials
§
Engine oil
(non-hazardous)
§
Antifreeze
(non-hazardous)
§
Light ballasts
§
Lead-containing
paint chips (from paint removal)
§
Latex and
oil-based paints, and flammable solvents
§
Acid cleaners
§
Degreasing
solvent from parts washer (non-hazardous)
§
Pesticides and
pesticide containers
§
Computer monitors
and other electronic equipment that may contain mercury or lead
§
Ink cartridges,
drums and toners Ink-jet cartridges (desk-top printers)
§
Lead acid
batteries
§
Ni-Cd and similar batteries
§
Alkaline
batteries (non-hazardous)
§
Miscellaneous
mercury containing devices (i.e., thermometers)
Prepared by L. Durante
5/8/06.
Certain chemicals are permissible for drain disposal.
Available MSDS information is contacted to determine what is and is not
acceptable. The drain system connects to a sanitary sewer system that
ultimately flows to a wastewater treatment facility to a sanitary sewer at the
V. I. Water and Power Authority. At no time was a septic tank system used. Only
those chemicals reasonably soluble in water are suitable for drain disposal. A
compound is considered water soluble if it dissolves to the extent of at least
3%. These compounds are flushed with at least 100 volumes of excess water.
Some exceptions should be noted:
·
Those organics
with boiling points less than 50 C
·
Those fuel
hydrocarbons, halogenated hydrocarbons, halogenated inorganic compounds, mercaptans, and most oxygenated compounds that contain more
than five carbon atoms (e.g., freon)
·
Those organics
that are explosives such as azides and peroxides
·
Concentrated
acids or bases
·
Either highly
toxic, malodorous or lachrymatory substances
Incineration in an environmentally acceptable manner
is the most practical disposal method for combustible laboratory waste.
Indiscriminate disposal by pouring waste chemicals down the drain or adding
them to mixed refuse for landfill burial is unacceptable. Hoods are not to be
used as a means of disposal for volatile chemicals. Disposal by recycling or
chemical decontamination is used when possible.
Waste is removed from laboratories to a central waste
storage area at least once per week and from the central waste storage area at
regular intervals. For quantities of hazardous waste between 220 and 2,200
pounds, storage is allowed from the day of generation of the waste up to 180
days if the waste is shipped less than 200 miles. Once 2,200 pounds are
exceeded, storage is for 90 days only. University of the Virgins laboratories
will store their hazardous waste at a central storage area and transports it by
a contracted waste disposal company to an area designated by the company for
the handling of specific waste types.
III. HAZARDOUS WASTE DISPOSAL INFORMATION
1. Planning and Purchases
It is your responsibility as generators of hazardous
waste to make every attempt possible to minimize the amount produced. To the
extent that chemicals can be recovered, recycled, or reused safely there is
obvious economic incentive to do so. In addition, materials that are recovered,
recycled, or reused do not become a liability problem or a problem for the
environment.
The planning of every purchase must include the
consideration of the disposal of leftover starting materials and of the
products and by-products that may be generated as a result of usage of a
hazardous material. Questions to be considered include the following:
·
Can any material
be recovered, reused, or recycled?
·
Will the
experiment produce any acutely hazardous waste?
·
Can any unusual
disposal problem be anticipated?
·
Are materials
being acquired in only the quantities needed? Are any of the materials already
on site? (in another location)
·
Is there the
possibility of replacing a hazardous material or solvent with one which is less
hazardous or more easily disposed of?
Almost 75% of our present laboratory waste consists of
partially used or unopened bottles of chemicals that have been accumulating for
decades. Chemicals should be purchased in the smallest possible volumes to
reduce the amount of unused chemicals that could end up as laboratory wastes.
As the cost of chemical reagents and disposal continues to climb, any reduction
in volume of chemicals purchased will offer benefits. Keep in mind that the
perceived economy of buying in bulk is more than offset by disposal costs for
the package and its residues
2. Recovery and Recycling
The recycling process is exempt from hazardous waste
regulation except that waste accumulated prior to recycling must be managed
according to accumulation requirements. Distillation is an example of a viable
recovery option. All residues such as still bottoms from the recycling process
are regulated and must be managed as hazardous waste.
·
Photographic
fixer solutions cannot be discharged to the sink and will be collected for
silver recovery.
·
Spilled or waste
mercury is to be collected in an appropriate mercury collection container and
to be removed by a reclamation company who handle mercury disposal.
·
Other candidates
for recycling include batteries, precious metals, scrap metals, waste oil, and
formaldehyde. Every effort must be made to determine if other materials can be
reused, recovered, or recycled.
3. Hazardous Waste Identification
The first step in hazardous waste management comes
when the following questions must be answered:
· Is this
material is being used? The
Environmental Protection Agency (EPA) has defined a hazardous waste as any
material that no longer has a use.
·
Is this material
a waste? A waste is any solid, liquid, or contained gaseous material that is
discarded by being disposed of, burned or incinerated, or recycled. There are
some exceptions for recycled materials. The waste can be a by-product of a laboratory
operation or process or a commercial reagent or product that is no longer
wanted or needed.
·
Is this waste a
regulated hazardous waste? First see if your waste is on one of the EPA or OSHA
lists. If your waste was not listed, it still may be hazardous if it
meets one or more of the following characteristics:
- Ignitable
- Corrosive
- Reactive
- Toxic
The hazardous waste regulations apply to materials
only when they become a waste and only if they are deemed hazardous under
specific evaluation criteria.
4. Hazard Determination
Once you determine that a chemical material is a
waste, it must be evaluated to determine if it is a hazardous waste. Hazardous
wastes are defined by the
a. Listed Wastes
Wastes that are hazardous because they appear on one
of four lists are called "listed hazardous wastes". The four lists are
categorized as wastes from specific sources (K-list), wastes from non-specific
sources (F-list), certain discarded commercial products (U-list), and
"acutely hazardous" commercial chemical products (P-list). The F and
K lists apply to general processes, while the U and P lists are for reagent
chemicals. The P-list category, which contains wastes such as cyanides, is more
rigorously regulated. As a small quantity generator (SQG), UVI cannot generate
more than 1 kg/month or store more than 1 kg of waste from the P-list.
Generation of acutely hazardous waste must be closely monitored. Mixtures of
hazardous and non-hazardous waste are regulated as hazardous waste. So please
segregate hazardous and non-hazardous materials whenever possible. Specifically
listed chemicals are cataloged on 40CFR 261.
The EPA has classified approximately 500 chemicals as hazardous waste on
these lists:
·
EPA P List
·
EPA U List
·
EPA F List
·
EPA D List
b. Characteristic Wastes
·
If a waste is not
on one of the lists of hazardous wastes, you must determine if the waste
possesses one or more of four hazardous characteristics defined below:
ignitability, corrosivity, reactivity, or toxicity.
Such wastes are called "characteristic hazardous wastes". A generator
may use his knowledge based on the materials or processes used or may test the
waste to determine if it possesses one of the four characteristics. Personnel
who generate chemical waste should have enough general knowledge of the
hazardous characteristics of their waste to characteristics of their waste to
classify it.
i. Ignitability
a liquid, other than an
aqueous solution containing less than 24 percent alcohol by volume, with a
flash point below 140 degrees F (60 C).
a
non-liquid, which under standard conditions is capable of causing fire through
friction, absorption of moisture, or spontaneous chemical
changes and when ignited,
burns in a manner that creates a hazard
an
ignitable compressed gas, which includes gases that form flammable mixtures at
a concentration of 13 percent or less in air
an
oxidizer, such as permanganate, inorganic peroxide, or nitrate, that readily
stimulates combustion of organic materials.
ii. Reactivity
normally unstable and readily undergoes violent change
without detonation.
reacts violently with water.
forms potentially explosive mixtures with water
generates, when mixed with water, toxic gases, vapors, or fumes
in a quantity sufficient to present a danger.
is a cyanide or sulfide bearing waste that generated
toxic gases, vapors, or fumes at a pH between 2 and 12.5.
is capable of detonation or explosive reaction when
subject to a strong initiating source or heated in confinement
is readily capable of detonation, explosive
decomposition, or reaction at standard temperature and pressure.
is an explosive
iii. Corrosivity
is aqueous and has a pH less than or equal to 2 or
greater than or equal to 12.5.
is a liquid that corrodes steel at a rate greater than
6.35 mm per year at a test temperature of 130 degrees F (55 C).
iv.
Toxicity
tested using the Toxicity Characteristic Leaching Procedure (TCLP), which stimulates the leaching of materials in a landfill into the surrounding groundwater.
contains certain heavy metals or organic constituents above regulated limits (EPA D List) (see 40CFR 261).
Good sources for assistance in hazard determination are
MSDSs, hazardous materials handbooks, chemical
dictionaries, and labels. Some chemical products that are not regulated as
hazardous waste can be disposed of in the sanitary sewer or normal trash. The
decision to use one of these methods of disposal must be made after careful
consideration of the consequences.
5. Accumulation and Storage
An important step in the chemical disposal sequence
involves the temporary storage of waste at or near the point of generation.
Except when single chemicals are accumulated for recycling or recovery, waste
accumulation generally involves bulking several materials into one container.
Please adhere to the following guidelines for safe storage of chemical waste:
·
Waste must be
segregated according to compatibility. Please
do not store: Acids with Bases; Oxidizers with Flammables; Strong Corrosives
with Organics; and Water-Reactive Chemicals with Water.
·
Accurate records
of the amounts of hazardous chemical waste and type of hazardous waste
generated and accumulated by faculty, researchers, staff, or students must
written into the appropriate Hazardous Waste Log Book before placing such waste into the
appropriate Hazardous Waste Container.
·
A person
knowledgeable with the generation of the waste should complete entry in the
Hazardous Waste Log Book.
·
Label Hazardous
Waste Containers with words that clearly identify the contents as Hazardous Waste and affix completed
Hazardous Identification Waste Tag(s) into them.
a. Hazardous Waste
Identification Tag
°
A person knowledgeable
with the generation of the waste should complete the tags.
°
Write out
complete chemical name. Chemical formulas are not acceptable.
°
Include ppm or percentage for each component, which should add up
to 100%.
°
If identity and
quantity of waste is completely unknown, mark this on the tag.
°
State the
properties of the hazardous waste Flammable (i.e., ignitable), Corrosive,
Toxic, Poison, Water-Reactive.
°
State the
physical state (gas, liquid, solid) of the material.