The purpose of this training is to provide information on the proper disposal and management practices of all hazardous waste generated on ETSU campuses. Compliance begins with the responsibility of individual researchers and employees who generate any hazardous waste.
There are State and Federal government regulators involved in the compliance of hazardous waste. TOSHA (Tennessee Occupational Safety & Health Association), EPA (Environmental Protection Agency), DOT (Department of Transportation) and NFPA (National Fire Protection Association). TOSHA deals with the Laboratory Standard, Hazard Communication, and Personal Protective Equipment. The EPA deals with hazardous chemicals as it effects the Environment through the Resource Conservation and Recovery Act (RCRA). The NFPA is associated with flammable storage and compressed gases in laboratories. The DOT deals with how to safely transport hazardous waste.
What is a Hazardous Waste?
The initial step to effectively manage your hazardous waste is to determine whether it is a “waste” and if it is considered “hazardous”.
Hazardous waste is a waste with properties that make it dangerous or potentially harmful to human health or the environment. Hazardous waste can be liquids, solids, contained gases, or sludges. They can be the by-products of manufacturing processes or simply discarded commercial products, like cleaning fluids or pesticides.
Materials are generally considered a waste when the materials are no longer used and will be discarded.
In regulatory terms, a RCRA hazardous waste is a waste that appears on one of the four hazardous wastes lists (F-list, K-list, P-list, or U-list) or exhibits at least one of four characteristics-toxicity, reactivity, ignitability, or corrosivity. Hazardous waste is regulated under the Resource Conservation and Recovery Act (RCRA) Subtitle C.Ignitability
- Can create fires under certain conditions
- Spontaneously combustible
- Have a flash point less than 60°C (140°F)
- Wastes which are acids or bases (pH less than or equal to 2, or greater than or equal to 12.5) that are capable of corroding metal containers
- Wastes which are harmful or fatal when ingested or absorbed
- Toxicity is defined through a laboratory procedure called the Toxicity Characteristic Leaching Procedure (TCLP)
- Wastes which are unstable under “normal” conditions
- They can cause explosions, toxic fumes, gases, or vapors when heated, compressed, or mixed with water
- Examples include lithium-sulfur batteries and explosives
Hazardous Waste Determination
Departments, labs, clinics, and/or studios are responsible for determining what hazardous waste they generate. Assistance can be obtained from Environmental Health & Safety (EH&S). Also, referring to the Material Safety Data Sheet (MSDS) for the chemical of concern can help in determining whether it is considered hazardous waste.
You must make the initial determination that a material is a waste and then determine if it is a hazardous waste or non-hazardous waste. All hazardous waste must be managed properly until picked up by EH&S.
Storage & Labeling Requirements
The Tennessee Department of Environmental and Conservation (TDEC) allows for laboratories, clinics, studios, and shops to accumulate as much as 55 gallons on non-acute hazardous waste in containers at or near any point of generation. The storage area must be under the control of the operator in the departmental laboratories, studios, clinics or shops that are generating the waste. When on-site quantities approach near 55 gallons, please notify EH&S, 439-6028 so that a pick-up can be scheduled within 3 days. Request may be submitted on-line through EH&S website: Hazardous Waste Pickup Request Form
When storing hazardous waste, the containers must be capped or closed at all times (except during transfer), must be in good condition, compatible with contents, and segregated by compatibility.
All containers must be labeled with the words “Hazardous Waste”, the name of the chemical(s) (no abbreviations and no chemical formulas). The ETSU Hazardous Waste Tag, when used properly, enables compliance with these requirements. You may obtain these tags by contacting EH&S.
Make sure everyone knows where the spill response materials are for their work area and are familiar on how to use them. If there is a chemical spill within your respected area, the department personnel will be the first responder. Determine if the spill can be safely cleaned-up with existing personnel and resources. If you are ever uncertain to whether the spill can safely be cleaned up, contact EH&S (9-6028) and Public Safety (911) notifying them of the location and material spilled.
The following are some general spill response guidelines:
- Immediately alert area occupants and supervisor, and evacuate the area, if necessary
- If there is a fire or a medical emergency, notify Public Safety at 911
- Attend to anyone who may be contaminated. Contaminated clothing must be removed immediately and the skin flushed with water for no less than 15 minutes.
- If a flammable material is spilled, immediately warn everyone, control sources of ignition and ventilate the area
- Don personal protective equipment appropriate for the hazard(s)
- If respiratory protection is needed immediately evacuate and restrict the area. Notify EH&S (9-6028) and Public Safety (911).
- Loose spill control materials should be distributed over the entire spill area, working from the outside, circling to the inside. This reduces the chance of splash or spread of the spilled chemical
- POWERSORB (by 3M) products or their equivalent will handle hydrofluoric acid. Specialized hydrofluoric acid kits also are available. Many neutralizers for acids or bases have a color change indicator to show when neutralization is complete
- When spilled material have been absorbed, use a brush and scoop to place material in an appropriate container
- Five gallon pails are the preferred containers for collecting the clean-up material
Complete an ETSU hazardous waste tag, identifying the material as “Spill Debris involving XYZ Chemical”, and affix onto the container. Decontaminate the surface where the spill occurred using a mild detergent and water, when appropriate.
Universal wastes are not hazardous wastes if properly recycled. Types of universal wastes consist of the following:
- Batteries (nickel cadmium and lead acid)
- Certain Pesticides
- Mercury containing thermostats
- Fluorescent lamps/bulbs
All universal waste streams are to be segregated and stored in a designated satellite storage area. Each container must have a designated description label attached (“Used Fluorescent Bulbs” or “Waste Batteries”) and the accumulation start date written in the label or container. These labels are provided by the EH&S department. Containers used to store universal waste must be structurally sound, adequate to prevent breakage and compatible with the contents. It is best to use the original package that the device or material was shipped in. All universal waste containers must remain closed, leak free and have the accumulation start date on them. Universal waste may be stored onsite for up to one year.
For collection, please submit a chemical waste pick-up request form on-line or call the EH&S Department at 9-6028.
Anyone dealing with Hazardous Waste must be trained on an annual basis.
*Resource information by the Environmental Protection Agency, University System of Georgia, and the Center for Industrial Services @ University of Tennessee.