PLU Hazardous Waste Management Plan
The purpose of the Hazardous Waste Management program at Pacific Lutheran University (PLU) is to ensure the proper management of hazardous chemical wastes generated within the university. Regulations on handling and disposing of hazardous waste are comprehensive and complex on the federal, state, and local level. To comply with these regulations, all generators of hazardous wastes at PLU must follow the procedures in this program.
Environmental Health & Safety has the primary responsibility for conducting the hazardous waste management program. However, everyone at PLU who generates or handles hazardous waste is ultimately responsible for compliance with regulations and the success of the program.
A good resource for waste disposal guidance is the Department of Ecology website (http://www.ecy.wa.gov/programs/hwtr/). See the Step-by-Step Fact Sheets for Hazardous Waste Generators.
Pacific Lutheran University is committed to handling its hazardous wastes responsibly by adhering to these objectives.
- Reduce the quantity of hazardous waste generated to the lowest practical level.
- Manage hazardous wastes in a manner that protects the health and safety of students, staff, and faculty at PLU as well as the surrounding community.
- Manage hazardous wastes using the most responsible and environmentally sound methods practical. This includes reducing the potential for releases of hazardous waste into the environment and providing quick response to hazardous waste spills to minimize risk to people and the environment.
- Comply with all federal, state, and local regulations regarding hazardous waste management.
Hazardous Chemical Waste Determination
The proper management of chemical wastes begins by determining first which wastes are hazardous. “Hazardous Waste” or “Dangerous Waste” is a term defined by regulatory agencies. State and federal regulations define categories that determine whether chemical wastes are considered hazardous, and if they are regulated.
Washington State waste determinations are defined in WAC 173-303. These regulations also define the Quantity Exclusion Limits (QEL), which determine the amount of hazardous wastes that may be accumulated and the frequency of disposal required. It is the intent of this management program to follow these regulations as they apply to all hazardous wastes at Pacific Lutheran University.
Containers that have held hazardous materials are not classified as hazardous wastes when they are empty. A container is legally empty if the residue is less than one inch deep or less than one percent of the total capacity of the container. However, containers of acutely hazardous materials (QEL of 2.2 lb.) must be triple rinsed with an appropriate solvent. Any rinse solution must be disposed as a hazardous waste. The empty container may then be discarded or recycled after the label is removed or obliterated.
Priority Waste Management
Effective chemical waste management uses priorities to minimize environmental impact of hazardous waste while meeting federal and state requirements. Priority waste management at PLU attempts first to minimize the volume of hazardous waste generated and then to manage the minimized volume of waste in the most responsible and environmentally sound manner possible.
Priority 1: Waste Minimization
The highest priority is to minimize the volume of waste generated using the following methods:
- SubstitutionOften a non-hazardous chemical can be used in place of a hazardous chemical. Similarly, different procedures may be available that do not require use of hazardous chemicals. One should look for methods and materials that decrease the hazardous characteristics or quantity of the waste that we do generate, whenever possible.
- Scale ReductionMicroscale experimentation can be an effective procedure for hazardous waste reduction in research and teaching labs. Reducing the scale of experiments and procedures will reduce the quantity of hazardous waste produced.
- Inventory ControlA substantial portion of hazardous waste generated at PLU consists of unused, outdated chemicals and materials. Careful planning of quantities required can reduce disposal costs of excess chemicals and reduce costs due to over-purchasing. In many cases, costs to dispose of chemical wastes are greater than the purchase price of the original material.Departments are discouraged from purchasing new material that is already in inventory somewhere on campus and can be shared.Purchasing the smallest volume container that will last no longer than one year is strongly encouraged.
- ExchangesChemical purchases can also be reduced by borrowing and trading chemicals between laboratories, and by returning unused portions to the central stockroom for use by others. Other materials, such as paints, may be useful to other departments on campus or may be donated to community agencies or individuals. You may offer product that you would otherwise dispose through a formal exchange, such as the Industrial Materials Exchange (IMEX) at http://www.govlink.org/hazwaste/business/imex/.
Priority 2: Waste Recovery
Certain kinds of wastes can be recovered by commercial waste processing companies for repurification or use in commercial products. Waste recovery or recycling should be used whenever possible. Certain solvents, motor oil, photographic fixer, and metallic mercury will be collected and consolidated for commercial recovery and/or recycling.
Priority 3: Treatment-by-Generator
A variety of chemicals can be treated in the laboratory process to reduce or eliminate the hazardous properties. These processes must follow the Washington State Department of Ecology Treatment-by-Generator guidelines (Technical Information Memorandum No. 96-412). In-lab waste reduction methods will be used only if Priority 1 and 2 methods are not feasible.
- Acid-Base Neutralization
- Carbon Absorption
These wastes must be treated in suitable containers. Aqueous residuals must have a pH greater than 5.5 and less than 11 prior to discharge to the POTW sewer system. The precipitated solids must be managed and disposed appropriately. These methods are generally intended for small volumes of dilute wastes rather than for large quantities of unused materials. These may be especially effective when used in teaching labs as part of student and laboratory worker responsibilities.
Employees who choose to treat hazardous wastes must still mark the container with an accumulation start date. The container must be emptied every 180 days and any residue of the treatment process must be disposed within this same 180-day period.
Employees who treat hazardous wastes must maintain a written log (Appendix A) of treatment activities, including:
- Quantity in pounds
- Treatment method
- Date of treatment
The log must be submitted to the Environmental Health & Safety Office at the end of the calendar year for inclusion in our annual Hazardous Waste Report to the state.
Priority 4: Commercial Disposal
Hazardous materials that cannot be managed by any of the previous methods will be collected for packaging and transport by a commercial waste processing company for final disposal. The Environmental Health & Safety Office will arrange for packing and shipping.
Procedures for Hazardous Chemical Waste Disposal
All personnel handling hazardous chemicals on the PLU campus must be familiar with PLU’s Hazard Communication Program. This program explains the rights and responsibilities associated with working with hazardous materials. Please contact the Environmental Health & Safety office for training or information on Hazard Communication.
Personnel working in non-production laboratory facilities on campus must be aware of the OSHA Laboratory Standard (29CFR 1910.1450). They must be trained according to PLU’s Chemical Hygiene Plan to ensure awareness of the hazards of chemicals present in their workplace. Please contact the Environmental Health & Safety office for training or information on Hazard Communication.
The Department of Ecology Step-by-Step Guide to Better Laboratory Management Practices #97-431 (http://www.ecy.wa.gov/pubs/97431.pdf) is another very good resource. It includes information on managing laboratory wastes, minimizing wastes, and storing chemicals compatibly.
1. Accumulation Areas
Hazardous chemical wastes being held for commercial waste disposal or recycling will be stored in Accumulation areas as follows.
Reike Science Center Chemistry stockroom
- Hazardous Waste storage facility at Facilities Management (central storage)
- Wastes in the Reike Science Center will be taken to the Chemistry Laboratory Supervisor in the Chemistry Stockroom.
Other locations on campus should call the Office of Sustainability Manager in Facilities Management (x7380) and submit a work request for pick-up of hazardous wastes.
As soon as a chemical is declared a waste or removed from a satellite accumulation area, the accumulation date must be added to the label, in addition to the chemical name and hazard associated with the chemical. See Labels below.
2. Satellite Accumulation Areas
Wastes from routine processes may be accumulated at or near their point of generation before consolidation at a designated storage area. The satellite area must be under the control of the generator and secure at all times. As much as 55 gallons of dangerous (hazardous) waste or one quart of extremely hazardous waste per waste stream may be collected. When the containers are full or volumes reach these limits, containers must be immediately marked with an accumulation start date, and moved to the accumulation storage areas within three (3) days. Sites for satellite accumulation of used hazardous materials include, but are not limited to, the laboratories in Reike Science Center, studios in the Art Department, service areas in Facilities Management.
3. Storage Time
Because PLU is a regulated medium quantity generator of hazardous wastes, most hazardous materials cannot be held longer than 180 days in the storage areas. Acutely hazardous wastes in excess of the QEL of 2.2 lb. can be held only 90 days.
Each hazardous waste must be stored in containers appropriate for that material.
- Specific categories of organic solvent wastes can be combined into a common collection vessel. Chemically compatible solvents can be accumulated into the same container.
- Common, compatible solvents from the maintenance shops may be bulked into the same container or drum.
- Other hazardous wastes should be collected, each in a separate container, using the smallest container to match the amount of the chemical waste generated.
- All containers must be tightly capped or covered at all times and clearly labeled. If a funnel is used, the bung must be immediately replaced following use of the funnel.
- Secondary containment must be provided for hazardous waste containers in accumulation areas.
As indicated in PLU’s Hazard Communication Program, any vessel containing a hazardous material must be properly labeled at all times. This requirement is especially important in dealing with hazardous wastes, because if the material is unidentified, disposal may be very expensive, difficult, or even impossible. Hazardous waste labels must contain additional information as well.
Labels on all containers of hazardous chemicals must include at least:
- Term “Hazardous Waste” or “Dangerous Waste”
- Chemical name of the hazardous material. The chemical name must be in English and must not be abbreviated. Names such as “Sample 1, Run 2” or names referring to page numbers in laboratory books are not acceptable. Rather than using chemical formulas to identify wastes, the generator must name the compound in English, even if the name refers to the starting material in a reaction (e.g., “diethylmalonate derivative” or “aniline/diethylamine reaction mixture”).
- Chemical risk or hazard of the material (e.g., corrosive acid, ignitable, toxic) must be marked on the label.
- Accumulation start date. This is the date that the container or drum was placed in the Accumulation area.
Standard hazard labels are available from safety supply companies. The Chemistry Laboratory Supervisor, the Environmental Services Coordinator, and Environmental Health & Safety will maintain a stock of labels for use by all areas. See Appendix B for examples of labels that are available on request and Appendix C for labels that you can print out.
Environmental Health & Safety will arrange for the disposal of all hazardous wastes by a commercial waste disposal or recycling company. Disposal dates will be scheduled in consultation with the Chemistry Laboratory Supervisor and Office of Sustainability and other waste generators at PLU and in keeping with regulatory time requirements.
Inspection of Accumulation Areas
The Chemistry Laboratory Supervisor and the Environmental Services Coordinator will conduct a weekly inspection of the hazardous waste Accumulation area(s) in Reike Science Center and Facilities Management, respectively. Please use the Weekly Inspection Checklist in Appendix E or equivalent.
The EHS Manager, Chemistry Laboratory Supervisor, Biology Lab Manager, or Facilities Management Mechanic may sign manifests. The manifests and supporting documents will be filed in the EHS Office. EHS will report to Ecology when manifests are not returned within 45 days from shipment.
Emergency Response and Preparedness
PLU is required to prepare for emergencies associated with handling of hazardous wastes. The Chemistry Laboratory Supervisor (Reike) and the Environmental Services Coordinator (Facilities) will be responsible for ensuring that the following information is posted and equipment is present and working at the Accumulation areas. Post near accumulation area:
- Location of Emergency Coordinator and phone number. The Environmental Health & Safety Manager will be the Emergency Coordinator for the university.
- Location of Fire Extinguisher
- Location of Spill Control
- Location of Fire Alarm
- EHS cell phone number: (360) 402-1991
- Campus Safety @ x7911
Test and maintain safety equipment:
- Communication equipment
- Alarm System
- Maintain 30” aisle space
Special Waste Categories:
Photographic fixer solutions cannot be disposed into the sewer. All photo fixer from PLU photography labs must be collected in plastic carboys or drums. Call Environmental Health & Safety (x7233) for pick-up and disposal. All other photographic chemicals may be sewer disposed. The word “Toxic” must be marked or labeled on the drum.
Latex paints may be disposed into the regular trash, if they are dry and solidified and the lid to the can is removed. Materials such as sawdust, vermiculite, or Portland cement may be stirred into latex paint to encourage the drying and solidifying process. The material may also be bulked for disposal.
All oil-based paints are considered hazardous materials and must be disposed through the hazardous waste disposal process. However, oil-based paints may be poured into an accumulation drum for bulk disposal.
Batteries (not including lead acid), Mercury-containing Thermostats, and Spent Lamps:
These items designate as dangerous wastes, but can be managed as “Universal Wastes”, which reduces the regulatory burden for handling. Use data sheets from manufacturers to determine which lamps designate as dangerous waste. Some lamps are “green” and do not designate and do not require special handling. See Department of Ecology publication 00-04-020 and 98-407.
PLU is a small quantity handler of universal wastes because we accumulate less than 11,000 pounds of all universal waste types or less than 2200 pounds of spent lamps at any time.
The following must be followed when handling these wastes:
- Unless actively adding or removing contents containers must be closed at all times.
- Labels must state “Universal Waste” and the content, such as “Batteries” or “Lamps”.
- Container, regardless of storage or accumulation location, must be labeled with the date the first item went into the container.
- Accumulation, regardless of location, is limited to one year.
This applies to televisions and computer monitors that contain cathode ray tubes (CRT). CRTs designate as dangerous waste, but can be managed under a conditional exclusion according to publication 02-04-017. Other electronic wastes that designate as dangerous waste can also be managed under this program.
These wastes do not require manifesting or reporting to the Department of Ecology provided the hazardous components of the electronic waste are legitimately recycled. Recycling includes remanufacturing the components into new products, smelting, or salvaging usable parts.
The following must be followed when handling these wastes:
- Accumulation is allowed up to 180 days. PLU requires a start date on the accumulation container to verify that we are not holding these materials longer than 180 days.
- Use a recycling vendor that has notified Ecology of its activity in writing. Request a copy of the vendor’s letter to Ecology for verification.
Biohazardous materials will be handled according to PLU’s Bloodborne Pathogen and & Infectious Waste Management Program. Biohazardous materials, including syringes and sharps containers that are generated in Natural Sciences will be autoclaved by the Biology Department staff before disposal. Biohazardous materials generated elsewhere on campus will be collected for shipment at East Campus. A vendor will handle these materials. All biohazardous materials must be packaged in orange or red plastic bags and conspicuously marked with the biohazard PLU Hazardous Waste Management – April 2013 7 sign. Call the Office of Sustainability (x7380) for pick-up of all Biohazard containers for disposal.
Animal carcasses, either fresh or preserved, cannot be disposed into the regular trash. Call Environmental Health & Safety (x7233) for pick-up and disposal of all animal remains.
Radioactive wastes are not included in this program. For more information on the proper handling and disposal of radioactive materials, see the PLU Radioactive Materials Procedure Manual or speak with the Radiation Safety Officer in RSC.
PCB Light Ballasts and other PCB Items
PCBs are regulated under the Toxic Substances Control Act or TSCA. PCB items that contain less than 50 ppm and greater than 2 ppm are regulated by Washington State under the dangerous waste regulations. Equipment that is labeled “non-PCB” indicates that it contains less than 50 ppm PCB.
Ballasts manufactured before July 1, 1979 should be assumed to contain.PCBs, unless credible documentation is available to state otherwise. This might include manufacturer’s specifications or MSDS. Fluorescent light ballasts that contain less than 2 ppm of PCB were required to be labeled “No PCB” by the manufacturer if manufactured after July 1, 1979 and before July 1, 1998. After July 1, 1998, no marking was required.
PCB light ballasts must be marked with the out of service date or the disposal container may be marked with the out-of-service date of the first ballast that goes in the container.
PCB items must be shipped within one year of the out-of-service date.
For disposal of other wastes not listed, call Environmental Health & Safety (x7233).
Separation from the University
Employees who are leaving the university must completely clean out their laboratory, studio or shop of hazardous materials, and this activity must be signed off by the Chemical Hygiene Officer or the Environmental Health & Safety Officer on the Human Resources Out-processing form.
This Hazardous Waste Management Plan will be included in PLU’s Occupational Health, Safety and Accident Prevention Manual.
National Research Council. Prudent Practices in the Laboratory; National Academy Press: Washington, DC., 1995
Task Force on Laboratory Waste Management. Laboratory Waste Management: A Guidebook; American Chemical Society: Washington, DC, 1994.