Part 400: Hazardous Materials Disposal Procedures

• 400.01 General
  
• 400.05 Unacceptable Hazardous Materials Management Practices
• 400.10 Special Accumulation and Packaging Instructions
• Table 2: Special Accumulation and Packaging Requirements
• 400.20 Hazardous Materials Container Selection
• 400.30 Accumulation and Storage
• 400.40 Chemical Waste Disposal Request Completion Procedures
• 400.50 Hazardous Materials Collection by EHS
• 400.55 Hazardous Waste Inventory
• 400.60 Used Oil Disposal Procedures
• 400.70 Lead-acid Battery Recycling/Disposal
• 400.80 Universal Waste Handling Procedures
• 400.90 Hazardous Household/Consumer Commodities Disposal Procedures

400.01 General

1. Following these procedures will help ensure that containers of hazardous materials are properly labeled, containerized and stored according to state and federal hazardous waste regulations. Adhering to these procedures will also help expedite the safe collection and disposal of hazardous materials by EHS personnel.
2. There are several basic steps and regulations that all individuals must follow to properly and safely handle, store and dispose of hazardous materials generated in their work area:
   1. First investigate whether or not processes using hazardous materials can be eliminated; or determine if alternative methods exist for processes that do not use hazardous materials.
   2. Attempt to reduce the quantity, toxicity or other hazardous characteristic of materials being generated from processes that cannot be eliminated or substituted for by an environmentally safe process.
   3. Evaluate hazardous materials characteristics to ensure that incompatible materials are not combined or stored near one another.
   4. Do not dispose hazardous materials to the sanitary sewer system, atmosphere (i.e., evaporation), or solid trash receptacles (please see Part 400.05 - Unacceptable Hazardous Materials Management Practices).
   5. Insure that proper containers are available to accumulate each waste stream in advance of actually conducting research, analyzing samples or starting a chemical process.
   6. Properly label containers with words that accurately identify each container's contents.
   7. Keep track of accumulations to the container (all constituents and their concentrations). A log book with entries referenced to unique container numbers is helpful.
   8. Containers must always be kept closed between accumulations.
   9. Minimize the accumulation of hazardous materials in your area by submitting materials and full containers promptly to EHS for disposal. Never accumulate more than 55 gallons of hazardous materials or one (1) liter of acute hazardous waste in a given area.
   10. Submit all chemicals and hazardous materials to EHS for final characterization, collection and proper disposal.

400.05 Unacceptable Hazardous Materials Management Practices

1. There are several management practices that are NOT acceptable under EPA and state DEQ regulations. These management practices are illegal and could make the University susceptible to violations, fines and other liabilities.
   1. Disposal - The disposal of hazardous wastes to the sanitary sewer system, a solid waste receptacle, or directly to the environment (including evaporation) is illegal. EPA regulations require that generators determine (either by knowledge or through chemical analysis) whether or not a material is a hazardous waste before it is discarded.
   2. Transport - Do not deliver discarded hazardous materials to the EHS office, either in person or via campus mail. Delivery of discarded hazardous materials to the Hazardous Materials Storage Building (HMSB) is also not authorized. These materials will be returned to the individual, and will not be accepted for collection until proper protocols have been followed.
   3. Treatment - Treating hazardous waste to reduce its toxicity or make it less reactive without an EPA permit and/or a “waste analysis plan” is a violation of EPA regulations. Treatment includes but is not limited to heavy metal precipitation and oxidation/reduction.
      NOTE - simple neutralization of corrosive materials is allowed, as long as no other constituents (e.g., toxicity characteristic (TC) materials or spent solvents) are present in the waste stream that would make it a hazardous waste even if neutralized. Report quantities of corrosive materials neutralized to EHS.
   4. Waste Stream Dilution/Evaporation - The dilution or evaporation of hazardous waste to "lessen" its toxicity is not permitted by the EPA. Hazardous wastes containing characteristic waste constituents above TCLP regulatory levels cannot be diluted or evaporated down to below regulatory levels and disposed of to the sanitary sewer system. (e.g., a 2 mg/L mercury solution cannot be diluted to below 0.2 mg/L and discarded to the sewer system for disposal. Also, a material containing benzene CANNOT be allowed to evaporate in order to achieve benzene concentrations below regulatory levels).
   5. Storage - Storing more than 55 gallons of hazardous waste and/or one kilogram of acute hazardous waste (P-listed waste) in a given storage area is not allowed. Removing waste from one room or building to another room or building without approval from EHS personnel is also not allowed. Hazardous materials must be stored in a physically sound and chemically compatible container with its closure on at all times (see (1) above) between accumulations and during storage.

400.10 Special Accumulation and Packaging Instructions

1. Due to reactivity, toxicity, and disposal restrictions, certain materials can only be accumulated in certain size containers or must be packaged to reduce a potentially violent reaction or prevent exposure to water, air and/or personnel. Table 2 lists hazardous materials requiring certain stipulations that must be followed to facilitate their collection and disposal.

Table 2: Special Accumulation and Packaging Requirements

400.20 Hazardous Materials Container Selection

1. Properly preparing hazardous materials will help facilitate their safe and expedient collection and disposal by EHS personnel and meet applicable state and federal regulations.
1. Proper Containers - A proper container is one that has retained its integrity and can be sealed tightly. Containers should be resistant to chemical degradation and corrosion. Liquids must be stored in containers designed for liquids, not solids.
2. Unacceptable Containers - The following containers are not acceptable for materials storage and disposal: beakers; test tubes; Erlenmeyer, filter, volumetric, round bottom and other flasks; Petri and weighing dishes; and food, drink and beverage containers (e.g., coffee cans and jars; milk and juice containers). Only containers manufactured for the purpose of holding hazardous materials can be used for the containment of hazardous materials. Unused hazardous materials still in their original containers are acceptable, but only if the container has retained its integrity. Also note the following:
   1. Openings - Containers must not have a spigot (e.g., carboy), valve, or other opening in addition to the main opening on top.
   2. Plastic Bags - Plastic bags are not acceptable as primary containers for the containment or storage of hazardous materials or wastes. They can only serve as secondary containment. Plastic bags can never be used to contain sharps (see (v) below).
   3. Liquids - Use containers designed to hold liquids (i.e., wide mouth containers that were manufactured for solids should not be used for the containment of liquid waste).
   4. Solids - Containers holding solids must be capable of forming a tight seal. Containers not forming a tight seal must be transferred into a new container capable of forming a tight seal, or over-packed in another proper container.
   5. Sharps - Sharps (e.g., needles, broken glass, wire, razor blades, etc.) must be contained in strong, tight, puncture-proof containers. Plastic bags are not acceptable;
   6. Gas Cylinders - Gas cylinders must have their valve protection caps included for disposal purposes. Leaking cylinders will not be collected by EHS personnel, but must be evaluated for safe disposal options. Contact EHS if you discover a leaking cylinder.
3. Container Size - Plastic and metal containers up to five gallons in size, and glass containers up to one gallon in size are acceptable for routine liquid and solid hazardous materials collection and disposal. Larger sized (e.g., drums and barrels, etc.) containers require prior approval from EHS personnel before being used to contain hazardous materials.
4. Container Condition - Containers must not be warped, cracked, or leaking. They must not have degraded/corroded from the material(s) they contain or otherwise pose a threat to lose their contents. Note the following:
   1. Closures - Containers containing liquids must have screw cap closures that form a tight seal. Stoppers, septums, wax paper, etc., are not acceptable as closures and such containers will not be collected until the contents have been transferred to a proper container.
   2. Surface Contamination - All containers must be relatively void of chemical residue on the surface. Contaminated or excessively dirty waste containers will not be collected for disposal until cleaned.
5. Container Type - The list below provides guidelines to follow when choosing a container for hazardous materials storage:
   1. Mineral Bases - Sodium hydroxide, etc., are usually best stored in glass or plastic containers without glass stoppers.
   2. Mineral Acids - Hydrochloric acid, sulfuric acid, etc., are best stored in glass or heavy plastic containers, depending on the material’s compatibility with glass and plastic. Exception: hydrofluoric (HF) acid, which attacks glass, must be collected and stored in plastic containers.
   3. Chlorinated Organic Solvents - Methylene chloride, chloroform, etc., are best stored in glass containers.
   4. Polar Organic Solvents - Acetone, ethanol, etc., are ideally stored in glass or metal containers. However, plastic may be acceptable for short term storage.
   5. Non-polar, Non-chlorinated Organic Solvents - Hexanes, ethyl ether, benzene, etc., are best stored in glass or metal containers. Avoid plastic containers.
   6. Organic Peroxides - Benzoyl peroxide, etc., are usually stored in plastic containers. Check with the manufacturer's recommendations for the specific material you are using.
   7. Oxidizers - Potassium permanganate, sodium nitrate, bleach, etc., are best stored in glass containers.
      Note: Avoid containers with metal caps for the containment of corrosive materials.
      Many waste streams and hazardous materials will have mixtures of the above wastes; when in doubt use glass containers.
6. Empty Reagent Containers - Empty reagent containers should be rinsed thoroughly before being reused or discarded. Follow the procedures below to prepare "empty" reagent containers for reuse or disposal:
   NOTE: Reagent containers that held an acute hazardous waste (see Section 200.20, F027 waste and “P”-listed waste) MUST be triple-rinsed with a solvent capable of removing the chemical product; combine the rinsates for disposal through EHS.
   NOTE: Never use ethers to rinse empty containers. Make sure that all chemicals are compatible with the solvents used for rinsing "empty" chemical containers. Submit rinsates to EHS for disposal.
   1. Preparing "empty" reagent bottles:
      1. For organic reagents:
         1. Rinse "empty" containers first with acetone or other appropriate solvent (these rinsates will most likely be hazardous waste and must be submitted to EHS for disposal);
         2. Rinse with water if acetone was used in step one (1), or rinse with acetone, then water if a different organic solvent was used [combine with rinsates from step one (1)];
         3. Allow the container to thoroughly drain into the waste collection container for the rinsates. The reagent container is thoroughly drained when rinsate ceases dripping from the inverted container; then,
         4. Air dry the reagent container.
      2. For inorganic reagents:
         1. Rinse container thoroughly with water (or appropriate solvent) followed by acetone and then again with water (submit rinsates for disposal);
         2. Allow the container to thoroughly drain into the waste collection container for the rinsates. The reagent container is thoroughly drained when rinsate ceases dripping from the inverted container; then,
         3. Air dry the container.
      3. If chemical residue is still evident, repeat steps above.
      4. Deface the label and other markings on the original container.
      5. Reuse for waste containment, discard as normal trash, or donate to EHS personnel.
7. Empty Lecture Bottles and Gas Cylinders - The disposal of empty lecture bottles and small non-returnable gas cylinders should be carried out as follows:
   1. Make sure the cylinder is empty (atmospheric pressure);
   2. Remove the valve;
   3. Rinse cylinders out with an appropriate solvent, collecting the rinsate as a hazardous waste;
   4. Air dry;
   5. Deface the label(s) and other markings;
   6. Recycle the metal.

1. Container Markings — On waste collection containers, completely deface any existing label. Properly label and identify the contents of each container before accumulation begins. DO NOT date the container.
   1. Adequate Chemical Descriptions - Example, use "potassium permanganate" instead of just "permanganate"; or "lead nitrate" instead of just "Pb⁺²"; do not use acronyms, chemical formulas, etc.
   2. Constituent Concentrations - Note the concentrations for each constituent in percent (%) or parts per million (ppm) and total quantity of each addition to the container to calculate final concentrations of each constituent in the material.
2. Accumulation - All containers must remain closed between accumulations (i.e., an open container with a funnel resting in its mouth is not considered closed by EPA regulations).
3. Storage - Choose a safe location to store the container for accumulation purposes.
   1. Location - Waste must be stored within the same area, laboratory or room that it was generated.
   2. Quantity Limitations - No more than 55 gallons of hazardous waste or one (1) liter of acute hazardous waste can be accumulated in any one area.
   3. Secondary containment - Use secondary containment, such as a small plastic tub, to hold the waste containers. Segregate by compatibility groups (see Section 620.10).
4. Full Containers - When the container is full (leave room for expansion), calculate the concentrations for all constituents.
5. Disposal Request - Complete an online waste disposal request for the container, and submit it as soon as possible.

400.40 Chemical Waste Disposal Request Completion Procedures

1. Departmental offices must have computer access to the online waste disposal request system. Instructions are available on the Environmental Health and Safety website where disposal requests are completed. Below are guidelines that will aid in completing the request and expediting the collection process:
1. Carefully enter each request to avoid errors;
2. Fill out one request for each container unless instructed otherwise by EHS personnel;
3. Small vials and bottles should be placed in a re-closeable plastic bag and the form label attached to the bag;
4. If disposing a stock bottle of chemical, do not obscure a container's original label.
   NOTE: Fill out one (1) collection request for each container unless instructed otherwise by EHS personnel.
2. Any of the common web browsers may be used for entering a chemical waste collection request. Go to the input page.

    

   1. Log in with your U of I/VandalWeb username and password.
   2. Complete the Chemical Waste Collection Request form.
   3. Review the information you have entered. If necessary, you may edit the entries. If it is correct, click the Submit Request button and a confirmation message will appear. Click OK or Cancel as appropriate.
      NOTE: The system performs some error checking and displays an asterisk next to the field that requires correction; a message appears just above the Generator Information block to explain what action you must take.
   4. A new page will appear with the instruction “Please print the label below and attach to the container.” Select the highlighted Print button and a new window will open for printing the label.
      IMPORTANT!! This label is specific to the container for which you entered the information. You must submit a new request and print a new label for each container.
   5. Close the print window.
   6. You will now have three (3) options:
      1. Log Out to exit the Chemical Waste Collection Request system;
      2. Submit another request for a different waste material;
      3. Submit another request for an identical container, which allows you to submit another waste container with a waste composition similar or identical to the one previously submitted. Edit the new entry as necessary.
   7. Check your email inbox for a receipt of your waste collection request. Though not the preferred method, you may print a copy of the email receipt to use as a label if you forget to print the label immediately after submitting the request.
      REMEMBER: The Chemical Waste Collection Request system will accept only one container per request. Additional containers require additional requests.

400.50 Hazardous Materials Collection by EHS

1. Hazardous materials will not be collected prior to EHS personnel receiving completed chemical waste collection requests. EHS makes every effort to collect the waste in a timely manner, dependent on the hazardous characteristics of the material and the likelihood of consolidating similar materials for cost-effective, off-campus shipment.

400.55 Hazardous Waste Inventory

1. Individuals using hazardous materials and generating chemical wastes will be required to complete an inventory of waste streams not yet submitted to EHS as collection requests. Inventories will be used to meet the Idaho DEQ requirement of periodically reporting all hazardous waste that is generated. Normally, the reporting cycle is each January. The inventory includes waste being accumulated but not yet submitted to EHS for disposal purposes. Unused discarded chemical products (i.e., chemicals still in their original containers) do not need to be reported to EHS.

400.60 Used Oil Disposal Procedures

1. Individual generators will not dispose of used motor oil by draining or pouring oil into the sanitary sewer or storm drain systems, a sump, or onto the ground/road. Used oil can only be offered to EHS for off-site shipment. Only used engine oil (including synthetic oil), hydraulic oil, transmission oil, and other oils approved by EHS are to be accumulated in drums provided by EHS and labeled "USED OIL." These oils may be combined into the same drum. Antifreeze, refrigerant oil, vacuum pump oil, brake fluid, paint and paint thinners, parts cleaners, and other solvents ARE NOT TO BE ADDED OR MIXED WITH USED OIL (OR EACH OTHER). Accumulate these materials separately and submit to EHS for disposal as hazardous materials. Used oil is not to be collected in an underground or aboveground storage tank without prior EHS permission.
1. Accumulation of Used Oil - Collect used oil in drums stored in a location protected from the weather. Drums must be labeled "USED OIL" and are supplied by EHS. Do not mix any other materials with the used oil.
   1. Collection Containers - Initially, individual generators will be provided with a 30-gallon drum for collecting and storing used motor oil. Smaller containers may be provided as appropriate.
   2. Containers must be in good condition and not leaking.
   3. Collection and Disposal of Full Drums/Other Containers - Submit a collection request using the online Chemical Waste Collection Request system. On the submittal under Chemical Name/Constituents, describe the material as “Used oil.” NOTE: Drums must not be overfilled and surfaces must be clean of oil.
2. Oil Filter Disposal
   1. Filter Removal - Remove filters from engines at operating temperature. "Hot-drain" the oil from the filter by puncturing either the filter anti-drain back valve or the filter dome and drain for 12 hours. A filter is drained when it no longer drips any oil.
   2. Filter Disposal - Discard drained filters (as previously described) as normal trash.
      NOTE: For the management and disposal of other automotive fluids, oils, or parts cleaner fluids not mentioned in this section, please contact EHS.

400.70 Lead-acid Battery Recycling/Disposal

1. Non-leaking automotive, marine, tractor, and other lead-acid batteries, including sealed lead-acid batteries, will be managed by the Facilities Surplus/Recycling/Solid Waste Division. Call 208-885-2091 for additional information.
2. Leaking lead-acid batteries must be plastic in a plastic container such as a tub or 5-gallon pail. Submit a Chemical Waste Collection Request for disposal through EHS.

400.80 Universal Waste Handling Procedures

1. Lamps. Separate TCLP Compliant lamps from Non-TCLP Compliant lamps.
1. TCLP Compliant:
   1. Place the lamps in a box or other container that can be closed. The original packaging box is a good choice. Keep the box closed except when adding lamps.
   2. Mark on the box “TCLP Compliant Lamps”.
   3. When full, deliver the box to Facilities Surplus/Recycling/Solid Waste.
      NOTE: Occupants of University Housing or Idaho Student Union and Bruce M. Pitman Center should contact their building representative to determine where used TCLP Compliant lamps should be taken.
   4. Broken TCLP Compliant lamps. Scoop or sweep up the glass fragments and powder and dispose as you would broken glass.
2. Universal Waste Lamps (or Non-TCLP Compliant lamps):
   1. Place used lamps in a box or other container that can be closed. The original packaging box is a good choice. Keep the box closed except when adding lamps.
   2. Mark on the box “Universal Waste — Lamps”
   3. Mark on the box the date you placed the first used lamp in it.
   4. When full, or within six (6) months of the date marked on the box or container, whichever comes first, deliver the box to Facilities Surplus/Recycling/Solid Waste.
   5. Broken Universal Waste Lamps:
      1. This procedure is applicable to situations where only one lamp is broken. In all other situations, leave and secure the area, and contact Environmental Health and Safety, 208-885-6524.
      2. Wearing gloves, carefully pick up or scoop up the glass fragments and powder with a stiff piece of paper or cardboard.
      3. Use sticky tape (e.g. duct tape) to pick up fragments or powder.
      4. If a hard surface, wipe the area clean with a wet paper towel.
      5. Place all items in a plastic bag, seal the bag, then put the bag in a strong, tight container such as a 5-gallon plastic pail. Mark on the pail “Broken Universal Waste — Lamps.”
      6. Submit a Chemical Waste Collection Request to EHS.
2. Batteries.
   1. Segregate batteries by type:
      1. Alkaline — dispose in normal trash;
      2. Lead-Acid — manage in accordance with 400.70 above;
      3. Lithium and Lithium ion; manage as universal waste.
      4. All others including Ni-Cad, NiMH, mercuric oxide, silver oxide, button cell batteries, and other rechargeable type batteries; manage as universal waste.
   2. Tape the electrodes on universal waste batteries or place each battery in a re-sealable plastic bag.
   3. Place the taped or bagged universal waste batteries in a box or other container.
   4. Mark on the box or container “Universal Waste — Batteries”.
   5. Mark on the box or container the date you placed the first battery in it.
   6. When full, or within six (6) months of the date marked on the box or container, whichever comes first, deliver the box or container to Facilities Surplus/Recycling/Solid Waste.
   7. If a universal waste battery shows any evidence of leakage, spillage, or damage, follow the steps above except that you must place the battery in a re-sealable bag, placed in a compatible container such as a 5-gallon plastic pail, and submitted to EHS for disposal. Follow the instructions in 400.40 for completing a Chemical Waste Collection Request.
3. Mercury-Containing Equipment (MCE).
   1. Do not remove mercury ampules from thermostats or other electrical switches.
   2. Place the MCE in a re-sealable plastic bag.
   3. Mark the bag “Universal Waste — Mercury Containing Equipment.”
   4. Mark the date on the bag when you decided to discard the MCE.
   5. Submit all MCE to EHS for recycling/disposal. Follow the instructions in 400.40 for completing a Chemical Waste Collection Request.
   6. If an MCE is broken, leave and secure the area and contact EHS at 208-885-6524.
4. Pesticides.
   1. Once or twice each year, the Idaho Department of Agriculture sponsors a pesticide collection day as part of its Pesticide Disposal Program. Collection sites are located at several sites in the state of Idaho. EHS will send notice to the campus community, including facilities located outside of Moscow, in advance of these collection days.
   2. Stocks of unused pesticides, including dilutions and rinsates, are acceptable.
   3. If you have stocks of recalled pesticides, contact EHS at 208-885-6524 as soon as you are aware that the pesticide has been suspended or canceled.
   4. If the pesticide container is structurally sound, securely close it. Opened bags or boxes of pesticides should be taped closed.
   5. If the pesticide container is not structurally sound (e.g. tears in bags or boxes, degraded plastic bottles), place the pesticide container in a heavy plastic bag and securely close it.
   6. Mark on the container “Universal Waste — Pesticide.”
   7. Mark on the container the date when you decided to discard the pesticide.
   8. Submit all pesticides to EHS for recycling/disposal. Follow the instructions in 400.40 for completing a Chemical Waste Collection Request.

400.90 Hazardous Household/Consumer Commodities Disposal Procedures

1. Preparation for Disposal - Many cleaners, solvents, lubricants, paints, degreasers, etc., sold under a trade name are hazardous materials and must be disposed of properly. Household type hazardous materials submitted for disposal must be accompanied by a current Material Safety Data Sheet (MSDS) for that product.
2. How to Obtain an MSDS - MSDSs can be obtained through the vendor or manufacturer of a given product or contact EHS for assistance. Most MSDSs are now available online.
3. EHS will accept materials that were purchased for University of Idaho business. Products that were purchased for personal use (e.g. at your private residence) can be disposed at the Latah County Solid Waste Processing Facility.