Hazardous Materials Management Program

The EHS Hazardous Materials Management Program strives to provide quick, professional hazardous waste services to the university community. Services provided include collecting generated hazardous chemicals/waste from satellite accumulation areas, hazardous and universal waste management consultations, used oil collection and recycling, PCB ballast disposal and more.

EHS provides the following services free of charge:

• Routine chemical waste collection
• Guidance on managing hazardous chemicals and waste
• Spill response to incidents involving hazardous waste and materials
• Training through hazardous waste management workshops

The following are situations where EHS may charge back for services provided:

• The processing and disposal of unknown waste
• The disposal of waste that proves to be extremely costly
• Any monetary fine resulting from a Department of Environmental Quality (DEQ) notice of violation
• Analyses that may be required to properly characterize/classify waste

Please allow up to ten business days for EHS to respond to hazardous waste collection requests. Contact EHS for free consultation involving the management of hazardous and other wastes at 208-885-6524 or safety@uidaho.edu.

Resources:

• Chemical Waste Collection Request Guide

The secure management of hazardous materials is essential. While maintaining openness and transparency inherent to academic institutions, the university recognizes the need to implement prudent safeguards to reduce the risk of theft, misuse, diversion, or unauthorized access to hazardous chemicals, biological agents, radioactive materials, and other regulated substances.

EHS emphasizes practical, common-sense measures and follows simple guidelines to reduce the potential for problems, including:

• Do not leave laboratories, or other areas where hazardous materials are present, open and unattended. If you leave the area, make sure the door is locked.
• When not in use, return hazardous materials to their proper storage area. Storage areas in unattended spaces should be locked.
• Maintain an inventory of hazardous materials and routinely check and update inventories annually. Identify highly hazardous materials and ensure they are stored in a secure area under lock and key.
• Limit access to authorized personnel only. Greet and offer to help unfamiliar people who enter your workspace. If they appear suspicious, report it to your supervisor.
• If you notice any hazardous materials missing or believe they have been stolen, please contact Environmental Health and Safety at 208-885-6524 and U of I Security at 208-885-2254.

These practices are not intended to alarm but to reinforce standard expectations for responsible stewardship of hazardous materials in a laboratory setting.

Related Training:

• Environmental Waste Awareness Training for Custodians
• Environmental Waste Awareness Training for Shops and Maintenance
• Hazardous Waste Management Workshop for Laboratory Operations
• Hazardous Waste Management Workshop for Very Small Quantity Generators (VSQG)

Hazardous materials and dangerous goods are materials or articles that pose an unreasonable risk to health, safety, and property during transport, and therefore require special handling to ship them in commerce. Dangerous goods come in many forms, including but not limited to, the following:

• Hazardous chemicals
• Radioactive materials
• Infectious substances
• Compressed gases
• Biological samples on dry ice
• Lithium batteries
• Aerosol cans

Specific training is required by the Department of Transportation (DOT) and the International Air Transport Association (IATA) for shipping and, in some cases, receiving these products. Personnel in EHS and Office of Research Assurances (ORA) have completed this training and are able to ship the products correctly. Please contact ORA to ship biological samples, infectious substances, or dry ice. Contact EHS for all other dangerous goods.

• Shipping services — EHS and ORA can pack, label, complete the paperwork, and schedule pick up of dangerous goods by an appropriate shipper.
• Requirements — To ship non-biological dangerous goods, contact EHS at least 10 business days in advance. More time is preferred and remember to allow time for travel of the shipment. EHS will provide a worksheet to gather the necessary information for shipping the specific material(s). Complete one form for each dangerous good and email it back to EHS. An index number is required to cover the cost of shipping and supplies.
• Training — Training can be provided to designated personnel involved with shipping or receiving specific dangerous goods. ORA provides online training when shipping biological materials on/off dry ice and EHS can provide basic awareness training for individuals receiving packages of dangerous goods.

If you are unsure of the hazards of your material, or need to ship a dangerous good, contact EHS at 208-885-6524 or safety@uidaho.edu for assistance.

Lithium-ion batteries provide power for a variety of devices that many people use daily, including smart phones, laptops, power tools, drones, delivery robots, e-scooters, e-bikes, e-cigarettes, smoke alarms, toys, golf carts, and vehicles, etc.

If used improperly, charged outside the manufacturer's specifications, or physically damaged, lithium batteries can overheat, catch fire, or explode. All university users of rechargeable lithium batteries (e.g., lithium-ion (Li-ion) and lithium polymer (LiPo) cells) and battery packs must be alert when using, charging, and storing them. University employees must dispose of batteries through EHS, whereas students should take their batteries to Moscow Recycling.

While fires and explosions involving lithium batteries are relatively uncommon, the consequences can be severe. When a lithium battery fails and catches fire, it can release toxic gases, intense heat, and flames, making the fire difficult to control and extinguish. Understanding the hazards associated with lithium batteries is essential to preventing incidents before they occur.

Resources:

• National Fire Protection Association Li-ion Batteries
• Battery University: Learn About Batteries
• U.S. Environmental Protection Agency Battery FAQs
• U.S. Department of Energy — How Li-ion Batteries Work

Polychlorinated biphenyls (PCBs) are a group of colorless oils used extensively during the 50s, 60s and 70s in applications requiring highly stable oils possessing low conductivity and flammability properties. PCBs were used extensively in capacitors, transformers, and heat transfer systems. PCBs were also used in vacuum pumps and as hydraulic fluids, plasticizers, fire retardants, wax extenders, dusting removal agents, pesticide extenders, printing inks, lubricants, cutting oils, and in carbonless reproducing paper. 

Because of their toxicity to humans and persistence in the environment, the domestic production of PCBs was banned in 1977. PCBs are listed as carcinogens by the Environmental Protection Agency (EPA). PCBs and PCB containing articles are regulated by the EPA under the Toxic Substance Control Act (TSCA) and are not regulated as a hazardous waste unless they characterize as such. TSCA regulates the disposal of PCBs and PCB containing articles and the cleanup of PCBs when released into the environment.

Older fluorescent light ballasts are the most common source of PCBs on University of Idaho’s campus. Ballasts manufactured before July 1, 1979, may contain PCBs. Ballasts manufactured between July 1, 1978, and July 1, 1998, that do not contain PCBs must be labeled "No PCBs." PCB oils are also used in large commercial electrical transformers and must be tested before being recycled or disposed.

Be alert to sources and handling of potential PCB material, PCB Sources and Handling. Submit any PCB items to EHS using the Chemical Waste Collection Request form.

Contact EHS if you have any questions or concerns about potential PCB items.

Resources:

• Learn about Polychlorinated Biphenyls | US EPA
• PCB Sources and Handling Guidance

Environmental Health and Safety strives to recycle used oil in a safe and environmentally responsible manner. Used motor oil must never be disposed of by pouring or draining it into sanitary sewers, storm drain systems, sumps, or onto the ground. Used oil may not be stored in underground or aboveground storage tanks without prior approval from EHS and must be managed and disposed of through EHS-approved procedures.

EHS collects and recycles used oil that is not contaminated with hazardous waste. EHS will provide a 30-gallon drum or smaller container to collect the used oil. Once the container is full, submit a Chemical Waste Collection Request and EHS will collect the container.

Collect used oil only in containers that are marked "USED OIL." Do not add spent solvents (e.g., parts washer solvent), antifreeze, paint thinners, or other toxic materials to the container. Used oil containers must be stored in secondary containment in an area protected from the weather. Keep the container closed except when adding more used oil. Do not accumulate used oil in 55-gallon or larger containers.

Used oil containing elevated concentrations of halogenated compounds, such as those found in chlorinated brake cleaners, solvents, or other toxic constituents, require management as hazardous waste.

Used oil filters must be hot drained for 24 hours before being recycled. Drilling a hole in the dome will facilitate draining all oil not absorbed by the filter. Place properly drained filters in a container that is labeled “Used Oil Filters” provided by EHS. Notify EHS when container is full for collection or if you need a collection container.

Shop rags and absorbents contaminated with used oil should be thoroughly wrung out and drained before disposal. Collect the drained oil in an approved used oil container. Place oily rags in a fire-safe container for disposal. Additionally, oil spill debris and absorbent materials should be placed in a heavy-duty container, such as a 5-gallon plastic bucket. Disposal of these contaminated items should be submitted using the online chemical waste collection request system.

Have spill cleanup supplies readily available. Spill pads, kitty litter, and other commercial oil-spill cleanup products work well. Clean up spills immediately. Call EHS for assistance at 208-885-6524.

Resources:

• Used Oil Management Guidance

Aerosol products are manufactured for many purposes, including personal hygiene, painting, coating, degreasing, lubricating and cleaning; and may contain toxic, corrosive and flammable substances. Aerosol cans are also capable of exploding when subjected to extremely high temperature conditions.

As aerosols are managed as universal waste, do not place them in a solid waste receptacle for disposal or intentionally puncture aerosol cans to empty their contents. Instead, submit them to EHS for proper disposal. If you generate aerosol cans on a regular basis, contact EHS for a collection container that can be added to the routine collection route.

Notify EHS at safety@uidaho.edu or call 208-885-6524 if the routine collection container becomes full. If submitting an individual aerosol container, mark it "Universal waste — Aerosol" and write the date you submitted it to EHS.

Many batteries, such as lithium, nickel-cadmium (NiCd), nickel-metal hydride (NiMH), mercury, and silver oxide batteries, are hazardous and must be managed as Universal Waste. Lead-acid batteries do not fall under universal waste regulations but are instead managed separately through EHS. Do not dispose of them as regular trash. However, newer alkaline, zinc chloride, and zinc-carbon batteries contain very little, if any, mercury and are not considered hazardous waste; they can be disposed of as municipal waste (i.e., normal trash).

All universal waste batteries should be submitted to EHS for proper disposal by filling out a Chemical Waste Collection Request Form. Fill out the form and mark it as "Universal waste — Battery" and indicate which type of battery it is. Write down the date you submit it to EHS; this is the out-of-service date.

To prevent arcing, which can start a fire, tape the terminals on spent batteries with electrician’s tape, or place each battery in a separate plastic sealable bag. Keep batteries away from chemicals and store them in a dry, cool area.

Leaking or breached batteries

Batteries rarely leak, but if you find a leaking battery, wear nitrile or rubber gloves when handling it. Place it in a leak-proof plastic container; do not use cardboard. Wash your hands after handling a leaking battery. Submit the leaking battery to EHS. For leaking lead-acid batteries, call EHS for assistance if visible signs of liquid or white residue are present. If the battery is dry and does not have dry residue on it, you can wear gloves and place it in a leak-proof container, leaving the gloves in the container with the battery.

For bulging lithium batteries, contact EHS immediately at 208-885-6524.

Resources:

• Universal Waste Batteries Guidance

Lamps that contain mercury must be managed as universal waste, including fluorescent, compact fluorescent (CFL), ultraviolet (UV), high-intensity discharge (HID), and mercury vapor, as well as neon, xenon, high-pressure sodium, and metal halide lamps, which do contain smaller amounts of mercury. If you are unsure whether a lamp contains mercury, submit it to EHS for evaluation.

Lamps without mercury, such as halogen, incandescent, and LED (light-emitting diode) lamps, can be disposed of as regular trash or in an uncontaminated lab glass box if made of glass.

EHS provides containers across campus that are routinely collected twice a year by EHS staff. To use these containers, contact EHS for the nearest location of a container that meets your needs. These containers are for intact lamps only; broken lamps must be managed as hazardous waste and submitted to EHS separately for disposal.

For individual UW lamps, please submit them to EHS using the Chemical Waste Collection Request form. Mark it on the form as "Universal waste — Lamps" and write down the date you submit it to EHS; this is the out-of-service date.

Managing broken lamps

If a small (< 8’) fluorescent lamp breaks, wear gloves and use a hand brush and dustpan to carefully sweep up the glass fragments and powder. Do not use a vacuum cleaner as it may produce airborne dust. Use duct tape followed by a damp paper towel to pick up any small glass fragments and residual powder. Place all cleanup materials into a heavy-duty plastic bag and seal it closed with duct tape by twisting the opening of the bag, folding it over, and taping it securely. Submit cleanup materials to EHS for disposal.

For incidents involving more than one lamp or other situations not described above, secure the area to keep people out, then contact EHS at 208-885-6524 during work hours or 911 after work hours.

Resources:

• Universal Waste Lamps Guidance

Mercury-containing equipment (MCE) refers to devices or parts of devices containing elemental mercury (see 40 CFR 273.9) and is regulated as universal waste. There are many types of mercury-containing equipment which may include thermometers, barometers, manometers, natural gas safety relays, and tilt switches used in appliances and older automobiles. However, equipment and devices from which the mercury-containing components have been removed are no longer considered mercury containing equipment. It is strongly encouraged to replace MCE but it is not required.

Mercury is a very toxic metal. It readily evaporates, posing a breathing hazard, and can be readily absorbed through the skin. If an MCE breaks and releases its mercury, it becomes a hazardous waste and can no longer be managed as UW.

Managing MCE

When removing MCE from service, place the mercury-containing equipment in a resealable plastic bag, cardboard box, or other suitable container. Add cushioning (e.g., bubble wrap, newspaper, or packing peanuts, etc.) to prevent it from breaking. If there is any evidence of damage to the device but no evidence of a leak, place the device in a resealable plastic bag first, then place it into a container that forms an airtight seal with its closure. Do not attempt to remove mercury ampules from MCE; doing so may cause the ampule to break and spill mercury. Mark the date you removed the MCE from service on the container. Submit the MCE to EHS using the Chemical Waste Collection Request Form. Mark it on the form as "Universal waste — Mercury containing equipment" and include information on what type of MCE it is (e.g. mercury thermometer, switch, etc.).

Spills

Small spills involve amounts that may have been released from a broken thermometer, usually less than two tablespoons (~15 mL), can be cleaned by individuals. Do not use a vacuum cleaner, broom, or mop to clean up the spill. Instead, use a mercury spill kit which typically includes zinc amalgamation powder. This powder will bind to and solidify the mercury. Once this has occurred, the solid mercury can be scraped up with a wet paper towel and placed into a sealable bag. Submit this to EHS as mercury spill cleanup.

For larger spills, contact EHS at 208-885-6524 and evacuate the area.

Unused or recalled pesticides are managed at University of Idaho as universal waste. Pesticides meeting this definition should be submitted to EHS using the Chemical Waste Collection Request form. Annually, the Idaho Department of Agriculture hosts a Pesticide Disposal Program; EHS coordinates disposal through this program.

Spent pesticide disposal

For the most part, any leftover or spent pesticides should be added to a pesticide spray tank and applied to the land whenever possible. If this is not possible, any leftover material should be collected and labeled as hazardous waste. Rinses from different pesticides can be added to the same container, but remain separated by compatibility and type (herbicide, insecticide, fungicide, etc.). These spent pesticides are not managed in this manner and must be submitted to EHS as hazardous waste using the Chemical Waste Collection Request Form.

Spills

If the original pesticide container is damaged or is leaking, wear gloves and place it in a plastic bag. Place this bag into a larger, sturdy, compatible container that can be sealed airtight. Attach a label to the container displaying the words: “Universal waste – Pesticide” and submit it to EHS.

Resources:

• Universal Waste Pesticides

Your right to know and understand chemical hazards

University of Idaho’s Hazard Communication Program is intended to provide employees with information and training on the chemical and health hazards of the chemicals they use. Our program is a requirement of a federal standard that incorporates the international standard known as the Globally Harmonized System (GHS). The federal standard is often referred to as "Employee Right to Know and Understand." In other words, employees should not only have access to safety and hazard information about chemicals they are expected to use but also be able to understand it.

Your supervisor should provide you with access to and the details of the university's written program, including the following:

• A list of hazardous chemicals in the workplace
• The location of safety data sheets (SDSs)
• Primary and secondary container labeling procedures
• The chemical and health hazards present when performing procedures, or tasks
• Procedures to follow when contractors use hazardous chemicals

Your responsibilities as an employee

Just as your employer, University of Idaho, has the responsibility of providing you with a safe and healthy work environment, you also have the responsibility for maintaining a safe and healthy work environment by:

• Adhering to established policies and procedures regarding safe chemical handling
• Participating in applicable training programs
• Reading and applying safety data sheet (SDS) information
• Using personal protective equipment and clothing in accordance with prescribed training and SDS
• Maintaining a clean and organized workplace
• Ensuring that all chemical products have SDSs and are adequately labeled; and notifying your supervisor if no SDS is available for a hazardous chemical or if an unlabeled chemical container is discovered

Hazard communication information and training you should receive

As a new employee, you will complete University of Idaho’s online Hazard Communication with GHS course before you begin working with chemicals. The course provides basic information on safety data sheets (SDSs), container labeling, and physical and health hazard properties of chemicals along with other information for managing chemicals safely. In addition, your supervisor will provide training on the specific details that apply to your work area. The training should include:

• An explanation of the Hazard Communication Standard
• A discussion and overview of the Standard Operating Procedures (SOPs) used in your work area for working with and managing hazardous materials.
• Training on how to use and manage specific hazardous chemicals safely when performing specific tasks in your area.
• Methods and observations that may be beneficial in detecting the presence or release of a hazardous chemical in your work area.
• How to protect yourself from exposure to chemical hazards, including mechanical equipment (such as chemical fume hoods) and the use of personal protective equipment (PPE).
• Primary and secondary container labeling procedures.
• The location of SDSs.
• Emergency response procedures for spills and incidents involving hazardous materials.

Training must be provided to new employees (and current employees who have not been trained) upon initial assignment and whenever a new hazard is introduced into the work area, or if the employee has been reassigned to a new area or position using different chemical products, etc. Training must be provided before performing specific tasks involving the use of hazardous materials.

Depending on your job duties, you may need additional safety training. A full list of available courses is available on the safety training webpage.

What is the Hazard Communication Standard?

The Hazard Communication Standard is founded on an employee's right to know about workplace chemical hazards. To meet this requirement, employers must identify hazardous chemicals, maintain appropriate labels and safety data sheets, and provide training so employees can recognize hazards and protect themselves from exposure.

The tools developed under the university’s Hazard Communication Program help supervisors and administrators meet these requirements. Increasing awareness of workplace hazards helps employees at all levels better understand their surroundings and question if more needs to be done to keep the workplace safe.

What is the Globally Harmonized System (GHS)?

GHS is a United Nations standardized system that has been adopted to improve hazard communication between manufacturers, suppliers, distributors, shippers, end users, and others, whether they are in the same or different countries, by using the same labels, signal words, pictograms, SDS (formerly MSDS) format, etc.

The United Nations Standard was officially adopted by the United States in 2012.

Does this program apply to my employees?

The program applies to all university employees who may handle or be exposed to hazardous chemicals except for the specific exemptions described below:

1. Office workers — Office workers that use consumer products for their intended purposes, provided they are used in a manner consistent with reasonable consumer use are exempt from following GHS. For example, office use of products such as printer toner, glass cleaner, disinfectants, furniture polish, etc., is exempt if the frequency and duration of use is comparable to home use. An employee that uses glass cleaner all day long every day would not be exempt from this program.
2. Warehouse/shipping employees — Warehouse and shipping/receiving operations where employees only handle chemicals in sealed containers that are not opened under normal conditions of handling by these employees are conditionally exempt. However, they must be provided with the information necessary to protect them in the event of a hazardous chemical release.

Additionally, certain substances are exempt from this program. Please refer to the Hazard Communication Written Program for a list of specific exemptions.

What are the major program components?

• A written plan, specific to each work area, must be readily available to employees (see link below for plan template).
• An inventory of hazardous chemicals in the specific work area must be maintained.
• Safety data sheets (SDSs) for hazardous chemicals must be readily available to employees.
• All chemical containers must be properly labeled.
• All employees must complete training at the time of initial hire and at any time a new chemical hazard is introduced into the workplace (see links below for training record templates).

What are the responsibilities for supervisors under this program?

Supervisors play a key role in the effectiveness of the Hazard Communication Program. Implementing and observing these major responsibilities shows employees that supervisors value their safety:

• Completing the unit-specific written program template and maintaining a copy in the work area
• Identifying and listing all hazardous chemicals in use by employees
• Obtaining safety data sheets (SDSs) and ensuring employees have access to them (electronic or paper copies may be used; however, a binder of organized paper copies is considered best practice)
• Ensuring all chemical containers are labeled
• Completing job hazard analyses (JHAs) and SOPs as necessary
• Identifying the hazards of non-routine tasks
• Informing and training employees
• Ensuring proper personal protective equipment (PPE) is available and properly used
• Maintaining documentation (SOPs, employee training, etc.)
• Informing non-university personnel (such as contractors, USDA employees, and volunteers, etc.) of the hazards associated with hazardous substances to which they may be exposed to while performing their work in their area.

What are the responsibilities for unit administrators under this program?

In addition to ensuring supervisors are completing the requirements outlined in the major program components question above, unit administrators are responsible for the following:

• Ensuring supervisors maintain documentation, to include SOPs, employee training records, etc.
• Adequately informing any non-university personnel (such as contractors) that may share the same work area, of any hazardous substances to which they may be exposed to while performing their work.
• Correcting any deficiencies that Environmental Health and Safety or the Idaho Division of Occupational and Professional Licenses may observe during inspections.
• Periodically reviewing the program implementation within the unit to ensure compliance with program requirements.

These steps will assist supervisors in building and maintaining a unit-specific hazard communication plan. It is also recommended to complete the online course titled Hazard Communication for Supervisors, which outlines the process and provides additional regulatory information on why this is required.

Step 1: Create a binder

Select an appropriate binder, large enough to contain the written plan, chemical inventory, safety data sheets (SDS), and training records for your department/laboratory. Binder cover and section tabs templates (links) to create a binder are available from EHS. Using these templates will maintain consistency across campus and make it easier to recognize across units.

Step 2: Written plan

Using EHS-provided templates, identify the persons with primary and secondary responsibility for the unit-specific hazard communication program, the requirements for labeling of containers (including secondary containers) and other forms of warning, information employees may need, and training.

Step 3: Labeling

When hazardous materials are transferred to secondary containers, the person making the transfer is responsible for ensuring that the secondary container is labeled appropriately. At a minimum, secondary containers must include the following:

• The name of the product(s) (exactly as they appear on the related SDSs); and
• Appropriate pictograms or hazard statements

If space allows for a larger label, the labels may also include the appropriate signal word.

Step 4: Chemical inventory and safety data sheets (SDSs)

Chemical inventories and libraries of SDSs for the hazardous materials used and stored in the work area must be maintained and updated. This should be done at least once a year; ideally, they should be updated every time a change is made. The person with primary responsibility for this program must ensure a complete hard copy library of safety data sheets for the unit is maintained and accessible to workers during their shifts. This SDS library must be organized for easy access to SDSs and cross-referenced to the inventory of hazardous chemicals.

Step 5: Training

Training is required for all employees affected by the Hazard Communication Program. In addition to the online course “Hazard Communication with GHS,” supervisors must ensure their employees are provided additional training for handling specific hazardous chemicals in their work unit area. This training must be documented, and records maintained in the written plan binder. Employees must have the opportunity to review the specific safety data sheets for products they use in the workplace prior to using the product.

Regulations and resources

• APM 35.60 Hazard Communication Program
• APM 35.61 Safety Data Sheets
• OSHA Hazard Communication
• Sigma Aldrich Globally Harmonized System (GHS)

Informational guides

• Hazard Communication Program Definitions (Appendix A of Written Plan Template)
• OSHA Brief: HCS Labels and Pictograms
• OSHA Brief: HCS Safety Data Sheets
• GHS Pictograms (PDF)

Hazard communication templates

• Binder Spine Labels
• Binder Cover Page
• Binder Index Sheet - to be used with 10-tab numbered dividers
• HazCom Written Plan Template
• Hazardous Chemical Inventory
• HazCom Program New Employee Training Record
• HazCom Program New Hazard/Non-routine task Employee Training Record
• Hazard Communication Program Compliance and Review Checklist

Secondary container labels

• Avery 5160 labels (1”x2-5/8”)
• 2”x4” labels
• Pictograms for Secondary Container Labels

Q1. Lithium vs. lithium-ion vs. lithium polymer batteries — what’s the difference?

• Lithium-based batteries differ from other battery types (e.g., alkaline, lead acid, etc.) in that they store a much greater amount of energy in a smaller space.
• Lithium batteries are “single use.” These non-rechargeable (also referred to as primary cell lithium batteries) batteries have a longer shelf life than lithium-ion per charge and have a lower upfront cost.
• Lithium-ion (Li-ion) batteries are rechargeable (secondary cell). The ability to recharge them for many cycles makes them more cost effective than single use lithium batteries over time. Li-ion batteries use a liquid electrolyte (an electrically conductive material).
• Lithium polymer (LiPo) batteries are also rechargeable but can hold more stored energy in a much lighter-weight package than Li-ion batteries by using a semisolid (gel) polymer electrolyte.

Q2. What is the difference between a cell and a battery pack?

In its simplest sense, a cell is a single primary or secondary battery (e.g., AA, AAA battery). When multiple cells of the same type are connected together and sealed inside a case, it’s referred to as a battery pack.

Q3. Why do lithium-based batteries present fire hazards?

Lithium-based batteries, rechargeable or not, have high energy densities, or the ability to store a much greater amount of energy in a small amount of space. Damaged lithium batteries can enter an uncontrollable self-heating process known as thermal runaway, which may happen during charging, use or storage under certain conditions. 

Thermal runaway may cause a fire and/or an explosion. In either case, there is a lot of stored energy available to sustain the process, more than other battery types (e.g., alkaline & lead acid batteries, etc.). Additionally, lithium batteries create oxygen as they burn, making it more difficult to interrupt the burning process, which further intensifies the amount of heat emitted and accelerates thermal runaway. Thermal runaway can cause severe damage to property, inflict burns, potential exposure to toxic gases and is harmful to the environment.

Q4. How might lithium batteries become damaged?

Damaged batteries can lead to thermal runaway, so care must be taken to protect your batteries and devices from any of the situations below.

• Over-charging or discharging: Lithium batteries are best kept between 20% - 80% of their charge capacity. Both fully-charging batteries and a fully-discharging them can reduce their lifespan and overall capacity.
• Unbalanced cells: Using mismatched cells can cause excessive cell wear and degradation reducing the lifespan of the entire battery. When replacing multiple single-cell batteries in devices, be sure they are all fresh and identical batteries to help avoid this problem. Never mix batteries from different manufacturers.
• Excessive current discharge: A battery that discharges faster than its rated capacity may overheat and be physically damaged.
• Short circuits or poor electrical connections: Both situations may cause overheating and physical damage.
• Physical damage: Dropping, crushing or puncturing a lithium battery or exposing it to temperature extremes (roughly, below freezing or above 130 degrees Fahrenheit), can cause damage to the internal structure and potentially trigger thermal runaway.
• Improper storage.

See also: Q12, Can I store Li-ion batteries?

Q5. What are indications that a lithium battery is damaged?

According to the U.S. Occupational Safety and Health Administration (OSHA), signs of damage include:

• Bulging
• Cracking
• Hissing
• Leaking
• Abnormal odors
• Rising temperature
• Smoking

Always inspect batteries for any signs of damage before use. Any battery that is known or suspected to be damaged must be taken out of service. Contact EHS at 208-885-6524 promptly to arrange for proper disposal.

Q6. How do I dispose of old, malfunctioning or damaged lithium batteries?

Dispose of used lithium batteries by contacting EHS directly (208-885-6524). You may be asked to complete an online Chemical Waste Collection Form, but start with a phone call so we can respond quickly. EHS staff will arrange to collect the batteries. Never send lithium batteries to Surplus, through Campus Mail or place them in regular trash.

Although EHS can only take batteries used by the university, we still want to know about any damaged lithium batteries on campus. Report damaged batteries to EHS directly (208-885-6524).

Q7. What should I do in case of emergency?

If batteries are showing evidence of thermal runaway, or if there is any other indication of immediate danger to life, property or the environment, call 911 and notify EHS at 208-885-6524. Outside of regular business hours, call 911 and notify Campus Security at 208-885-7233 (SAFE).

ONLY if it is safe to do so, follow these steps if there is evidence of a battery malfunction (e.g., swelling, heating, abnormal odors):

• Use personal protective equipment, such as gloves, goggles/safety glasses, and a lab coat.
• Use extreme caution because the emitted gases may be flammable and toxic.
• Disconnect the battery from its power source/charger.
• Remove the battery from the equipment/device.
• Place the battery in a metal container away from combustibles. Ceramic pots or cinderblocks may also work as emergency containers. Fill the container with sand or kitty litter if readily available.
• Contact EHS at 208-885-6524 for assistance. Outside of regular business hours, call the fire department (911) and Campus Security (208-885-7233).

Q8. Are electric hover boards, e-bikes, e-scooters and similar devices allowed to be charged and/or stored inside university buildings?

No. Given the fire hazards that come with lithium-ion batteries, these items are not allowed in university buildings. The batteries on these devices are much larger than those in cell phones, laptops, and similar devices, and can store substantially more energy. If a battery malfunction occurs, the larger batteries will be able to burn longer and have a much higher potential for personal injury and property damage.

Because there are many variables that lead to lithium-ion battery failures, and the safety of any individual battery cannot be ensured, hover boards, e-bikes, e-scooters and other similar devices are not allowed in university buildings.

Q9. What are the best practices for using Li-ion batteries?

If you are using lithium batteries, you should:

• Always purchase batteries from a reputable manufacturer or supplier.
• Read all documentation supplied with your battery.
• Never burn, overheat, disassemble, short-circuit, solder, puncture, crush or otherwise damage battery packs or cells.
• Do not put batteries in contact with conductive materials, including water, seawater, strong oxidizers or strong acids.
• Avoid excessively hot and humid conditions, especially when batteries are fully charged.
• Do not place batteries in direct sunlight, on hot surfaces or in hot locations.
• Do not store batteries at low or freezing temperatures.
• Immediately disconnect the batteries if, during operation or charging, they emit an unusual smell, generate heat, change shape/geometry or behave abnormally.
• Contact EHS for disposal; do not request collection by Surplus, send through Campus Mail or place in regular trash.

See also: Q10, Are there safe battery charging protocols?

Q10. Are there safe battery charging protocols?

Yes, the National Fire Prevention Association (NFPA) and battery manufacturers have common charging recommendations. Here are some general recommendations:

• If a battery will not take a charge, something is likely wrong with the battery. Remove it from the charger and contact EHS.
• Always use the charger that came with the battery and follow manufacturer’s instructions.
• Never charge a disposable (lithium or alkaline) battery; store one-time use batteries separately.
• Charge or discharge the battery to approximately 50% of capacity before long-term storage.
• Use chargers and methods designed for lithium batteries and their specific charge profile.
• Disconnect batteries immediately if, during operation or charging, they emit an unusual smell, develop heat, change shape/geometry or otherwise behave abnormally. Contact EHS for proper disposal.
• Remove cells and packs from tools/devices when not in use and chargers promptly after charging is complete. Do not use the charger as a storage location.
• Charge and store batteries in a fireproof container and on a noncombustible surface.
• Do not parallel charge batteries of varying age and charge status.
• Do not overcharge Li-ion batteries.

Q11. Can I ship Li-ion batteries or devices containing Li-ion batteries?

No; however, EHS can help. Li-ion or equipment containing Li-ion batteries are considered “dangerous goods” because they can pose significant safety risks in transportation. If you must ship Li-ion batteries or equipment containing Li-ion batteries, contact EHS for assistance. EHS has qualified staff with specialized training in shipping dangerous goods. 

For your awareness: Failure to comply with regulations for shipping hazardous materials can result in significant civil penalties for the shipper of up to $100,000.00 per violation; $235,000 if the violation results in a serious injury, death or substantial damage to property.

Q12. Can I store Li-ion batteries?

Absolutely. Proper lithium battery storage is critical for both battery performance as well as for your safety.

• Store Li-ion batteries at room temperature.
• Li-ion/LiPo batteries should never be stored fully charged. When not in use, store the Li-ion/LiPo battery pack at about 50% of the pack’s rated capacity.
• Remove the battery from a device before storing.
• Use a Li-ion/LiPo battery fireproof safety bag or other fireproof container when storing batteries.
• Cell terminals must be protected by covering them with non-conductive electrical tape.
• Have a reserved storage area for Li-ion/LiPo batteries ONLY. It must be a cool and dry place, away from heat sources and separated from any combustible materials.
• The ideal surface for storing Li-ion batteries is concrete, metal, ceramic or other non-flammable material. A rated metal flammable cabinet is also an option.
• A smoke detector should be in the battery storage area.
• A class ABC or CO2 fire extinguisher should be readily available near the storage area.
• Do not store Li-ion batteries on loading docks, behind buildings, in basements or in stairwells.
• Do not store Li-ion or equipment containing Li-ion batteries under any stairway, indoors or out
• Do not leave e-bikes and other similar equipment near building stairs or doors where they may prevent people from exiting the building if a fire occurs.
• Do not send Li-ion batteries to U of I Surplus or through Campus Mail.
• Do not store malfunctioning or bad Li-ion batteries. Contact EHS promptly for proper disposal.

Q13. Is it safe to use Li-ion or LiPo batteries at my workplace?

With proper handling, the risks are minimal, and these batteries are safe for daily use. Most incidents involving lithium batteries result from inadvertent mishandling, overcharging, and damage to the battery’s shell.

Q1. Is there a training class for hazardous waste?

EHS offers four classroom training sessions on hazardous waste management, which include the following:

1. Hazardous Waste Management Workshop for Labs — This workshop is intended for students and employees who primarily work in laboratory settings.
2. Environmental Waste Awareness Training for Custodians — This workshop is for custodial staff.
3. Hazardous Environmental Waste Awareness Training for Shops and Maintenance — This workshop is intended for employees that work in shops and/or provide maintenance and repair services, etc.
4. Hazardous Waste Management Workshop for VSQG — This workshop provides training specific to employees working at very small quantity generator (VSQG) facilities throughout the state (e.g., Research and Extension centers and teaching facilities). This workshop is the only one offered via Zoom or Teams.

Classes are generally offered once per month, depending on demand. To see availability of workshops scheduled, check the safety training calendar. You can register for the appropriate workshop by contacting safety@uidaho.edu.

Q2. Who must attend hazardous waste training?

All employees and students who are identified by their unit administrators as individuals who generate and/or manage hazardous waste shall attend the appropriate university hazardous waste management workshop prior to generating and/or managing hazardous waste at a university facility. Hazardous waste training must be repeated every five years.

Q3. What is "hazardous waste"?

In general, chemical waste is a hazardous waste if it is listed (e.g., F-listed, U-listed or P-listed) and/or characterizes (i.e., is ignitable, corrosive, reactive or toxic) as hazardous waste as defined in the EPA regulations. Realize that just because a chemical does not meet the definition of an EPA hazardous waste, does not mean it is not toxic or harmful to the environment.

Q4. What are acute hazardous wastes?

These are highly toxic and/or reactive materials capable of causing or significantly contributing to an increase in serious irreversible or incapacitating illness or death. For our purposes, they include discarded unused formulations of trichlorophenol, tetrachlorophenol, and pentachlorophenol AND discarded commercial chemical products, including dilutions, that are specifically listed as acute hazardous wastes (also called P-listed chemicals).

Q5. How do I get empty chemical waste containers?

You can reuse empty reagent bottles as chemical waste containers. Make sure that the container residue is compatible with the anticipated waste. Rinsing containers is recommended before adding aggressive chemical waste, such as oxidizers or corrosive waste. Empty waste bottles can be obtained for free through ChemStores during their business hours.

Q6. How do I label a hazardous waste container?

Chemicals become hazardous waste when someone decides to no longer use them. Label containers as soon as they contain even one drop of an unwanted chemical. Use a waste accumulation label, provided by EHS, to mark the container with its constituents, hazards, and responsible person(s).

Q7. What is the general process for accumulating hazardous waste?

1. Choose a container that is compatible with the chemical waste.
2. The container must be sturdy and have a tight-fitting screw cap.
3. Label the container with a waste accumulation label provided by EHS.
4. Keep the container closed except when adding or removing waste.
5. Liquid waste must be kept in a secondary containment. This containment must be a chemically compatible containment tub of adequate capacity (10% of total volume of waste that will be stored inside the tub).
6. Store the waste at or near the point of generation. DO NOT move it to another room.
7. Keep the waste under the control of the person who generates it. Make sure to identify and dispose of all waste before leaving the university.
8. Store no more than 55 gallons of hazardous waste or one quart of acutely hazardous waste.
9. If a container of chemical waste leaks, transfer the remainder to another container that is in good condition, and clean up the leaked material. Submit the spill cleanup material as waste to EHS.
10. Submit waste when full or instructed by EHS to do so by using the application attained through the EHS website to prevent excess accumulation in your workspace.

Q8. How do I request a pickup of my hazardous waste?

Submit a request to EHS through our online Chemical Waste Collection Request system. When prompted, be sure to print a collection request label and attach it to the waste container.

Q9. How long will it take for waste to be picked up?

EHS makes every effort to collect waste within 10 working days from the online request. However, extenuating circumstances may prolong waste collection, such as waste shipments, issues with the waste, or reductions in staff, etc. If your waste has not been collected within two weeks (or longer), please feel free to call or email EHS to check on its status and/or to see if collection has been paused for any reason.

Q10. Why would EHS not collect a waste container?

• It has not been submitted for disposal via an online Chemical Waste Collection Request.
• A Chemical Waste Collection Request label is not attached to the container.
• The contents of the container are unknown, different or the listing of constituents is incomplete, etc.
• A container for liquid waste does not have a tight-fitting lid or the lid is missing.
• The container is incompatible with the contents, damaged or leaks, etc.
• The container is overfilled.
• The container is in a different location than that appearing on the submittal.
• The container’s contents are incompatible or present an unsafe condition, etc.

Q11. How can I dispose of containers of unknown chemicals?

First, try to avoid the generation of “unknowns” by labeling all chemical containers. If an unknown container appears, inquire of your co-workers if they may know of the contents. Submit a Chemical Waste Collection Request, listing the constituents as “Unknown.” Under the "Additional Information” section, provide as much information as possible, such as color and appearance, pH if applicable, possible constituents, etc. Please provide an index number to charge back characterization and disposal costs.

Q12. How do I collect and dispose of sharps?

The university defines a “sharp” as any used labware capable of puncturing a plastic bag causing potential exposure to EHS staff handling it. Sharps include such items as:

• Needles
• Scalpels and knife blades
• Razor and X-acto blades
• Syringe needles
• Broken glass such as Pasteur pipettes and labware
• Plastic pipette tips, syringes & tubes, etc.
• Glass Pasteur and volumetric pipettes

An EHS Laboratory Guidance on sharps disposal is available to help you properly dispose of sharps.

EHS provides free sharps containers for accumulating most sharps, except for broken lab glass. Broken glass must be accumulated in a broken glass box, which is available online as well as through ChemStores.

Sharps containers that accumulate chemically contaminated sharps must comply with all EPA hazardous waste regulations for accumulating, storing, and disposal.

Do not comingle chemically contaminated metal sharps with any other chemically contaminated sharps.

Q13. How do I handle chemically-contaminated biohazardous waste?

Do not use red biohazard bags for chemically-contaminated biohazardous waste. Disinfect the biohazard component by applying a recognized chemical disinfectant; then, manage the sterilized waste as a chemical waste. List the chemical constituents on the hazardous waste label. Never autoclave chemically contaminated biohazardous sharps.

Q14. How do I dispose empty chemical containers?

For empty containers that did not contain acutely hazardous waste (P-listed chemicals), thoroughly empty the container by pouring until dripping stops, or scooping solid chemicals from the container, etc. Use a thick black marker, obliterate the manufacturer’s label and mark “EMPTY” or “MT” on the container. Then place the empty liquid containers in a fume hood to ventilate until completely dry. You may reuse the container for waste accumulation or place it in a laboratory broken glass box or in a sturdy cardboard box that is marked “Broken glassware” or “Laboratory glass.” When full, tape the box closed and place directly in a municipal waste dumpster.

In order to dispose of containers which contained acute hazardous waste, these containers must triple-rinsed with an appropriate solvent and the rinses collected. However, as this requires time and effort and generates a much larger volume of acute hazardous waste, it is generally recommended to simply submit the container as an acute hazardous waste to EHS for disposal.

Q15. What are universal wastes?

For many years, certain common commercially available products manufactured and produced in the United States (that were hazardous waste) were ending up in solid waste municipal landfills when disposed of by the companies and businesses that purchased them. However, to prevent improper disposal of these products, the EPA passed the universal waste regulations that consisted of reduced requirements for the disposal for universal waste (i.e., aerosol cans, batteries, pesticides, mercury-containing equipment and mercury lamps).

For more information about how to dispose of each of these types of universal waste, see the universal waste section above.

Q1. What should I do with old material safety data sheets?

Retain the older MSDSs until you obtain a revised safety data sheet (SDS) for the same product, after which the older version can be discarded. Place the old MSDSs into a separate binder labeled “Archive MSDS” and the new SDSs into a binder labeled “Active SDSs”.

Q2. Can safety data sheets be stored only on a computer?

SDSs must be readily accessible to all employees during each work shift. Electronic access and other alternatives to maintaining paper copies of the SDSs are permitted if no barriers to immediate employee access in each workplace are created by such options. However, what would happen during a power outage? How conveniently located is the computer? Do all employees have access to it? What if the computer crashes? While an electronic copy of the SDS is highly convenient, it cannot replace hard copies of the SDSs. These must be maintained in a centrally located area for immediate access by all employees working in the lab, shop, or other work area.

Q3. Does this Hazard Communication Program apply to shop, custodial and laboratory employees?

Yes. Hazard communication is required for all employees that handle hazardous chemicals, including, but not limited to shop employees and custodians. It is also an important component of the Laboratory Safety Program.

Q4. I work in shipping and receiving, and my job never requires me to open a chemical container. Does the Hazard Communication Standard apply to this situation?

Yes, to a limited extent. In this situation, employees need information and training to protect themselves in the event of a hazardous materials spill or leak from a package or other shipping container; and employers must ensure that labels on incoming containers of hazardous chemicals are not removed or defaced. However, supervisors may choose to train shipping and receiving employees to the same extent as other employees required to complete hazardous communication (HazCom) training.

Q5. Are pesticides covered by the Hazard Communication Standard?

Yes and no. The Hazard Communication Standard does NOT apply to the labeling of pesticides because they have their own labeling regulations issued by the Environmental Protection Agency. However, other provisions do apply, such as the requirement to have safety data sheets readily available.

Q6. Are there situations in which the Hazard Communication Standard does not apply at all?

Yes, including, but not limited to:

1. Hazardous waste, as defined by the Resource Conservation and Recovery Act (RCRA), must have its hazards indicated according to the Hazard Communication Standard (HCS) if it meets the standard's definition of "hazardous chemical" in 29 CFR 1910.1200(c), unless it falls under any of the HCS exemptions.
2. Tobacco or tobacco products.
3. Wood or wood products where the only hazard is due to flammability or combustibility.
4. Food or alcoholic beverages.
5. Cosmetics intended for personal use by employees while in the workplace.
6. Ionizing and nonionizing radiation.
7. Biological hazards.
8. Consumer products where the employer can show that it is used in the workplace for the purpose intended by the chemical manufacturer of the product, and the use results in a duration and frequency of exposure which is not greater than what is reasonably experienced by consumers (e.g. cleaning products).

Q7. How are hazardous chemical labels prepared under the Hazard Communication Standard?

According to the Hazard Communication Standard, labels prepared for hazardous chemicals must indicate the identity of the chemical and the appropriate hazard warnings. Once the hazard classification is completed, the standard specifies what information is to be provided for each hazard class and category. Labels will require the following elements:

Pictograms — Pictograms are symbols plus other graphic elements, such as a border, background pattern, or color that are intended to quickly convey specific information about the health/physical hazards of a chemical. Each pictogram consists of a different symbol on a white background within a red square frame set on a point (i.e., a red diamond). There are nine pictograms under the GHS.

Signal words — Single words alert users of the relative level of severity for the hazards indicated on the label. There are only two signal words used – "danger" and "warning." "Danger" indicates a more severe degree of the hazards indicated on the label, while "warning" indicates a less severe degree for hazards indicated on the label.

Hazard statements — Hazard statements assigned to a hazard class and/or category describe the nature of the hazard(s) of a chemical, including, where appropriate, the severity of hazard.

Precautionary statements — Precautionary statements include phrases that describe recommended measures to be taken to minimize or prevent exposure, to properly store and/or handle, etc., hazardous chemicals.

Q8. What pictograms are required in the revised Hazard Communication Standard? What hazard does each identify?

There are nine pictograms under the GHS to convey the health, physical and environmental hazards of a hazardous chemical.

Q9. What information is required or provided in safety data sheets (SDS)?

Information required on safety data sheets (SDS) is presented using specific headings in a specified sequence.

The 16-section SDS format includes the following sections:

Section 1. Identification
Section 2. Hazard(s) identification
Section 3. Composition/information on ingredients
Section 4. First-Aid measures
Section 5. Fire-fighting measures
Section 6. Accidental release measures
Section 7. Handling and storage
Section 8. Exposure controls/personal protection
Section 9. Physical and chemical properties
Section 10. Stability and reactivity
Section 11. Toxicological information
Section 12. Ecological information
Section 13. Disposal considerations
Section 14. Transport information
Section 15. Regulatory information
Section 16. Other information, including date of preparation or last revision