1. Hazardous Waste and Chemical Management
Glenn Magley
MKC Enterprises, Inc.

2. Hazardous Waste Management Learning Objectives
The generator of hazardous waste will be able to:
Identify hazardous waste
Ensure it is properly managed 1. 2. 3. 4.

3. Hazardous Waste Module
State and federal regulations require that employees who produce (generate) hazardous waste must be trained.
This module has been developed to meet this expectation.

4. Hidden Hazards Dangerous chemicals in school labs an explosive situation
By Katheleen Conti, Boston Globe Staff  |  April 10, 2005
Chemistry lesson one: Accidents happen, like the recent spill at Exeter High School in New Hampshire, when fumes in a lab class sent three students to the hospital and shut down the school for the day.
Chemistry lesson two: Adding unknowns to the mix -- like improper storage and handling of toxic substances -- can be a formula for disaster.
In January, firefighters responding to an alarm triggered by a chemistry experiment at Pope John XXIII High School in Everett found a jar containing a potentially volatile material that is used to produce rocket fuel. Deemed unstable, the chemical -- 2, 4-dinitrophenol -- was detonated by the State Police Bomb Squad.

5. Chemicals Ordered Removed
By Tarron Lively, THE WASHINGTON TIMES, Published March 25, 2005
D.C. Public Schools Superintendent Clifford B. Janey issued a protocol yesterday for removing potentially dangerous chemicals from schools, after a series of mercury contaminations and the revelation that a previous removal effort was incomplete.     The nine-page protocol lists more than 200 chemicals including mercury, chlorine, chloroform, ether, hexyl alcohol and nicotine. The protocol was issued to the principals of each of the city's roughly 150 public schools. The school system's Hazmat Removal Team, D.C. Fire and Emergency Medical Services and the American Association for the Advancement of Science helped create the protocol and will handle the removal and disposal of the materials.       School administrators ordered all potentially hazardous materials removed after an October 2003 mercury spill at Ballou High School in Southeast. The incident closed the building for more than a month, and cleanup cost at least $1 million. A student who was charged in the case had taken the mercury from a science lab.     However, investigations into the recent mercury incidents at Cardozo High School and Hardy Middle School revealed that potentially hazardous materials were still inside schools.

6. Recently In Colorado, 300 schools were inspected.
They Reported:
          99% had inherited their inventories           98% had incompatible storage           94% had shock sensitive compounds           85% had inadequate chemical hygiene plans           65% had inadequate functioning fume hoods           30% had explosive chemicals           15% had radioactive materials

7. The EPA “Reaches Out”
In February 2007, EPA Region 4 launched the Colleges and Universities Compliance Incentive Initiative, encouraging.
Region 4 mailed letters to public and private colleges in the southeastern United States to “highlight the opportunity to take advantage of voluntary environmental self-audits” .
This provides incentives for schools to voluntarily discover, disclose, and correct non-compliance.
Disclosures may receive a partial or complete reduction in financial penalties.

9. Summary of Incentives under EPA’s Audit Policy
Penalty mitigation
No recommendation for criminal prosecution.
No routine requests for audit reports.

10. EPA seeks $171,050 from Plymouth State University, Plymouth, NH for Hazardous Waste Violations
Contact: Sheryl Rosner, EPA Office of Public Affairs, (617)
For Immediate Release March 3, 2005; Press Release #sr050301
The U.S. Environmental Protection Agency announced today that it has proposed a $171,050 penalty against Plymouth State University, in Plymouth, NH for violations of hazardous waste laws. ….
Specifically, EPA claims that the University failed to:
make hazardous waste determinations;
properly store hazardous waste;
maintain spill and fire control equipment;
post “no smoking” signs;
post emergency telephone numbers;
keep hazardous waste containers closed;
mark hazardous waste containers with accumulation dates;
conduct inspections of hazardous waste storage areas.

11. EPA Cites Puerto Rico University at Mayaguez for Multiple Violations of Environmental Safety Rules Wednesday, October 5, 2005
The U.S. Environmental Protection Agency (EPA) has cited the University of Puerto Rico (UPR) in Mayagüez for violating EPA Regulations… and proposed that the university pay nearly $1 million in penalties for these violations. …….
UPR submitted self-disclosures under EPA's Audit Policy … Normally, EPA would grant relief from financial penalties for self- disclosed violations, but it was determined that UPR was not eligible for full relief because UPR was not correcting all its violations. As a result, EPA conducted its own comprehensive inspection .. and found numerous violations.
EPA and the Commonwealth found that UPR failed to operate its facility in a manner that would minimize the risk of releasing hazardous wastes … The containers held wastes ranging from used oil, various acids and spent solvents to formaldehyde. UPR was also storing hundreds of containers of old and expired chemicals, such as picric acid, in an unsafe manner.

12. What is a Waste?

13. EPA describes several ways something becomes a waste:
Discarded
Inherently waste-like (dioxins)
Use constituting disposal
Speculative accumulation
40 CFR Part 261 (

14. Speculative
accumulation:
pack rats

15. Go to the handout on waste types

16. Compliance Tips Helpful Tip #1: How do you tell whether it’s waste?
Is it in good condition and labeled?
Is it currently legal for use in the U.S.?
Has anyone used it in the last year or two? Be honest.
Will anyone use it in the next year or two? Be brutally honest.

17. Compliance Tips Helpful Tip #2: How old is that bottle?
Plastic Screw Caps: 1912
Fisher Scientific incorporated: 1926
ZIP codes: 1963
CAS numbers: 1966
You DO date your bottles, don’t you?
If it has a cork, it’s older than 1912.
If the bottle says Eimer, it’s older than 1926.

18. Is it a Hazardous Waste?

19. Hazardous Waste Classification
Can be a:
Solid
Liquid
Gas
Sludge
Hazardous waste is a material that no longer has an intended value

20. Hazardous Waste Definition
The following categories are not considered hazardous waste:
Sewage
Regular trash
Radioactive waste
Biohazard waste

21. Determination of Waste Status
The burden of proof to determine if a waste material is defined as “hazardous” is on the generator
May need to analyze the waste to determine its status

22. Waste is Hazardous for:
Characteristics:
Ignitability: Flash Point <140°F (60C): diethyl ether, acetone, magnesium, perchlorates
Corrosivity: pH <2 or >12.5, 10% solution
Reactivity: water-reactive, pyrophoric, generates sulfides or cyanides, shock-sensitive: picric acid, white phosphorus, sodium, NaCN, NaS

23. Waste is Hazardous for:
Toxicity:
Benzene
Carbon tetrachloride
Chloroform
Methyl ethyl ketone
Pyridine
Tetrachloroethylene
Trichloroethylene
Vinyl chloride
Plus……
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver

24. Waste is Hazardous for:
Listed wastes:
Beryllium powder
Carbon disulfide
Dieldrin
Vanadium pentoxide
Acetaldehyde
Acrylamide
Creosote
Diethylstilbesterol
Formaldehyde
Maleic anhydride
Phenol
Plus…..

25. Some
hazardous
wastes are
obvious

26. Some are not

27. How do you tell it’s hazardous?

28. Hazardous Waste 101 How do you tell? Ask the vendor Use the MSDS Book
Use the MSDS Online

29. Hazardous Waste Examples of hazardous waste:
Mercury from a broken thermometer
Acetonitrile from HPLC
Ethidium bromide
Flammable Paints and Solvents
Waste isopropyl alcohol
Aerosols
Electronic circuit boards (lead solder)

30. Hazardous Waste Locations
Laboratories and Classrooms
Maintenance Facilities (paint, pesticides, maintenance fluids)
Light Bulbs
Nursing Schools / Health Services
Buildings repurposed from science curriculum

31. What do I do once I found it?

32. Improper Waste Management

33. Management of Chemical Waste
Separate incompatible material
Label Each Waste Container
Seal each waste container
Keep track of constituents (rough quantities)
Store waste in appropriate locations (cabinets, not in active hoods)

34. Proper Labeling All waste containers must be properly labeled.
Hazardous Materials Must have the words “Hazardous Waste”
“Used Oil”
“Universal Waste -- Lamp(s),” or “Waste Lamp(s),” or “Used Lamp(s)",
Must include all hazardous components

35. Improper Labeling

36. Improper Methods of Disposal for Hazardous Waste
Hazardous waste should not be:
Placed In regular trash
Mixed with biohazard waste (red bag or sharps)
Flushed down the drain
Allowed to reach surface water (rivers, lakes) via storm sewer system
Allowed to evaporate (note - open containers imply evaporation)

37. Where did the waste go?

38. Satellite Accumulate Area
Satellite accumulate area – is defined as the area (typically a room) where the hazardous waste is generated.
Must be designated with signs
Containers must remain closed except when adding material.
Containers must be marked with the words “Hazardous Waste”.

39. Satellite Accumulation Area
Can accumulate up to 55 gallons of hazardous waste or a maximum of one quart of acutely hazardous waste
May need to segregate chemicals and provide secondary containment
Do not date hazardous waste label until the container is moved out of lab

41. Reduction of Chemical Waste
Replace reagents with less toxic alternatives (green chemistry)
Work in smaller scales
Centralize purchasing
Buy only what you need for 1 year
Supervise what is coming into stock
Neutralize acids and bases (not chromic or fuming acid)

42. Containers Contents must be compatible with container material
Problems:
Certain solvents placed in plastic containers
Hydrofluoric acid in glass containers

43. Containers Do not mix incompatibles that will produce: Heat
Violent reactions
Fire/Explosion
Flammable or toxic gases

44. Empty Containers
Empty containers that once held a hazardous material may be placed in the regular trash.
Containers that held acutely toxic materials (selected list from EPA) are considered hazardous waste and may not be placed in regular trash.

45. Empty Container Definition
An empty container is defined as:
All waste has been emptied using common practice
Maximum of 1 inch of product remains in container
No more than 3% by weight of the container remains (tanks <110 gallons)

46. Examples of Violations

47. Summary of Most Common Violations
Waste containers were not marked “Hazardous Waste”
Waste Containers without dates of accumulation
Waste Containers are not closed
Universal waste light bulbs were not being managed properly
Training of employees who handle hazardous waste is not documented
Inspections were not recorded on a weekly basis
Onsite Treatment of wastes is occurring.
Waste material has not been determined as being hazardous
Not all MSDS’s

48. Violations

49. Violations (cont.)

50. Liabilities = Injury to Students / Personnel
Violations can be up to $5,000 each
Willful Neglect
Repeat Offenses
Violations with Immediate Threat to Human Health or Environment - $25,000
Unreported spills, Dumping, Misrepresentation =

51. Chemical Management and Handling

52. Labeling
Be certain to label all containers including date of receipt or formulation. Ink should be waterproof and fade resistant.
Must have accurate chemical inventory and MSDS’s accessible throughout school.

53. Arrangement
Placement of the items on a stockroom shelf should be based upon compatibility--not alphabetical succession.
Ammonium nitrate + acetic acid mixture will ignite especially if acid is concentrated
Cupric sulfide + cadmium chlorate explode on contact
Sodium + sulfur reaction proceeds with explosive violence
Sodium cyanide + sulfuric acid release of HCN gas, death vigorous reaction, highly exothermic
The Flinn Scientific Catalog has an excellent system to store chemicals based upon their compatibility.

54. Improper Arrangement

55. Shelving
Shallow trays (e.g. Rubbermaid) will provide spill protection.
Shelving needs to be secured to a wall or floor.
Shelves with raised lips help to prevent bottles being pushed onto the floor.

56. Improper Shelving Usage

57. Large Containers
Large containers should be avoided by ordering chemicals in the smallest practical size. (The initial cost savings are not worth the disposal costs and liability.)
They should be placed on lower shelves.

58. Flammables / Acids / Bases Storage
Flammable liquids should be stored in safety cabinets.
Appropriate cabinets for Organic Acids, Inorganic Acids (at least separate trays in cabinet), and Nitric Acid should be used if volumes appropriate.
Bases need to be stored separately.

59. Acid Cabinet Too Full

60. Compressed Gasses Compressed gas cylinders should be avoided.
If cylinders are in a stockroom they should be secured to a fixed object (e.g. a wall).

61. Unsecured Cylinder

62. Health and Safety Equipment
Safety showers and Eye Washes (accessible and inspected)
Laboratory Fume Hoods (inspected and clear)
Personal Protective Equipment (PPE) (used and required in lab, posted)

65. Chemicals to Remove
Anything not used last year this year or next year.
Reactive Chemicals
Hygroscopic (Wet) Chemicals
Low molecular weight organics
Strong Oxidizers
Older than 10 years
Poor packaging (repackage?)
Unlabeled / Unknowns

66. Inspections Should occur often and be recorded.
Looking for material that may be leaking, not properly closed, or out of place.
Annually the shelves should be examined and any chemicals disposed of that will not be used in the next year.

67. Unacceptable Storage Found in Inspection

68. Spilled / Leaking Chemical

69. Laboratory Inspection Sheet

70. Helpful References USEPA Website for Reference http://www.epa.gov/epa
MIT Environmental Virtual Campus
USEPA Website for Reference
Chemical Safety Information

71. Thank You