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This chapter discusses the University procedures for chemical and hazardous waste classification, packaging, labeling and handling. These procedures are necessary for compliance with regulations of the Environmental Protection Agency, the Nuclear Regulatory Commission, The Department of Transportation, the Occupational Health and Safety Administration, and the Ohio Department of Public Health. Principal Investigators and area supervisors must ensure that the appropriate personnel follow these procedures. Call Safety Services at 368-2907 with any specific questions or problems. In the University Hospitals areas, contact the UH Safety Department, 844-1458 for disposal procedures. For disposal of sharps and biohazardous waste in University Hospitals buildings, contact the Environmental Services Department at 844-3071. All researchers who handle any potentially hazardous materials should recognize the hazards and be aware of procedures required to protect themselves and the environment from the effects of these materials.

I. CHEMICAL WASTE

The purpose of this document is to assist you in understanding the regulations and how to comply with them.

A. Disposal of Chemicals

Wastes regulated by the EPA are not permitted to be disposed of down the sanitary sewer. These waste chemicals must be retained by each laboratory in a container labelled with the words "Hazardous Waste." No more than 55 gallons of waste may be accumulated.

1. Procedure

a) Segregate your chemical waste by compatibility (see Tables below) and clearly label waste bottles with the terms "Hazardous Waste." Plastic bottles are preferred over glass for storing hazardous wastes, but check the compatibility of the waste with the specific plastic first (compatibility charts are available in the Safety Office).

b) When containers are full, fill out a Hazardous Waste and Unwanted Chemical Disposal Listing form (See Appendix F for sample) and return it to Safety Services. Chemicals will be picked up for disposal at the earliest possible date after receipt of this form. In the University Hospitals areas, contact UH Environmental Services. Chemical waste containers should be labelled with the following:

1) exact composition of the waste

2) age of the waste

3) place of origin(department, room)

4) hazardous properties

5) PI's name and telephone number

6) bottle number assigned on corresponding waste sheet.

Waste containers must be accompanied by a completed Hazardous Waste Information form (See Appendix F).

2. Table of Incompatible Chemicals

TABLE 2. General Classes of Incompatible Chemicals*

The following general classes of chemicals are incompatible with one another.

Acids or Bases, metals, or

oxidizing agents reducing agents

Chlorates Ammonia, anhydrous and aqueous

Chromates Carbon

Chromium trioxide Metals

Dichromates Metal hydrides

Halogens Nitrites

Halogenating agents Organic compounds

Hydrogen peroxide Phosphorus

Nitrates Silicon

Nitric acid Sulfur

Perchlorates

Peroxides

Permanganates

Persulfates

*These examples of oxidizing and reducing agents are illustrative of common laboratory chemicals; they are not intended to be exhaustive.

See Appendix E for a table of specific chemical incompatibilities.

B. Specific Labelling and Waste Procedures

1) Hazardous Wastes

All materials that are regulated by the EPA under CFR 40 and may not be disposed of to the environment are considered hazardous wastes. Their containers must be labelled "hazardous waste" as well as having all the information listed in Section I, Part B of this chapter.

2) Handling and Storage Instructions for Hazardous Wastes

a) Ignitable Liquids and Organic Solvents

• Keep halogenated solvent wastes separate from nonhalogenated solvent wastes whenever possible.
• Separate organic solvents from aqueous solutions whenever possible.
• For larger waste volumes, use a metal 5-gallon can.
• For smaller volumes, or for solvents that react with metal, use a 1-gallon glass (or, preferably, plastic) container (check compatibility).

b) Acids, Bases and Aqueous Solutions

• Collect concentrated acids or bases in 1-gallon glass bottles if possible; otherwise, use a 5-gallon container. Exception: hydrofluoric acid must be stored in plastic.
• Do not mix strong acids or oxidizers with organic compounds.
• Keep all perchloric acid wastes in exclusive-use containers.

c) Heavy Metal Solutions

• Keep solutions containing arsenic, barium, cadmium, chromium, lead, mercury, selenium, silver, or other heavy poisonous metals separate from other wastes.

d) Paint and Paint Thinners

• Separate solid paint sludge from paint thinners by pouring off thinners into a separate waste container.
• Keep water and water-based paint wastes separate from oil-based wastes. Rinsate from water-based paint clean up is nonhazardous and can be disposed of down the sanitary sewer.

f) Used Chromatographic Adsorbent

• When possible, segregate chromatographic adsorbents from liquid wastes.
• Indicate the chemical and its concentration of contaminants in the adsorbent material.

g) Animal Waste Contaminated with Hazardous Chemicals

• Procedures for handling these wastes are implemented by the Animal Resource Center(ARC). Contact the ARC at 368-3490.

h) Broken Thermometers

• Attach a waste tag to the container and label the material as "broken thermometer and elemental mercury."
• Please note: mercury volatilizes and can be a hazard. Even the mercury from one thermometer can create a potential health risk. Call Safety Services promptly for disposal and pick up. In the University Hospitals areas, contact Protective Services at 844-HELP or the UH Safety Department at 844-1458.
• For larger spills or mercury, (>3cc), evacuate the area and call Safety Services (8:30 am - 5:00 pm, M-F). They will respond, clean up the spill and monitor the room air to ensure the area is safe to reenter. For a spill in University Hospitals, contact Protective Services at 844-4357, who will call Safety Services.
• Mercury spill kits and neutralization sponges should be available in all labs in the event of an after hours spill. All waste materials from the cleaning will be disposed of by Safety Services or the UH Safety Department, 844-1458, if in University Hospitals.

2) Discarded Hazardous Substances

a) Gas Cylinders

• Promptly return discarded or empty gas cylinders and lecture bottles to the vendor to regain your deposit on the cylinder and minimize rental charges. Contact General Stores for this service. See Chapter 5, Section II for more information.

b) Chemicals in Original Container

• Label these containers with the same information as you would a hazardous waste, only do not write "hazardous waste" on the container. Alternately, this material often can be re-used or recycled.

C) Procedures for Disposal of Explosive or Extremely Reactive Materials

• Potentially explosive materials, such as dry picric acid or old ethers, will be picked up separately from other wastes. Contact Safety Services as soon as possible upon discovering any potentially explosive materials.
• In general, extremely reactive materials should be disposed of in glass bottles.
• Alert handling and disposal personnel to the hazardous nature of these items.

D. Disposal of Chemicals in Sanitary Sewers (Drains)

Hazardous wastes are regulated by the Environmental Protection Agency under the Resource Conservation and Recovery Act (RCRA). In general, these regulations do not permit any drain disposal, except for those items listed below.

THE FOLLOWING CLASSES OF CHEMICALS MAY BE DISPOSED OF IN THE SANITARY SEWER (DRAIN)

• Inorganic acids and bases that have a pH between 5.0 and 10.0. These pH limits are imposed by local regional sewer regulations.
  
  Sewer disposal is permitted provided that no other regulated chemical is present. Neutralization is permitted to change the pH to within acceptable limits if it is written into the experiment's protocol.
• Aqueous buffer solutions containing no regulated materials, e.g., common salt solutions or tissue culture media.
  
  Such solutions may contain millimolar concentrations of common biochemicals, buffers, serum by-products, or cell metabolites.
  
  When in solution, common salts (chlorides, bicarbonates, citrates, phosphates, sulfates, acetates) of sodium, potassium, magnesium, and calcium may be disposed of in the sanitary sewer.
• Aqueous High Performance Liquid Chromatography (HPLC) solutions or other solutions containing less than 24% ethanol, propanol, or isopropanol (no other alcohols). The 24% limit is based on flammability of the alcohol.
  
  HPLC solutions containing any amount of acetonitrile or other organic solvents must be disposed of through Safety Services. In University Hospitals, contact the UH Safety Department, 844-1458 to arrange for disposal of these chemicals.
• Bacteriological and tissue culture media
  
  Such media containing live organisms must be sterilized by autoclaving or another acceptable procedure and must not contain anything other than common biochemicals. Serum by-products or cell metabolites containing azides or thioglycolate must be picked up by Safety Services for disposal, or, in University Hospitals, by the UH Safety Department.

Mixed waste (radioactive waste combined with a solvent or inorganic material) must be classified by chemical before drain disposal. Refer to the Radiation Safety Manual for procedures and acceptable limits.

No more than unavoidable traces of highly toxic organic chemicals, such as those found on glassware surfaces, of either synthetic or biological origin, should be allowed in the sanitary sewer.

Please note that hazardous materials cannot be diluted with a material which is not a waste, e.g., fresh water, in order to bring them to concentration suitable for drain disposal, unless this dilution is part of an experimental procedure.

II. DISPOSAL OF OTHER LABORATORY WASTE

A. Classification of Waste and Disposal Procedures

Prior to disposal, non-chemical waste must be classified as one of the following:

• Sharps
• Biohazardous/Infectious Waste
• Uncontaminated Lab Waste

Wastes which contain both chemical waste and another type of waste, e.g., animal parts stored in formalin, must be separated and disposed of according to each pertinent waste policy. That is, the animal waste is treated as biohazardous waste and the formalin is disposed of as chemical waste.

In addition, local landfills no longer permit the University to dispose of any biohazardous waste (whether or not autoclaved) or SHARPS in the general trash. Thus, it is essential to classify waste properly. Safety Services is available for consultation on a case-by-case basis at 368-2907. A summary of the following "bag" policies is illustrated in Figure 4 (Disposal of Biohazardous Waste and General Laboratory Waste). For individuals in University Hospitals, contact Environmental Services at 844-3071 for information on disposal of biohazardous waste.

1) Sharps

Definition: Discarded hypodermic needles, syringes, and scalpel blades. Cannulas, coverslips, microscope slides, all pipettes (glass or plastic) and pipette tips, test tubes, or broken Petri dishes. Broken glass or any other item capable of causing puncture wounds or cuts.

Procedure: All sharps, whether contaminated or not, must be contained in puncture-proof containers. Call Security (x3333) for the disposal of all sharps.

• All contaminated sharps; needles, syringes and scalpel blades; and all materials designed for use in biological, etiological, bacteriological or tissue culture work must be placed in red rigid SHARPS containers. Call Purchasing (x2560) for a list of vendors.
• All other sharps (such as broken glassware) which are not contaminated may be discarded in red SHARPS containers OR in a cardboard box labeled "SHARPS." The box should be lined with a plastic bag to prevent leaking and sealed with tape. The box must be clearly labelled "SHARPS" so that anyone inspecting the box will be aware of the nature of the hazard. The box can then placed into a black or clear plastic garbage bag.
• Empty glass chemical bottles must be marked "MT," have their label defaced, and be placed in cardboard boxes marked "SHARPS" and sealed with tape. All bottle caps must be removed.

Hypodermic needles should not be recapped, clipped, broken or disassembled prior to disposal.

IMPORTANT: NO items that have been contaminated by chemotherapeutic drugs or antineoplastic agents (with the exception of trace amounts) can be disposed of in SHARPS containers. Please call Safety Services (x2907) for disposal alternatives.

For pick-up of RADIOACTIVE SHARPS, contact the Radiation Safety Office at 368-2906.

Under no circumstances are contaminated sharps; hypodermic needles, syringes, scalpel blades; or materials designed for use in biological, etiological, bacteriological or tissue culture work permitted to be disposed of in any container other than the red rigid SHARPS container.

2) Infectious waste

Definition: All infectious plastic Petri plates and plastic tissue culture vessels containing media, cultures and stocks of infectious agents, devices used to transfer, inoculate or mix such agents, and paper or cloth material contaminated with these agents.

Procedure: All of the above materials present a potential hazard to workers and must be treated prior to disposal. Treatment of this waste is the responsibility of EACH researcher.

Steam sterilization for the appropriate amount of time and at the proper temperature is the simplest, most effective method. STEAM STERILIZATION SHOULD BE CONDUCTED AS CLOSE TO THE POINT AND TIME OF WASTE GENERATION AS POSSIBLE.

All waste must be sterilized in red or orange biohazardous bags. All bags must be autoclavable and conspicuously labelled with the international biohazard symbol. Biohazard bags can be ordered from scientific supply houses.

After sterilization and cooling, these bags are to be denoted "sterilized" and tagged with the Primary Investigator's name and date of sterilization.

NO SHARPS (which includes glass and plastic pipettes) are permitted to be placed in these autoclaved bags or any other bag. Such sharps are a hazard when handling these bags and cause contaminants to leak from bags in transit. These must be disposed of in the red rigid SHARPS container as biohazardous sharps.

After all AUTOCLAVED BIOHAZARDOUS WASTE HAS BEEN APPROPRIATELY TAGGED, University safety technicians will remove the waste during the evening for incineration. All biohazardous bags must remain in the room/laboratory for evening pick up. Biohazardous waste must be disposed of expeditiously.

Liquid biomedical waste that has been treated to render it non-infectious should be poured down a sanitary drain, which should then be flushed with water.

EXCEPTIONS:

Most radioactive wastes as set forth in the University Radiation Safety and Control Program.

Any liquid biomedical waste which contains hazardous chemicals as set forth in the University Chemical Disposal Policy.

Please contact Safety Services (x2907) to receive disposal instructions for these exceptions.

3) General Uncontaminated Laboratory Waste

Definition: All laboratory waste which has not been contaminated by radioactive, chemical or infectious agents: such as petri plates, plastic tissue culture vessels, paper cloths, gloves , tubing, nonsharp laboratory wastes, EMPTY chemical containers, as well as "ordinary trash" such as computer paper, cardboard, packing material and the like.

Procedure: Pick-up is provided by cutodial services.

III. RADIOACTIVE WASTE DISPOSAL SERVICE

The Radiation Safety Office provides radioactive waste pickup and radiation disposal services for all University units. Typically, individual units collect radioactive wastes in suitable containers, label the material with a yellow radioactive waste tag, provide secondary packing if necessary, and call the Radiation Safety Office to arrange for a pick-up (368-2906).

IV. WASTE REDUCTION AND RECYCLING

Wastes regulated by the EPA are not permitted to be disposed of down the sanitary sewer or into a landfill, making them expensive to dispose of in an environmentally responsible way. Reducing the amount of hazardous waste produced, both before the experimental procedure and after, and recycling whenever possible provide vital means of controlling the amount of hazardous waste.

A. Waste Reduction Procedures

1) Pre-Experiment Techniques

a) Pre-weigh chemicals for undergraduate teaching labs. This will reduce spills and other wastes generated by students weighing their own materials.

b) Substitute less hazardous chemicals in experiments to reduce the cost of the disposal of hazardous chemicals. For example, use alcohol instead of benzene; use sodium hypochlorite instead of sodium dichromate.

c) Use alcohol or digital thermometers instead of mercury thermometers, which break easily and are extremely expensive to clean up and dispose of.

d) Purchase only what is needed. Do not order larger quantities to take advantage of unit cost savingsÛdisposal costs down the road for the unused portion of the chemical greatly exceeds the initial savings. CWRUÌs chemical store sells chemicals in smaller quantities at bulk prices to facilitate waste minimization in individual laboratories.

2) Post-Experiment Techniques

1) When cleaning with solvents, use spent solvent for the initial cleaning and use fresh solvent only for the final rinse.

2) Destroy wastes as part of the last step of the experiment if possible, provided the result is not a regulated material (call Safety Services to confirm). Such end-procedure neutralization techniques include oxidation-reduction or precipitation and filtration of solids.

3) Label all containers, new or temporary, with the proper information, even if the solutions they contain are innocuous. Disposing of an ÏunknownÓ waste, which is what materials in unlabeled containers often become, requires time-consuming and costly analysis. In addition, unknowns are dangerous in that they may explode or cause adverse reactions at any time.

B. Recycling Procedures

Safety Services now has a still that can recycle many would-be waste solvents to near-pure form. Call our department (x2907) to see if your department creates such reusable waste. Acetone, for example, is ideal. We have also recycled xylene and ethanol with success.