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The Hazardous Waste Management Program, overseen by the Office of Research Compliance – Lab Safety, provides guidelines and procedures for the proper management, disposal, and shipment of hazardous waste generated at the University of Texas at Dallas (UTD). Each laboratory employee must comply with the campus Hazardous Waste Management Program requirements and all applicable regulations. A regular pick-up service is provided to all research buildings on campus. Laboratory personnel are responsible for identifying waste, labeling it, storing it properly in the laboratory, and requesting timely waste removal. Laboratory clean-outs and disposal of high hazard compounds must be scheduled at least 2 weeks in advance. The PI/Laboratory Supervisor is responsible for coordinating the disposal of all chemicals from his/her laboratories prior to closing down laboratory operations.
Regulation of Hazardous Waste
The disposal of regulated waste and other unwanted chemicals has become increasingly complicated. The Texas Commission on Environmental Quality (TCEQ; Title 30 of the Texas Administration Code, Chapter 335) and the Texas Department of State and Health Services (DSHS) regulate the treatment and disposal of chemical wastes in Texas.
Federal Agencies, [the U.S. Department of Transportation (USDOT) and the U.S. Environmental Protection Agency (EPA) under the Resource and Conservation and Recovery Act (RCRA)], also govern some aspects of hazardous waste management.
Definition of Hazardous Waste
Federal and State regulations define hazardous wastes as a substance which poses a hazard to human health or the environment when improperly managed. A chemical waste is considered hazardous if it is either listed on one of the lists found in Federal or State regulations or if it exhibits one or more of the following four hazardous characteristics:
Extremely Hazardous Waste
Certain compounds meet an additional definition known as “extremely hazardous waste”. This list of compounds includes carcinogens, pesticides, and reactive compounds, among others (e.g., cyanides, sodium azide, and hydrofluoric acid). The Federal EPA refers to this waste as “acutely hazardous waste.”
Proper Hazardous Waste Management
All personnel who are responsible for handling, managing, or disposing of hazardous waste must complete training prior to working with these materials. View the UTD Laboratory Safety Training Matrix [[https://research.utdallas.edu/orc/lab-safety/laboratory-safety-training-matrix] for a listing of all offered courses and requirements.
All training courses are accessible through the Laboratory Management System (BioRAFT). A NetID and registration with a UTD research laboratory is required for access. If you are visiting a campus lab or do not have a NetID, please contact firstname.lastname@example.org for a temporary account.
All the chemical constituents in each hazardous waste stream must be accurately identified by knowledgeable laboratory personnel. This is a critical safety issue for both laboratory employees and the waste technicians that handle the waste once it is turned over to the Lab Safety Team. Mixing of incompatible waste streams has the potential to create violent reactions and is a common cause of laboratory accidents. If there is uncertainty about the composition of a waste stream resulting from an experimental process, laboratory workers must consult the PI/Laboratory Supervisor or Safety Specialist. In most cases, careful documentation and review of all chemical products used in the experimental protocol will result in accurate waste stream characterization.
Labeling Chemical Containers
Label all hazardous waste at the start of generation with the contents and any associated hazards. University labeling requirements and guidelines include the following:
- Inspect waste containers to ensure that containers have legible labels, are compatible with the generated waste stream, are and have secure closures;
- Clearly spell out the name of the each chemical component on the label. Do not use molecular formulas as sole identification;
- If the container contains a carcinogen or infectious agent, it must also be noted on the container; and
- Any labels which are incorrect should be defaced/marked through and replaced with accurate labels.
The hazardous waste storage area in each laboratory is considered a Satellite Accumulation Area (SAA) by the EPA. According to EPA requirements, this area must remain under the control of the persons producing the waste. This means that it should be located in an area that is supervised and is not accessible to the public. Other SAA requirements include:
- Hazardous waste containers must be labeled with an hazardous waste label at all times;
- Waste must be collected and stored at or near the point of generation. Additional SAA sites may be necessary to prevent undue transport of hazardous waste;
- According to State and Federal law, the maximum amount of waste that can be stored in a SAA is 55 gallons of a hazardous waste or 1 liter of extremely hazardous waste. If you reach these volumes for a specific waste stream, you must dispose of the waste within 3 days;
- All hazardous waste containers in the laboratory must be closed at all times, unless waste is actively being added;
- Hazardous waste streams must contain only compatible constituents, and must be compatible with the containers that they are stored in;
- Hazardous waste containers must be stored in secondary containment at all times;
- Containers must be in good condition with leak proof lids;
- Containers must be less than 2/3rd full; and
- Dry wastes must be bagged in a yellow plastic bag and placed in an appropriate container with a lid (these do not require secondary containment).
The disposal of laboratory wastes (chemical – hazardous and non-hazardous, radioactive, biohazardous, or unwanted materials including Universal wastes) has become more complex and expensive as regulations have become more stringent. Laboratory personnel are responsible for identifying and labeling waste generated in the laboratory, and storing it safely until it is removed for disposal. ORC Lab Safety is responsible for the transfer of hazardous wastes from laboratories to UTD’s Hazardous Materials Facility for treatment and/or packaging prior to shipment to off-site disposal facilities.
Frequent disposal will ensure that waste accumulation areas in labs are managed properly, and that maximum storage volumes are not exceeded. UTD policy states that hazardous chemical waste can be stored in a laboratory for up to 90 days. Once a waste container is 2/3 full or it is near the 90 day time limit, it should be scheduled for pick-up. Once an experiment or process is completed, all partially filled containers should be scheduled for pick-up.
To ensure that the collection and removal of laboratory wastes are performed safely and in an organized manner, certain procedures are to be followed:
- All laboratory personnel should be familiar with the UTD hazardous waste disposal procedures;
- All waste containers must be properly segregated, clearly labeled to identify contents, hazards, start date, and other pertinent information;
- Waste materials are not allowed to accumulate excessively in the laboratory and in no case, should be allowed to accumulate longer than 90 days;
- Needles and broken glassware are to be segregated in appropriately labeled containers away from other waste;
- Chemicals are prohibited from being disposed of through the sanitary sewer system; and
- Consult with the University’s Chemical Hygiene Officer or Hazardous Waste Manager for guidelines on disposing of chemicals requiring special consideration (i.e. chemicals that have become hazardous or unstable due to age).
Wastes Acceptable for Standard Pick-Up
- Liquid waste in suitable containers that are clean, free of contamination, and have a leak proof cap;
- Dry and/or solid waste that is in a suitable container, free of contamination, and properly sealed;
- Chemical contaminated sharps (with no infectious or biohazardous contamination) in a rigid sharps container;
- Treated infectious waste streams or deactivated biological agents that are mixed with chemical wastes; and
Wastes Unacceptable for Standard Pick-Up
- Radioactive Waste;
- Controlled Substances;
- Reactive waste streams without a properly vented cap, or containers that are bulging, fuming, or bubbling;
- Leaking, overflowing, or contaminated containers, or containers that are compromised;
- Wastes that require special handling procedures or have shipping restrictions; and
- Waste streams in incompatible containers.
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