Dangerous Waste Management
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- Appendix A: Chemical Collection Request (CCR) Form 16
- Appendix B: Central Waste Accumulation Area (CWAA) Inspection Form 17
- Appendix C: Shipment Checklist 20
The following plan provides information on requirements for the management of hazardous waste. The proper management of hazardous waste is necessary to ensure good stewardship of the environment, to protect WSU from unwanted citations and fines from regulatory agencies, reduce liabilities, to ensure safety of employees, students, volunteers, and visitors, and to reduce disposal costs. This plan applies to maintenance activities, laboratories, offices, grounds, and field activities performed by employees, students, volunteers, or visitors.
D. Hazardous Waste Designation
The Washington State Department of Ecology (Ecology) regulates hazardous wastes for the State of Washington. “Hazardous” wastes are termed “Dangerous” by Ecology. When a waste material is generated, it must be determined if it is a dangerous waste to dispose of it in a proper manner. Waste designation is important, as many chemicals may appear non-hazardous, especially those at low concentrations, which could be regulated as dangerous waste in the State of Washington. Be aware that waste disposal recommendations found in Material Safety Data Sheets, books and researcher’s publications that describe waste disposal procedures may not apply in the State of Washington. The following list identifies common materials that often must be collected and managed as dangerous waste.
- Most laboratory chemicals, their mixtures, and solutions. Even very dilute solutions may require management as dangerous waste;
- Expired chemicals that no longer have a use;
- Pesticides, herbicides, paints, automotive and maintenance wastes; and,
- Oils, cleaning wastes, batteries, all fluorescent light bulbs/tubes, aerosol cans, and electronics.
There are two ways to designate your waste.
- Designate the waste yourself, using information provided on the WSU EHS web site.
- Request an EHS representative designate the waste.
It is very helpful to have the following information available for the designator:
- All chemical and non-chemical (contaminated paper, plastic, etc.) constituents and their estimated or known concentrations, including water;
- If material being disposed has a trade name, the actual chemical names of the ingredients are needed;
- If it is corrosive, the pH is helpful;
- Safety Data Sheet (SDS).
E. Pollution Prevention
It is recommended to work with an EHS representative before generating waste. This will allow time for possible substitution of chemicals or procedures to reduce or eliminate waste generation. EHS will advise on ways to containerize the waste to reduce disposal costs.
It is also recommended that WSU units do not accept chemical donations or order chemical products in bulk to keep chemical inventories and wastes to a minimum.
Return pesticides, including experimental pesticides, to the vendor when projects are finished.
F. Labeling Hazardous Waste
Ecology refers to hazardous waste as Dangerous Waste; thus, labels follow the Ecology’s regulations using the word Dangerous Waste. Dangerous waste labels may be obtained from an EHS representative, hazardous waste coordinator, or the EHS website. An example of a waste label is provided below.
The following information must be on the label:
- The words Dangerous Waste;
- The proper chemical name and known or estimated percentages;
- Do no use chemical formulae, abbreviations, or trade names.
- Include water and its percentage if present.
- Primary hazard of the waste e.g., flammable, corrosive, poison;
- The date that the waste container is physically moved to the Centralized Waste Accumulation Area (the CWAA Date);
- The CCR number (see Section H);
- Building, room number and contact phone number should also be on the label.
The waste container must be labeled when waste is first added to the container. All other labels, such as manufacturer’s labels must be defaced or removed.
G. Hazardous Waste Containers and Accumulation
Satellite Accumulations Area (SAA) Procedures
These procedures are for the accumulation of hazardous waste in the area where they are generated. Each laboratory, program, or department may accumulate hazardous waste under specific conditions in a designated area under their control. This area is called the Satellite Accumulation Area (SAA).
The following are the specific conditions:
- Waste containers may be accumulated in a designated area at the location of generation. The area must be secured when not occupied.
- Select a waste container that is compatible with the waste material.
- The container must be in good condition, clean outside, and must have a tight fighting cap. Do not use ground glass, cork, or rubber stoppers, parafilm, or snap cap lids.
- Label the waste container before the first waste is added (see Section F).
- Waste containers must be closed at all times except when adding waste or removing waste.
- Do not overfill containers, leave 2-3 inches of head space to allow for expansion.
- Do not mix wastes in the same container unless directed by an EHS representative.
- Do not store incompatible waste containers together. Separate them using secondary containment (plastic tubs) or by distance, and store solids above liquids where possible.
Hazardous waste must be removed from the SAA to the Central Waste Accumulation Area (CWAA) within 3 days when any of the following occurs:
- A waste container is full.
- A waste will no longer be generated.
- A chemical will not be used again.
- An unknown chemical is discovered.
- More than 2.2 pounds of an Acutely Hazardous Waste (see EHS website for list, ehs.wsu.edu ) or 55 gallons of waste has accumulated in the SAA.
After any of the above scenarios, a fill date should be written on the label and the generator shall complete an online Chemical Collection Request (CCR) Form. The form can be found at http://www.ehs.wsu.edu/ccr/ccr.html. This link provides step by step instructions. Once the submit button has been selected electronic copies will be sent to the EHS representative. Print a copy of the CCR (see Section H) and arrange a time with the Hazardous Waste Coordinator (HWC) to transfer the waste container to the CWAA.
H. Chemical Collection Request (CCR) Form
When a container is ready to be transferred (see Section G) from the Satellite Accumulation Area (SAA) to the Central Waste Accumulation Area (CWAA), a CCR must be completed. Listed below are the step-by-step instructions for filling out a CCR. The form can be found at http://www.ehs.wsu.edu/ccr/ccr.html. A sample CCR is provided in Appendix A.
- Generator Information includes:
Name of generator, contact phone number, mail stop, building, room number, email, and waste location (pull down menu of the different WSU locations).
- Constituents and Percentages:
List all chemical constituents and their estimated or known concentrations, including water. If material being disposed has a trade name, the actual chemical names of the ingredients are needed. Click on the “Add This Constituent/ Percentage” button after each constituent and percentage/estimated percentage are entered. This section should match the information listed on the Dangerous Waste label and add up to 100%.
- Physical State:
Check the appropriate box; solid, liquid or gas.
- Number of containers:
List the number of containers that have the same constituents.
Type the container’s size and use the pull-down menu to select appropriate units.
- Major Hazard:
Check the appropriate box e.g., flammable, corrosive, or poison. This should match the information listed on the Dangerous Waste label.
- Secondary Hazard:
Check appropriate box or boxes. It is not required to have any secondary hazards, but you can have more than one.
- Additional information:
Please type in any information that could affect how a container is managed or handled.
Once all the fields have been filled, either select “Proceed to Data Verification” or “Clear Form”. “Proceed to Data Verification” allows the generator to verify information before electronically submitting to the EHS representative. After reviewing information the generator can either “submit”, “submit and enter another”, or “edit form”.
Once submitted, the generator will receive an electronic verification that EHS has received the CCR. A unique CCR number will automatically be produced for the form. This number should be written on the corresponding space on the Dangerous Waste label. Alternatively, print out a copy of the CCR generated label and affix it to the waste container(s). Print out a copy of the CCR generated label for the HWC’s records.
I. Central Waste Accumulation Area (CWAA) procedures
The cabinets inside the CWAA storage room are labeled with hazards: flammable, corrosive acid, corrosive base, toxic, and reactive that will match provided segregation information. The HWC and generator will arrange a time when they can deliver the container to the CWAA. The generator will transport the properly labeled (see Section E) waste container to the CWAA. For transport, place the waste containers in secondary containment trays/buckets and segregate incompatible materials. The HWC will verify that the label matches the corresponding CCR submission.
Waste storage times for the CWAA may vary depending on the quantity and type of waste generated and stored at the WSU unit. Waste storage periods allowed by the Ecology will fall into a category of 90 day, 180 day, or longer under some circumstances. An EHS representative will help make this determination and arrange disposal through an approved hazardous waste vendor accordingly.
J. Hazardous Waste Coordinator’s Responsibilities
The WSU unit must appoint and an EHS liaison and must train a Hazardous Waste Coordinator (HWC) to properly manage the handling and storage of hazardous waste. The Washington State Department of Ecology requires initial training as well as annual refreshers. The HWC must be trained on the following duties:
- Upon receipt of a Chemical Collection Request (CCR) form and segregation information from the generator, the Hazardous Waste Coordinator (HWC) will arrange a time for the waste generator to transfer the containers to the CWAA.
- When transferring the waste the HWC and the generator will, at the minimum, wear the following personal protection equipment (PPE): safety eye wear and disposable nitrile gloves. Depending on specific conditions other PPE may be required.
- Before accepting the container from the generator the HWC should assess each container for integrity, compatibility with waste, proper labeling, container transfer date (the CWAA date), tightly secured lids, contamination on the outside of the container, and reasonable head space.
- Carry a cell phone or radio during waste transfer if there isn’t a phone or fire pull station in the CWAA, in case of an emergency.
- Place each container in proper CWAA cabinet/shelf labeled for its hazard classification. Place solids on the upper shelves and liquids on lower shelves when possible.
- The 90-day or 180-day clock (if applicable) begins once the first container of hazardous waste is placed in the CWAA. EHS will determine storage restrictions and schedule waste shipments accordingly.
- Maintain a CWAA Hazardous Waste inventory notebook by placing completed CCRs into the notebook.
- Perform a weekly inspection of the CWAA (see Section K) when there is waste in the CWAA, and maintain the inspection records.
K. Central Waste Accumulation Area (CWAA) Inspections
The HWC must maintain a weekly inspection schedule for the CWAA when hazardous wastes are present using the “CWAA Inspection” form and detailed instructions found in Appendix B. If a discrepancy is found mark a “D” for that item and explain the discrepancy in the section at the bottom of the inspection form. The date, time, and name of inspector printed and signed must be on the form.
When a discrepancy is noted during an inspection, the HWC contacts whoever is responsible for correcting the situation and notifies them of the problem. When corrected, note the date, corrective action and initial next to the original discrepancy note. If during an inspection, there is an outstanding discrepancy noted, follow up on the status and note, if appropriate, on the inspection form.
The inspection forms must be retained for three years.
L. Hazardous Waste Disposal Shipment Procedure
The EHS representative will arrange all shipments with contractors and be the main point of contact for the HWC and the contractor. The following steps should be taken by the EHS representative.
- The EHS representative should schedule a hazardous waste shipment with an approved disposal contractor. The scheduled shipment date should be at least one week prior to the 90-day or 180-day storage limit (if applicable) to allow for emergencies.
- Approximately 1 month prior to a waste shipment an EHS representative should contact the site HWC and notify them of the shipment date.
- The HWC will notify the sites waste generators of the upcoming hazardous waste shipment date and request submittals of CCR’s for all wastes needing disposal not already in the CWAA. Half full containers should be submitted for disposal. CCR’s should be submitted two weeks prior to the shipment date.
- One week prior to shipment the EHS representative should submit a rough inventory to the waste contractor.
- Prior to the shipment the HWC should meet with the EHS representative showing location of all hazardous waste to be disposed.
- The EHS representative needs to provide the contractor with access to the CWAA. The representative should also familiarize the contractor with the location of the nearest phone, emergency shower and eye wash unit, and fire extinguisher.
- The EHS representative needs to ensure that the contractor:
- Knows which waste containers are being disposed.
- Only package containers that have a CCR number on them. If no ID number is present, bring this to the attention of the HWC who can locate the generator to complete a CCR for the container.
- Writes the CCR number on the contractor’s drum inventory sheet.
- Write the estimated weight of each container on the drum inventory sheet.
- Write the Washington State and EPA hazardous waste codes on the drum inventory sheets.
- EHS representative should inspect the waste storage cabinets and area to make sure all wastes have been packaged and no waste spilled.
- Use the Shipment Checklist (Appendix C) to: inspect drums, labeling of containers and truck, review manifesting paperwork for accuracy, and sign the paperwork. The EHS representative is the only person authorized to sign the manifest and other shipping paperwork. Ensure each checklist task or item is completed before the contractor leaves.
- The waste shipment’s original copies of manifesting paperwork, shipment checklist, contractor’s time and materials sheet, and CCRs should be placed in a file dated for the shipment and placed in the WSU location’s central hazardous waste file. The EHS representative should retain a copy of all shipment paperwork.
- The EHS representative will ensure that the HWC receives within 45 days an original copy of the manifest signed by the receiving facility. The HWC should place the original manifest with the other shipment paperwork that is stored in the central hazardous waste file.
M. Hazardous Waste Recordkeeping
A central hazardous waste file must be established at each WSU location. This file should contain the following:
- Manifest paperwork for each waste shipment, including the signed returned manifest and certificate of disposal (CD)
- Annual Dangerous Waste reports
- Exception reports
- Analytical data/testing for any waste
- Chemical Collection Request (CCR) forms for wastes shipped for disposal
- CWAA inspection records
- Training records for HWC
Hazardous waste manifest and shipment records must, by WSU policy, be retained on site indefinitely.
Recycled materials such as, waste oil, Universal Waste shipment records, and pesticide redistribution records also need to be kept on file indefinitely.
An EHS representative will audit the files annually to ensure completeness.
Hazardous waste management requires varying levels and forms of training depending on the individual’s tasks and responsibilities.
- Waste Generator: Trained in the proper waste handling procedures. This would include: container selection and labeling, satellite accumulation procedure, emergency procedures, waste reporting and record keeping. Individuals should also be familiar with all components of their Lab Safety Manual and/or Hazard Communication Program.
- Hazardous Waste Coordinator (HWC): Trained in the proper waste handling procedures and HWC duties. These would include: waste collection procedures, container labeling, CWAA procedures, CWAA inspections, emergency procedures, and record keeping. Individuals should also be familiar with all components of their Lab Safety Manual and/or Hazard Communication Program.
- EHS Representative: Trained in the proper waste handling procedures and EHS representative duties. These would include: waste designation, container selection and labeling, satellite accumulation storage procedures, waste reporting and record keeping, CWAA procedures, emergency response procedures, pertinent State of Washington Department of Ecology regulations and pertinent U.S. Department of Transportation regulations. Must also maintain US DOT Hazmat Employee training.
O. Universal Waste (Light Bulbs/Tubes, Batteries, Used Oil, Computer Waste)
Ecology regulates specific wastes as Universal Waste. If a facility chooses to manage waste under the Universal Waste regulations that material must be recycled with an approved vendor. Materials that WSU handles as Universal Waste are listed below, along with the specific waste management procedures.
Compact fluorescent lamps (CFL), high intensity discharge (HID) and high pressure sodium (HPS) bulbs and fluorescent light tubes (FLT) must be collected for proper recycling. The CFL should be collected in separate boxes than the HID and HPS if possible. The FLT should also be collected in separate boxes from the other bulbs.
Burnt out CFL, HID, and HPS should be placed into the individual package the replacement bulb is supplied in. If this is not available, they should be placed in packaging (e.g. put it a small box, placed in bubble wrap, placed in a re-sealable bag) to prevent breakage. FLT should be placed in the boxes the new replacement bulbs come in or in boxes provided by Ecolights Northwest (WA State contract) or EHS. Typically, the tines are bent slightly to distinguish old tubes from new tubes.
Packaged CFL, HID, HPS and FLT should be placed into appropriately labeled collection boxes. Collection boxes must be labeled with the words “Used Lamps”, “Universal Waste Lamps”, or “Waste Lamps”, and the date the first lamp is placed into the box. For CFL, HID and HPS, plastic liners should be used in the boxes to help contain the contents should the bulbs break. Collection boxes must be kept taped shut except when adding or removing waste. Any box that can be taped shut and has integrity may be used for the collection of CFL, HID, HPS and FLT.
In the case a CFL, HID, HPS or FLT is broken, staff must be trained to use appropriate personal protective equipment when cleaning up the tube. Staff must also be trained on how to properly clean up, contain and dispose of broken CFL, HID, and HPS.
- Protective equipment: Normal work attire with disposable gloves
- Sweep broken glass, lamp components, and lamp phosphor (the white powder inside) up and place into a plastic bag. A damp towel may be used to clean up remaining phosphor. Place any damp towels and used gloves into the plastic bag. Do not vacuum up the debris.
- The properly filled out Dangerous Waste label should be attached to the bag and a CCR submitted.
- The properly labeled bag should be taken to the CWAA where it can be sent out for proper disposal
Collection boxes must be kept in areas under the control of trained staff (i.e. mechanical rooms, storage rooms, janitorial closets, etc.) that are locked. The public should not have access to collection boxes unless a trained staff member is present.
Staff who will place CFL, HID, HPS or FLT into collection boxes must be trained to observe the above procedures. This is all the training that is required.
Once collection boxes are removed from the original building, they need to be stored in a weather-protected, locked enclosure until they are shipped off-site for recycling.
Collection boxes must be completely emptied or removed at least once each year. This should occur in time to allow the CFL, HID, HPS and FLT to be shipped off-site (to the recycler) prior to one year from the date the first CFL, HID, HPS and FLT was placed in the box. Environmental Health and Safety (EHS) coordinates all shipments with WSU approved recycling contractors.
All types of used batteries must be collected and recycled. Different types of batteries that are collected include:
- Carbon Zinc
- Lead Acid
- Lithium and Lithium Ion Silver Oxide
- Nickel Cadmium
- Nickel Iron
- Nickel Metal Hydride
- Nickel Zinc
- Sodium Chloride
In order to comply with state and federal environmental regulations the batteries must be managed as Universal Waste. They must be collected in properly labeled containers in designated areas. The container shall remain closed unless a battery is being added. The attached label must say one of the following: Universal Waste – Batteries, Waste Batteries, or Used Batteries and have the accumulation start date (date the first battery was placed in the container). A trained employee periodically checks containers to verify container labeling and ensure guidelines are followed. When the containers are full or prior to one year from the accumulation start date, the batteries must be prepared for shipment.
Prior to shipment batteries must be sorted by type and placed separately into properly labeled, sealed containers. Terminals for all batteries, except alkaline and carbon zinc, must be taped. The containers are recycled using Washington State University approved recyclers. EHS coordinates all shipments.
Used oil not contaminated with other chemicals is eligible for recycling and management under the Universal Waste guidelines. Used oil is collected in 55 gallon steel and poly drums or larger totes. The containers must meet the following requirements:
- Have the words “Used Oil” written on the container
- Container closed, except when adding or removing used oil
- Container stored inside or under cover
- If contaminated, manage the oil mixture as Dangerous Waste
An approved oil contractor periodically collects the used oil for recycling. A WSU employee must be present during transfer, sign the bill of lading, and ensure safe oil transfer practices are followed. Place the Bill of Lading in the hazardous waste shipment records file cabinet.
Unwanted computers, computer components and other electronic equipment (printers, faxes, etc.), known as “e-waste”, are collected for surplus or recycling. While items are waiting to be surplused or recycled, follow the labeling and storage procedures below.
- Older computer monitors (e.g. not flat screen) must be labeled with an accumulation start date, and the words “used cathode ray tubes – contains leaded glass” and “do not mix with other glass materials”.
- Additional computer components and electronic equipment must be labeled with an accumulation start date, and the words “do not mix with other glass material” and “used electronic products-contains circuit boards”.
- Computer monitors, computer components and other electronic equipment must be stored inside or under cover from weather/precipitation.
- If an electronic component is broken during collection or storage, WSU personnel should clean up the debris using a broom and dustpan. The solids are placed in a bag and the sealed bag is treated as Dangerous Waste (see Section F).
Departments wanting to surplus or recycle e-waste start by submitting a request to WSU-Pullman Surplus Stores. Instructions and the on-line surplus request form are located at: http://facops.wsu.edu/Surplus/sur_disposal.htm#Computer_Hard_Drive_Destruction . After completing and submitting the on-line surplus form, WSU-Pullman Surplus Stores staff will arrange for picking up the e-waste (Pullman and Whitman County) or evaluate whether there is enough value to warrant shipping the e-waste to Pullman from outside Whitman County. For WSU facilities outside of Whitman county (and particularly west of the Cascade Mountains) there is typically not enough value so WSU-Pullman Surplus Stores will do the paperwork to transfer the e-waste to the State of Washington Surplus. WA Surplus will then contact the WSU representative (the person who originally completed the on-line WSU surplus form) to make arrangements to pick up the e-waste and take it to their main surplus facility for processing. There is no fee for this procedure. If you have any questions regarding e-waste surplus/recycling contact WSU-Pullman waste management at firstname.lastname@example.org or 509-335-4630.
For e-waste with hard drives that are being transported to WSU-Pullman Surplus Stores there is no need to swipe (permanently erase) hard drives. WSU-Pullman Surplus Stores erases hard drives as part of their surplus service. For hard drives going to WA Surplus each department is responsible for swiping/erasing their hard drives (or rendering them unreadable by physically damaging them) to ensure that no sensitive information is released. If the department doesn’t have the ability to swipe hard drives, the hard drives can be removed and mailed to WSU-Pullman Surplus Stores who will provide the service at no charge.
P. Facilities Operations/Maintenance Wastes
Maintenance activities such as vehicle and equipment repair, painting, pesticide applications, construction projects may generate wastes, several of which may be regulated as dangerous waste. Dangerous wastes created by maintenance activities must be managed as stated in this procedure. Never dispose of shop fluids via storm drain, septic tank, dry well, dumpster, or sewer.
Specific handling procedures apply to spent materials for them to qualify as recyclable materials, see Section O for guidance. Keep waste streams separated when collecting for disposal or recycling. Fluids that become contaminated with chlorinated products, solvents, and metal working fluids must be treated as dangerous waste. Do not pour these wastes into the Used Oil containers. Only trained and authorized staff should place fluids into recycle/waste containers.
Some material does not designate as Universal Waste or Dangerous Waste, but still should be recycled. Following is a list of common materials used in maintenance and how they should be handled. When feasible, recycling, in lieu of disposal, is a more cost effective and environmentally friendly option for handling spent materials. Recycling records must be maintained with hazardous waste files (file all bills of lading).
Pesticides, research, experimental or otherwise, provided to WSU by manufacturers, distributors, or field representatives need to be returned to the supplier when projects are finished. This practice saves the university money and storage room, and prevents unnecessary waste generation. Suggestions for carrying this out are as follows:
- Have a written agreement with the supplier, before receiving the material that commits the supplier to take back the unused material at the end of the spray season or research project. Work out return logistics before accepting the pesticide.
- A suggestion to help encourage company representatives to pick up the surplus materials is to dedicate a set of shelves in the pesticide storage building where returns are placed. Label shelves by company. When company representatives come to visit, they learn over time to check these shelves for return pesticides. This then becomes a service that representatives can provide.
- Mailing Pesticides: Mail back pesticides in the same shipping containers they were sent in (requires the containers be saved). If pesticide is mailed, have the company confirm and/or provide the necessary shipping labels, hazard labels, bill of lading, and packaging. DO NOT mail improperly packaged or labeled pesticides as large monetary fines may be issued when hazardous materials are not packaged per DOT shipping regulations. For assistance with shipping hazardous materials contact the WSU Office of Research Assurances at 509-335-7183.
- Only receive/accept the pesticide quantities needed for the season. Calculate closely how much material is needed and request suppliers repackage pesticides to provide only that amount. Arrange for suppliers to send additional small amounts of product, if the initial estimates prove inadequate.
- Coordinate with EHS to dispose unwanted/outdated pesticides through the Washington State Department of Agriculture pesticide disposal program.
- Donate registered pesticides (not experimental). Unused pesticides that are registered can sometimes be used by local growers. In order for this to happen:
- Use WSU extension agents familiar with various growers and grower commodity groups as the go-between in locating growers able to take WSU’s unused pesticides.
- Only distribute pesticide(s) to a person who is a licensed pesticide applicator that will use the pesticide only on crops delineated on the label.
- The WSU employee donating a pesticide must validate and record in writing the name of the person the pesticide was donated to, their applicator’s license number, and the intended pesticide use. Record and maintain this information in a pesticide redistribution file. Store this file with the location’s other waste records.
- The unused pesticide must be redistributed in a timely manner so it can be applied by the grower while the pesticide is not expired. For example, some pesticides, if over-wintered, can freeze causing them to be unusable and a disposal problem for the grower.