SAA Guidance

The purpose of this document is to provide additional regulatory guidance for establishing laboratory hazardous waste accumulation areas in accordance with federal environmental regulations and state and local fire code.

  • The EPA requires that all hazardous waste be stored in a Satellite Accumulation Areas (SAA) per 40 CFR 262.15
  • Massachusetts State Fire Code states that chemicals and hazardous waste shall not be stored in fume hoods, per NFPA 45 Chapter 8.3.4.7.
  • Fire code requires that a fume hood be used when transferring flammable or toxic chemical waste to a waste accumulation container.

To comply with these regulations, BU laboratories can establish short-term, in-hood SAAs for daily hazardous waste handling and permanent, outside hood SAAs for overnight and longer-term waste storage.

  • In hood Satellite Accumulation Areas:
    1. Shall be established only for short-term use when transferring flammable or toxic waste to a hazardous waste container to prevent exposure to hazardous chemicals.
    2. Transfer all hazardous waste containers to permanent SAAs located elsewhere in the laboratory at end of task or daily operations. No chemicals or waste shall remain in hood overnight.
    3. SAA signage and empty secondary containment may remain permanently within the hood.
    4. Waste container movement considerations to reduce risk of spills, injuries, and exposures:
      • Remove funnels and tightly close lids before transferring waste containers between SAAs.
      • Carboys full of dense liquids like acids, bases, and solvents can weigh > 50-lbs when full and are unwieldy to move into and out of fume hoods. Consider placing waste pick-up request when carboy is ⅓ to ½ full if lab staff are uncomfortable lifting 50 pounds.
  • Permanent / overnight Satellite Accumulation Areas:
    1. Establish following all SAA regulatory requirements per BU’s Chemical Hygiene Plan
    2. Shall be outside of the fume hood
    3. Shall not be in an under-sink cabinet
    4. Can be:
      • In flammable cabinets – required for all ignitable chemicals not in safety cans
      • In secondary bins under laboratory benches
      • On open un-used counter space
      • On a lab cart
      • In chemical storage closets
      • Laboratory floor spaces not posing a tripping, egress, or obstruction hazard
    5. Clearly delineate SAAs in chemical cabinets and closets from the general chemical storage. This will help prevent environmental regulators misidentifying virgin chemicals as waste.
      • Post SAA signage on exterior of cabinet door AND either:
    6. All flammable chemical waste must be in flammable cabinet SAA or accumulated in a solvent safety can.
      • No corrosive (acidic or caustic materials) in solvent safety cans.
  • Instrument and Fixed Equipment Satellite Accumulation Areas
    1. Instrument waste requires closed system
      • NOTE: Laboratories are responsible for purchasing their own closed system waste containers and/or caps.
  • SAA Resources
    1. SAA supplies are available through the comments section of the SciSure (formerly SciShield) Hazardous Waste Pick Up Request Page
    2. SAA Signage – for printing and posting in your SAA