Chemical Waste Management Guide

Chemicals on the Massachusetts toxic list:
Waste Oil Any amount (excluding animal/vegetable origin)
PCBs 50 mg/l (note: we should collect PCBs at any concentration)

Listed Hazardous Wastes

The chemical waste regulations have a series of lists which spell out some specific chemicals which should be collected as hazardous waste.

The F List

The “F List” specifies some commonly-generated chemical wastes at specific concentrations that must be collected. The entire list can be seen here http://www.epa.gov/waste/hazard/wastetypes/listed.htm, but for laboratory purposes the following chemicals are of particular importance.

• Any dioxin waste
• Any waste with any combination of the following halogenated solvents at a concentration of 10% or more by volume before use (these wastes are toxic):
  • Tetrachloroethylene
  • Methylene Chloride
  • Trichloroethylene
  • 1,1,1-trichloroethane
  • Chlorobenzene
  • 1,1,2-trichloro-1,2,2-trifluoroethane
  • Orthodichlorobenzene
  • 1,1,2-trichloroethane
  • Carbon tetrachloride
  • Any chlorinated fluorocarbons
• Any waste with any of the following non-halogenated solvents at a concentration of 10% or more by volume (these wastes are ignitable except as indicated below):
  • Xylene
  • Acetone
  • Ethyl acetate
  • Ethyl benzene
  • Ethyl ether
  • Methyl isobutyl ketone
  • N-butyl alcohol
  • Cyclohexanone
  • Methanol
  • Cresols (toxic)
  • Cresylic acid (toxic)
  • Nitrobenzene (toxic)
  • Toluene (ignitable and toxic)
  • Methyl Ethyl Ketone (ignitable and toxic)
  • Carbon disulfide (ignitable and toxic)
  • Isobutanol (ignitable and toxic)
  • Pyridine (ignitable and toxic)
  • Benzene (ignitable and toxic)
  • 2-ethoxyethanol (ignitable and toxic)
  • 2-nitropropane (ignitable and toxic)

Note that the concentration limit here is ‘before use’ – this is to prevent a person from using a solvent, mixing it with water during use, and then claiming that the resulting waste is not hazardous. If you have questions about the status of your solvent waste contact EHS.

The U List

The ‘U List’ technically only applies to un-used chemicals that become wastes (expired, spilled, or no longer necessary for a laboratory’s experimentation). However, it is best practice to collect as hazardous wastes any laboratory waste stream which contains a chemical present on the list. Contact EHS if you have any questions about the applicability of the U List to your chemical wastes.

The full list of U wastes is included as Appendix A to this document.

The P List

The EPA has a list of chemicals which are considered ‘acutely’ hazardous when disposed of. Like the U List, the P List technically only applies to chemicals which are un-used when they become wastes. Again, however, it is best practice to collect as hazardous waste any waste stream which contains a chemical on the list.

In addition, the empty containers which once held ‘P-listed’ materials must be handled as hazardous wastes themselves.

The most common laboratory chemicals found on the P List are:

• Acrolein
• Allyl alcohol
• Carbon Disulfide
• 2,4, Dinitrophenol
• Nitric oxide
• Nitrogen dioxide
• p-Nitroaniline
• Osmium Tetroxide
• Phosgene
• Phosphine
• Sodium Azide
• Vanadium pentoxide

The full list is included as Appendix B to this document.

Satellite Accumulation Areas

The next step after classifying hazardous chemical wastes is accumulating them in ‘satellite accumulation areas’ (SAA). These are areas where hazardous wastes that are generated as part of work activity are collected and properly stored until they are transferred by EHS to the main accumulation area prior to off-site shipment. The satellite area is essentially the waste collection point until a container becomes full.

The rules of Satellite Accumulation dictated by federal and state regulation:

• Location: An SAA must be ‘at or near the point of generation’. In practice this typically means that if you have to leave the room or go through a doorway your SAA is too far from the area the waste was created.
• Number: There is no limit to the number of SAAs in an area, however unnecessary SAA locations provide more potential for regulatory violations.
• Signage: Every SAA must be indicated with a sign. Please use these signs which can be printed from the EHS website.
• Secondary Containment: Every container of chemical waste in an SAA must be provided with a secondary form of containment; so that leaks or spills do not migrate. This is most often accomplished with plastic tubs or trays provided by EHS.
• Segregation of Incompatibles: Chemical wastes which are incompatible (strong acids and strong bases, organics and oxidizers, etc.) must be separated into different secondary containers. They can be present in the same SAA, however they can’t be in the same secondary containment tray/tub.
• Duration: A container of chemical waste can stay in a SAA as long as it is not full. Once it is full it must be removed by EHS within 3 days. It is the user’s responsibility to notify EHS as soon as a container becomes full.
• Duplication of Waste Streams: There can only be one container of each type of waste in a single SAA. Fill the first container, contact EHS for removal, and start filling the second container.
• Weekly Inspection: Each SAA must be inspected weekly by a person in the lab or work area (by rule EHS cannot perform these weekly inspections). The SAA sign provided above is intended to be the inspection guide. Correct any problems in the SAA during your inspection, but there is no need to document the inspection events.

Chemical Waste Containers

Every container of regulated chemical waste must meet the following minimum requirements per federal and state regulation.

• Closure: Every chemical waste container must be tightly closed at all times; unless a user is in the process of pouring waste into the container. The only certain way to achieve this is with a tight-fitting screw cap tightly secured on the container. If a container would leak if tipped over, then it’s not tightly closed.
  • See our guidance for equipment such as HPLC machines which automatically drain chemical wastes into containers.
• Condition: Every chemical waste container must be in good condition; free of cracks, leaks and corrosion.
• Compatibility: Every chemical waste container must be compatible with and resistant to the chemical wastes which are collected inside. Contact EHS for help selecting the right container type.
• Size:
  • No hazardous waste container may be larger than 55 gallons.
  • Additionally, Fire Department and other regulations often place further restrictions on container size depending on the nature of the chemical stored inside.
  • P-listed chemicals must be removed from Satellite Accumulation Areas once one quart has been generated (although the container itself can be larger than one quart – the volume of p-listed waste inside cannot exceed one quart).
• Labeling: Every container in a Satellite Accumulation Area must be labeled. See the labeling handout on the Research Support website. Each label, at a minimum, must include the following 4 elements:
  • The words “Hazardous Waste”
  • The name of the hazardous waste chemical (or chemicals) inside the container. These names must be spelled out in full, English words (no abbreviations or formulas are allowed).
  • A ‘statement of the hazard’ indicating which of the 4 hazard classes the chemical(s) exhibit. This is typically done by putting a check mark in the appropriate box on a pre-printed hazardous waste label.
  • The date the container became full. Since full chemical waste containers must be removed within three days, no container in a Satellite Accumulation Area should have a date older than 3 days.

Pre-printed hazardous waste labels, like the one below, are available through EHS:

Training

All personnel who handle or generate chemical waste in laboratories or other campus locations must receive training on proper waste handling procedures and emergency response procedures.

Initial training must be completed during the first six months of employment; refresher training is provided annually thereafter.

Hazardous waste training is a topic included in Laboratory Safety Training, which is available either in-person or on-line. Facilities Department personnel receive chemical waste training as part of their annual training program. Additionally, some departments receive hazardous waste training tailored to the specific wastes generated in that department. Visit the EHS training website for more information.

Disposal of Unknowns

All chemicals must be identified and containers properly labeled at all times. Laboratory staff is responsible for seeing that this requirement is met in their laboratories.

If an unknown chemical is discovered, label it as “unknown-pending analysis” and attach a note detailing any information about what the chemical may be or what experiment it may have been used for and where it was found. Contact EHS immediately for characterization.

Chemical Spills and PPE Waste

In general, a material that is used to clean up a chemical spill (excluding equipment which is to be re-used) must be disposed of in the same manner as the chemical itself. Gloves, spill pads, absorbents, etc. which are used to clean up a chemical spill become chemical wastes themselves, subject to the same rules as the spilled chemical.

See the campus spill response page or the emergency flipchart in your laboratory for spill response instructions.

Personal Protective Equipment (PPE) such as gloves, and lab equipment such as pipette tips, which become contaminated with hazardous chemicals should be disposed of in the same manner as the chemical waste.

Pipette tips (which are not sharp enough to puncture skin) can typically be placed into the same container the chemical waste is collected in. Disposal lab coats and larger items which become contaminated can be sealed in a bag, tied closed, and then managed (labeling, etc.) as a chemical waste container.

Dilution and Evaporation

Dilution of a waste stream (by adding clean water, for example) so that it no longer meets a hazardous waste characteristic (a concentration of a toxic metal, for example) is not allowed. Chemical waste streams must be identified and dealt with at the time they become wastes; typically at the conclusion of an experimental protocol. Dilution is not the solution to pollution.

Mixing a listed hazardous waste with other waste streams results in the entire mixture becoming a regulated hazardous waste.

Evaporation of liquid chemical wastes in NOT an acceptable method of disposal. Liquid wastes must be captured and disposed of properly. In addition to being a prohibited practice, the addition of volatile organic compounds (VOCs) to the atmosphere contributes to the generation of harmful ground-level ozone, which is a serious health threat especially in urban areas. It is therefore important from both a compliance standpoint and a public health standpoint to minimize the evaporation of chemical liquids as much as possible.

Elementary Neutralization

In the majority of cases EHS recommends collection of chemical wastes with high or low pH values (remember that chemical wastes with of 2 or lower, or 12.5 or higher, exhibit the corrosive characteristic and are hazardous wastes) for disposal off-site.

However, there are circumstances in which it is allowable to neutralize the pH of a corrosive waste – a process called elementary neutralization. The high or low pH waste must ONLY be hazardous because of pH (cannot carry any other characteristic or be a listed hazardous waste) and the neutralization process must not generate toxic gases or dangerous levels of heat.

If you would like to explore the option of elementary neutralization for your chemical wastes, contact EHS.

Nanoparticles

The fate and behavior of nanoparticles (defined as particles with at least one dimension between 1 and 100 nanometers in length) which are released to the environment is not fully understood. For this reason, disposal of nanoparticle wastes should accomplished via the hazardous chemical waste program.

Pure nanoparticles (tubes, dots, etc.), items contaminated with nanomaterials (PPE, wipes, etc.), liquid suspensions of nanoparticles and any material from which nanoparticles could detach from the surface (a friable matrix involving nanomaterials or with nanoparticles attached to the surface) should not be disposed in the regular trash or via a drain.

Nanoparticle wastes should be:

• Collected in the same way as hazardous chemical wastes (in tightly closed containers free of leaks and cracks).
• Labeled as a hazardous chemical waste, including:
  • The words ‘Hazardous Waste’,
  • The words ‘Nanoparticle Waste’,
  • The name of the base material (carbon, metal, etc.) and for solutions the name of the liquid solvent,
  • A statement of hazard: ‘toxic’ for the nanoparticle in addition to any hazard associated with the base material or solvent (‘ignitable’, for example).
• Removed from the laboratory by scheduling a pickup through the EHS hazardous chemical waste program.

Waste Minimization

Effective management is the key to minimizing the risks associated with hazardous chemical waste. Every member of the Boston University research community can take steps to minimize the volume and toxicity of chemical wastes that are generated.

Inventory Management

• Maintain an up-to-date inventory of the chemicals in your laboratory to avoid re-purchasing existing materials and to understand usage patterns.
• Only purchase the amount of chemical you will need in the short term. Buying in bulk never makes financial sense when the risks of storage and the costs of disposal are considered.
• Use the RIMS system to identify coworkers in your area who might have a chemical that you need.
• Dispose of outdated or unwanted chemicals immediately. Some materials, such as peroxide-forming chemicals, become more dangerous over time. It is much safer and much less expensive to get rid of ether that does not have significant peroxide formation.
• Label all chemical containers, regardless of what’s inside. Unknown chemical wastes are extremely expensive to dispose of.
• Only purchase cylinders from companies who will pick them up when empty.

Scaling and Substitution

• Consider using microscale experiments to reduce the volume of chemical wastes generated.
• Avoid unnecessary dilutions in experimentation which might increase the volume of hazardous waste generated.
• Substitute less hazardous materials into experiments, for example:
  • Use biodegradable detergents instead of toxic, chromium-based cleaners
  • Use latex paints and coatings instead of oil-based
  • Use non-mercury thermometers
  • Select non-mercury preservatives, and choose products such as antibodies which have been manufactured using non-mercury preservatives
  • Preserve specimens in ethanol instead of formaldehyde which is much more toxic
  • Use non-halogenated solvents in place of halogenated solvents wherever possible to reduce toxicity and disposal costs
  • Use sodium hypochlorite instead of dichromate
  • Use ‘SYBR safe’ or other DNA gel stain instead of ethidium bromide
  • Substitute F-TEDA-B54 or other product in place of fluorinating agents
  • Use scintillation cocktails which are non toluene/xylene based
  • Eliminate metal catalysts whenever practical, even if it means longer experimentation times
  • Purchase chemicals pre-mixed or in the desired concentration to avoid unnecessary experimental steps and un-needed chemical stores
  • Substitution of ethanol in place of methanol in experiments can often provide more waste management options.

Recycling

• If your research relies on a large quantity of a specific solvent EHS can help you evaluate a benchtop solvent recycling system.
• If digital image processing is not possible, work with EHS to set up silver recovery and recycling for your darkroom.

Mixing Waste Streams

• Flammable liquids are the most cost-effective waste stream to dispose of. Avoid mixing halogenated solvents, metals or other hazardous materials with flammable liquid wastes.
• Wastes containing heavy metals should not be combined with any other waste streams.
• Mercury wastes should be kept separate from all other waste streams.