- \n
- Introduction<\/a><\/li>\n
- Applicability<\/a><\/li>\n
- Responsibilities<\/a><\/li>\n
- Classification<\/a>\n
- \n
- Ignitable Characteristic<\/li>\n
- Corrosive Characteristic<\/li>\n
- Reactive Characteristic<\/li>\n
- Toxic Characteristic<\/li>\n
- The F List<\/li>\n
- The U List<\/li>\n
- The P List<\/li>\n<\/ul>\n<\/li>\n
- Satellite Accumulation Requirements<\/a><\/li>\n
- Container Management and Labeling<\/a><\/li>\n
- Training<\/a><\/li>\n
- Disposal of Unknowns<\/a><\/li>\n
- Chemical Spills and PPE Wastes<\/a><\/li>\n
- Dilution and Evaporation Prohibitions<\/a><\/li>\n
- Elementary Neutralization<\/a><\/li>\n
- Nanoparticle Wastes<\/a><\/li>\n
- Pollution Prevention and Waste Minimization<\/a><\/li>\n<\/ul>\n
Appendices<\/h6>\n
- \n
- Appendix A: U Listed Chemicals<\/a><\/li>\n
- Appendix B: P Listed Chemicals<\/a><\/li>\n<\/ul>\n
<\/a><\/p>\n
Introduction<\/h2>\n
Personnel who use chemicals as part of their jobs follow protocols to prevent exposure and minimize the potential for spills and incidents. Personal Protective Equipment (PPE) such as gloves and eye protection can protect workers from splashes and contact hazards, fume hoods can eliminate the risk of inhaling harmful chemicals, and storage cabinets can mitigate the risk of fires and spills.<\/p>\n
There is another facet of chemical safety which must be managed, however, and that is protecting the environment from chemical contamination. Improper or careless disposal practices have significant effects on our environment, including polluting water sources, poisoning wildlife, and creating toxic sites which aren\u2019t suitable for animal or human habitation. For employees who work with chemicals (and therefore generate chemical wastes) the single most important \u2018green\u2019 activity is conscientious, careful management of chemical wastes.<\/p>\n
In order to protect the environment, Federal and State governments have created very strict regulations governing chemical waste management. The only way to ensure such regulations are followed is to accompany them with severe penalties
\nfor non-compliance.<\/p>\nThe guidance that follows is intended to provide Boston University employees with the information they need to properly manage chemical wastes. It is up to each user of chemicals to understand and follow the rules. Together we can protect the environment and protect the University from costly fines and penalties.<\/p>\n
<\/a><\/p>\n
Applicability<\/h2>\n
Location:<\/h4>\n
It doesn\u2019t matter where at BU you work; in a laboratory, in a mechanical room, or anywhere else. Chemical waste rules must be applied in the same manner across all workplaces. Most chemical wastes are generated in laboratories but many are generated outside of laboratory settings; contaminated soils, building materials, lubricants, paints and many other materials can fall under these rules.<\/p>\n
Waste Chemicals:<\/h4>\n
The information that follows in this document applies only to chemical wastes. Chemicals that are going to be used in a process or experiment must be managed safely; however if they are not wastes then the information that follows does not apply. Keep in mind that just because a chemical is unused, doesn\u2019t necessarily mean it is not a waste. For example:<\/p>\n
- \n
- Expired Materials: if a chemical bottle has an expiration date that has passed, and that chemical cannot be used when it\u2019s expired, then it is a waste.<\/li>\n
- Extraneous Materials: if the process or experiment for which a chemical is used is no longer practiced, and that chemical will not be used for another purpose, that chemical is a waste. Some examples include:\n
- \n
- When a researcher leaves, and leaves behind chemical bottles for experimentation that no longer occurs, or<\/li>\n
- Containers of oil for a piece of equipment that has been removed.<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n
Once you\u2019ve determined that a chemical is not useful \u2013 for any reason \u2013 then the information in this document applies and decisions about waste management must be made.<\/p>\n
Volume:<\/h4>\n
It doesn\u2019t matter how much waste you are generating: 1 ml is regulated the same as 1 gal when it comes to chemical waste.<\/p>\n
<\/a><\/p>\n
Responsibilities<\/h2>\n
Every person at Boston University<\/strong> who generates chemical waste is responsible for the proper management of chemical wastes. These responsibilities include:<\/p>\n
- \n
- Complete hazardous waste training at least once every 12 months. Employees and students in laboratories can satisfy this requirement
\nthrough Laboratory Safety Training. Employees in other departments must attend their scheduled training programs. New employees must
\ncomplete training within 6 months.<\/li>\n - Identify the chemical wastes generated in the workplace and make decisions – with help from the Environmental Health and Safety Department (EHS) – on proper disposal.<\/li>\n
- Collect, label and manage all chemical wastes according to University protocols.<\/li>\n
- Seek help from the Environmental Health and Safety Department when questions or issues arise relative to chemical waste management.<\/li>\n
- Maintain good housekeeping in chemical waste accumulation areas.<\/li>\n<\/ul>\n
Principal Investigators and Department Managers<\/strong> have the responsibility of ensuring that personnel working under their supervision have attended training and are following University protocols.<\/p>\n
Lab Safety Coordinators<\/strong> are asked to ensure that weekly inspections of all chemical waste accumulation areas are conducted, and to serve as the liaisons between laboratories and EHS to get questions answered and problems resolved.<\/p>\n
Environmental Health and Safety (EHS) Department<\/strong> members are the subject-matter experts in the field of chemical waste management and have oversight of the chemical waste program. Responsibilities include:<\/p>\n
- \n
- Provide written guidance outlining the university\u2019s hazardous waste procedures.<\/li>\n
- Work with campus staff and students to resolve chemical waste issues, provide support and answer questions.<\/li>\n
- Provide training to chemical waste generators on campus.<\/li>\n
- Remove chemical wastes from labs and other areas on campus where they are generated, and manage them through to their final destination offsite.<\/li>\n
- Generate and maintain all disposal records as required by regulation.<\/li>\n<\/ul>\n
<\/a><\/p>\n
Classification of Chemical Waste<\/h2>\n
The next step after identifying a chemical as a waste is to classify that waste. Chemical wastes will ultimately fall into one of 4 management categories:<\/p>\n
- \n
- Collected as a Hazardous Waste:<\/strong> A chemical which exhibits a \u2018hazardous\u2019 characteristic, is listed according to Federal or State regulation, or best management practices dictate strict control must be managed as a hazardous waste. Most of the information in this document describes the rules to follow when managing hazardous wastes.\n
- \n
- Hazardous wastes have the greatest potential to harm people or the environment, and bear the full burden of environmental regulation.<\/li>\n
- Mis-management of hazardous wastes can result in significant environmental penalties and enforcement actions.<\/li>\n
- The term \u2018hazardous waste\u2019 should only be used when describing chemicals. Infectious or radioactive wastes are not \u2018hazardous wastes\u2019 unless they are mixed with chemical wastes.<\/li>\n
- Hazardous wastes are generated routinely at Boston University.<\/li>\n
- Collection and management of chemical wastes as hazardous wastes ensures the maximum level of environmental protection and is the safest means of chemical waste management.<\/li>\n<\/ul>\n<\/li>\n
- Collected as a Non-hazardous Waste:<\/strong> A chemical which does not exhibit a state or federal hazardous characteristic and isn\u2019t listed as a \u2018hazardous waste\u2019 isn\u2019t necessarily safe for disposal via sink or in the regular trash.\n
- \n
- In some cases, protection of the environment requires us to go above and beyond the hazardous waste regulations. An example would be ethidium bromide<\/strong>, which doesn\u2019t technically exhibit a hazardous characteristic but which isn\u2019t safe for handling as regular trash. Other examples include materials like nanoparticles for which comprehensive safety information does not yet exist. Often the
\nprecautionary principle dictates that we collect these materials because we do not understand the potential harm they can cause in the environment.<\/li>\n- In other cases, a different regulation might stipulate collection of a waste chemical. An example would be very small concentrations
\n(part-per-billion level) of mercury in otherwise benign reagents. Local Clean Water Act enforcement prohibits mercury disposal to sink drains even though the level of contamination is low.<\/li>\n- In cases where a chemical is collected as a non-hazardous waste, some of the hazardous waste management rules do not apply.<\/li>\n<\/ul>\n<\/li>\n
- Collected as a Universal Waste:<\/strong> A small subset of chemical wastes have been de-regulated to some extent based on the fact that they are so widespread.\n
- \n
- Management regulations still exist, but they are lessened relative to hazardous waste regulations.<\/li>\n
- Universal wastes are most often generated and managed through Facilities Management Department operations.<\/li>\n
- Universal Wastes include:\n
- \n
- Fluorescent bulbs of all shapes and sizes<\/li>\n
- Many types of batteries<\/li>\n
- Mercury-containing devices such as switches and thermostats.<\/li>\n<\/ul>\n<\/li>\n
- Boston University has a separate policy detailing how Universal Wastes must be managed.<\/li>\n<\/ul>\n<\/li>\n
- Safe for Sink or Trash disposal:<\/strong> A very small percentage of chemical wastes are un-regulated and safe to pour into sinks or place in the trash. Some examples include benign salts like sodium chloride, and non-toxic, non-corrosive cleaning chemicals. Contact EHS prior to disposing any chemical into a sink or via the trash.<\/strong><\/li>\n<\/ul>\n
Hazardous Wastes<\/h2>\n
The most important question to answer when managing a chemical waste: \u201cdoes my chemical waste have to be collected and managed as a hazardous waste?\u201d It is necessary to know the answer to this question as this is the first step in a process known as making a \u2018waste determination\u2019<\/strong>, and is a required step in chemical waste management.<\/p>\n
In order to determine whether a chemical waste must be collected as a hazardous waste you must have information about the properties and behavior of the chemical. This knowledge is fundamental to safe laboratory operations, and literature is available in your workplace in the form of Safety Data Sheets (SDS or MSDS) which can help. If you don\u2019t know or are unsure about the characteristics or properties of a chemical waste contact EHS for assistance.<\/p>\n
Never assume a chemical waste is safe for disposal in the regular trash or via a sink or drain. Always err on the side of caution; collection and management as a hazardous waste because this is the safest and most responsible way to collect a chemical waste.<\/p>\n
A chemical waste must be classified and managed as a hazardous waste if it exhibits any of the four characteristics described below, or is specifically listed in the regulations.<\/p>\n
Ignitable Characteristic<\/h3>\n
A chemical waste is a hazardous waste due to ignitability if:<\/p>\n
- \n
- Liquid Chemicals:<\/strong> the flash point of the liquid chemical is less than or equal to 140 degrees F.\n
- \n
- Equivalent is 60 degrees C<\/li>\n
- Flashpoint determination is \u2018Pensky-Martens Closed Cup Tester\u2019<\/li>\n
- Common examples include:\n
- \n
- Alcohols (note: for ethanol, mixtures greater than or equal to 20% are hazardous wastes. For other alcohols the cut-off is 10%.)<\/li>\n
- Organic Solvents and mixtures containing organic solvents such as xylenes, hexane, toluene, acetone, etc.<\/li>\n
- Stains and mixtures containing stains (because they are solvent-based).<\/li>\n
- Oil-based paints and coatings<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n<\/li>\n
- Solid Chemicals:<\/strong> the chemical is capable, under standard temperature and pressure, of causing fire through friction, absorption of moisture or spontaneous chemical changes, and burns vigorously when ignited\n
- \n
- Common examples include:\n
- \n
- Paraformaldehyde<\/li>\n
- Parafin wax with xylene<\/li>\n
- Rags saturated with an ignitable liquid<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n<\/li>\n
- Compressed Gas:<\/strong> Ignitable compressed gases must also be managed as hazardous wastes.\n
- \n
- Generally this involves partially-full, or left-over cylinders of gas<\/li>\n
- Common Examples include:\n
- \n
- Hydrogen<\/li>\n
- Acetylene<\/li>\n
- Propane<\/li>\n
- Butane<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n<\/li>\n
- Oxidizers:<\/strong> the chemical is capable of enhancing the combustion of other materials, generally by yielding oxygen.\n
- \n
- Common examples include:\n
- \n
- Chlorates<\/li>\n
- Chlorites<\/li>\n
- Nitrates<\/li>\n
- Perchlorates<\/li>\n
- Perchlorites<\/li>\n
- Permanganates<\/li>\n
- Peroxides<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n
If your chemical waste exhibits any of the \u2018ignitable\u2019 characteristics above, you must manage it as an ignitable hazardous waste.<\/p>\n
Corrosive Characteristic<\/h3>\n
A chemical waste is a hazardous waste due to corrosivity if:<\/p>\n
- \n
- It is aqueous and has a pH less than or equal to 2, or greater than or equal to 12.5, or<\/li>\n
- It is a liquid and corrodes steel (Type SAE 1020) at a rate greater than 6.35 mm (approximately 0.250 inch) per year.<\/li>\n
- Common examples include:\n
- \n
- Hydrochloric Acid<\/li>\n
- Sulfuric Acid<\/li>\n
- Nitric Acid<\/li>\n
- Sodium Hydroxide<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n
Reactive Characteristic<\/h3>\n
A reactive hazardous waste is defined as a material which:<\/p>\n
- \n
- Under normal conditions is unstable and can undergo violent changes without detonating<\/li>\n
- Reacts violently with Water\n
- \n
- Common Examples Include:\n
- \n
- Sodium metal,<\/li>\n
- Anhydrides,<\/li>\n
- Sodium Borohydride<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n<\/li>\n
- Reacts violently with Air\n
- \n
- Common Examples Include:\n
- \n
- tert<\/em>-butyllithium,<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n<\/li>\n
- Capable of detonation or violent explosion\n
- \n
- Common Examples Include:\n
- \n
- Dry picric acid,<\/li>\n
- Azide compounds,<\/li>\n
- Organic peroxides,<\/li>\n
- Old ether or tetrahydrofuran with peroxide formation<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n<\/li>\n
- A cyanide or sulfide which, when exposed to a pH of between 2 and 12.5, generates toxic gases, vapors or fumes\n
- \n
- Common Examples Include:\n
- \n
- Sodium cyanide,<\/li>\n
- Potassium cyanide,<\/li>\n
- Sodium sulfide,<\/li>\n
- Carbon disulfide<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n
Toxic<\/h3>\n
The toxic \u2018characteristic\u2019 is where the regulations start to get into listing specific chemicals. To determine whether a chemical waste exhibits the toxic characteristic, it is necessary check the federal toxic list, known as the \u2018D\u2019 list. The state of Massachusetts adds some chemicals to the list as well.<\/p>\n
As a general rule, a waste that contains any material on this list should be collected for disposal regardless of concentration; even if it\u2019s not technically regulated as a hazardous waste it still doesn\u2019t belong in the environment.<\/p>\n
The concentration listed next to the chemical names below refers to a very specialized analytical method known as the TCLP test (the Toxic Characteristic Leachate Procedure). The TCLP test is designed to simulate the concentration of contaminant that would leach out of the material if it were in a landfill under acid rain conditions. EHS can provide TCLP analysis if necessary. However, in most cases the right thing to do is to collect wastes with any concentration of the chemicals listed below. As always, contact EHS if you have questions.<\/p>\n
Chemicals on the federal toxic List<\/p>\n
\n\n\n
- Common Examples Include:\n
- Capable of detonation or violent explosion\n
- tert<\/em>-butyllithium,<\/li>\n<\/ul>\n<\/li>\n<\/ul>\n<\/li>\n
- Common Examples Include:\n
- Common Examples Include:\n
- Common examples include:\n
- Common examples include:\n
- Liquid Chemicals:<\/strong> the flash point of the liquid chemical is less than or equal to 140 degrees F.\n
- In other cases, a different regulation might stipulate collection of a waste chemical. An example would be very small concentrations
- In some cases, protection of the environment requires us to go above and beyond the hazardous waste regulations. An example would be ethidium bromide<\/strong>, which doesn\u2019t technically exhibit a hazardous characteristic but which isn\u2019t safe for handling as regular trash. Other examples include materials like nanoparticles for which comprehensive safety information does not yet exist. Often the
- Collected as a Hazardous Waste:<\/strong> A chemical which exhibits a \u2018hazardous\u2019 characteristic, is listed according to Federal or State regulation, or best management practices dictate strict control must be managed as a hazardous waste. Most of the information in this document describes the rules to follow when managing hazardous wastes.\n
- Complete hazardous waste training at least once every 12 months. Employees and students in laboratories can satisfy this requirement
- Appendix B: P Listed Chemicals<\/a><\/li>\n<\/ul>\n
- Container Management and Labeling<\/a><\/li>\n
- Applicability<\/a><\/li>\n
![](\"http:\/\/www.bu.edu\/researchsupport\/files\/2016\/11\/Hazardous-Waste-Labeling-Guidance-636x387.png\")
<\/><\/p>\n