Section 8: Radioactive Waste Management and Disposition of Radioactive Materials and Devices

Transportation of radioactive materials is regulated by the Massachusetts DPH, U.S. Nuclear Regulatory Commission, U.S. Department of Transportation (DOT), and the U.S. Postal Service. These regulations require that BU/BMC maintain a central inventory of all radiation sources. Therefore, all radiation source shipments must be approved and documented by the DMPRS.

Radioactive materials may only be transferred to another PH, either at BU/BMC or at another institution, when pre-approved by the DMPRS (and as specified in the permit holder’s permit). Only Radiation Safety staff may transfer radiological sources and products between buildings or campuses. If the transfer is to another institution, please allow enough time for DMPRS staff to work with the other institution’s Radiation Safety Organization and complete the appropriate paperwork.

BU/BMC are required under state law to store all radioactive waste in approved containers using approved handling techniques and to maintain written records regarding the storage and disposal of radioactive waste. It is a violation of Federal, state, and University regulations to dispose of radioactive waste as normal trash. The DMPRS must be contacted immediately (617-638-7052) if it is found that radioactive waste is or has been disposed of improperly or if laboratory personnel are unsure of proper (approved) waste handling/disposal techniques.

1. Radioactive waste is required to be segregated by isotope
2. NOTE: The laboratory may combine 3H and 14C into a single container or may combine short half-life (T1/2 < 120 days) materials together. In all cases, materials added to a waste container shall be chemically non-reactive with both the container and its contents.
3. All radioactive waste shall be separated and stored into the following physical forms:
   • Solid waste
   • Liquid waste
   • Sharps waste
   • Animal carcasses
   • Lead (Pb) shipping containers

   Detailed instructions on proper radioactive waste storage and handling for each physical waste form (also referred to as a “waste stream”) are described below.

4. Environmental and Waste Management is available to assist in finding vendors of approved radioactive waste containers.
5. Regardless of the type of radioactive waste generated, all radioactive waste shall be assembled in designated restricted areas and stored in waste containers clearly labeled with the following: “RADIOACTIVE WASTE” or “CAUTION RADIOACTIVE MATERIAL.” Environmental and Waste Management will not accept radioactive waste stored in improper waste containers.
6. Radioactive chemicals or powders, contaminated sharps, and radioactive animal carcasses are examples of a “mixed waste stream.” All such waste shall meet the requirements for radioactive material waste handling documented in this procedure and the requirements for chemical/hazardous material waste handling as documented by EHS’s Environmental and Waste Management division. Lead containers must not be placed in radioactive waste containers. Keep lead containers in a separate storage bin for pick up by Environmental and Waste Management.
7. Laboratories shall maintain a list containing the isotope and total activity present within each waste container generated or used by that laboratory. It is the responsibility of the PH to ensure that this list is up-to-date and accurate.
8. Radioactive labels must be removed or defaced prior to being placed in a radioactive waste container.
9. When in use, a radioactive waste container shall be labeled with the following information:
   1. “RADIOACTIVE WASTE” or “CAUTION, RADIOACTIVE MATERIAL” warning sign;
   2. A listing of the radioisotope(s) present within the container;
   3. One (1) entry for each time waste is added to the container; and
   4. The chemical form(s) of the radioisotope(s) present (if liquid).
10. When full, a radioactive waste container shall be labeled with the following information:
    1. A listing of the radioisotope(s) present within the container;
    2. A estimate of the activity present of each radioisotope (preferably in mCi);
    3. The chemical form(s) of the radioisotope(s) present;
    4. The permit holder’s name;
    5. The laboratory room number;
    6. The name of person labeling the waste; and
    7. The date that the waste was labeled.
11. All radioactive waste receptacles shall be kept in an approved area within the laboratory (not in the hall or other unsecured area). It is the responsibility of the PH to verify that the location of the waste receptacle within the laboratory does not present a health hazard.
12. When a radioactive waste container is full, a “Waste Pickup Request” must be submitted via SciShield. NOTE: Environmental and Waste Management will not accept any waste containing contaminated glass unless it is stored in a plastic lined rigid container (plastic or cardboard) or any other improperly stored waste.
13. It is the responsibility of the PH to verify that waste is properly contained and identified. The PH is also responsible for ensuring that any improperly stored waste (especially waste refused for pickup) is properly repackaged as soon as possible.
14. Short-lived waste may NOT be stored for decay (i.e., until the activity of the waste is indistinguishable from background) in the laboratory. The City of Boston Fire Department requirements preclude the storage of such waste in the laboratory for the purpose of decay in storage. The Boston Fire Department has permitted a specific area for this purpose.

1. On the bench top, solid (dry) radioactive waste (gloves, absorbent material, etc.) shall be stored in clear Plexiglas containers lined with clear plastic bag. All labels indicating radioactivity must be defaced prior to placing in the waste bin.
2. Bags from the bench top containers may be consolidated into larger containers; however, the containers must be the yellow five-gallon pails available from Environmental and Waste Management (at no charge).
3. Each radioactive waste container (bench top or floor pail) shall be identified with the magenta and yellow radiation symbol and the words: “RADIOACTIVE WASTE” or “CAUTION RADIOACTIVE MATERIAL.”
4. Radioactive solid waste is required to be segregated by isotope.NOTE: The laboratory may combine 3H and 14C into a single container or may combine short half-life (T1/2 < 120 days, i.e. P-32, S-35, Tc-99m, and I-131) materials together. In all cases, materials added to a waste container shall be chemically non-reactive with both the container and its contents.
5. The laboratory shall maintain a list of the isotope(s) and total activity present within each container. It is the responsibility of the PH to ensure that this list is up-to-date and accurate.
6. While in use, each radioactive waste container shall be clearly labeled with the information required above and this information shall be clearly visible.
7. Radioactive waste placed in containers shall NOT include any liquids, animal tissue, animal excreta, blood products, lead (Pb), or loose sharp objects likely to cause a laceration or puncture wound.
8. Radioactive material must not be put into a waste container if there is the possibility of a chemical reaction during storage that may cause a fire, explosion, or the release of radioactive material.
9. Special care must be taken in storing radioactive waste containing volatile isotopes such as iodine and some forms of Sulfur-35. It is suggested that these wastes be double bagged and tightly sealed. Charcoal felt must be used to assist with the control of iodine volatility. Please call Environmental and Waste Management (358-7840) with any questions on this matter.
10. When the container is full, the waste shall be labeled to clearly display the information required in above. Verify that the label is not obscured from view.
11. After labeling a full waste container, a “Waste Pickup Request” must be submitted online via SciShield. NOTE: Environmental and Waste Management will not accept any waste containing contaminated glass unless it is stored in a plastic lined rigid container (plastic or cardboard).

1. Liquid radioactive waste (including liquid scintillation fluid) shall be contained in plastic or glass sealable jugs. Call Environmental and Waste Management (617-358-7840) if special consideration must be given to another type of container due to chemical incompatibility with approved plastic or glass containers. NOTE: Liquid radioactive waste should be doubly protected; plastic storage bins are available from the Environmental and Waste Management Office.
2. Each radioactive liquid waste container shall be identified with the magenta and yellow radiation symbol and the words: “RADIOACTIVE WASTE.”
3. Radioactive waste is required to be segregated by isotope.
4. NOTE: The laboratory may combine 3H and 14C into a single container or may combine short half-life (typically T1/2  90 days, i.e. P-32, S-35, Tc-99m, and I-131) materials together. In all cases, materials added to a waste container shall be chemically non-reactive with both the container and its contents.
5. While in use, each liquid waste container shall be clearly labeled with the information required in above. Verify this information is not obscured from view.
6. The laboratory shall maintain a list of the isotope and total activity present within each container. It is the responsibility of the PH to ensure that this list is up-to-date and accurate.
7. When the liquid radioactive waste container is nearly full, a Radioactive Material Tag must be attached to the container including the information required in above. Verify that the label is not obscured from view.
8. A “Waste Pickup Request” shall be submitted online via SciShield.
9. Organic based Liquid Scintillation cocktails containing 3H or 14C at concentrations below 0.05 Ci/ml (1.11105 dpm/ml) are disposed of as toxic waste without regard to radioactivity (that is, it is considered non-radioactive).
10. Disposal of aqueous liquids via a designated radioisotope laboratory sink may be performed only if the laboratory meets the following criteria:
    1. The waste is an aqueous solution;
    2. TThe isotope concentration falls within the limits specified in BU/BMC Sink Disposal Limits of Radioisotopes (available at https://www.bu.edu/ehs/ehs-topics/radiation-safety/radiation-safety-operational-forms/); and
    3. The PH has been approved by EHS for sink release for the specific chemical in question.
11. The PH is responsible for maintaining records which document the total activity disposed via the sink disposal route, the isotope disposed, and the date.

1. All animal carcasses shall first be placed in a plastic bag and then in a brown paper biohazard material bag (e.g. a Kraft bag). Animal carcass, animal tissue/parts, and animal excreta/bedding may be placed together in the same bag for the same animal.
2. Animal carcass waste bags shall NOT contain:
   1. Needles
   2. Syringes
   3. Knives
   4. Blades
   5. Glass
   6. Sharps
   7. Scalpels
   8. Pipettes
   9. Ceramics.
3. Once the animal carcass has been double bagged, it must be frozen for at least twenty four (24) hours prior to pick up by Environmental and Waste Management. Environmental and Waste Management will provide the container for the animal carcasses to ensure compatibility with the waste vendor acceptance criteria.
4. A radioactive material tag (or sticker) must be placed on the outermost bag and must be fully labeled as described in above. To arrange pickup, an online request must be submitted via SciShield.

1. All sharps (needles, syringes, razor blades, scalpel blades, microtome blades, microscope slides/covers, pipette tips, Pasteur pipettes, broken glass, or any object likely to cause a laceration or puncture wound) contaminated with radioactive material shall be deposited into a sharps container marked for radioactive waste.
2. Radioactive sharps waste is required to be segregated by isotope. NOTE: The laboratory may combine 3H and 14C into a single container or may combine short half-life (typically T1/2 less than equal to 90 days) materials together. In all cases, materials added to a waste container shall be chemically non-reactive with both the container and its contents.
3. Each radioactive sharps container shall be identified with the magenta and yellow radiation symbol and the words: “RADIOACTIVE WASTE.”
4. While in use, each sharps container shall be clearly labeled with the information required in above. Verify this information is not obscured from view.
5. The laboratory shall maintain a list of the isotope and total activity present within each container. It is the responsibility of the PH to ensure that this list is up-to-date and accurate.
6. When the sharps radioactive waste container is full, a Radioactive Material Tag must be attached to the container including the information documented in above. Verify that the label is not obscured from view.
7. Submit a request online via SciShield to arrange a pickup.

Many stock vials are shipped from vendors within lead (Pb) shielded containers. These containers shall be disposed of by EHS Environmental and Waste Management. Non-contaminated lead shields must be disposed of in accordance with applicable BU EHS procedures. Any lead shield contaminated with radioactive material shall be either labeled and stored as radioactive waste or labeled and given to the DMPRS.