MONTCLAIR STATE UNIVERSITY
HAZARDOUS WASTE PLAN
The purpose of this manual is to provide important information for Montclair State University personnel concerning management of hazardous wastes, which include (chemical, biological, medical and radioactive waste) generated at the University.
Proper
chemical waste management is important in order to provide safe working
situations for faculty, staff and students, to protect the environment, and to
ensure our compliance with all applicable federal, state and local laws and
regulations.
In
1976, Congress enacted the Resource Conservation and Recovery Act (RCRA) to
protect human health and the environment from improper chemical hazardous waste
management practices. This legislation required each waste generator to obtain
an EPA identification number for its activities that occurred within a
continuous area. RCRA regulations also exempted two categories of small
quantity generators from many of the hazardous waste regulations: these are the
Conditionally Exempt Small Quantity Generator
(CESQG) and the Small Quantity Generator (SQG). Montclair State
University has one EPA number for its area which is defined as a SQG. This means
that MSU must follow the regulations for SQGs. Under RCRA, a small quantity
generator is defined as an entity which produces less than 1000 Kilograms but
more than 100 Kilograms per month of hazardous waste and/or less than 1 Kilogram per month of acutely hazardous
waste. .MSU also comes under other environmental laws and regulations,
including the Toxic substances Control Act (TSCA), Superfund Amendments and
Reauthorization Act (SARA), Clean Water
Act (CWA), Clean Air Act (CAA), Emergency Planning and Community Right-to-Know Act (EPCRA), and New
Jersey General Safety Code One. Thus, it is very important to not discard as
ordinary trash any reagents, chemical solutions, chemical mixtures, industrial
products, or any items containing substances which may be regulated under one
or more of these programs.
Under
the Resource Conservation and Recovery Act (RCRA), all solid biological and
chemical wastes and discarded liquids and gases in containers (like ingredients
of discarded aerosol cans) must be disposed in a manner that will prevent
pollution of the environment (usually, significant degradation of water
quality, or visual and physical pollution of the land). Non-hazardous waste is
all waste that can fall into this classification which is not specifically designated
a hazardous waste by name because of its chemical and physical properties.
These regulated non-hazardous wastes may be generated without registration or a
permit, but are subject to specific prohibitions on treatment and disposal.
They must be disposed only at facilities having a permit to treat and dispose
of wastes, such as a sanitary landfill. On-site treatment and disposal of
non-hazardous waste without a permit is prohibited. Exceptions are made for
sanitary wastes discharged to wastewater treatment systems. Such discharges are
regulated under the federal Clean Water Act.
Hazardous
waste material comes from many sectors of our technological society -industry,
hospitals, research laboratories, and all levels of government. The US
Environmental Protection Agency and the New Jersey Department of Environmental
Protection are authorized to regulate all aspects of hazardous waste management
including generation, storage, treatment, disposal, and transportation. These
agencies define a hazardous waste as a solid waste that may cause or
significantly contribute to serious illness or death, or that may pose a
substantial threat to human health or the environment if managed improperly.
Solid waste includes liquids, semisolids, and compressed gases. The EPA has
expanded the definition of a hazardous waste to mean a solid waste that is not
excluded from regulation and that:
a.
Exhibits
one or more of the characteristics of a hazardous waste, such as ignitability,
corrosivity, reactivity or toxicity.
b.
Is listed
in 40 CFR 261 as a hazardous waste.
c.
Is a
mixture of solid waste and one or more of the listed (40 CFR 261) hazardous
wastes.
d.
Is disposed
of, burned or incinerated; or accumulated, stored, or treated (not recycled)
before burning or disposal.
e.
Is recycled
in a manner constituting disposal, burned to recover energy or to produce a
fuel, or accumulated speculatively.
The
characteristics for identifying a hazardous waste are ignitability,
corrosivity, reactivity, and toxicity. Infectivity, and radioactivity are
characteristics of special wastes. Any waste that exhibits any of these
characteristics is considered to be a hazardous or special waste, whether or
not it is listed by the EPA or NJDEP.
a. Ignitable - This characteristic identifies a waste that may
cause a fire during routine waste disposal and storage conditions. There are
several ways to identify ignitable wastes, depending on whether the waste is
liquid, solid, or compressed gas. A waste is ignitable if:
·
It is a
liquid other than an aqueous solution containing less than 24 percent alcohol
by volume that has a flash point of 140 degrees Fahrenheit (60C) or less.
·
It is not a
liquid and is capable of causing a fire at standard temperature or pressure
through friction, absorption of moisture, or spontaneous chemical changes.
·
It is a
compressed gas classified as flammable by the Department of Transportation.
DOT's definition of flammable is a material that has a flash point below 100
degrees Fahrenheit.
·
It is an
oxidizer as defined by the Department of Transportation. An oxidizer is defined
as a material that yields oxygen readily and stimulates the combustion of
organic materials. Examples are chlorates, nitrates, permanganates, or organic
peroxides.
b. Corrosivity - This characteristic identifies a waste that is
a liquid or solid that may cause visible destruction or irreversible alteration
on human skin, or a liquid that has a severe corrosion rate on steel. A waste
is corrosive if:
·
It is a
liquid and has a pH of less than or equal to 2.5 or a pH greater than 12.5.
·
It is a
solid and has an aqueous solution pH of less than or equal to 2.5 or a pH greater
than 12.5.
c. Reactivity - This characteristic identifies a waste that is a
liquid, solid, or gas that produces dangerous gases and/or fire when mixed with
air, water or pH changes. A waste is reactive if:
·
It reacts
violently with water or air.
·
It forms
potentially explosive mixtures with water or air.
·
It contains
cyanide or sulfide-bearing wastes that, when exposed to pH conditions between 2
and 12.5, can generate sufficient toxic gases, vapors, or fumes to pose a
danger to human health or the environment.
·
It is
capable of detonation or explosive decomposition or reaction at standard
temperature and pressure.
d. Toxicity - This characteristics identifies a waste that is a
liquid, solid or gas that can have an acute or chronic effect on human health
or the environment.
e. Infectious - This characteristic identifies that portion of
Potentially Infectious Biomedical Waste (PIBW) which contains pathogens with
sufficient virulence and quantity that exposure to the waste by a susceptible
host could result in an infectious disease. Potentially Infectious Biomedical
Waste (PIBW) includes medical waste and infectious waste. Waste considered likely to be infectious by
virtue of what it is or how it may have been generated in the context of health
care or health care like activities. It includes but is not limited to the
following:
·
Human
blood, human blood products, blood collection bags, tubes, and vials.
·
Sharps used
or generated in health care or laboratory settings.
·
Sharps
include glass fragments, needles, syringes, scalpels, scalpel blades, pipettes
and other medical instruments or laboratory waste capable of puncturing or
lacerating skin.
·
Bandages,
diapers, "blue pads," and other disposable materials IF they have
covered infected wounds or have been contaminated by patients isolated to
protect others from the spread of infectious diseases.
·
Any other
refuse that has been mingled with Potentially Infectious Biomedical Waste.
f. Radioactive - This characteristic identifies a waste that is
capable of emitting alpha, beta, or gamma rays of radioactivity. Radioactive
waste must be disposed of according to the guidelines in the University
Radiation Plan.
g. Specialty Wastes - These wastes are identified by the special
problems they impose for storage and disposal. A specialty waste is:
·
A waste
that is a combination of two or more of the above wastes (such as an infectious
waste that is contaminated with a radioactive isotope).
·
PCB
(polychlorinated biphenyls).
·
Reactive
metals (such as sodium which is water reactive and also a flammable solid).
·
Gas
Cylinders (such as lecture bottles and acetylene bottles).
Wastes
containing low level radioactive contamination can be retained until they decay
to background radiation levels as indicated by obtaining a background level
reading with a survey meter. This requires that the waste be kept in a locked,
shielded enclosure. Such an enclosure may be located in only one room of an
operating unit and can be relatively small. It is the responsibility of the
person who generates radioactive waste to separate it from regular solid and
chemical waste to avoid contamination. The waste contaminated with radiation
should be immediately sealed, labeled and taken to the proper storage area.
Shielded garments, glove boxes and radioactive material fumehoods as specified
by the EH&S Radiation Safety Officer should be used during containment.
Radioactive
waste containers must be clearly labeled with radiation markings showing each
radioisotope present, quantity and types of material in the container, the date
the waste was generated, and name of the licensed user. It is important that
the person generating the waste be as specific as possible about the chemical
and biological constituents of the waste. The material in the waste mixture,
especially carrier solutions or excipients, may be regulated material which
EH&S office is responsible for properly disposing. Exceptions to these
regulation-mandated packaging and labeling procedures, such as the handling of
excreta for animals receiving radioisotope injections, are usually presented in
the EH&S Radiation Safety Plan.
All
discarded items known or suspected of containing a potentially infectious
biological waste should be handled as a biohazard. Wastes containing a
biohazard should be sealed in an impervious (red) bag, marked with a biohazard
label and placed in covered receptacles marked with the words "Biohazard
Waste" and with the biohazard symbol. Handling of these wastes should be
conducted according to OSHA's "Universal Precautions and Blood-borne
Pathogens" regulations. Biohazards contaminated with radioactive wastes
should be sealed, labeled and disposed of in accordance with the EH&S
Radiation Plan.
Discarded
mixtures which contain chemical and biohazards must be handled with precautions
appropriate to the dangers present and marked with both chemical and biohazard
warning labels. Biohazards in chemical wastes can be destroyed by the use of
disinfectants and rarely, by sterilizing the mixture. Following any infection
destruction procedure, the person treating the waste must seal the residuals in
the proper container and apply to it the appropriate label, identifying its
chemical components.
Hazardous
materials are the active constituents of many commercial products used by the
faculty, staff and students of the university. Hazardous materials are
knowingly used for their unique chemical or physical properties in campus
workshops, teaching and research laboratories. Properly marking for disposal
spent, used, or aged chemicals, discarded or aged products containing hazardous
materials as their active ingredients, or the by-products of using these
hazardous materials or products is the legal responsibility of the generator.
Such wastes must be handled according to all federal, state and local laws and
policies set forth by EH&S office.
Solid
hazardous wastes in teaching and research labs, should be placed in sturdy
containers and properly labeled. When breakable containers are used, they
should be placed in carriers. As with solid hazardous wastes, liquid wastes should
be placed in containers provided for that purpose. Liquid wastes of a common
chemical composition may be generated continuously in teaching and research
labs. Regulated waste from these activities may not be poured down the drain
unless with the written consent of EH&S office.
Untreated
wastes must be properly contained and labeled for disposal by EH&S office.
If vented safety cabinets for storage of compatible wastes are provided, the
daily accumulation of mixtures may be temporarily stored. When these waste
containers are full, they are to be disposed according to EH&S office
policies and procedures pertaining to hazardous wastes.
When
hazardous wastes are generated during an experiment as process in a lab, the
material may be reduced to a non-hazardous material by the person conducting
the procedure or process, as the last step in the experimental procedure or
process. Primary neutralization is an example of this. The now, non-hazardous
waste can be disposed as regular waste.
Some
hazardous wastes generated in universities can be treated or reduced in
toxicity if there are approved methods for such treatment. The following
methods of reducing the amount of waste should be done with the consent of the
EH&S office:
·
Acids and
Bases: All acids that are 15% or less should be neutralized by adding a 30%
solution of sodium bicarbonate to the acid slowly until a range of 5-8 pH is
reached. The mixture can be poured down the drain with an excess of water.
·
All bases
that are 15% or less should be neutralized by adding a 5% solution of sulfuric
acid to the base slowly until a range of 5-8 pH is reached. The mixture can be
poured down the drain with an excess of water.
·
Aldehydes
and Peracids All aldehydes or peracids
that are 20% or less should be treated with excess sodium bisulfite solutions
and then neutralized. The resulting mixtures can be poured down the drain with
excess water.
·
Mercaptans
and Nitriles All mercaptans and
nitriles that are 15% or less should be oxidized with a 15% solution of
hypochlorite (bleach). Neutralize the resulting mixture, then discard down the
drain with excess water.
These
methods can be done on a limited basis as long as the generator has prior
approval of the EH&S office.
In
order for EH&S office to provide technical assistance with and
recommendations for disposal of hazardous wastes, information concerning the
materials must be obtained:
·
The full
name of the chemical must be properly marked on the container and the container
must be properly sealed.
·
List the
full name of each chemical to be discarded; do not abbreviate names. If only a
trade name is given, list the trade name, any descriptive material on the
label, and the vendor and/or manufacturer's name and address. EH&S office
will assist in obtaining contents information from the vendor or manufacturer.
The disposal options available depend upon the nature of the hazard(s) of the
materials being discarded. Every effort is made to properly and economically
dispose of unwanted chemicals in a safe and proper manner, considering safety
aspects as well as regulatory requirements.
1.
No
hazardous materials, toxic or flammable, are to be discharged into the drains
or put into the trash. Arrangements should be made with EH&S to dispose of
all toxic, flammable, or otherwise hazardous chemicals and reagents which are
no longer needed or wanted.
2.
Waste
containers should be compatible with the waste material, i.e. non-reactive with
that waste, and wastes should be stored until pickup of the materials can be
arranged with EH&S. Special containers with self-closing covers should be
used for volatile liquids and spent chemicals.
3.
Alkalis and
acids must be between the pH of 5.5 and 10.0 in order to be disposed via the drains
with copious amounts of water.
4.
Handle all
materials carefully. Many hazardous materials can deteriorate over a period of
time and cause more harm than the original material. Do not open containers to
determine the quantity of the contents; loosening a lid or cap could cause
serious harm to health or the environment.
5.
Likewise,
avoid jarring or shaking containers. Wear proper clothing when handling
hazardous materials. (Material Safety Data Sheets can be a good source for
information on handling hazardous materials.)
6.
All
containers must be clearly labeled as to contents and dated. For unknown
materials, make every effort to identify the contents of the container.
Commercial disposal firms do not accept unknowns, and EH&S office cannot
offer valid assistance without some knowledge of the nature of the materials.
If possible, contact the person(s) who generated the waste to obtain knowledge
of the material. A physical description such as solid, liquid, pH, odor or
flammability could be helpful.
7.
Gas cylinders
should be returned to the vendor when gas has been expired and should be
handled according to NFPA rules. Since rental on most cylinders involves
monthly charges, empty or unwanted cylinders should be returned as soon as
possible to the vendor. The Purchasing Office usually can offer assistance with
return of cylinders. Gas cylinders cannot be accepted by commercial firms;
arrangements for disposal through other sources are scarce and extremely
expensive.
8.
Any
unwanted experimental pesticides should be returned to the manufacturer.
9.
Radioactive
waste will be handled by the methods allowed by Radiation Safety Regulations
(see Radiation Safety plan).
10.
Biological
or infectious material should be handled in strict accordance to sanitary codes
and rendered non-recognizable and non-infectious by using methods such as red
bagging, sterilization, autoclaving and incineration of wastes. All infectious
waste is to be sterilized prior to disposal or packaged properly for immediate
incineration. No untreated infectious waste is to be discarded into solid waste
(normal trash) containers for disposal.
Generators
are those who produce or accumulate and dispose of over 1,000 kilograms (2200
lbs) of hazardous waste in a month's time. Montclair State University is
classified as a generator because we produce more than 1000 kilograms of
hazardous wastes a month, store the wastes for up to 90 days, and don't treat
acutely hazardous wastes on-site. MSU is not authorized to treat, store (for
more than 90 days), or dispose of hazardous wastes on-site due to the
restrictive nature of the hazardous waste regulations.
The
Resource Conservation and Recovery Act authorizes the Environmental Protection
Agency to set standards for generators of hazardous wastes. Under these
standards, the generator must:
1.
Notify EPA if hazardous waste is
generated.
2.
Prepare and follow-up a manifest
for off-site shipments.
3.
Make sure shipments reach the
designated facility.
4. Package, label, mark and placard
properly.
5.
Keep records and submit reports.
EH&S
office encourages the recycling of unwanted chemicals to others within the
University who can use the material. Every effort should be made to verify that
no other use can be found for the unwanted materials. For example, lists of
unwanted chemicals can be distributed within a department, or EH&S may know
of someone who could use the material. Anyone wishing to claim the material may
do so at no cost. Because of the costs
and efforts involved in typical waste disposal, recycling is an attractive
alternative in many cases.
Redistillation
as a method to reuse some solvents is also encouraged. Large volume solvent
users may find distillation to be a suitable method of reusing materials and
reducing disposal costs. Also, methods of volume reduction to concentrate
wastes should be pursued by those generating the waste.
Any
material which is to be discarded, abandoned, or accumulated prior to recycling
is
considered
a waste. Some major categories of hazardous chemicals and potentially hazardous
waste are listed below, including examples. If you are uncertain about a
particular waste, please contact the EH&S office at X4367.
Perhaps
the most expensive and time-consuming group of potentially hazardous chemical
waste
is the unknown. If no identity can be assigned to a chemical or chemical
mixture, or it cannot be determined by process knowledge, the unknown must be
subjected to analytical procedures that can cost MSU many hundreds or even
thousands of dollars, and take several
weeks to complete. Most unknowns can be avoided by using standard laboratory protocol: Label each
container as to its content, date received or
prepared,
concentration, and the initials of the preparer. If the chemical is a
commercial
preparation,
please make every attempt to contact the original manufacturer and obtain
MSDS
sheets for the material. This could save the university much time and money.
Unknowns
should NOT be placed in storage or transported to the TAA until an analysis of
the unknown has been completed. DO NOT LEAVE ANY CHEMICALS AT THE TAA WITHOUT FIRST OBTAINING APPROVAL FROM
TSO PERSONNEL !!
Exposure
of certain chemicals to weather extremes can create dangers of fire, explosion,
or
container rupture and subsequent expensive cleanup activities along with
an environmental contamination
potential.
Chemicals
that have been abandoned, or for which ownership cannot be identified, may be
hazardous waste. If the identity of the material is not known, treat it
according to the instructions for an unknown listed above. If the chemical
identity is known, and is abandoned because of other actions or activities,
notify the EH&S at X4367 for characterization and pick-up.
Unknown or Questionable
Purity
Chemicals
with unknown or questionable purity cannot be expected to be used in either a
teaching or research capacity. While some of these chemicals may be hazardous
waste once they are characterized, others often are not, but still must be
disposed of properly. The EH&S office will assist individuals with this
task to ensure safe and environmentally sound disposal practices.
Some
chemicals have specified expiration dates which must be observed for safety and
regulatory reasons. For example, peroxidizable chemicals, some which are listed
in Appendix A, have expiration dates which should not be exceeded under any
circumstances. In addition, manufacturers often supply expiration dates on
labels of chemicals that are related to potency or even compositional changes
that occur with time. These dates should always be observed, and if they are
exceeded, the chemical declared a waste. Please contact the EH&S office for
information about chemicals which are in this category.
When
these materials are no longer useful, they may be considered waste. However,
another possibility is to recycle them by identification through the Hazardous
Material Tracking Program inventory system. Each material manager or laboratory
supervisor should attempt to determine whether a chemical they need is
available elsewhere on the campus before buying more from an outside vendor.
This will help reduce the financial
burden on both initial cost and ultimate disposal cost when it is
eventually declared a waste. Some
examples of these kinds of activities include:
1)
a PI leaves
the University
2)
lab work on
specific projects is completed
3)
the
responsibility for a lab or work area changes. Please consult with the EH&S
at X4367 concerning the fate of these chemicals and the procedures to be
followed to ensure proper closure of a laboratory or program within the lab.
Excess
stock with no likelihood of use either by their current owners, the department,
or others elsewhere on the campus, is considered waste. Careful planning when
purchasing chemicals can reduce the volume of excess chemicals that must
ultimately be managed as hazardous waste
Spent
cleaning and wash solvents are almost always considered hazardous waste,
because
either
the solvent itself or the materials which contaminate the solvent are
considered hazardous. Spent solvents from automobile, diesel, aircraft, or
other parts washers are currently recycled under a monitored program. Other
generators of spent solvents should contact the EH&S at X4367 for waste
solvent management options.
Waste
paints and stains which contain hazardous metals such as lead or chromium, or
hazardous solvents which may be flammable, must be considered hazardous waste.
Old paint cans which have hardened contents must also be presented for proper
disposal. Most water-based latex paints currently are not considered to be
hazardous, but may not be acceptable to a RCRA Subtitle D landfill. Please
consult the EH&S at X4367 for proper disposal information.
Regulation
on used motor oil and filters are subject to change. Currently, oil is
recycled, but properly drained filters are not. The State of New Jersey
regulates these items. If you have questions concerning either the regulatory
status or recycling options, contact the EH&S office at X4367.
Metallic
mercury is commonly found in calibration instrumentation such as thermostats,
thermometers, and barametric pressure equipment. Bulk quantities of metallic
mercury or mercury sulphide can usually be recycled, but articles contaminated
with mercury or its compounds must be disposed of as hazardous waste. The cost
of recycling metallic mercury is not excessive at this time, and the TSO has
collection containers for that specific use. However, cleanup of a mercury
spill from a broken thermometer generates large quantities of mercury waste,
which is very costly to dispose of. For the University, it is far less
expensive to obtain an electronic thermometer than to pay disposal costs of a
broken mercury thermometer. Do not buy any new mercury-containing equipment for
use at the university.
Mercury
compounds are currently very expensive to dispose of. Every attempt to find
alternatives to using mercury compounds should be made, as the cost per gram of
disposal is approximately 50-200 times
the purchase cost!! Do NOT buy mercury compounds if you can find acceptable alternatives. If you have mercury
compounds to dispose of, consider sulphide precipitation as a final step in
your process. Currently, mercury sulphide is the only mercury compound which is
accepted for recycling.
Older
electrical transformers often contain PCB dielectric oils. In the past, great
expense has been incurred in testing for and disposing of these fluids from
equipment that has been donated to the university. DO NOT ACCEPT DONATED ELECTRICAL
EQUIPMENT UNTIL IT HAS BEEN EVALUATED BY EH&S PERSONNEL FOR HAZARDOUS
MATERIALS!! The cost to dispose of contaminated donated equipment is very high
and does not need to be incurred if properly evaluated prior to acceptance of
the item.
Older
fluorescent light bulbs (pre-1978) usually contain PCB oils as dielectric
fluids in capacitors inside the ballast. These bulbs must be disposed of as
hazardous waste under TSCA and RCRA Subtitle D regulations. In addition, if a
ballast shows any signs of leakage without being opened, it must also be
disposed of as hazardous waste, whether it contains PCB oils or not. All bulbs
should be brought to the Physical Plant, where barrels are located for their
storage. EH&S personnel will sort them for proper disposal.
MSU
could potentially spend thousands of dollars on "free" chemicals
donated to the university, which ultimately would have to be disposed of as
hazardous waste. Do not accept any donated chemicals from any outside source
without first consulting with the EH&S. Accepting any "free"
chemicals may result in additional expense incurred to dispose of these items
properly.
These
items contain both corrosive and toxic compounds and lead, which are regulated
under RCRA and TSCA. Lead-acid batteries can be recycled and should be taken
to: Batteries are no longer accepted at
the landfill. Contact EH&S personnel at X4367 if you need assistance.
Some
special purpose battery packets contain mercury and mercury compounds, and
cannot be disposed of as normal waste or refuse. These items are normally marked as containing mercury, and should be
disposed of or recycled as hazardous waste. Please contact EH&S personnel
for assistance with these items.
These
batteries are designed to be returned to the supplier, and should not be
disposed of in normal trash. Special requirements for shipping also exist,
including documentation from the supplier. If you have lithium batteries to
return to the vendor, please contact either your department material handler or
the EH&S at X4367 for assistance.
These
rechargeable batteries should be disposed of as hazardous waste when they can no longer be recharged, or when they
begin to leak. The cadmium in them is listed as a suspected carcinogen, and
must be disposed of as regulated waste when
generated by MSU.
Spent
chemicals used in developing x-ray films and black-and-white photographic
negatives and prints contain silver compounds from dissolution of the emulsion
on print paper. These silver compounds are regulated under both RCRA and the
NJDEP pre- treatment standards, and must be recycled. The EH&S has arranged
for recycling of silver wastes through a local company. Please contact EH&H
personnel for details and listing of your develop facility in our recycling
program.
Sodium Vapor Lamps
Sodium
vapor lamps contain metallic sodium, which represents a fire and explosion
hazard when exposed to either moist air or water. These lamps should not be
disposed of in normal trash, and must not be broken. Please bring them to the
Physical Plant, where barrel storage is located. EH&S personnel will
oversee safe disposal of these lamps when sufficient quantity has been
collected.
Mercury
vapor lamps contain small quantities of metallic mercury and/or mercury
compounds that are considered hazardous waste under RCRA. These items must be
collected for proper disposal, and should not be discarded into the normal
trash. Please bring mercury vapor lamps to the ISSU Heat Plant, where a storage
barrel is located. EH&S personnel will provide proper disposal through our
hazardous waste vendors.
Fluorescent Lamps
Fluorescent
lamps disposal is regulated under RCRA because they fail the TCLP
(leachability) test for mercury. These lamps contain only small quantities of
mercury, but their disposal is currently regulated because so many wind up in
landfills. The EH&S will keep you informed of changes regulating how these
items are to be disposed of in New Jersey. At this time, do not discard any
fluorescent lamp bulbs into ordinary trash.
RCRA
requires that generators keep records verifying that hazardous wastes are
segregated, packaged, labeled, stored, transported, treated and disposed of in
accordance with regulations established by EPA, and that the hazardous wastes
are transported over the public roads in accordance with the regulations of
DOT. State law may require similar recordkeeping on applicable state hazardous
waste handling requirements.
According
to U.S. DOT regulations, any generator who transports off-site hazardous
material, including hazardous waste, is required to complete a manifest to
accompany the shipment. The manifest is used to verify the contents of the
hauler and to support containment and cleanup operations in the event of an
accident. In addition, EPA regulations specify how the shipping manifest must
be used to document the fate of hazardous wastes (40 CFR 262, Subpart B). To
satisfy EPA regulations, each class of hazardous waste generator must record on
a manifest for hazardous wastes:
·
name of
transporter
·
name and address
of treatment, storage or disposal facility
·
EPA
identification numbers
·
the
quantity of the specific contents of each waste container, including DOT
identification
·
numbers,
waste classification and proper shipping name, signatures of the person(s) at generator's
facility, transporter, and receiving facility's manager.
The
largest class of generators must file reports on hazardous waste handling
activity. The federal biennial report is a summary of generator, transporter
and disposal facility activity that must be submitted to the Regional EPA
Administrator. NJ Department of Environmental Protection requires that
generators of hazardous wastes report on hazardous handling activities
annually.
Generators
are only required to keep a copy of manifest, landban certifications, and
generator reports for three years.
There
are specific training requirements for individuals who work with hazardous
waste. These requirements are found in federal code, and specify minimum
training levels and re-certification intervals. For this reason, the people who
are designated as material handlers, laboratory supervisors, and custodial
workers must be certified to work with hazardous waste. In addition, there are
training requirements under OSHA for those who work with hazardous materials, a
much broader class of materials by OSHA definition. It is very important that
all MSU employees who work with hazardous waste and hazardous materials receive
proper training. Under OSHA, this definition will include stockroom personnel,
teaching assistants, graduate assistants, faculty, and staff, custodians,
shipping/receiving, grounds maintenance, essentially anyone who can be
considered an employee of the State by virtue of being paid from State funds.
Faculty who receive federal grant monies are already under this definition, and
should be trained.
The
Environmental Health and Safety Office provides training which meets the OSHA
Hazard Communication Standard for employees.
There
are several responsibilities common to all hazardous chemical waste generators
which must be followed. Chemical waste handling procedures, proper packaging
and labelling, and proper training in chemical safety and awareness should be
utilized including precautions appropriate to the hazard class of the chemicals
in the waste material. These precautions include as a minimum:
a)
Conduct all
operations involving chemical waste in a properly functioning chemical fume
hood
b)
Use
appropriate personal protective equipment (PPE) such as eye, face, skin and
respiratory protection whenever working
with chemical waste
c) Use secondary containment to control
the spread of any spill that may occurs in a
fume hood.
c)
Do not mix
incompatible waste streams in the same SAA or fume hood.
d)
Due to
the variety of hazardous chemical
wastes encountered, it is extremely important for waste generators to correctly evaluate, pack, and label their
hazardous chemical waste. This will help ensure the safety of all personnel who
encounter hazardous chemical waste in their work.
Hazardous
chemical waste generated in teaching laboratories should be properly packaged,
labeled and stored in a proper storage area. In accordance with departmental or
college policy, the materials manager, instructor, or teaching assistants
should be responsible for collection and management of all wastes generated by
student experiments in their laboratory. No potentially hazardous waste
materials should be left in student drawers, lockers, on bench tops, or in
chemical fume hoods. The professor and
teaching assistant should work closely with their material handler and the
EH&S office in evaluating wastes generated in their labs. If any student
preparations meet the criteria of hazardous waste, they must be prepared for
disposal within an appropriate SAA. Test tubes, vials, mason jars, open
containers and some plastic containers are often found in teaching labs, and
are not acceptable as hazardous waste containers.
The
requirements for hazardous chemical waste generation in research laboratories
is essentially the same as in teaching laboratories, except that the wastes
generated may need further characterization and analysis, depending on the starting
materials. Material Safety Data Sheets (MSDSs) for all chemicals used in a
research lab should be made available to all personnel working in that area.
Many
kinds of chemical wastes are often generated outside of either teaching or research laboratories. Most are not
regulated as hazardous wastes, but some can be dangerous, depending on their
use and properties. Be aware of the contents of chemicals, pesticides, paints, cleaners, and solvents which may
be used in your work area. If you have questions about these materials, refer
to the Material Safety Data Sheets
which should be available in your work area.
Custodial
employees must be considered when disposing of non-hazardous and hazardous
solid waste. These personnel must not encounter hazardous chemical waste in
maintaining floors, sinks, counter or bench tops, closets, or waste
recepticles. All non-hazardous chemical waste must be placed in separate
disposable containers or plastic bags and clearly labelled as non-hazardous
waste before discarding into a waste recepticles. Also, sharp items such as
broken glassware or needles need to be placed in an appropriate
"Sharps" container and labelled as such. Remember that combinations
of non-hazardous waste may turn out to be DANGEROUS to your own health and
safety.
These
employees frequently come into contact with potentially hazardous chemicals and
hazardous waste. Examples include pesticides, cleaning agents, oil-based paints
and stains, PCB oils, cylinderized
gases, and shipments of incoming chemicals. Some of these generate hazardous waste after usage. If you
work with any of these chemicals or mixtures and would like more detailed
information concerning the risks and precautions recommended for safe handling
and disposal, contact the EH&S office at X4367.
It
is important that each person who uses or is exposed to chemicals in their
environment understand the benefits and risks associated with exposure to these
materials. The use of Material Safety Data Sheets, reference texts, safety
training, work demonstrations, videos, and medical monitoring can be beneficial
for individuals who are potentially exposed to chemicals and their chemical
hazardous waste. The EH&S office strives to maintain a complete inventory
of hazardous materials located on campus, and informational data to educate the
University personnel concerning the hazardous properties.
Chemical
Purchases
There
are currently no limitations placed on ordering of chemicals by the various
departments at MSU. This poses many problems with maintaining our SQG status,
particularly regarding P-listed chemical wastes under RCRA. At present, it is a
good idea to not order chemicals which may become P-listed hazardous waste
without first notifying the EH&S. By evaluating all purchases for potential
quantities of waste generated, the EH&S office can help MSU meet the
"cradle-to-grave" responsibilities under RCRA. Appendix E contains
the list of D-listed hazardous chemical wastes, and P-listed wastes can be
found at 40 CFR 261.33. Please review these lists prior to each chemical purchase. IT IS VERY IMPORTANT THAT MSU
MAINTAIN THE SQG STATUS FOR ITS LOCATIONS!!
Since
there is no central chemical stores or specific method of effective control of
chemical purchases on the MSU campus, it is the responsibility of each person
who obtains any specific chemical or chemical mixture to obtain an MSDSs both
for themselves and the EH&S office. MSDSs can be obtained directly from the
manufacturer, and should be supplied at the same time as the original order.
The
Chemical Inventory Tracking System is designed to help all University
departments and users to track the
location of chemicals on the campus. It is expected to be fully implemented in
Fall of 2000, including the bar coding
capability. Please contact the EH&S office at X4367 for more information on
this system and its availability.
Personal Protection
Equipment (PPE)
Whenever
hazardous chemicals or hazardous waste are used by or handled in an area of the
University, proper personal protection equipment should always be used to
protect all potentially exposed personnel. This includes, but is not limited
to, safety glasses, chemical gloves, face shields, aprons, lab coats designed
to offer chemical splash protection,
and filtering face masks. The use of personal protection equipment (PPE) is
covered in Chemical Safety training offered by the EH&S office. It is
advisable to cover the use of PPE prior to initiation of activities involving
any chemicals, and to repeat the training whenever a significant change in use occurs. Please consult with the
EH&S office for assistance involving PPE.
The
Environmental Health and Safety Office
can respond to a variety of incidents which involve hazardous materials and
chemical hazardous waste. It is best to be aware of the ways of reaching both Environmental Health and Safety
Office personnel PRIOR TO an actual emergency. Emergency telephone and
emergency paging numbers are found at each facility and in the front of this
manual. Be sure you have these numbers handy in the event of a chemical spill,
fire, or other emergency. In the event of a power loss on the campus, the
EH&S office is located in College Hall room 206. Remember, what happens in
the first five minutes of an emergency will often determine the outcome. Be
prepared for safety.
Montclair State University
Office of Environmental
Health and Safety
1 Normal Avenue, Montclair, N.J. 07043, USA
(973) 655-4367
Fax: (973) 655-7837
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