This guide has been designed to assist the students, staff and faculty of the University of North Texas (UNT) in the safe and economical management of hazardous waste. Risk Management Services (RMS) coordinates all facets of hazardous waste management in accordance with state and federal regulations, including the identification of hazardous wastes, hazardous waste storage and disposal, and hazardous waste minimization.
The university community plays a vital role in the management of hazardous wastes at UNT. Proper waste management is dependent upon your day-to-day handling of these wastes in your lab or worksite. Please read this guide carefully and feel free to call (940) 565-2109 if you have any questions.
The framework for hazardous waste regulation was established in 1976 by the Federal Resource Conservation and Recovery Act (RCRA). RCRA was enacted by Congress to protect human health and the environment from improper management of hazardous waste. RCRA introduced the concept that the generator of a waste is responsible for proper waste management from "cradle-to-grave" (i.e. from the laboratory to the waste's ultimate destruction). RCRA regulations may be found in 40 CFR Parts 260-279.
Hazardous chemicals are not allowed to be disposed of in drains, in the trash, or by evaporation. All chemical waste is required to be held in the generating location for subsequent pick-up and disposal by RMS.
There are specific regulatory requirements for the individuals who generate and accumulate chemical waste. These individuals must properly identify and label all hazardous wastes in their workplace. They must properly store and submit requests for disposal of chemical wastes. Finally, they must minimize the amount of waste generated and recycle whenever possible. The purpose of this document is to assist labs and shops with this regulatory compliance. Every lab and shop on campus is subject to unannounced inspections by both the Federal Environmental Protection Agency (EPA) and the Texas Commission on Environmental Quality (TCEQ). Lack of compliance can result in citations and fines.
The regulatory requirements covered in this document include:
- identification of hazardous wastes
- labeling of hazardous waste containers
- accumulation of hazardous wastes
- disposal of hazardous wastes
Our Waste Management System
The success of our hazardous waste management program depends on your cooperation. You should use this management guide to identify hazardous wastes and determine their appropriate route of disposal.
There are three routes of disposal for waste chemicals:
- Management by RMS – You may request a pickup using the online form.
- Disposal of non-hazardous materials into the normal trash or sanitary sewer; and
- Chemical treatment, such as neutralization, followed by disposal into the sanitary sewer system. Note: Any treatment method other than neutralization must be incorporated into an experimental procedure to be considered legal.
When your surplus chemicals are given to RMS, we determine the degree of hazard and the appropriate disposal route. Throughout this process, the university is required to keep records that account for hazardous wastes "from cradle to grave."
Most of your waste will likely need to be handled by RMS; we determine the degree of hazard and the appropriate disposal route. Throughout this process, the university is required to keep records that account for hazardous wastes "from cradle to grave." Waste that can go to the sanitary sewer or be placed in the normal trash is limited due to safety, environmental and legal considerations. If in doubt, it is prudent to have RMS characterize your waste and determine how it should be managed.
Hazardous Waste Minimization
The Resource Conservation and Recovery Act (RCRA) outlines proper hazardous waste management, placing special emphasis on waste reduction and recycling. Waste minimization is any action that reduces the amount and/or toxicity of chemical wastes that must be shipped off-site for disposal as hazardous waste.
The success of any waste minimization program is dependent on the conscientious participation of every individual at the University of North Texas. Through waste minimization, you can help reduce unnecessary expenditure of university funds (and ultimately your department's funds) on waste disposal and material procurement. These are some general guidelines for minimizing waste:
- Inventory your chemicals: The most important step you can take toward waste minimization is to maintain a running inventory of chemicals present in your lab. An inventory will prevent you from ordering more of what you already have. It also helps you to store chemicals properly and can be an invaluable tool in emergency situations.
- Order only what you need: Don't buy a kilogram of material when you plan to use only a few grams. The economy of larger sizes may be offset by the cost of disposing of your excess. Before ordering chemicals, check your current stock; and it may be possible to borrow small amounts of chemicals from other labs. Please take the time to check.
- Use recycled chemicals whenever possible: Before you call RMS for disposal of your unwanted but usable chemicals, please check to see whether other labs in your building can use the material. You should contact other labs for chemical availability before ordering, as well.
- Substitute non-hazardous or less hazardous materials: There are many non-hazardous substitutes for commonly used chemicals, such as chromic acid (see Appendix A). Other alternatives may be much less toxic. These substitutions can be done with satisfactory results in most cases.
Participating in waste minimization practices reinforce our commitment to being an increasingly "green" campus. Additional guidance for reducing waste can be found in Appendix H.
Identifying a Hazardous Waste
Waste: A material/chemical that has no intended use or reuse, including chemicals and materials from a spill clean-up.
Hazardous Waste: A waste that is EPA listed, possesses one of the EPA's hazardous characteristics, or is determined to be hazardous by review of the material's SDS or other source.
The requirements described in this guide do not apply until a material becomes a waste. From a regulatory perspective, a waste is something that is spent, has no further use, or no intended use. A determination must be made for every waste generated at the University of North Texas as to whether or not the waste should be considered a hazardous waste. A waste is determined to be hazardous by one of three means:
- It is on one of the EPA's four published lists of hazardous chemicals.
- It meets the definition of at least one of the EPA-defined characteristics of toxicity, ignitability, reactivity, or corrosiveness.
- The waste's generator, utilizing some outside source of information (SDS, manufacturer's website, etc.) determines that the waste should be treated as hazardous.
Many chemicals which are not listed by the EPA and do not possess a characteristic of a hazardous waste are nonetheless hazardous. Concentrated solutions of Ethidium Bromide are an example. Consult the product's SDS or other product information prior to disposal. If you are ever unsure of a waste's characteristics, contact RMS so that a waste determination can be made.
Waste Accumulation Requirements
It is the responsibility of the Principal Investigator (PI) and his/her designee to ensure that waste storage areas are maintained in accordance with applicable rules and regulations. Hazardous waste can be accumulated as long as necessary, but no more than 1 quart or 1 kilogram of an acutely hazardous waste (P-Listed Waste) may be accumulated at one time. Empty containers that once contained a P-listed waste must be triple rinsed prior to disposal, but the rinsate does not have to be handled as a hazardous waste. P-listed wastes are identified in Appendix B with bold print and an asterisk.
All waste containers must have at least one (1) inch of headspace to allow for expansion. The exterior of the container must be free of chemical contamination. Leaking or overfilled containers must be repackaged before they will be transported by ES.
A Hazardous Waste label should be affixed to any hazardous waste. Original labels are acceptable, as long as they are also clearly marked 'HAZARDOUS WASTE.' Click here for examples of proper labeling.
Incompatible chemicals must not to be placed in the same container. This list indicates waste streams that should be segregated. When placing a chemical into the waste container, consider venting to prevent over-pressurization resulting from any abnormal reactions.
It is vital that chemical waste be compatible with its container. If the waste is placed in an inappropriate container, the container might disintegrate or rupture. The chemical wastes on this list must be placed in glass containers.
A spill kit must be accessible to all lab personnel. The spill absorbent or neutralizer must be appropriate for the spilled chemical.
Do not hold unneeded chemicals or waste. Dispose of these promptly to ensure regulatory compliance and to maintain a safe workplace.
The hazardous waste container must be clearly labeled as Hazardous Waste, and should include the contents and percentage of hazardous waste if it is in a solution. Containers with original product labels are acceptable if clearly labeled as Hazardous Waste.
These examples illustrate properly completed labels:
Handling Specific Wastes
Certain wastes generated at the University have special handling or labeling requirements. Examples are:
- Pharmaceutical waste
- Gas cylinders
- Peroxide formers
- Dinitro and trinitro compounds
- Ethidium bromide
- Common-named reagents:
- Used oil
- Spilled Materials
Universal Wastes are EPA regulated wastes, but are not Hazardous Wastes if properly recycled. They include spent batteries, certain types of lamps and mercury containing devices or equipment. All universal waste containers must be labeled clearly with the appropriate label when waste is first added.
Clean Glassware Disposal
The University of North Texas employs a cost saving process for the disposal of clean labware and glassware. All glassware and labware that has not been contaminated by chemicals listed in Appendix B or in the toxicity list of Appendix C, may be disposed of in the normal solid waste (trash).
For a container to be thrown away it must be completely empty and rinsed. To avoid confusion, any original labels should be removed or defaced. Then place the container in a cardboard box lined with a plastic bag. On the outside of the box, write the words "Clean Glassware", and the room number.
You can place this box outside your lab's door and the custodial staff should remove it for you, or you may take the box to the nearest solid waste container or dumpster.
You may not dispose of sharps containers, red bags, or anything with the biohazard symbol on it in this manner. Also, tissue culture and biological labware may not be disposed of in this manner.
Chemical Waste Pick-up Procedures
In order to have hazardous waste picked-up from your accumulation area, submit a Hazardous Materials Pickup Request, available online at https://riskmanagement.unt.edu/riskman/index.php?section=hazmatpickup. Complete only one request form for large chemical waste pickups. If there are numerous chemical wastes to be picked up, list all of the chemicals on the same request form.
Provide as much information about the contents of each container as possible. As a minimum, the chemicals' names, the number of containers, and the total weight or volume should be listed.
Spill Response and Management
If there is an immediate danger to health, life, property, or risk of an environmental release, evacuate the area and contact ES and emergency personnel immediately at 565-2109. All spills occurring after normal working hours should be reported to the University Police Department (UPD) at 565-3000. A UPD representative will contact ENVM if necessary.
Each laboratory should have a spill kit. In the event of a spill which does not meet the above criteria; stop the spill, contain the spill, notify others in area, and clean up immediately. All flames should be extinguished and spark-producing equipment turned off. All non-essential personnel should be evacuated.
After cleaning up the spill, place the chemical and absorbents in a container with a Hazardous Waste label on it. A Chemical Waste Pickup Request form should be submitted, as in other waste disposal. Ensure that the Hazardous Waste label identifies the absorbent and the chemical(s).
Mercury Spill Clean-up Procedures
This policy outlines the actions that shall be taken in responding to elemental mercury spills. Simple spills should be managed and cleaned up by the lab or area creating the spill, and are discussed in this section. More complex spills are evaluated by Environmental Health and Safety to determine whether spill clean-up by ES personnel or by an outside contractor. Procedures for complex spills are discussed in this section.