Hazardous Waste Inspections – Lids, Leaks, Labels, and Location
The management and storage of hazardous waste is subject to regulatory compliance obligations. The University is regularly audited and inspected for compliance with these regulatory compliance obligations by the NC Department of Environment and Natural Resources Division of Waste Management (NCDENR DWM) and the U.S. Environmental Protection Agency (EPA) Hazardous Waste Section. Hazardous waste located in managed storage locations at University laboratories are known as “satellite accumulation areas” in the regulations and are subject to regulatory compliance obligations including:
- Waste containers stored at or near the point of generation (Location)
- Waste quantities limited to not more than 55-gallons of hazardous waste or 1-quart of acutely hazardous waste (Limits)
- Waste container(s) managed under the control of the operator
- Waste containers in good condition with no leaks (Leaks)
- Waste must be compatible with container
- Waste containers must be kept closed (Lids) when not adding waste
- Waste containers must be marked with the words “Hazardous Waste” or other words that identify the content of the container (Labels)
The Environmental Affairs Section of EHS is responsible for managing the regulatory compliance obligations associated with managing hazardous waste at the University. The laboratory PI’s are responsible for identifying and submitting laboratory waste for waste pickup approval by the Environmental Affairs Section and managing the hazardous waste stored in satellite accumulation areas prior to waste pickup for transport and disposal.
Hazardous waste managed within satellite accumulation areas at University labs must meet regulatory requirements for containerization, marking/labeling, secondary containment (liquids), and managed control of the waste and limits for waste accumulation as outlined above. When a waste is generated, a determination is made to distinguish whether the waste is a hazardous waste, a radioactive waste, or a mixed waste (hazardous and radioactive). Once the determination has been made as to the waste classification, the waste is then containerized in a compatible waste container and the waste container is marked/labeled with the waste contents. For example, a waste solvent containing a 50/50 mixture of methanol and chloroform would be marked with the words, Waste Methanol and Chloroform Solvent. The marking must be descriptive as to the waste contents and clearly marked on the outside of the waste container.
When the waste container is close to becoming full, an e-510 waste form should be electronically completed and submitted to EHS for proper classification and arrangements for pick-up will then be made. The EHS Environmental Affairs, Hazardous Materials Manager reviews and, if correctly submitted, approves the waste pick up request and issues an e-501, Waste Pickup Approval Form. The PI, or responsible laboratory employee, will receive the approval form via email. The approval form must be printed and attached to the waste container. EHS Environmental Affairs hazardous materials technicians will pick up the approved waste from the satellite accumulation location within 10 business days. PI’s should ensure that the e-501 form is attached to the waste container(s) to be picked up and that the satellite accumulation areas in the laboratory are accessible to EHS personnel when they arrive.
To summarize the waste storage requirements when managing hazardous waste in satellite accumulation, remember the 5 Ls, i.e., Lids, Leaks, Labels, Location and Limits:
- Keep lids or caps securely in place and tight except when you add materials. A funnel resting on the mouth of a bottle is not a lid; neither is Parafilm®.
- Be sure that gas-producing reactions (e.g. organics in acids, water-reactive metals in aqueous solution, etc.) have worked to completion before transferring the material to a hazardous waste container.
- A properly closed container, when tipped over, will not leak.
- The lid that came on the container is the best one for that particular bottle. EHS suggests keeping the lids from all bottles that will be recycled or discarded.
- Secondary containment is required for all glass containers of liquid hazardous materials (including waste) stored on the floor.
- Secondary containment is also required for all containers of liquid hazardous waste, with capacity of 4 liters or less, regardless of storage location.
- Hazardous waste regulations require the words “Hazardous Waste” on waste containers, OR words which identify the contents (e.g. “Acetone Waste”). EHS provides labels that can be printed out on the EHS website.
- Hazard communication regulations require clear identification of the chemical(s). Abbreviations such as H2SO4, HCl, EtBr, EtOH, etc. are not acceptable on the label or the E-510 form.
- You must keep the waste container(s) at or near the point of generation and under control or supervision of the individual directly responsible for the waste-generating process. Do not store wastes in a separate room or down the hall.
- Limit of 55-gallons (208 liters) of hazardous waste in a satellite accumulation area
- Limit of 1-quart (0.95 liters) of acutely hazardous waste (P-Listed hazardous waste) in a satellite accumulation area