Chapter 12: Management of Laboratory Wastes
This chapter discusses the basic rules and restrictions for the accumulation, storage, and disposal of laboratory wastes. This chapter also includes a brief overview of the regulatory requirements and agencies having jurisdiction, and several waste management definitions.
The Principal Investigator (PI) for each laboratory has overall responsibility for managing the process of:
- characterizing laboratory waste
- containerizing laboratory waste
- marking/labeling laboratory waste and,
- managing laboratory waste in satellite accumulation
Prior to waste disposal confirmation and waste pickup by EHS, the Environmental Affairs Section of the EHS Department is responsible for managing the review and characterization of laboratory waste as well as the approval of laboratory waste disposal requests from the laboratory PI.
EHS personnel conduct the transfer of chemical wastes, radioactive wastes, and mixed wastes from laboratory satellite accumulation areas to the UNC Hazardous Materials Facility, or the Storage Facility for treatment (i.e., bulking) or package consolidation and managed storage prior to the transport to off-site treatment and disposal facilities.
- 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 PIs 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. PIs 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
Liquid wastes may be accumulated in glass reagent bottles compatible with the waste. If you generate a large volume of liquid waste, consider 5-gallon carboys for solvent accumulation. Filled containers of liquids must have at least ten percent headspace (roughly 1.5 liters) to accommodate thermal expansion during transport and storage.
Solid wastes may go into a double-lined cardboard box. Liners must be 1.5 mil or greater polypropylene bags. Do not use biohazard or radiation waste bags for solid waste accumulation, regular, labeled trash bags are preferred. Tie and seal each bag individually.
Ethidium bromide/Acrylamide-containing solid and semi-solid waste (e.g. used gels) is also collected in double bags within cardboard boxes. Collect liquid ethidium bromide/acrylamide materials in carboys or bottles and manage accordingly.
Reactive chemicals must be disposed of in their original shipping containers, or in containers provided by EHS.
Hydrofluoric acid presents a special hazard and must be stored in Teflon® containers or the original product containers. Refer to Chapter 6, Safe Handling of Toxic Materials, for more information about managing hydrofluoric acid waste.
Medical Waste (sometimes called biohazard waste) is defined as, “any solid waste that is generated in the diagnosis, treatment, or immunization of human beings or animals, in research pertaining thereto, or in the production or testing of biologicals.” (Medical Waste Tracking Act of 1988) Generators should place solid medical waste (other than sharps) in a container that is:
- ≤ 15-gallons (57-L),
- closable with a lid,
- labeled with the universal biohazard symbol,
- lined with a plastic bag that is:
- labeled with universal biohazard symbol
- a red colored container.
Limit the use of orange plastic bags to medical waste that must be autoclaved before disposal or incinerated. All biohazard bags must be orange in color. Red bags should not be used or ordered. For autoclaving, label the bags with heat sensitive autoclave indicator tape in an X-pattern over the biohazard symbol, and secure the bag opening with indicator tape (Figure 12-2). Do not seal the bag tightly. This will allow more steam to enter the bag during the sterilization process. Do not use biohazard bags for radioactive or hazardous waste. Disposal contractors will return drums containing biohazard bags or any other labels indicating biohazard materials, and the landfill will reject waste that contains biohazard bags that have not clearly been marked with indicator tape as autoclaved.
North Carolina medical waste regulations stipulate that autoclaves used for the treatment of medical waste be tested at least weekly with a biological indicator. Do not confuse the chemical indicator tape with biological indicators. After autoclaving medical waste, place it in the barrels marked for AUTOCLAVED or DECONTAMINATED waste (Figure 12.3). Housekeeping will empty these barrels, but will not touch or move orange bagged waste from any other locations, whether it was autoclaved or not.
For procedures on biohazard waste disposal that are more specific, refer to UNC’s Biohazard Waste Policy.
Unlabeled chemicals present a challenging, dangerous, and potentially very costly disposal problem. Hazardous waste disposal firms require certification of the waste characterization by the generator. If the generator is unable to provide this certification based on process knowledge of the chemicals in the waste, a laboratory analysis is required. Depending upon the hazard class associated with the unknown waste, the cost to sample, analyze, treat and dispose of this waste (after it has been identified) can be very significant. EHS provides periodic identification and removal of unknowns through contract with qualified hazardous waste management and disposal companies. Exercise every precaution to avoid generating unknowns in the laboratory. If you discover unknown chemicals in a laboratory, please contact the University Hazardous Materials Manager (919-962-5509) for assistance and handling information.
If you are not a Principal Investigator or Laboratory Worker, or if you wish to request waste pickup from a location other than a laboratory, choose the “Non-PI Organizations/Locations” field on the waste pickup screen. You do not need an ONYEN to request a non-lab waste pickup. If your non-lab location is not among the drop-down menu choices under “Non-PI”, contact the Hazardous Materials Manager at 919-962-5509 for further assistance.
Do not use older, paper versions of the Hazardous Materials Transfer Form. The online request is the only approved method for requesting waste pickup. The EHS website offers a tutorial for using the online e-510 waste disposal form.
Below are condensed instructions for completing the e-510 form. These instructions are specific to the PI/Registered Lab Worker portal that you must have a valid ONYEN and password to enter. However, most of these instructions also apply to non-PI/non-lab waste pickup requests. From the EHS main website, under Chemical Disposal, type in your current ONYEN and password.
- Click on the “Make New Request as PI” field under the Chemical Waste Pickup Menu.
- Next, choose the name of the faculty member responsible for the laboratory and click “submit”.
- Room and Building: Choose the building where the waste is located from the drop-down menu, and list the room number.
- Contents: Identify waste as liquid, solid, or gas. Indicate if liquid waste is aqueous solution, organic solvent, or other.
- pH value: Complete for aqueous solutions that contain corrosives (acids or bases); otherwise, enter 7 as pH.
- Mixed chemicals: Indicate whether waste generators mixed chemical constituents before (“new”) or after (“used”) use. This affects proper classification of solvent wastes and may provide a basis for waste minimization, as non-hazardous materials become hazardous waste when mixed with a hazardous waste.
- Chemical composition: List all constituents and their estimated percentages. Total must add up to 100 percent. Do not use abbreviations or chemical formulas. Include percentages of water, already listed, if any.
- Container size: List size of the waste container (gallon, liter, etc.)
- Container type: Identify the container type from drop-down menu; choose “other” if your container type is not otherwise listed.
- Weight: Net weight of the contents, in kilograms (required for regulatory purposes). We estimate that a liter of liquid weighs one kilogram.
- Number of containers: Give the number of containers of equal type, size, and contents that you want to have picked up.
- Notes: List any additional information that will assist EHS, or any special pickup instructions. For example, indicate where to find the waste in the room if the location is not obvious (e.g. refrigerator, cabinet).
After submitting your request, you will see a pickup request confirmation. If all information is correct, press the confirm button at bottom of page. You will receive an e-mail indicating that your request was received and is under review. After the Hazardous Materials Manager reviews and approves the request, you will receive a confirmation e-mail that includes a hyperlink to the Hazardous Material Transfer Form. You must print out this form and affix it to the waste container(s). This marks the waste for pickup. During the approval process, the Hazardous Materials Manager may send you an email for more information. This email will reference the identification number you received by email when you submitted the waste. Prompt replies allow your waste to be approved and the waste technicians to schedule your waste for pickup.
- Wastes that may create a fire or explosion hazard.
- Corrosive wastes with a pH less than 6.0 standard units (s.u.) or greater than 10.0 s.u.
- Solid or viscous waste s in quantities that would obstruct flow or interfere with operations.
- Heated waste discharges which could either inhibit biological activities or increase the wastewater treatment plant influent temperature to 104°F (40°F) and higher.
- Waste discharges of any toxic waste material(s) in volumes or strengths to cause interference with wastewater treatment processes, or possibly contaminate waste sludge or effluent from the wastewater treatment plant so as to violate its NPDES permit.
- Note on Biocides: Do not release concentrated solutions to the sanitary sewer. Limit disposal to one gallon of “working strength” solution per laboratory per day. This also applies to germicides and disinfectants. Pesticides and other chemicals that are persistent in the environment cannot go to the sewer.
Only neutral salts and buffer solutions may be disposed of down the sanitary drain. Do not dispose any of the following down the drain:
- acids with a pH < 6.0 s.u.
- bases with a pH > 10 s.u.
- alcohols, ethers, esters, ketones, aldehydes, amines, amides, nitriles, ethidium bromide, carbon disulfide, phenol or phenolic materials, other halogenated or non-halogenated hydrocarbons, or other chemical agents unless present as trace constituents in aqueous solution
- sodium azide containing wastes
- formaldehyde containing wastes
- solutions with heavy metals
Contact EHS at 919-962-5507 with any questions regarding this policy.
For long-lived radioactive materials, any type of hard-walled container is suitable. Refer to the UNC Radiation Safety Manual for radioactive sharps disposal procedures.
Decontaminated wastes placed into general waste must be in an autoclaved bag marked with heat sensitive tape to signal that the material has been decontaminated. State law requires biological indicator testing at least once a week. Refer to Section III of this chapter or the UNC Medical Waste Policy for specific procedures.
- Asbestos Waste
- Asbestos containing materials (ACM) containing more than one percent asbestos.
- A waste exhibits the characteristic of corrosivity if it is aqueous and has a pH < 2 or > 12.5. The EPA Waste Code for corrosivity is “D002”.
- DOT – U.S. Department of Transportation
- The DOT enforces rules involving transport of hazardous materials. All hazardous materials removed from laboratories and transported to the University’s Hazardous Materials Facility must be properly identified and packaged prior to transporting. DOT hazard classes are:
Class Name 1.1 – 1.6 Explosives 2.1 Flammable gas 2.2 Non-flammable, non-poisonous gas 2.3 Poisonous gas 3 Flammable liquids 4.1 Flammable solids 4.2 Spontaneously combustible materials 4.3 Dangerous when wet materials 5.1 Oxidizers 5.2 Organic peroxides 6.1 Poisonous materials 6.2 Infectious substances 7 Radioactive materials 8 Corrosive materials 9 Miscellaneous hazardous materials
- Empty Container
- A container that has held hazardous waste is not a hazardous waste if it is empty. A container is empty if all wastes have been removed that can be removed using the practices commonly employed to remove materials from that type of container, e.g., pouring, pumping, and aspirating, or no more than three percent by weight of the total capacity remains in the container.
- EPA – U.S. Environmental Protection Agency
- Hazardous waste must be identified, stored, recycled and/or treated and/or disposed in accord with EPA regulations. The EPA regulates all solid waste disposal including municipal landfills and sanitary sewer.
- Hazardous Materials
- A DOT term that refers to a liquid, solid, or gas which has properties requiring special handling precautions due to biological, physical, chemical or radiological characteristics.
- Hazardous Waste
- An EPA term that refers to a used and discarded hazardous material. This includes abandoned, recycled, or inherently waste-like hazardous materials. Hazardous waste is also called RCRA-regulated waste. For acute hazardous wastes, see definition of P-listed waste under RCRA-regulated Waste.
- A waste exhibits the characteristic of ignitability if it is:
- a liquid with a flashpoint of less than 60°C (140°F);
- a solid capable of causing fire through friction, absorption of moisture or spontaneous chemical changes and, when ignited, burns so vigorously and persistently that it creates a hazard;
- a flammable compressed gas; or
- an oxidizer.
The EPA waste code for ignitability is “D001”.
“Ignitable” substances include flammable liquids, flammable solids, flammable gases, and oxidizers.
- Flammable liquid is defined as a non-aqueous solution which has a flash point of less than 60 degrees C. (140 degrees F.) as measured by a Pensky-Martens Closed Cup Flash Tester utilizing a specific method.
- Flammable solid is defined as any material which is not a liquid at standard temperature and pressure, and which may ignite as a result of friction or the absorption of moisture, or which may ignite spontaneously.
- Flammable gas is defined according to 49 CFR 173.300, as “a compressed gas” in which “any one of the following occurs”:
- Either a mixture of 13% or less (by volume) with air forms a flammable mixture or the flammable range with air is wider than 12% regardless of the lower explosive limit (tested using a specified method).
- When igniting the gas at the valve, the flame projects more than 18 inches beyond the ignition source with the valve opened fully, or, the flame flashes back and burns at the valve with any degree of valve opening (tested using a specified method).
- There is any significant propagation of flame away from the ignition source (tested using a specified method).
- There is any explosion of the vapor-air mixture in a drum (tested using a specified method).
- Oxidizer is defined as “a substance such as a chlorate, permanganate, inorganic peroxide, or a nitrate, that yields oxygen readily to stimulate the combustion of organic matter.” Oxidizer is also defined as “an organic compound containing the bivalent-O-O- structure and which may be considered a derivative of hydrogen peroxide where one or more of the hydrogen atoms have been replaced by organic radicals”, unless the material is classified as an explosive, forbidden for transportation, or it is determined that the predominant hazard of the material containing the organic peroxide is other than that of an organic peroxide
- Listed Wastes
- Some wastes are organized into several different “lists” by the EPA. The F-List (40 CFR 261.31) includes non-specific source wastes. The K-List consists of wastes from specific industrial sources (full list at 40 CFR 261.32). The P-List and U-List are discarded commercial chemical products (full list at 40 CFR 261.33). Below are particular listed wastes common to laboratories.
Spent Solvents (subsets of F-Listed Waste)
- EPA Waste Code F002 – Halogenated solvents containing, before use, a total of ten percent or more of one or more of the following:
- methylene chloride
- EPA Waste Code F003 – The following non-halogenated solvents or mixtures/ blends containing only these solvents.
- ethyl ether
- methyl isobutyl ketone
- ethyl acetate
- n-butyl alcohol
- ethyl benzene
- EPA Waste Code F005 – Non-halogenated solvents containing, before use, a total of ten percent or more of one or more of the following:
- methyl ethyl ketone
- carbon disulfide
Discarded commercial chemical products, container residues, and spill residues of materials listed in Appendix 12-B are acute hazardous wastes. These wastes are “acutely toxic” or “P-listed” wastes. Note: if these materials are used (spent), they are not RCRA-regulated hazardous wastes unless they meet the definition of a characteristic hazardous waste or wastes from non-specific sources; however, they may still require disposal as a hazardous material (see definition of “non-RCRA regulated waste”).
Discarded commercial chemical products listed in Appendix 12-C are listed wastes because of toxicity (T), reactivity (R), corrosivity (C) or ignitability (I). Note if these materials are used (spent), they are not hazardous wastes unless they meet the definition of a characteristic hazardous waste or wastes from non-specific sources; however, they may still require disposal as a hazardous material (see definition of “non-RCRA regulated waste”).
- EPA Waste Code F002 – Halogenated solvents containing, before use, a total of ten percent or more of one or more of the following:
- Medical Waste
- Defined at UNC as any one of the following:
- materials contaminated or potentially contaminated during the manipulation or clean-up of material generated during research and/or teaching activities requiring biosafety level 1, 2, or 3 or animal or plant biosafety level 1, 2, or 3 (refer to your laboratory’s Biological Hazards Registration section of the Laboratory Safety Plan to identify these materials in your lab);
- human liquid blood and body fluids;
- human tissue and anatomical remains;
- materials contaminated with human tissue or tissue cultures (primary and established) because these are handled at BSL-2; and
- animal carcasses, body parts, blood, fluids and bedding from animals infected with BSL-2 and BSL-3 agents.
- Mixed Waste
- A radioactive waste that also meets the definition of a RCRA-regulated hazardous waste.
- Non-RCRA Regulated Waste
- A solid waste, other than radioactive or RCRA-regulated waste that is subject to additional EPA requirements because disposal to the sewer or the sanitary landfill is prohibited or imprudent. Wastes in this category include batteries, carcinogens, compressed gases, controlled substances, corrosive solids, infectious waste, latex paint, medical waste, mutagens, poisons, sharps, teratogens and waste oils. This includes “Universal Wastes” (see definition below).
- Radioactive Waste
- Radioactive material regulated by the North Carolina Radiation Protection Division that is to be discarded.
- RCRA-Regulated Waste
- Waste regulated under the Resource Conservation and Recovery Act (RCRA), commonly referred to as the “hazardous waste regulations”. According to RCRA definitions (40 CFR 260), a waste is a hazardous waste if it exhibits one or more of the “characteristics” of a hazardous waste or contains “listed” waste. The four hazardous waste characteristics are ignitability, corrosivity, reactivity, and toxicity.
- A waste exhibits the characteristic of reactivity if:
- it is normally unstable and readily undergoes violent change without detonating;
- it reacts violently with water;
- it forms potentially explosive mixtures with water;
- it generates gases sufficient to endanger human health;
- it is a cyanide or sulfide bearing waste that can generate toxic gases upon contact with an acid or base; or
- it is readily capable of detonation.
The EPA Waste Code for reactivity is “D003”.
- Broken glass, pipettes, scalpels, razor blades, serrated metal, hypodermic needles, slides, cover slips, capillary tubes, and any other items capable of penetrating trash bags and skin.
- Solid Waste
- Any discarded solid, compressed gas or liquid material other than domestic sewage. “Discarded” includes abandoned, recycled or inherently waste-like hazardous materials. All solid waste disposal is regulated by the EPA. Solid waste may be further classified and regulated as:
- Hazardous or RCRA-regulated waste
- Mixed Radioactive waste
- Infectious waste
- Non-RCRA regulated waste
- Medical waste
- Radioactive waste
- A waste exhibits the characteristic of toxicity if it contains any of the contaminants listed in Appendix 12-A at the concentration equal to or greater than the respective value given in that table. The Toxicity Characteristic Leaching Procedure (TCLP) is used to determine whether waste exhibits the toxicity characteristic.
- Universal Wastes
- Widely-generated wastes that are subject to the Standards for Universal Waste Management (40 CFR 273), to facilitate environmentally sound collection and proper recycling or treatment. Universal wastes include batteries, pesticides, mercury containing equipment, and lamps (fluorescent bulbs). For disposal information, contact EHS.
- Appendix 12-A: Maximum Concentration of Contaminants for the Toxicity Characteristic Leaching Procedure
- Appendix 12-B: P-Listed Wastes
- Appendix 12-C: U-Listed Wastes