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Chemical Disposal Training

Cornell University EH&S

Revised Feb 2011, Brian S.

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OBJECTIVE

What EH&S wants you to learn today…

1. What rules and regulations govern waste management

2. Cornell EH&S’s role in assisting you with your wastes

3. Types of waste – specifically hazardous wastes

4. Understanding the satellite accumulation area requirements

5. Procedures for packaging waste for removal from your work spaces

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This Training

This training is tailored to laboratories, research areas and chemical use areas across campus but most of the information is also applicable to hazardous waste management for shop areas as well

Everyone who handles materials that become “Hazardous Waste” has to know:

• How to properly contain / store it

• How to properly identify it

• How to properly get rid of it

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Chemical Waste Disposal

Laws

Federal: The Environmental Protection Agency (EPA) waste regulations • Rules for waste management are mandated by the

Resource Conservation and Recovery Act (RCRA)

State: New York Department of Environmental Conservation (DEC) waste regulations • Must be as/or more strict than Federal Regulations

• EPA will be using the NY version of the regulations

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Why Manage Chemical Wastes

Carefully?

Health and Safety Risks are Real! • Student/Staff/Faculty health & safety are #1

Our goal is to prevent:

Injury to personnel

Damage to the environment

Regulatory compliance violations

Fines to Cornell

It’s a Cornell Health & Safety Policy Requirement (University Policy 2.4)

Cost Effective

Fines and Bad Public Relations

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Result of Mixing Incompatible Wastes

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TRUE STORY Professor pleads guilty to dumping chemical

UW researcher put solvent down sink to avoid paying fee

March 8, 2007 Seattle PI

When a University of Washington professor whose work includes studying the brain, found out that getting rid of potentially dangerous chemicals in his lab would cost $15,000, he decided to find a cheaper way.

The professor in the Department of Pharmacology, dumped ethyl ether down the sink.

He pleaded guilty in federal court in Seattle to pouring the ethyl ether, which can explode or catch fire if handled improperly, down the laboratory sink in June 2006. Prosecutors say the professor then tried to cover up his actions.

He faced a possible 5 years in jail and a $250,000 fine for knowingly disposing of a hazardous waste without a permit.

He was sentenced to three years of probation, 80 hours of community service and a $5,000 fine.

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Cornell EH&S’s Role

EH&S is a technical resource that is

customer focused

EH&S is not an “enforcer” or

“police-type” function

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Cornell’s Haz Waste Program Role

• Pick up waste from your research spaces

• Provide technical advice for the proper

disposal of chemicals

• Minimize disposal costs

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Making the Waste Determination

Is it a waste / is it reusable?

• Talk to your department – others may want it

• Campus-wide surplus chemical exchange

• Chemicals and pickups are free

• Go to:

http://www.ehs.cornell.edu/chem_lab_safety/SurplusChemical.cfm

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Making the Waste

Determination (cont.)

Is it hazardous? • Review label & material safety data sheets

• Ask your Department Safety Representative

(DSR)

• EH&S Website and Chemical Waste Manual

• Contact EH&S

Is it regulated? - Is it a “Hazardous

Waste” as defined by the EPA

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Objective – Determining the

types of hazardous wastes

Is it a “Listed Hazardous Waste?”

Is it a “Characteristic Hazardous Waste?”

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It Is Regulated If . . .

It is a Listed Hazardous Waste as defined in

40 CFR 261 Subpart D & NYCRR 371

• K – Specific source wastes (none at CU)

• F – Non-Specific source wastes

• U – Commercial chemical products, toxic

• P – Commercial chemical products, acutely

toxic

• B – PCB wastes, (NYS code)

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It Is Regulated If . . .

It possesses any of the following hazardous

characteristics as defined by EPA and

NYSDEC

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It Is Regulated If . . .

Flammable examples include:

• Ethanol

• Glacial Acetic Acid

• Toluene

• Xylene

• Acetone

• Ether

• Organics w/ FP <140 F

Oxidizing examples include:

• Nitric & Perchloric Acids

• Ammonium Persulfate

• Potassium Dichromate

• Silver Nitrate

• Hydrogen Peroxide

• ending in “ate”

• beginning with “per”

It is ignitable

ignitable is defined by the EPA as having a flash point of

<140F (flammable) or promoting combustion as an oxidizer

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It Is Regulated If . . .

Corrosive acids include:

• Hydrochloric Acid

• Sulfuric Acid

• Nitric Acid

• Perchloric Acid

• Acetic/Formic/Propionic

Corrosive bases include:

• Potassium Hydroxide

• Ammonium Hydroxide

• Sodium Hydroxide

• Lithium Hydroxide

• ending with “hydroxide”

It is corrosive

corrosive is defined by the EPA as having a pH ≤2.0 or ≥12.5

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It Is Regulated If . . .

It is reactive

It is readily reactive with other chemicals, when exposed to air or water, or is shock sensitive. Will generate toxic gas, heat or may explode.

Examples include

• Hydrides

• Metal Powders, e.g. Lithium, Sodium

• Organic peroxides

• Picric acid

• Carbides

• Aromatic + Nitros

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It contains any of the following metals in any media

(salt, solution, or metal) regulated by ppm (this is not the complete Toxicity Characteristic table)

Arsenic 5.0

Cadmium 1.0

Chromium 5.0

Lead 5.0

Mercury 0.2

Silver 5.0

Selenium 1.0

Barium 100

Or…If it is a

halogenated organic

Chloroform 6.0

Chlordane 0.03

Trichloroethylene 0.5

It is regulated if…

It is toxic… as identified in 40 CFR Subpart C

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Useful or waste?

It Is Regulated If . . .you can’t use it, and

You declare it a

hazardous

waste

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Empty Containers Are Exempt

Regulatory definition of 'Empty' is less than 1% of the

original contents

Triple-rinsing empty containers:

• it is recommended that all empty containers are triple-

rinsed prior to trash disposal

• empty containers that held P-Listed chemicals must be

managed as hazardous waste; or triple rinse the empty

container and manage the rinse as hazardous waste

Other considerations

• where will the container go, who will have contact with

it, could someone be harmed

• will it smell, will warning label scare someone

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Wastes not listed or exhibiting

hazardous characteristics

In many cases if a chemical does

not meet the definition of a

regulated “Hazardous Waste”, it is

may be acceptable to dispose of it in

the regular trash or down the drain

followed by copious amounts of

water.

Radiological and biological wastes

cannot be put in the regular trash.

Contact EH&S at 5-8200 or go to

“Ask EH&S”at www.ehs.cornell.edu

if you have waste disposal

questions.

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Chemical Residue

The following materials may be disposed of in the regular trash:

Used gloves

Bench paper

Pipette tips

If you are using something acutely toxic or highly hazardous – check with EH&S

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Chemical Residue (cont.)

Used Syringes

Any syringe having a needle and requiring disposal,

must be placed in a sharps container.

Syringes without needles that were used for transferring

chemicals should be bagged or boxed and taken to the

dumpster for disposal. Do not throw used syringes in the

laboratory trash can.

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Drain Disposal Limits

Non-Hazardous chemicals acceptable for drain disposal

This is not an all inclusive list

Sugar solutions

Dilute non-toxic salts solutions and physiological saline

Inorganic phosphate or bicarbonate based buffers

Organic buffers at use concentrations

Fresh and spent supernatants rendered non-infectious

Water soluble vitamins

Surfactants in small amounts

Neutralized acids and bases with no other hazardous constituents e.g. toxic metals

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Drain Disposal Limits cont.

Chemicals Unacceptable For Drain Disposal

Hazardous Waste may not be drain disposed. It is a violation of federal law to intentionally dilute or treat a hazardous waste to render it non-hazardous without an EPA permit.

The one exception to this law is described on the next slide.

Refer to Hazardous Waste Manual for Cornell’s full policy

related to drain disposal of chemicals

(www.ehs.cornell.edu/)

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Allowed Treatment in a

Satellite Accumulation Area

Neutralization of Corrosives • only if you are comfortable doing it

5.5 to 9.5 pH for drain

• chromic acid (Chromerge) should be sent out as hazardous waste due to the chromium precipitate

Chemical Deactivation (for non-haz wastes only)

Recyclable/Reclaimable:

• metallic mercury – (shipped for recycling, not treated)

• silver in photographic wastes - campus recycling program managed by EH&S

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Waste Storage Areas

Storage Area types

90-day Accumulation (Time Limit)

Conditionally Exempt Small Quantity Generator (Geneva - Agricultural Experiment Station)

Satellite Accumulation (Volume Limit) 55 Gallons Satellite areas are regulated by volume not time

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Objective – satellite

accumulation area

This training is tailored to personnel working at

Cornell University in satellite accumulation areas

Satellite accumulation is a less burdensome option for managing small volumes of hazardous waste

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New Satellite Accumulation Signs Should Be Posted

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Satellite Accumulation Area

(SAA) Definition

EPA defines a Satellite Accumulation Area as:

• The waste containers must be at or near the point of generation

• The waste containers must be under the control of the operator of the process generating the waste.

(operator = user)

• Current strict interpretation means that a Satellite Accumulation Area = a single room

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Satellite Accumulation Area

Limitations

• Up to 55 gallons of hazardous waste

• There is no time limit until you have 55 gallons of waste

in storage

• Any excess over 55 gallons must be removed in

three days

• Facilities may have as many accumulation areas as

needed provided they are properly maintained

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Satellite Accumulation Area

Requirements

Triggers that bump you from a SAA to a 90 Day Area:

• Storing more than 55 gallons of hazardous waste for more than 3 days

• Collecting hazardous waste from other areas

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Container Labeling

Requirements

Containers must have:

the phrase “Hazardous Waste” written on them

words that identify the contents

Taping a hazardous waste label to a bottle is OK:

the phrase “Hazardous Waste” is already on the label

add contents to the label when the chemical is added

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Container (physical)

Requirements

containers must be in good CONDITION

wastes must be chemically

COMPATIBLE with the container

containers must be CLOSED except when

adding or removing waste

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Are you prepared to

convince the DEC or EPA

that this will be used?

What is this?

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ID: “Hazardous Waste” needed

What’s inside?

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Are These Waste Containers

OK?

Labeling

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Cornell’s

Hazardous

Waste

Label

“Hazardous Waste”

Contents

Hazards

Location and contact

Ready for

disposal date

450mls

Amount

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Does it need a

waste label?

Is the container

open?

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Unless adding to the

container, the cap

must be secure

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Chemical Hygiene

Properly Labeled

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Additionally…

• Storage must be in a Designated SAA

• Secondary Spill Containment

• Defacing original container labels on reused bottles

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Secondary Containment

funnels; residue

blocking hood’s flow

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Also . . . . . . . . . . Segregate by

Hazards

Isolate Reactive & Toxics

Acids from Bases

Organic acids from Oxidizing acids

Organics from Oxidizers

Hazardous Waste Spills

• Many hazardous waste spills can be safely cleaned up

by laboratory staff without the help of EH&S. Only

attempt to clean up incidental spills if you are trained and

have the proper spill cleanup materials available.

• Call 911 for hazardous waste spills outside the cleanup

capability of the area or facility personnel.

• More information on chemical spills response can be

found in Section 5.4 of Cornell’s “Laboratory Safety

Manual” at:

http://www.ehs.cornell.edu/lrs/manual/ch5.cfm#5.4

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Boxing Chemicals for Pick Up

Locations where boxes are stored will be included in the updated Waste Disposal Manual.

Assure boxes are in good condition

Full boxes must stay in the SAA when ready for transport

to 90 Day Accumulation Area

The HazWaste Specialists need to easily locate them

Give us 5-working days, then call if not serviced

UN/DOT Box

Rigid cardboard

Styrofoam inserts

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Other Types of Waste

Managed by Solid Waste Group

Fluorescent light bulbs

Rechargeable Batteries

Requirements

sturdy packaging & proper labeling

accumulation start date & 9-months on

site

Universal Waste

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Other Types of Waste Used Oil

Managed by Solid Waste Group

Requirements: Label containers with

“USED OIL”

the container capacity

Prevent any release to the environment

Do not place in normal refuse containers

Do not mix other waste with Used Oil NOTE: Used oil containing PCB’s are considered Hazardous

Waste in New York State

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Waste Computers and monitors are

separately regulated

Managed by Solid Waste Group

These are regulated because of their high

content of toxic metals such as lead

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Contaminated Waste Label

This label is

used for non

hazardous

wastes or

recyclable

materials that

require special

disposal

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Biohazard/Radioactive

Wastes

Radioactive wastes are picked up weekly

Biohazard wastes are shipped off site for

deactivation and disposal

Contact EH&S for scheduling and pick up at

255-8200, or online scheduling at,

www.ehs.cornell.edu/rad/wasteform.cfm

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Further Thoughts & Services

General Housekeeping – include upkeep of the satellite accumulation area

Discuss safety concerns with your Dept. Safety Rep.

Get to know your HazWaste & Radiation/Med. Waste Technicians

EH&S waste services

• Free and friendly service

• Assist with laboratory clean outs & waste I.D.

• Technical reference for identification & disposal

• RCRA and other laws

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Online Cornell EH&S,

MSDS & Grounds Info.

• EH&S website:

www.ehs.cornell.edu

For Chemical Waste Pick ups:

http://www.ehs.cornell.edu/rad/ChemWasteForm.cfm

MSDS URL:

http://www.ehs.cornell.edu/

Cornell Grounds Department:

www.fm.cornell.edu/fm/recycle/fmn_recycle.cfm

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Cornell EH&S and Grounds

Department Contacts:

• EH&S “ASK EH&S”

WWW.EHS.CORNELL.EDU/

255-8200, ask for Research & Safety Group

member

• Grounds Department

254-1666, recycle@cornell.edu

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THANKS