Hazardous Waste Policy and Procedure

I. Overview

The Federal Resource Conservation and Recovery Act (RCRA) established the framework for hazardous waste regulation in 1976. 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 the proper waste management from “cradle-to-grave” (i.e., from purchase to disposal). RCRA regulations are found in 40 CFR 260-279.

At Georgia Southern University (GSU), all hazardous waste disposal is managed by GSU Public Safety Division’s Environmental Safety Services (ESS). Chemicals are not allowed to be disposed in drains, in the trash, or by evaporation. All hazardous waste is required to be held in the generating location for subsequent pick-up and disposal by ESS.

There are specific regulatory and GSU requirements for individuals who generate and accumulate chemical waste: minimize and recycle, properly label and identify, and properly contain and dispose chemical waste. The purpose of this document is to assist personnel who generate chemical waste with regulatory compliance. Every lab and shop on campus is subject to unannounced inspections by the Federal Environmental Protection Agency (EPA) and the Georgia Environmental Protection Division (EPD) as well as by Georgia Southern’s Environmental Safety group. Lack of compliance can result in citation and fines by the EPA and EPD.

II. Applicability

The requirements set fourth by this procedure apply to all personnel on the GSU campus to include: all contractors, employees, students, visitors, and invitees.

III. Hazardous Waste Generator Status

    GSU is classified as a Large Quantity Generator (LQG). Being a LQG means that:

  • GSU produces over 1000 kg (2,200 Lbs) per month of RCRA hazardous waste, or
  • Accumulates at any time more than 1 kg (2.2 Lbs) of acute hazardous waste, or
  • Generates in any calendar month more than 100 Kg (220 Lbs) of spill cleanup material contaminated with RCRA acute hazardous waste.
IV. Identification of Hazardous Waste

A hazardous waste is a waste that:

  • Causes, or significantly contributes to, an increase in mortality or an increase in serious irreversible or incapacitating reversible illness
  • Poses a substantial present or potential hazard to human health or the environment when it is improperly treated, stored, transported, disposed of or otherwise managed. The EPA defines hazardous waste by two different methods, characteristic wastes and listed wastes.

Characteristic Wastes

    Characteristic wastes are defined by exhibiting any of the four characteristics outlined below: ignitability, corrosivity, reactivity, and/or toxicity.

  1. Ignitability
    • A liquid with a flash point of less than 140 degrees Fahrenheit (e.g., alcohols, benzene, toluene, xylene, and acetonitrile)
    • A non-liquid capable, under standard temperature and pressure, of causing fire through friction, absorption of moisture, or spontaneous chemical changes and, when ignited, burns vigorously and persistently
    • An ignitable gas
    • An oxidizer (e.g., nitrates, perchlorates, bromates, permanganates, peroxides, and periodates)
  2. Corrosivity
    • These wastes are defined as having a pH of less than 2 (acidic), or greater than or equal to 12.5 (basic), or it can be any liquid that corrodes steel at a rate greater than 6.35 millimeters (0.25 inches) per year at a test temperature of 130 degrees Fahrenheit. (e.g., inorganic acids, organic acids, and bases).
  3. Reactivity
  4. These wastes are those defined as having the potential for dangerous reactions when exposed to atmospheric changes, air, water, or impact. Reactive hazardous wastes are defined as having any of the following properties:

    • Normally unstable and readily undergoes violent change without detonating.
    • Reacts violently with water
    • Forms potentially explosive mixtures with water
    • When mixed with water, it generates toxic gases, vapors or fumes in a quantity sufficient to present danger to human health or the environment
    • Cyanide or Sulfide bearing waste
    • Capable of detonation or explosive reaction if it is subjected to a strong initiating source (impact) or if heated under confinement. (e.g., dinitro and trinitro compounds as well as picric acid)
    • Readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure
    • Forbidden explosives (49CFR 173.5), Class A explosives (49CFR 173.53), or Class B explosives (49CFR 173.88).
  5. Toxicity Characteristic
  6. The characteristic of toxicity is determined through laboratory analysis according to the Toxicity Characteristic Leaching Procedure (TCLP). If an extract of the waste contains the contaminants listed below in concentrations designated by EPD to be hazardous, the waste is hazardous. This list consists of 8 heavy metals, 10 pesticides, and 22 organic chemicals.

Listed Wastes

    Listed wastes are identified on four lists: F, K, U and P. Materials identified on these lists are hazardous wastes by definition. Hazardous wastes found on these lists are identified by the chemical name, source, or industrial process (K-waste).

  1. “F” waste codes: Non-source specific
  2. “K” waste codes: Source specific
  3. “U” waste codes: Discarded commercial waste products
  4. “P” waste codes: Acutely hazardous discarded commercial chemical products

Acute Hazardous Waste

Definition of Acute Hazardous Waste – It has been found to be fatal to humans in low doses, or in the absence of data on human toxicity, it has been shown in studies to have an oral LD-50 toxicity (rat) of less than 50 milligrams per kilogram, and inhalation LC-50 toxicity (rat) of less than 2 milligrams per liter, or a dermal LD-50 toxicity (rabbit) of less than 200 milligrams per kilogram or is otherwise capable of causing or significantly contributing to an increase in serious irreversible, or incapacitating reversible illness. All “P” listed wastes and some “F” listed wastes are acute hazardous wastes. Any container containing an acute hazardous waste must be triple rinsed with a solvent capable of removing the acute hazardous waste from the container before it can be considered an “empty” container.

V. Hazardous Waste Accumulation

Satellite Accumulation

Once a determination has been made that a laboratory, darkroom, or other facility within the university is generating a hazardous waste, these facilities are then required to comply with EPA regulations pertaining to the accumulation, storage, labeling, and disposal of hazardous waste.

Accumulation of up to 55 gallons of hazardous waste or 1 quart of acutely hazardous waste (P listed wastes and some F listed wastes) may be performed in an area at, or near, the point of generation which is under the control of the person generating the waste. The time limit does not apply while the waste is being accumulated in this fashion. However, once the 55-gallon or 1 quart limits have been reached, the waste must be picked-up by ESS and transported to the Hazardous Waste Storage Building within 3 days or 72 hours of reaching these limits.

Hazardous Waste Accumulation Point Requirements

It is the responsibility of the Principal Investigator (PI) and his/her designee to insure that waste accumulation areas are maintained in
accordance with applicable rules and regulations. Waste can be accumulated in “Satellite Accumulation Areas” that are posted as such. The PI
must designate a Lab Waste Manager to ensure that the waste is being handled correctly on a day-to-day basis. The PI must also ensure that
everyone in the lab has read and is familiar with the below requirements.

  • All chemical containers must be properly labeled before waste is put in the container. Hazardous waste containers must be marked with the words HAZARDOUS WASTE and the chemical(s) in question. The date waste(s) were first added must be marked as well.
  • For those containers with mixtures, a breakdown of the substances by percentage or volume is required. This component is CRITICAL to proper disposal.
  • Your assistance is needed to prevent the generation of UNKNOWN CHEMICALS. Unknown chemicals are a serious safety hazard and costs for identification and disposal fees can be very high. Proper labeling, inventory and reporting, especially for those containers leaving the facility, will eliminate a great deal of this problem. Any hazardous waste container with “unknowns” will need to be characterized through laboratory analyses by the generating department. Alternatively, ESS will perform the characterization and the generating department will be debited for this analysis.
  • It is critical that every effort be made to fully and correctly identify all chemical constituents and their respective concentrations on the container labels. Incorrectly labeled containers could result in improper disposal and subsequent fines being assessed. An improper label could also cause serious and potentially fatal threats to both laboratory and ESS personnel. Hazardous Waste labels can be obtained from ESS at x 5234.
  • All hazardous wastes shall be collected in sealable containers. Foil or film closures are not acceptable. DO NOT put hazardous wastes into sinks, drains or the trash. The waste must be compatible with other wastes in the container and the type of container in which it is stored. The exterior of the container must be free of chemical contamination. Store containers of incompatible waste apart from each other (i.e., keep Oxidizers away from Flammable Solvents). Also, considers safe temperature storage requirements.
  • Containers shall be kept closed during accumulation except when adding waste to the container.
  • Choose a central area for waste storage and label with a sign saying “Satellite Accumulation Area”. This area should be at or near the process generating the waste. Keep open flame and ignition away form chemicals, especially hazardous waste and chemical containers. No smoking rules apply.
  • Do not overfill hazardous waste containers. Two inches headspace should be allowed.
  • Keep all containers properly labeled and complete all requested information (container contents, volume, etc.) for proper storage and disposal of container. Inspect waste containers weekly for leaks and proper labeling.
  • All employees working in the area must complete Right-To-Know training. All people responsible for hazardous waste in their area must complete Lab Safety training. Documentation of training must be sent to ESS.
  • Dispose of PEROXIDE FORMING CHEMICALS (i.e., Ethers, Dioxane, Tetrahydrofuran) through ESS within 6 months after date of opening or 1 year after date of receipt. Realize that certain chemicals with the passage of time can become shock-sensitive explosives. Attention to detail will save the facility a significant amount of time and money and could save someone’s life.
  • Major laboratory clean-outs must be planned well in advance of waste removal. Please coordinate these activities through ESS.
  • Radioactive materials are not handled in the same fashion as hazardous waste. NEVER MIX RADIOACTIVE AND HAZARDOUS WASTES.
  • All fires, regardless of size, must be reported to the Instructor and/or ESS at x 5234.
  • All Fire Extinguishers used for any fire or discharged to any degree must be reported immediately to the Instructor and/or ESS at x 5234.
  • All CHEMICAL SPILLS AND OR RELEASES must be cleaned up properly and safely. All spills in amounts greater than 0.5 liter or 1 pound, or of ANY acutely hazardous materials require a response from the Instructor and/or ESS. Any size spill directly to the ground or water must also be immediately reported.
  • If you have any questions, please call ESS at x 5234.
  • In the event of a FIRE call 9-911 then GSU Police at 681-5234.
  • In the event of a CHEMICAL SPILL contact Environmental Safety Services (ESS) at 681-5234.

Container Management

All hazardous waste accumulation points are required to follow proper container management practices while accumulating hazardous wastes. Proper practices are outlined below:

  • Use containers compatible with the waste collected.
  • Place only compatible wastes in the same container. Label all containers with the words “Hazardous Waste” and include the contents, identify components if a mixture.
  • Containers must be kept closed when not being filled.
  • Keep incompatible wastes separated; use secondary containment if necessary.
  • Leave at least two inches of headspace in the waste container to allow for any expansion while waste is in storage.
  • Choose a central storage area at or near the point of waste generation and mark with a sign saying “Satellite Accumulation Area”. All waste should be stored in this area.
  • Perform and document weekly inspections of containers for leaks, corrosion, bulging and proper labeling.
  • Transfer waste from leaking containers to intact ones. Contact ESS at x 5234 if assistance is needed.
  • Use appropriate personal protective equipment when handling waste.
  • The following chemical wastes must be placed in glass containers. These chemicals cannot be placed in plastic HDPE containers.
    • Amyl chloride
    • Aniline
    • Benzyl alcohol
    • Bromine
    • Bromobenzene
    • Bromoform
    • Butadiene
    • Butyric acid
    • Carbon disulfide
    • Cedarwood oil
    • Chlorinated solvents
    • Concentrated acids
    • Cinnamon oil
    • Cresol
    • Cyclohexane
    • O-dichlorobenzene
    • P-dichlorobenzene
    • Diethyl benzene
    • Diethyl ether
    • Ether
    • Ethyl chloride, liquid
    • Nitrobenzene
    • Perchlorethylene
    • Phenol/Chloroform mixtures
    • Nitric acid
    • Thionyl chloride
    • Toluene
    • Trichloroethene
    • Trichloroethylene
    • Vinylidene chloride
    • Xylene
    • Brominated & fluorinated solvent

Special precautions need to be taken when dealing with water or air reactive and explosive materials that are no longer wanted. With the passage of time, many materials become explosive hazards. Some ethers, dioxanes, tetrahydrofuran and others fall into this category as well as dry picric acid. Elemental sodium and potassium are water reactive and can cause considerable damage if they come in contact with water. White phosphorus is spontaneously combustible in air and can also cause extreme damage and injury. These are just a few of many hazards that can be found on campus and research labs. If you find any of these materials, DO NOT MOVE THEM. Call ESS at (921) 681-5234.

Special Wastes

  1. Gas Cylinders-Generators should attempt to establish accounts with suppliers who will allow the return of unused product and empty cylinders. Generators must ensure that aging cylinders are picked up by ESS before the integrity of the valve and cylinder is compromised. The department may be billed directly for cylinders that require special handling and disposal procedures such as unknown or old cylinders.
  2. Peroxide Formers-Must be picked up by ESS within six (6) months after date of opening or one (1) year after date of receipt. Common peroxide formers are ethyl ether, ethylene glycol dimethyl ether (vinyl ethers, isopropyl ether, potassium metal and sodium amide).
  3. Ethidium Bromide-Concentrated stock solutions must be handled by ESS as a hazardous laboratory waste. The rinsate and destained gels can be placed down the sink and into the trash.
  4. Reagents-The following reagents contain mercury and should be handled as hazardous waste:
    • Dobbin’s Reagent
    • Millon’s Reagent
    • Hayem’s Solution
    • Hopkins-Cole Reagent
    • Nessler’s Reagent
    • Hubb’s Reagent
    • Rohrbach’s Solution
    • Tyrosine Reagents
    • Jacquemart’s Reagent
    • Sachsse’s Solution
    • Knapp’s Solution
    • Spiegler’s Reagent
    • Mercresin
    • Tanret’s Reagent
    • Meyer’s Solution

    Other hazardous reagents include: Flemming’s Solution (osmium, chromic acid), Folin-Dennis Solution (mercuric cyanide), Fisher’s Reagent (phenyl hydrazine), and Erlicki’s Solution (chromium).

  5. Dinitro and Trinitro Compounds-These compounds must be picked up by ESS before the contents have dried. Some are potentially shock sensitive when the moisture content is less than 10 percent. Picric acid is a common example of this type of compound.
  6. Photochemical-If a silver recovery unit is not used, ESS must handle the fixer. No concentrated photo chemicals of any kind can be placed in the trash or sink.
  7. Used Oil-All vacuum pump oil, synthetic oil, transmission and brake fluids, lubricating greases, etc. must have the words “Used Oil” on the container.
    • Keep containers and tanks in good condition. Don’t allow tanks to rust, leak, or deteriorate. Fix structural defects immediately.
    • Never store used oil in anything other than tanks and storage containers. Used oil may also be stored in units that are permitted to store regulated hazardous waste. Tanks and containers storing used oil do not need to be RCRA permitted, however, as long as they are labeled and in good condition. Storage of used oil in lagoons, pits, or surface impoundments that are not permitted under RCRA is prohibited.
    • Don’t mix used oil with anything.
    • If there is a spill:
      1. Call ESS at 5234 for assistance.
      2. Take steps to prevent leaks and spills. Keep machinery, equipment containers, and tanks in good working condition and be careful when transferring used oil. Have sorbent materials available on site.
      3. If a spill or leak occurs, stop the oil from flowing at the source. If a leak from a container or tank can’t be stopped, put the oil in another holding container or tank.
      4. Contain spilled oil. For example, containment can be accomplished by erecting sorbent berms or by spreading a sorbent over the oil and surrounding area.
      5. Clean up the oil and recycle the used oil as you would have before it was spilled. If recycling is not possible, you first must make sure the used oil is not a hazardous waste and dispose of it appropriately. All used cleanup materials, from rags to sorbent booms, that contain free-flowing used oil also must be handled according to the used oil management standards. Remember, all leaked and spilled oil collected during cleanup must be handled as used oil. If you are a used oil handler, you should become familiar with these cleanup methods. They may also be part of a spill response action plan.
      6. Remove, repair, or replace a defective container or container immediately.
  8. Universal Waste
    • Batteries – Alkaline batteries can be disposed of in the trash. Other batteries which contain hazardous metals such as mercury, lead, silver, and cadmium must be handled by ESS.
    • Mercury Containing Devices – Many types of equipment contain elemental mercury. Equipment must be free of mercury devices before it is recycled or discarded.
    • Examples Include:

      • Heating and air conditioning thermostats
      • Tilt switches used in silent light switches, washing machine lids, chest type freezers
      • Pressure gauges, displacement / plunger relays
      • Flow meters
      • Sump pump float switches
      • Thermometers, monometers
      • Fluorescent Lights containing mercury
      • Mercury containing devices must be disposed of by ESS.

    • Agricultural Pesticides – Pesticides that have been recalled or banned from use, are obsolete, have become damaged, or are no longer needed due to changes in cropping patterns or other factors. They often are stored for long periods of time. These pesticides must be disposed of by ESS.
  9. Empty Container Rule
  10. CFR 261.7 Residues of hazardous waste in empty containers.

    1. Any hazardous waste remaining in either
      • an empty container or
      • an inner liner removed from an empty container, as defined in paragraph (b) of this section, is not subject to regulation under parts 261 through 265, or part 268, 270, and 124 of this chapter or to the notification requirements of Section 3010 of RCRA.
    2. Any hazardous waste either
      • a container that is not empty or
      • an inner liner removed from a container that is not empty, as defined in paragraph (b) of this section, is subject to regulation under parts 261 through 265, and parts 268, 270, and 124 of this chapter and to the notification requirements of Section 3010 of RCRA.
    3. A container or an inner liner removed from a container that has held any hazardous waste, except a waste that is a compressed gas or that is identified as an acute hazardous waste listed in 261.31, 261.32, or 261.33(e) of this chapter 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, and
      • No more than 2.5 centimeters (one inch) of residue remain on the bottom of the container or inner liner, or
        1. No more than 3 percent (3%) by weight of the total capacity of the container remains in the container or inner liner if the container is less than or equal to 110 gallons in size, or
        2. No more than 0.3 percent (0.3%) by weight of the total capacity of the container remains in the container or inner liner if the container is greater than 110 gallons in size.
          • A container that has held a hazardous waste that is a compressed gas is empty when the pressure in the container approaches atmospheric.
          • A container or an inner liner removed from the container that has held an acute hazardous waste listed in 261.31, 261.32, or 261.33(e) is empty if:
          • The container or inner liner has been triple rinsed using a solvent capable or removing the commercial chemical product or manufacturing chemical intermediate;
          • The container or inner liner has been cleaned by another method that has been shown in the scientific literature, or by tests conducted by the generator, to achieve equivalent removal, or
          • In the case of a container, the inner liner that prevented contact of the commercial chemical product or manufacturing chemical intermediate with the container has been removed.
VI. Spill Control Procedures

All areas generating hazardous wastes must have spill control measures in place to deal with minor non-emergency type spills. Spill kits should be readily accessible to those working in the area. Only minor, non-emergency spills may be cleaned up by those working in the area. Minor non-emergency spills are limited to those spills of non-acutely hazardous materials of less than 500 milliliters in volume or 1 pound in weight. If a minor spill occurs, use the following procedures:

  • Secure area, notify supervisor and others.
  • Consult MSDS, determine if the spill can be managed.
  • Assemble spill control equipment.
  • Don the appropriate personal protective equipment
  • Absorb and containerize the spilled material
  • Label the container with: The contents of the container, the words “Hazardous Waste”, and the accumulation start date.
  • Store spill container with other compatible hazardous waste.

All spills should be reported to the designated safety manager. Always call ESS at x 5234 concerning any questions you have regarding a spill or in the event the amount spilled is greater than those listed above, or of any acutely hazardous materials are spilled. Any size spill directly to the ground or water must be immediately reported to ESS.

VII. Waste Pick-up Procedures
  1. Fax your completed Hazardous Materials Pickup Inventory to ESS at 681-0806 for a chemical waste pick-up. Large inventories may be sent through campus mail
  2. Containers must be labeled “Hazardous Waste” and include an exact and complete list of chemicals (no abbreviations or chemical formulas) in the container(s), amounts, and total weight or volume of chemicals.
  3. Direct ESS to the Satellite Accumulation Area when they arrive to pick up the waste. When chemicals are picked up, you will be asked to sign the pick-up request.
VIII. Waste Minimization

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 GSU. There are two methods of waste minimization:

A. Source Reduction

The most desirable method of waste minimization is source reduction. This is any activity that reduces or eliminates the generation of chemical hazardous waste at the source. Good materials management, substitution or less hazardous materials, and good laboratory procedures can accomplish this. Examples include:

  • Date chemical containers when received so that older ones will be used first.
  • Purchase chemicals in the smallest quantities needed.
  • Label ALL chemical containers to prevent the generation of unknowns.
  • Avoid the use of reagents containing arsenic, barium, cadmium, chromium, lead, mercury, selenium and silver.
  • Eliminate the use of chromic acid cleaning solutions altogether, and use non-hazardous solutions such as Alconox.
B. Recycling

The second most desirable approach is recycling. When a waste material is used for another purpose, treated and reused in the same process, or reclaimed for another process, it is considered recycling. Examples include:

  • Purchase compressed gas cylinders only from manufacturers who will accept empty cylinders.
  • Do not contaminate used oil with solvents because this prevents the oil from being recycled.
  • Recirculate unused or excess chemicals within the department.
  • Return excess pesticides to the distributor.
IX. Hazardous Waste Storage Time Limitations

All hazardous waste generators have a time limit on how long hazardous waste can be stored once it is designated hazardous waste. For SQGs there is a 180-day accumulation storage limit for designated hazardous waste. After 180 days of storage by the SQG the hazardous waste must be sent to a permitted treatment, storage, and disposal facility.

X. Short List of Incompatible Materials

This is not a complete list of incompatible materials. It contains some of the more common incompatible materials. Always research the material you work with to be safe.


such as calcium, potassium and sodium with: water, carbon dioxide, carbon tetrachloride and other chlorinated hydrocarbons.
with: chromic acid, nitric acid, hydroxyl containing compounds, ethylene glycol, perchloric acid, peroxides and permanganates.
with: concentrated sulfuric acid and nitric acid mixtures.
with: copper (tubing), fluorine, bromine, chlorine, iodine, silver, mercury or their compounds.
with: mercury, halogens, calcium hypochlorite or hydrogen fluoride.
with: acids, metal powders, flammable liquids, chlorates, nitrates, sulfur and finely divided organics and other combustibles.
with: nitric acid, hydrogen peroxide or other strong oxidizing substances.
with: ammonia, acetylene, butadiene, butane, hydrogen sodium carbide, turpentine or finely divided metals.
with: ammonium slats, acids, metal powder, sulfur, carbon, finely divided organics or other combustibles.
with: acetic acid, naphthalene, camphor, alcohol, glycerine, turpentine and other flammable liquids.
with: ammonia, acetylene, butadiene, benzene and other petroleum fractions, hydrogen, sodium carbides, turpentine and finely divided
with: acids.
with: copper chromium, iron, most metals and their respective salts, flammable liquids and other combustible materials, aniline and
with: nitric, acid, oxidizing gases.
generally, with fluorine, chlorine, bromine, chromic acid or sodium peroxide.
with: ammonia or acetylene.
with: acetylene, fluminic acid or hydrogen.
with: acetic, chromic or hydrocyanic acids, aniline, carbon, hydrogen sulfide, flammable liquids or gases or other substances which
are readily nitrated.
with: oils, greases, hydrogen flammable liquids, solids or gases.
with: silver or mercury.
with: acetic anhydride, bismuth and its alloys, alcohol, paper, wood and other organic materials.
with: water.
with: glycerine, ethylene glycol, benzaldehyde or sulfuric acid.
with: any oxidizable substance, for instance: methanol, glacial acetic acid, acetic anhydride, benzaldehyde, carbon disulfide, glycerine, ethylene glycol, ethyl acetate, furfural, etc.
with: chlorates, perchlorates.

Last updated: 3/28/2014

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