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ENVIRONMENTAL SAFETY

Office of Central Facilities and Public Safety

Hazardous Waste

Introduction

There are many sources of hazardous waste at Montgomery College. A generator can be an individual, a department, or a College campus. Areas at the College that generate hazardous waste include laboratories, art and photography studios, swimming pools, print shops, automotive maintenance areas, paint shops and other facilities. The Safety Office (MC–ES) is responsible for coordinating hazardous waste disposal through outside contractors in accordance with all Federal and State regulations. However, responsibility for hazardous wastes cannot be sold or transferred, even by contract. Moreover, liability for improper hazardous waste disposal can apply both to individuals, supervisors and employers. EPA regulations make improper disposal, whether intentional or accidental, punishable by fines and/or imprisonment.

Scope and Application

The hazardous waste program applies to anyone at the College who generates hazardous waste. It provides guidelines for the proper handling, storage, labeling, and packaging of hazardous wastes prior to their pickup for disposal. It does not cover the special category of infectious waste, for which a separate safety program exists.

Program Description

Who Regulates Hazardous Waste?

Federal and State Environmental Protection laws determine what can be discharged into the air, the water, and the land. Three federal agencies and two state agencies administer these regulations. The Environmental Protection Agency (EPA) has two major programs that address the disposal of hazardous waste: the Resource Conservation & Recovery Act (1976), known as RCRA, and the Comprehensive Environmental Response, Compensation & Liability Act (1980), known as CERCLA. In addition, certain waste materials and waste-generating processes are regulated through other EPA programs — TSCA, FIFRA, CWA, and CAA. (Links to these regulations can be reached from our "EPA Regulations" page.)

Maryland Department of the Environment (MDE) enforces EPA regulations, as well as additional State regulations regarding waste disposal. The Department of Transportation (DOT) regulates the transportation of hazardous materials and waste. Finally, the Occupational Safety and Health Administration (OSHA) specifies standards for response to hazardous chemical emergencies, which are enforced by Maryland Occupational Safety and Health (MOSH).

What is a Hazardous Waste?

Hazardous Waste (HZW is any material that is to be discarded AND contains certain regulated components or is flammable, corrosive, reactive and/or toxic to the environment. These characteristics are defined in 40 CFR Part 261.22 as follows:

  • Flammability – A liquid (other than an aqueous solution containing less than 24% alcohol by volume) with a flash point of less than 60o C (140o F) as determined by a Pensky-Martens closed cup tester using ASTM method D-93-70 or D-93-80; or it is not a liquid and is capable under standard temperature and pressure of causing a fire; or it is an ignitable compressed gas; or it is an oxidizer.
  • Corrosivity – An aqueous waste having a pH </= 2 or >/= 12.5; or a liquid that corrodes steel as described in 40 CFR Part 261.22.
  • Reactivity – A material that is normally unstable and readily undergoes violent change without detonating; or reacts violently with water; or forms potentially explosive mixtures with water; or when mixed with water, generates toxic gases, vapors or fumes; or a cyanide or sulfide bearing waste that generates toxic gases, vapors or fumes when exposed to pH conditions between 2 and 12.5; or is capable of detonation or explosive reaction.
  • Toxicity – Using the test procedure specified in 40 CFR Part 261.24, an extract of the material contains one or more constituents at concentrations in excess of those specified in Table I of 40 CFR Part 261.24. (These are heavy metals or specific organic compounds that could be released into ground water.)
  • Listed Wastes – The EPA and MDE have identified several hundred chemicals and solid wastes by name as hazardous. If your waste appears on any these lists, it must be handled as hazardous waste. (See "EPA Links" below to view these lengthy documents.)

If you are not certain whether a particular waste is hazardous, contact the College's Environmental Safety Manager for assistance.


 

Policies and Procedures

General Guidelines

All College personnel who generate or dispose of regulated wastes have the following responsibilities:

  1. Select chemicals carefully and know the hazards associated with each and how to handle and store them safely. This information can be found on the Material Safety Data Sheet (MSDS) that is required for every hazardous material.
  2. Purchase only amounts that you expect to use in the foreseeable future. The cost to dispose of an unused chemical often exceeds the purchase price by a substantial amount.
  3. Follow the College waste minimization program. Investigate alternative materials and, if feasible, scale back experiments or other activities to use the smallest amount of hazardous materials possible.
  4. Develop a Standard Operating Procedure for identifying, segregating, collecting, and labeling all hazardous wastes.
  5. Contact MC–ES for guidance. MC–ES will help you to determine if a waste is hazardous and will provide information on appropriate storage containers for your hazardous waste.
  6. Dispose of hazardous wastes within the legal time limit. Contact MC–ES early to be included in the next regularly scheduled pickup.

Packaging and Storing Hazardous Waste

Universal Procedures:

  1. Keep the waste in closed containers that are compatible with their contents. (No hydrofluoric acid in glass, for example.) Often the original container is fine. Containers must remain closed except when adding waste. (Do not leave funnels in the containers between additions!) Finally, do not overfill containers - allow some headspace for expansion of the contents. Use appropriately sized containers.
  2. Properly label the container with the following:
    1. The words "Hazardous Waste."
    2. The name(s) of the material(s) included in the waste. The name of a particular material may be:(1) the process that created the waste  (e.g., "Waste acid from copper etching" or "Waste products from Experiment X"), or (2) the manufacturer's name and product number (e.g., "Ace Cleaner #199"), or (3) the known components of mixtures (e.g., "10% battery acid" or "50% antifreeze/water").
  3. Do not mix solid and liquid waste.
  4. Do not dilute wastes.
  5. Do not mix waste chemicals without prior approval from the Environmental Safety Manager. Even though the chemicals may be compatible, the cost to dispose of the mixture may be higher than for its component parts. However, if you routinely generate substantial quantities of compatible solvents, contact the Environmental Safety Manager about bulking the waste, as this could provide significant savings to the College.
  6. Do not mix heavy metal solutions with any organic solvent or solution.
  7. Do not pour halogenated and non-halogenated organic solvents into the same container.
  8. Avoid placing wastes from incompatible hazard classes in the same container (e.g., flammables with oxidizers). Some metals also cause problems when mixed with flammable liquids or other organic liquids.
  9. Maintain containers of hazardous waste in a designated storage area prior to pickup for disposal. This area must be controlled by the personnel generating the waste. Regularly check the containers for leakage. If a leaking container is found, use established spill cleanup procedures to clean up the area and transfer the material to a container that is in good condition.
  10. As in any chemical storage area, segregate the containers according to the type of waste. Also, it is always advisable to provide secondary containment in case of spillage.

Special Wastes:

The following materials require special handling by the generator prior to their disposal:

  • Aerosol Cans
    Pressurized spray cans must have their original content label and/or MSDS available at the time of pickup. If possible, use the spray material until the container is empty (no pressure or free liquid). Empty cans are not hazardous wastes and can be put into regular trash.
  • Batteries
    Spent batteries are considered a hazardous waste. Separate by type (lead acid, nickel cadmium, mercury, etc.) and store in different containers. Lead acid batteries should be stored indoors or in an enclosure. The College recycles all batteries.
  • Gas Cylinders
    Gas cylinders have a high disposal cost. Cylinders should be purchased from vendors who will accept them back after use. Buy only the necessary number and use them as soon as possible. (If the pressure in a lecture bottle is equal to atmospheric pressure, the generator can legally declare the container empty and discard it with other non-regulated wastes.)
  • Empty Containers/Glassware
    Most glassware can be disposed of in the trash. Containers that held acutely toxic hazardous waste must be triple rinsed before being placed in the trash. The rinsate must be handled as a hazardous waste.
  • Fluorescent, Sodium Vapor and Metal Halide Light Tubes
    Do not break or throw fluorescent light tubes in the trash. The College recycles all light tubes. Place the tube in its original carton, if available, and contact your Campus Facilities Office or MC–ES to have it stored appropriately until it can be picked up for recycling.


 

Coordinating and Scheduling the Hazardous Waste Disposal

MC–ES is responsible for coordinating all waste pickups by the hazardous waste contractor. Pickups are normally scheduled four times each year and whenever necessary for special projects.

You may notify the Environmental Safety Manager that you have materials for inclusion in the next scheduled pickup at any time. Notification may be made by phone (x. 74308) or e-mail. Along with your request, you must submit a completed HAZARDOUS WASTE COLLECTION REQUEST FORM. This form is available on our Forms page. The completed request must include the storage location; the generating department's name; the size, type and number of containers; and the chemical or product names (see "container labels" above). This form should be submitted as soon as possible and must be in our office no later than 7 days prior to the scheduled disposal date. Last minute additions usually are not permitted.

When a pickup is scheduled for the mutual convenience of the generating department and the contractor, the waste must be accessible for pickup. Neither the Environmental Safety Manager nor other College employees will collect the wastes prior to the day they are to be removed by the contractor. Consequently, a departmental contact person must be available to provide information and access on the day of pickup.


 

Unknown Wastes

Federal and State regulations specifically prohibit the transportation, storage and disposal of unknown waste materials. Consequently, unknown chemicals will not be accepted for disposal! Analysis of unlabeled materials may cost thousands of dollars per container. The cost of such analysis will be borne by the generator or generating department. Proper management practices in your department can prevent the generation of unknown wastes. Make sure all hazardous materials and wastes are properly identified when accumulation begins. Do not permit students, faculty or staff to use or leave unidentified materials on College property.


 

Emergencies

Spilled hazardous material and all cleanup materials become hazardous waste. The generator is responsible for mitigating any damage and minimizing exposure for anyone in the vicinity of the accident. The generator must notify the Campus Security Office of a hazardous materials spill as quickly as possible. This will permit rapid coordination of emergency responses both internal and external to the College.

In addition, State and Federal laws require that certain notifications be made to appropriate officials. The notification is handled by the Environmental Safety Manager. In some cases, cleanup operations may best be handled by professionals, who will be contacted by the Environmental Safety Manager in both emergency and non-emergency situations.


 

Roles and Responsibilities

Department

  • Identify activities that may generate hazardous waste.
  • Develop a waste minimization program.
  • Develop standard operating procedures for managing hazardous waste.
  • Be aware of College policies and procedures regarding hazardous waste.

Supervisors

  • Ensure that personnel involved in activities that generate hazardous waste understand and follow the waste policies and procedures.
  • Ensure that wastes are disposed of properly at the conclusion of a project.
  • Ensure that all wastes are identified for disposal before the generator leaves the College.
  • Review current activities for the purpose of minimizing the amount of hazardous waste generated.

Individual

  • Follow all specified policies and procedures.
  • Properly dispose of all hazardous waste in a timely manner.
  • Ensure that all waste for which he/she is responsible has been identified and disposed of prior to leaving employment or a particular position at the College.

MC–ES

  • Secure and administer contracts for hazardous waste disposal.
  • Coordinate all hazardous waste pickups with contractors.
  • Provide technical assistance on proper waste identification, storage and disposal requirements.
  • Maintain disposal records and submit all required reports to the appropriate authorities.

EPA Links

Links to all of the major EPA regulations that may affect College operations are available from our "EPA Regulations" page. To go to the full index for 40 CFR 261, which defines hazardous waste and includes lists of all of EPA's waste codes, click here. This document is available as a text or Adobe Acrobat® PDF file.

For More Information

Do not rely on government documents to determine whether a particular waste is considered hazardous waste. Contact the Environmental Safety Program Supervisor at x. 74308 or by e-mail for assistance whenever you have questions or concerns regarding waste disposal.




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Montgomery County, MD

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