Hazardous Waste Collection and Disposal Procedures
Introduction to Waste Disposal
Most wastes generated in the laboratories and shops located on campus are prohibited from disposal in the regular trash or down the drain. Many of these wastes are regulated under the federal Resource Conservation and Recovery Act (RCRA).
The term hazardous waste is defined under RCRA as solids, liquids, and gases that exhibit certain characteristics or are specifically listed in the rules. Hazardous waste is regulated under a “cradle to grave” concept, meaning that the waste is tracked via written records from the time it becomes a waste, and that ownership remains with the generator forever. Therefore, the best method to reduce the risk of future remediation costs is to reduce the amount of hazardous waste generated. It is essential to consider the amounts and types of wastes that will be generated when a project is in the proposal stage in order to ensure that a disposal method exists that is both legal and affordable—and to minimize the amount of waste generated. Every person responsible for the generation of waste at Michigan Tech must understand the proper disposal procedures and the requirements of the Michigan hazardous waste rules under RCRA.
Rules for Hazardous Waste Accumulation
- A generator must perform a “waste determination” to see if a waste is regulated under RCRA. That determination can be based on the generator’s knowledge of the waste composition or through chemical analysis if the composition is unknown. The waste determination must be made no later than the moment a substance becomes a waste. Documentation supporting this waste determination must be kept on file for three years.
- Hazardous waste must be accumulated and stored at the point of generation until removed by Environmental Health and Safety (EHS) and must be:
- Collected in a container that is compatible with its contents under all conditions that it might be subjected to during accumulation, storage, and shipment.
- Kept tightly sealed except when adding waste to the container.
- Handled only by personnel trained in the requirements of these hazardous waste rules.
- Removed from the accumulation area within three days if the quantity of any one waste exceeds fifty-five gallons. (From a safety perspective, no more than five gallons should be accumulated in a laboratory or shop.)
- Labeled with the words “hazardous waste,” the waste identification number (see below), the accumulation start date, and a chemical description.
Hazardous Waste Determination
Waste determination involves comparing the characteristics and composition of the waste to the descriptions and tables contained in the hazardous waste rules. The basic process involves answering the following questions:
Is the waste specifically listed in any of the tables (see Waste Descriptions)?
Does the waste meet the definition of ignitability (see Waste Descriptions)?
Does the waste meet the definition of corrosivity (see Waste Descriptions)?
Does the waste meet the definition of reactivity (see Waste Descriptions)?
Does the waste meet the definition of toxicity (see Waste Descriptions)?
If the answer to any of these questions is yes, the waste is regulated and the rules in 2 (a-e), above, apply. If the answer to all of the questions is no, the rules in 2 (a-e) apply except that the words “hazardous waste” and the waste identification number may be omitted from the label.