Environmental health and safety office

 Environmental Health and Safety Office
Preparing Chemical Waste for Disposal

Step 1. Evaluate Your Waste

Departments are required to evaluate their wastes, in compliance with Minnesota Rules, to ensure proper waste disposal. 
  • To determine if your unwanted chemicals (whether pure or in mixtures) are hazardous check if they are listed in the Chemical Waste Registry. If the chemicals are listed in the Registry and they do not have a nonhazardous designation ("xxNH" DDC number), then they must be managed as hazardous waste following the directions in this Guidebook (see the warnings regarding the disposal of nonhazardous chemicals in Part 1 and Part 2).
  • If the compounds in question are not listed in the Registry, or you have chemical mixtures, follow the detailed instructions in Step 6 - Complete the Hazardous Waste Packing Form as per this guide
  • If in doubt, Always manage the chemicals as hazardous waste, following the directions in this guide, send them  to the EHS Office 19 DADB for proper disposal.
  • If you believe your waste is not hazardous, or at low concentration that it could be disposed of in the in the sewer or regular trash. you must first obtain permission from the UMD EHS office. Print and fill out the Permission to Sewer or Trash Chemicals and send to 19 DADB for approval.  Remember sewering or trashing chemicals is not allowed without proper permissions.

For further assistance on proper waste evaluation, call the UMD Office of environmental Health and Safety 726-7139.

Step 2. Collect the Waste in Appropriate Containers

Hazardous waste Collection bottles and lids must be compatible with the chemicals stored in them, both the bottle and screw cap must be chemically resistant to the waste chemical contained. Collection bottles must be kept capped, properly labeled, and stored in a safe location in the laboratory.  Also, bottles containing liquids should be stored with secondary containment, such as a plastic tray or in proper safety cabinet.  Drums if used should not be stored with an open bung or a funnel in them.  All waste containers should be stored in appropriate locations, i.e. flammable liquid or acid storage cabinets.

If containers larger than four liters in size are desirable for collecting the waste in a laboratory, obtain prior approval from the UMD Office of Environmental Health and Safety 726-7139.

Fig 1: Collect waste in a compatible and
          properly labeled container

Fig 2: Keep containers closed (except when
          adding or removing waste) and use
          secondary containment

Package Chemical Waste for Collection in Appropriate Containers as Follows:

Screw cap bottles:

Stoppered or corked flasks and bottles are unacceptable. The contents of these containers should be over packed into or transferred to a screw cap bottle using a fume hood, proper protective equipment, and secondary containment.  Bottles with broken or cracked screw caps are also unacceptable. Note that there are exceptions to using screw cap bottles and some of these are listed below. If there are problems in transferring the waste to the suggested container for disposal, contact our office at 726-7139 for assistance.

Exceptions to screw cap bottles: Over packed containers:

The following containers may be over packed into a larger screw top bottle or a plastic bucket with secure lid and surrounded with an absorbent material such as vermiculite. The bucket must be labeled with the contents and amount of chemical waste in the enclosed container.
  • Flasks with frozen stoppers of unknown substance
  • Bottles containing unwanted hydrofluoric acid
  • Glass sealed ampules with low boiling point chemicals
  • Microcentrifuge tubes with snap caps or similar containers
  • Contaminated glassware or powdered chemicals which are not in a proper containers should be packaged in sealed plastic bags, then over packed and labeled.

CAUTION: Wastes from different sources (i.e., reactions or processes) may react dangerously when mixed. Mixtures should be stored separately.

Step 3. Label the Waste Container

Bottles of waste must be labeled as they are generated in the laboratory or work area. Every bottle must be labeled in one of two ways:

Original Label
Unused or outdated chemicals that are in their original containers with labels identifying the contents are suitable for waste pickup by boxing the containers and affixing the pink copy of the hazardous waste form to the box. The completed waste form provides the words "Hazardous Waste" and the date. If the original label appears faded or illegible, affix a new label to the bottle.

Yellow Hazardous Waste Label
Collection bottles used for process wastes or mixtures of spent waste must use the yellow hazardous waste label supplied by the UMD EHS Office.  To obtain hazardous waste labels, call 218-726-6764

Figure 3: Hazardous Waste Label

The following procedures should be carried out to ensure proper labeling and safe handling of collection bottles:
  1. Attach the label to the bottle as soon as the bottle is started as a collection container. Record this starting date on the label.
  2. As ingredients are added to the collection bottle, maintain a separate ledger recording the ingredients and amounts added. All solvents, including water in solutions and sludges, must be recorded. The ledger must be kept next to the container
  3. Bottles in the process of being filled must be kept capped and stored in a safe location; storage location should be selected based on the characteristics of the contents.
  4. When submitting the bottle for disposal, the following information must be recorded on both the label and waste packing form:
    1. ingredients and their percentages;
    2. pH of aqueous solutions, or for organic liquids, the pH of an aqueous solution containing 10% of the organic mixture; and
    3. presence of any sludge or precipitate in the waste.

Most Common Chemical Collection and Packaging Problems:

  • Chemicals not labeled
  • Incomplete information on labels and on waste packing forms, e.g., contents descriptions, percentages, pH, and amounts
  • Chemical names and descriptions on waste packing form do not match those on container labels
  • Some containers are not listed on forms
  • Hazardous liquid containers packed on their side
  • Bottles not tightly capped
  • Incompatible chemicals packed together

These problems will delay the prompt collection of your wastes!

Step 4:Segregate the Chemicals for Waste Storage and Transportation

For compliance with federal and state regulations and safety considerations of the University community, waste chemicals stored and/or submitted for disposal or redistribution must be segregated and packaged by chemical hazard class. These hazard classes are identified by the first two digits of the Drum Designator Code (DDC) listed for the compound in the Chemical Registry.

Chemical waste should be segregated and packaged for disposal according to the following procedures:

  • Materials must be packed in sturdy cardboard boxes, each box including materials within one hazard class only. The hazard class is designated by the first two digits of the DDC. These DDC numbers are based on Department of Transportation (DOT) hazard classes and packages for shipment need to comply with these requirements.
  • Concentrated sulfuric acid, perchloric acid, nitric acid, water sensitive ("xxWS"), shock sensitive ("xxSS"), cyanide ("xxCN") compounds, and mixtures are exceptions and must be packaged in separate boxes.
  • Chemical mixtures containing different hazard class chemicals should be stored and packaged separately.
  • Chemicals and commercial products not listed in the Chemical Waste Registry, and unlabeled chemicals awaiting testing for their chemical characteristics, should be packaged, or stored separately until further guidance from the UMD EHSO at 218-726-6764 is obtained.

The following chemicals should always be packed in separate boxes:

  • Concentrated or fuming sulfuric acid
  • Perchloric acid
  • Nitric acid
  • Cyanide compounds
  • Water sensitive (WS) compounds (also segregate by DDC)
  • Shock sensitive (SS) compounds (also segregate by DDC)
  • Chemical mixtures containing different hazard class chemicals

Caution: Some potentially explosive chemicals, identified as shock sensitive, "xxSS" (DDC), and certain chemicals that react with water violently to produce flammable or toxic gases, identified as water reactive, "xxWS" (DDC), require special handling.  For assistance, contact  our office at: 218-726-6764

Note also that any waste containing mercury compounds should be kept in separate collection bottles. Do not mix mercury waste with any other waste.

Step 5. Box the Chemicals for Transportation

After chemical waste bottles have been properly labeled, package the waste for transportation by carrying out the following procedures:

Fig 4: Package containers upright in a            sturdy box with no glass-on-glass               contact

Fig 5:  Tape a copy of the waste packing                  form to the box

Caution: Perchloric acid, fuming nitric acid, and fuming sulfuric acid are strong oxidizers and are exceptions to these procedures. If spilled, they might react with newspaper or cardboard. They should be packaged separately in a plastic bucket with a lid and surrounded by kitty litter, floor dry, or sand.

  1. Bottles must be completely enclosed within sturdy cardboard boxes.
  2. All bottles must be tightly capped and packed in an upright position.
  3. Use appropriate cushioning or absorbent material to separate the inner containers; acceptable materials include vermiculite (preferred choice), cardboard dividers, or crumpled newspaper. Bottles should not be individually wrapped in paper. When the box is lifted, there should be no "clinking" sound heard from contact between glass bottles.
  4. It is not necessary to box five gallon pails of waste chemicals, but attach the waste packing form directly to the pail.
  5. In the case of highly volatile chemicals requiring refrigeration, do not package these chemicals for waste collection. Complete the waste packing form according to normal procedures and note on the form:
    1. that the chemicals are refrigerated and require packaging
    2. the location of the refrigerator.
  6. Do not store the boxes in the hallway while awaiting pickup. Store them in a safe area in the laboratory or shop and separate them by DDC (e.g. acidic, caustic, flammable, oxidizer). If stored closely together, segregate the boxes by DDC numbers, using secondary containment trays. Secondary containment trays are available from University Stores, (612) 624-4878, part numbers CX18998 (medium) or CX18999 (large).

Laboratories generally have only four storage areas for their reagent (non-waste) chemicals: flammable, acid, base, and other, but there are several notable exceptions to this simplified segregation scheme (e.g. nitric acid). Check compatibilities using this Chemical Registry DDC system or Material Safety Data Sheets (MSDS).  Tubs and Trays can be used to separate chemicals within cabinets and on storage shelves.

Step 6. Complete the Hazardous Waste Packing Form

Fig 6: Fill out the waste packing form                       following directions in this Guide

Fig 7: Mail the top two copies to the Chemical
          Waste Program

The Hazardous Waste Packing Form is designed to meet regulatory marking requirements for transporting hazardous waste.  Failure to properly complete the waste packing form may delay the collection of the waste.  The waste packing form requires the following: generator information, chemical information describing the box's contents, and a signature assuming liability (see Figure 8).

Fig 8: waste Packing Form

Generator Information

Fill out the following information: name, phone number, email address, date, department number, building number, and room number.  Building numbers and department numbers can also be obtained from the Chemical Registry Page.  Use these numbers rather than names. If your location is not listed, call our Office at 218-726-6764 for assistance

Chemical Information

The waste packing form is designed to have information about one container or component of a mixture per line.

The chemical information requested on the waste packing form must match the container label description for each item and should be completed adhering to the following instructions.

Chemicals listed in the Chemical Registry

The waste packing form should include the following information for pure chemicals listed in the Chemical Registry:

  1. Drum Designator Code (DDC) and Chemical Abstract Service (CAS) numbers. These numbers can be found in the Chemical Registry.
  2. Compound name
  3. EPA number(s) found in the Chemical Waste Registry.
  4. If unopened, check the recycle box (RECY?).
  5. List the amount of chemical in the container in kilograms (for solids) or liters (for liquids). If the same substance is present in several containers in the same box, put the chemical amount for each container on its own line and use arrows drawn down to indicate that the rest of the information is duplicated (see Figure 8).

NOTE: The on line Registry is much more extensive than previous hard copy versions, so it is recommended that you use it, especially if you cannot find your chemicals listed in the older version.

Chemicals not listed in the Chemical Registry

Prepare for pickup as follows:

  1. For a small number of unlisted chemicals, less than 5 containers, either package the items individually (single chemical type per box) or call 726-6764 for further instructions.
  2. Complete the chemical information on the waste packing form as above, leaving the DDC and CAS sections blank.
  3. If any of the following information is known, include this on the waste packing form:
    1. Product name
    2. Name and address of manufacturer or distributor
    3. Product or catalog order number
    4. Approximate age
  4. Include the pH of aqueous solutions, or for organic liquids, the pH of an aqueous solution containing 10% of the organic mixture.
  5. If a Material Safety Data Sheet (MSDS) is available, include a copy with the waste packing forms.
  6. When submitting a large number of unlisted chemicals for pickup, greater than 4 containers, send a list of the chemicals to our office at 13 DADB or Fax to: 726-6730 before packing.  Pack these chemicals only after you receive proper instructions from the UMD EHS Office.

Chemical Mixtures

  1. List the mixture ingredients and their percentages on both the bottle label and waste packing form. (Include water as an ingredient of aqueous solutions.) Enclose the mixture ingredients in brackets on the waste packing form (see  Figure 10).
  2. Write the pH of aqueous solutions, or for organic liquids, the pH of an aqueous solution containing 10% of the organic mixture, on both the bottle label and waste packing form.
  3. Indicate on the bottle label and waste packing form (underneath the compound name) the presence of any sludge, precipitate, or material which is polymerizable.
  4. Package mixtures separately, in their own containers and boxes.

Commercial (Trade Name) Products

  1. Include the following information on the waste packing form (see  Figure 11).
    1. Product name
    2. Ingredient list from the bottle label with respective percentage composition
    3. Description of product's usage
    4. Manufacturer/distributor name, address, city, and telephone number
    5. Product catalog number or batch code
    6. Approximate age
    7. pH (if liquid)
  2. If available, send a Material Safety Data Sheet (MSDS) with the form.
  3. If none of the above information is accessible, it may be necessary to treat the chemical as an unknown.

Unknown or Unlabeled Chemicals

  • Unknown materials cannot be handled by the Chemical Waste Program until some identification is made.
  • To evaluate an unknown material, follow the guidelines outlined in "Wastes Requiring Special Processing" Unknown Chemicals.  Contact our Office 726-6764 if questions arise concerning preliminary analysis procedures.

Generator Signature

It is the responsibility of each generator (shop or laboratory personnel) to follow the guidelines given in this Guidebook for evaluating, packaging, and labeling chemical wastes. By signing the waste packing form, the generator is stating that the procedures outlined in this Guidebook have been followed and the waste is ready for pickup. Make sure you sign your hazardous waste packing form before sending it in!

Step 7: Requesting Waste Collection

After taking inventory of the box and packaging the waste, submit the Waste Packing Form as follows:

  1. Seal the box and tape the pink bottom copy of the waste packing form to the top of the box. Draw "Up" arrows on the sides of the box and mark the top side "This End Up." Never store containers on their sides.
  2. <>Attach a separate note or write on the waste packing form below the compound name if special pickup arrangements are necessary (i.e., where box is stored, what days the room is open, etc.). Also note when our staff need to go elsewhere to get access to the waste location.
    Send the top two (white and yellow) pages of the waste packing form to:
    Chemical Waste Program
    13 DAdB
    Fax: 726-6730
    Chemical Waste Program
    13 DAdB
    1049 University Drive
    Duluth, MN 55812

  3. If more than one waste packing form is needed to document the waste in a box, annotate the "page __ of __" in the lower left hand corner of the waste packing form. Tape a copy of the packing forms, or all the bottom (pink) pages to the box. Staple together all the top (white and yellow) pages for the box and mail to the Chemical Waste Program at the address above.

Collection by the Chemical Waste Program

Typically, laboratories and shops can expect their waste to be picked up within one to two weeks of sending in the waste packing forms. If you have concerns about the timeliness of your waste collection, or your waste has not been picked up within three weeks, call the EHSO at 726-7273, or 726-6764 or e-mail at ehso@d.umn.edu, Include the tracking number from the upper right-hand corner of the waste packing form, along with the generator name and department when requesting the status of your order.   Experiment Stations have collections scheduled at less frequent intervals

Figure 9: Pure Chemical Wastes

Figure 9 describes nine separate containers of pure chemical waste in one box. Drum Designator Codes (DDC) and Chemical Abstracts Service (CAS) numbers are listed in the Chemical Waste Registry, Appendix I. Note that the first four containers hold chemicals which are potentially recyclable. For chemical wastes that consist of mixtures of chemicals, commercial products, or unknowns  see fig 10 and 11.

Figure 10:
Chemical Waste Mixture

Figure 10 describes two bottles, each filled with the same chemical mixture. For each component of the mixture, the Drum Designator Code (DDC), Chemical Abstracts Service (CAS) number, compound name, and the approximate percentage are listed. Note that the pH of the liquid mixture is indicated on the waste packing form.

Figure 11: Waste Pure, or Commercial -Chemicals

Figure 11 shows a single container of a commercial product waste. The product name, catalog number, manufacturer's name, address, and phone number, the approximate age of the chemical, and the DDC and CAS numbers are listed on the waste packing form.

Note: If a Material Safety Data Sheet (MSDS) is available for a commercial product waste, it should be attached directly to the waste packing form.

Please note: Prior to requesting waste Disposal, employee must take required Chemical Waste Management Training Tutorial

Questions or comments regarding any of the Information on this page should be directed to: Andrew Kimball at 726-6764, or  ehso@d.umn.edu

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