A Step by
Step Guide to 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 whether your unwanted
chemicals are hazardous or not check if they are listed in the Chemical
Waste Registry. If the chemicals are listed and do not have a
nonhazardous designation ("xxNH" DDC number), then they must be managed
as hazardous waste following the directions in this Guide.
If the chemicals in question are not
listed in the Registry, or you have a chemical mixture that needs
disposal, follow Step 6 instructions.
If in doubt, you must manage your
chemicals as hazardous waste, following the directions in this guide,
fill out and send the
waste disposal request form to the EHS Office 13 DADB for proper
disposal.
If you believe your waste is not hazardous, or
of low concentration that it could be disposed in the sewer or regular
trash. You must first obtain
permission from the EHS office before sewering or trashing
chemicals. Print and fill out the Permission
to Sewer or Trash Chemicals and send to 13 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 726-7273.
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 726-7273.
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
Waste
containers must be labeled immedialtely 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 a copy of the waste
disposal request 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
The following procedures should be carried out to ensure proper
labeling and safe handling of collection bottles:
Attach the label to the bottle as soon as the
bottle is started as a collection container. Record this starting date
on the label.
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
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.
When submitting the bottle for disposal, the
following information must be recorded on both the label and waste
packing form:
ingredients and their percentages;
pH of aqueous solutions, or for organic
liquids, the pH of an aqueous solution containing 10% of the organic
mixture; and
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:
Chemicals must be packed in sturdy
cardboard boxes. Each box must only contains materials with the same
hazard class in order to comply with Department of Transportation (DOT)
shipping 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 unknown chemicals awaiting testing to determine
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.
After chemical waste bottles have been properly labeled, package the
waste for transportation by carrying out the following procedures:
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.
All containers must be completely
enclosed within a the box.
All bottles must be tightly capped and
packed in an upright position.
Use appropriate cushioning or absorbent
material such as vermiculite, cardboard dividers, to separate
packed containers. Do not individually wrap bottles in paper.
Do not pack five gallon containers in
boxes, but simply attach a copy of the waste
disposal request form directly onto the pail.
Do not package highly volatile chemicals
requiring refrigeration. Simply complete the waste
disposal request form according to normal procedures and note on
the form:
that the chemicals are refrigerated and require
packaging
the location of the refrigerator.
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 Waste Disposal
and Packing Form
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 1).
Fig 1: waste
Disposal Request and 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 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 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 online Chemical Registry
Drum Designator Code (DDC) and Chemical
Abstract Service (CAS) numbers. These numbers can be found in the Chemical Registry.
Compound name
EPA number(s) found in the Chemical Waste
Registry.
If unopened, check the recycle box
(RECY?).
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 1).
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:
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.
Complete the chemical information on the waste
packing form as above, leaving the DDC and CAS sections blank.
If any of the following information is known,
include this on the waste packing form:
Product name
Name and address of manufacturer or
distributor
Product or catalog order number
Approximate age
Include the pH of aqueous solutions, or for
organic liquids, the pH of an aqueous solution containing 10% of the
organic mixture.
If a Material Safety Data Sheet (MSDS) is
available, include a copy with the waste packing forms.
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
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).
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.
Indicate on the bottle label and waste packing
form (underneath the compound name) the presence of any sludge,
precipitate, or material which is polymerizable.
Package mixtures separately, in their own
containers and boxes.
Commercial (Trade Name) Products
Include the following information on the waste
packing form (see Figure 11).
Product name
Ingredient list from the bottle label with
respective percentage composition
Description of product's usage
Manufacturer/distributor name, address,
city, and telephone number
Product catalog number or batch code
Approximate age
pH (if liquid)
If available, send a Material Safety Data Sheet
(MSDS) with the form.
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 will 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:
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.
<>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:
CAMPUS MAIL Chemical Waste Program
13 DAdB
Fax: 726-6730
US MAIL Chemical Waste Program
13 DAdB
1049 University Drive
Duluth, MN 55812
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 2: 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 3: 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 4:Waste Pure, or Commercial
-Chemicals
Figure 4 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.
