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.