Hazardous Waste Collection and Labeling Policy
Have hazardous waste? Collect into an appropriate sized compatible container and label with one of our "official" yellow pre-printed Hazardous Waste Labels, located on the front of most fume hoods. Department offices and the Safety Office have them also. Call COTA Safety x55246 when the waste is approaching six months of age, or if full before that date. For detailed instructions on how to fill out the Hazardous Waste Label, see point 5 below. NO OTHER LABEL IS ALLOWED! NEVER WRITE ONLY THE WORD "WASTE" ON ANYTHING!
1. Waste Minimization
Unwanted but still useful chemicals and consumer products in sound containers that bear legible labeling should be screened for potential re-use prior to being sent off-campus as waste. These unwanted items may simply be marked by the owner with colored tape and left in the customary storage location, or placed compatibly in boxes, trays, etc. pending pickup. In either case, make sure that the COTA Safety Office (x55246) is aware that surplus chemicals and/or waste in an area under your control has been identified. On or before the routine quarterly waste pick-up day, the materials will be evaluated for possible re-use by another then removed. COTA Safety personnel will then transfer the materials to another user, the COTA Waste Minimization area or to the custody of the hazardous waste contractor.
Please remember to contact COTA Safety before ordering chemicals - the needed item may be available at no cost to you!
2. Control of Waste-Producing Operations
Faculty (course coordinators, thesis advisors, principal investigators, etc.), staff (technicians, trades persons, supervisors, researchers, etc.) and administrators (program directors, Deans, Chairs) must anticipate and prepare for the responsible management of any hazardous waste generated from the campus activities they perform and/or oversee. Cal/OSHA has strict requirements regarding who may handle hazardous waste; you and your personnel may handle ONLY the waste generated by yourselves at your own worksite (usually a lab).
This written procedure is designed to help campus personnel fulfill this obligation. Nearly any use of a hazardous material can generate hazardous waste. Regulated hazardous waste can be created from "non-hazardous" materials. When hazardous waste must be produced, COTA Safety Office personnel will help in the development of a process-specific plan to ensure safety and regulatory compliance. If possible, a non-hazardous or less-hazardous option will be proposed.
3. Generation Point Hazardous Waste Containers
Selection of an appropriate container or containers to hold the waste routinely generated by workplace operations is a critical step. As the containers used are typically NOT the final "over-the-road" containers that require new and specific types of containers, almost any safe and effective container will suffice.
Sound containers may be used over and over again for the same waste-stream (emptied by specifically trained personnel into larger waste containers and then returned to the generation site) OR they may be one-use containers (the disposition of unwanted emptied waste containers is the responsibility of the hazardous waste contractor). The following container selection/use guidelines must be observed at all times:
- Container material: The container must be compatible with the waste, i.e. no acids in steel containers, no gasoline in styrofoam, no picric acid or perchloric acid solutions in lead soldered or zinc coated containers.
- Container condition: The container must be in sound condition -- including the closure(s) and gasket(s) as appropriate. No brittle, degraded plastics, structurally corroded metal, etc.
- Container closure: The container must be equipped with a leak-proof mechanical closure such as a threaded cap. The cap must be equipped with a gasket that holds in the material when tipped, carried. Cap threads must match the container. Friction-fit stoppers or film seals are generally unacceptable.
- Container size: Whenever possible, the container size should be matched to the volume of waste generated in 90 days. 100 ml. of waste liquid in a 5 liter bottle can be a very wasteful situation as some waste contractors simply place the bottle in a drum rather than transfer/consolidate the material. Always leave room in the full container to allow for expansion. In the case of extremely hazardous materials however, a small volume, including an unrinsed "empty" container, can be an acceptable waste item.
- Container spill control: Employ "double containment" for waste containers. Put the collection container in some type of tray, tub, bucket, etc. These containment units sometimes provide the only suitable surface for affixing the required Hazardous Waste Label. Some double containment units are available at no cost through the COTA Safety Office.
4. Required Labeling for Hazardous Waste Containers
State and Federal EPA regulations are very strict as to the labeling of hazardous waste. Never write the word "WASTE" on any container! For this reason, self-adhesive EPA-compliant Hazardous Waste Labels are widely distributed to COTA personnel. The use of this waste label IS REQUIRED BY LAW. A supply of these yellow labels is provided in packets on or near most fume hoods and they are also available from the COTA Safety Office, department offices and issue rooms.
The generator information on the label must be legibly completed by lab/workplace personnel at the time the label is affixed (see detailed instructions below as points a thru e). If using an empty chemical bottle for waste, remove or deface all conflicting information on the old container label. The person who sets up the waste collection container must write in information by hand, check boxes and circle categories to complete the label.
When waste containers are too small for the COTA Hazardous Waste label, put the completed label on a tray, tub or beaker that holds the small waste bottle(s). One label on a tub constitutes adequate waste labeling for many small containers of a single waste-type. Contact the department issue room or the COTA Safety Office for more information regarding the data required on the label or any other waste related question.
5. Instructions for Completing the Hazardous Waste Label
Please have a label in your hand as your read this information.
- Start date: The date waste was first placed in the container or date the material was designated as waste must be indicated. Mark the date directly on the label. IN NO CASE MAY GENERATION POINT WASTE BE ACCUMULATED FOR MORE THAN SIX MONTHS -- EVEN IF THE CONTAINER IS NOT YET FULL! Request a pickup from your department issue room or the science Safety Office when the waste is six months old. This will prevent the receipt of costly fines by Cal/EPA.
- Name/identity of the waste material: The box marked "This container is to be used for the collection of:" requires a general name for the waste. This name must, where possible, be a recognized chemical or product name (such as "toluene" or "pump oil"). When the waste consists of a mixture of materials (such as "halogenated solvents", "animal preservative", or "HPLC waste") each component of the mix must be listed and the approximate percent of the total mixture volume indicated. If the mixture contains more than 10 components, write the other components on an attached sheet. For example:
- This container is to be used for the collection of: "Mixed solvents".
- Components: "acetone 60%", "isopropanol 5%", "chloroform 5%", "water 30%". COTA has a more detailed guide on how to list percentages. Contact them if you want this information.
- Below the "This container ..." box, circle the properties that apply to the waste. In the case of this example, circle "Solvents(non-halogenated)" and "Solvents (Halogenated)".
- Physical state: Check the box to indicate Solid, Liquid or Gas. This MUST be done -- even if the waste is in a clear bottle and the physical state is obvious.
- Hazards(s): Check box(es) to indicate Flammable, Oxidizer, Corrosive, Poison, etc. as appropriate. Hazard information may be taken from the original product label, or ask your issue room or Safety Office (hazards assigned per DOT: 49CFR Sect. 172.101). See COTA Safety Memo 41. For the example above, Flammable, Poison and perhaps Carcinogen would be appropriate.
- Contents: As discussed under point "b" above, use these 10 spaces to list the Components and Amount in % of the waste.
- Faculty or staff name: The name of the faculty, staff or administrator responsible for the contents and oversight of the waste container must be indicated on the label. Please note that official responsibility for effective, ongoing oversight of a waste generating operation cannot be delegated to a student. The person listed is responsible for ensuring compliance and conveying these hazardous waste guidelines to everyone who generates waste. Having a person's name on the label also facilitates timely return of re-usable waste containers.
- DEPT (Department): Write in the department responsible. It may be an academic department, College, trades group (like Paint Shop, Auto Shop, Grounds), Animal Facility, etc. The department that acquired the original material is typically the group responsible for the waste created by its use.
- Room #: List the room/location where the waste was created. Only waste generated on the CSULB campus may be managed by the CSULB program. Transport of waste to the campus from elsewhere is forbidden.
- Acc. Fac. S.D.: Generators do not use this box. Campus Safety personnel indicate here when a full container has been moved to an approved on-campus storage area.
6. GENERATION SITE WASTE MANAGEMENT PRACTICES
The faculty and/or staff considered responsible for a given waste-generating process should regularly examine the container(s) and monitor compliance. The responsible person must ensure that:
- all persons adding waste are trained in waste compatibility and policies.
- all material added to the container is chemically compatible.
- hazardous waste is collected -- not dumped in a sink or trash can.
- the container is sound and compatible with the waste.
- solid and liquid waste are segregated -- do not add solids to liquid waste.
- the container is KEPT CLOSED except when adding waste.
- the container is kept in a containment tub or tray.
- the container is not over-filled -- do not fill past the shoulder of the bottle or beyond about 80%.
- the container, label and any log sheet lists contents and amount.
- any spills are dealt with promptly.
- the COTA Safety Office (x55246) is notified when (1) The container is full, or (2) The six-month anniversary date (from first use) is approached, whichever comes first.
Restricting access to a waste container (locking it away or locking it in a closed position to preclude improper "contributions") is sometimes the only way to make sure all of the above rules are followed -- especially when the waste container is in an area used by more than one faculty or staff person. The COTA Safety Office can help design and expedite fabrication of such arrangements.