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Handbook of Operating Procedures
Chapter 9 - General Provisions
Publication Date: October 15, 1996
Responsible Executive: VP for Business Affairs

9.25 Hazardous Waste Management Program

The UTSA Hazardous Waste Management Program is administered by Environmental Health, Safety & Risk Management (EHSRM). Each member of the University community, however, is responsible for the proper management of hazardous materials or wastes used or generated by that individual. This responsibility includes compliance with all applicable laws and regulations, including proper identification and labeling of all hazardous materials and guidelines and procedures established by EHSRM.

UTSA encourages each member of the University community to have a positive attitude toward proper hazardous waste management and a commitment to waste reduction. Commitment by the University community to these goals can greatly reduce escalating hazardous waste disposal costs and ensure compliance with applicable laws.

UTSA has applied for and received an identification number from the U.S. Environmental Protection Agency (EPA) and the Texas Natural Resource Conservation Commission (TNRCC) identifying UTSA as a hazardous waste generator. UTSA is a generator of Hazardous Waste as defined by the Resource Conservation and Recovery Act (RCRA). UTSA is subject to regulations applicable to non-industrial small quantity generators.

The primary federal law governing the management of hazardous waste is the RCRA. Regulations implementing RCRA are promulgated and enforced by EPA. The primary state law governing the management of hazardous waste is the Solid Waste Disposal Act, found in the Health and Safety Code. Regulations implementing the Solid Waste Disposal Act are promulgated and enforced by the Texas Natural Resource Conservation Commission (TNRCC).

This University program must comply with all the "General Facility Standards" including accumulation time; general waste analysis; security; general inspection requirements; personnel training; contingency and emergency procedures; record keeping and reporting requirements, and use and management of containers.

This program is developed to give generators of hazardous waste at The University of Texas at San Antonio a better understanding of Federal and State hazardous waste disposal regulations and to explain The University's program for compliance.

Please refer inquiries to the University's Environmental Health, Safety & Risk Management, located in the Building Services Annex.

  1. Definitions

    1. Waste - Any material for which there is no use and which is to be discarded as valueless.

    2. Hazardous Waste - Any solid waste material that exhibits a hazardous characteristic or is listed specifically, as described in Title 40 Code of Federal Regulations, Part 261, Subpart C and D. Refer to UTSA's Laboratory Safety Manual for specific characteristics and lists.

    3. Disposal - The discharge, deposit, injection, dumping, spilling, or placing of any hazardous waste (whether containerized or uncontainerized) into or on any land or water so that such waste or any constituent thereof may enter the environment or be emitted into the air or discharged into any water, including ground waters.

    4. EPA Identification Number - The number assigned by the US EPA to the UTSA as a registered generator of hazardous waste.

    5. Facility - Includes all contiguous land, and structures, other appurtenances, and improvements on the land for storing, processing or disposing of municipal hazardous waste.

    6. Generator - Any person, by site, who produces hazardous waste; any person who possesses municipal hazardous waste to be shipped to any other person; or any person whose act first causes the waste to become subject to regulation.

    7. Processing - The extraction of materials, transfer, volume reduction, conversion to energy, or other separation and preparation of waste for reuse or disposal, including the treatment or neutralization of hazardous waste, designed to change the physical, chemical, or biological character or composition of any hazardous waste so as to neutralize such waste, or as to recover energy or material from the waste so as to render such waste non-hazardous or less hazardous; safer to transport, store, and dispose; or amenable for recovery, amenable for storage, or reduced in volume.

    8. Recyclable Material -Wastes that are recycled or employed in a particular function or application as an effective substitute for a commercial product.

    9. Storage - The holding of waste for a temporary period, at the end of which the waste is processed, disposed of, recycled, or stored elsewhere.

    10. Transporter - Any person who conveys or transports hazardous waste by truck, ship, pipeline or other means.

  2. Prudent Practices and Special Concerns

    1. Minimizing Quantities of Hazardous Waste - It is common practice to order chemicals in larger quantities than necessary to take advantage of reduced costs of substances. As a result, aging reagents or solvents are left for disposal. With the current high disposal costs, often disposal is more than the initial acquisition cost of the chemicals. It is estimated that as much as 40% of laboratory hazardous waste may be unused chemicals. Besides reducing the disposal cost, smaller inventories reduce exposure to personnel. Storage of unused chemicals for an extended period of time tends to increase the risk of an accident.

      Another way to reduce quantities of waste is by precipitating out the active chemicals and drying or filtering the water from the hazardous waste. As waste technology advances, the removal of non-hazardous materials and separation of chemicals from waste is becoming more desirable. This is often most easily accomplished at the point of generation.

    2. Substitution - Substitution of non-hazardous or less hazardous chemicals for a hazardous chemical is a commonly used method of reducing hazards and wastes. Examples include using hot water and soap for cleaning instead of toxic, flammable organic solvents; "Nochromix" instead of toxic chromic/sulfuric acids; water-based paints instead of oil-based paints; spirit-filled thermometers instead of mercury-filled thermometers; and non-carcinogenic solvents instead of carcinogenic solvents. Substitution is not always possible but should be accomplished when practical.

    3. Surplus Chemical Exchange - The concept of exchanging excess solvents and reagents with other labs or departments needing these materials reduces purchasing and disposal costs. It has been established that about 30% to 40% of excessive or unused materials can be used by other labs. Exchange of materials should be emphasized.

    4. Unknown - Unknowns are a special problem in labs, especially when labs change occupants or processes. Labs should be cleaned up and old, unneeded chemicals disposed of by the occupant who is terminating the use of the lab.

      Label all chemicals before they become unknowns. All chemicals, mixtures and solutions should be clearly labeled at all times. The Safety Office cannot dispose of unknowns. Although analysis is often expensive and time consuming there is no alternate solution to proper identification of hazardous materials. Each generator of hazardous waste is responsible for the identification of hazardous materials prior to requesting disposal. Cost for analysis and identification of any unknowns, whenever necessary, is the responsibility of generators of hazardous waste, and will be accomplished prior to request for disposal.

    5. Special Laboratory Disposal Methods - Small amounts of common inorganic acids (except hydrofluoric and chromic acids) can be diluted and neutralized to a pH between 5 and 10 and disposed of via the sanitary sewer.

      Inert, non-toxic salts, sugars, and buffers can be diluted and disposed via the sanitary sewer. Contact EHSRM before any treatment or disposal of chemical waste is performed in the laboratory.

    6. Reactive Materials - Reactive wastes include cyanides, sulfides, air and/or water reactives, oxidizers, explosives, and flammable solids. Special care must be exercised when handling these materials to prevent contact with incompatible materials, such as air, water, or organic materials. Reactives should be isolated from other wastes and should be stabilized whenever possible. For example, water reactives should be stored in a desiccator and picric acid should always be saturated with water.

    7. Disposal Costs - A lab-pack is the most common and most expensive method of packaging non-bulkable solid chemical waste, such as toxics and reactives, for disposal. Waste materials in various sized containers are packed into metal drums for transportation and final disposal. An inert packing material (vermiculite) is used to surround and protect the containers. Lab-packs contain a maximum of 17 gallons of waste chemicals per 55-gallon drum, 8 gallons per 30-gallon drum, and 1 gallon per 5-gallon pail.

      The most recent disposal cost of a 55-gallon lab-pack averages about $300.00. This cost includes preparation, packaging, labeling, transportation, and ultimate treatment or disposal.

    8. Non-hazardous Waste Disposal - All chemical wastes that do not meet the definition of a RCRS-hazardous waste must still be disposed of properly to protect human health and the environment. In most cases, disposal via the sanitary sewer or the trash is not permitted; however, there are exceptions which will be made by EHSRM on a case by case basis.

    9. For radioactive waste disposal procedures, see the UTSA Radiation Safety Manual or contact the UTSA Radiation Safety Officer (RSO) ext. 5250.

  3. Emergency Procedures

    Laboratory personnel require training on the hazards associated with laboratory chemicals used and how to respond to emergencies. Materials Safety Data Sheets are an excellent source for training information and should be compiled for all chemicals used or stored within each laboratory. Special clean up (spill) supplies should be available in each area where chemicals are used and personnel trained on how to use these supplies. Hazardous waste disposal procedures should be followed for disposal of contaminated clothing, rags, absorbent materials or other waste generated from clean up of spills or leaks.

    All laboratories should know emergency numbers and develop a response scenario for emergencies.

    Some emergency telephone numbers of importance are listed below:

    Campus Emergency Number 4911
    Occupational and Safety Programs 5250
    Radiation Safety Office 5250
    Student Health Services 4142
    University Police 4242
    SE TX Poison Control Center at UT-Medical Branch (Galveston, TX) (800) 764-7661

  4. Responsibilities and Procedures

    1. The generator requesting disposal service shall:

      1. Assure that the laboratory waste is correctly identified by chemical name/common name. Chemical formulas are not acceptable.

      2. Inform the EHSRM, ext. 5250, of any special handling requirements.

      3. Place labeled containers of liquid/solid chemical waste in a conspicuous area that is convenient for pick up. Do not place containers in the corridors or areas where waste could cause a health exposure to personnel.

      4. Insure that containers of liquid and solid chemical waste are in good condition so that handling can be done in a safe manner, and that containers do not leak at a later date. Containers must be suitable for the types of chemicals they hold and must be suitable for storage for at least 180 days. Containers must be closed or sealed in such a manner that leakage will not occur.

      5. All waste containers must be properly segregated and clearly marked regarding the contents, hazards and other pertinent information.

      6. Complete a Hazardous Waste Disposal Form for each container of waste materials. Generator name is the person in charge of the laboratory. Building/Room is the location of the lab where the waste was generated. Phone is the telephone extension of the lab generating the waste. Date requested is the date in which a request was made to EHSRM for a waste pick up (and thereby the date that the generator declared the chemical(s) to be a waste). Chemical contents are the names (in full) of the chemical(s) constituting the waste, including water. All chemicals in the waste must be accounted for. Conc/vol is either the concentration or the volume of each chemical listed in chemical contents. This is very important in hazardous waste determination. Hazard - indicate all applicable hazards of the waste by checking the appropriate box.

      7. After completing the information, attach the form to the waste container. Do not remove the top copy of the form.

      8. Call the EHSRM, ext. 5250, to request waste pick up.

    2. EHSRM shall respond as follows:

      1. On receipt of a pick-up request, collect the waste material from the requestor at the predesignated location site.

      2. Segregate the waste materials according to compatibility before transporting the wastes.

      3. Transport the waste materials to the Hazardous Waste Storage Facilities (HWSF's) on West Campus where the wastes are "bulked" (if possible) and accumulated.

      4. EHSRM will supply the generators with Hazardous Waste Disposal forms, coordinate disposal requirements with generators, provide a storage facility for hazardous wastes, maintain records of disposal services, and provide reports as appropriate to Federal or State agencies.

    3. Disposal

      1. Ultimate disposal shall be accomplished off-site by a permitted Transportation, Storage, Disposal Facility (TSDF).

      2. The service contractor's chemist shall package the lab pack chemicals, label the shipping containers, and complete a manifest in accordance with Federal/State requirements.

      3. The service contractor shall transport the hazardous waste to the permitted TSDF. Certificates of disposal shall be furnished to UTSA by the service contractor.

      4. Commercial disposal shall be accomplished when the quantity of waste warrants such service but prior to 180 days storage.

Editorial Amendment Issued June 20, 2002