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Requirements for Chemical Waste

Laboratories and other MSU units that generate hazardous waste are now required to comply with the generator requirements of the Resource Conservation and Recovery Act (RCRA, CFR Title 40) and Michigan Hazardous Waste Management Act (Michigan Public Act 451). Every generator site (laboratory) is subject to inspection by the EPA and DEQ. The changes necessary for compliance are summarized below.

Manifesting
Waste must be manifested when it is transported from campus to the MSU central waste storage facility. To do this, generators complete a Waste Pick-up Request form (see Appendix B) and send it to the ORCBS. The ORCBS prepares a manifest to pick up the waste on campus, and then the waste is tracked to the waste facility with yet another manifest required by EPA/DEQ.  

Labeling
Each container of hazardous waste must be labeled with the words “Hazardous Waste,” and have a completed waste tag attached. An exception to this rule is individual small bottles of discarded commercial chemical product; however, if the discarded commercial product is not in the original container, it must also have a waste tag.

Accumulation Time
Chemical wastes shall not be accumulated for longer than 90 days. Each container shall be labeled with a collection start date and chemical constituents when waste is first added to the container.    

Collection & Storage
Collect and store compatible wastes (see Appendix C) in strong, tight containers in a secured area that is protected from the weather, such that none can escape by gravity into the environment. Keep lids tightly secured when not in use.

Emergency Response Personnel
Attach to the outer door of each laboratory the name and phone number of a person(s) to contact in case of an emergency.

Waste Minimization
Institute methods to recycle wastes and to reduce waste volume and toxicity. Substitute nonhazardous or less toxic materials whenever possible. Purchase only the amount of chemical that is needed. Excess chemicals often become waste and any purchase savings are outweighed by disposal costs.

Training
Personnel who handle hazardous waste or prepare it for shipping shall receive training on proper handling procedures and emergency response procedures. This includes Right-to-Know training, review of this document, and completion of the Chemical Hygiene & Laboratory Safety and Hazardous Waste training courses.

Classification of Chemical Waste

Waste Disposal Guide Table of Contents