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THE
ORCBS > Hazardous
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FREQUENTLY
ASKED QUESTIONS
- What
does RCRA mean?
- What
is a non-RCRA hazardous waste?
- What
is a non-RCRA non-hazardous waste?
- How
do we label waste that is non-RCRA hazardous waste?
- What
types of waste MUST have lids?
- What
counts as a hazardous waste lid?
- Are
pipettes contaminated with trace phenol and chloroform a hazardous
waste?
- Is
it acceptable to have open containers of solid phenol/chloroform
waste in the hood?
- Can
I put chloroform/phenol tips in a beaker and dry them overnight?
- Do
I have to put a waste tag on all my containers?
- I
have to label many small containers or vials? Or are there other
ways to label these?
- Can
I write the common name of a chemical, abbreviation, or product
name instead of the iupac name? For example-TRIS, HCl or TEMED?
- Can
we use biohazard bags for hazardous waste?
- What
bags can be used for hazardous waste?
- What
bags can be used for non-RCRA hazardous waste?
- Can
I put the hazardous waste label on the hazardous material tag
or does it go on the container?
- What's
the correct way to label and date a 1-gal glass bottle used to
collect solvent waste effluent from our HPLC system and subsequently
dumped into our larger 5 gallon waste container?
- If
sodium chloride is not a hazardous waste, why does it have a number
in the waste book?
- Can
I generate a hazardous waste in my lab and put it into a container
in someone else's lab?
- What
training is required? Who needs to be trained?
- Do
I need to do the annual refresher training?
- How
can I see my workers' training records as a PI?
- How
can I see my own training records?
- What
is the ORCBS web address?
- How
do you manage used silica column contaminated with trace solvent?
- How
should I handle rags that have come in contact with waste solvent?
- How
do I label and collect used vacuum pump oil?
- Can
I dilute my methanol to a level below flammable limits and pour
it down the drain?
- How
do I attach a waste tag to the container?
- What
exactly is meant by color/consistency on a waste tag?
- I
am recovering solvents. How do they need to be managed?
- The
ORCBS cleaned up a spill in my lab. What do I have to do with
the waste?
- How should precious metals destined for reclamation be handled?
- What
does RCRA mean?
The Resource
Conservation and Recovery Act (RCRA) of 1976. This is the federal
law passed by Congress which has been the foundation for all of
the hazardous waste laws. The ORCBS picks these wastes up and
properly disposes of them. They are referred to as "hazardous
waste."
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- What
is a non-RCRA hazardous waste?
Any waste that
does not meet the definition of hazardous waste in RCRA, but is
still a hazardous chemical, is a non-RCRA hazardous waste. The
ORCBS picks these wastes up and properly disposes of them.
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- What
is a non-RCRA non-hazardous waste?
These are such
things as paper towel, uncontaminated gloves, or anything that
is not defined as RCRA to be hazardous waste, and is not a hazardous
chemical. These wastes are put into municipal waste containers.
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- How
do we label waste that is non-RCRA hazardous waste?
Non-RCRA hazardous
wastes should be labeled as such. In order to ensure that inspectors
do not cite the University for improperly labeled waste, non-RCRA
hazardous waste, such as ethidium bromide, or pipettes tips drying
should be labeled 'non-RCRA hazardous waste' with other wordage
describing the waste such as 'ethidium bromide gels' or 'acrylamide
gels' or 'used silica gel'. For example, a bucket of silica gel
might have a waste tag completely filled out with the words 'Used
Silica gel - non-RCRA hazardous waste' or for gels 'Ethidium bromide
gels - non-RCRA hazardous waste' written in the Unabbreviated
Chemical Name section.
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- What
types of waste MUST have lids?
Containers
used to collect Hazardous Waste must be closed at all times
except as necessary to add or remove materials.
- Any liquid
waste must have a lid.
- Non-RCRA
hazardous waste solids are not required to be stored in closed
containers.
- Biohazardous
wastes are required to have a lid.
- If a
container left open would expose persons to hazardous chemicals,
then the wastes should be stored in closed containers.
- If the
compounds with which you are working are so dangerous that
it entailed extra precautions to avoid contact, then that
same amount of precaution should be used when storing the
waste materials.
Examples
of non-RCRA hazardous waste which would not require a closed
lid: ethidium bromide gels, papers/gloves contaminated with
acrylamide gels.
Examples
of non-RCRA hazardous wastes which should be kept closed - or
at least stored in an operating hood: silica gel with thiophenol
residues, silica gel with acetonitrile (unless it has completely
evaporated), wipes contaminated with formaldehyde.
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- What
counts as a hazardous waste lid?
Lids should
be constructed of a solid material. They should also be of such
form so as to minimize the amount of vapors that could escape
the container that they cover. Threaded lids or those of such
quality as Tupperware would be considered proper for container
closure. Foil, plastic trays, or loose fitting plastic lids would
not be considered acceptable. Containers used to hold non-RCRA
hazardous waste would not necessarily have to have lids or lids
meeting these specifications.
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- Are
pipettes contaminated with trace phenol and chloroform a hazardous
waste?
Chloroform
is considered a hazardous waste in concentrations of 6.0ppm or
greater. If a material being collected for disposal states that
there is 'trace' chloroform, then the researcher creating the
waste must decide whether the waste materials contain chloroform
at that level. If the level of chloroform is less than 6.0ppm,
then the material is non-RCRA hazardous waste and should be labeled
as such to avoid the perception that it is an unlabeled hazardous
waste. Otherwise it must be labeled 'hazardous waste' and have
an attached, completed waste tag and a closed lid.
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- Is
it acceptable to have open containers of solid phenol/chloroform
waste in the hood?
There are
cases where you would not be permitted to store phenol/chloroform
waste open in the hood. If the waste consisted of an eppindorf
tube that, after use, still contained 3% or more of its contents,
then drying the remaining liquids would constitute treating
the waste (which requires a permit). In this circumstance, the
materials would have to be collected in a labeled hazardous
waste container with a lid, kept closed at all times except
so as to add or remove waste. An open container would not be
permitted.
Chloroform/phenol
wastes (solid debris) can only be stored open if it is determined
that the waste is non-RCRA hazardous waste. If a pipette is
used to transfer chloroform, then when that process is finished
the pipette becomes solid waste. If it no longer contains more
than 3% of its original contents, it is RCRA empty. At that
point there may be a small amount of residual chloroform in
the pipette. If you choose to further dry the pipettes in the
hood for subsequent disposal into a trash can, you are permitted
to do so.
It is advised
that the pipettes be placed into the normal trash as soon as
they dry (which should be in less than an hour). By removing
the dried pipettes or tips from the work area as quickly as
possible, there is no possibility for confusion on the status
as a RCRA hazardous waste or a non-RCRA hazardous waste. In
addition, a designated drying area could be marked off or labeled
with lab tape specifically for that purpose.
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- Can
I put chloroform/phenol tips in a beaker and dry them overnight?
Pipettes and
tips eligible for drying and disposal as normal trash should not
be kept longer than the end of a worker's shift. If, however,
it is necessary to do so, then the beaker should be labeled 'non-RCRA
hazardous waste - drying chloroform/phenol tips'. In general if
work areas are kept clean and free of ambiguously labeled materials
there will be fewer problems when an inspection occurs.
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- Do
I have to put a waste tag on all my containers?
"Attach
an MSU
Materials Pick Up Tag to each and every container of process
waste." (MSU
Waste Disposal Guide) If the container is the original container
with unused portions of chemicals, then you do not need to attach
a waste tag.
The main
reason for attaching a waste tag is to fulfill the requirement
that waste be identified by knowledge of the generator. Attaching
a waste tag to otherwise non-RCRA hazardous waste conveys what
the material is to any inspector or emergency responder. In
order to comply with the law, you need to prove that you know
what you are managing as a waste.
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- I
have to label many small containers or vials? Or are there other
ways to label these?
If a number
of wastes in small containers have the same waste in them, then
a box can be used to store these wastes. The box itself would
need the proper marking and labeling. If the small containers
have different wastes in them, then they would each need their
own waste tags.
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- Can
I write the common name of a chemical, abbreviation, or product
name instead of the iupac name? For example-TRIS, HCl or TEMED?
The regulations
state that the chemical name must be on the container. The waste
tags list unabbreviated chemical name under 'Contents'. If you
want to use abbreviated or common product names, then you will
have to define them by attaching the definitions to the waste
tag.
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- Can
we use biohazard bags for hazardous waste?
No. Biohazard
bags should only be used for what they were intended - biohazardous
materials. A biohazardous material is one which is generated through
the lab process, contaminated with potentially infectious materials
or recombinant DNA. Ethidium bromide or chloroform do not fit
this definition.
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- What
bags can be used for hazardous waste?
If the waste
is hazardous waste, then the bag must be able to be closed during
storage (unless being kept inside a closable container), and
able to be closed upon disposal. A zip lock bag is often useful
in these cases. Other options may include trash bags used to
line a closable container which are removed when the waste is
picked up or made ready for pick up by the ORCBS. The bag may
not be a biohazard bag.
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- What
bags can be used for non-RCRA hazardous waste?
It can be
the bag of your choice, as long as it is leak proof and not
a biohazard bag.
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- Can
I put the hazardous waste label on the hazardous material tag
or does it go on the container?
The best place
to put a hazardous waste label or write the words “hazardous
waste” is directly on the container. If doing so is not possible
due to container configuration or the material from which it is
made, then you may put the words on the MSU materials pick up
tag.
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- What's
the correct way to label and date a 1-gal glass bottle used to
collect solvent waste effluent from our HPLC system and subsequently
dumped into our larger 5 gallon waste container?
A container
used as an intermediate storage container for hazardous waste
must:
- be labeled
“hazardous waste”
- have
the unabbreviated name(s) of the chemicals being collected
- be closed
at all times when being stored
- be emptied
into the main container at the end of the shift/day
To accommodate
circumstances where a waste is being constantly generated, such
as with HPLC instrumentation, a cap should be modified to tightly
hold the tubing. A hole should be drilled into the cap of the
container just large enough so that no vapors will escape during
use or storage. Where possible, it would be preferred that intermediate
waste containers be avoided.
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- If
sodium chloride is not a hazardous waste, why does it have a number
in the waste book?
The Waste Disposal
Guide contains a list of common chemicals in use on campus. The
list is used as an aid for the researcher and ORCBS personnel.
Some chemicals have designated letters or symbols next to the
name. The symbols help the researcher determine whether a chemical
can be treated as non-hazardous or whether it has any particularly
hazardous properties. For example, all chemicals marked with an
asterisk are considered non-hazardous.
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- Can
I generate a hazardous waste in my lab and put it into a container
in someone else's lab?
No. Wastes
must be kept near the location that they are created. The storage
of chemicals in laboratories is governed by the Satellite Accumulation
rules. The law states that “a generator may . . . accumulate
. . . in containers at or near any point of generation where
wastes initially accumulate and which is under the control of
the operator of the process that generates the waste. . ."
As soon as waste is being carried to a different location (i.e.
through a door into another room) the generator can no longer
store wastes according to the more lenient satellite accumulation
rules. The more stringent rules requiring things such as weekly
inspections, containment pads, and using special waste codes
instead of the chemical name.
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- What
training is required? Who needs to be trained?
Hazardous waste
training is required for anyone who, by their action or inaction,
could cause non-compliance with federal waste regulations. This
would include persons who create or handle hazardous waste, fill
out a pick up requests, are in charge of lab areas where waste
is created, and supervisors of these persons. The hazardous waste
initial training is a part of the Chemical Hygiene and Laboratory
Safety Training.
ORCBS
Training Sign-up
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- Do
I need to do the annual refresher training?
All persons
required to take hazardous waste initial training must take
refresher training annually. This requirement is a matter of
federal law.
On-line
Hazardous Waste Refresher Training
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- How
can I see my workers' training records as a PI?
All PI's
should now have an access code allowing them to view
the records of all persons listed as working for them. If
you do not have access to the ORCBS database in this manner,
please contact our Safety Informational
Specialist.
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- How
can I see my own training records?
You should
have been sent an access code by email to view
records on-line. If you do not have access to the ORCBS
database, please contact our Safety
Informational Specialist.
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- What
is the ORCBS web address?
Our web
address is: www.orcbs.msu.edu
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- How
do you manage used silica column contaminated with trace solvent?
Silica column
materials contaminated with trace solvent can be collected as
non-RCRA hazardous waste. Because the column materials did not
come into contact with the waste solvent, they are not subject
to the rules involving process wastes. If, however, the solvent
being used is on the toxic characteristic list (pyridine, chloroform,
benzene - see pg. 61 of the Waste Disposal Guide or the back
of a waste tag) then the material may be RCRA hazardous and
thus subject to all required storage provisions. Please contact
the ORCBS for specific questions on this issue.
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- How
should I handle rags that have come in contact with waste solvent?
Rags used to
wipe listed (LINK) solvents can be used and reused without any
special storage. Rags containing some solvents (methanol, xylene,
methyl isobutyl ketone, butanol, ether, ethyl acetate, ethyl benzene)
can be discarded when used up and dry.
Spent rags
used to wipe other solvents (toluene, methylene chloride, trichloroethylene,
benzene, methyl ethyl ketone, 11,1,-trichloroethane, plus many
others) must be collected and stored as hazardous waste. Sending
the used rags to Laundry would constitute treating the waste,
which requires a permit and would not be allowed. For compounds
not addressed here, contact the
ORCBS for specific answers.
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- How
do I label and collect used vacuum pump oil?
Any oil
being collected for disposal must have the words 'Used Oil'
on it. The oil must be collected in a closed container with
an attached, completed waste tag. Cutting oil and refrigerator
oil must be kept separate from pump oil or other oils since
they contain too high a level of halogenation.
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- Can
I dilute my methanol to a level below flammable limits and pour
it down the drain?
No. While
it may technically be legal to dump various items down the drain,
it is not the policy of MSU to dump flammable liquids (e.g.
ethanol), mutagens or carcinogens (e.g. formaldehyde) down the
drain even after dilution. Diluting the wastes we generate strictly
for the purpose of avoiding waste regulations technically constitutes
waste "treatment" for which we are not licensed and
could also have implications for our local sewer authority.
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- How
do I attach a waste tag to the container?
A list of
the contents attached to a waste container must be of sufficient
quality that it will not disconnect as soon as the container
is nudged or a strong breeze blows over the container. This
can be accomplished by:
- A twist
tie that is supplied with the ORCBS container.
- Taping
the tag to a container
- A chain
attaching the container and a clipboard is an acceptable system.
The clipboard would need the tag, or sheet with the contents.
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- What
exactly is meant by color/consistency on a waste tag?
Generators
must prove by knowledge or testing that a waste they create
is as they have described it. The University agreed with regulators
to verify that the contents of a container match the description,
thus avoiding extensive and expensive chemical testing costs.
This subjective means of analyzing wastes is considered sufficient
to prove that the generator does indeed know what has been placed
in a waste container. Some suggestions are already given on
the waste tags to aid in describing the waste. If you are using
bromocresol green, then the color will likely be green. If you
are using nonhalogenated solvents, then the solution may be
colorless. The consistency ranges from waterlike to viscous/oily.
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-
I
am recovering solvents. How do they need to be managed?
Solvents
being stored with the intent of recovery should be recovered
within the 90 days since the waste was generated. Until they
are recovered, they must be labeled with the words 'hazardous
waste' and have an attached waste tag. After recovery, a log
must be kept stating the type and quantity of materials were
recovered. The still bottoms from the recovery must be sent
as waste to the ORCBS. Within the first month of every year
a report must be submitted to the Hazardous Waste Coordinator
summarizing the year's recovery activities.
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-
The
ORCBS cleaned up a spill in my lab. What do I have to do with
the waste?
The waste should be treated like any other waste generated.
If it is hazardous, it will need to have the words 'hazardous
waste' with an attached waste tag. If it is non-hazardous, attach
a waste tag, and write 'non-RCRA hazardous material' on the
container. Before the ORCBS personnel have left the area, you
should consult with them regarding whether the waste generated
by the spill activities is RCRA hazardous.
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How should precious metals destined for reclamation be handled?
Precious metals in non-RCRA hazardous matrices (not hazardous wastes), like gold, platinum, or palladium are not regulated under EPA as a hazardous waste. The EPA does regulate precious metals like silver, or any precious metal containing hazardous constituents, like cyanides. Precious metals wastes destined for reclamation need only be labeled something to the effect of "silver salts for reclamation" or "scrap gold". However the EPA prohibits generator speculative accumulation of such materials and requires that 75% of the material be recycled per calendar year. Records showing the volume of the materials stored at the beginning of the calendar year, the amount received during the year, and the amount remaining at the end of the calendar year must be maintained. Thus recyclers need to keep an accurate log and be able to demonstrate they are processing at least 75% of their accumulated stocks in a calendar year. If the material would be considered a hazardous waste and is being sent off site for refining, a Uniform Hazardous Waste Manifest must accompany the material. The ORCBS must be consulted before doing so to ensure that the required information is correct.
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