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EHS > Hazardous Waste > Resources & Links >

FREQUENTLY ASKED QUESTIONS

  1. What does RCRA mean?
  2. What is a non-RCRA hazardous waste?
  3. What is a non-RCRA non-hazardous waste?
  4. How do we label waste that is non-RCRA hazardous waste?
  5. What types of waste MUST have lids?
  6. What counts as a hazardous waste lid?
  7. Are pipettes contaminated with trace phenol and chloroform a hazardous waste?
  8. Is it acceptable to have open containers of solid phenol/chloroform waste in the hood?
  9. Can I put chloroform/phenol tips in a beaker and dry them overnight?
  10. Do I have to put a waste tag on all my containers?
  11. I have to label many small containers or vials? Or are there other ways to label these?
  12. Can I write the common name of a chemical, abbreviation, or product name instead of the iupac name? For example-TRIS, HCl or TEMED?
  13. Can we use biohazard bags for hazardous waste?
  14. What bags can be used for hazardous waste?
  15. What bags can be used for non-RCRA hazardous waste?
  16. Can I put the hazardous waste label on the hazardous material tag or does it go on the container?
  17. 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?
  18. If sodium chloride is not a hazardous waste, why does it have a number in the waste book?
  19. Can I generate a hazardous waste in my lab and put it into a container in someone else's lab?
  20. What training is required? Who needs to be trained?
  21. Do I need to do the annual refresher training?
  22. How can I see my workers' training records as a PI?
  23. How can I see my own training records?
  24. What is EHS web address?
  25. How do you manage used silica column contaminated with trace solvent?
  26. How should I handle rags that have come in contact with waste solvent?
  27. How do I label and collect used vacuum pump oil?
  28. Can I dilute my methanol to a level below flammable limits and pour it down the drain?
  29. How do I attach a waste tag to the container?
  30. What exactly is meant by color/consistency on a waste tag?
  31. I am recovering solvents. How do they need to be managed?
  32. EHS cleaned up a spill in my lab. What do I have to do with the waste?
  33. How should precious metals destined for reclamation be handled?

 

1. 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. EHS picks these wastes up and properly disposes of them. They are referred to as "hazardous waste."

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2. 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. EHS picks these wastes up and properly disposes of them.

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3. 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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4. 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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5. 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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6. 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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7. 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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8. 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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9. 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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10. 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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11. 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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12. 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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13. 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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14. 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 EHS. The bag may not be a biohazard bag.

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15. 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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16. 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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17. 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:

  1. be labeled “hazardous waste”
  2. have the unabbreviated name(s) of the chemicals being collected
  3. be closed at all times when being stored
  4. 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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18. 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 EHS 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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19. 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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20. 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.

Chemical Hygiene & Laboratory Safety/Hazardous Waste Initial Training

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21. 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.

Hazardous Waste Refresher Training

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22. 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 EHS in this manner, please contact our Safety Informational Specialist.

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23. 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 EHS database, please contact our Safety Informational Specialist.

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24. What is the EHS web address?

Our web address is: www.ehs.msu.edu

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25. 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 EHS for specific questions on this issue.

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26. 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 EHS for specific answers.

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27. 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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28. 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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29. 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 EHS 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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30. 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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31. 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 EHS. 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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32. EHS 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 EHS 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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33. 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.  EHS must be consulted before doing so to ensure that the required information is correct.

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