Procedure 5:
Laboratory Management of Waste Containers

Policy

Management of laboratory waste containers is the key to proper disposal of hazardous waste. This section outlines UVM's practices for laboratory management of chemical waste.

Labelling of Waste Containers

Containers of laboratory waste must be properly labeled, even while waste is being accumulated in a less than full container. Lab workers accomplish this by using:

1. the Laboratory Waste Label when accumulating waste in a container; or
2. the Laboratory Waste Tag, when a waste container is full or ready for pick-up.

Labels and Tags are available through the ESF; another label with equivalent information may be used if approved by ESF staff. Dirty containers must be cleaned before affixing labels and waste tags.

Laboratory workers will determine if waste is acutely hazardous when completing the Label or Tag. Acutely hazardous laboratory waste is defined by regulation. The list of generic names of acutely hazardous wastes can be found at http://esf.uvm.edu/acute.html. This determination is verified by ESF staff when reviewing the waste tag.

If a container is small, attach the Label or a Tag with a string or wire, or place the container in a larger, properly labeled, secondary container. If groups of compatible chemicals are stored together in a secondary container, the Label or Tag must be placed on the secondary container.

Storage of Laboratory Waste

Laboratory Storage Limits

Lab workers should arrange for waste pickup regularly to avoid excess storage of material within the workspace. Labs are required to arrange for disposal whenever they accumulate:

• up to 55 gallons of laboratory waste or
• one quart of acutely hazardous laboratory waste.

Upon reaching these thresholds, laboratory personnel must tag the laboratory waste container and include the date when this threshold was met.

Closed containers

Laboratory personnel must assure that containers of laboratory wastes are securely closed except when wastes are being added to or removed from the container either manually, or automatically by means of an in-line waste collection system.

Snap caps, such as those found on milk bottles, caps of the wrong size, parafilm, or other loose fitting lids are not acceptable. Laboratory waste containers can be closed with a funnel only if the funnel has a tight-fitting lid and secondary containment is provided, or if the lidded funnel fits securely into the container so that if it turned over, the contents would not spill out. Solid debris can be packaged into sealed plastic bags.

Removal of Laboratory Waste

Only the Laboratory Waste Tag is used to notify ESF staff that laboratory wastes are ready to be removed from the laboratory. Laboratory personnel are responsible for submitting a copy of the Laboratory Waste Tag to the ESF and attaching the remaining copies of the Laboratory Waste Tag to the waste container (Procedure 12).

Plan

Who:

Laboratory workers are responsible for

• Proper labeling of all chemical and waste containers,
• marking the date when waste is accumulated,
• proper storage of waste and chemicals,
• preventing spills of waste or chemicals,
• monthly inspection of waste containers and in-line collection systems,
• informing ESF staff of the presence of laboratory waste ready for removal by sending the top copy of the Tag to the ESF,
• limiting waste storage within the lab and adhering to storage limits.

ESF personnel are responsible for:

• managing tags received at the ESF, and
• removing the waste from the laboratory within 30 days of the date on the tag (Procedure 12).

When:

Laboratory waste containers must be labeled when waste is first added to them

Waste containers must be closed, and properly stored whenever waste is not actually being added to or removed from the container.

Laboratory waste containers will be tagged for disposal when

1. they are full,
2. ready for disposal,
3. when 55 gallons of laboratory waste has accumulated in the laboratory, or
4. when 1 quart of acutely hazardous laboratory waste has accumulated in the laboratory.

In no case, will 55 gallons of laboratory waste be stored in a laboratory without being tagged for disposal.

Where:

Appropriate storage locations

Laboratory personnel are responsible for assuring that laboratory wastes are stored only in active laboratories or supervised and secured storage rooms with ventilation and fire suppression systems. Teaching labs, closets or unused rooms are not appropriate for chemical storage.

Laboratory wastes stored on the floor must have adequate secondary containment. ESF staff will supply secondary containment bins when necessary.

Containers of laboratory wastes must not block emergency egress or safety showers.

Waste accumulation labels and Laboratory Waste Tags will be used in all laboratories covered by the UVM Chemical Hygiene Plan or the UVM Environmental Management Plan

Preventing leaks

Leaks can be prevented by leaving empty space at the top of waste containers.

Containers will be inspected at least monthly to assure that no degradation of the container or its contents has occurred.

Containers of laboratory wastes must be compatible with the laboratory waste so that the container's integrity is not impaired by its contents.

Laboratory personnel must not commingle incompatible wastes. ESF staff can supply containers suitable for waste storage and transport when necessary.

A leaking container must be either packed in a secondary container, or its contents transferred to another container.

Procedure

Records

Accumulation labels will be replaced by the Laboratory Waste Tags and so will generate no records.

Laboratory Waste Tags have four parts. One copy alerts ESF staff to remove the waste from the lab. One remains attached to container until it is packaged for end disposal, recycle or reuse. The others are used by the ESF for waste tracking purposes (Procedure 12).

Records of laboratory waste designations, pickups and management will be managed and stored in a database maintained by the Environmental Safety Facility Staff. The records of laboratory waste disposal will be maintained for at least three years after disposal of the waste.