Procedure 12:
Laboratory Waste Pickup
and RCRA Hazardous Waste Determination

Policy

Identifying laboratory wastes

Laboratory workers designate a chemical as a laboratory waste when:

• it has gone through a research process and is no longer needed,
• it is a virgin chemical no longer needed,
• has exceeded its expiration date, or
• it is a clean up material from a chemical spill.

Removal of laboratory wastes

Laboratory workers notify ESF of waste to be removed by completing a Laboratory Waste Tag and sending one copy to the ESF (Procedure 5).

Using the tag information, ESF staff create a "tags on campus" list prior to picking up laboratory waste from labs and moving it to the Given Bunker. Lab wastes are transported through the buildings using plastic bins, wheeled carts with spill containment edges or other secondary containment equipment. Lab wastes are unloaded at the short term storage area for determination of disposition.

A University vehicle, permitted to haul hazardous waste, and stocked with spill containment and emergency response equipment is used to transport the waste from the laboratory buildings on the contiguous campus to the short term storage area in the Given Bunker. Wastes transported in ESF vehicles are placed within plastic bins or other secondary containment.

ESF personnel are trained in accordance with 29 CFR 1910.120, 1200 and 1450. They wear Personnel Protective Equipment (PPE) appropriate to the relative risks of handling closed containers of laboratory waste during pick-up.

In the event an emergency or release at the Given Bunker or during transportation, ESF staff will implement the Campus Contingency Plan, calling for assistance or evacuation as needed. In the event that hazardous materials are released to the environment or personnel, ESF staff will notify the Vermont DEC. All incidents will be reported at the ESF.

Identifying RCRA hazardous wastes

At the Given Bunker, ESF personnel determine if laboratory wastes:

• are acceptable for reuse through the ChemSource program,
• are non hazardous wastes which can be managed as solid waste, or
• are destined for management as hazardous waste through the ESF.

ESF staff will determine if "laboratory waste" is acceptable for reuse if:

• the container, cap and label are all in good condition,
• the useful life of the chemical has not passed,
• the chemical is in a usable form, and
• there is anticipated need for the chemical at UVM.

ESF staff will determine that a laboratory waste is destined for management as a RCRA hazardous waste if the material cannot be reused and:

• is regulated as hazardous under Vermont Hazardous Waste Management Regulations, or
• is, in the opinion of ESF staff or public perception, hazardous in any other way.

Wastes that are not destined for reuse or for management as hazardous waste will be either recycled or disposed in accordance with solid waste regulations, policies and procedures.

Packaging Wastes

Upon arrival at the Given Bunker, lab wastes are "lab-packed," or packaged into DOT shipping containers approved for transport of that waste. Shipping containers are labeled with the UVM Hazardous Waste Barrel Labels (this is not a laboratory waste label) and DOT hazard labels, or with equivalent labels and markings, in accordance with EPA and DOT regulations. A second copy of the tag is attached to the barrel label to complete the inventory for that shipping container.

Lab wastes destined for potential reuse will be packaged for transport to the ESF. The copy of the Laboratory Waste Tag which is still attached to the waste container will be marked to reflect this determination. The lab waste will be placed in the ChemSource inventory upon arrival at the ESF.

Plan

Who:

Laboratory workers will tag the waste when it is ready to be removed from the lab.

ESF staff will manage the tagged lab waste when it is

1. removed from the laboratory,
2. transported to and stored at the Given bunker, and
3. shipped to and managed at the ESF.

When

ESF staff generally remove lab waste from the labs at least once each week. Under no circumstance will lab waste remain in the lab longer than 30 days after the date when it is tagged.

ESF personnel will determine the fate of each container of lab waste when it reaches the short term accumulation area under the control of ESF staff (currently, the Given bunker).

ESF staff ship hazardous waste from the Given bunker within 90 days of its arrival at the bunker. This date is referenced on the hazardous waste barrel label.

Where

This procedure will cover all laboratories covered by the UVM Chemical Hygiene Plan or the UVM Environmental Management Plan, as well as UVM's short term accumulation area and transportation routes.

Governing Regulations

The Given Bunker is managed as a short term storage area under Vermont Hazardous Waste Management Regulations. Wastes received at the ESF will be managed in accordance with RCRA and Vermont Hazardous Waste Management Regulations, as well as the ESF hazardous waste facility certification (Part B Permit).

Hazardous wastes are shipped to the ESF on permitted hazardous waste transporter vehicles with Vermont Hazardous Waste Manifests. Placardable amounts of hazardous materials are transported only by drivers with a valid Commercial Driver's License with a Hazardous Materials endorsement.

Procedure

Hazardous Waste Barrel Label

Records

Records of tags, barrel labels, manifests and other shipping papers will be stored in the waste tracking database maintained at the Environmental Safety Facility.