Lab Hazardous Waste General Fact Sheet
Hazardous waste is a category of waste which poses a threat to employees and the environment if mismanaged. Harvard University produces a variety of hazardous wastes subject to strict regulation. These wastes require special handling and management practices and disposal by licensed hazardous waste facilities. This document has been developed to assist Facilities Maintenance, Construction/Renovation Managers, Engineering and other University personnel with proper hazardous waste handling. The key hazardous waste issues typically related to University operations are summarized below. Additional information is available by contacting your local EH&S office or the EH&S Web Site.
Hazardous waste regulations require that hazardous waste be accurately identified. Common hazardous wastes generated by University operations include:
- Waste oils and lubricants generated by a variety of University operations including motor vehicles, elevators, plant maintenance, etc.
- Unused chemicals and other hazardous substances, such as pesticides, strong acids & bases, paints, aerosol cans, etc. that are no longer needed, do not meet specifications, are contaminated, have exceeded their storage life, or are otherwise unusable.
- Used ethylene glycol and other coolants.
- Used solvents from cleaning, painting or other processes.
- PCBs, batteries, lead paint and other miscellaneous materials including, contaminated rags and wipes, broken mercury-containing lamps (i.e. fluorescent lamps) and thermometers.
- Contractor hazardous wastes can include any of the above. Harvard University is ultimately responsible for the proper on-site management and off-site disposal of these hazardous wastes.
Common lab hazardous wastes include:
- Spent solvents, acids, bases and oxidizers used in extractions, cleaning or other processes.
- Unused reagents and other chemicals that are no longer needed, do not meet specifications, are contaminated, have exceeded their storage life, or are otherwise unusable in the lab.
- Waste oils.
- Other miscellaneous materials, including broken mercury thermometers, heavy-metal salts, poisons, etc.
These wastes may either:
- Appear on lists of specific chemicals defined as hazardous waste issued by the Massachusetts Department of Environmental Protection (DEP) or,
- Exhibit certain characteristics defined by the DEP.
These characteristics include ignitability, corrosivity, reactivity and toxicity. Once it has been determined that a chemical or material will not be used or reused at the University, typically become subject to hazardous waste regulation. It should also be noted that in many cases, mixtures which contain a hazardous chemical can be subject to hazardous waste regulation. Your local EH&S representative is available to provide assistance with waste identification (or see the EH&S Home Page).
Regulations require a permit for the transport of hazardous waste on public roads. Discharging hazardous wastes and chemicals in sinks is prohibited by wastewater regulations. Regulations also require that hazardous wastes be accumulated and stored in properly managed containers. Containers storing hazardous wastes are subject to the following requirements:
Storage
Containers may only be stored in a designated "satellite" accumulation areas or "main" accumulation areas. Satellite areas are accumulations of hazardous waste at or near the point of generation under the control of a single person. Once a satellite accumulation container is filled, it must be dated and transferred to a main accumulation area or shipped off-site for disposal, within three days. Be aware that there can only be one container per waste stream (same chemical or mixture) in the SAA at any given time. Main accumulation areas are designated storage areas which are subject to longer term storage time limitations and must meet various other criteria.
Labeling
Labels must include the following information:
- The words "Hazardous Waste."
- The waste type in words (i.e. Spent Non-Halogenated Solvents, Waste Oil, etc.).
- The associated hazards in words (i.e. ignitable, toxic, etc.).
- The date upon which the container becomes filled or otherwise ready for disposal.
Containers must be labelled and situated so that labels are clearly visible for inspection.
Closure
Containers must be closed at all times, unless waste is being added or removed. Open-top funnels may not be left in container opening.
Condition & Compatability
Containers must be in good condition. There may not be severe rusting, dents, or other conditions which could cause a leak, etc. Containers must be compatible with hazardous wastes stored within them. A metal container should not be used to store aggressively corrosive substances. When in doubt, use the original shipping container.
Weekly Inspections
Containers must be inspected weekly to ensure that they are properly labeled, in good condition, and meet other criteria described above. It is the responsibility of facility personnel to inspect satellite accumulation hazardous waste containers on a weekly basis.
University personnel whose duties or activities involve the management (i.e. generation or responsibility for waste containers, etc.) of hazardous waste are required to receive hazardous waste training within 6 months of the start of such activities or duties and annually thereafter. At Harvard, initial training is provided by attending one of the regularly scheduled EH&S classroom training sessions offered at the Longwood and Cambridge/Allston campuses. Thereafter, annual refresher training is provided via EH&S web-based training program. Federal law requires generators of hazardous waste to implement measures to limit and reduce the volume and toxicity of hazardous waste. Waste minimization techniques include:
- Process/equipment adjustment or modification.
- Toxic material substitution.
- Waste segregation and separation.
- Recycling.
Please integrate these practices whenever and wherever you can.
Releases of hazardous waste(s) to the environment should be immediately reported to your Department's Environmental and Safety Compliance Officer. Releases to the environment include discharge of solids, liquids and/or gases to lab drains, trash containers or to the atmosphere. If there has been a release, please immediately call the local EH&S office during normal business hours (Cambridge: 495-2060, Longwood: 732-1720). After-hours releases should be reported to the Control Center:495-5560. EH&S will assist in determining whether the release must be reported to regulatory agencies.
Both the DEP and EPA have hazardous waste program enforcement responsibility and authority. Either or both may perform unannounced compliance inspections at anytime. Commonly observed compliance deficiencies observed during DEP/EPA compliance inspections include:
- Mislabelling of containers.
- Containers not properly closed.
- Failure to transfer waste from satellite accumulation areas within 3 days.
- Incompatible wastes not properly segregated.
- Lack of sufficient personnel training and training records.
Universal Waste
The following wastes are NOT considered hazardous when recycled:
- Hazardous batteries primarily nickel cadmium (NiCd), Lithium and mercury containing button batteries (Note: Lead Acid batteries are not considered universal wastes - they should be recycled thru alternative means - contact EH&S (617) 496-3322 Cambridge/Allston; (617) 432-1720 Longwood).
- Mercury-containing switches
- Mercury-containing lamps, such as fluorescent lamps; and
- Hazardous waste pesticides (e.g. mercury-based, arsenicals, chlorinated), pesticides that have been recalled or banned from use, and/or pesticides that are obsolete, have become damaged or are no longer used due to changes in application practices.
If collected and recycled these wastes are considered “universal” wastes and subject to less stringent waste storage requirements listed below:
- Designate a Universal Waste Storage Area and Post Appropriate Signage -Signage can be obtained through University Operation Services (UOS) - Solid Waste and Recycling Group, (617) 495-3042 or can be downloaded from the EH&S web page at /ehs/env.shtml.
- Label and date containers/boxes - Containers or boxes used to collect and store Universal Waste must be labeled with Harvard’s “Universal Waste” label and must also include the specific name of the waste item(s). In addition, the label must be marked with the date upon which storage begins. The on-site storage limit for universal wastes is one year.
Harvard’s Universal Waste labels can be obtained through the UOS Solid Waste and Recycling Group, (617) 495-3042 or EH&S at (617) 496-3322 (Cambridge) ; Longwood at (617) 432-1720.
- Ensure Safe Storage - Store non-leaking batteries, unbroken mercury containing devices and intact fluorescent lamps in a secure drum or box to prevent breakage. In some instances it may be prudent to store Universal Waste on pallets that allow for secondary containment.
- Pick-up/Removal of Universal Waste - If you contract with the UOS Solid Waste and Recycling Group for services, then you can contact them at (617) 495-3042 and schedule pick-up of Universal Waste. If your facility/department does not contract with UOS Solid Waste and Recycling Group, then you can contact EH&S at (617) 496-3322 to arrange for pick-up or call an outside recycler for pick-up of Universal Waste.
- Record Keeping - If your facility/department contracts with the UOS Solid Waste and Recycling Group for pick-up and removal of Universal Waste, they maintain shipment logs with quantities, etc. If you choose to use an alternate recycler for Universal Waste pick-up, you must maintain shipment records, which indicate quantities of Universal Waste removed from your facility, for a minimum of three (3) years.
Enforcement penalties can result in fines of up to $25,000 per day, per violation.
If you have any hazardous waste related questions, contact your local EH&S representative at:
Cambridge/Allston: 496-3322
Longwood: 432-1720
