Frequently Asked Questions (Facility/Laboratory Waste Streams
HAZARDOUS WASTE DISPOSAL
1. Q - How do I dispose of Ethylene Glycol from chillers, boilers and other recirculation systems in my facility?
The Massachusetts Water Resource Authority (MWRA) prohibits drain discharge of Propylene and Ethylene Glycol based heat transfer fluids if they do not meet MWRA discharge limits. Harvard is required to analyze spent glycol for copper, lead, nickel, zinc, pH (Approximately $100) and send results to MWRA for review and approval. Alternatively, you may store waste glycols in 55-gallon drums and ship off-site as non hazardous waste. In either case, call EH&S (6-3322 Cambridge or 2-1720 Longwood) prior to draining and recharging systems to request a sample and analysis or to arrange pickup.
LIGHT BALLASTS
1. Q - Can a light ballast be disposed in the regular trash?
Answer - No, a ballast will contain packing material that is typically ignitable or may contain PCB's. The proper disposal route for all (non leaking) ballast is recycling. To establish a recycling area in the Cambridge / Allston Campus, contact Rob Gogan 495-3042 for assistance . For assistance in establishing a recycling area in the Harvard Medical School or School of Public Health, contact Bob Christiano 432-0701 or Operations 432-1152, respectively.
2. Q - How do I know if a ballast contains Polychlorinated Biphenyl's ( PCB's)?
Answer - Unless the ballast label does not specifically read - "NON PCB CONTAINING" or something similar, you must assume that the ballast contains PCB's. If the ballast label is illegible, consider it to contain PCB's. All (non leaking) PCB ballasts must be collected for recycle.
3. Q - What should I do with NON LEAKING PCB ballast?
Answer - All non-leaking PCB ballasts must be collected for recycle. Facilities generating PCB ballast as a result of ongoing maintenance activities are encouraged to set up a suitable container for their collection. If you are involved in a large scale renovation or construction project, ensure a system is in place to aggregate all ballasts. Please use adequate collection containers for the ballasts eg.- 5 gallon poly ( plastic) screw top pail, 15 gallon poly open top, 30/ 55 gallon poly or steel drums. The containers should be closed when not adding ballasts and be labeled as USED PCB BALLASTS FOR RECYCLE.
To establish a recycling area in the Cambridge / Allston Campus, contact Rob Gogan 495-3042 for assistance. Contact EH&S for any additional assistance at 496-6034. To establish a recycling area in the Harvard Medical School or School of Public Health, contact Bob Christiano 432-0701 or Operations 432-1152, respectively, for assistance.
4. Q - What should I do if the PCB ballast are LEAKING?
Answer - Leaking ballast cannot be recycled, they must be managed as hazardous waste. Contact EH&S in Cambridge 496-3322 / Longwood 432-1720 for assistance in collection and removal.
5. Q - What should I do with NON LEAKING, NON PCB Ballasts?
Answer - All Non-Leaking, Non- PCB ballasts should be collected for recycle. Facilities generating Non- PCB ballast as a result of ongoing maintenance activities are encouraged to set up a suitable container for their collection. If you are involved in a large scale renovation or construction project, ensure a system is in place to aggregate all ballasts. Please use adequate collection containers for the ballasts eg.- 5 gallon poly screw top pail,15 gallon poly open top, 30/ 55 gallon poly or steel drums. The containers should be closed when not adding ballasts and be labeled as USED NON PCB BALLASTS FOR RECYCLE. To establish a recycling area in the Cambridge / Allston Campus, contact Rob Gogan 495-3042 for assistance . To establish a recycling area in the Longwood Campus, contact Bob Christiano (HMS) 432-0701 or Operations (HSPH) 432-1152 for assistance. Contact EH&S for any additional assistance at 496-6034 (Cambridge) or 432-1720 (Longwood).
6. Q - What should I do with LEAKING, NON PCB Ballasts?
Answer - Leaking ballast cannot be recycled, they must be managed as hazardous waste. Contact EH&S in Cambridge 496-3322 / Longwood 432-1720 for assistance in collection and removal.
7. Q - How do I establish a collection area and arrange for the removal/recycle of ballasts?
Answer - To establish a recycling area in the Cambridge / Allston Campus, contact Rob Gogan 495-3042 for assistance.
To establish a recycling area in the Harvard Medical School or School of Public Health, contact Bob Christiano 432-0701 or Operations 432-1452, respectively, for assistance.
BATTERIES
1. Q - Are spent batteries hazardous waste?
Answer - The majority of rechargeable batteries have to be managed as hazardous waste for disposal under the Resource Conservation and Recovery Act (RCRA). Most alkali batteries are not hazardous and therefore do not need to be collected. Under The Code of Massachusetts Regulation (CMR) 310 CMR 30.1034 hazardous batteries are subject to the Universal Waste Management Standards. This standard was designed to "relax" and provide flexibility within some of the hazardous waste regulations pertaining to the collection and disposal of spent hazardous batteries. Nickel cadmium (NiCd), Lithium and mercury containing button batteries must be managed through the universal waste program or must be managed as hazardous waste if leaking - contact EH&S (617) 496-3322 (Cambridge) or (617) 432-1720 (Longwood) for assistance (Note: Lead Acid batteries are not required to be managed as universal wastes if they are intact and are to be recycled through a distributor).
To Comply with Universal Waste Standards
- Post collection area with UNIVERSAL WASTE AREA sign (available at- /ehs/environmental/unv_waste_sign_cam.pdf).
- Container must be in good condition and closed.
- Containers in which batteries are collected for recycle must be labeled or marked clearly with the phrase Universal Waste Batteries.
- Containers must be dated with the accumulation start date, and may be used accumulate batteries for no longer than one (1) year.
If your department has contracted with FMO for Solid Waste and Recycling Services, contact Rob Gogan (5-3042 Mgr. FMO Solid Waste Recycling) and ask about obtaining some battery recycling containers (typically 5 gallon buckets) and labels. If you do not contract with FMO, Contact EH&S Cambridge 6-3322 for labels and to request pickup of these batteries. On the Longwood Campus, drop off your batteries in bins at elevator lobbies.
2. Q - How should I dispose of spent alkaline batteries? (AAA, AA, C, D, 9 volt etc.)
Answer - Although not regulated as hazardous or universal waste, the best disposal route for these batteries is recycling. FMO Solid Waste Recycling group has instituted a battery recycling program that includes all types of dry, non-leaking batteries (alkalines included). If your department has contracted with FMO for these services, contact Rob Gogan (5-3042 Mgr. FMO Solid Waste Recycling) and ask about obtaining some battery recycling containers. On the Longwood Campus, drop off your batteries in bins at elevator lobbies.
3. Q - What should I do with LEAKING batteries --LEAD ACID--
Answer - These batteries must be managed as hazardous waste. Caution! When leaking, these batteries pose a significant contact hazard. SULFURIC ACID is often the liquid constituent of these batteries, and is severely corrosive to skin. Only handle if properly trained and if proper personal protective equipment is available. Leaking batteries cannot be recycled, they must be managed as hazardous waste. Contact EH&S in Cambridge 496-3322 / Longwood 432-1720 for assistance in collection and removal.
FLUORESCENT AND OTHER LIGHTS
1. Q- What should I do with spent (intact) NON BROKEN lights? (Fluorescent, Ultra Violet, Mercury Bulbs)
Answer - These intact lights must be collected for recycle due to their inherent risk to the environment. Under The Code of Massachusetts Regulation (CMR) 310 CMR 30.1034 mercury containing lamps are subject to the Universal Waste Management Standards. This standard was designed to “relax” and provide flexibility within some of the hazardous waste regulations pertaining to the collection and disposal of spent lamps containing mercury. The Universal Waste Management Standards states that universal waste lamps must be managed in such a way that prevents releases of any components of the universal waste to the environment. Fluorescent and Ultraviolet lights are similar in size and technology, and should be collected and packed in original shipping packages or boxes provided by Facility Maintenance. Mercury lamps require special attention and packaging procedures. Mercury lamps are under higher pressure and have elevated levels of mercury over their counterparts. There is an inherently higher risk for breakage and exposure. Only original packaging or Facility Maintenance approved packaging may be used for collection and transport.
To Comply with Universal Waste Standards
- Post collection area with UNIVERSAL WASTE AREA sign (available at unv_waste_sign_cam.pdf)
- Container/Boxes must be in good condition and closed.
- Containers in which batteries are collected for recycle must be labeled or marked clearly with the phrase Universal Waste Used Mercury-Containing Lamps.
- Containers must be dated with the accumulation start date, and may be used accumulate batteries for no longer than one (1) year.
If your department has contracted with FMO for these services, contact Rob Gogan (5-3042 Mgr. FMO Solid Waste Recycling) and ask about obtaining boxes and Universal Waste labels for collection of spent fluorescent bulbs. If you do not contract with FMO Solid Waste and Recycling, contact EH&S Cambridge 6-3322/ Longwood HMS/HSDM Facilities 2-1901 or HSPH Operations 2-1152 for supplies and pickup of these bulbs.
PAINTS
1. Q - I just finished going through the stock of various paints we have used over the years, there are many old cans and colors that we do not have a use for, how should I dispose of them?
Answer - Paint is a common product used throughout the University. The following information will help you make decisions on how to avoid health and environmental hazards from disposing of paint. Most paint has four components: resin, solvent, pigment and additives. To determine the hazardous ingredients of paint, request a Material Safety Data Sheet from the retailer when you buy it.
- The resin is the main ingredient and forms a coating or film on the surface being painted. This typically non-hazardous component includes linseed, acrylic or other synthetic resins. The solvent keeps the paint in a liquid form until the solvent evaporates after the paint is applied.
- The solvent in oil-based paint is derived from a petroleum distillate and can include such hazardous ingredients as mineral spirits, toluene and xylene. The solvent in latex paint is water and therefor not hazardous as a result of its solvent component.
- Pigments provide the color and opacity or covering power. The major pigments used presently are titanium oxide, iron oxide, calcium sulfate, clay or silicates. These pigments are relatively nontoxic and not considered to be hazardous according to the EPA. Some highly colored pigments may contain heavy metals such as chromium, cadmium, or arsenic. If your paint contains these metals for pigmentation, the paint is considered to be hazardous waste.
- Paints purchased before 1977 may contain lead in the pigment. Lead, also a heavy metal, is poisonous. Do not use paint purchased prior to 1977. Paint may also have additives. Some latex paints contain a mercury-based fungicide preservative. Mercury is a heavy metal that is highly toxic. Paints containing mercury produced since August 1990 had to be labeled exclusively for exterior use.
As of August 1991, the United States Environmental Protection Agency prohibits mercury in all newly manufactured paints. The National Paint and Coatings Association has voluntarily complied with these guidelines. To determine if your latex paint contains mercury, call the National Pesticide Telecommunication Network at 1-800-858-7378.
What to do with unusable paint. Never put liquid paint into the trash or pour it down the drain. Paint disposed of this way can contaminate our water resources and the environment.
2. Q - I have a small amount of latex paint, its in a semi-solid state after having sat around for a while, can I solidify the paint and throw it into the trash?
Answer - Yes, as a last resort, small amounts of latex paint not containing heavy metals for pigmentation can be solidified.
Safety precautions
Solidify paint in well-ventilated areas that are inaccessible to children and pets. Do not solidify the paint in a basement or inside a building. Avoid inhalation of fumes. If you can smell it, you are breathing the product. Wear protective gloves to avoid skin contact while handling the paint.
How to solidify paint
Warning! This management option can cause harm to human health and the environment if the described procedures are not followed carefully.
Materials needed
- Protective gloves
- Paint can / Bucket
- Stirring stick
- Non-flammable absorbent, such as clay-based kitty litter
Procedures
To solidify small quantities, such as an inch or two in the bottom of a can, simply remove the lid, add non-flammable absorbent and stir until all the liquid is absorbed. When the paint is solidified, place the absorbent and paint cans inside a garbage bag, seal the bag tightly and dispose of it in the trash destined for the landfill.
How to dispose of empty paint cans.
Leave the lid off the paint cans so that the hauler can see that they are empty. Place the empty paint cans and lids along side or on top of your trash.
FIXER
1. Q - I have a darkroom and use a variety of chemicals to develop my film and I know that some of these chemicals require special handling. Can I pour them down the sink drain?
Answer - Typical substances utilized in photo processing include fixer, bleach fixer, developers, stabilizers, and rinse water. Due to the chemical constituents in these substances (some used and mostly unused), discharge of these substances to the sewer is typically (normally) prohibited. For example, used fixer typically contains levels of silver which exceed Massachusetts Water Resources Authority's (MWRA's) limitation of 2 parts per million (ppm). As a result, discharge of used fixer to the sewer is a violation of MWRA regulations. In the cases of spent fixer, it must be collected as hazardous waste or treatment and recovery equipment must be can be installed and operated to extract silver from the used fixer to allowable (reduce) levels below 2 ppm. For assistance in setting up a hazardous waste collection area or to obtain information on the installation of a silver recovery unit call EH&S for assistance (6-6034).
CHIP TANKS
1. Q - I recently took a job that requires cleaning or removing a neutralization tank full of marble chips, about 5 gallons . Is there a protocol to clean the tank and get rid of the old chips?
Answer - A protocol has been established by EH&S as guidance for chip tank cleaning and removal. Follow the steps below:
Note: All persons performing the inspection and maintenance of chip tanks must be a licensed plumber and have current Bloodborne Pathogen training
Before performing any work on the tank:
1. Put on personal protective equipment. Safety glasses/goggles and faceshield, lab coat or apron, and nitrile or other chemical protective gloves are required. Other PPE such as chemical resistant sleeves and respirators may be worn if warranted. Note: Respirators may only be worn if you have completed a respirator training, fit test and medical evaluation within the last 12 months. Respirators must be equipped with fresh organic vapor/acid gas cartridge.
2. In areas where chemicals are used: flush the tank out by running water for at least 10 minutes prior to opening.
3. If the sink is a radiological disposal sink, call the Radiation Safety Operations line @ 5-0777 to arrange for a radiation survey prior to do any work on the tank.
4. In areas where unusual biological hazards may exist, flush the tank for 10 minutes with water. Add a 10% bleach solution to the chip tank (64 oz. for a 5 gallon tank) for 20 minuets. (It is important to use fresh bleach (< 30 days after opening) to ensure it will disinfect appropriately.) After 20 minutes, flush the tank with clean water for at least 10 minutes. Note: Remember that bleach is very caustic and drains are usually dirty. Under most circumstances, your personal protective equipment should protect you, but if you get bleach or liquid from the drain on your skin, wash for 15 minutes in running water and, if necessary, go to UHS for treatment. If you splash it in your eyes, flush your eyes for 15 minutes in an eyewash and report to UHS for treatment or follow-up.
Tank Inspection
1. Remove the tank cover or inspection port slowly.
2. Visually inspect the tank contents.
- If sharps (glass pipette tips, needles, syringes or razor blades) are observed, do not touch them with your hands. Remove them with forceps or similar tool and place them in sharps container. Call the Biosafety Office if you need to arrange for pick up.
- If the chip level is less that 3/4 of the way to the outlet pipe, carefully add additional chips. Avoid splashing any liquids when adding chips.
- If the Chips are heavily contaminated with biologic material or sediment, the entire contents of the tank must be changed.
- Note: Chips and tank liquids that need to be disposed of must be treated as Hazardous Waste. To arrange for disposal call the hazardous waste hotline @ 6-3322
3. Replace the tank cover/inspection port and record your actions on the logsheet. Managing Laboratory Waste Streams
ETHIDIUM BROMIDE
1. Q - How should I manage and dispose of ethidium bromide waste?
Answer - Ethidium bromide is a mutagen that requires special storage, handling, and disposal as waste. Further, take appropriate step to minimize your exposure.
- Buffer solutions
- Gels
- Stock solutions
- Crystals and powders
- Contaminated debris
For ethidium bromide waste that is generated at Harvard, each waste stream is to be managed or accumulated as described below.
- Waste buffer solutions and other dilute aqueous solutions (less than 0.01% by wt.) containing very small concentrations of ethidium bromide may be discharged to sinks.
- Gels with trace amounts of ethidium bromide (0.3-0.5 μg/ml) may be disposed of daily in double bag-lined containers (e.g., five-gallon pails). This waste is not considered a hazardous waste. However, the chemical waste vendor will pick up any vendor-supplied pails that are labeled as "Non-Hazardous Ethidium Bromide Gel Waste". Cambridge labs that have mini-mains will have to bring the pails to the mini-mains when full.
- Sharps must be managed in sharps containers.
- Pipette tips can be disposed of in regular trash
- Stock solutions, crystals, and powders must be accumulated in containers that are stored in secondary containment bins, remain closed when not in use, and are managed and labeled as: "Hazardous Waste: Ethidium Bromide (Mutagen)".
Remember that Ethidium bromide waste exposed to biological hazards and not decontaminated in a manner that would destroy the biological hazard, must be collected and stored in biowaste bags.
Ethidium bromide mixed with other chemicals (e.g., solvents) which are required to be managed as hazardous waste, must be managed and disposed as hazardous waste.
2. Q - Can I use bench top ethidium bromide extraction/filtration units?
Answer - Laboratories generating large volumes of ethidium bromide buffers should consider the use of commercially available filter cartridges to remove ethidium bromide from buffers and other dilute aqueous solutions from waste solution prior to discharge to sink. Spent cartridges must be collected in waste containers designated for this purpose. For more information, see Resources on the Ethidium Bromide information page
CHARACTERISTIC OF REACTIVITY
1. Q - When filling out the hazardous waste label, I often am confused as to which chemicals receive the reactive designation. How do I know if something is reactive?
Answer - A waste exhibits the characteristic of reactivity if a representative sample of the waste has any of the following properties:
(1) It is normally unstable and readily undergoes violent change without detonating.
(2) It reacts violently with water.
(3) It forms potentially explosive mixtures with water.
(4) When mixed with water, it generates toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health and the environment.
(5) It is a cyanide or sulfide bearing waste which, when exposed to pH conditions between 2 and 12.5, can generate toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health or the environment.
(6) It is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under confinement.
(7) It is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure.
Many examples of functional groups that have been shown to exhibit a certain level of instability and/or unusual reactivity are listed in Material Safety Data Sheets (MSDS's) here.
DRUG ENFORCEMENT AGENCY REGULATED SUBSTANCES
1. Q - Will EH&S take and dispose of my DEA regulated material as part of the hazardous waste operational service they provide to the university?
Answer - It is against the law for EH&S to take possession of any DEA regulated substances.The DEA strictly regulates all purchase, storage, dispensing and disposal of expired/ unwanted or off spec SCHEDULE 1-5 DRUGS.
Only individuals or institutions that submit an application and are assigned a DEA REGISTRATION NUMBER are allowed to purchase and possess DEA REGULATED SUBSTANCES.
DEA REGULATED MATERIAL within the laboratory research community at Harvard University is most commonly used for:
- EXPERIMENTAL PROCEDURES
- ANTEDOTES
THOSE SEEKNG DISPOSAL OF EXPIRED/UNWANTED SCHEDULED DRUGS MUST MEET AND SATISFY THE FOLLOWING CONDITIONS -
DESTUCTION OF CONTROLLED SUBSTANCES
Privacy Act Information for DEA Form 41 / DEA Form 222.
Authority: Section 307 of the Controlled Substances of 1970 (PL-513)
- MUST HAVE A CURRENT DEA REGISTRATION NUMBER
- MUST HAVE AN INVENTORY OF ALL MATERIALS THAT ARE TO BE DISPOSED
- MUST SET UP AN ACCOUNT WITH A D.E.A. REGISTERED AND APPROVED INCINERATOR. (see attachment)
- MUST FILL OUT THE GOVERNMENT 41 D.E.A. FORM FOR CONTROLLED SUBSTANCES ALLOWING AND DOCUMENTING TRANSFER OF OWNERSHIP OF THE REGULATED MATERIAL. To obtain a copy of this form, visit the DEA web site. http://www.deadiversion.usdoj.gov/21cfr_reports/surrend/announce_41.htm
- MUST FILL OUT THE GOVERNMENT 222 D.E.A. FORM FOR SCHEDULE 2 CONTROLLED SUBSTANCES ALLOWING AND DOCUMENTING TRANSFER OF OWNERSHIP OF THE REGULATED MATERIAL. Official Order Forms may be ordered by calling the DEA Headquarters Registration Unit toll free at 1-800-882-9539 or the nearest DEA Registration Field Office. The forms will be mailed within 10 working days.
EH&S will provide guidance for laboratories attempting to dispose of DEA regulated material. Call EH&S for technical assistance with this process 496-3322. For additional information refer to our web site.
SHARPS
1. Q - What is a sharp, and how do I manage them?
Answer - Sharps are defined by the regulation as medical articles that may cause punctures or cuts including but not limited to, all used and discarded hypodermic needles and syringes, pasteur pipettes, broken medical glassware, scalpel blades, disposable razors, and suture needles. Sharps containers are to be available in the laboratory where sharps are used. These containers must be disposed of as biological waste by placing them into "burn" boxes, location of boxes are typically designated by your lab.
Cambridge/Allston Campus: Sharps containers are sold in the Biological and Chemistry VWR Stockrooms. To set up a Biohazard "burn" box or identify the closest available location for proper disposal of your sharps container call Sid Paula 5-2345.
Longwood Campus: Sharps containers are available through the Longwood EH&S Safety Office (2-1720). To set up a Biohazard "burn" box or identify the closest available location for proper disposal of your sharps container call facilities Harvard Medical School (2-1567) / School of Public Health (2-4720).
Refer to the EH&S Biosafety web site for additional information. /ehs/biosafety/
2. Q - I do not work with biological material, but use and generate sharps (hypodermic needles, Pasteur pipettes, broken medical glassware, scalpel blades, disposable razors, and suture needles) which are put in a sharps container. How do I properly dispose of my sharps container?
Answer - Sharps containers are to be available in the laboratory where sharps are used. These containers used to collect spent sharps should be disposed of as biological waste by placing them into "burn" boxes located in areas designated by your lab. Ask personnel in your lab where the nearest "burn" box is located.
Cambridge/Allston Campus: Sharps containers are sold in the Biological and Chemistry VWR Stockrooms. To set up a Biohazard "burn" box or identify the closest available location for proper disposal of your sharps container call Sid Paula 5-2345.
Longwood Campus: Sharps containers are available through the Longwood EH&S Safety Office (2-1720). To set up a Biohazard "burn" box or identify the closest available location for proper disposal of your sharps container call facilities Harvard Medical School (2-1567) / School of Public Health (2-4720).
SECONDARY CONTAINMENT
1. Q - What happens if our secondary containment bins used for hazardous waste storage and segregation becomes contaminated over time? Should I throw them away?
Answer - If the secondary containment bins used in your Satellite Accumulation Area becomes grossly contaminated, please call EH&S for its removal and replacement Cambridge (6-3322)/Longwood (2-1720).
2. Q - How can I properly segregate incompatible waste containers?
Answer - EH&S has mandated the use of secondary containment bins (plastic bins) at all locations generating hazardous waste. Secondary containment bins are available to laboratories through the VWR Stockrooms on the Cambridge Campus and through the EH&S Office in Longwood (2-1720). These secondary containment bins are used for storage of hazardous waste containers to ensure that the "surface underlying the container shall be free of cracks, gaps, and sufficiently impervious to contain leaks". (310 CMR 30.340(4)(d)). Secondary containment bins are also used to separate incompatible hazardous wastes during accumulation (e.g. use separate trays or bins).By definition incompatible hazardous waste are materials that as a result of commingling under uncontrolled conditions may produce heat or pressure; fire or explosion; violent reaction; toxic dusts, mists, fumes or gasses; or flammable fumes or gasses. Listed below are web-site resources to help you identify possible incompatible storage conditions. You may also call EH&S 496-6034 for additional technical assistance.
For more information see the following links for compatibility briefs and charts.
LABELS
1. Q - How can I get a supply of hazardous waste labels?
Answer - If you reside on the Cambridge Campus hazardous waste labels are available through your local VWR stockrooms (Biology Basement / Naito Basement).
In Longwood you must call EH&S directly 2-1720, and request hazardous waste labels which will be dropped off during routine hazardous waste pickups (Tuesday & Friday).
TRAINING
1. Q - Do I need hazardous waste training if I work in a Laboratory that generates hazardous waste even if I don't? How and when is training is offered, and how frequently must I take it?
Answer - Personnel who generate, handle or may handle hazardous waste must be trained in hazardous waste requirements every year. The training program at Harvard University consists of both classroom and web based training sessions and reviews the key procedures of Harvard's hazardous waste program. These procedures have been developed through a cooperative effort between the Department of Environmental Health & Safety (EH&S), the faculty, and the administrative staff at Harvard and meet the regulatory requirements prescribed by Massachusetts and Federal law. Following these procedures will help to maintain a safe and environmentally responsible workplace by ensuring that wastes are properly identified, stored and removed from the laboratory. These procedures are presented in four sections:
Section 1: Legal & Regulatory Background
Section 2: Identifying Hazardous Wastes in the Lab
Section 3: Storing Hazardous Wastes in the Lab
Section 4: EH&S Waste Pick-up ServiceFor a schedule of classroom training, visit our web site at /redir/training.html
For web-based hazardous waste training , visit our web site at /cgi-bin/training/hazwaste/hazwaste.pl
GLASSWARE RINSING
1. Q - I often wash and dry my glassware with acetone, is it ok to pour the "acetone rinse" down the drain?
Answer - No. The Environmental Protection Agency (EPA) defines acetone as a volatile organic compound which exhibit the flammability characteristic of (Flash point < 140 F). The EPA considers materials exhibiting the flammability characteristic as hazardous and must managed and disposed of according to the hazardous waste regulations. In addition the EPA regulates acetone when it is used for its solvent properties. Volatile organic compounds are also strictly prohibited by the Massachusetts Water Resource Authority (e.g. acetone, benzene, toluene, xylene) in concentrations greater than 1.0 milligram per liter. Laboratories may be significant users of toxic organic compounds (e.g.solvents), which cannot be treated by conventional wastewater treatment systems. These toxic organics (also known as TTOs) must be prevented from sink disposal and must be disposed of as hazardous waste. See our web site for instruction in the proper collection, storage and disposal of hazardous waste. For additional information visit on sink disposal visit our web site at Sink_Disposal.pdf
2. Q - Can acetone be discharged to drain?
No - when used to clean glass it is regulated either as ignitable or as F003 hazardous waste, both of which are prohibited from being drain disposed.
3. Q - Can I treat and rinse glassware that is contaminated with reactive residues or high hazard chemicals so it is no longer contaminated with the compound?
Yes. Treatment of glassware prior to re-use is not something HW law addresses. However, rinseate and cleaning residue should be evaluated to determine if it is hazardous waste. Refer to P-listed (acutely toxic) chemicals on our web site.
EMPTY CONTAINERS
1. Q - Our lab has quite a few empty glass bottles that used to contain stock solvent. What should we do with them now that they are empty?
Answer - First, EH&S recommends keeping a supply of bottles for hazardous waste accumulation. If you have an excess of empty containers they may be disposed through the regular trash as long as 1) They are "empty". (All material has been removed that can be removed using the practices commonly employed to remove materials from that type of container. eg, pouring, pumping and aspirating & 2) The containers did not contain a chemical on the acutely hazardous waste P list. If they did contain a P listed chemical either dispose of the "empty" as hazardous waste or triple rinsethe container and collect the rinsate as hazardous waste. For the list of P ( acutely hazardous wastes) visit our web site.
TREATMENT
1. Q - Can quenching be used to react substances prior to disposal?
Quenching various reactive chemicals to rendering them less or non-hazardous for the sole purpose of disposal is considered RCRA treatment and prohibited. Quenching, for the purposes of rendering equipment, lab instruments and other devices used in research, clean and safe for use is acceptable and not a RCRA issue. If quenching is necessary to a lab protocol and is documented in the protocol, it would generally be considered part of the experimental process and not subject to RCRA.
2. Q - Can pH be adjusted via neutralization so that it can be poured down the drain?
Lab buildings at Harvard contain wastewater treatment systems for the neutralization of lab wastewater that may be mildly corrosive. Therefore, the discharge of weak corrosive solutions (5.5 < pH <10.5) to the laboratory sinks in small quantities (less than one liter per hour) is permissible. Corrosive solutions with pH ranges (2.0< pH<5.5) and (10.5<pH<12.5) must be neutralized before sink/drain disposal. Corrosive solutions with pH ranges (pH<2.0) and (pH>12.5) at the conclusion of the lab process must be collected and managed as hazardous waste.
3. Q - Can compounds be modified structurally so that they are not as hazardous?
Personnel modifying compounds need to ensure that not treating a hazardous waste. If original material would be hazardous waste, then any modification to it is considered treatment. Treatment requires a permit unless structural modification is necessary to a lab protocol and is documented in the protocol.
HAZARDOUS WASTE DISPOSAL
1. Q - How much does it cost to analyze and dispose an unknown waste?
Analytic and hazardous waste disposal costs for unknown substances range from $200-$1500.
2. Q - How much does it cost to dispose of hazardous waste?
Cost of disposal of hazardous waste range $30/5-gal solvents to $800-$1,000/55-gallon drum of reactive hazardous waste.
HAZARDOUS WASTE DETERMINATION
1. Q - What chemicals are considered hazardous (i.e. must be handled as hazardous waste and cannot just be thrown in the trash)?
See the hazardous waste site.
Any chemical inclusive of solids, liquids and gases, which are listed by the EPA/DEP or exhibit characteristics of a hazardous waste (Ignitable, Corrosive, and Reactive, Toxic) must be managed and disposed of as hazardous waste.
SINK DISPOSAL
1. Q - Why can't we just throw chemicals that biodegrade when in contact with H2O, down the drain?
By law we are required to make a HW determination at point material becomes waste. If listed HW or meets characteristics must be managed as HW - drain disposal prohibited.
