Effective Date:  05/15/04

9.9 Hazardous Waste Policy

APPLICABILITY

This policy is applicable to all Institute faculty, staff, and students.

GENERAL

Federal, state, and local governments impose strict regulations concerning the management, storage, and disposal of hazardous materials.  Compliance with these laws, good safety practices, and the necessity to avoid future liabilities dictate that the Institute take a conservative approach in handling this material.

The term "hazardous waste" as used in this policy means any substance no longer of use to the possessor whose chemical or biological properties have the potential to endanger personnel, material, or the environment if handled improperly.  Hazardous waste includes, but is not limited to items specifically identified as "hazardous waste" under federal and state statutes.

With the exception of radiological material, EH&S is charged with ensuring that all hazardous waste generated at Georgia Tech is handled properly.  Within specific activities, EH&S will provide advice and technical assistance.  However, it is the responsibility of each individual to know the possible dangers associated with any material being used or generated, and know how the material should be handled and disposed of BEFORE A PROJECT IS BEGUN.

Activities will not arrange for off or on site disposal of hazardous material or use the Institute's EPA ID number without prior coordination.  This does not preclude the routine transfer of chemicals between activities or the use of the ID number on research proposals.

TYPES OF WASTE:

Material for Which EH&S is Responsible:

• Chemical waste to include Highly Toxic Material.
• Highly Toxic Material is any chemical which is either specifically identified by the Environmental Protection Agency (EPA) as an "acute hazard" or has a Lethal Dose 50 (LD₅₀) of 50 mg/kg or less oral-rat.  Samples include inorganic cyanides, many pesticides, arsenic compounds, etc.  A listing of EPA listed "acute hazards" may be obtained from EH&S.
• Used oil (handle the same as chemical waste).
• Biological/Infectious Waste.
• Fluorescent Bulbs and Ballast.
• Batteries.
• Computers.
• Asbestos.
• Lead-Based Paint.

Material for Which EH&S is NOT Responsible:

• Radioactive waste, to include mixed (chemical and radiological) is the responsibility of the Radiation Safety Officer.
• Broken glass, whose only danger comes from its ability to inflict wounds is not considered hazardous waste.  Activities which anticipate generating broken glass should obtain puncture proof containers and dispose of the material appropriately.

CHEMICAL WASTE

Waste Minimization

Government regulations and cost effectiveness require that as little hazardous waste as possible be generated.  The following guidelines are a checklist to accomplish waste minimization - they are not intended to restrict activities:

• Before beginning a project, determine the hazards associated with the material.  Where possible substitute less hazardous substances.
• Use small batch or micro-level reactions where possible.
• Order and maintain minimum quantities of chemicals.
• Certain chemicals are difficult and/or costly to dispose of and should be given special consideration. Some types are:

1. Any heavy metal, e.g., mercury, barium, cadmium, chromium, beryllium, silver, selenium, tellurium, either elememental or in compounds.
2. Chlorophenols, dioxins, and cyanides.
3. Compressed gases (to include lecture bottles) or containers with liquids under pressure (especially if the substance is poisonous).  Where possible arrange with the supplier to accept return of used containers.
4. Manufacturers' samples.  Either arrange for the manufacturer to accept return of unused material or ensure they provide an ample description of the product and its characteristics.

Disposal of Material by Users

Plumbing systems whether or not they are "chemically resistant" and whether or not they are equipped with "dilution tanks" are capable of handling only incidental quantities of waste - they are NOT designed for use as a primary disposal method.

Bench Top procedures designed to make material non-hazardous or less hazardous, such as acid-base neutralizations should be undertaken with caution.

Containers that have been emptied using normal practices (e.g., pouring) are generally not considered hazardous and can be discarded in normal trash.  (Containers that held Highly Toxic Material are considered hazardous even when empty and shall be handled as such). 

Although legally empty the following procedures are recommended to preclude possible incidents arising from residual material:

• For solvent based material open the container in a fume hood and allow residue to evaporate overnight - discard the container opened.
• For aqueous based material (acids and bases) triple rinse with water and discard the container opened.

Accumulation

Excess amounts of waste and/or unneeded material are not to accumulate.

Waste generated in the process of conducting research or other activities (spent solvents) will be removed on a routine basis.  In no case, will an activity allow more than 50 gallons (~1 kg) of an Highly Toxic Waste) nor will any waste container be retained for longer than one year.

At the end of any project or prior to the departure of an individual, all research products and other material shall be clearly identified and disposed of.

In addition:

Each laboratory/activity will conduct at least an annual physical survey of their area and dispose of unneeded/expired material.  Special attention will be given to the following:

• Refrigerators and freezers.
• Ethers and other peroxide forming substances.
• Materials that become more dangerous due to evaporation such as sodium, organo-metallic compounds in solvents, or picric acid.

And, a responsible individual (e.g., Primary Investigator or Shop Foreman) will review the biannual Right to Know Inventory and attest to the fact that the materials retained are required.  Records will be maintained of these reviews.

Segregation of Waste

To the extent feasible, waste should be segregated and not combined.  Mixing of different type waste poses dangers.

Containers

It is the responsibility of the generating activity to provide suitable waste containers for waste accumulation prior to pick-up.

Waste containers must be compatible with the waste collected, kept closed unless material is being added, capable of being transported, and appropriately labeled.  Do not use containers over 5 gallons/20 liters without prior consultation with EH&S.

Multiple small containers, such as sample vials containing research products, should be consolidated into single packages.

EH&S cannot guarantee that re-useable containers will be returned to the waste generator.

Labeling

EH&S will supply labels or activities may use their own.  Waste collection containers must be clearly labeled with:

1. The word "WASTE" in a conspicuous location.
2. The type waste being accumulated in the container, e.g., "halogenated solvent, hydrochloric acid."  Generic terms that give no indication of the type hazard associated with the waste, e.g., "aqueous waste", are not acceptable.
3. Approximate amount or percentage of each constituent.
4. The date the first waste was added to the container.
5. Containers of excess or spent oil will be labeled "USED OIL".

Before the material is picked-up the following must by on the label:

• The name and telephone number of an individual who certifies the waste container contents.
• The actual contents of the container - provide chemical names not abbreviations.

Containers of excess materials, with the manufacturers' original label, need not be re-labeled - unless, the manufacturers' label does not identify the contents by chemical name.  In such case the activity must appropriately label the container or provide a Material Safety Data Sheet for the material.

BIOLOGICAL/INFECTIOUS WASTE

Used sharps and/or needles that have been contaminated with potentially pathogenic or infectious materials will be collected in puncture proof containers (i.e., sharps containers).

All biological/infectious waste (including sharps containers) will be placed in approved "RED" biohazard bags; the bag will be sealed with tape and placed in an approved biohazard box which will also be sealed.

EH&S will provide bags and boxes.

Specific procedures for segregating and packaging biological/infectious waste may be obtained from EH&S.

FLUORESCENT BULBS

Producers of this material are responsible for packaging of bulbs.  Bulbs may be packaged in original containers (use the box the bulbs were supplied in with packing material removed).  If appropriate packaging is not available, contact EH&S for fiber drums.

Any broken bulbs will be immediately cleaned up with the residue placed in a suitable container, marked as to contents and disposed of with spent bulbs.

BATTERIES

Lead-Acid batteries, automotive type or sealed, are disposed of by EH&S.

Standard alkaline batteries, such as those used in flashlights, do not normally require handling as hazardous material and can usually be disposed of as normal trash.  Large quantities of these batteries or those used in research are handled by EH&S.

Non-alkaline, rechargeable batteries, e.g., Nickel-Cadmium Metal (Nickel, Lithium, et al) Hydride, Lithium Ion, etc., used in cell phones, pagers, hand-held radios, computers, and powered hand-tools are potentially hazardous and should be properly disposed of - not placed in normal trash.  Even when discarded, these batteries should be handled carefully, by placing the batteries in individual plastic bags or taping over the electrodes.  These batteries will be collected and recycled by EH&S.  Personnel are encouraged to dispose of batteries from personal equipment in an environmentally sound manner - many retailers that sell replacement batteries have recycling programs.

COMPUTERS

Computers and related equipment (monitors, keyboards, scanners, etc.) and parts (cards, cords, etc.) are an environmental concern.  Most components contain metals such as lead, which are regulated by the Environmental Protections Agency, and, hence, cannot be disposed of as normal trash.  When these items are replaced or otherwise no longer needed they need to be disposed of properly.  At Georgia Tech all such items, whether or not they carry a Georgia Tech Inventory number, are to be processed through Capital Assets Accounting.  Specific procedures can be found at www.business.gatech.depts/PURCHASE/ca/cahome/html.

SPILLS/INCIDENTS

Each activity should expect and be prepared to deal with "routine" spills of material.  Activities are encouraged to purchase and position appropriate pre-packaged "spill kits".

Absorbents and/or contaminated material from such incidents will be collected in an appropriate container and disposed of in the same manner as other hazardous chemical waste.

Request assistance if required.  Generally, conditions requiring assistance include, but are not limited to:

• Clean-up cannot be accomplished without harm to yourself or others.
• Questionable levels of respiratory exposure.
• Significant amounts of highly hazardous material.
• Unidentified spilled material.
• Medical assistance is required.

If assistance is required:

• Contact EH&S or Campus Police at (404) 894-2500.  If immediate assistance is required:  Contact Campus Police.
• Arrange to meet responder and remain in area until released.

COLLECTION

EH&S is responsible for picking up hazardous waste from individual activities.  Notify EH&S with the type, amount, location, contact person, and phone number.

EH&S will respond to telephonic, e-mail, faxed, or written requests.

The internal procedures of some elements require processing of requests through a certain point of contact.  Enforcement of such procedures is the responsibility of the element imposing the requirements.  EH&S will cooperate to the extent feasible.

Activities outside the area bounded by Techwood Drive, North Avenue, Tech Parkway, Northside Drive, and Tenth Street require different procedures.  Typically, EH&S will arrange direct contractor pickups at these locations. It is especially important that such activities promptly identify and notify EH&S of any material requiring removal.

In most instances, EH&S will respond to requests within three working days.

CONTACTS

Address any questions to Hazardous Material Officer, EH&S (404) 894-4635 or (404) 894-6224 (direct).