Laboratory Safety Manual - Chapter 12: Laboratory Waste Management Plan


Laboratory Safety Manual - Chapter 12: Laboratory Waste Management Plan

Table of Contents

  1. Introduction
  2. Part 1: Labeling
  3. Part 1: Chemical Waste Removal
  4. Part 2: Best Management Practices for Chemical Waste
    1. Containers
    2. Chemical Waste Segregation
    3. Training
    4. Laboratory Cleanouts
    5. Chemical Waste Emergencies
  5. Part 2: Other Laboratory Wastes
    1. Waste Disposal of General Waste – Broken Glass/Sharps
    2. Broken Glass and Other Sharp Objects
    3. Regulated Sharps
    4. Other Regulated Sharps
    5. Disposal of Medical Waste
    6. Disposal of Radioactive Wastes
    7. Empty Chemical Containers and Recycling

I. Introduction

The characterization, management storage and disposal of laboratory wastes (i.e., chemical waste including hazardous and non-hazardous solid waste, radioactive or mixed waste, biohazardous and medical waste, and universal waste) is regulated and requires strict compliance with regulatory obligations.

The Principal Investigator (PI) for each laboratory has overall responsibility for managing the process of:

  • characterizing laboratory waste
  • containerizing laboratory waste
  • marking/labeling laboratory waste and,
  • managing laboratory waste in their laboratory spaces

prior to waste disposal confirmation and waste pickup by EHS. The Environmental Affairs Section of the EHS Department is responsible for managing the review and characterization of laboratory waste, making the waste determination, as well as the approval of laboratory waste disposal requests from the laboratory PI.

EHS personnel conduct the transfer of chemical wastes, radioactive wastes, and mixed wastes from laboratory areas to the UNC Hazardous Materials Facility for treatment (i.e., bulking) or package consolidation and managed storage prior to the transport to off-site treatment and disposal facilities.

The University of North Carolina at Chapel Hill operates as a large quantity generator (LQG) of hazardous waste. The management and storage of hazardous waste is subject to regulatory compliance obligations; the University is regularly audited and inspected for compliance with these regulatory compliance obligations by the NC Department of Environmental Quality Division of Waste Management (NCDEQ DWM) and the U.S. Environmental Protection Agency (EPA) Hazardous Waste Section.

The purpose of this Laboratory Waste Management Plan (LWMP) is to comply with the provisions of 40 CFR 262 (Subpart K – Alternative Requirements for Hazardous Waste Determination and Accumulation of Unwanted Material at Laboratories Owned by Colleges and Universities and Other Eligible Academic Entities Formally Affiliated with Colleges and Universities). The Laboratory Waste Management Plan applies only to laboratories on campus (teaching labs, research labs, art labs, photo labs, field labs, diagnostic labs in teaching hospitals, and areas that support labs such as chemical stockrooms or prep rooms).

II. Part 1: Labeling

The University refers to chemical waste generated in laboratories as “Unwanted Material”. When a material has no further use, laboratory personnel must identify the material as an unwanted material by affixing the label shown below. Label templates are available on the EHS website.

Unwanted Material Label

The full chemical name (no formulas, abbreviations or structures) of each component in the waste container must be listed as well as the estimated percentages. The accumulation start date must also be noted when waste is first added to the container. The label must include whether the unwanted material is used or unused. If the size of the container or number of contents does not fit on a label, an associated tracking sheet may be used.

III. Part 1: Chemical Waste Removal

The University requires that all unwanted materials are removed from laboratories no more than 12 months from the accumulation start date indicated on the container label. When the waste container is close to becoming full, an online chemical waste pickup form (e510) should be electronically completed and submitted to EHS for proper classification and arrangements for pick-up will then be made.

Collection limits for each laboratory are set at 55 gallons of chemical waste or 1 quart of acute reactive waste. Acute reactive wastes include one or more of the following P-listed chemicals or a mixture that has one or more of the following:

  • P006: Aluminum Phosphide
  • P009: Ammonium Picrate
  • P065: Mercury Fulminate
  • P081: Nitroglycerine
  • P112: Tetranitromethane
  • P122: Zinc Phosphide (>10%)

If either of the volumes listed above are exceeded, the waste must be removed from the laboratory within 10 calendar days of the date that the limits were exceeded. Contact the EHS Hazardous Materials Manager (919-962-2209) immediately if you exceed the limit.

For each waste type to be disposed of, you must submit an online Chemical Waste Pickup Request (e-510 form). Typically, this is done once the container accumulating the waste in the lab is full. Submittal of the e-510 form alerts EHS that a waste determination is to be made (by the EHS Hazardous Materials Manager) and triggers the scheduling of the waste pick-up. If you are requesting pickup from a research laboratory, you must have a valid ONYEN, a current registration with EHS as a Principal Investigator or Laboratory Worker and an updated Laboratory Safety Plan. If you work in multiple labs, you must have a worker registration form for each lab. Go to the ONYEN website if you do not have an ONYEN, your ONYEN has expired, or you have forgotten your password. If the system blocks you from entering an online pickup request, contact EHS at 919-962-5507 for further assistance.

The EHS website offers a tutorial for using the online e-510 waste disposal form. Below are condensed instructions for completing the e-510 form. These instructions are specific to the PI/Registered Lab Worker portal that you must have a valid ONYEN and password to enter. From the EHS main website, under Chemical Disposal, type in your current ONYEN and password.

  • Click on the “Make New Request as PI” field under the Chemical Waste Pickup Menu.
  • Next, choose the name of the faculty member responsible for the laboratory and click “submit”.
  • Room and Building: Choose the building where the waste is located from the drop-down menu, and list the room number.
  • Contents: Identify waste as liquid, solid, or gas. Indicate if liquid waste is aqueous solution, organic solvent, or other.
  • pH value: Complete for aqueous solutions that contain corrosives (acids or bases); otherwise, enter 7 as pH.
  • Mixed chemicals: Indicate whether waste generators mixed chemical constituents before (“new”) or after (“used”) use. This affects proper classification of solvent wastes and may provide a basis for waste minimization, as non-hazardous materials become hazardous waste when mixed with a hazardous waste.
  • Chemical composition: List all constituents and their estimated percentages. Total must add up to 100 percent. Do not use abbreviations or chemical formulas. Include percentages of water, already listed, if any.
  • Container size: List size of the waste container (gallon, liter, etc.)
  • Container type: Identify the container type from drop-down menu; choose “other” if your container type is not otherwise listed.
  • Weight: Net weight of the contents, in kilograms (required for regulatory purposes). We estimate that a liter of liquid weighs one kilogram.
  • Number of containers: Give the number of containers of equal type, size, and contents that you want to have picked up.
  • Notes: List any additional information that will assist EHS, or any special pickup instructions. For example, indicate where to find the waste in the room if the location is not obvious (e.g. refrigerator, cabinet).

After submitting your request, you will see a pickup request confirmation. If all information is correct, press the confirm button at the bottom of the page. You will receive an e-mail indicating that your request was received and is under review. After the EHS Hazardous Materials Manager reviews and approves the request, you will receive a confirmation e-mail that includes a hyperlink to the Hazardous Material Transfer Form. You must print out this form and affix it to the waste container(s). This marks the waste for pickup and provides waste determination information. During the approval process, the Hazardous Materials Manager may send you an email for more information. This email will reference the identification number you received by email when you submitted the waste. Prompt replies allow your waste to be approved and the waste technicians to schedule your waste for pickup.

IV. Part 2: Best Management Practices for Chemical Waste

In addition to container labeling and accumulation time limit requirements, chemical waste managed within laboratories at UNC Chapel Hill should follow best management practices for containerization, waste segregation, personnel training, lab cleanouts and emergencies.


Waste containers and lids must be in good condition and chemically compatible with the waste inside the container. Waste containers must have securely fitting lids, preferably the original lid(s) for the container(s); do not use corks or stoppers. Laboratory beakers, flasks, or plastic milk cartons are not acceptable as waste containers. Metal containers are not acceptable unless they are the original container for the chemical waste being managed (no mixtures). Glass or plastic reagent bottles are generally the most convenient to use.

Working Containers

A working container is a small container (two gallons or less) that is in use at a laboratory bench, hood, or other work station, which is used to collect lab wastes from a laboratory experiment or procedure. A working container may remain open until the end of the procedure or work shift, or until full, whichever comes first, at which time it must either be closed or the contents emptied into a properly labeled waste container.

All containers of waste must be kept closed at all times, except:

  1. When the waste is being temporarily collected in a working container, as described above.
  2. When waste is being added to, removed from, or consolidated in the container.
  3. When venting of the container is necessary for either the proper operation of laboratory equipment (such as HPLC), or to prevent the dangerous buildup of extreme pressure that may result from a reaction between the wastes being added. In some cases, a vented container lid should be employed to prevent gas build-up. For help in locating a vented lid for waste storage containers, Call EHS (919-962-5507) for assistance.

Liquid wastes may be accumulated in glass reagent bottles compatible with the waste. If you generate a large volume of liquid waste, consider 5-gallon carboys for solvent accumulation. Filled containers of liquids must have at least ten percent headspace (roughly 1.5 liters) to accommodate thermal expansion during transport and storage. Store glass waste containers in rubber safety carriers, buckets, or similar containers to protect against breakage and spillage. All waste containers holding 4 liters or less of liquid chemical waste, and all glass containers of liquid chemical waste stored on the floor, require secondary containment.

Solid wastes may go into a double-lined cardboard box. Liners must be 1.5 mil or greater polypropylene bags. Do not use biohazard or radiation waste bags for solid waste accumulation, regular, labeled trash bags are preferred. Tie and seal each bag individually. Ethidium bromide-containing solid and semi-solid waste (e.g. used gels) is also collected in double bags within cardboard boxes. Collect liquid ethidium bromide waste in carboys or bottles and manage accordingly.

Reactive chemicals must be disposed in their original shipping containers, or in containers provided by EHS.

Chemical Waste Segregation

Acids and Bases

Segregate containers of acids and bases from one another in individual, compatible containers while accumulating as waste. EHS will pick up concentrated acids and bases as chemical waste. Do not discharge acids or bases containing heavy metals to the sanitary sewer, i.e., through the laboratory sinks. The Orange Water and Sewer Authority (OWASA) Sewer Use Ordinance prohibits discharge of aqueous liquids with a pH of 10 pH units. Do not mix acids and bases containing heavy metals with other acidic or basic wastes and do not include neutralization disposal of aqueous waste into the sanitary sewer as the last step in laboratory procedures.


Package oxidizers separately; store and accumulate away from organics including flammable materials. Oxidizers should never be stored or accumulated adjacent or proximate to any organic substances.

Used Solvents

Segregate and collect halogenated and non-halogenated solvent wastes in separate waste containers. Please also note that in accordance with the OWASA Sewer Ordinance, pollutants that can create a fire or explosion hazard (e.g. non-halogenated hydrocarbons) should not be sewered. Moreover, toxic solvents including all chlorinated ethenes and ethanes must not be sewered to avoid potential upsets or adverse impacts to the biological treatment system at the OWASA publically owned treatment works (POTW).

Disposal of Compressed Gas Cylinders

Disposal of non-returnable (e.g., lecture-size) cylinders that are not “empty” can be very expensive, especially for reactive gases. Consider residual gas disposal options before purchasing reactive or highly toxic compressed gases. Compressed gas suppliers generally are not licensed to receive hazardous waste, and thus cannot accept non-returnable cylinders. However, suppliers can accept reusable cylinders with residual gas. Make every effort to purchase from suppliers who have a cylinder return program. For disposal, fill out the waste disposal form online for pickup. Even if the cylinder seems empty, it cannot be thrown in the trash. Always treat pressurized cylinders it as waste.

“Unknowns” – Unidentified Chemicals

Unlabeled chemicals present a challenging and potentially very costly disposal problem. Waste disposal firms require certification of the waste characterization by the generator. If the generator is unable to provide this certification based on process knowledge of the chemicals in the waste, a laboratory analysis is required. Depending upon the hazard class associated with the unknown waste, the cost to sample, analyze, treat and dispose of this waste (after it has been identified) can be very significant. EHS provides periodic identification and removal of unknowns through contract with qualified waste management and disposal companies. Exercise every precaution to avoid generating unknowns in the laboratory. If you discover unknown chemicals in a laboratory, please contact the EHS Hazardous Materials Manager (919-962-5509) for assistance and handling information.


All new laboratory workers are trained on chemical waste management procedures via the online lab safety orientation training. In addition, the PI specific lab safety plan covers chemical waste management in the Schedule B – Hazardous Chemicals and Equipment section and is reviewed annually. If chemical waste issues are found during laboratory inspections the lab will be asked to take a refresher training to ensure future compliance, Laboratory Waste Management at UNC-CH.

Laboratory Cleanouts

All laboratories are required to inventory their chemicals at least once a year as part of their laboratory safety plan. Chemicals that are unwanted or no longer needed should be removed from the laboratory and disposed of. Follow the normal waste pickup process by filling out an online waste pickup form for each of these unwanted or unneeded chemicals.

Waste Minimization

The most significant way that you can assist in the management of chemical waste is to reduce the volume that must be disposed. Principal Investigators are encouraged to consider ways to reduce the volume of waste or preserve the reuse of materials through the redesign of experiments. Keep recyclable materials separate from other wastes.

Disposal to Sewage System

Do not use the sanitary sewer for the disposal of unwanted materials, with the exception of trace quantities associated with cleaning and washing operations, e.g., glassware. Under no circumstances should halogenated or non-halogenated solvents be sewered directly or in aqueous solution when the solvent concentrations are more than trace (e.g. >1% by volume).The following discharges to the sanitary sewer are prohibited by the Clean Water Act:

  • Wastes that may create a fire or explosion hazard.
  • Corrosive wastes with a pH less than 6.0 standard units (s.u.) or greater than 10.0 s.u.
  • Solid or viscous waste s in quantities that would obstruct flow or interfere with operations.
  • Heated waste discharges which could either inhibit biological activities or increase the wastewater treatment plant influent temperature to 104°F (40°F) and higher.
  • Waste discharges of any toxic waste material(s) in volumes or strengths to cause interference with wastewater treatment processes, or possibly contaminate waste sludge or effluent from the wastewater treatment plant so as to violate its NPDES permit.
    • Note on Biocides: Do not release concentrated solutions to the sanitary sewer. Limit disposal to one gallon of “working strength” solution per laboratory per day. This also applies to germicides and disinfectants. Pesticides and other chemicals that are persistent in the environment cannot go to the sewer.

Only neutral salts and buffer solutions may be disposed of down the sanitary drain. Do not dispose any of the following down the drain:

  • acids with a pH < 6.0 s.u.
  • bases with a pH > 10 s.u.
  • solvents
  • alcohols, ethers, esters, ketones, aldehydes, amines, amides, nitriles, ethidium bromide, carbon disulfide, phenol or phenolic materials, other halogenated or non-halogenated hydrocarbons, or other chemical agents unless present as trace constituents in aqueous solution
  • sodium azide containing wastes
  • formaldehyde containing wastes
  • solutions with heavy metals

Contact EHS at 919-962-5507 with any questions regarding this policy.

Chemical Waste Emergencies

If a dangerous situation occurs to a chemical waste in your laboratory, do not touch the container. As best as possible, try and determine the contents and potential hazards and call EHS (919-962-5507) to report. The EHS Emergency Response Team and/or the EHS Hazardous Materials Manager will immediately respond, assess the situation, remove the container or leave in place and sequester the area until an outside vendor can remove.


Chemicals such as peroxides can become dangerous over time and have expiration dates that must be closely tracked. See Chapter 13: Safe Handling of Peroxidizable Compounds for best management practices and a list of potential peroxides found in campus labs.

Reactive Chemicals

For the safety of EHS waste pickup personnel and to ensure compliance with the Resource Conservation and Recovery Act (RCRA) regulations, exercise care to identify reactive wastes. Although the process of using reactive chemicals in laboratory experiments usually eliminates the reactivity characteristic, some reactive chemicals can exhibit dangerous, residual properties. As an example, residual metallic sodium added to a solvent to remove water could result in a fire or explosion if that solvent is mixed with aqueous wastes. Likewise, you must label solutions containing sulfides and/or cyanides to alert personnel not to mix these with acid wastes. This mixing could release lethal amounts of toxic hydrogen sulfide (H2S) and/or hydrogen cyanide (HCN) gases. Due to the cost and hazards associated with shipping and disposing of reactives, make every effort to use or react the entire contents of the container.

V. Part 2: Other Laboratory Wastes

Medical Waste (sometimes called biohazard waste) is defined as, “any solid waste that is generated in the diagnosis, treatment, or immunization of human beings or animals, in research pertaining thereto, or in the production or testing of biologicals.” (Medical Waste Tracking Act of 1988). Generators should place solid medical waste (other than sharps) in a container that is:

  • ≤ 15-gallons (57-L),
  • closable with a lid,
  • durable,
  • labeled with the universal biohazard symbol,
  • leak-proof,
  • lined with a plastic bag that is:
    • autoclavable
    • orange
    • labeled with universal biohazard symbol
  • a red colored container.

Limit the use of orange plastic bags to medical waste that must be autoclaved before disposal or incinerated. All biohazard bags must be orange in color. For autoclaving, label the bags with heat sensitive autoclave indicator tape in an X-pattern over the biohazard symbol, and secure the bag opening with indicator tape. Do not seal the bag tightly. This will allow more steam to enter the bag during the sterilization process. Disposal contractors will return drums containing biohazard bags or any other labels indicating biohazard materials, and the landfill will reject waste that contains biohazard bags that have not clearly been marked with indicator tape as autoclaved.

North Carolina medical waste regulations stipulate that autoclaves used for the treatment of medical waste be tested at least weekly with a biological indicator. Do not confuse the chemical indicator tape with biological indicators. After autoclaving medical waste, place it in the barrels marked for AUTOCLAVED or DECONTAMINATED waste. Housekeeping will empty these barrels, but will not touch or move orange bagged waste from any other locations, whether it was autoclaved or not. For procedures on medical waste disposal that are more specific, refer to UNC’s Medical Waste Policy.

Waste Disposal of General Waste – Broken Glass/Sharps

Waste or trash placed in wastebaskets is picked up by Housekeeping personnel, transferred to dumpsters and transported to the sanitary landfill for burial. Prohibited items from the sanitary waste stream include batteries, liquid wastes, radioactive wastes, hazardous wastes as defined by the Resource Conservation and Recovery Act (RCRA), poisons, biohazardous wastes, and other wastes that would pose a threat to the health and safety waste-handling personnel or the environment.

Broken Glass and Other Sharp Objects

Place uncontaminated and/or decontaminated glassware and non-regulated sharp objects in a plastic bag within a cardboard box identified with a label indicating: “CAUTION, GLASS AND SHARPS, and NON-HAZARDOUS WASTE ONLY“. You can download these labels from the EHS Safety Labels webpage. EHS recommends this manner for disposal of all glass items. Housekeeping will pick up these boxes if they are sealed.

Regulated Sharps

North Carolina law requires special handling of hypodermic needles, razor blades, scalpels, lancets, syringes with/without needles, slide covers, and specimen tubes. Please dispose of these items in a hard-walled waste container. At UNC-CH research laboratories, biohazardous sharps are collected in red, plastic containers available from Fisher Scientific (stock # 14830124 for contaminated, 1482664B for non-contaminated). These containers must bear the biohazard symbol and marked with an “x” using autoclave indicator tape. Federal OSHA regulations (29 CFR 1910.1030, Bloodborne Pathogens) require biohazard laboratories to minimize their use of sharps whenever possible and that needles not be recapped, purposely bent, broken, or otherwise manipulated by hand. To avoid accidents and prevent overfilling of the sharps waste containers, remove the waste containers for disposal when they are 2/3 full. When removing the sharps container from a biosafety cabinet, always decontaminate the exterior of the container. Containers of sharps contaminated with biohazardous waste materials should be autoclaved inside of an orange autoclavable bag marked with autoclave indicator tape forming an “x” over the bag’s biohazard symbol. After autoclaving is complete, the bags with the containers of sharps can be disposed of with the regular trash. Non-hazardous sharps should be placed in the white plastic sharps containers. The non-hazardous sharps containers should be disposed of in regular trash once they are 2/3 full.

Other Regulated Sharps

Place broken glass and other sharps contaminated with carcinogens or radioactive material in the containers provided for these waste streams. Metal cans are not suitable for sharps contaminated with trace carcinogens or short-lived radioactive material, since these wastes are incinerated. Plastic-walled containers with tight-fitting lids are appropriate for disposal of these waste streams.

For long-lived radioactive materials, any type of hard-walled container is suitable. Refer to the UNC Radiation Safety Manual for radioactive sharps disposal procedures.

Disposal of Medical Waste

You must decontaminate medical wastes before disposal to the sewerage system, general waste, chemical waste, radioactive waste or any other disposal system. Liquid infectious wastes such as human blood or pathogenic cultures must be autoclaved prior to sanitary sewer disposal. Do not attempt to disinfect this waste with bleach without registering the process on your Lab Safety Plan Schedule F.

Decontaminated wastes placed into general waste must be in an autoclaved bag marked with heat sensitive tape to signal that the material has been decontaminated. State law requires biological indicator testing at least once a week. Refer to the UNC Medical Waste Policy for specific procedures.

Disposal of Radioactive Wastes

The purchase, use, storage, and disposal of radioactive materials are governed by the NC Regulations for Protection Against Radiation, and policies and procedures promulgated by the UNC Radiation Safety Committee. Refer to the UNC Radiation Safety Manual for details. For disposal, fill out the waste disposal from online for pickup. For access to the Radiation Waste Disposal section, you must have taken either the instructor-led training course or the online EHS training course, depending on your experience.

Empty Chemical Containers and Recycling

Empty glass containers can either be used for waste collection if it is compatible with the waste, or defaced and put in with your glass waste box. If the container once held a P-listed, or acutely toxic substance, dispose as waste.

Back to Chapter Eleven

Proceed to Chapter Thirteen

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Article ID: 132024
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