Laboratory Safety Manual - Chapter 12: Laboratory Waste Management Plan

Title

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 
   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 chemical waste including hazardous and non-hazardous solid waste, low-level radioactive or mixed waste, biohazardous and medical waste, and universal waste requires strict compliance with state and federal regulations. 

The Principal Investigator (PI) for each laboratory has overall responsibility for:

• containerizing laboratory waste,
• labeling laboratory waste, and
• managing laboratory waste

prior to waste disposal confirmation and pickup by the Department of Environmental, Health and Safety (EHS). The Environmental Affairs Section of the EHS Department is responsible for reviewing laboratory waste, classifying waste, and approving of waste disposal requests from labs.

EHS personnel conduct the transfer of chemical wastes, low-level radioactive wastes, and mixed wastes from laboratory areas to the UNC Hazardous Materials Facility (HMF) for bulking, package consolidation, and managed storage prior to being transported to off-site treatment and disposal facilities. Waste disposal vendors may also collect waste from laboratories and ship them directly for proper off-site disposal.

The University of North Carolina at Chapel Hill operates as a Large Quantity Generator (LQG) of hazardous waste. The management of hazardous waste is subject to regulatory compliance obligations. The University is regularly audited and inspected by the North Carolina 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 applicable 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. The LWMP applies only to laboratories on campus, such as teaching labs, research labs, art and photo labs, field labs, diagnostic labs in teaching hospitals, and supporting areas 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.

Figure 12.1. Example of 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

Regulations require 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 (about two-thirds full), an online chemical waste pickup form (e510) shall 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, but are not limited to, 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 Office (919-962-5509) immediately if you exceed the limit.

To dispose of waste, you must submit an online Chemical Waste Pickup Request (e-510 form) for each unwanted material container. One request may be submitted for multiple containers that contain waste of the same chemical composition, concentration, and size of container. Submitting the e-510 form prompts the EHS Hazardous Materials Manager to review the request and initiates the waste pick-up process once the request has been approved. If you are requesting a 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 under multiple PIs or buildings, you must have a worker registration form for each PI and building to submit tickets for the designated lab space. 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.

Instructions for submitting waste are provided below:  

1. Navigate to the online Chemical Waste Pickup Request (e-510 form)

• Click the “Chemical Waste Pickup” link.
• Click on the “Make New Request as PI” field.
• Choose the name of the faculty member responsible for the laboratory and click “submit”.

2. Fill out the e-510 form

• 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 an aqueous solution, organic solvent, or other.
• pH value: Complete for aqueous solutions that contain corrosives (acids or bases); otherwise, enter a neutral pH value (i.e., ‘7’).
• Mixed chemicals: Indicate whether the chemical constituents were mixed before use (“new”) or after use (“used”).
• Chemical composition: List all constituents and their estimated percentages. The total must add up to 100 percent. Do not use abbreviations or chemical formulas. “Water” is already listed in this section. Include the percentage of water, if applicable.
• Container size: List the size of the waste container (gallon, liter, etc.)
• Container type: Identify the container type from the drop-down menu; choose “other” if your container type is not otherwise listed.
• Weight: Provide the 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 any hazards to alert the technician or describe the location of the waste.
• Container Delivery: Waste containers can be requested from EHS in this section. Specify the type and number of containers you would like the waste technician to deliver. Liquid waste may be accumulated in 10-liter carboys, 19-liter carboys, or closed-top drums. Solid waste may be accumulated in buckets or open-top drums. If you are requesting a drum, please indicate whether you are requesting an open-top or closed-top type in the Notes section.

3. Confirm the request

• 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.

4. Print and attach the Hazardous Material Transfer Form

• After your request has been approved, you will receive a confirmation e-mail that includes a link to the Hazardous Material Transfer Form. You must print out this form and affix it to each individual waste container. You may need to print more than one copy. The form identifies the waste for pickup and provides crucial information for the technicians who process the waste. The waste technician will not collect the waste unless the form is securely attached to each container.

During the review process, the Hazardous Materials Manager may send you an email requesting 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 collected in a timely manner. Controlled substances cannot be submitted for disposal through this ticket process and must go through a witnessed destruction. For information and guidance on disposal of controlled substances, see Chapter 9 of the Laboratory Safety Manual.

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.

Containers

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. Do not use corks or stoppers in place of lids. 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 recommended.

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 waste from an experiment or procedure. A working container may remain open until the end of the procedure, until the end of a work shift, or until the container is two-thirds full, whichever comes first. The container must then 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 or removed from the container.
3. When venting the container is necessary for proper operation of laboratory equipment (such as HPLC) or to prevent dangerous build up of pressure that may result from a reaction between waste constituents. In some cases, a vented container lid should be employed to prevent gas build-up. HPLC waste should utilize solvent caps with appropriate ports when in use and should be closed with an appropriate sealed cap at the end of a work shift. For help locating vented lid or solvent caps, contact EHS (919-962-5507).

Liquid waste may be accumulated in reagent bottles or carboys that are chemically compatible with the waste. If you generate a large volume of liquid waste, consider 19-liter carboys (Figure 12.2). Containers of liquid wastes must have at least ten-twenty percent head space (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 active waste containers holding liquid chemical waste and all glass containers of liquid chemical waste stored on the floor, require secondary containment. 19-liter carboys that are no longer being added to, two-thirds full, and have been submitted to EHS for pick-up can be stored as shown in Figure 12.2. Do not stack more than two 19-liter carboys. 

Figure 12.2. Example of 19-liter carboys used for collecting liquid waste that are two-thirds full and have been submitted and approved for pick-up. 

Solid waste (e.g., gloves, paper towels, pipette tips, gels, etc.) must be placed into a five-gallon screw-top bucket or appropriate solid waste drum and lined (Figure 12.3). Liners must be 1.5 mil or greater polypropylene or low-density polyethylene (LDPE) bags. Do not use biohazard, radiation, or colored waste bags for solid waste accumulation. Regular clear or black 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 a five-gallon screw-top bucket. Collect liquid ethidium bromide waste in carboys or bottles and manage accordingly. Sharps containers cannot be placed within solid waste or broken glass boxes and must be disposed of accordingly. For more information, see the section below on “Regulated Sharps.”

Figure 12.3. Example set up for solid waste disposal showing 5-gallon screw top bucket lined with clear liner.

Reactive chemicals must be disposed in their original shipping containers, or in containers provided by EHS. More information is provided below on reactive chemicals disposal. Chemicals still within their manufacturer container can be submitted to EHS as is and do not need to be removed or placed into another container unless leaking or broken.

Chemical Waste Segregation

Acids and Bases

Segregate containers of waste acids and bases from one another in individual, compatible containers during accumulation and storage. EHS will pick up concentrated acids and bases as chemical waste. Do not discharge acids, bases, or acidic or basic solutions containing heavy metals to the sanitary sewer through laboratory sinks. The Orange Water and Sewer Authority (OWASA) Sewer Use Ordinance prohibits discharge of aqueous liquids with a pH of less than 6 and greater than 10. 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.

Oxidizers

Store and accumulate oxidizers away from organic substances, including flammable materials. Oxidizers shall 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. Note that in accordance with the OWASA Sewer Ordinance,  halogenated and non-halogenated solvent wastes shall not be discharged to the sanitary sewer. This can result in a fire or explosion hazard (e.g. non-halogenated hydrocarbons) or 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 have not been fully emptied can be 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 as chemical waste.

“Unknowns” – Unidentified Chemicals

Unlabeled chemicals present a challenging and potentially 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 significant. EHS provides periodic identification and removal of unknowns through 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 Office (919-962-5509) for assistance and handling information.

Training

All new laboratory workers are trained on chemical waste management procedures via the online lab safety orientation training. In addition, the PI-specific Laboratory 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.

If the laboratory has recurring laboratory waste disposal issues (e.g., improper disposal of sharps, chemical liquid waste, biological liquid waste, etc) identified through either laboratory inspections or the Hazardous Materials team upon pick-up, all laboratory personnel will be required to go through an in-person retraining regarding laboratory waste management.

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 shall be removed from the laboratory through proper disposal procedures. Follow the waste pickup process by filling out an online waste pickup form for each unwanted or unneeded chemical.

Waste Minimization

The most significant way that you can assist in the management of chemical waste is to reduce the volume of unwanted materials. Principal Investigators are encouraged to consider ways to reduce their volume of waste or reuse materials by redesigning experiments. Keep recyclable materials separate from other wastes.

Disposal to the Sewage System

Do not use the sanitary sewer for the disposal of unwanted chemicals, with the exception of trace quantities associated with cleaning and washing operations, e.g., glassware rinsate. Under no circumstances should any chemicals and halogenated or non-halogenated solvents be discharged to the sewer. 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 or greater than 10.0.
• 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 waste water treatment plant influent temperature to 104°F (40°F) or greater.
• Waste discharges of any toxic waste material(s) in volumes or strengths that could cause interference with waste water treatment processes or that could contaminate waste sludge or effluent from the waste water 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 be discharged to the sewer.

Do not dispose any of the following down the drain:

• Acids with a pH less than 6
• Bases with a pH greater than 10
• Any halogenated or non-halogenated hydrocarbons, solvent, or other chemical agents 
• Wastes containing sodium azide
• Wastes containing formaldehyde
• Solutions containing heavy metals

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

Chemical Waste Emergencies

If a dangerous situation occurs involving chemical waste in your laboratory, do not touch the container. If safe to do so, determine the waste components and potential hazards and call EHS (919-962-5507) to report the incident. The EHS Emergency Response Team and/or the EHS Hazardous Materials Manager will immediately respond, assess the situation, remove the container, or leave it in place and sequester the area until an outside vendor can remove it for proper disposal.

Peroxides

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 waste technicians and to ensure compliance with the Resource Conservation and Recovery Act (RCRA) regulations, exercise care to identify reactive wastes. Some reactive chemicals can exhibit dangerous, residual properties, even after a reaction is completed. 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 reactive materials, make every effort to use or react your entire stock and only order these materials in necessary quantities.

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 shall place solid medical waste (other than sharps) in a closable red-colored container that is:

• Less than or equal to 15-gallons (57-L),
• closable with a lid,
• durable,
• labeled with the universal biohazard symbol,
• leak-proof,
• and lined with a plastic bag that is:
  • autoclavable
  • orange, and
  • labeled with universal biohazard symbol

Orange plastic bags shall only be used for biohazard waste that must be autoclaved before disposal or incineration. All autoclavable 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 shall 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 bins marked for AUTOCLAVED or DECONTAMINATED waste. Housekeeping will empty these bins 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. If the laboratory prefers or requires their medical or biohazardous waste to be incinerated, contact EHS for more information on setting this up. The laboratory is required to document all biohazardous waste disposal procedures in their Laboratory Safety Manual.

For more information regarding biological waste disposal or decontamination of biological hazards, see Chapter 10 of the Biological Safety Manual.

Waste Disposal of General Waste 

Waste or trash placed in waste baskets will be picked up by Housekeeping personnel, consolidated, and transported to the municipal landfill for burial. Prohibited items from the municipal waste stream include batteries, liquid wastes, low-level 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 of 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 or without needles, slide covers, and specimen tubes. Please dispose of these items in a hard-walled appropriate container (Figure 12.6). At UNC-CH research laboratories, biohazardous sharps are collected in red, plastic containers available from any major scientific supplier. The laboratories and departments are responsible for supplying sharps containers to their reseachers. Biohazard containers must bear the biohazard symbol and be 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 state that needles must not be recapped, purposely bent, broken, or otherwise manipulated by hand. To avoid injuries and prevent overfilling, 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.

Figure 12.6. Example of appropriate sharps containers that can be purchased and used in laboratories.

Non-hazardous or chemically contaminated sharps should be placed in  white or clear plastic sharps containers without a biohazard symbol and labelled appropriately. Non-hazardous sharps containers should be sealed and taped and should be disposed of directly into a dumpster once they are 2/3 full. Chemically contaminated sharps containers should be properly sealed and submitted to EHS via the waste pick-up request website. Metal cans or other hard-walled containers should not be used as sharps containers for non-hazardous or chemically contaminated sharps. Appropriate sharps containers must be used and purchased by the laboratory.

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 sewer, municipal landfill, chemical waste treatment facility 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 disinfect this waste with bleach without registering the process on your Lab Safety Plan Schedule F.

Decontaminated wastes discarded into the municipal solid waste stream 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. For more information regarding biological waste disposal or decontamination of biological hazards, see Chapter 10 of the Biological Safety Manual.

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 form 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 chemical waste collection if the container material is compatible with the waste, or they can be defaced and placed in a glass waste box. If the container once held a P-listed, or acutely toxic substance, dispose of it as chemical waste. Before reusing a container, ensure that the chemical container is tripled-rinsed (rinsate should be disposed into appropriate waste container) and allowed to fully dry.

Back to Chapter Eleven

Proceed to Chapter Thirteen