Hazardous Waste Management Committees
Issued August 2, 2004
Table of Contents
Chemicals have become a part of everyone's life. The disposal of used or waste chemicals has not always been considered by chemical users. The safe use and disposal of chemicals is required of everyone. Chemicals are used in every department on the Kansas State University campus. It is the responsibility of each faculty, staff, and student at the University to deal with chemicals properly and to dispose of chemicals in a responsible and lawful manner.
The U.S. Environmental Protection Agency (EPA) and the Kansas Department of Health & Environment (KDHE) enforces various laws such as the Resource Conservation and Recovery Act (RCRA), the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund), and the Superfund Amendment Reauthorization Act (SARA). These laws are meant to protect the environment.
The President and the University's central administrative staff take RCRA and the other Acts very seriously. Faculty and staff are expected to strictly follow the regulations of the EPA and KDHE. The Division of Public Safety is responsible for overseeing compliance of these regulations. The department or college that permits the improper disposal of chemicals or chemical products will be held liable for any fees or penalties imposed by the EPA or KDHE. College Safety Committees formed within each college are expected to include RCRA inspections as part of their responsibilities.
Individuals (faculty, staff or students) who have knowledge of improper disposal of chemicals or chemical products must make the University administration aware of the situation. This can be accomplished by advising the Division of Public Safety, the University Environmental Stewardship Committee, or the Campus Environmental Health & Safety Committee. The University guarantees that no reprisal will be held against the individual.
Hazardous waste is defined under RCRA and the Hazardous & Solid Waste Amendments (HSWA) as any solid waste that has the following hazardous characteristics:
Ignitability (flash point less than 140EF);
Corrosivity (pH less than 2 or greater than 12.5);
Reactivity (reacts with air or water to produce an explosive, flammable or toxic product); or
Toxicity (contains specific pesticides, heavy metals, or organic solvents).
Waste chemicals found in the K-list or F-list, as well as off specification, out dated, excess, or spilled chemicals found in the U-list or P-list are also considered hazardous waste. Chemicals must be handled correctly when they are to be discarded. Kansas State University is regulated as a generator of hazardous waste (EPA Generator status) and must comply with the laws governed by KDHE and the EPA. Chemicals may not be haphazardly discarded down the sink drain, put in the trash, poured onto the ground, or discharged to the atmosphere.
Hazardous waste regulations require that containers of hazardous waste are
kept tightly closed;
marked with the words "Hazardous Waste;
marked with the chemical name of the contents and not abbreviations or chemical formulas;
marked with the date when waste is first put into the container;
marked with the date when filled; and
stored not more than three days in the room when full.
The waste must be stored in the room where the waste is generated. In addition, only one container per waste stream is allowed per room. Words, names, and dates must be marked in English. Unmarked containers with contents are considered hazardous waste, and therefore are considered to be a deficiency. Mark all chemical containers appropriately. Deface empty chemical containers and promptly discard in an appropriate manner.
The Division of Public Safety will ensure that departments conduct regularly scheduled inspections of laboratories, shops, and other rooms for hazardous waste deficiencies. Teaching laboratories will be inspected at least once each semester. Research and service laboratories will be inspected at least once each year. Deficiencies found during inspections by the College Safety Committee will be corrected by the department head. Each College Safety Committee must send a copy of the inspection report to the Division of Public Safety for review by the Campus Environmental Health & Safety Committee.
Unannounced inspections for RCRA violations will be performed by the Division of Public Safety staff during the year. Following inspections, a notice of deficiencies will be forwarded to the responsible department and corrections must be made within thirty days of the notice.
If no response is made after thirty days, a memo will be sent to the appropriate Dean for the responsible department. If the deficiencies are not corrected or recur, department heads will be held responsible. The assessment of fines by the EPA is driven by many and varied requirements and regulations. These Federal fines fall between $2,000.00 to $27,500.00 per violation per container per day. Colleges will be responsible for any fines levied by the KDHE or the EPA.
If the violations continue, the Division of Public Safety may impose strong sanctions against the offending individual or principle investigator. These sanctions include loss of laboratory privileges or restrictions to purchase chemicals. Minimum inspection standards include:
Lack of "hazardous waste" marking
Unidentified or improperly identified contents
Multiple containers of same waste stream
Improper waste disposal
Many of the hazardous waste management issues on campus arise from the fact that university populations are somewhat transient and are governed by many different organizational structures. Due to this, certain management protocols must be enacted and enforced in order to better manage hazardous wastes and improve regulatory compliance. These guidelines are subject to change and will be modified as needed:
Campus departments will be responsible to maintain an up to date listing of active laboratories and shops and the responsible faculty or staff member.
Each laboratory must generate and update written methods for all experiments and analyses conducted including the content of all wastes.
Prior notification must be made to the Division of Public Safety if there is to be a planned change in the faculty or staff member responsible for any laboratory or shop. The exiting responsible party must identify and label all chemicals and waste in each room. At that time the Division of Public Safety will take possession and remove all outdated chemicals and hazardous waste. A hazardous waste determination will be made on any unlabeled chemicals at the current contract cost specified by the hazardous waste disposal vendor.
The Division of Public Safety must be notified immediately in the event of an unplanned change in the party responsible for a given laboratory or shop. At such time, the Division of Public Safety will take possession and remove all outdated chemicals and hazardous waste. A hazardous waste determination will be made on any unlabeled chemicals at the current contract cost.
A Presidential committee will be formed comprised of faculty and/or staff from each College and from the staff of the Vice President for Administration and Finance. This committee will be known as the University Environmental Stewardship Committee. The committee will be responsible for recommending policy to the Campus Environmental Health & Safety Committee, reviewing RCRA compliance issues, reviewing notice of violations, setting penalties, and acting as a review board for complaints.
Questions are to be directed to the Department of Environmental Health and Safety, telephone number (785)532-5856.