Hazardous Waste Management
Revised May 17, 2017
Table of Contents
Chemicals are used in every department on the Kansas State University campuses. It is the responsibility of faculty, researchers, staff and students at the University to manage 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 and Environment (KDHE) enforce laws governing the management of hazardous materials, including the Resource Conservation and Recovery Act (RCRA). These laws are established to protect human health and the environment.
The President and the University's central administrative staff take RCRA, other related acts and associated regulations seriously.
Faculty, researchers, staff and students are expected to strictly follow the regulations of the EPA and KDHE and understand their personal responsibility under the law. Kansas State University's Department of Environmental Health and Safety (EHS) is responsible for overseeing compliance of these regulations. College and department Environmental Health and Safety Committees (as defined in Chapter 3740), formed within each college, are expected to include hazardous waste inspections as part of their responsibilities.
Colleges and/or departments will be responsible for any fines levied by State and Federal regulatory agencies resulting from improper management of hazardous materials. Any department and/or college that permits the improper disposal of chemicals or chemical products will be responsible for paying costs of corrective actions imposed by the EPA or KDHE.
Individuals (faculty, researchers, staff or students) who have knowledge of improper disposal of chemicals or chemical products must make the University administration aware of the situation by advising the EHS Director or the Campus Environmental Health and Safety Committee (8050) chair. The University guarantees that there will be no reprisal against the individual for reports made in good faith.
Hazardous waste is defined as any solid waste that is either 1) a listed hazardous waste under federal regulation 40 CFR Part 261.30, or 2) a waste that exhibits the following hazardous characteristics:
Ignitability (flash point less than 140° Fahrenheit);
Corrosivity (pH less than or equal to 2 or greater than or equal to 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).
Kansas State University is regulated as a hazardous waste generator, governed by a specific set of regulations that are based on the generator status of each campus. All chemicals must be handled and disposed in accordance with the applicable regulations. Chemicals that do not match the definition of a hazardous waste may be regulated by other laws restricting their disposal and/or may not be received into other waste streams. Chemicals or other hazardous materials may not be discarded down the sink or floor drain, placed in the trash, buried or poured onto the ground, or discharged to the atmosphere.
At minimum, hazardous waste containers must be:
kept tightly closed;
marked with the words "Hazardous Waste";
marked with the chemical names of the contents, not abbreviations or chemical formulas, and their percentages;
- marked with words, names and dates in English;
stored in the room where the waste is generated or moved within 24 hours to an EHS-approved satellite accumulation area (SAA);
- only one container per waste stream (waste type) is allowed per room or SAA;
- marked with the date the container is full and no longer needed; and
stored not more than three days after the container is full or no longer needed.
Unmarked containers with contents are considered hazardous waste, and therefore are considered to be a deficiency. Mark all chemical containers appropriately. Remove or deface labels from empty chemical containers and promptly discard in an appropriate manner. Contact EHS for disposal of hazardous materials.
The Department of Environmental Health and Safety and Campus Environmental Health and Safety Committee will ensure that college and/or department Environmental Health and Safety committees, or their designee(s), conduct regularly scheduled inspections of laboratories, shops and other areas containing hazardous waste materials to identify safety and hazardous waste deficiencies. Minimum criteria for waste inspections must include verification of requirements listed in section .040 of this policy.
- Teaching laboratories will be inspected at least once each semester.
- Research and service laboratories will be inspected at least once each year.
- Department heads will ensure that deficiencies found during inspections by the college safety committees are corrected.
- College/department Environmental Health and Safety Committee must report annually to the Campus Environmental Health and Safety Committee the status of inspections and make inspection reports available to the EHS Department for review.
Unannounced inspections for hazardous waste violations may be performed by EHS Department staff during the year. Following inspections, a notice of deficiencies will be forwarded to the responsible department and corrections must be made within 30 days of the notice. If no response is made after 30 days, the appropriate dean for the responsible department will be notified. If the deficiencies are not corrected or recur, department heads must be held responsible.
Individuals responsible for significant violation(s), multiple or recurrent violations will be sanctioned, including but not limited to: loss of laboratory privileges, restrictions on the use of chemicals and/or the ability to purchase chemicals, and suspension or termination of employment.
All individuals that generate or handle hazardous waste must take online or classroom hazardous waste management training provided or approved by EHS and must receive on-the-job hazardous materials/waste training appropriate to their specific job duties that is provided by the responsible supervisor, laboratory or shop manager. Training is required within six months of employment or transfer of job duties that involve hazardous materials management. A refresher training is required annually thereafter. For information on hazardous waste management training contact EHS (785-532-5856).
Management protocols must be enacted and enforced in order to better manage hazardous materials and ensure regulatory compliance. These protocols are subject to change and will be modified as needed:
- Campus departments/units will maintain an active chemical inventory of all hazardous materials within the KSU centralized chemical inventory system.
- Campus departments will be responsible for maintaining an up-to-date listing of active laboratories and shops and the responsible faculty or staff member. Laboratories must register with EHS and provide this information.
- 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 EHS when there will 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. EHS must be notified immediately in the event of an unplanned change in the employee responsible for a given laboratory or shop. EHS will remove all outdated chemicals and hazardous waste. A hazardous waste analysis will be made on any unlabeled chemicals at the current contractor cost. Departments may incur waste costs for “abandoned" or unlabeled chemicals and equipment in laboratories.
- The University Environmental Health and Safety Committee will be responsible for recommending policy to administration, reviewing hazardous materials/waste compliance issues, reviewing notices of violation, setting penalties and acting as a review board for complaints.
EHS (785-532-5856 or www.ksu.edu/safety) is responsible for clarification or interpretation of hazardous waste policy and regulations. EHS provides guidance and resources to assist the institution with implementation of these requirements, including the management and coordination of proper hazardous waste disposal.