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 legal responsibility of each faculty, staff, and student at the University to deal with chemicals properly.
The EPA and the Kansas Department of Health and Environment (KDHE) enforce various laws which are meant to protect the environment. The EPA and KDHE encourage chemical waste minimization in every industry. The Kansas State University administration agrees with the need to reduce the quantities of hazardous waste that are generated. With this in mind, the Hazardous Waste Minimization Policy was written and is enforced (see section IX.H. below).
The department or college that allows the improper storage or disposal of chemicals or chemical products will be held liable for any fees or penalties imposed by the EPA or the (KDHE). Any costs for waste disposal that may have been prevented by proper management or recycling may be imposed on the offending department or college by EHS.
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 EHS, any member of the Campus Environmental Health & Safety Committee, or the KSU Maintenance and Service Employee Safety Committee. The University guarantees that no reprisal will be held against the individual.
Identifying Hazardous Waste
Hazardous waste is defined under the Resource Conservation and Recovery Act (RCRA) and the Hazardous & Solid Waste Amendments (HSWA) as any liquid, solid or gas that has no commercial value (solid waste) and has a hazardous characteristic component. These characteristics are:
- Ignitability (flash point less than 140°F);
- 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).
In addition to the above characteristics, chemicals that are hazardous waste also identified in the F-list, K-list, P-list and U-list, which are in the EPA and KDHE regulations. 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 discarded down the sink drain, poured onto the ground, discharged to the atmosphere, or buried at an unpermitted site.
Hazardous Waste Minimization
Laboratories are accountable for their hazardous waste from the time it is generated until it no longer exists. The one method to ensure proper disposal is to reduce or minimize the waste produced. The EPA requires waste minimization as a method of pollution prevention. The Kansas State University administration agrees with the EPA for the need to reduce the quantities of hazardous waste generated. Management and staff at all levels must be openly and actively committed to supporting sound waste management policies and practices.
The success of the Waste Minimization Plan depends ultimately on the participation and cooperation of all laboratory workers and students. The KSU community must do everything that is within its means to reduce hazardous waste on the campus. Each campus unit is urged to use any of the following techniques to reduce hazardous waste:
- substitution (use a less hazardous chemical)
- small quantity purchases
- microscale experiments
- redistribution (use of recycled chemicals)
- waste segregation (keep waste streams separate, for example, separate organic from aqueous or halogenated from nonhalogenated).
- Re-use waste as is or after purification. Certain purification processes such as distillation are permitted in the laboratories. The waste from these processes should be handled as hazardous waste. For assistance, Contact EHS.
Handling and Disposal of Waste
These guidelines will enable the user to directly process and discard most materials appropriately or minimize hazardous waste:
- The person responsible for the generation of the waste or the person in charge of the materials should handle the chemical waste.
- Use and recycle materials in their intended fashion to limit disposal problems.
- Each laboratory should be equipped with a fume hood and the means to carry out simple neutralization reactions.
- All chemicals must be identified with the name (not symbols, formulae, or abbreviations). This includes hazardous waste.
- All waste containers must be marked with the words “Hazardous Waste.”
- All containers of hazardous waste must be kept closed.
- Hazardous waste must be kept in the room where the waste is generated.
- Full containers of hazardous waste must be dated when full and removed from the laboratory within three (3) days of the date.
- Empty containers should be rinsed three times and then properly discarded to a trash dumpster. Deface the label on empty containers so there is no question about hazards. Do not rinse containers that held P-listed waste. These containers are considered hazardous waste and should be managed as such.
Containers or container liners that held hazardous materials are not usually regulated as hazardous waste if they are empty. A container is considered empty if: All wastes have been removed that can be removed by pouring, pumping, and aspirating, and; no more than one inch of residue remains in the container, or; no more than 3.0% by weight of the contents remain inside the container (≤110 gallons), or; no more than 0.3% by weight of the contents remain inside the container (>110 gallons).
- Do not rinse “empty” containers that held P-listed materials or wastes. If you do, the rinsate must be collected and handled as hazardous waste.
- Non-rinsed P-listed material containers must be turned in for hazardous waste disposal. See Appendix D: P-Listed Chemicals.
Acids and bases
Laboratory acids or bases should not be haphazardly discarded. Most acid and base wastes can be neutralized to a pH of 5 to 9 and washed down the sink drain with copious amounts of water.
There are many alternatives today to the use of chromic acid cleaning baths. There are many suitable non-chromate containing substitutes available on the market that are safer than and just as effective as chromic acid.
No batteries may be discarded in the trash. Batteries will be recycled if possible by EHS. An effort will be made to return dead or weak batteries to the manufacturer or a battery recycler. If no means are found to recycle batteries, they may be discarded as hazardous waste by EHS.
Gas cylinders should only be procured from dealers or manufacturers that will accept the return of empty cylinders (see section VIII. J above). This is especially important in the use of lecture size or smaller bottles. Aerosol cans are considered to be gas cylinders. Empty aerosol cans may be discarded in the trash. For assistance, call EHS.
Used oil from vehicles, machines, pumps, compressors, etc., must be turned in to EHS. Used oil may not be dumped on the ground for weed or dust control. To dispose of used oil, call EHS.
Waste petroleum-based paints or paints containing lead, silver, chromium or other toxic heavy metals must be disposed of as hazardous waste. Use latex paints rather than petroleum solvent-based paints. Use alternatives to paints containing chromates. Do not buy and store large quantities of petroleum-based paints. Use up all paints; do not leave small quantities that will require hazardous waste disposal. Liquid latex paint may not be discarded in the trash. EHS will also pick up latex paint.
The use of organic solvents in the laboratory is very common. Laboratory personnel should consider the purchase and operation of solvent stills or high performance liquid chromatography (HPLC) solvent recyclers to reclaim used solvent.
Do not buy or request more pesticides than is necessary for the research. Use less toxic or less flammable pesticides if possible. Limit the amounts kept in storage to prevent disposal of out-dated pesticides. Arrange for the return of research pesticides to the manufacturer. Old or unwanted pesticides will be picked up by EHS.
Silver waste from photographic development is considered hazardous waste and must not be discarded into the sink drain. For assistance, call EHS.
Do not discard elemental mercury or glassware contaminated with mercury in the trash. Do not sprinkle sulfur on mercury spills. Contact EHS to clean up mercury spills. Mercury and mercury-contaminated materials are picked up by EHS.
Departments are encouraged to replace mercury-containing devices such as manometers, barometers, thermometers, etc., with non-mercury devices.
Each laboratory that uses chemicals must make an effort to reduce shelf stock wherever possible. A great deal of Kansas State's hazardous waste is from the clean out of vacated laboratories. This waste generation could have been minimized if greater care were spent in purchasing, stocking, and using chemicals.
Purchase only what is needed and maintain a current inventory of chemicals in stock. EHS expects laboratory managers to use inventories as a means to reduce waste. Buy only the quantities of chemicals needed without overstocking. Use up old chemical stock before buying new stock.
Establish a centralized chemical storage area. This would facilitate the redistribution of surplus chemicals. Buy chemicals at the established chemical storerooms on campus such as the Biology Storeroom (Ackert Hall) or the Chemistry Storeroom (King Hall).
Promptly replace deteriorated labels and containers. No chemical container may be kept in storage without an identifying label.
In-Lab Disposal Methods
Neutralization. Many laboratory chemicals can be neutralized or made nonhazardous in the laboratory and discarded into the sanitary sewer system. For instance, mineral acids may be neutralized with a base to a pH between 5 and 9. The resulting solution may then be washed down the sink drain with copious amounts of water. For additional information or help in neutralizing chemicals, call EHS. Several books have been published that suggest laboratory neutralization processes, some noted ones are:
Prudent Practices in the Laboratory
Hazardous Laboratory Chemicals Disposal Guide
Destruction of Hazardous Chemicals in the Laboratory
Waste Disposal in Academic Institutions
Evaporation. Do not dispose of chemicals by evaporation. Evaporation of solvents or other chemicals as a means of disposal is not permitted under hazardous waste regulations.
Sanitary sewer system (the sink drain). Very few chemicals may be discarded into the sanitary sewer. Only small quantities of non-flammable, low hazard, biodegradable and water-soluble materials may be disposed this way. Amounts of less than 100 g or 100 ml per day may be flushed down the drain with copious amounts of water.
Trash dumpster. Do not dispose of chemicals in the trash.
A pick-up service is provided by EHS provided the following guidelines are observed:
- Waste material may be collected in empty compatible glass or plastic containers.
- Waste collection containers must be marked with the words “Hazardous Waste.”
- Waste collection containers must be marked with the date when full.
- Waste collection containers must be kept closed except when adding waste.
- Halogenated waste must be kept separate from non-halogenated waste.
- Organic waste should be kept separate from inorganic waste.
- "Defuse" or stabilize reactive waste in the laboratory when it is appropriate.
- Keep waste materials from different processes separate, if possible.
- Excess, off-spec, or outdated unused laboratory reagents for pick-up do not need to be labeled “Hazardous Waste” as long as there is a chemical identification label on the container.
In preparation for hazardous material pick up:
- Collection containers for hazardous waste must be labeled with the words “Hazardous Waste,” marked with the name of the chemical contained, dated when full, and be closed to prevent spillage.
- Non-compatible materials must be kept separated (see Appendix A).
- Box groups of containers so that they can be carried easily by hand.
- Label the box "PUBLIC SAFETY WASTE". Appropriate labels are available at no charge from EHS.
- Fill out a Hazardous Waste pickup request form on the EHS webpage at www.k-state.edu/safety. The form is on the right-hand side of the page. For assistance, call EHS at 2-5856.
Waste awareness training is provided by the University. One-hour classes are held monthly in the basement training room in Edwards Hall. Departments may request a seminar at their location and training is available on the EHS web page.
All employees are encouraged to attend this training at least once a year.