PROGRAM
Hazardous waste disposal is governed by the EPA and the TCEQ through State and Federal regulations. The purpose of environmentally sound disposal methods is to prevent harm to the water, land, and air.

TWU complies with hazardous waste disposal regulations by means of the Hazardous Waste Management Program.

Permits and Requirements
TWU is a "Small Quantity Generator" of hazardous waste. The University's generator permit applies to all campuses in Denton, Dallas and Houston. Unlike the main campus, other campuses do not generate enough chemicals and are therefore "conditionally exempt". The Safety Office will assist any department in determining its hazardous waste disposal needs.

Penalties of Noncompliance
Noncompliance with any hazardous waste regulation may result in substantial fines and penalties for the University. In addition, individual generators may be personally liable. Generators may be cited or fined for numerous types of violations. Violations range from improperly labeling a waste container to intentionally disposing of hazardous waste incorrectly.

Function of the Safety Office
The Safety Office administers the Hazardous Waste Management Program at TWU. Compliance with this program is very demanding. It requires full cooperation by all campus entities. The primary focus of this program is chemical and biological infectious waste management. The program does not include procedures for the disposal of radioactive or nonhazardous waste. (See plans for Radiation Safety, and Chemical Hygiene Plan.)

The Safety office coordinates the collection of chemical hazardous waste until it is shipped for final disposal. Safety Office also maintains records of all disposed hazardous chemical waste and infectious biological incenerator waste.

Definitions
Central Accumulation Area
Area(s) designated by the Safety Office to be used for the storage of hazardous wastes prior to shipment to permitted disposal facilities.a

Disposal
The discharge, deposit, injection, dumping, spilling, or placing of any solid waste or hazardous waste (whether containerized or un-containerized) into or on any land or water so that such solid waste or any constituent thereof may enter the environment or be emitted into the air or discharged into any water, including ground waters.

Generator
Any person, by site, who produces municipal hazardous waste or industrial solid waste. Any person who possesses municipal hazardous waste or industrial solid waste to be shipped to any other person; or any person whose act first causes solid waste to become subject to regulation.

Hazardous Waste
Any solid waste material listed or identified in Title 40 Code of Federal Regulations, Part 261, Subpart C or D or exhibiting the characteristics of ignitability, corrosivity, reactivity, or E.P. toxicity also defined in Part 261. Tables containing the listing and characteristics of hazardous wastes are shown at the end of this policy.

Mixed Waste
A radioactive waste that is also a hazardous waste.

Satellite Accumulation Area
An area, system, or structure for temporary accumulation of hazardous waste prior to transport to the central accumulation area.

Solid Waste
Any garbage, refuse, sludge from a waste treatment plant, water treatment plant, or air pollution control facility or other discarded material. Solid waste can be solid, liquid, semi-solid, or contained gaseous material resulting from industrial, municipal, commercial, mining and agricultural operations, and from community and institutional activities.

Waste
Any useless and valueless material that is to be discarded.

Types of Hazardous Waste
An item is considered waste when the owner determines that the material is no longer useful and needs to be discarded.
Mixture contains a listed hazardous waste and a non-hazardous waste.

Material meets the definition of one of the following:
Ignitability (flashpoint < 60' C or supports combustion)
Reactivity (e.g., water reactives, cyanides, explosives, unstable chemicals)
Corrosivity (ph < 4 or >10) EP
Toxicity (e.g., pesticides, heavy metals, poisons)

Material is not excluded from regulations.

Pure chemical contains only one source of hazardous waste

Individual departments are responsible for properly identifying the hazardous waste they generate and for following University disposal procedures.

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Chemical Waste Disposal (Containers, Tags, and Collection)
Proper containment, tagging, collection and disposal are essential to the success of the Hazardous Waste Program.

Filling Containers
Hazardous waste collection containers must be in good condition, must not leak, and must be compatible with their hazardous contents (e.g., do not use metal containers for corrosive waste or plastic containers for organic solvents).  All containers must have suitable screw caps or other secure mans for closure.  When large waste containers (greater than 10 gallons total volume) are warranted, contact the Safety Office for assistance.

If you are reusing a container to accumulate waste, destroy the original product label. EPA regulations require that waste containers be labeled with the accumulation start date, the identity of the contents, and the words "Hazardous Waste". Use a new label to identify the hazardous waste, do not use the disposal tag for this purpose.

Never overfill hazardous waste containers. Expansion and excess weight can lead to spills, explosion, and extensive environmental exposure.

Hazardous waste containers for liquids are generally rated by volume capacity. Allow extra room in liquid containers to allow for contents expansion.

Do not fill jugs and bottles past the shoulder of the container. The shoulder of the container is the place where the container slopes in towards the neck.

Fill closed head cans (5 gallons or less) to leave approximately two inches of space between the liquid level and the top of the container.

Fill closed head drums (larger than 5 gallons) to leave approximately four inches of space.

Hazardous waste containers for solids are generally rated by their weight capacity and volume capacity.

Take care not to exceed the weight capacity of a solid container. Weight is generally not a problem for jars and open head cans (5 gallons or less), but it can be a problem for open head drums (larger than 5 gallons). Depending on weight requirements, you may fill containers for solids within two inches of the closure.

Keep all waste collection containers closed except when adding or removing material.

Completing Tags
When a container is ready for disposal, complete a waste tag (available from the Safety Office) and attach it to the container. A waste disposal tag must be attached to each waste container before disposal.

Follow these guidelines for completing hazardous waste tags:

Completely fill out all sections of the tag. (This information is essential for record    keeping.)

Each chemical must be designated a chronologically assigned number by the department disposing of the chemical. Chemistry department will begin all number designations with the letter C; Biology with B; Nutrition and Food Science with N; and Fashion and Textile with F. All other departments must contact the Safety Office for requirements.

The "NAME OF ORIGINATOR" is the person in charge of the lab.

Use full chemical names or common names. Chemical formulas or abbreviations are not acceptable.

List the weight and/or total volume of the container and not just the amount in the container i.e. 4 liter container with 2 liter full is noted as 4 liter on tag.

List all chemical components in the waste container, including water. Long lists may be continued on the back of the tag. Organic Waste/Metal Waste/Solid Waste and ecetera must indicate what types of chemical componets are included in the container.

Indicate the percent concentration of potentially explosive materials such as picric acid and nitro compounds.

Place additional hazard information in REMARKS.

Attach the tag to a string which encircles the container.

After completing the tag, attach the the tag to the container.

Collection and Disposal
A typed list of chemicals, including the designation number will be given to the Safety Office at the time of the departmental disposal.

After receiving a properly completed waste disposal tag and waste, the Safety Office will coordinate the disposal of the hazardous waste.

Containers with improper caps, leaks, outside contamination, or improper labeling will not be accepted.

• Improper disposal methods for hazardous chemical waste include the following:
  Disposal down the drain.
  Intentional evaporation in a fume hood.
  Disposal in the regular trash.

Disposing of Empty Containers
EPA regulations stipulate that empty containers must meet the following requirements:
Containers must not contain free liquid or solid residue.
Containers must be triple rinsed.
Product labels must be defaced or removed.
Container lids or caps must be removed.

Punch holes in the bottom of metal containers and plastic jugs before disposing of them in the regular trash. It is not necessary to break empty glass containers.

Minimization and Substitution
The cost of commercial waste disposal continues to rise and the amount of waste generated can increase. TWU cannot control disposal costs, but it can reduce the amount of waste generated. The following sections discuss how to minimize waste sources and waste products.

Waste Source Reduction Techniques

Purchasing and Inventory Control
Use computerized tracking systems to manage purchasing and control inventory.

Maintain current inventory records to prevent overstocking and to monitor the shelf life of remaining chemicals.

Develop a campus-wide chemical exchange network to promote chemical sharing and avoid redundant purchases.

Negotiate with suppliers to gain volume discounts, flexible delivery schedules, and delivery of fewer small-sized containers without cost penalties.

Purchase quantities for immediate use only. Do not order quantities to obtain a special unit cost savings.

Obtain compressed gases from vendors who accept return of empty or partially full cylinders.

Include waste generation as a criteria in equipment selection.

Rotate chemical stocks to use chemicals before their shelf-life expires.

Chemical Usage
Use lab procedures that assure the integrity of chemical quality.

Reduce spills and waste by pre-weighing chemicals for undergraduate use.

Require proper labeling of all secondary containers. Replace all deteriorating labels on primary and secondary containers.

Substitute less hazardous chemicals whenever possible (e.g., biodegradable scintillation cocktails instead of xylene or toluene-based cocktails).

Minimize the use of  heavy metals (e.g., silver, chromium, mercury, barium, cadmium, and lead).

Substitute alcohol or electronic thermal monitors for mercury thermometers.

Use "No-Chromix", detergents, or enzymatic cleaners to clean laboratory glassware. Minimize solvent waste by recycling or substitution.

Waste Minimization Techniques
Follow these techniques to reduce hazardous waste:

• Review waste streams and recommend waste minimization procedures. Do not mix different types of waste.
• Do not put non-hazardous waste, such as a mixture of water, sodium bicarbonate, and acetic acid, into a waste container of hazardous waste.
• Do not combine inorganic heavy metal waste with organic solvents waste.
• Segregate halogenated waste solvents from non-halogenated waste solvents
• Segregate waste streams by storing them in separate waste containers.
• Store waste containers separate from reagent containers being used to avoid accidental contamination. Decontaminate empty containers to make them non-hazardous.
• Neutralize dilute acids and bases to make them non-hazardous and suitable for drain disposal.
• When possible, redesign experimental protocols so that harmful byproducts are detoxified or reduced.
• Recycle chemicals via purification.
• Make lab employees accountable for waste when labs are decommissioned.

Segregation
Segregated waste is safer and easier to dispose of than nonsegregated waste.

Each employee who generates waste is personally responsible for the following:

Ensuring that hazardous wastes are accumulated in safe, transportable containers.
Ensuring that hazardous wastes are stored properly to prevent possible exposure.

In addition to the guidelines for waste minimization and substitution, follow these guidelines for waste segregation:

• Segregate waste into the following groups:
  Halogenated solvents
  Non-halogenated solvents
  Acids Bases
  Heavy metals
  Poisons Reactives

Do not mix non-hazardous waste, such as water, with hazardous waste.

Do not combine inorganic heavy metal waste with organic solvent waste in hazardous waste containers.

Double-bag dry materials contaminated with chemicals (paper, rags, towels, gloves, or kim wipes, etc.) in heavy-duty plastic bags. Do not use biohazard bags. Dispose of these items in the same manner as hazardous waste. Encapsulate and autoclave sharps (e.g., needles, razor blades, etc.) then place them in trash.

Infectious (BIOHAZARD)Waste Incinerator Disposal (Containers, Label, and Disposal)
Proper containment, tagging, collection and disposal are essential to the success of the Infectious (BIOHAZARD)Waste Incinerator Disposal.

Containment
Bloodborne pathogens, also known as infectious, waste collection containers must be in good condition, must not leak, and must be compatible with their hazardous contents (e.g., do not dispose of any chemical or radiation waste through this method).  Proper Protective Equipment that is provided shall be used.

All hard plastic bloodborne pathogens containers must have suitable screw caps or other secure means for closure.  All plastic red bag bloodborne Pathogens containers must be tied up or use some other secure means for closure. 

Biohazard waste containers for disposal are generally rated by their weight capacity.

Keep all waste collection containers closed except when adding or removing material.

BIOHAZARD Labels
EPA and state regulations require that waste containers that are not BIOHAZARD bags also known as red bags be labeled with the the words "BIOHAZARD". Use a label to identify the hazardous waste not secured in a red bag. Contact Safety Office for labels.

When a container tha is not clarly identified as a BIOHAZARD container or a "red bag" is ready for disposal, attach the BIOHAZARD label to the disposal container (available from the Safety Office.) A waste BIOHAZARD label must be attached to each waste container before disposal.

Collection and Disposal
The Biology Department, Dental Hygiene, Student Health Services, Kinesiology Department, Housing, and Institute for Womens Health are identified as most likely to dispose of some type of BIOHAZARD waste. All biological waste genetated from these areas shall be incinerated.

Transporting of Infectious (BIOHAZARD)Waste Containers
TWU guidelines stipulate that containers must meet the following requirements:
Red bag containers must be placed in a black bag and be secured for pick-up and transportion to the on campus incinerator located at the Facilities Management Building.

The Safety Office coordinates the transportation of the hazard BIOHAZARD waste with the Kinesiology, Housing, Institute for Women's Health and the Dallas Camps departments.The Facilities Managment department routinely transports BIOHAZARD waste from Dental Hygiene and Student Health Services. Biology department transports its own BIOHAZARD waste.

A BIOHAZARD label must be attached to the black bag in preparation for transporting.

Hard plastic containers must be labeled with the BIOHAZARD label if not clearly identified as BIOHAZARD waste.

All transported BIOHAZARD waste containers must be delivered to the on campus incinerator using a state vehicle. Personnel are not allowe to use their personal vehicle to transport BIOHAZARD waste.

Disposing of BIOHAZARD Waste Containers
The Animal Care Attendant has been identified to use incinerator to dispose of BIOHAZARD containers. The attendant shall notify the Safety Office when the ash waste containers are full. Ash waste shall be disposed of in the the local landfield as a non-hazardous waste.

Recordkeeping of BIOHAZARD Incinerator Waste
The Safety Office shall note on the standard Incinerator Recordkeeping Form how many and what type containers were transported from the Kinesiology, Housing, Institute for Women's Health and the Dallas Camps departments to the incinerator.

The Facilities Managment department transporter shall record containers from Dental Hygiene and Student Health Services as needed.

Biology department shall record it's own BIOHAZARD waste and deliver forms to Safety Office when form is filled. Forms are maintained and filed in the Safety Office.

Special Concerns
Employees who generate hazardous waste must maintain and control their hazardous waste accumulation areas. Special concerns for hazardous waste include the following:

Unneeded chemicals that are to be discarded must be handled and managed as hazardous waste.

*Unknown chemical waste will be picked up by Safety Office. Departments will be charged for the chemical analysis to determine proper disposal method.

Gas cylinders are extremely difficult to discard. They should be returned to the manufacturer or distributor.

Photographic chemicals containing silver may not be placed in the sanitary sewer.

Some developing equipment has a filter to capture silver before the photographic effluent enters the drain. Please notify the Safety Office if you have this type of equipment.