Hazardous Waste Management Plan

1. GENERAL

The JSNN Hazardous Waste Management Plan (HWMP) is intended to assist PIs and researchers to comply with the provisions of the “Resource Conservation and Recovery Act (RCRA)” and the “Hazardous Waste Generator Improvement Rule (40 CFR 260 – 265)” requirement. State and federal regulatory agencies require specific labeling, storage, and disposal requirements for the hazardous waste, unused/abandoned, and expired chemicals to which JSNN must adhere for both safety and compliance purposes. JSNN does not allow any drain disposal of hazardous materials.

2. Definition

a. ACUTE HAZARDOUS WASTE means Hazardous Waste that is one of the acutely hazardous commercial chemical products listed in § 261.33(e) for reactivity and toxicity.

b. HAZARDOUS WASTE means any chemical, mixtures of chemicals, products of experiments or other materials from a laboratory that is expired or otherwise no longer needed, wanted, or usable and that is destined for hazardous waste determination by a trained professional. Hazardous Wastes include reactive, acutely hazardous wastes, and materials that may eventually be determined not to be solid waste pursuant to 40 CFR 261.2, or a hazardous waste pursuant to 40 CFR 261.3.

3. Roles and responsibilities

     I. PIs

     1.  Must assume the primary responsibility for ensuring that all JSNN hazardous waste program requirements are met

      2. Need to ensure that all researchers complete their annual hazardous waste training and follow the waste storage and disposal requirements

      3. Must report any concerns or deficiencies to JSNN Research Operations and Environmental Health and Safety (ROEHS)

     4. Need to educate researchers and students on proper waste disposal and prevent any drain disposal

     5. Need to develop and follow procedures for reducing hazardous waste generation during their research activities

   II. Researchers

1. Understand and follow proper hazardous waste labeling and storage requirements
2. Avoid any drain disposal
3. Comply with JSNN hazardous waste labeling and disposal form requirements and prepare waste for monthly pick up schedules
4. Report spill and any other safety concerns to ROEHS
5. Follow waste minimization practices

 III. ROEHS

1. Provides annual hazardous waste training
2. Performs routine lab and waste storage facility inspections
3. Develops and maintains JSNN hazardous waste management plan
4. Manages hazardous waste pickup, waste storage facility, and third-party disposal
5. Develops and maintains the emergency response and compliance plan for the waste storage facility
6. Ensures EPA compliance and reporting requirements

IV. Gateway

1. Maintains the EPA small waste generator license
2. Communicates with third-party for bi-annual waste shipment
3. Ensures proper waste management for non-JSNN waste generators
4. Maintains JSNN-generated waste records, manifest and other regulatory documents

  V. Third-party waste disposal contractor

1. Removes all hazardous waste on a scheduled semi-annual schedule
2. Ensures compliant bulking, packaging, labeling, documenting, and offsite shipping of the hazardous waste
3. Reports any discrepancies to JSNN ROEHS

4. Hazardous waste collection, storage, labeling, and disposal requirements

 I. Chemical waste

Chemical waste includes any chemical, mixtures of chemicals, products of experiments or other material from a laboratory that is no longer needed, wanted, usable, or expired. The JSNN hazardous waste program requires specific labeling, storage, and disposal procedures that need to be followed.  To avoid any unintended exothermic chemical reactions, waste bottle overpressurization, and toxic chemical by-product generation, chemical waste shall not be mixed together. Drain disposal is against EPA regulations and shall be avoided.

A. Collection

To avoid any unintended exothermic chemical reactions, waste bottle over pressurization, and toxic chemical by-product generation, chemical waste of different nature shall not be mixed together. Drain disposal is against EPA regulations and shall be avoided. All chemical waste containers must be

• Collected in compatible containers
• Kept closed with a proper sealed cap
• Placed in a secondary containment
• Processes generating waste on a continuous basis (e.g. gas chromatography) must be collected via tubes that are fed through the cap without allowing chemical evaporation

B. Labeling

All chemical waste containers must be posted with ROEHS-provided waste labels at the beginning of the waste accumulation. Waste labels must indicate:

• The word “hazardous Waste”
• Bottle #
• Chemical name(s) (no acronyms or formula)
• Hazard category (e.g. flammable)
• Accumulation start date
• PI name
• Room number.

C. Storage

Chemical waste storage requirements include:

• Waste must be stored inside the room where it is generated
• Containers must be kept closed (except when adding material). Use vented caps if there is a potential for waste bottle pressurization
• Waste bottles must be stored in proper storage cabinets until ready for disposal
• Chemical waste bottles can be kept inside the fume hoods while waste is being accumulated. Do not overload or use the fume hood as a waste storage
• All chemical waste containers must be placed in a secondary containment
• Funnel must be removed and bottle closed when not in use, or use a sealed attached funnel with a locked latch. Parafilm, rubber stoppers, or corks are not acceptable
• Over accumulation of the waste must be avoided and waste shall not be stored for more than 6-months
• Waste must be stored in a clean container with no visible residue outside. To avoid chemical reactions, keep the original containers for collecting and discarding the same material, once it becomes waste
• See the “Hazardous Waste Satellite accumulation Poster”
• If more than 1 Kg (2.2 lbs) of acute hazardous waste chemicals (EPA p list), it must be removed within 3 calendar days of the date that the 1 Kg was exceeded

D. Disposal

For proper waste disposal:

• Do not overfill. Keep at least 10% space for expansion
• List all chemical containers on the waste disposal form. Make sure the bottle number on the container matches the number on the form
• Once ready for disposal, place form and waste bottle inside the satellite accumulation containers
• Drain disposal of any chemicals, including media, is not allowed
• No more than 55-gallons of waste is allowed in a satellite accumulation area
• If more than 1 Kg (2.2 lbs) of acute hazardous waste chemicals (EPA p list), it must be removed within 3 calendar days of the date that the 1 quart/1 Kg was exceeded
• Waste will be picked up on the first Wednesday of each month from 10:00 – 11:30 a.m.

E. Empty chemical container disposal

            To discard empty chemical containers, researchers must:

• Collect all contents/residue in a compatible container and discard it as hazardous waste
• Remove or deface the label (chemical name and hazard pictograms)
• Remove the cap
• Store in a lined cardboard box
• Avoid overfilling and making boxes too heavy to lift
• Carry on a cart and discard in regular outdoor dumpster
• For highly toxic chemical containers (EPA P-list), the empty container needs to be discarded as hazardous waste. Otherwise, the container needs to be first triple rinsed before disposal. Rinsate must be collected and discarded as hazardous waste.

II. Biological waste

A. General

Biological waste includes any biological material generated from research activities during manipulation or clean- up, regardless of its potential to infect humans, plants or animals that is/are no longer useful. Biological waste must be collected and disposed of properly. Avoid any drain disposal (liquid) or mixing with regular trash (solid). Examples of the biological waste include:

• Materials contaminated or potentially contaminated during the manipulation or clean-up with Biosafety Level 1, 2, 3, or 4 material, animal or plant Biosafety Level 1, 2, or 3, or liquid human blood and body fluids
• Materials contaminated with human/primate tissue or human/primate tissue cultures (primary and established) because these are handled at BSL-2
• Animal blood, fluids and bedding from animals infected with agents requiring BSL-2 and BSL-3 container
• Transgenic materials or animals
• Biological sharps (e.g., needles, scalpels)

B. Proper collection and labeling

Biological waste shall be collected in red, hard-walled biohazard waste collection containers with maximum 15-gallon capacity. Waste containers must be lined with a clear autoclavable bag.

• Use only clear biohazard bags for autoclaving. The red/orange biohazard bags are not allowed.
• Biological waste containers must have a lid which remains closed when not in use. Both lid (if removable) and container must bear the biohazard symbol with the word “Biohazard.”
• All biological waste containers including biohazard sharps shall only be filled 2/3.
• Liquid biological waste such as spent culture media should never be allowed to sit for longer than 24 hours.

 C. Biological Waste Disposal

Biological solid waste, liquid waste, and sharps each have specific requirements for collecting, labeling, storage, autoclaving, and disposal. See the Biological waste Disposal Chart for biological solids, liquids, sharps, and animal/plant disposal requirements.