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.
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
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
- Understand and follow proper hazardous waste labeling and storage requirements
- Avoid any drain disposal
- Comply with JSNN hazardous waste labeling and disposal form requirements and prepare waste for monthly pick up schedules
- Report spill and any other safety concerns to ROEHS
- Follow waste minimization practices
- Provides annual hazardous waste training
- Performs routine lab and waste storage facility inspections
- Develops and maintains JSNN hazardous waste management plan
- Manages hazardous waste pickup, waste storage facility, and third-party disposal
- Develops and maintains the emergency response and compliance plan for the waste storage facility
- Ensures EPA compliance and reporting requirements
- Maintains the EPA small waste generator license
- Communicates with third-party for bi-annual waste shipment
- Ensures proper waste management for non-JSNN waste generators
- Maintains JSNN-generated waste records, manifest and other regulatory documents
V. Third-party waste disposal contractor
- Removes all hazardous waste on a scheduled semi-annual schedule
- Ensures compliant bulking, packaging, labeling, documenting, and offsite shipping of the hazardous waste
- 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.
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
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.
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
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
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.
JSNN ROEHS will perform at least one scheduled and one unannounced follow-up waste inspection annually. Labs are encouraged to perform self annual inspections as well. See the JSNN waste inspection form for items reviewed during the ROEHS visit. Highlights of the waste inspection include:
- Waste is accumulated in the room where generated
- Waste containers are suitable for the contents (compatibility)
- There is no visible residue on waste containers
- All containers are affixed with the JSNN-ROEHS provided hazardous waste labels, displaying all required information
- Waste containers are properly closed
- 10% head space allowed for expansion
- Waste containers are stored properly in designated storage cabinets, or in satellite accumulation areas, once ready for disposal.
- Waste form and labels are properly utilized with accurate information
6. Hazardous waste reduction and best management practices
JSNN is committed to a policy for hazardous waste management that places a high priority on waste minimization and environment pollution prevention In accord with the EPA guidelines through:
- Guiding researchers in substitution of the hazardous chemicals with more environmentally friendly alternatives
- Reducing purchase and storage volumes
- Utilizing good practices in maintaining chemical containers closed and using secondary containment for potential spill
- Reuse and recycling material
- Utilizing processes and practices requiring lower chemical volume/ concentration and generating less hazardous waste
- Training and audit to ensure effectiveness of the waste management program
- Using satellite accumulation area for proper collection, labeling, and disposal
- Routine waste pickup schedules to prevent waste accumulation in research labs
- Distributing hazardous waste labels and waste disposal forms for a unified hazard identification method
All JSNN research faculty, staff, interns, and partners are required to fulfill the annual hazardous waste training, presented by ROEHS. Lab/equipment access will not be granted until training requirements are satisfied.
8. Waste Storage Facility
Collected waste from the laboratories is stored at the JSNN waste storage room until it is processed and transported off-site by a licensed third-party for final disposal. The third-party waste pickup is scheduled twice a year. GATEWAY is the EPA small waste generator permit holder and arranges for the bi-annual waste pick up and other regulatory compliance requirements for waste removal. JSNN-ROEHS will inspect the waste storage room on a monthly basis, making sure that hazardous waste is safely stored with no sign of spills, pressurization, or reactions. The monthly inspection checklist will be kept inside the waste storage room.
9. Unknown Materials
Researchers are required to ensure proper identification of all chemicals throughout their storage and use cycle. PIs must follow the student off-boarding process and make sure that all chemicals/samples are identified, labeled, and discarded before the researcher’s departure. Disposal cost for unknown material is substantially higher than identified material. Unknown materials must be labeled “Hazardous Waste-Unknown”
10. Spill Minimization and Cleanup
Use secondary containments to contain any spill from hazardous waste. Maintaining certifications may range from annual to up to three years. For each process in the lab safety plan, PIs must include a section for emergency and spill clean up procedures and address spill prevention, containment, and control plans specific to their labs and communicate this information to all employees, students, and interns. Laboratory chemical inventory must be maintained and updated, as chemicals are removed and discarded.
For any life threatening chemical spill emergency, call 911. For all other contained spills, call ROEHS at 336-285-2878 (during normal working hours) or 919-357-1134 (after hours). Do not attempt any spill clean up before consulting ROEHS. Report any spill to your supervisor, leave the area, and make sure that area is posted with a visible “Do Not Enter, Hazardous Chemical Spill” sign until the area is cleared by ROEHS.
In case of chemical exposure to eye or skin, use emergency eyewash (eye exposure) and safety shower (skin exposure) and seek medical assistance by calling 911.