XI (a).

WASTE DISPOSAL -- CHEMICAL WASTE

___________________________________________________________________
A. WHAT IS HAZARDOUS CHEMICAL WASTE?
In order to determine proper handling procedures and disposal, a decision must be made
regarding whether the chemical waste is hazardous. Federal (EPA 40 CFR 261) and Massachusetts
(DEP 310 CMR 30.100) regulations define various categories of hazardous chemical waste.
Additionally, the college holds a pretreatment permit from the Town of South Hadley that regulates
discharge to the sewer system. A summary of waste typically generated in academic laboratories is
included in Appendix A. Regulatory lists for the following waste categories are available at the DEP
website referenced below.

hazardous chemicals (specific list of chemicals) - U wastes

acutely hazardous chemicals - P wastes
solvent waste - F wastes
characteristic wastes - D wastes
ignitable
corrosive
reactive
toxic (includes metals, pesticides, and various organics)
waste oil and PCBs - M wastes

Faculty are responsible for determining whether laboratory waste generated is a hazardous
waste. The Laboratory Hazardous Waste Determination checklist found in Appendix B can be
used to evaluate laboratory waste. Departments will keep the checklist or other documentation for
teaching laboratories, faculty will keep documentation for their research laboratories. Faculty will
review the determination when changes in the laboratory experiment could change the classification
of the waste. The checklist does not apply to evaluation of unused chemicals, or spill clean-up
materials. The Chemical Hygiene Officer can assist with evaluation of these materials, as well as
laboratory waste.
There are other chemicals that have not been defined as hazardous by EPA or the Massachusetts
DEP that should be handled using the procedure for hazardous waste. These include:
* carcinogens that have not been deactivated (see Section V(i) Select
Carcinogens),
* reproductive toxins, e.g., ethidium bromide, that have not been deactivated (see
Section V(j) Reproductive Toxins), and
* acute toxins (see Section V(h)).
Faculty or staff may designate other chemical wastes to be handled as hazardous based on their
knowledge of the hazards of the waste.

XI(a) - 1

XI (a). WASTE DISPOSAL -- CHEMICAL WASTE

______________________________________________________________________________

DEP, 310 CMR 30.100 Identification and Listing of Hazardous Waste at

http://www.mass.gov/dep/service/regulations/310cmr30.pdf

B. DISPOSAL OF NON-HAZARDOUS CHEMICAL WASTE

Once a waste determination concludes that waste is not a hazardous waste, it may be
disposed of as a non-hazardous waste. Liquid wastes that are non-hazardous and water-soluble may
be flushed to the sewer with copious amounts of water. Liquids, which are not water-soluble, must
be solidified (absorbed) and disposed of as a solid. Non-hazardous solid waste must be labeled
"non-hazardous" and can then be put in the laboratory trash.

C. HAZARDOUS WASTE COLLECTION AND LAB ACCUMULATION

All hazardous waste must be collected for disposal by an EPA approved method at a
licensed facility. Hazardous waste should be collected in each laboratory in screw top containers,
which are compatible with the waste. Each container should be labeled with a red and white
"Hazardous Waste" label at the time waste is first put into the container. The label must contain:

waste components; each chemical present must be identified (no chemical formulas,
structures or abbreviations may be used)
hazards (e.g., flammable, oxidizer, corrosive, toxic, reactive)

Additional space on the label may be used to list a generic waste name such as chlorinated
solvents. The "Date Full or Moved to Storage" should be completed when the container is full or,
if not full but the waste is no longer being generated, when it is moved to storage. Indelible markers
should be used for labeling and abbreviations cannot be used. Containers must be closed except
when waste is being added. A poster describing laboratory waste collection requirements is included
in Appendix C.
To minimize the hazard of incompatible chemical reactions, wastes should not be mixed in
the laboratory. It is also important to separate chlorinated from non-chlorinated solvents whenever
possible, as non-chlorinated solvents can be processed for reuse and chlorinated solvents must be
incinerated.
Waste containers must be kept near the point of generation and all liquid waste must be in
secondary containment. The secondary containment must provide for separation of wastes which
are incompatible. The amount of waste accumulated in the laboratory at any time should be
minimized. Only one bottle of a particular type of waste is allowed in the laboratory.

XI(a) - 2

XI (a). WASTE DISPOSAL -- CHEMICAL WASTE

______________________________________________________________________________

D. LABORATORY WASTE REMOVAL

When a waste container is full or the waste will no longer be generated in the laboratory, the
waste must be moved to the storage area within 3 days. Check the containers to make sure they are
properly closed and that the labels are complete and legible.
Request a pick-up immediately upon filling a container, or ahead of time if you anticipate
filling a container in the next day or two. For waste pick-up, the Chemistry Department should
contact the Director of Chemical Laboratories, all other departments should contact the Chemical
Hygiene Officer.

E. WASTE STORAGE AND DISPOSAL

Upon receipt at the waste storage room all waste is separated and stored by hazard category.
To minimize the potential for releases all waste containers are placed in trays or other secondary
containers.
Wastes are shipped off-site using a licensed hazardous waste transporter. All hazardous
waste is taken to licensed facilities who treat, recycle, incinerate, or otherwise dispose of the
materials using EPA approved methods for the particular waste type.

F. DISPOSAL OF EMPTY CONTAINERS AND SHARP WASTE

The hazardous waste regulations define an empty container as a container from which all
hazardous chemical which can be poured has been removed and no more than one inch of chemical
remains.
Most empty containers can be safely and legally disposed of as laboratory trash with the
exception of "Acutely Hazardous Waste" containers. Empty containers which contained P listed,
acutely hazardous, chemicals should be handled as hazardous waste (Appendix XI(a)-C). As an
alternate, these containers can be triple rinsed with an appropriate solvent, with the solvent disposed
of as hazardous waste, the label defaced, and the container discarded in the laboratory trash.
Empty containers should be placed next to (not mixed in with) laboratory trash. Broken
glass and other sharp waste, except needles should be placed in cardboard containers designated for
that purpose. The custodians will discard these containers in such a manner as to avoid injury.
Needles must be collected in plastic needle boxes and sent off-site for incineration as biomedical
waste.

XI(a) - 3

XI (a). WASTE DISPOSAL -- CHEMICAL WASTE

______________________________________________________________________________

G. DISPOSAL OF UNKNOWNS
It is extremely difficult and costly to identify the content and hazards of unlabeled materials.
As discussed in Section V(c), it is crucial that maintaining labels be a standard laboratory practice.
If you do have unknowns, please contact the Chemical Hygiene Officer immediately upon their
discovery.

H. DISPOSAL OF EQUIPMENT
All hazardous materials (e.g., mercury switches, PCB capacitors, oil) must be removed
from equipment before it is discarded. The faculty member or department is responsible for
removal of these materials and management of them as hazardous waste. Electronic equipment
should be collected for recycling. Contact the Chemical Hygiene Officer for instructions.

I. WASTE INSPECTION
The Chemical Hygiene Officer inspects the waste storage area and satellite accumulation
areas in the labs weekly when waste is present. Deficiencies that could result in a release of
waste are corrected immediately, other deficiencies are referred to the responsible faculty
member for correction. The Chemical Hygiene Officer then confirms that the correction has been
completed.

J. WORKING CONTAINERS
DEP Working Container provisions allow more than one container of a particular waste in
the laboratory for immediate use at the bench top. The Working Container must be:

emptied into the satellite container in the laboratory at the end of each laboratory period or
day, or when full whichever comes first
closed except during active use
located on an impervious surface and managed to prevent spills
labeled as hazardous waste with words describing the hazard
located at or near the point of generation
under the control of faculty of staff responsible for the laboratory

XI(a) - 4

XI (a). WASTE DISPOSAL -- CHEMICAL WASTE

______________________________________________________________________________

APPENDIX XI (a) - A

HAZARDOUS WASTE IDENTIFICATION

XI(a) - 5

XI (a). WASTE DISPOSAL -- CHEMICAL WASTE

______________________________________________________________________________

HAZARDOUS WASTE IDENTIFICATION

The following is a summary of the typical wastes generated in laboratories. References cited
are to the subsequent sections of this Appendix. The following categories are the regulatory
definition of hazardous waste, there may well be other materials which do not meet the regulatory
definition that you determine should be handled as hazardous waste because of their toxicity. For a
more detailed description of waste definitions refer to:
http://www.mass.gov/dep/service/regulations/310cmr30.pdf
Definition of Waste
To be a hazardous waste the material must first meet the definition of a waste: a waste is any
material that is no longer useful and is therefore destined for disposal (or storage or treatment in lieu
of disposal). Once a material becomes a waste it must be properly classified, labeled and stored.
Typically, the end products of an experiment are a waste unless they are going to be used in a future
experiment.
Unused Chemicals
Unused laboratory chemicals that are of questionable quality and can no longer be used are
hazardous waste if they are listed on the "U" list) or "P" list (see web site referenced in section A),
or if they meet the definition of a characteristic waste as described below.
Solvents
The following solvents are specifically listed as "F" waste (see web site referenced in
section A). This not only applies to pure solvents but to any mixtures containing the solvents where
the total quantity of listed solvents was greater than 10% by volume before use. Materials
contaminated with these solvents (e.g., rags, drying agents) are included.
tetrachloroethylene
trichloroethylene
chlorobenzene
1,1,2-trichloro-1,2,2-trifluoroethane
1,1,2-trichloroethane

methylene chloride
1,1,1-trichloroethane
ortho-dichlorobenzene
trichlorofluoromethane

XI (a). WASTE DISPOSAL -- CHEMICAL WASTE

______________________________________________________________________________
xylene
ethyl acetate
ethyl ether
n-butyl alcohol
methanol
cresylic acid
toluene
carbon disulfide
pyridine
2-ethoxyethanol

acetone
ethyl benzene
methyl isobutyl ketone
cyclohexanone
cresols
nitrobenzene
methyl ethyl ketone
isobutanol
benzene
2-nitropropane

Characteristic Waste
When a waste is not specifically listed, it must be evaluated to determine if it meets the
definitions for ignitable, corrosive, reactive, or toxic waste (see web site referenced in section A).
Characteristic wastes cannot be intentionally diluted to make them nonhazardous.
Ignitable Waste
1. Liquids with flash points of less than 60oC (approx. 140oF) with the exception of aqueous
solutions of ethyl alcohol which contain less than 24 percent alcohol by volume.
2. Flammable solids.
3. Ignitable compressed gases.
4. Oxidizers.
Corrosive Waste
1. Liquids with a pH less than or equal to 2 or greater than or equal to 12.5.
2. Corrodes steel as specified rate.
Reactive
1. Normally unstable and undergoes violent changes.
2. Reacts violently, forms potentially explosive mixtures, or generated toxic fumes when mixed
with water.
3. Cyanide or sulfide bearing wastes.
4. Explosives.

XI (a). WASTE DISPOSAL -- CHEMICAL WASTE

______________________________________________________________________________

Toxic
Toxic chemicals are defined based on the concentration of certain contaminants in solutions,
or, for solids, the concentration in the extract when subject to a TCLP (Toxicity Characteristic
Leaching Procedure). Specific concentration limits are listed in the web site referenced in section A.
You should use your knowledge of the waste to determine if it may exceed the listed limits. The
chemicals for which there are limits are:
arsenic
cadmium
copper (town sewer discharge restriction)
lead
selenium

barium
chromium
mercury
silver

benzene
chlorobenzene
o-cresol
p-cresol
1,4-dichlorobenzene
1,1-dichloroethylene
hexachlorobutadiene
hexachlorobenzene
nitrobenzene
tetrachloroethylene
vinyl chloride

carbon tetrachloride
chloroform
m-cresol
cresol
1,2-dichloroethane
2,4-dinitrotoluene
hexachloroethane
methyl ethyl ketone
pyridine
trichloroethylene

chlordane
endrin
lindane
pentachlorophenol
2,4,5-trichlorophenol
2,4,5-TP (Silvex)

2,4-D
heptachlor
methoxychlor
toxaphene
2,4,6-trichlorophenol

Oil and PCBs

In Massachusetts, waste oil, including oil/water mixtures, and PCBs, concentrations greater
than or equal to 50 ppm, are hazardous waste, "M" wastes (see web site referenced in section A).

XI (a). WASTE DISPOSAL -- CHEMICAL WASTE

______________________________________________________________________________

Spill Clean-Up Debris

Clean-up debris from a spill of any "U", "P", "F" or "M" waste is a hazardous waste. Debris
from a clean-up of characteristic waste is a hazardous waste if it still meets the definitions for
ignitable, corrosive, reactive or toxic wastes.
Empty Containers
The regulations define an empty container as a container from which all material has been
removed using common practices (e.g., pouring) and contains no more than one inch of residue in
the bottom. If the material is on the "P" list of acutely hazardous waste the container must also be
triple rinsed. Containers meeting this "empty" definition are not hazardous waste and can be
discarded in the trash.
Particular precautions should be taken in disposing of empty ether cans. Once empty, the
can should be allowed to evaporate in a hood overnight, it should then be rinsed several times with
water and put in the trash. If is very important that empty ether cans be disposed of immediately
after use to prevent the formation of peroxides.
Treatment of Waste
In Massachusetts, a special permit is required to treat hazardous waste. The most common
example of laboratory treatment is neutralization of acids or bases. It is not acceptable to collect
corrosive materials, neutralize them and discharge to the sewer.
Some institutions allow neutralization as part of the experimental procedure performed by
each student as an educational activity. Their interpretation is that the material is not yet a waste.
The regulations do not address this interpretation. Treatment as part of the experiment can be
justified based on safety concerns if the material is reactive and can be deactivated.
Universal Waste
Universal Waste is a special category of materials defined by the EPA that would be
hazardous waste if disposed of but are defines as Universal Waste if recycled. They include
batteries (lead acid, nickel/cadmium, silver, lithium, mercury) and mercury containing lamps (e.g.,
fluorescent light bulbs).
Other Regulated Materials
Antifreeze is a regulated waste and must be collected for shipment off-site. Latex paints,
while not hazardous waste, can not be put in the trash in liquid form. Dried paints can be put in the
regular trash. Liquid latex that can no longer be used is shipped off-site as a non-hazardous waste.

XI (a). WASTE DISPOSAL -- CHEMICAL WASTE

______________________________________________________________________________

Non-Hazardous Waste
There are other chemicals that have not been defined as hazardous by EPA or the
Massachusetts DEP that should be handled using the procedure for hazardous waste. These include:
* carcinogens that have not been deactivated (see Section V(i) Select
Carcinogens),
* reproductive toxins, e.g., ethidium bromide, that have not been deactivated (see
Section V(j) Reproductive Toxins), and
* acute toxins (see Section V(h)).
Faculty or staff may designate other chemical wastes to be handled as hazardous based on their
knowledge of the hazards of the waste.

XI (a). WASTE DISPOSAL -- CHEMICAL WASTE

______________________________________________________________________________

APPENDIX XI (a) - B

HAZARDOUS WASTE DETERMINATION

Hazardous Waste Determination

Applies to waste generated as the result of chemical use.
Does not apply to evaluation of unused chemicals, or spill clean-up materials.
(contact Nancy Apple with questions about these items).
To determine if a waste is a hazardous waste, answer the following questions. If the answer to any question is
yes, then the waste is a hazardous waste. Answer all the questions for each waste to identify all the hazards
associated with the waste and required on the label. Information on the characteristics (e.g., flash point) of
chemicals can be found on the Material Safety Data Sheet (MSDS).
Area:

Faculty/Staff:

Date:

Waste Description:
Waste Evaluation
Contains Flammable solvents (flash point < 140oF)
Exception: aqueous solutions of < 24% ethyl alcohol

Yes/No

If yes, LABEL
Flammable

Contains halogenated compounds

Is Reactive (unstable materials, reacts with water to form potentially
explosive mixtures or toxic gases, contains cyanides or sulfides,
explosives)

Toxic
Reactive

Is an Oxidizer (materials that readily yields oxygen, or accepts

electrons, to stimulate combustion)

Oxidizer

Is a Flammable Solid (capable of catching fire through friction,

adsorption of moisture or spontaneous changes)

Flammable

Has a pH < 2 or > 12.5

Corrosive

Contains any of the following metals at or above the conc. in mg/l.

Arsenic
5
Barium 100
Cadmium 1
Chromium 5
Copper 1
Lead
5
Mercury 0.2
Selenium 1
Silver 5
Contains any of the following pesticides at or above the conc. in mg/l
Chlordane 0.03
Heptachlor 0.008
Endrin 0.02
Methoxychlor 10
Lindane 0.4
Toxaphene 0.5
Pentachlorophenol 100
2,4,5-Trichlorophenol 400.0
2,4.6-Trichlorophenol 2.0
2,4,5-TP (Silvex) 1.0
2,4 D
10
Contains any of the following organics at or above the conc. in mg/l
Benzene 0.5
Carbon tetrachloride 0.5
Chlorobenzene 100
Chloroform 6
Cresol, o-, p-, m- 200
1,4-Dichlorobenzene 7.5
1,2-Dichloroethane 0.5
1,1-Dichloroethylene 0.7
2,4-Dinitrotoluene 0.13
Hexachlorobenzene 0.13
Hexachlorobutadiene 0.5
Hexachloroethane 3
Methyl ethyl ketone 200
Nitrobenzene 2
Pyridine 5
Tetrachloroethylene 0.7
Vinyl Chloride 0.2
Contains petroleum oil or polychlorinated biphenyls

Comments:

Toxic

Toxic

Toxic

Toxic

XI (a). WASTE DISPOSAL -- CHEMICAL WASTE

______________________________________________________________________________

APPENDIX XI (a) C

HAZARDOUS WASTE COLLECTION POSTER

Mount Holyoke College

Hazardous Waste Collection

1. Collect waste in a screw cap container and keep the cap on except when waste is being
added.
2. Do not mix incompatible materials and keep halogenated solvents separated whenever
possible.
3. Put on and fill in a hazardous waste label when you start collecting the waste. Add to the
label as necessary as more waste is added.
A.
A generic waste name (e.g. chlorinated solvents) -- optional
B.
Each chemical present required (no chemical formulas, structures or abbreviations)
C.
The hazard of the waste (flammable, oxidizer, corrosive, toxic, reactive) required -If the waste is not flammable (flash point <140oF), an oxidizer, corrosive (pH < 2 or >
12.5) or reactive, check toxic.
D.
When the container is full, write in the date (month, day, and year).

HAZARDOUS WASTE
A

WASTE NAME: __________________________________________

CHEMICAL CONTENT
HAZARD
______________________________

FLAMMABLE

______________________________

OXIDIZER

______________________________

CORROSIVE

______________________________

TOXIC

______________________________

REACTIVE ___________
Describe

______________________________
______________________________

Date Full or Moved

to Storage: ____________

4. Keep all waste bottles in secondary containment. The waste containment tray should only
contain waste.
5. Do not let multiple bottles of waste accumulate in the laboratory. Only one bottle of a
particular type of waste is allowed.
6. Request a pick-up when the container is nearly full, or on the same day the container is filled
and dated. Contact Lori Smith (email: lbsmith, ext. 3554) for pick-up.
7. For more information, contact Nancy Apple (email: neapple, ext. 2529).

EH&S 6/2010