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Chemical Waste Management

Guide
Revision: Summer 2016

Contents

 Introduction
 Applicability
 Responsibilities
 Classification
o Ignitable Characteristic
o Corrosive Characteristic
o Reactive Characteristic
o Toxic Characteristic
o The F List
o The U List
o The P List
 Satellite Accumulation Requirements
 Container Management and Labeling
 Training
 Disposal of Unknowns
 Chemical Spills and PPE Wastes
 Dilution and Evaporation Prohibitions
 Elementary Neutralization
 Nanoparticle Wastes
 Pollution Prevention and Waste Minimization

Appendices

 Appendix A: U Listed Chemicals

 Appendix B: P Listed Chemicals
Introduction
Personnel who use chemicals as part of their jobs follow protocols to prevent
exposure and minimize the potential for spills and incidents. Personal
Protective Equipment (PPE) such as gloves and eye protection can protect
workers from splashes and contact hazards, fume hoods can eliminate the
risk of inhaling harmful chemicals, and storage cabinets can mitigate the risk
of fires and spills.

There is another facet of chemical safety which must be managed, however,

and that is protecting the environment from chemical contamination. Improper
or careless disposal practices have significant effects on our environment,
including polluting water sources, poisoning wildlife, and creating toxic sites
which aren’t suitable for animal or human habitation. For employees who work
with chemicals (and therefore generate chemical wastes) the single most
important ‘green’ activity is conscientious, careful management of chemical
wastes.

In order to protect the environment, Federal and State governments have

created very strict regulations governing chemical waste management. The
only way to ensure such regulations are followed is to accompany them with
severe penalties
for non-compliance.

The guidance that follows is intended to provide Boston University employees

with the information they need to properly manage chemical wastes. It is up to
each user of chemicals to understand and follow the rules. Together we can
protect the environment and protect the University from costly fines and
penalties.

Applicability
Location:

It doesn’t matter where at BU you work; in a laboratory, in a mechanical room,

or anywhere else. Chemical waste rules must be applied in the same manner
across all workplaces. Most chemical wastes are generated in laboratories but
many are generated outside of laboratory settings; contaminated soils,
building materials, lubricants, paints and many other materials can fall under
these rules.

Waste Chemicals:

The information that follows in this document applies only to chemical wastes.
Chemicals that are going to be used in a process or experiment must be
managed safely; however if they are not wastes then the information that
follows does not apply. Keep in mind that just because a chemical is unused,
doesn’t necessarily mean it is not a waste. For example:

 Expired Materials: if a chemical bottle has an expiration date that has

passed, and that chemical cannot be used when it’s expired, then it is a
waste.
 Extraneous Materials: if the process or experiment for which a chemical
is used is no longer practiced, and that chemical will not be used for
another purpose, that chemical is a waste. Some examples include:
o When a researcher leaves, and leaves behind chemical bottles for
experimentation that no longer occurs, or
o Containers of oil for a piece of equipment that has been removed.

Once you’ve determined that a chemical is not useful – for any reason – then
the information in this document applies and decisions about waste
management must be made.

Volume:

It doesn’t matter how much waste you are generating: 1 ml is regulated the
same as 1 gal when it comes to chemical waste.

Responsibilities
Every person at Boston University who generates chemical waste is
responsible for the proper management of chemical wastes. These
responsibilities include:

 Complete hazardous waste training at least once every 12 months.

Employees and students in laboratories can satisfy this requirement
through Laboratory Safety Training. Employees in other departments
 must attend their scheduled training programs. New employees must
complete training within 6 months.
 Identify the chemical wastes generated in the workplace and make
decisions – with help from the Environmental Health and Safety
Department (EHS) – on proper disposal.
 Collect, label and manage all chemical wastes according to University
protocols.
 Seek help from the Environmental Health and Safety Department when
questions or issues arise relative to chemical waste management.
 Maintain good housekeeping in chemical waste accumulation areas.

Principal Investigators and Department Managers have the responsibility

of ensuring that personnel working under their supervision have attended
training and are following University protocols.

Lab Safety Coordinators are asked to ensure that weekly inspections of all

chemical waste accumulation areas are conducted, and to serve as the
liaisons between laboratories and EHS to get questions answered and
problems resolved.

Environmental Health and Safety (EHS) Department members are the

subject-matter experts in the field of chemical waste management and have
oversight of the chemical waste program. Responsibilities include:

 Provide written guidance outlining the university’s hazardous waste

procedures.
 Work with campus staff and students to resolve chemical waste issues,
provide support and answer questions.
 Provide training to chemical waste generators on campus.
 Remove chemical wastes from labs and other areas on campus where
they are generated, and manage them through to their final destination
offsite.
 Generate and maintain all disposal records as required by regulation.

Classification of Chemical Waste

The next step after identifying a chemical as a waste is to classify that waste.
Chemical wastes will ultimately fall into one of 4 management categories:
 Collected as a Hazardous Waste: A chemical which exhibits a
‘hazardous’ characteristic, is listed according to Federal or State
regulation, or best management practices dictate strict control must be
managed as a hazardous waste. Most of the information in this
document describes the rules to follow when managing hazardous
wastes.
o Hazardous wastes have the greatest potential to harm people or
the environment, and bear the full burden of environmental
regulation.
o Mis-management of hazardous wastes can result in significant
environmental penalties and enforcement actions.
o The term ‘hazardous waste’ should only be used when describing
chemicals. Infectious or radioactive wastes are not ‘hazardous
wastes’ unless they are mixed with chemical wastes.
o Hazardous wastes are generated routinely at Boston University.
o Collection and management of chemical wastes as hazardous
wastes ensures the maximum level of environmental protection
and is the safest means of chemical waste management.
 Collected as a Non-hazardous Waste: A chemical which does not
exhibit a state or federal hazardous characteristic and isn’t listed as a
‘hazardous waste’ isn’t necessarily safe for disposal via sink or in the
regular trash.
o In some cases, protection of the environment requires us to go
above and beyond the hazardous waste regulations. An example
would be ethidium bromide, which doesn’t technically exhibit a
hazardous characteristic but which isn’t safe for handling as
regular trash. Other examples include materials like nanoparticles
for which comprehensive safety information does not yet exist.
Often the
precautionary principle dictates that we collect these materials
because we do not understand the potential harm they can cause
in the environment.
o In other cases, a different regulation might stipulate collection of a
waste chemical. An example would be very small concentrations
(part-per-billion level) of mercury in otherwise benign reagents.
Local Clean Water Act enforcement prohibits mercury disposal to
sink drains even though the level of contamination is low.
o In cases where a chemical is collected as a non-hazardous waste,
some of the hazardous waste management rules do not apply.
  Collected as a Universal Waste: A small subset of chemical wastes
have been de-regulated to some extent based on the fact that they are
so widespread.
o Management regulations still exist, but they are lessened relative
to hazardous waste regulations.
o Universal wastes are most often generated and managed through
Facilities Management Department operations.
o Universal Wastes include:
 Fluorescent bulbs of all shapes and sizes
 Many types of batteries
 Mercury-containing devices such as switches and
thermostats.
o Boston University has a separate policy detailing how Universal
Wastes must be managed.
 Safe for Sink or Trash disposal: A very small percentage of chemical
wastes are un-regulated and safe to pour into sinks or place in the
trash. Some examples include benign salts like sodium chloride, and
non-toxic, non-corrosive cleaning chemicals. Contact EHS prior to
disposing any chemical into a sink or via the trash.

Hazardous Wastes
The most important question to answer when managing a chemical waste:
“does my chemical waste have to be collected and managed as a hazardous
waste?” It is necessary to know the answer to this question as this is the first
step in a process known as making a ‘waste determination’, and is a
required step in chemical waste management.

In order to determine whether a chemical waste must be collected as a

hazardous waste you must have information about the properties and
behavior of the chemical. This knowledge is fundamental to safe laboratory
operations, and literature is available in your workplace in the form of Safety
Data Sheets (SDS or MSDS) which can help. If you don’t know or are unsure
about the characteristics or properties of a chemical waste contact EHS for
assistance.

Never assume a chemical waste is safe for disposal in the regular trash or via
a sink or drain. Always err on the side of caution; collection and management
as a hazardous waste because this is the safest and most responsible way to
collect a chemical waste.
A chemical waste must be classified and managed as a hazardous waste if it
exhibits any of the four characteristics described below, or is specifically listed
in the regulations.

Ignitable Characteristic
A chemical waste is a hazardous waste due to ignitability if:

 Liquid Chemicals: the flash point of the liquid chemical is less than or

equal to 140 degrees F.
o Equivalent is 60 degrees C
o Flashpoint determination is ‘Pensky-Martens Closed Cup Tester’
o Common examples include:
 Alcohols (note: for ethanol, mixtures greater than or equal to
20% are hazardous wastes. For other alcohols the cut-off is
10%.)
 Organic Solvents and mixtures containing organic solvents
such as xylenes, hexane, toluene, acetone, etc.
 Stains and mixtures containing stains (because they are
solvent-based).
 Oil-based paints and coatings
 Solid Chemicals: the chemical is capable, under standard temperature
and pressure, of causing fire through friction, absorption of moisture or
spontaneous chemical changes, and burns vigorously when ignited
o Common examples include:
 Paraformaldehyde
 Parafin wax with xylene
 Rags saturated with an ignitable liquid
 Compressed Gas: Ignitable compressed gases must also be managed
as hazardous wastes.
o Generally this involves partially-full, or left-over cylinders of gas
o Common Examples include:
 Hydrogen
 Acetylene
 Propane
 Butane
 Oxidizers: the chemical is capable of enhancing the combustion of
other materials, generally by yielding oxygen.
o Common examples include:
 Chlorates
  Chlorites
 Nitrates
 Perchlorates
 Perchlorites
 Permanganates
 Peroxides

If your chemical waste exhibits any of the ‘ignitable’ characteristics above, you
must manage it as an ignitable hazardous waste.

Corrosive Characteristic
A chemical waste is a hazardous waste due to corrosivity if:

 It is aqueous and has a pH less than or equal to 2, or greater than or

equal to 12.5, or
 It is a liquid and corrodes steel (Type SAE 1020) at a rate greater than
6.35 mm (approximately 0.250 inch) per year.
 Common examples include:
o Hydrochloric Acid
o Sulfuric Acid
o Nitric Acid
o Sodium Hydroxide

Reactive Characteristic
A reactive hazardous waste is defined as a material which:

 Under normal conditions is unstable and can undergo violent changes

without detonating
 Reacts violently with Water
o Common Examples Include:
 Sodium metal,
 Anhydrides,
 Sodium Borohydride
 Reacts violently with Air
o Common Examples Include:
 tert-butyllithium,
 Capable of detonation or violent explosion
 o Common Examples Include:
 Dry picric acid,
 Azide compounds,
 Organic peroxides,
 Old ether or tetrahydrofuran with peroxide formation
 A cyanide or sulfide which, when exposed to a pH of between 2 and
12.5, generates toxic gases, vapors or fumes
o Common Examples Include:
 Sodium cyanide,
 Potassium cyanide,
 Sodium sulfide,
 Carbon disulfide

Toxic
The toxic ‘characteristic’ is where the regulations start to get into listing
specific chemicals. To determine whether a chemical waste exhibits the toxic
characteristic, it is necessary check the federal toxic list, known as the ‘D’ list.
The state of Massachusetts adds some chemicals to the list as well.

As a general rule, a waste that contains any material on this list should be
collected for disposal regardless of concentration; even if it’s not technically
regulated as a hazardous waste it still doesn’t belong in the environment.

The concentration listed next to the chemical names below refers to a very
specialized analytical method known as the TCLP test (the Toxic
Characteristic Leachate Procedure). The TCLP test is designed to simulate
the concentration of contaminant that would leach out of the material if it were
in a landfill under acid rain conditions. EHS can provide TCLP analysis if
necessary. However, in most cases the right thing to do is to collect wastes
with any concentration of the chemicals listed below. As always, contact EHS
if you have questions.

Chemicals on the federal toxic List

 Material TCLP Concentration (mg/l) CAS Number

Metals
 Material TCLP Concentration (mg/l) CAS Number

Arsenic 5.0 7440-38-2

Barium 100.0 7440-39-3

Cadmium 1.0 7440-43-9

Chromium 5.0 7440-47-3

Lead 5.0 7439-92-1

Mercury 0.2 7439-97-6

Selenium 1.0 7782-49-2

Silver 5.0 7440-22-4

Pesticides

Chlordane 0.03 57-74-9

Endrin 0.02 72-20-8

Heptachlor 0.008 76-44-8

Lindane 0.4 58-89-9

Methoxychlor 10.0 72-43-5

Toxaphene 0.5 8001-35-2

2,4-D 10.0 94-75-7

2,4,5 TP Silvex 1.0 93-72-1

 Material TCLP Concentration (mg/l) CAS Number

Organics

Benzene 0.5 71-43-2

Carbon Tetrachloride 0.5 56-23-5

Chlorobenzene 100.0 106-90-7

Chloroform 6.0 67-66-3

o-Cresol 200.0 95-48-7

m-Cresol 200.0 108-39-4

p-Cresol 200.0 106-44-5

Cresol 200.0

1,4-Dichlorobenzene 7.5 106-46-7

1,2-Dichloroethane 0.5 107-06-2

1,1-Dichloroethylene 0.7 75-35-4

2,4-Dinitrotoluene 0.13 121-14-2

Hexachlorobenzene 0.13 118-74-1

Hexachloro-1,3- 0.5 87-68-3

butadiene

Hexachloroethane 3.0 67-72-1

 Material TCLP Concentration (mg/l) CAS Number

Methyl ethyl ketone 200.0 78-93-3

Nitrobenzene 2.0 98-95-3

Pentachlorophenol 100.0 87-86-5

Pyridine 5.0 110-86-1

Tetrachloroethylene 0.7 127-18-4

Trichloroethylene 0.5 79-01-6

2,4,5-Trichlorophenol 400.0 95-95-4

2,4,6-Trichlorophenol 2.0 88-06-2

Vinyl Chloride 0.2 75-01-4

Chemicals on the Massachusetts toxic list:

Waste Oil Any amount (excluding animal/vegetable origin)
PCBs 50 mg/l (note: we should collect PCBs at any concentration)

Listed Hazardous Wastes

The chemical waste regulations have a series of lists which spell out some
specific chemicals which should be collected as hazardous waste.

The F List
The “F List” specifies some commonly-generated chemical wastes at specific
concentrations that must be collected. The entire list can be seen
here http://www.epa.gov/waste/hazard/wastetypes/listed.htm, but for
laboratory purposes the following chemicals are of particular importance.
 Any dioxin waste
 Any waste with any combination of the following halogenated solvents
at a concentration of 10% or more by volume before use (these wastes
are toxic):
o Tetrachloroethylene
o Methylene Chloride
o Trichloroethylene
o 1,1,1-trichloroethane
o Chlorobenzene
o 1,1,2-trichloro-1,2,2-trifluoroethane
o Orthodichlorobenzene
o 1,1,2-trichloroethane
o Carbon tetrachloride
o Any chlorinated fluorocarbons
 Any waste with any of the following non-halogenated solvents at a
concentration of 10% or more by volume (these wastes are ignitable
except as indicated below):
o Xylene
o Acetone
o Ethyl acetate
o Ethyl benzene
o Ethyl ether
o Methyl isobutyl ketone
o N-butyl alcohol
o Cyclohexanone
o Methanol
o Cresols (toxic)
o Cresylic acid (toxic)
o Nitrobenzene (toxic)
o Toluene (ignitable and toxic)
o Methyl Ethyl Ketone (ignitable and toxic)
o Carbon disulfide (ignitable and toxic)
o Isobutanol (ignitable and toxic)
o Pyridine (ignitable and toxic)
o Benzene (ignitable and toxic)
o 2-ethoxyethanol (ignitable and toxic)
o 2-nitropropane (ignitable and toxic)
Note that the concentration limit here is ‘before use’ – this is to prevent a
person from using a solvent, mixing it with water during use, and then claiming
that the resulting waste is not hazardous. If you have questions about the
status of your solvent waste contact EHS.

The U List
The ‘U List’ technically only applies to un-used chemicals that become wastes
(expired, spilled, or no longer necessary for a laboratory’s experimentation).
However, it is best practice to collect as hazardous wastes any laboratory
waste stream which contains a chemical present on the list. Contact EHS if
you have any questions about the applicability of the U List to your chemical
wastes.

The full list of U wastes is included as Appendix A to this document.

The P List
The EPA has a list of chemicals which are considered ‘acutely’ hazardous
when disposed of. Like the U List, the P List technically only applies to
chemicals which are un-used when they become wastes. Again, however, it is
best practice to collect as hazardous waste any waste stream which contains
a chemical on the list.

In addition, the empty containers which once held ‘P-listed’ materials must

be handled as hazardous wastes themselves.

The most common laboratory chemicals found on the P List are:

 Acrolein
 Allyl alcohol
 Carbon Disulfide
 2,4, Dinitrophenol
 Nitric oxide
 Nitrogen dioxide
 p-Nitroaniline
 Osmium Tetroxide
 Phosgene
 Phosphine
  Sodium Azide
 Vanadium pentoxide

The full list is included as Appendix B to this document.

Satellite Accumulation Areas

The next step after classifying hazardous chemical wastes is accumulating
them in ‘satellite accumulation areas’ (SAA). These are areas where
hazardous wastes that are generated as part of work activity are collected and
properly stored until they are transferred by EHS to the main accumulation
area prior to off-site shipment. The satellite area is essentially the waste
collection point until a container becomes full.

The rules of Satellite Accumulation dictated by federal and state regulation:

 Location: An SAA must be ‘at or near the point of generation’. In

practice this typically means that if you have to leave the room or go
through a doorway your SAA is too far from the area the waste was
created.
 Number: There is no limit to the number of SAAs in an area, however
unnecessary SAA locations provide more potential for regulatory
violations.
 Signage: Every SAA must be indicated with a sign. Please use these
signs which can be printed from the EHS website.
 Secondary Containment: Every container of chemical waste in an
SAA must be provided with a secondary form of containment; so that
leaks or spills do not migrate. This is most often accomplished with
plastic tubs or trays provided by EHS.
 Segregation of Incompatibles: Chemical wastes which are
incompatible (strong acids and strong bases, organics and oxidizers,
etc.) must be separated into different secondary containers. They can
be present in the same SAA, however they can’t be in the same
secondary containment tray/tub.
 Duration: A container of chemical waste can stay in a SAA as long as it
is not full. Once it is full it must be removed by EHS within 3 days. It is
the user’s responsibility to notify EHS as soon as a container becomes
full.
  Duplication of Waste Streams: There can only be one container of
each type of waste in a single SAA. Fill the first container, contact EHS
for removal, and start filling the second container.
 Weekly Inspection: Each SAA must be inspected weekly by a person
in the lab or work area (by rule EHS cannot perform these weekly
inspections). The SAA sign provided above is intended to be the
inspection guide. Correct any problems in the SAA during your
inspection, but there is no need to document the inspection events.

Chemical Waste Containers

Every container of regulated chemical waste must meet the following
minimum requirements per federal and state regulation.

 Closure: Every chemical waste container must be tightly closed at all

times; unless a user is in the process of pouring waste into the
container. The only certain way to achieve this is with a tight-fitting
screw cap tightly secured on the container. If a container would leak if
tipped over, then it’s not tightly closed.
o See our guidance for equipment such as HPLC machines which
automatically drain chemical wastes into containers.
 Condition: Every chemical waste container must be in good condition;
free of cracks, leaks and corrosion.
 Compatibility: Every chemical waste container must be compatible
with and resistant to the chemical wastes which are collected inside.
Contact EHS for help selecting the right container type.
 Size:
o No hazardous waste container may be larger than 55 gallons.
o Additionally, Fire Department and other regulations often place
further restrictions on container size depending on the nature of
the chemical stored inside.
o P-listed chemicals must be removed from Satellite Accumulation
Areas once one quart has been generated (although the container
itself can be larger than one quart – the volume of p-listed waste
inside cannot exceed one quart).
 Labeling: Every container in a Satellite Accumulation Area must be
labeled. See the labeling handout on the Research Support website.
Each label, at a minimum, must include the following 4 elements:
o The words “Hazardous Waste”
 o The name of the hazardous waste chemical (or chemicals) inside
the container. These names must be spelled out in full, English
words (no abbreviations or formulas are allowed).
o A ‘statement of the hazard’ indicating which of the 4 hazard
classes the chemical(s) exhibit. This is typically done by putting a
check mark in the appropriate box on a pre-printed hazardous
waste label.
o The date the container became full. Since full chemical waste
containers must be removed within three days, no container in a
Satellite Accumulation Area should have a date older than 3 days.

Pre-printed hazardous waste labels, like the one below, are available through
EHS:

Training
All personnel who handle or generate chemical waste in laboratories or other
campus locations must receive training on proper waste handling procedures
and emergency response procedures.

Initial training must be completed during the first six months of employment;
refresher training is provided annually thereafter.

Hazardous waste training is a topic included in Laboratory Safety Training,

which is available either in-person or on-line. Facilities Department personnel
receive chemical waste training as part of their annual training program.
Additionally, some departments receive hazardous waste training tailored to
the specific wastes generated in that department. Visit the EHS training
website for more information.

Disposal of Unknowns
All chemicals must be identified and containers properly labeled at all times.
Laboratory staff is responsible for seeing that this requirement is met in their
laboratories.
If an unknown chemical is discovered, label it as “unknown-pending analysis”
and attach a note detailing any information about what the chemical may be or
what experiment it may have been used for and where it was found. Contact
EHS immediately for characterization.

Chemical Spills and PPE Waste

In general, a material that is used to clean up a chemical spill (excluding
equipment which is to be re-used) must be disposed of in the same manner
as the chemical itself. Gloves, spill pads, absorbents, etc. which are used to
clean up a chemical spill become chemical wastes themselves, subject to the
same rules as the spilled chemical.

See the campus spill response page or the emergency flipchart in your
laboratory for spill response instructions.

Personal Protective Equipment (PPE) such as gloves, and lab equipment

such as pipette tips, which become contaminated with hazardous chemicals
should be disposed of in the same manner as the chemical waste.

Pipette tips (which are not sharp enough to puncture skin) can typically be
placed into the same container the chemical waste is collected in. Disposal
lab coats and larger items which become contaminated can be sealed in a
bag, tied closed, and then managed (labeling, etc.) as a chemical waste
container.

Dilution and Evaporation

Dilution of a waste stream (by adding clean water, for example) so that it no
longer meets a hazardous waste characteristic (a concentration of a toxic
metal, for example) is not allowed. Chemical waste streams must be identified
and dealt with at the time they become wastes; typically at the conclusion of
an experimental protocol. Dilution is not the solution to pollution.

Mixing a listed hazardous waste with other waste streams results in the entire
mixture becoming a regulated hazardous waste.

Evaporation of liquid chemical wastes in NOT an acceptable method of

disposal. Liquid wastes must be captured and disposed of properly. In
addition to being a prohibited practice, the addition of volatile organic
compounds (VOCs) to the atmosphere contributes to the generation of
harmful ground-level ozone, which is a serious health threat especially in
urban areas. It is therefore important from both a compliance standpoint and a
public health standpoint to minimize the evaporation of chemical liquids as
much as possible.

Elementary Neutralization
In the majority of cases EHS recommends collection of chemical wastes with
high or low pH values (remember that chemical wastes with of 2 or lower, or
12.5 or higher, exhibit the corrosive characteristic and are hazardous wastes)
for disposal off-site.

However, there are circumstances in which it is allowable to neutralize the pH

of a corrosive waste – a process called elementary neutralization. The high or
low pH waste must ONLY be hazardous because of pH (cannot carry any
other characteristic or be a listed hazardous waste) and the neutralization
process must not generate toxic gases or dangerous levels of heat.

If you would like to explore the option of elementary neutralization for your
chemical wastes, contact EHS.

Nanoparticles
The fate and behavior of nanoparticles (defined as particles with at least one
dimension between 1 and 100 nanometers in length) which are released to
the environment is not fully understood. For this reason, disposal of
nanoparticle wastes should accomplished via the hazardous chemical waste
program.

Pure nanoparticles (tubes, dots, etc.), items contaminated with nanomaterials

(PPE, wipes, etc.), liquid suspensions of nanoparticles and any material from
which nanoparticles could detach from the surface (a friable matrix involving
nanomaterials or with nanoparticles attached to the surface) should not be
disposed in the regular trash or via a drain.

Nanoparticle wastes should be:

  Collected in the same way as hazardous chemical wastes (in tightly
closed containers free of leaks and cracks).
 Labeled as a hazardous chemical waste, including:
o The words ‘Hazardous Waste’,
o The words ‘Nanoparticle Waste’,
o The name of the base material (carbon, metal, etc.) and for
solutions the name of the liquid solvent,
o A statement of hazard: ‘toxic’ for the nanoparticle in addition to
any hazard associated with the base material or solvent
(‘ignitable’, for example).
 Removed from the laboratory by scheduling a pickup through the EHS
hazardous chemical waste program.

Waste Minimization
Effective management is the key to minimizing the risks associated with
hazardous chemical waste. Every member of the Boston University research
community can take steps to minimize the volume and toxicity of chemical
wastes that are generated.

Inventory Management

 Maintain an up-to-date inventory of the chemicals in your laboratory to

avoid re-purchasing existing materials and to understand usage
patterns.
 Only purchase the amount of chemical you will need in the short term.
Buying in bulk never makes financial sense when the risks of storage
and the costs of disposal are considered.
 Use the RIMS system to identify coworkers in your area who might have
a chemical that you need.
 Dispose of outdated or unwanted chemicals immediately. Some
materials, such as peroxide-forming chemicals, become more
dangerous over time. It is much safer and much less expensive to get
rid of ether that does not have significant peroxide formation.
 Label all chemical containers, regardless of what’s inside. Unknown
chemical wastes are extremely expensive to dispose of.
 Only purchase cylinders from companies who will pick them up when
empty.
Scaling and Substitution

 Consider using microscale experiments to reduce the volume of

chemical wastes generated.
 Avoid unnecessary dilutions in experimentation which might increase
the volume of hazardous waste generated.
 Substitute less hazardous materials into experiments, for example:
o Use biodegradable detergents instead of toxic, chromium-based
cleaners
o Use latex paints and coatings instead of oil-based
o Use non-mercury thermometers
o Select non-mercury preservatives, and choose products such as
antibodies which have been manufactured using non-mercury
preservatives
o Preserve specimens in ethanol instead of formaldehyde which is
much more toxic
o Use non-halogenated solvents in place of halogenated solvents
wherever possible to reduce toxicity and disposal costs
o Use sodium hypochlorite instead of dichromate
o Use ‘SYBR safe’ or other DNA gel stain instead of ethidium
bromide
o Substitute F-TEDA-B54 or other product in place of fluorinating
agents
o Use scintillation cocktails which are non toluene/xylene based
o Eliminate metal catalysts whenever practical, even if it means
longer experimentation times
o Purchase chemicals pre-mixed or in the desired concentration to
avoid unnecessary experimental steps and un-needed chemical
stores
o Substitution of ethanol in place of methanol in experiments can
often provide more waste management options.

Recycling

 If your research relies on a large quantity of a specific solvent EHS can

help you evaluate a benchtop solvent recycling system.
 If digital image processing is not possible, work with EHS to set up silver
recovery and recycling for your darkroom.
Mixing Waste Streams

 Flammable liquids are the most cost-effective waste stream to dispose

of. Avoid mixing halogenated solvents, metals or other hazardous
materials with flammable liquid wastes.
 Wastes containing heavy metals should not be combined with any other
waste streams.
 Mercury wastes should be kept separate from all other waste streams.

Appendix A: U Listed Hazardous

Wastes

Environmental and Waste Management

 Chemical Waste

o Chemical Waste Management Guide

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