The University of Chicago
Safety Manual
Environmental Compliance Programs

Policy

All hazardous waste shall be managed in accordance with federal, state and local regulations.

Authority and Responsibility

Environmental Health and Safety is responsible for:

1. Developing a Hazardous Materials Management Program;

2. Coordinating compliance with this policy for all University properties;

3. Notifying parties responsible for violation of this policy;

4. Identifying a corrective action plan; and

5. Conducting follow-up inspections to ensure compliance.

Departments managing hazardous materials are responsible for:

1. The proper handling, storage, transportation and removal of all hazardous materials as outlined in this policy.

Waste Minimization

In an effort to reduce the amount of chemicals needing disposal, the following guidelines shall be followed:

1. Only purchase what is needed for a three to six month period;
2. If practical, use non-hazardous materials;
3. If the chemical is still useful, recycle the waste instead of disposing of it by finding an associate that could use the remainder of the chemical;
4. If the material can be safely neutralized at the point of use, then do so; and
5. The contractor providing disposal services shall segregate chemical waste from non-hazardous waste.

Hazardous Material Disposal

The United States Environmental Protection Agency (USEPA) has developed a listing of chemicals considered to be hazardous.  These chemicals include spent solvents, poisons and corrosives.  If a chemical exhibits any one of the following characteristics, the chemical would be considered hazardous:  ignitable, corrosive, reactive or toxic.

Ignitable

• Flammable Liquids - Flashpoint <140°F (e.g., alcohols, benzene, toluene, xylene, acetonitrile )
• Oxidizers (e.g., nitrates, perchlorates, bromates, permanganates, peroxides, iodates )
• Organic Peroxides (e.g., benzoyl peroxide, cumene hydroperoxide, methyl ethyl ketone peroxide)

Corrosive

Aqueous liquids with a pH < 2 or > 12.5 or other liquids capable of corroding steel at a rate of > 6.35 mm (0.250 inches) per year at a test temperature of 55^o Celsius. 

• Inorganic Acids (e.g., hydrochloric acid, sulfuric acid, nitric acid, perchloric acid, phosphoric acid)

• Organic Acids – (e.g., formic acid, lactic acid)

• Bases – (e.g., hydroxide solutions, amines)

Reactive

Materials which can react violently or create toxic fumes:

• Sulfides and cyanides
• Peroxide formers (e.g., ethers, potassium amide, sodium amide, vinyl acetate, tetrahydrofuran)
• Alkali metals (e.g., sodium, potassium, lithium)
• Dinitro and trinitro compounds (e.g., picric acid)
• Isocyanates
• Perchlorate crystal formers (e.g., perchloric acids)

Toxic

A waste which, when using the toxicity characteristic leaching procedure, leaches any number of metallic, organic, or pesticide constituents in concentrations greater than specified in the regulation.  Examples for these constituents include arsenic, barium, cadmium, chloroform, chromium, m-cresol, mercury, selenium and silver. 

Disposal of these materials into sinks, drains, commodes or other sewage disposal channels is STRICTLY PROHIBITED.  Empty containers with 3% or less chemical residual can be disposed of in the general waste stream. 

Chemical Waste Disposal Procedures

To facilitate the removal of waste materials from your area, waste generators are instructed to contact one of the following departments based on their location:

Waste collection shall occur each week on Thursdays or as needed.  To arrange for collection on a particular week, please contact one of the above listed departments by Wednesday of that week to ensure collection on that Thursday. For large chemical clean-outs, allow a one week notice.

Waste shall be collected from the area in which the waste is located.  If special access arrangements or instructions are needed, provide this information when making arrangements for a chemical pick-up.

Appendix A - "Chemical Waste Disposal Form" shall be completed by the generator prior to a waste pick-up.  A copy of this form shall be provided to the person(s) removing the waste for disposal.  Waste will not be collected without the completion of this form.  Each type of waste and associated quantity shall be listed as accurately as possible.

All hazardous waste containers shall be properly labeled to indicate the type of material contained in the container.  If bottles are reused, remove the old chemical name and hazards completely and indicate the type of chemical waste on the container.  Hazardous waste containers not labeled in accordance with this policy shall not be removed from the area until such label is affixed to the container.  If the contents of the container are unknown, please indicate this on the label.  All containers of hazardous waste shall have an accumulation start and end date.  If labels are needed, Environmental Health and Safety will supply a limited amount.

All hazardous waste shall be packaged in accordance with the following instructions.

1. Use a leak-proof container that will safely contain the contents.  Chemical flasks, plastic bags or culture dishes will not be accepted.  Containers must be closable.
2. The container shall not be overfilled with liquid waste.  Empty space of at least five percent of the container volume shall be left to allow for thermal expansion.
3. Be suspicious of any pressure build-up inside the container.  If this is a concern when closing the container, do not secure the cap tightly and if appropriate, place the container inside a fume hood or other well ventilated area until the chemical is removed by the waste collector.
4. If a safety can(s) or re-usable container(s) is used, write your location on the can with a permanent marker to ensure the return of your safety can within one week.
5. Old cans of ether, picric acid and other peroxide forming compounds shall be left in place and not moved until the waste collector has evaluated the condition of the container.
6. If waste is accumulated over time, list the accumulation start date and disposal date on the container.

Scintillation Vials

All scintillation vials containing amounts of radioactive material reading above background levels shall be disposed of through the Radiation Safety Office at 702-6299 with the exception of H-3, C-14 or I-125.  These are de-regulated vials if they are below 0.05 microcuries per milliliter and shall be disposed of in accordance with this program.  All other vials greater than 0.05 microcuries per milliliter of those three nuclides shall be disposed of through the Radiation Safety Office.

Mixed Waste

If mixed waste such as a radioactive compound combined with an infectious agent is being generated, Environmental Health and Safety and/or the Office of Radiation Safety shall be contacted to determine the proper disposal procedure.

In conducting research with controlled substances, University authorized employees must comply with federal and state laws and regulations regarding their uses, including registration with the Drug Enforcement Administration (DEA), storage requirements, inventory maintenance and substance disposal.

For all other types of waste, dispose in accordance with the Appendix B - "Hazardous Waste Disposal Flow Chart". 

Empty Chemical Containers

Chemical containers that have been emptied of their contents by normal methods are not regulated as hazardous waste.  The container shall be triple rinsed with water or other suitable solvent and air-dried to ensure that it is free of liquid or other visible chemical residue before disposal.  For volatile organic solvents (e.g., acetone, ethanol, ethyl acetate, ethyl ether, hexane, methanol, methylene chloride, petroleum ether, toluene, xylene) not on the list of acutely hazardous wastes, the emptied container can be air-dried in a ventilated area (e.g., a chemical fume hood) without triple rinsing.  Note:  It is improper to dispose of volatile liquids by evaporating.

If  the chemical is on the list of acutely hazardous wastes or if the material is known to have high acute toxicity, the washings shall be collected and disposed of as hazardous waste by contacting Environmental Health and Safety and requesting a chemical pick-up.

Note:  Empty reagent bottles are excellent for the disposal of laboratory chemical wastes.

Laboratory Glassware

Laboratory glassware free from any biohazardous, radioactive and chemical contamination shall be disposed of by packing in a cardboard box or other rigid container.  This includes the disposal of the following uncontaminated items:

• Broken glass;
• Pasteur pipettes;
• Glass slides; and
• Glass vials.

Broken glass containers free of chemical residue shall be placed in broken glass receptacles or placed in a puncture resistant container, such as a rigid plastic container or corrugated cardboard box. 

Metal Containers

Metal containers must be triple-rinsed with water or other suitable solvent and air-dried.   If the container is free of hazardous chemical residues, it may be placed in the regular laboratory trash. 

Secondary Containers

Containers that were used as overpack for the primary chemical container may be placed in regular trash or recyclable trash.  Any packing materials, such as vermiculite, perlite, clay, styrofoam, etc., may be placed in the regular trash unless it was contaminated with the chemical as a result of container breakage or leak.  Packing materials contaminated with hazardous materials shall be disposed of as hazardous waste.

Disposal of Empty Chemical Containers and Broken Glass

To minimize various potential hazards when discarding broken or unserviceable glassware, the guidelines below shall be followed:

• Dispose of only laboratory glassware in broken glass containers;

• Completely remove or deface chemical labels using a permanent black marker;

• Remove any caps from chemical containers;

• Discard chemical containers and laboratory glassware into a puncture proof, double-lined cardboard box or a container specifically designed for the disposal of glassware not weighing more than 20 pounds when full;

• When the box is full, securely seal with tape to prevent any leaks;

• Label the container as “TRASH”;

• Never use broken glassware boxes for the disposal of sharps, biohazardous materials or liquid wastes;

• The following items contaminated with medical/biohazardous waste shall be placed in a sharps container:

  • Broken glassware;

  • Glassware with sharp edges or point;

  • Pasteur pipettes; and

  • Glass slides.

• If you are located in the following campus buildings:  Knapp Center for Biomedical Development, Cummings Life Science Center or Biological Sciences Learning Center/Gwen Knapp, contact the appropriate facility manager to make arrangements for pick-up;

• If you are located in any other campus building, contact the Facilities Services work order desk at 834-1414 to generate a work order for pick-up and provide the following information:

  • Location;

  • Contact Information;

  • Number of broken glass containers;

  • Number of “empty” bottles;

• If you are located in the Medical Center or Kovler, follow normal waste disposal procedures; and

• Do not accumulate mass quantities prior to requesting a pickup.

All personnel handling broken glass containers shall:

• Check the weight and integrity of the container prior to lifting;

• Wear safety glasses and work gloves when handling the container;

• Do not remove the box if you see a red or orange liner;

• Do not remove the box if open, compromised, wet or suspected of containing chemicals; and

• Immediately contact your supervisor with any issues.

Transporting Chemicals

Transportation of chemicals from one building to another on campus is discouraged, but when absolutely necessary all chemicals shall be labeled and transported within secondary containers capable of holding all materials in the event of a spill.  Acceptable secondary containers include plastic bottle carriers with closed tops and handles or non-metal chemical transport carts with lips on all four sides.  Never transport incompatible chemicals in the same secondary containment.  Use plastic tubes or separate bottle carriers to prevent incompatibles from mixing.  During transport of chemicals between buildings, use paved paths and sidewalks rather than streets or roads.

During transportation of chemicals, appropriate personal protective equipment (PPE) shall be worn.  Minimum PPE includes safety glasses, lab coat, or other appropriate lab attire and closed toe shoes.  Appropriate gloves shall be kept on the cart for protection of transporter in case of a spill during transit.  Hazardous chemicals shall be attended at all times while being transported. 

During transport, if a spill occurs and there is question as to whether a spill can be safely cleaned up, or you are uncertain of the hazards of the substance, or you do not feel comfortable in dealing with the spill, immediately contact University Police at 702-8181.  Do not leave spill unattended at anytime.

Do not attempt to clean up any spill if the following conditions apply: 

• More than one chemical has spilled;
• If quantity spilled is more than the available absorbent provided in the spill control station or the spill is greater than one liter;
• If the chemical is classified as a toxic/poison;
• If the chemical is highly flammable or explosive;
• The substance is unknown or you are uncertain of the hazards of the substance;
• A secondary emergency situation exists (e.g., fire); or
• You are uncomfortable in the situation.

All spills shall be cleaned up in accordance with the Chemical Spill Response quick reference, Section 1.2.

Transportation of compressed gas cylinders across campus shall be in accordance with the Compressed Gas Cylinders policy, Section 5.8 of the University’s Safety Manual.

Storage of Chemicals

Typical storage considerations may include temperature, ignition control, ventilation, segregation and identification. Proper segregation is necessary to prevent incompatible materials from inadvertently coming into contact.  If incompatible materials were to come into contact, fire, explosion, violent reactions or toxic gases could result.

General chemical storage practices are as follows:

• Do not overfill containers;
• Inventory all chemicals in each laboratory annually;
• Check for damaged labels, outdated chemicals, damaged containers and peroxide forming compounds;
• Store liquid hazardous chemicals below six feet;
• Do NOT store incompatible chemicals in a common safety cabinet (e.g., corrosives with solvents; acids with bases; oxidizing agents with organic compounds such as sulfuric acid with acetic acid); and
• For volumes of solvents larger than one pint, use safety cans instead of glass if the purity required does not mandate glass storage.

Flammable Liquid Storage

Flammables shall be stored as follows:

• Class I liquids in sealed containers or safety cans not more than one gallon capacity, not exceeding a total of ten gallons;
• Class II liquids in sealed containers or safety cans of not more than five gallons capacity or in barrels, drums or tanks not more than sixty gallons capacity, to a maximum aggregate amount of sixty gallons;
• Class III liquids in sealed containers of not more than five gallons capacity, in barrels, drums and tanks not exceeding one hundred twenty gallons capacity to a maximum aggregate amount of one hundred twenty gallons;
• Ten gallons of flammable liquids are permissible outside a flammable cabinet;
• Anything in excess of ten gallons shall be stored in an approved flammable cabinet not exceeding its rated capacity;
• Flammable cabinets shall be labeled “Flammable - Keep Fire Away”;
• Flammable cabinets must have either an Underwriters Laboratory or Factory Mutual Label and meet the Occupational Safety and Health Administration (OSHA) and National Fire Protection Association (NFPA) Code 30 specifications;
• Flammable storage cabinet shall not be required to be vented for fire protection purposes and vent openings shall be sealed with the bungs supplied with the cabinets or with bungs specified by the cabinet manufacturer;
• If flammable storage cabinets are vented for any reason, the cabinet shall be vented directly outdoors in such a manner that will not compromise the specified performance of the cabinet and in a manner that is acceptable to the authority having jurisdiction;
• Use a fume hood whenever appreciable quantities of flammable substances are transferred from one container to another, allowed to stand in open containers, or handled in any other way; and
• Avoid contact with heat, sparks, and flames.

Classifications of Flammable Liquids

• Class I – Liquids with a vapor pressure less than forty pounds per square inch absolute at 100 degrees Fahrenheit and a flashpoint below 100 degrees Fahrenheit, 38 degrees Centigrade as determined by the herein required test (e.g., ether, gasoline, benzol, ethyl alcohol);
• Class II – Liquids with vapor pressure less than forty pounds per square inch absolute at 100 degrees Fahrenheit and a flashpoint above that for Class I and below 140 degrees Fahrenheit, 60 degrees Centigrade, as determined by the herein required test (e.g., kerosene, fuel oil no.1); and
• Class III – Liquids with a flashpoint above that for Class II and below 200 degrees Fahrenheit, 93 degrees Centigrade (e.g., fuel oil no.2, aniline, creosole).

Corrosive Storage

Corrosives shall be stored as follows:

• Store corrosives in chemical-resistant, lipped trays so as to keep any spills contained;
• Inspect corrosives every six months for damaged containers;
• Corrosives in excess of ten gallons shall be stored in a Corrosives Cabinet;
• Currently, there are regulations regarding the construction of corrosive/acid cabinets, however, most manufacturers construct them out of polyethylene and they are usually blue in color;
• Corrosive cabinets are primarily vented only when required by local authorities or the company;
• Metal cabinets are the final option for the storage of corrosives and most likely will need to be vented to prevent rusting or corrosion;
• When venting a corrosive cabinet, connecting to an existing exhaust such as a fume hood is strongly recommended since fume hood exhaust systems are designed to handle corrosive vapors;
• PVC is the best material for venting of corrosive; and
• Store compatible corrosives according to the Appendix C - "Chemical Segregation and Storage Chart".

Chemical Segregation

Segregation of laboratory chemicals shall be done in accordance with the following segregation scheme or an equally effective system developed by the laboratory director or department.

The segregation schematic in no means is a fool-proof system for chemical segregation; however, it is far superior over the alphabetical and inorganic/organic systems.

Section 6 Index

 Table of Contents

Environmental Health and Safety
Issued:  01/24/96
Revised:  11/10/09