All hazardous waste shall be managed in accordance with federal, state, and local regulations.
Note: This policy deals with the disposal of hazardous chemical waste. For information on the disposal of potentially infectious waste, please refer to the Potentially Infectious Waste Policy. For information on the proper disposal of radioactive materials, please contact the Office of Research Safety - Radiation Safety Office at 773.702.6299.
Authority and Responsibility
Environmental Health and Safety is responsible for:
- Developing a Hazardous Waste Management Program;
- Coordinating compliance with this policy for all University properties;
- Taking annual Hazardous Waste Management and Generator training;
- Signing hazardous waste manifests;
- Tracking hazardous waste documentation;
- Conducting periodic audits of hazardous waste, waste streams; and
- Acting as the liaison during regulatory inspections.
Departments disposing of hazardous waste are responsible for:
- Properly identifying and labeling all waste containers;
- Scheduling periodic waste pick-ups;
- Managing their waste and inventory to avoid stock-piling;
- Properly segregating incompatible wastes; and
- Disposing of hazardous waste in a safe and legal manner.
The Office of Research Safety is responsible for:
- Conducting periodic audits of labeling and storage of hazardous waste containers within research laboratories; and
- Working with responsible departments to ensure hazardous waste containers are properly identified and labeled, to facilitate proper disposal as part of the laboratory decommissioning process for laboratories that are closing down or being remodeled.
Hazardous Material Disposal
Hazardous waste is waste that is dangerous or potentially harmful to our health or the environment. Under the United States Environmental Protection Agency (USEPA), waste can be a listed hazardous waste, or characteristically hazardous. Listed hazardous wastes, by definition, have been determined by USEPA as being hazardous.
Waste that has not been specifically listed can still be characteristically hazardous if it exhibits any one of the following characteristics:
- Reactivity; or
- Flammable Liquids – Flashpoint <140ºF (e.g., alcohols, acetone, ethyl acetate, mineral spirits, gasoline)
- Oxidizers (e.g., nitrates, perchlorates, bromates, permanganates, peroxides, iodates)
- Organic Peroxides (e.g., benzoyl peroxide, cumene hydroperoxide, methyl ethyl ketone peroxide)
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 55ºF.
- 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)
Materials which can react violently or create toxic fumes:
- Sulfides and cyanides
- Peroxide formers (e.g., ethers, potassium amide, sodium amide, vinyl acetate, tetrahydrofuran)
- Water Reactive Materials (e.g., sodium, potassium, lithium, calcium carbide)
- Multi-nitrated Compounds (e.g., picric acid, nitrosoguanidine, trinitroaniline)
- Perchlorate crystal formers (e.g., perchloric acids)
- Compounds that may undergo vigorous polymerization (e.g., acrylic acid, vinyl acetate, methyl acrylate)
A waste which, when using the toxicity characteristic leaching procedure (TCLP), 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 hazardous materials into sinks, drains, commodes, or other sewage disposal channels is STRICTLY PROHIBITED.
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:
- Campus and Satellite Locations: Environmental Health and Safety - 773.702.9999
- University of Chicago Medicine: Environmental Health and Safety - 773.702.1733
All laboratory hazardous waste pick-ups shall be submitted via the EH&S Assistant Program. If laboratory personnel have difficulties using the EHS Assistant program please contact Environmental Health and Safety at firstname.lastname@example.org. Personnel located in the clinical University of Chicago Medicine shall submit waste pick up requests by contacting the University of Chicago Medicine Environmental Health and Safety office.
Waste collection shall occur each week on Wednesdays for the University of Chicago Medicine and Thursdays for the University of Chicago campus or as needed for off-campus locations and large clean-outs. Please submit your pick-up request by 3 p.m. of the previous day to be included in the pick-up.
Please set up periodic waste pick-ups based on the amount of waste your area typically generates.
Large waste pick-up requests (Non-typical): If a waste pick-up is not associated with normal quantities of waste generated during typical research activities, a separate audit by EHS shall be required. The cost associated with non-typical research waste (i.e., inventory clean-out related to a laboratory decommissioning for a pre-renovation or pre-relocation event) shall be the responsibility of the lab/division and/or treated as a renovation cost and absorbed in the project budget. Allow at least four weeks for large pick-up requests. 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.
All chemical wastes shall be stored using proper chemical segregation practices to avoid intermixing of incompatible materials. (See the Chemical Segregation and Storage Chart for guidance on how to properly store chemical waste containers).
All chemicals shall be stored in a satellite accumulation area near where the waste was generated. Moving/relocating hazardous wastes away from where they were generated is prohibited.
Additionally, no more than 55 gallons of hazardous waste (cumulative total of all wastes in an area) and only one quart of an acutely hazardous waste can be present within a single point of generation (laboratory or maintenance shop). Please note, single used oil containers or petroleum-based products equal to or exceeding 55 gallons are subject to additional requirements found within the Spill Prevention, Control, and Countermeasures (SPCC) Policy.
All hazardous waste containers shall be properly labeled with the words "Hazardous Waste", a description of the waste contained in the container, the hazards associated with the waste, and the location where the material was generated. If bottles are reused, remove the old chemical name and hazards completely and indicate the type of chemical waste on the container without abbreviations. 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 (see "Labeling-Hazardous Waste Containers" ). If the contents of the container are unknown, please indicate this on the label and in the waste pick up request. Containers of unidentified wastes may need to be evaluated in person by EHS/ORS staff and/or the University's waste vendor before they are removed for disposal.
In an effort to make container labeling easier for users EHS has created multiple labeling options. Please see the links below for links to Adobe forms for printed and handwritten label formats. Additionally, waste labels may also be printed from within the EHS Assistant program once a waste request has been entered.
Handwritten Waste Labels
Adobe Template Waste Labels
All hazardous waste shall be packaged in accordance with the following instructions:
- Use a leak-proof container that will safely contain the contents. Open chemical containers, plastic bags or culture dishes will not be accepted.
- Containers must be closable.
- 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.
- Be suspicious of any pressure build-up inside the container (e.g. piranha waste)
- If this is a concern when closing the container, use a cap designed to allow venting of over-pressure or do not secure the cap tightly and if appropriate, place the container inside a fume hood or other well-ventilated area until the chemical reaction has reached equilibrium and is removed by the waste collector.
- Old cans of dry picric acid or other shock-sensitive compounds and all known or suspected peroxide forming chemicals (PFC) shall be left in place and not moved until the waste collector has evaluated the condition of the container. (Note: Friction, heat, and exposure to air can cause aging PFCs to explode).
- PFCs that MUST be disposed of within three (3) months of opening:
- Divinyl acetylene
- Divinyl ether
- Isopropyl ether
- Potassium amide
- Potassium metal
- Sodium amide
- Vinylidene chloride
- PFCs that must be monitored for peroxides or discarded 12 months after opening. (This list is not exhaustive. Please check the SDS and dispose of the material per the manufacturer's expiration date.)
- Acetal (1,1-diethoxyethane)
- Benzyl alcohol
- Diethyl ether
- Methyl isobutyl ketone
All scintillation vials containing amounts of radioactive material reading above background levels shall be disposed of through the Office of Radiation Safety (773.702.6299) 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 Office of Radiation Safety.
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.
The Principal Investigator (PI) must acquire a license from the Drug Enforcement Agency (DEA) if they will use controlled substances during their research activities. If you will acquire a DEA license or ship hazardous or infectious substances (not waste), then alert the Office of Research Safety.
Do not submit a hazardous waste pick-up request to EHS for a controlled substance. The controlled substance is registered to the PI and the specific storage location. The hazardous waste vendor cannot remove controlled substances from the lab they are registered to.
If the PI adheres to the regulations and terms outlined in their DEA license, then the unused or expired controlled substance will be sent to a reverse distribution vendor. The PI holding the license must complete DEA forms and become a reverse distribution registrant. The original registration information for the substance will be needed to complete the forms. This option will allow the PI to transfer ownership to a DEA-approved Pharmaceutical Returns Processor for re-use, re-sale, or destruction. The cost associated with this process should be considered when procuring controlled substances. If a PI is closing or relocating a lab, please work with the Office of Research Safety to complete decommissioning processes. The PI should confirm they have closed out their DEA license and have returned all unused or expired controlled substances.
If a PI holding a DEA license abandons controlled substances, then the department must make every effort to reach the PI to ensure they properly close out their DEA license and initiate the reverse distribution program for any unused or expired controlled substances.
If a controlled substance is orphaned or the PI will not respond to department requests, then the department will need to document they made every effort to identify/reach the original PI but were unsuccessful. If this occurs alert the Office or Research Safety and Environmental Health and Safety. Destruction of the abandoned material can be quite difficult and is treated by the DEA on a case-by-case basis. The department may be asked to submit a letter to the DEA explaining the circumstances regarding the orphaned material and formally requesting the transfer of the ownership of the material to another PI or approval to denature the substance with a solvent or other chemical/process to render it unrecoverable. Once completed, the PI/Department should submit a copy of the DEA approved destruction documentation to Environmental Health and Safety.
It should be noted that is illegal to dispose of research related controlled substances in a medical center, law enforcement, or pharmacy “take back” collection box. These boxes are strictly meant for personal prescriptions, not controlled substances registered to a DEA license.
Refrigerators and Freezers
Equipment containing refrigerants must be disposed of in a manner which is compliant with the EPA's Clean Air Act. For more information regarding the disposal of refrigerators, freezers or other small appliances containing <5 Gallons of refrigerant please see the Disposal of Refrigerators and Freezers guidance document.
For all other types of waste, dispose of in accordance with the 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 EPA Acutely Hazardous Waste "P" List, the emptied container can be air-dried in a ventilated area (e.g., a chemical fume hood) without triple rinsing.
If the chemical is on the EPA Acutely Hazardous Waste "P" List, 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. In many circumstances, it may advisable to dispose of the empty chemical container as waste rather than triple rinsing the container, which may only increase the volume of waste material needing to be disposed of. Additionally, containers with residual reactive materials (pyrophoric, water-reactive, or strong oxidizers) should not be treated as empty and should be disposed of as hazardous waste.
Empty reagent bottles may be used for the disposal of laboratory chemical wastes. However, it is important to verify that the chemical wastes are compatible with the empty reagent containers.
Note: It is improper to dispose of volatile liquids by evaporating.
Empty, intact, unbroken glass chemical containers that meet the above requirements for empty containers may be disposed of as regular laboratory waste in the general waste stream. Completely remove or deface chemical labels using a permanent black marker before disposal. Remove any caps from the bottles.
If you are located in a campus building, put in a service request with Facilities Services at 773.834.1414 for a pick-up of empty bottles.
Broken laboratory glassware free from any biohazardous, radioactive, and chemical contamination shall be disposed of by packing in a designated broken glass receptacle, cardboard box, or other rigid container. This includes the disposal of the following uncontaminated items:
- Broken glass
- Glass vials
To minimize various potential hazards when discarding broken or un-serviceable glassware, the guidelines below shall be followed:
- Dispose of broken laboratory glassware in designated broken glass containers only. These shall be puncture-proof, double-lined cardboard boxes or other containers specifically designed for the disposal of glassware not weighing more than 20 pounds when full. They can be obtained from various laboratory equipment distributors;
- 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, medical/biohazardous materials or liquid wastes;
The following items contaminated with medical/biohazardous material shall be placed in a designated sharps container (for more information see the Potentially Infectious Waste Policy):
- Broken glassware
- Glassware with sharp edges or point
- Pasteur pipettes
- Glass slides
Contact the appropriate Facility Manager to make arrangements for pick-up if you are located in the following campus buildings:
- Knapp Center for Biomedical Development
- Cummings Life Science Center
- Biological Sciences Learning Center/Gwen Knapp
If you are located in any other campus building, contact the Facilities Services work order desk at 773.834.1414 to generate a work order for pick-up and provide the following information:
- Contact Information
- Number of broken glass containers
- Number of "empty" bottles (intact)
If you are located in the University of Chicago Medicine or in Kovler Laboratories, follow normal waste disposal procedures and do not accumulate mass quantities prior to requesting a pickup.
All personnel handling broken glass containers should:
- 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.
Metal containers must be triple rinsed with water or other suitable solvent and air-dried. If the container is free of hazardous chemical residues, remove or deface any hazard markings or labels, it may then be placed in the regular laboratory trash or recycling receptacles.
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.
Hazardous Waste Minimization
It is the responsibility of all University of Chicago employees to reduce the amount of chemicals requiring disposal. The following guidelines shall be followed:
Supported by Principal Investigators, Lab Personnel, Laboratory Safety Specialists, and the Office of Research Safety:
- Only purchase what is needed for a three to six month period;
- If practical, use non-hazardous materials;
- Segregate non-hazardous waste materials from hazardous wastes;
- Use sound chemical hygiene practices to avoid spills while handling chemicals and keep all containers closed when not actively adding/removing chemicals;
- 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;
- If the material can be safely neutralized at the point of use, then do so; and
- Properly label waste to communicate hazards, which helps the disposal vendor more accurately define/manage waste streams.
Process level impacts
Supported by Environmental and Health and Safety and the hazardous waste disposal vendor:
- Stress the importance of properly labeling laboratory waste at the point of generation; and
- The contractor providing disposal services shall segregate chemical waste from non-hazardous waste.
Reviewed: December 2020