All hazardous waste shall be managed in accordance with federal, state, and local regulations.
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;
- Tracking hazardous waste documentation; and
- Acting as the liaison during regulatory inspections.
Departments disposing of hazardous waste are responsible for:
- Properly labeling all waste;
- 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.
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:
- Flammable Liquids – Flashpoint <140oF (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)
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 55oC.
- 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);
- Multinitrated Compounds (e.g., picric acid, nitrosoguanidine, trinitroaniline);
- Perchlorate crystal formers (e.g., perchloric acids); and
- 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 these 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: Safety and Environmental Compliance - 773.702.1733
All laboratory waste pick-ups shall be submitted via the EH&S Assistant Program. Laboratory personnel can request access to the EH&S Assistant program by contacting Environmental Health and Safety at email@example.com.
Waste collection shall occur each week on Wednesdays for the University of Chicago Medicine and Thursdays for the campus or as needed. Please submit your pick-up request by 3:00 pm of the previous day to be included in the pick-up.
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 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.
Please set-up periodic waste pick-ups based on the amount of waste your area typically generates. Please avoid scheduling weekly pick-ups if waste is not being generated at a rate to necessitate such a frequency.
Note: No more than 55 gallons of hazardous waste (cumulative total off 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). However, a single used oil container cannot exceed 55 gallons or it will become subject to Spill Prevention, Control, and Countermeasures (SPCC) Policy.
Hazardous Material Waste Form
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 chemical waste vendor at the time of pick-up. 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 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. If the contents of the container are unknown, please indicate this on the label. All containers of hazardous waste shall have an accumulation start date (this is the date that the collection container was declared full and ready for disposal). If labels are needed, Environmental Health and Safety can supply a limited amount upon request.
All hazardous waste shall be packaged in accordance with the following instructions.
- 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.
- 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.
- 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.
- Old cans of dry picric acid and all other known or suspected peroxide forming chemicals (PFC) or shock sensitive compounds shall be left in place and not moved until the waste collector has evaluated the condition of the container. 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.
For all other types of waste, dispose 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.
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 may be disposed of as regular laboratory waste in the general waste stream. If an empty glass container has less than 3% chemical residue and is not present on the EPA Acutely Hazardous P-List, 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, contact the Facilities Services work order desk 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;
- Pasteur pipettes;
- Glass slides; and
- 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 box or other container 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 waste shall be placed in a designated sharps container:
- Broken glassware;
- Glassware with sharp edges or point;
- Pasteur pipettes; and
- 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 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 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;
- 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: March 2015