V. Environmental Management
According to 40 CFR Part 262.102, LABORATORY WASTE means a hazardous chemical that results from laboratory scale activities and includes the following: excess or unused chemicals that may or may not be re-used outside their laboratory of origin; hazardous chemicals determined to be a RCRA hazardous waste as defined in 40 CFR Part 261; and hazardous chemicals that will be determined not to be a RCRA hazardous waste pursuant to § 262.106. Based on this definition in UMB Labs a chemical becomes a laboratory waste when:
- it has gone through a research process or class experiment and is no longer needed, or
- it is a virgin chemical no longer needed, or
- it is a clean up material from a chemical spill.
The following individuals may determine if materials within a laboratory are laboratory waste and should be managed according to the Minimum Performance Criteria (Appendix H):
- Laboratory Workers
- EH&S Personnel
- Trained Hazardous Waste Contractor
When a chemical is determined to be a laboratory waste, it will be removed and transferred to the main accumulation area. At that time, EH&S will determine if the material will be re-used, if it is a RCRA solid or hazardous waste or if the material is non-hazardous.
Acutely hazardous laboratory waste (or p-listed waste, see APPENDIX G) is defined in 40 C.F.R. 261.33 and 310 C.M.R. 30.136. In laboratories at UMass Boston, this type of waste originates from the following sources:
- UNUSED commercial p-listed chemical products
- residue of p-listed chemicals from a spill
- residue and the container from a p-listed chemical
The generic name for these chemicals is listed in Appendix E.
Laboratory workers will be responsible for ensuring that no more than 1L (1 Qt) of acutely hazardous laboratory waste is accumulated at any time in a laboratory. If an accumulation threshold is reached, follow the procedures for pick up of waste material from a laboratory.
All laboratory waste will be labeled with the following information:
*the words "laboratory waste"
*building, floor and room
*date material is ready for removal (pickup request sent)
*general hazard class
All containers of laboratory waste will be labeled immediately when filling begins. Labels are available from EH&S. If a container is too small to hold a label, the label may be placed on a secondary container.
Containers of laboratory waste must be closed at all times with a secure cap, lid or funnel (with attached lid) except when waste is being added or removed. The only exception is for in-line waste collection (described below).
In-Line Waste Collection
"In-line waste collection" refers to any system that automatically collects laboratory waste and is directly connected to laboratory activity. The system may be a piece of laboratory equipment, such as an HPLC, or a repetitive manual motion. Under these types of "systems" a container of laboratory waste does not have to be closed with a cap or a lid however, the system must be constructed and/or operated in a way that prevents any release of laboratory waste into the environment.
- All in-line waste collection systems must have secondary containment in case of accidental overflow.
- All in-line waste collection systems must be attended or periodically inspected by trained personnel to insure that the contents do not overflow secondary containment.
Each laboratory may temporarily hold up to 208L (55 gallons) of laboratory waste or 1L (1 QT) of acutely hazardous laboratory waste. Once containers are full, they must be removed from a laboratory within 30 days. A laboratory may exceed the 55 gallon/1 quart limit by up to 55 gallons for laboratory waste. At no time can the amount of laboratory waste in a lab exceed 110 gallons in total. Should this situation arise, upon monthly PI, or PI designee inspection, the EH&S office is to be notified immediately, so the excess waste can be removed. All containers should be examined each time they are used by a laboratory worker and documented at least once monthly on posted inspection logs.
Laboratory waste shall be stored in a manner that prevents leaks, spills, and releases to the environment. Secondary containers are recommended and are available from EH&S.
Containers of waste must be compatible with their contents. Containers should be segregated by chemical class (see EHS Manual, sec. 3).
When a container is ready for removal, when quantity thresholds have been reached or when material has been designated "excess" in a laboratory, a request for pickup will be forwarded by phone, email, or campus mail to EH&S. EH&S will pick up the material(s) upon request as soon as possible but in no longer than 30 days.
Unused chemicals that are no longer needed in a laboratory will be labeled with a "laboratory waste" tie-on label (available from EH&S), and will be removed with the other laboratory waste.
Material that may be re-used or redistributed comes from the hazardous waste determination made by EH&S at the central accumulation area or may come from laboratory cleanouts. First, to start the program, EH&S sent out pamphlets requesting that PIs look through their chemicals and determine if there materials that they are no longer using. Second, during routine laboratory waste collections, once material is removed from the laboratory, EH&S will evaluate these materials for reuse opportunities on campus. Once there are chemicals available for re-use or redistribution, a list of excess chemicals will be maintained and published by EH&S. Principal investigators or laboratory workers may request excess re-usable chemicals on the list and EH&S will deliver the material to their laboratory. If an excess chemical remains in the EH&S inventory for more than 2 years, the material will be disposed of.
Laboratory waste is not to be disposed of as solid waste. Discharges into the air, land or water are prohibited.
In addition, the Massachusetts Water Resources Authority (MWRA) prohibits the disposal of any of the following items down any sink or drain or any other way that will introduce the materials into the municipal sewage system:
- Any water or wastewater with a pH lower than 5.5 or higher than 10.5
- Any liquid, solid, or gas, including, but not limited to, gasoline, kerosene, naphtha, benzene, toluene, xylene, ethers, alcohols, ketones, aldehydes, peroxides and methyl ethyl ketone, which is a fire or explosion hazard, or is otherwise injurious either alone or by interaction with other substances
- Any noxious or malodorous liquid, solid, gas, or solid, or any other pollutant which either singly or by interaction with any other waste causes a public nuisance, a dangerous situation, or which results in the presence of toxic gases, vapors, or fumes that may cause acute worker health and safety problems.
- Any hazardous waste or any wastewater which results from the treatment of hazardous waste
- Any discharge of mercury, pesticides, or phenanthrene
- Any substance containing pathogenic organisms in such quantities as determined by local, state, and/or federal law as hazardous to the public health or the environment
- Specific substances in excess of predetermined concentrations, as listed in Appendix F.
The University has been issued a Sewer Use Discharge Permit by the MWRA. The permit requires self-monitoring of all laboratory discharges on a quarterly basis. Additionally, at any time the MWRA can conduct sampling. All laboratory sinks are posted with warnings not to discharge strong acids & bases (pH < 5.5 OR > 10.5), mercury and other heavy metals (all mercury-containing compounds) or volatile organic compounds (common laboratory solvents).
Whenever a laboratory changes ownership the UMass Boston Procedure for Laboratory Clean-out of Hazardous Materials (EHS Manual, section 1.4) must be followed.