CHEMICAL/HAZARDOUS WASTE CHECKLIST
FOR EPA COMPLIANCE

• Is your laboratory or area of responsibility neat and orderly?

When things look messy, EPA considers this a "visual clue of possible non-compliance warranting further inquiry."

• Do you have a designated area in your laboratory or room for storage of waste? (These are called Satellite Accumulation Areas)  Is your designated area posted with a sign?

Look for an area in your laboratory or room that can be designated as your waste storage area.  (More than one designated area is allowed).  Signs with a list of some reminder procedures must be posted.  (Call the Environmental Health and Radiation Safety (EHRS) Department if you need a sign).

• Is your waste labeled with the "Chemical/Hazardous Waste" tag and labeled with the name of the chemical(s) and approximate percentages, if a mixture? Put the name of the chemical(s) on the tag when the waste is first placed into the container.

The Griffith Hall and McNeil Science and Technology Center central stockrooms have these pre-printed tags available.
Leave date field on tag blank until just before disposal. Hazardous waste must be labeled with the words "hazardous waste." Therefore, use the tags.
No abbreviations or formulas are allowed.
(i.e., unacceptable: waste HCL
              required:  hazardous waste - hydrochloric acid)

• Are all waste containers kept closed at all times unless adding or removing waste? (This includes biohazard waste)

No open containers are allowed anywhere (i.e., laboratory, fume hood, storage area).  Do not store waste in open beakers or flasks.  Open funnels must be removed from the bottles unless actively pouring waste. However, the new sealable funnels attached to bottles are acceptable.  Parafilm is also not allowed.  The EPA considers an open and improperly labeled waste container a serious violation.

• Do waste bottles that have collection tubes in place (i.e., from lab instruments) have a hole in the bottle cap JUST large enough for the effluent tube?

This will allow you to keep the collection tube in place, even if the instrument is not running. Also, store this waste container in a tub. If there is not a small hole in the cap, make sure the tubing is removed and then the container sealed with the cap as soon as you are no longer adding waste to the container. (Special caps with holes are available in the Griffith Hall Central Stockroom.)

• Do you make sure that full hazardous waste containers do not sit around in the laboratory or facilities area too long? Three days is the limit for full containers.

When the hazardous waste container is full, date the tag and then move the waste to the Griffith Hall or McNeil Science and Technology central stockrooms within three days of that date. Add the date just before pick-up. However, make sure that once it is dated, it gets moved to the stockroom within the three days. Call the stockroom to let safety know (Griffith Hall at X8843) (STC at X3141) or bring it down to the stockrooms if you have been trained on how to transport properly or if you have had annual laboratory safety or hazard communication training. If the hazardous waste container is not full, it may remain in your satellite accumulation area, as long as you have not accumulated too much waste in the laboratory or room and it is closed, stored and labeled properly. However, waste must never be stored for longer than one year. Also, if the waste is moved to a nearby room, (separate from the point of generation) then it is not considered in satellite accumulation and is subject to more stringent requirements. Do not do this.

• Is the date field on the chemical/hazardous waste tag blank?

Again, do not date the tag until the container is full and then move the waste to the Griffith Hall or McNeil Science and Technology Central Stockrooms within 3 days of that date.

• Is your chemically incompatible waste separated?

Use tubs that are available from the stockrooms to keep containers of incompatibles separated. Separate the containers, but also never place incompatible wastes in the same container.

• Are hazardous waste containers in secondary containment?

Store your waste containers in tubs. This is important to contain leaks or spills, to separate incompatible wastes, and especially when chemicals are stored near a drain or sink.

• Are waste containers in good condition, free of deterioration, and not leaking?

• Are waste containers compatible with the hazardous waste stored within them?

Always try to store waste in plastic containers rather than glass, if compatible.
i.e., Never put corrosives in metal containers.

• Never put hazardous waste down the drain.

Unless approved by EHRS, disposal of hazardous chemicals by way of the sanitary sewer system is not permitted.

• Are your sinks clear of beakers, flasks, bottles, etc. that contain chemicals, or look as if they contain chemicals?

EPA will assume that hazardous chemicals are going down the drain.

• Are you sure that there are no dusty, rusty, crusty, expired, unclaimed, or abandoned chemicals, or old peroxide-former and reactive chemicals in your area?

These will be considered waste-like by the EPA and if not tagged, labeled, sealed and stored as waste, they will be in violation of the regulations. Some of these are also a potential hazard.

• Are beakers and flasks which contain residual materials, cleaned out or labeled properly with chemical names?

  These will also be considered waste-like by the EPA if not cleaned out or labeled and sealed properly.

• Did you check that your shelving and storage areas are not crowded, unsafe or corroded?

• Are all substances in your laboratory labeled properly with full chemical names?

• Do you separate hazardous wastes from non-hazardous wastes?

Never place these in the same container.
Volumes of hazardous waste will increase subjecting us to increased regulatory requirements and costs. To determine if the chemical is a regulated hazardous waste, contact the EHRS Department or consult EPA regulation 40 CFR 261. You may also visit the EHRS Department's web site for the EPA hazardous waste list by clicking on the link below. Then link to EPA's Hazardous Waste List. (http://www.usip.edu/safety/policies/EPAcheck.htm)

See EPA's Hazardous Waste List.

• Is everyone in your laboratory or area of responsibility thoroughly aware of emergency procedures and proper waste handling procedures relevant to their responsibilities?

 Examples of emergency procedures include spills or leaks, injuries or illnesses, fire and accidental chemical exposure.  (The EPA will conduct interviews with faculty, staff and students during their inspections of the University).

• Has everyone who is responsible for generating or handling hazardous waste or transporting hazardous waste to our stockrooms completed annual laboratory safety training (for laboratories) or Hazard Communication training (for other areas)?

We have classroom training, or safety discussion guides and our new web-based training modules to meet these requirements.  Laboratory directors must make sure that employees and students in their laboratories comply with these hazardous waste policies in their daily operations.

Examples of Questions that EPA Inspectors May Ask Personnel and Students.

What type of waste do you generate?  Simply name the chemicals or classes of wastes.  (i.e., hydrochloric acid or corrosives)

What are you doing with your hazardous waste? EPA is determining if you are handling and disposing of it properly.  (e.g., checking that you are not putting it down the drain;  making sure you are aware that the waste must be stored in compatible containers, separated from other incompatible wastes and that you are disposing of the waste through the EHRS Department).

Where are you storing your hazardous waste? Show your designated waste storage area(s).

How do you dispose of it?  Bring to the EHRS Department Stockrooms in a secondary container or on a cart.

What do you do in an emergency? i.e., spill:

1)  contain it, so it doesn't go into a drain, etc.
2)  secure area,
3)  call supervisor, and
4)  call safety and/or security.

   (Be prepared, have spill control materials nearby.)

Where are your MSDS's? Know the locations in your area. Also, a master set of all University MSDS's are stored in the Griffith Hall Central Stockroom, room #B-10. A web-based MSDS program is available at (http://usp.edu/safety/msds.shtml), or link from the EHRS website for generic and manufacturer's MSDS's.

If you have any questions regarding hazardous waste handling procedures or emergency procedures, please do not hesitate to call the EHRS Department. (X8925, X8843 or X3141)