Chemical and Hazardous Waste Management and Disposal Policy
Authority: Student Affairs
Date Enacted or Revised: Enacted February 2016; Revised March 15, 2022
This policy provides guidelines and expectations for the safe handling, storage, and disposal of chemical and hazardous waste.
Responsibility for Chemical and Hazardous Waste
Faculty and staff are responsible for the administration of safe work practices and procedures in their respective work areas. Faculty and staff working with chemical and/or hazardous waste must coordinate proper disposal of chemical/hazardous waste with the University Police safety officer. The safety officer works with departments and units for the proper storage and disposal of chemical or hazardous waste generated. The following information should provide guidance for safe handling procedures for chemicals and hazardous waste.
The U.S. Environmental Protection Agency (EPA) and the federal and state Department of Transportation regulate hazardous waste handling and disposal. Non-compliance with regulatory requirements can result in significant fines and may compromise safety for the campus environment. The cooperation of all supervisors and personnel is necessary to make laboratories and areas where chemicals are utilized safe places to learn and work. Any questions that are not covered in this document should be directed to the safety officer.
The ultimate responsibility for proper inventory, handling, storage or disposal of chemicals or chemical/hazardous waste materials lies with the dean or similar-level supervisor who has oversight of the faculty/staff utilizing the original substance or material. Any improper management or disposal of materials resulting in additional cost analysis for disposal, additional cost of materials/services for disposal, and any regulatory actions or fines resulting from improper management or disposal will accrue to the responsible college/departmental operating or restricted funds and may impact the ability to procure additional supplies.
Hazardous Materials and Waste Defined
According to the EPA, hazardous waste is any waste that is ignitable (flash point of < 140 F) or corrosive (pH of < 2 or > 12.5). Reactive chemicals, radioactive materials, poisonous materials, carcinogens, biohazards, compressed gasses, toxic chemicals, and infectious items and other specifically listed materials by the EPA are considered toxic or toxic waste. In addition, hazardous wastes may include byproducts and wastes from chemical reactions or unwanted commercial products and chemicals. Hazardous waste determinations are not always straightforward; therefore, the safety officer may assist with guidance for handling and proper disposal.
Material Safety Data Sheets (MSDS) or Safety Data Sheets (SDS) Required
Material safety data sheets (MSDS) or safety data sheets (SDS), which may be found online and printed out from the manufacturer of the material or chemical, are a good source of information for determining whether a particular material meets criteria to be designated as hazardous. MSDSs/SDSs must be accessible and available in laboratories or other spaces that store or utilize chemicals. All chemicals must be labeled properly and stored properly in appropriate containers. Deans are responsible for assigning duties for maintaining the MSDS/SDS sheets for each lab in the academic colleges; supervisors of non-academic units that deal with hazardous materials or waste are responsible for assigned duties for maintaining the MSDS/SDS sheets for each space where hazardous materials or waste is present.
Disposal of Hazardous Waste
Hazardous waste may not be disposed of in the trash or drain. Hazardous waste must be collected, submitted to University Police, and shipped to a permitted treatment, storage, or disposal facility. Improperly managed hazardous waste can present a safety hazard to the campus, students, and employees; create a physical hazard to plumbing and buildings; and create an environmental hazard should releases occur to the air, ground, or water.
Hazardous Waste Accumulation and Storage
The following are general guidelines for accumulating and storing hazardous waste. More detailed information is available from the safety officer.
- Material Safety Data Sheets/Safety Data Sheets (MSDS/SDS) must be accurate and maintained in a designated place in any area containing chemicals or hazardous waste.
- Appropriate personal protective equipment (eye protection, gloves, aprons, etc.) must be worn when dealing with chemicals and hazardous materials or hazardous waste.
- Hazardous waste should be stored near the point of generation or in the lab in which it is generated. Waste should be consolidated in one place in the lab—not spread out in several different cabinets and countertops.
- A single hazardous waste accumulation area is appropriate for a suite of labs under the supervision and control of the same supervisor.
- All lab occupants must be familiar with the activities/experiments of the lab.
- Hazardous waste should not be removed from the labs or room.
- Waste material must be compatible with the collection container (e.g., corrosives must not be stored/collected in metal containers). When possible, plastic containers are preferred to glass, as they are less likely to break if knocked over. If a particular waste is generated on a fairly large scale, as with some solvents, a 2½ gallon plastic container may be appropriate for collection.
- Only similar wastes should be collected in the same container. Mixing incompatible or different types of wastes may cause a chemical reaction or greatly increase disposal costs. It may be necessary to have different waste containers accumulating materials (e.g., one for non-chlorinated flammable solvents, another for acids, etc.).
- All chemical/hazardous waste must be collected in tightly closing, leak-proof containers that must be kept closed except when adding waste. Stoppered glassware or beakers are not appropriate waste collection containers. Waste must be collected in appropriate containers, and collection containers may not be left open or open with funnels. Waste may not be deposited into Contraband Bayou.
- Hazardous waste containers must be labeled with the words “Hazardous Waste” in addition to the specific chemical contents.
- The label must list the specific contents (e.g., flammable solvents – acetone, hexane, etc.).
- Chemical names must be completely spelled out; abbreviations or chemical structures are not in accordance with regulations.
- If empty commercial chemical containers are used to collect waste, the old chemical label must be obliterated and a new label affixed to the container to avoid possible confusion as to the contents.
- Only the safety officer is authorized to remove chemical or hazardous waste with appropriate notification from the employee responsible for the MSDS/SDS sheet.
- Waste containers and any chemical container must not be stored in a location where a spill could potentially cause a release to the environment. Containers should not be stored next to sinks and ideally not in hoods with sinks. Containers should not be stored on the floor where they can be kicked over, particularly in rooms with floor drains.
Laboratory Chemical Inventories and Housekeeping
For safety reasons, the chemicals on-hand in the laboratory should be limited to those actually in use or planned for use during the semester or term of the experiment or instruction. Chemical inventories must be taken each semester or session and unwanted, unneeded, or duplicate chemicals must be removed by the safety officer. Reviews each semester should include monitoring all containers for good condition and clear labels and taking corrective action if necessary and a reconciliation of the MSDS/SDS sheet.
Every laboratory/work area is subject to inspection by the Environmental Protection Agency (EPA) or safety officer. In order to be compliant with EPA rules, the following steps by supervisors of laboratories are required:
- Weekly inspections, with notification to the safety officer regarding removal of hazardous materials or waste when necessary;
- Segregation and containment of wastes in proper containers;
- Storage in separate containers for different types of waste; and
- Closed containers.
Deans, department heads, and supervisors share responsibility to ensure students and faculty/staff properly dispose of any wastes or residuals from their work. Deans, department heads, and supervisors must ensure faculty/staff properly dispose of any wastes or residuals prior to the faculty/staff leaving the University. Deans must supervise and designate appropriate personnel to act as the safety officer liaison for handling and removal of chemicals or hazardous waste and ensuring complete compliance for safety and safe handling of chemicals and/or hazardous waste.
The safety officer will conduct periodic inventories (at least annually) and review compliance for handling and storage of chemicals or hazardous waste. The safety officer liaison works collaboratively with the safety officer regarding inventory and policy requirements.
Removal of Chemical Waste
Chemical or hazardous waste must be removed as soon as possible in accordance with EPA and expectations outlined in this policy. Safety officer liaisons responsible for proximate work labs or areas or similar disciplines coordinate disposal of chemicals in order to ensure efficient use of supplies.
The safety officer liaison must notify University Police to arrange for disposal of chemical or hazardous waste material. A Chemical/Waste Disposal Form must be completed and the composition of the waste and quantity and size of containers must be noted. Waste components must be listed on the form along with approximate percentages of each component (e.g., methylene chloride 50%, water 50%). The original Chemical/Waste Disposal Form must be sent to University Police (safety officer), and a copy of the form must be attached to the waste container. If a large number of different wastes are being disposed, a list that includes all the pertinent information from the Chemical/Waste Disposal Form may be submitted.
When it is necessary to dispose of chemicals, all containers must be in good condition, sealed tightly, free of spillage on the outside of the container, and clearly labeled for transport. The safety officer liaison must contact the safety officer to schedule removal/disposal. The safety officer will remove the waste from the lab.
Radioactive waste handling is strictly regulated by the Federal Nuclear Regulatory Commission. Contact the safety officer for information about the procedure for proper collection and disposal procedures.
Storage and Chemical/Hazardous Material Inventory Management
- A written current chemical inventory shall be maintained for each campus location that stores/uses hazardous chemicals.
- The inventory list should include the location where the material is stored, the material name, manufacturer, CAS#, quantity, major characteristic (e.g., flammable, corrosive, toxic, reactive), and expiration date.
- The inventory should be checked on a bi-annual basis for each location. In addition to the departmental responsibility for maintaining inventory, the safety officer will conduct periodic inventory audits.
- Copies of the current inventory and location of chemicals should be provided to the safety officer and University Police each semester.
- Disposal arrangement for outdated chemicals or chemicals approaching end of shelf life should be done at the time of inventory.
Laboratory Supervisors/Safety Officer Liaison Responsibilities
- As designated by the dean, serves as safety officer liaison.
- Designs and conducts laboratory processes and operations to assure that personnel exposure to risk is minimized according to safety policies.
- Responsible to ensure appropriate safety procedures are followed and appropriate equipment is utilized by laboratory or work area occupants.
- Completes MSDS/SDS and maintains accuracy of information.
- Monitors the procurement, safe use, and proper disposal of chemicals and/or hazardous materials.
- Schedules with the safety officer hazardous waste disposal and oversees the handling of hazardous waste pending proper disposal.
- Completes and updates annual laboratory chemical inventories as required.
Safety Officer (University Police) Responsibilities
- Conducts periodic inventory of laboratory chemicals.
- Serves as a resource for chemical/hazardous waste handling, storage, and disposal.
- Removes hazardous waste when notified by safety officer liaison.
- Maintains contact with EPA and appropriate regulatory agencies and ensures policy is updated accordingly.
General Safety Guidelines for Faculty/Staff Dealing with Hazardous Materials or Chemicals
- Label all storage area and chemical properly.
- Use fume hoods whenever possible.
- Be familiar with safe procedures regarding materials.
- Be informed about the MSDS/SDS available for all chemicals in laboratory areas.
- Wear proper eye protection.
- Wear protective clothing to protect against spills/splashes.
- Wear gloves when appropriate.
- Consider other protective equipment (head protection, hearing protection, respiratory, foot protection, etc.).
- Wash hands before leaving laboratory.
- Keep exposed skin covered.
- Avoid leaving long hair loose and wearing loose clothing, especially in close proximity to flames and operating machinery.
- Never use mouth to pipette chemicals.
- Follow fire prevention safety (store flammables in appropriate cans; do not story incompatible chemicals together; do not store flammables in standard refrigerators, etc.).
- Report any compliance or other issues to the safety office liaison, safety officer, and dean immediately.
This policy is distributed via the Administrative Advisory Council and the University Policies webpage.