Hazardous Waste Management Program UW Superior Environmental Health and Safety Program March 2012

In the wake of the environmental problems at Love Canal, Congress enacted the Resource Conservation and Recovery Act (RCRA) to ensure that hazardous wastes are properly managed and to prevent health and environmental risks in the future. At the federal level, the Environmental Protection Agency (EPA) enforces the RCRA regulations. In Wisconsin, the authority to regulate hazardous wastes has been delegated to the Wisconsin Department of Natural Resources (DNR) by the EPA. The regulations apply to all industries and businesses, including higher education institutions.

If you use chemicals or chemical-like products, you could be a generator of hazardous wastes. For the purpose of this program, the terms chemicals or chemical-like products includes any material not intended for human consumption, including office or cleaning products, batteries, electronic equipment, treated lumber, lab chemicals etc. The purpose of this written program is to help you identify and manage your hazardous wastes in an environmentally sound manner and within the law. The citizens of Wisconsin expect nothing less from a great public institution and the proper management of hazardous waste sets positive examples of environmental stewardship for our students.

The Environmental Health and Safety Office is responsible for hazardous waste management at UW Superior. If you have any questions about the wastes you generate, please contact the Environmental Health and Safety office for assistance, ext. 8073.

Wastes and Hazardous Wastes

Within the complexity of the hazardous waste regulations, a very broad definition is applied to the terms "wastes" and "hazardous wastes." The legal definition of a waste may be substantially different than your definition. It is important that you always apply the following definitions used by the regulators to be in compliance with the laws:

Waste: Any solid, liquid or gaseous substance that: o can no longer be used for its originally intended purpose because it has become contaminated or has been used in some process, or o any material that is still useable, but which you decide to discard. o The definition includes anything that is contaminated, degraded, out-dated, off- specification, spills or spill clean up materials o EPA’s broad interpretation of a waste includes anything that has not been used in a timely manner. (e.g. unopened products in storage for more than 3-5 years). o Examples: trash, recyclables, chemicals, cleaning products or construction debris

Hazardous Waste: A material that meets the definition of a waste, and is listed in one of the tables of the hazardous waste regulations, or a waste that has one or more of the specific characteristics identified in the regulations, such as acutely toxic, toxic, ignitable, corrosive or reactive. The regulations and the definitions will be explained in more detail later in this written program.

Examples: flammable solvents, poisons, brush cleaners, rechargeable batteries

Hazardous Waste Management Program, Revised March 2012 page 1 Universal Wastes: The universal waste standard is a subset of the hazardous waste regulations intended to ease the regulatory burden on specific wastes by permitting proper recycling or treatment. Universal wastes are not subject to the full hazardous waste regulations unless a spill, breakage or mismanagement occurs. The management practices for universal wastes have incorporated in this program.

Other Wastes that Require Special Management Practices

Some hazardous materials do not meet the legal definition of a hazardous waste, but are covered by other laws and regulations and are banned from discharge to the air, sanitary sewers or municipal landfill. Examples include Freon, nickel, and zinc containing substances. Even though they do not meet the definition of a hazardous waste, UW Superior will manage these materials using collection and disposal procedures similar to those for hazardous wastes.

Where Do Hazardous Wastes Come From?

All departments at UW Superior have at one time generated hazardous wastes, including:

. laboratories . research . art studios & theater . residence halls . education department . maintenance activities . library . offices . academic activities . construction and renovation projects . technology . health services

Examples of wastes that require special disposal procedures are listed below (this list is not complete). Not all of the wastes would be considered hazardous wastes, but special management practices are necessary for all of them.

Acids Solvents Outdated chemicals or products Bases (alkali's) Paints Toxic chemicals & mixtures Oxidizers Light bulbs Unknowns (no labels or contents) Formaldehyde Aerosol cans Environmental samples Mercury thermometers Brush cleaners Biohazard waste and Sharps containers Photo chemicals Paint thinners Automotive fluids Non-alkaline batteries Paint strippers Infectious Materials

Hazardous Waste Management Program, Revised March 2012 page 2 How Do You Know When Special Disposal Methods are Needed?

You don't have to be a scientist to determine whether or not your waste requires special management, and you do not need to make the determination alone. Here are a few simple steps that anyone can do:

 Check the procedure for precautions or special guidance on disposal.

 Watch for clues. Clues that a material could require special disposal procedures might be found just by reading the container label or the material safety data sheet. Examine the product label for the "buzz" words shown below or symbols that indicate a hazard.

Warning Danger Water Reactive Dangerous When Wet Corrosive Acid Alkaline Hydroxide Poison Toxic Oxidizer Radioactive Flammable Combustible Compressed Gas Biohazard

 Check the Material Safety Data Sheet (MSDS). Read the MSDS for important safety information before using any chemical-like product. The MSDS will include helpful data on the pH, flash point, stability and toxicity of the substance.

 Contact the EH & S office for help – ext. 8073. You can also access the regulations and the lists of hazardous wastes at the EH & S web site: http://www.uwsuper.edu/ehs/envmanag/index.cfm

Hazardous Waste Regulations

The University of Wisconsin-Superior is subject to the same rules and regulations that affect businesses and industry, including the hazardous waste regulations. The Wisconsin legislature has created a state version of the RCRA regulations, which are found in Chapter NR 600-690 of the Wisconsin Administrative Code. The regulations define hazardous wastes as wastes that are either listed in the tables of the regulation, or if it contains a defined characteristic (i.e. ignitable, corrosive, reactive or toxic) that makes the waste hazardous. The defined wastes will be assigned a "code" consisting of a prefix letter and a three-digit number.

The Chancellor has assigned the authority for hazardous waste management to the UW Superior Environmental Health and Safety (EH & S) Director. All decisions for hazardous waste disposal and management must be coordinated with this office. The regulations are complex and the campus has many obligations to comply with, including recording keeping, manifesting, inspections, paying fees and high liability for environmental damage. The program will be successful only if all employees work cooperatively towards the same goal.

Individual generators are not expected to have a full understanding of the hazardous wastes regulations and are not required to classify the wastes they generate. The Environmental Health and Safety (EH & S) office will evaluate all wastes to determine the proper classification for the waste and then arrange for disposal. The campus has an obligation to accurately describe all wastes using either documentation of what was added to the container or through chemical analysis. To assure that the information is available to make this determination, a waste container inventory will be prepared by the generator. Hazardous Waste Management Program, Revised March 2012 page 3 The tables and characteristics of hazardous wastes found in the hazardous waste regulations are briefly described below. Additional information can be obtained by calling x-8073, or can be found on the Environmental Health and Safety website at: http://www.uwsuper.edu/ehs/envmanag/index.cfm

The Hazardous Waste Identification and Listing Tables (Chapter NR 661, Wis. Admin. Code)

F-Listed Wastes Waste mixtures from non-specific sources (Table in NR 661.31 [p. 29 in code]) are assigned an F-Code Example: a mixture of xylene, acetone (F003).

K-Listed Wastes: Wastes from specific industrial sources (Table in NR 661.32 [p. 32 in code]) are assigned a K-Code. K-listed wastes are not generated at UWS.

P-Listed and U-Listed waste tables (NR 661.33 [p. 38-55 in code]) are used only for unused commercial chemical products, or when a material contains a sole active ingredient that is listed in the tables, or any spills involving P-listed or U-Listed substances.

P-Listed wastes: Substances that are considered Acutely Hazardous are assigned a P-Code. Examples: Cyanides (P030), sodium azide (P105), or warfarin (P001). Please see the section on Problematic Wastes on page 5.

U-Listed wastes: Substances that are considered toxic are assigned a U-Code. Examples: Formaldehyde (U122), phenol (U188), acetone (U002), xylene (U239).

The Hazardous Waste Characteristics (Chapter NR 661, Wis. Administrative Code)

When wastes are mixtures or result from a process (not commercial compounds), the characteristic of the waste is the primary concern. The hazardous waste characteristics defined in the regulations are:

An ignitable waste is: [NR 661.21, p. 28 of the code] o Any liquid with a flash point < 140 F, or o Any substance that can cause fire thru friction, absorption of moisture, or o A compressed gases (includes aerosol cans), or o An oxidizer

A corrosive waste is: [NR 661.22, p. 28 of the code] o Any waste with a pH < 2 or > 12.5 o Note: Sanitary sewer ordinances require that all materials disposed of via the sanitary sewer have a pH > 5 and < 9.5. o The pH of a substance is a measure of its acidity or alkalinity. pH can be measured using a meter, indicator solutions, or pH paper.

A reactive waste is: [NR 661.23, p. 28 of the code] o Any substance that is unstable or reacts violently with water o Any substance that generates toxic gases or vapors when mixed with water o Any substance that contains sulfides or cyanides that creates toxic gases under corrosive conditions o Any substance that is capable of detonation or explosion at room temperature and normal atmosphere, or when subjected to a strong initiating source or heated under confinement, or is a DOT forbidden, Class A, or Class B explosive.

Hazardous Waste Management Program, Revised March 2012 page 4 TCLP Toxic: The TCLP test (Toxic Characteristic Leaching Procedure) is a special analysis conducted on a waste that determines if certain toxic substances could leach from the waste in concentrations that will affect the environment. If you suspect that your wastes contains any of the following, you should manage the waste as a hazardous waste until the EH & S department can make a more detailed evaluation or analysis. [Table 2, NR 661.24, p 28 of the code]

Metals: Arsenic Barium Cadmium Chromium Lead Mercury Selenium Silver Note: Sanitary sewer ordinances prohibit nickel and zinc solutions.

Organics: Benzene Carbon Tetrachloride Chlorobenzene Chloroform Cresols 1,4-Dichlorobenzene 1,2-Dichloroethane 1,1-Dichloroethylene 2,4-Dinitrotoluene Hexachlorobenzene Hexachloro-1,3-butadiene Hexachloroethane Methyl ethyl ketone Nitrobenzene Pentachlorophenol Pyridine Tetrachloroethylene Trichloroethylene 2,4,5-Trichlorophenol 2,4,6-Trichlorophenol Vinyl chloride Note: Sanitary sewer ordinances prohibit disposal of solvents, paints, oils and grease

Pesticides: 2,4-D or restricted use or banned pesticides like Chlordane, Endrin, Heptachlor, Lindane, Methoxychlor, Toxaphene, or 2,4,5-TP (Silvex).

Superior Municipal Sewer Code: Materials discharged to the sewer at UW Superior are regulated by the City of Superior Municipal Code of Ordinances sewer code (Sec. 114.26). This code prohibits drain disposal of the following: Contaminant Max Conc. Contaminant Max Conc. 5-Day BOD 300 mg/l Arsenic 0.0083 mg/l Total Suspended Solids 750 mg/l Cadmium 0.0057 mg/l Phosphorus 12.5 mg/l Chromium 1.2480 mg/l Oil and Grease 50.0 mg/l Copper 0.1112 mg/l Chloroform* 10.0 mg/l Lead 0.1070 mg/l Cyanide* 0.0208 mg/l Mercury 0.000055 mg/l Nickel 0.0520 mg/l Zinc 0.5800 mg/l

. Liquids/vapors having a temperature higher than 150º F. . Fats, wax, grease or oils, whether emulsified or not, in excess of 50 milligrams per liter or substances which may solidify or become viscous at temperatures between 32 - 150° F . Strong acids, iron pickling wastes, or concentrated plating solutions whether neutralized or not. . Any flammable liquid, including but not limited to gasoline, naphtha, benzene or fuel oil . Liquid wastes containing phenols, cyanide or chloroform . Radioactive wastes or isotopes . Liquids or wastes having a pH < 5.5 or a pH > 9.5. . Solid or viscous substances including but not limited to, ashes, cinders, sand, mud, straw, shavings, metal, feathers, tar, plastics, wood, unground garbage, whole blood, and entrails. . Inert suspended solids such as, but not limited to Fuller's earth, lime slurries, clay, sawdust

UW Superior will manage any material that is prohibited in the sanitary sewer, air or landfill using the procedures similar to those used for managing hazardous wastes.

Hazardous Waste Management Program, Revised March 2012 page 5 Problematic Wastes at UW Superior

Wastes aren’t just used materials for disposal—wastes also include materials that no longer have a useful purpose and old unused materials. Some of these wastes are problematic due to specific regulatory requirements or expensive disposal costs. Consult with the EH & S office and review MSDSs and product literature prior to purchasing, receiving or accepting donations of anything that may become a problem waste now or in the future. The following are examples of problematic wastes that have been generated by UW Superior:

o The most common problematic wastes at UW Superior are P-Listed wastes (acutely hazardous wastes). UW Superior must never exceed a total of 2.2 pounds (approximately 1 quart) of P-listed wastes. Exceeding this quantity places greater regulatory demands on the campus and increases the cost of managing our hazardous wastes approximately 4-fold. Past generation of P-listed wastes have included compounds or products containing cyanides, 2,4-dinitrophenol, sodium azide, certain pesticides, and tri-, tetra- or pentachlorophenol compounds, such as pentachlorophenol or 2,4,5-trichlorophenol. Prior to purchasing substances that may become a P-listed waste, contact the EH & S office to discuss purchase and waste management practices so the impact upon the campus can be minimized.

o PCB-containing wastes are very expensive for disposal and subject to additional regulatory requirements beyond the hazardous waste regulations. PCBs should never be used on campus without PRIOR approval by the EH & S office.

o Any waste, chemical, object or product with radioactive properties may require additional regulatory requirements. The disposal of such materials is cost prohibitive and any use or receipt of such materials should FIRST be reviewed by the EH & S office.

o Any material accepted as a “donation” is likely to become a problem waste. Prior to accepting a donation, find out all of the details about the instrument, product or chemical and then consult with the EH & S department prior to accepting the item. A strategy for use of the equipment or material needs to be in place, and your department must be willing to pay for disposal should it not meet the department needs once it is accepted.

Hazardous Waste Management Program, Revised March 2012 page 6 Generators of Hazardous Wastes

If you conduct a process that creates a hazardous waste, the hazardous waste regulations consider you a "Generator" of hazardous wastes. Generators are not expected to have a full understanding of all of the hazardous wastes regulations, but are required to fulfill some simple, but specific responsibilities.

Generator Responsibilities

 The generator is responsible for the waste until it is removed by EH & S department.  Recognize when a waste requires special disposal practices or when to ask for assistance.  Evaluate all procedures to determine if the waste can be minimized.  Contact the EH & S department prior to starting a new process that will generate a quantity of waste or type of waste that has not been generated in the past by your department.  Keep all waste containers in a secure area and under your control at all times.  Use containers that are in good condition and compatible with the waste.  Keep the lid on the waste container except when adding waste.  Label all containers with the words "Hazardous Waste", the primary hazard of the waste (i.e. flammable, corrosive, etc), and the date that waste is first added to the container.  Keep an inventory of what has been added to the container, by whom, and when.  Email the EH & S office to request a pick up within 3 days of the date that the container becomes full.  Regularly inspect the waste containers for leaks, spills and signs of deterioration.

Students can assist the generator with hazardous waste management, and proper management practices can be a valuable part of the curriculum. However, the generator responsibilities should only be assigned to regular full or part time employees because of the long-term responsibilities the campus has regarding hazardous waste management.

Satellite Accumulation

Waste that is collected and stored at or near the location that the waste is generated is called "satellite accumulation." The regulations permit the campus to generate, collect and store wastes at the satellite accumulation sites to promote efficient waste management as long as certain requirements are met:

o The wastes are stored in a secure location near the point of generation, such as a cabinet, and kept under the control of the person who generates it (the generator). o Up to 55 gallons of hazardous waste, and not more than 2.2 lbs. (approx. one quart) of acutely hazardous waste can be stored in the satellite location. o The EH & S office is contacted to remove full containers of wastes within 3 days that they become full. o The generator regularly inspects the satellite collection site and ensures that there are no spills, that the container is properly labeled and always kept closed except when adding wastes, and that the contents match the inventory sheet for the waste container.

Hazardous Waste Management Program, Revised March 2012 page 7

Managing Wastes in Satellite Locations

Question: Who is responsible for managing wastes at the site of generation? Answer: The GENERATOR! The steps the generator must complete will be found in this section.

Managing a waste is always easier if a few minutes are spent evaluating the procedure and the wastes it will generate BEFORE starting the process. With a little practice, this should only take a few minutes, and it can actually save time because the wastes can be managed as they are generated.

Step 1. Evaluate the wastes that will be generated Review the procedure and determine what wastes and how much will be generated at each step. The common wastes include left over raw materials, mixtures of the ingredients, outdated materials, new materials created during the procedure, and the end product. Each waste must be evaluated to determine proper disposal methods. Utilize label information, hazardous waste tables, known characteristics of the wastes, previous experiences, literature, and material safety data sheets to determine if the wastes generated during the process will require special management practices. Also consider the following: Is the procedure necessary? Will it add value to what you are trying to accomplish? Is a full batch needed or will a partial batch do? Is there an alternative method or material that generates less waste but is just as effective for your needs? Generally, the alternative methods are safer too. Purchase only what will be used within a short period of time (less than 2 years) or borrow from another department on campus. Buying in bulk sounds like a good idea, but most items become obsolete long before they are used up. The cost of disposal for obsolete materials is usually much greater than the original cost of purchase.

Step 2. Segregate and containerize wastes as they are generated

Once the type and quantity of each waste is determined, prepare the waste containers and labels that will be needed. Transfer wastes to labeled containers as the wastes are generated. Use separate containers for wastes from different processes and for wastes with different hazards. This may result in a few extra containers, but it can save the campus hundreds of dollars in disposal costs. Storage containers, labels and guidance on segregating wastes are available from the EH & S office.

It is especially important to segregate: PCB containing materials Mercury containing wastes Acutely hazardous wastes Chlorinated and non-chlorinated solvents Non-hazardous and hazardous wastes Phenolic compounds containing 3 or more chlorines Hazardous Waste Management Program, Revised March 2012 page 8 Step 3. Maintain a container inventory

The campus has an obligation to accurately describe all wastes using either documentation of what was added to the container or through chemical analysis. To avoid costly analyses, generators will prepare a waste inventory for every waste container and have the inventory available at the time the waste is picked up by EH & S. The inventory should include what was added to the container, when and by whom, and the concentration of the substance. The generator may prepare their own inventory form, or use the prepared form available from the EH & S program.

Step 4. On-Site Treatment

On-site treatment is considered any activity that is intended to either render the waste less hazardous or to reduce the volume of waste for disposal. Only a few on-site treatment methods can be conducted without a special treatment license from the Wisconsin Department of Natural Resources:

1. Elementary neutralization of acid or base (alkaline) solutions is permitted and encouraged. Elementary neutralization is the responsibility of the generator. o The acid or base waste solutions must not have any other hazardous contaminants. o Solutions should be neutralized to pH 5.5- 9.5 and flushed down the sanitary sewer followed by 20 volumes of water. o Keep a log of elementary neutralization, including dates and volumes. Submit the log to the EH & S office for inclusion in the annual DNR report. o Indicator solutions, test paper or a pH meter may be used to measure pH. o Be sure to neutralize solutions in a laboratory hood or well-vented area and wear chemically resistant gloves, an apron, goggles and faceshield.

Due to their high reactivity or low solubility with water, do not neutralize the following: . Acid anhydrides and chlorides . Fuming Nitric Acid . Liquid halides of boron, silicon, tin, titanium and vanadium . Liquid halides & oxyhalides of phosphorus, selenium, chromium, vanadium & sulfur . Chlorosulfonic Acid . Fuming Sulfuric Acid

2. Precious metal recovery for recycling (i.e. silver, gold, platinum, etc). Examples include recovering silver from fixer solutions used in photo processing.

3. The following are illegal hazardous waste treatment activities. DO NOT: o Evaporate hazardous wastes to reduce its volume or properties. o Intentionally dilute wastes to make them non-hazardous o Place hazardous waste in the trash or sanitary sewers

All other treatment methods must have prior approval of the EH & S office. The EH & S office will work with individuals to seek licenses for treatment procedures if the process can be conducted in a safe and environmentally sound manner.

Step 5. Call EH & S to remove full waste containers – ext. 8073

The EH & S office is responsible for the waste after the waste has been picked up. The generator should remain available to answer questions about the waste until all wastes have been disposed of.

Hazardous Waste Management Program, Revised March 2012 page 9 Services Available from the Environmental Health & Safety Office

The EH & S office will help you meet your responsibilities by providing advice on waste disposal options and management, suggestions on waste minimization, and supplies to manage your wastes. Labels, containers, pH paper, and inventory forms are provided free upon request. (7 day notice please).

Waste containers must be removed from your site when they become full, and at least once per semester is recommended. Generators should contact the EH & S office to arrange for a pickup.

Before EH & S will remove a container from the satellite accumulation site:

Containers and Labels

Labels

All containers must be labeled with:

 The words “Hazardous Waste” or other words that identify the contents of the container.  The date that waste was first added to container  A description of the waste  The hazard warnings that describe the primary characteristic  Remove or cover all old labeling to avoid confusion.

The Environmental Health and Safety office will

provide suitable labels for the collection of all hazardous wastes on campus. (A 7-day advance notice is requested). Generators can also prepare their own labels if desired.

Hazardous Waste Management Program, Revised March 2012 page 10

Waste Containers

Guidelines on the selection and use of waste containers:

 Each container must be 5 gallons or less in size. Keep the container size as small as needed.  All containers must be compatible with the wastes that they will hold.  Containers used for liquids should have a tight closing, screw-on lid.  Make sure all containers are tightly closed (sealed) at all times, except when adding wastes.  Used containers must be cleaned before re-use to prevent undesired chemical reactions.  Follow the guidelines for properly labeling the waste containers.  Remove or cover all old labeling to avoid confusion.  Generators should inspect all containers weekly for leaks and signs of deterioration.  Place another container under the waste container when spills or leaks could enter a drain or otherwise pose a risk, or when moving wastes from place to place.  Beakers, cans, tubs or flasks are not suitable containers for managing hazardous wastes.  Do not use food containers such as milk bottles, soda bottles, whipped topping containers, coffee cans, etc.  Never fill a container completely full - always leave some space for expansion due to temperature changes and for handling.  Suggested containers for hazardous wastes: Liquids: glass or plastic bottles with tight closing, screw on caps Solids: sturdy rigid containers like plastic pails. Dry solids: double-bagged with sealed plastic bags placed inside of cardboard boxes.

 In addition, use your knowledge of the specific incompatibilities of your chemicals to make a good container selection.

The Environmental Health and Safety office will provide containers for the collection of hazardous wastes on campus. (A 7-day advance notice is requested). Generators can also re-use suitable clean, empty containers that have previously held chemicals or other materials.

Hazardous Waste Management Program, Revised March 2012 page 11 Prepare for Emergencies

 Know the identity and hazards of the materials you work with.  Keep emergency telephone numbers posted in your lab or work area.  Locate your nearest fire extinguisher(s), showers, and eyewash stations, check them periodically, and learn how to use them.  Keep evacuation paths clear - don’t block doors or leave clutter in the aisles and halls.  Prepare for spills o Keep appropriate spill clean up supplies on hand and learn when and how to use them. o When in doubt - Get Out! Warn others as you go. o Report all spills to the EH & S office or Campus Safety, even if minor. Be prepared to provide: . where you are calling from and where the incident is . what kind of problem it is . whether anyone is injured. o Meet the emergency responders outside the building and direct them to the scene.

Waste Disposal Costs

When wastes are shipped off-site for disposal, a team of specialists from the waste hauler's facility package the wastes to meet transportation and destination facility packing requirements, and then transport the wastes to the destination. Shipments for hazardous waste disposal will include certain charges, including:

Mobilization Costs: The fees to have the team come to campus. (Est. $500-800) Labor Costs: the cost for the team to prepare the wastes for shipment. (est. $50-75/hr/person) Disposal Costs: the price to dispose of the waste and container. (Est. $1.25 – $15/lb) Supplies: Shipping containers to meet transportation regulations ($5 – $50 ea.)

The cost of hazardous waste disposal at UW Superior is supported by GPR funds (General Purpose Revenue.) in the EH & S department budget. Normally, academic programs are not charged for disposal of their wastes, but certain activities will initiate a charge back for the disposal costs. The EH & S program reserves the right to charge any department for waste disposal when:

o Wastes are generated by programs funded by Auxiliary funds o Wastes are generated by non-GPR funded research, or construction or renovation projects. o When the department or individual has demonstrated repeated uncooperativeness in waste management issues or conducted intentional acts of negligence. o When the department has accepted a "donation" of a material that later has proved to be unusable and must be disposed of as a hazardous waste. A charge back for disposal can be avoided by reviewing the donation with the EH & S office prior to accepting the donation. o Wastes are generated that require prolonged storage at a regulated facility off site. o Special waste types are generated such as acutely toxic wastes (including dioxin-bearing wastes), PCBs, radioactive wastes, or expired reactive materials such as ethers or picric acid.

Most charges include only the cost of disposal and analytical costs and not the other related charges. Programs or researchers who will be charged back for disposal of their wastes should contact the EH & S office for an estimate, so the cost of disposal can be included in the budget.

Hazardous Waste Management Program, Revised March 2012 page 12 Frequently Asked Questions

Can I bring my household hazardous waste to the campus for disposal?

Sorry, but the University cannot accept wastes from off-campus sources or from homeowners. No matter how well intended, this is a violation of the hazardous waste regulations and could potentially subject the individual and the University to heavy financial penalties. All incidences of abandoned wastes on campus are reported to the Wisconsin Department of Natural Resources for investigation.

At home or at work, hazardous chemicals pose a real risk to people and the environment and need to be managed appropriately. Municipalities run "Clean Sweep" programs to capture household hazardous wastes to prevent them from entering sewer or landfills. Contact your city or county recycling office for options on managing household hazardous wastes.

Can I take wastes home to avoid disposal costs for the campus?

UW Superior takes its responsibilities for hazardous waste management very seriously. Wastes generated by the University will always be an environmental liability for the campus, and the best way to minimize that liability is to manage the wastes according to the regulations. Removing waste from the University, no matter how well intended is a violation of the hazardous waste regulations and could potentially subject the individual and the University to heavy financial penalties.

Can a local Clean Shop Program or Clean Sweep Program be used for disposal?

No. The State of Wisconsin requires that its agencies, including all University of Wisconsin campuses, dispose of hazardous and universal wastes through use of mandatory disposal contracts. All waste disposal at UW Superior must be coordinated through the UW Superior Environmental Health and Safety Office.

Do I have any liability if I generate a hazardous waste?

Disposal of hazardous waste has a high environmental liability associated with it. The State of Wisconsin has a team of experts that evaluates every disposal site used for our wastes, and assists in negotiating a statewide contract for waste disposal services. All of the wastes from UW Superior are disposed via this state contract, and we can be assured that our long-term environmental liability has been reduced by the careful scrutiny of the state.

The EH & S staff account to the Chancellor, the community, and regulators for environmental compliance. But, in order to give a good accounting, everyone on campus needs to fulfill his or her role in environmental compliance. In fact, every individual on campus has the potential to be liable for environmental violations, even if they were not aware they were violating at the time. There can be both civil and criminal liabilities that arise out of hazardous waste management. Under some circumstances, the State of Wisconsin will provide legal assistance for an employee; however, the decision to provide legal assistance will include many factors, including whether or not the action was within the scope of employment and if a reasonable standard of care was applied. There is no guarantee of legal protection for criminal or civil actions. You can lessen your liability, and that of others, by following established procedures, adhering to the regulations, and regularly communicating with the EH & S office about waste management issues. Hazardous Waste Management Program, Revised March 2012 page 13 Disposal Recommendations for Common Wastes at UW Superior Unless otherwise noted, disposal should be arranged through the Environmental Health and Safety (EH & S) Office

Acids: See Corrosives.

Aerosol cans: The disposal method for aerosol cans is determined by the original contents of the can (see guidelines below). If in doubt on how to manage the aerosol can, contact the Environmental Health and Safety office to arrange for proper disposal. . Aerosol cans that contain any amount of its original product or is still under pressure should be sent to the Environmental Health and Safety office for proper disposal. . Empty and pressureless aerosol cans that had contained water-based cleaning products, such as window cleaner, can be recycled with other metal containers or placed in the trash. Do not intentionally release the contents of the container to meet the empty criteria. . Send aerosol cans that contained a pesticide, such as insect spray, to the Environmental Health and Safety office for disposal. . Full or empty aerosol cans that contained paints, varnish or other finishes should be sent to the Environmental Health and Safety office for proper disposal.

Animal tissues/carcasses: Animal tissue or carcasses that contain no known environmental contaminants should be double-bagged and placed directly into the trash dumpster adjacent to the building. Contact the EH & S office, ext. 8073, for assistance in disposing of human tissues or research animals contaminated with toxic substances or radioactive materials. Human tissues shall not be disposed in trash receptacles or dumpsters.

Animal specimens, preserved with Nasco Guard The specimens preserved in Nasco Guard or similar products have been determined not to be hazardous wastes, as they contain primarily propylene glycol or ethylene glycol as the active ingredient, and a trace of formalin. The specimen should be drained of liquid, rinsed briefly under running water and then bagged for disposal like other animal tissues. The liquid should be flushed down the drain of a lab hood followed by 20 volumes of water.

Ballasts: Some old fluorescent lighting ballasts contain polychlorinated biphenyls (PCB’s). Facilities staff will place PCB containing ballasts in the labeled disposal container in the hazardous waste accumulation area. Electronic ballasts and any ballast labeled as "Contains No PCB's" can be discarded in the normal trash.

Bases: See Corrosives.

Batteries, Alkaline: Alkaline batteries should be disposed of in the trash.

Batteries, Automotive: Contact the vendor where the replacement battery was purchased to arrange for recycling of the spent battery. Battery vendors are required to accept the spent batteries when a new battery is purchased. Batteries that are not recycled with the supplier must be managed as a hazardous waste.

Batteries, All Other Types: Only alkaline batteries can be disposed in the trash, all other batteries are recycled or managed as a hazardous waste. The management options include: • If the vendor that supplied the replacement battery offers free recycling, the spent battery should be returned to the vendor.

Hazardous Waste Management Program, Revised March 2012 page 14 • Rechargeable batteries such as Nickel-cadmium (NiCd), lithium ion, nickel metal hydride, and small sealed lead acid batteries can be recycled at one of the following Call-to-Recycle stations at UW Superior: Public Safety Building, Yellowjacket Union, IT Help Desk, or Facilities Management. Please bring the battery to one of the stations, place it in a bag and deposit in the collection box. • Otherwise, call the EH & S office to pick up the batteries for proper management. • Automotive batteries or large UPS batteries should be returned to the vendor when a replacement is purchased, or brought to Interstate Batteries for recycling.

Biohazards, no human body fluids: Laboratory specimens, culture plates, tubes, broths, etc that contain ordinary laboratory bacteriological cultures or infectious agents, (no human body fluids or blood) should be bagged in a biohazard autoclave bag. Prevent the bag from becoming overfilled, and store the bag in a covered receptacle. The covered receptacle must be labeled with a biohazard symbol. The bag should be autoclaved, and then placed into an opaque trash bag. Label the trash bag: "Autoclaved lab wastes – Contains No Human Blood or Body Fluids". Place the bag in a cardboard box, tape the box shut, and deposit it directly into the trash dumpster located adjacent to the building.

Biohazards, medical wastes: Bandages, compresses and other objects saturated (dripping) with blood, IV bags, speculums, medical wastes, etc should be bagged in "redbag" (biohazard) bags. Keep sharps, chemicals and medicines segregated. When the bags are full, contact the EH & S office to arrange for off-site disposal. Do not dispose of "redbag" waste in the trash.

Biohazards, bandages, etc: Articles like bandages, compresses, athletic tape, patient table covers, etc that are slightly soiled with human blood or body fluids are considered normal trash, providing it is not saturated with blood. Place the article inside a bag that can sealed or tied shut before placing it in the normal trash, then alert the custodian of its presence so he/she can use extra care in its handling.

Broken glass: Broken glass or glass that could break and become a cut or puncture hazard must be carefully packaged before being put in the normal trash. Remember, custodians must be able to do their work without the risk of being injured. Line a sturdy cardboard box with a heavy plastic bag, then place the glass in the box and label the container “BROKEN GLASS - NO NEEDLES OR CONTAMINATED MATERIALS ALLOWED”. Small glass slivers should be placed in a plastic bag before placing it in the box.

Compressed gas cylinders: Return all rented cylinders to the vendor. Call the EH & S office for additional assistance or disposal of non-rented or non-returnable cylinders. Contact the EH & S office, ext. 8073, if gas cylinders will be shipped through the mail or a package service so all DOT hazardous materials shipping regulations can be applied.

Computers, including monitors, keyboards, mice, printers, etc. Computer monitors and equipment contain leaded glass, and printed circuit boards contain heavy metals in the solders and components, causing them to be regulated as hazardous wastes if not recycled through state approved sites. Remove all personal files from the computer and then contact Facilities Management to arrange pickup of the units as with other recycling.

Corrosives: Liquids with a pH < 5.5 or > 9.5 must be neutralized with an acid or base by the generator, providing the liquid has no other hazardous waste characteristics (no heavy metals, organics, etc.) Liquids must have a pH 5.5 – 9.5 before drain disposal is appropriate. A log of the date and volume of waste neutralized must be maintained by the generator as the volume must be reported to

Hazardous Waste Management Program, Revised March 2012 page 15 the hazardous waste activity report annually. All other corrosives should be collected for disposal as a hazardous waste.

NOTE: Due to their high reactivity or low solubility with water, do not neutralize the following acids or bases: Acid anhydrides and chlorides; fuming nitric acid; fuming sulfuric acid; chlorosulfonic acid; liquid halides of boron, silicon, tin, titanium and vanadium; liquid halides & oxyhalides of phosphorus, selenium, chromium, vanadium & sulfur.

Cathode Ray Tubes, CRT's: See the procedure for computers or televisions.

Ditto fluid: Typical Ditto fluid is methanol-based, and is regulated as a hazardous waste. Contact EH & S to arrange for disposal or re-distribution of any unused ditto fluid.

Empty Containers A container is empty when all of the substance has been removed by methods commonly used to empty that type of container. (e.g. pouring, scooping, etc). Large containers must have less than 3% by weight of substance remaining, or less than 1 inch of substance left in the bottom. As a standard practice, triple-rinse the container and treat the rinsing as waste. After rinsing, discard the lid in the trash and then dispose of the container using the broken glass procedure. Compressed gas cylinders and aerosol cans are managed according to their respective procedures.

Equipment, including white goods: Equipment must be "decommissioned" prior to disposal, which includes removing the equipment from inventory, and having the equipment examined for PCB- containing transformers, mercury switches, printed circuit boards, Freon, etc. Submit a work order to Facilities Management to have the article examined. After the equipment has been examined and found to be free of hazardous substances, the equipment can be recycled or disposed of. Departments should be aware that there may be a cost for decommissioning equipment.

Glass See the procedure for all types of glass disposal, including containers and plate glass.

Laboratory and/or process wastes: A waste must be classified as hazardous or non-hazardous prior to disposal and some non-hazardous wastes have special management requirements. All hazardous wastes and wastes requiring other management practices must be managed through the EH & S office.

Lamps, light bulbs: Incandescent bulbs contain lead, and ALL fluorescent lamps contain mercury and other heavy metals. All lamps, including incandescent, fluorescent, compact fluorescent, halogen, HID and mercury vapor lamps will be recycled or disposed of as a hazardous waste. Contact the building custodian to dispose of fluorescent and incandescent lamps. Do not place lamps in the trash.

Mercury, metal: Free-flowing metallic mercury is recycled and should be kept in separate small, sealed and labeled containers prior to pickup. Mercury-contaminated labware, broken thermometers, mercury spill clean up products and any other mercury containing materials should be kept in separate sealed and labeled containers for management as a hazardous waste. Do not intentionally mix mercury-containing wastes with other wastes. Facilities staff should bring any mercury switches, gauges or other devices containing liquid mercury to the hazardous waste accumulation area.

Mercury, salts or compounds: Mercury compounds and solutions or medicinals containing mercury compounds will be managed as hazardous waste. The disposal of the compounds or solutions of the compounds is very expensive. Keep all materials containing mercury compounds segregated to minimize the volume of waste generated. Contact EH & S for disposal.

Non-hazardous wastes: Although certain non-hazardous wastes can be safely disposed in the normal trash or the sanitary sewer, great care must be taken to protect custodians, handlers, haulers and the Hazardous Waste Management Program, Revised March 2012 page 16 environment. Municipal solid waste regulations specify that no chemicals and no free liquids be allowed in trash receptacles. Cleaning products and surplus chemicals can be sent to the EH & S office for re-distribution rather than disposal in the trash or sewer.

Oil: Petroleum based oils used for lubrication of centrifuges, diffusion pumps, vacuum pumps and other equipment will be separately packaged in labeled containers. These oils can be recycled and should not be mixed with other materials. Facilities staff will recycle all used engine oil, gear oil, lubricating oil, hydraulic oil, cutting oil and other oils in the recycling tank at the Service Center.

Oil filters: All oil filters must be brought to the Automotive Shop at the Service Center for proper disposal.

Paint Brush Cleaners: Brush cleaners that are solvent-based (mineral spirits, toluene, acetone, limolene, naphtha's, etc) are considered hazardous wastes when disposed of. Brush cleaners can be used and re-used many times by allowing the paint solids to settle, then pouring off the clear layer for re-use. Contact EH & S to arrange for disposal when the brush cleaner can no longer be used.

Paint Cans, empty: Empty paint cans can be allowed to dry thoroughly and then discarded in the trash. Remove the lid before discarding. See “Aerosol Cans” for additional guidance.

Paint, latex: Latex paint is not considered a hazardous waste, unless it is known to contain lead, chromium, barium or other metals (check the labels). If small amounts remain in the bottom of the can, the contents can be allowed to dry and then discarded in the trash. Before discarding in the trash, verify that the surface has not "skinned" over leaving a layer of liquid beneath. Note: no liquids of any type can be thrown in the trash. If more than 1/8 of the contents remain, contact EH & S to arrange for pickup and re-distribution to other departments.

Paint, oil-based: Oil-based paints are regulated as a hazardous waste. Watch for the words “flammable” or “combustible” on the label. Contact EH & S to arrange disposal or redistribution.

Radioactive materials: Contact the Environmental Health and Safety Office, ext. 8073, for disposal of radioactive materials.

Sharps, biohazard: Sharps include items that can potentially cut or puncture skin, such as needles, syringes, lancets, scalpels and razor blades. Biohazard sharps are those sharps that have had contact with an infectious agent or human body fluids. Biohazard sharps must be placed in a labeled biohazard "sharps" container and sent to the EH & S office for proper disposal. Do not place sharps containers in trash receptacles or dumpsters.

Sharps, non-biohazard: Sharps include items that can potentially cut or puncture skin, such as needles, syringes, glass droppers, wires, and razor blades. Non-biohazard sharps have had no contact with infectious agents or human body fluids and cannot be used to administer medications to individuals. Put sharps in a puncture-resistant, leak-proof and sealed container, such as a plastic bottle. Label the container as SHARPS – Non-Infectious. Do not include any biohazard labels or symbols. Place the container in a cardboard box and seal before placing in the trash.

Solvents: All solvents, including brush cleaners, laboratory solvents, Freon, cleaning solvents, parts washing solvents and aerosol contact cleaners, are considered hazardous wastes. Containerize the solvent and contact the EH & S office for proper disposal. Segregate Freon and chlorinated solvents from all other solvents.

Hazardous Waste Management Program, Revised March 2012 page 17 Surplus chemicals or products: Contact the EH & S office to pick up surplus chemicals or products for re-distribution to other areas of campus.

Televisions, VCRs, etc: Television cathode ray tubes contain lead, and printed circuit boards contain lead and other heavy metals. Unless they are managed properly through state-approved vendors, the units are considered hazardous waste. Contact Facilities to arrange pickup of the units. Departments should be aware that there may be a charge for the pickup and/or disposal of the units.

Uninterruptible Power Supplies (UPS): UPS systems contain recyclable batteries, such as lead acid or nickel-cadmium. Follow the procedure for computer recycling or battery recycling.

Hazardous Waste Management Program, Revised March 2012 page 18 HAZARDOUS WASTE CONTAINER INVENTORY UW-Superior Hazardous Waste Program Note: Alternative inventory or sheets card may be substituted for this form.

Department:______Location: (Bldg & Rm) ______

Generator responsible for the waste:______

Date Started:______Date full:______Page _____ of ______

Complete the inventory each time an addition of waste is made to this container. This inventory should remain with the container until it is picked up for disposal. See the Example on how to complete this form in the policy.

Primary Description of the Waste: ______Waste Source: academic activity construction/renovation other ______ research list account to charge: ______

Approx. Volume Added Date Initials Description of the Waste (Include concentration if available) (provide units)

When the container is full, contact the EH & S Office (ext. 8073) for removal and disposal.

Hazardous Waste Management Program, Revised March 2012 page 19 p. 2 Approx. Volume Added Date Initials Description of the Waste (Include concentration if available) (provide units)

When the container is full, contact the EH & S Office (ext. 8073) for removal and disposal.

Remember!

All containers must be labeled with:

 The words “Hazardous Waste”  The date that waste was first added to container  A description of the waste  The hazard warnings that describe the primary characteristic  Remove or cover all old labeling to avoid confusion.

Before EH & S will remove a container from the satellite accumulation site:

o A completed waste container inventory form must included with the container o The container must not be leaking. o The container must be sealed to prevent spillage. o The container must be properly labeled. Hazardous Waste Management Program, Revised March 2012 page 20 This is how a completed waste inventory form should look for a typical lab waste container.

HAZARDOUS WASTE CONTAINER INVENTORY UW-Superior Hazardous Waste Program Note: Alternative inventory or sheets card may be substituted for this form.

Department: Chemistry Location (Bldg & Rm) Barstow 310

Generator responsible for the waste: Ima Chemist

Date Started: 10/1/00 Date full: 12/5/00 Page 1 of 1

Primary Description of the Waste: __Waste non-chlorinated solvents from lab experiments Waste Source:  academic activity research construction/renovation other

Approx. Volume Added Date Initials Description of the Waste (provide units)

IC Mixture of hexane and acetone, approx. 50/50% 250 mls 10/1/00

IC Toluene from glassware rinsing 1 cup 10/05/00 10/05/00 Mothballs (paradichlorobenzene type) in toluene NT 1 liter Includes 10 mothballs

CP Methanol and water mixture, about 10% water. About 50 mls 10/30/00 11/16/00 Phenolphthalein indicator in alcohol, outdated NT 50 mls About 1 gram of indicator/100 mls Mix of hexane, toluene, methanol, methyl ethyl ketone IC 2.5 liters 12/5/00 and acetone, about 20% ea.

Remember!

All containers must be labeled with:

Before EH & S will remove a container from the satellite accumulation site:

o A completed waste container inventory form must included with the container o The container must not be leaking. o The container must be sealed to prevent spillage. o The container must be properly labeled. Hazardous Waste Management Program, Revised March 2012 page 21 This is how a completed waste inventory form should look for a typical non-laboratory waste container.

HAZARDOUS WASTE CONTAINER INVENTORY UW-Superior Hazardous Waste Program Note: Alternative inventory or sheets card may be substituted for this form.

Department: Art Department Location (Bldg & Rm) Holden 2490

Generator responsible for the waste: Art Maker

Date Started: 10/1/04 Date full: 5/5/05 Page 1 of 1

Primary Description of the Waste: __Waste paint brush solvents from paint studio Waste Source:  academic activity research construction/renovation other

Approx. Volume Added Date Initials Description of the Waste (provide units) 10/1/04 AM Turpentine 1 cup

10/05/04 AB Naptha 1 cup

1/05/04 NT Brush cleaner 1 pint

3/30/05 BT Left over oil based paint. 2 tablespoons

4/16/05 AM Paint thinner 1 quart

5/1/05 ES Brush cleaner 2 quarts

Remember!

All containers must be labeled with:

Before EH & S will remove a container from the satellite accumulation site: o A completed waste container inventory form must included with the container o The container must not be leaking. o The container must be sealed to prevent spillage. o The container must be properly labeled. Hazardous Waste Management Program, Revised March 2012 page 22