Syracuse University is both ethically and legally responsible for the proper management of hazardous waste at University facilities. Under federal and state laws, generators of hazardous waste are accountable for the management of hazardous wastes from “cradle to grave” (from the point of generation to the disposal facility to any by-products from the disposal facility).
There are comprehensive federal, state and local regulations for the management of hazardous waste that apply to Syracuse University. The following laws and related regulations generally (not limited to) have applicability to waste generation and disposal.
- The Resource Conservation and Recovery Act (RCRA)
- The Department of Transportation Hazardous Material Transportation Act (HMTA)
- The Toxic Substance Control Act (TSCA)
- The Clean Water Act (CWA)
- Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)
- Superfund Amendments and Reauthorization Act (SARA)
State and Local:
- New York Environmental Conservation Law
- Onondaga County Solid Waste Disposal Authority
Onondaga County Department of Water Environment Protection
What is Hazardous Waste?
Solid waste is a material (solid, liquid or gas) determined to be either unwanted, discarded or no longer having a beneficial use. Waste materials also include, but are not limited to, material that is unwanted, expired (out of date), in poor condition or spent chemicals from a process. If solid waste is determined (preliminarily by the generator and definitively by EHSS trained personnel) to be applicable to hazardous waste regulations, it is then managed as a “hazardous waste”.
NOTE: If a waste can be reclaimed and reused for its intended purpose it is considered a product and not a waste.
Making a Hazardous Waste Determination
It is the responsibility of the solid waste generator to make a preliminary waste determination as to whether each waste material is regulated as a “hazardous waste”. To make a preliminary hazardous waste determination, the generator can follow the steps outlined below. The generator must follow these steps in order:
- Ensure the waste material is not an excluded waste
- Determine if the waste material is a listed waste, and
- Determine if the material meets the definition of a characteristic waste
1. Excluded Waste
Excluded wastes are materials that are excluded from the hazardous waste regulations. These waste items must comply with other regulations specifically in regard to their use and disposal. The three main types of excluded waste generated at the University are:
- Radioactive Waste
- Biological or Regulated Medical Waste
- “Controlled Substances”
Radioactive waste – Radioactive material is regulated by the Department of Energy, Nuclear Regulatory Commission, and/or by corresponding state programs. Refer to the University’s Radiation Safety Program located on the EHSS website under Laboratory Safety.
Biological or Medical Waste – Biological and regulated medical waste are regulated by the NYS Department of Health. Medical waste management and disposal guidelines can be found in this Manual (pages 21-23), and in the University’s Biological Safety Program located on the EHSS website under Laboratory Safety.
Controlled Substance – Controlled substances include the DEA schedule of regulated drugs. Since the DEA regulates use, handling, storage and disposal of these materials, federal hazardous waste regulation (RCRA) do not apply, with minor exceptions (i.e. Chloral or Chloral Hydrate). DEA Disposal guidelines are included in this Manual (pages 26-27).
2. Listed Waste
“Listed” hazardous wastes appear in 6NYCRR Part 371.4 on lists prepared by the Environmental Protection Agency (EPA) and/or the New York State Department of Environmental Conservation (NYSDEC). If waste material appears on one or more of the lists, it should be handled as a hazardous waste until a final waste determination can be made and it must be collected and handled in compliance with state, local and federal hazardous waste regulations and this Manual.
The F List – Waste from nonspecific sources such as spent solvents and process or reaction waste. This includes many common spent halogenated and non-halogenated solvents that are generated at the University.
The U List – Unused toxic waste. If the material is used it is not a “U-listed waste”, but may be a characteristic waste. Currently 455 compounds are designated by the NYSDEC as toxic waste.
The P List – Unused acutely hazardous waste (highly toxic chemicals, with a LD50 of less than 50mg/kg: oral, rat). If the material is used it is not a “P-listed waste”, but may be a characteristic waste. There are 203 compounds listed as acute hazardous waste.
The B List – Wastes containing PCB’s.
Note: A “Listed” waste may also meet the definition of a characteristic waste.
3. Characteristic Waste
Solid waste materials that exhibit one or more of the following four characteristics: ignitability, corrosivity, reactivity, or toxicity are classified as characteristic hazardous wastes. Each of these characteristics has a specific definition based on chemical and physical properties. If a waste material meets the definition of a characteristic waste, it should be handled as a hazardous waste until a final hazardous waste determination can be made. The waste material must be collected and handled in compliance with state, local and federal hazardous waste regulations and this Manual.
Generators should use available resources to determine if a material meets the definition of a hazardous waste. Resources that may be used include, but are not limited to:
- Safety Data Sheet, Material Specification Sheet
- Chemical reference books (Hawley’s Chemical Dictionary, Merck Index, NIOSH Pocket Guide, etc.)
- Laboratory analysis
- Generator knowledge and experience
- Liquids which have a flashpoint less than 140º F or 60º C
- Oxidizing materials which stimulate combustion of organic materials
- Ignitable compressed gases (this includes most aerosols and many cylinders)
Solids which are combustible through reaction or friction and will ignite and burn “vigorously and persistently” enough to cause a hazard
Typical Ignitable Wastes
Solvents such as acetone, toluene, xylene, hexane, methanol, methyl ethyl ketone, ethyl acetate, ethyl benzene, ethyl ether, isobutanol, pyridine, nitrobenzene, methylene chloride, carbon disulfide, carbon tetrachloride. Compressed gases such as hydrogen, acetylene, methane. Solids such as phosphorus, camphor, lithium aluminum hydride. Oxidizers and organic peroxides such as benzoyl peroxide, chlorates, perchlorates, nitrates and persulfates.
- Liquids that have pH less than or equal to 2 or greater than or equal to 5, or corrode certain grades of steel.
- Only liquids can be a corrosive hazardous waste.
Typical Corrosive Wastes
Typical corrosive wastes include acids such as hydrochloric acid, acetic acid, sulfuric acid, muriatic acid, and hydrofluoric acid. Bases such as sodium hydroxide, ammonia, potassium hydroxide, lye, cleaners, bleach, etc.
- Is normally unstable and readily undergoes violent change without detonating
- Reacts violently with water
- Forms potentially explosive mixtures with water
- Addition of water liberates toxic gases, vapors or fumes dangerous to human health
- Cyanides or sulfide bearing waste which, when exposed to pH conditions between 2 and 12.5, can liberate toxic fumes
- Capable of detonation if subjected to heat
- Capable of explosive decomposition at standard temperature and pressure
Typical Reactive Wastes
Common reactive materials include sodium metal, lithium metal, sodium cyanide, potassium cyanide, sodium azide, tin chloride, organic peroxides, pentachlorides, pentoxides, etc.
A solid waste exhibits the characteristic of toxicity if it, or an extract, exceeds specified regulatory thresholds for metals, pesticides and other organic chemicals using the EPA-defined Toxicity Characteristic Leaching Procedure (TCLP). The TCLP is an analytical test that measures the tendency of specific groups of toxic materials to be leached (extracted) from the waste material; simulating conditions in a landfill.
Typical Toxic Wastes
Heavy metals such as arsenic, barium, cadmium, chromium, lead mercury, selenium, silver. Pesticides such as chlordane, lindane, methoxychlor, and solvents such as carbon tetrachloride, benzene, chloroform, etc.
Shock Sensitive and/or Peroxide Forming Chemicals
Many common laboratory chemicals can, over time, form peroxides. Even a single use of a container could introduce enough oxygen to cause peroxide formation. Some types of compounds form peroxides that are violently explosive. Accordingly, peroxide containing liquids should never be evaporated to dryness. Peroxide formation can initiate a runaway, sometimes explosive polymerization reaction.
Disposal of highly reactive materials is expensive and potentially dangerous. Normal disposal and transport of shock sensitive material is not permitted unless the material has been stabilized through a special process. The stabilization process requires the contracting of a specialized company to perform an on-site high hazard stabilization. This process is expensive and requires extraordinary security arrangements.
At all times attention should be paid to the EXPIRATION DATE listed on the cans of ether or other peroxidizable compounds. Always use the material prior to the expiration date or arrange for pick by EHSS prior to expiration. It is recommended that periodic surveys of laboratory and storage areas be conducted for expired ether or other peroxide formers listed on the following page of this Manual. If the item is out of date, is visibly corroded, is known to be a potentially shock sensitive material, or if you feel the material may be potentially dangerous please DO NOT move the container and contact EHSS immediately.
If an ether or other peroxide forming chemical container has no expiration date, no receipt date, and no other way of tracking the age of the material, treat the container with the same caution as you would for an out of date, visibly corroded, or known potentially shock sensitive material. Always leave questionable containers where found, and call EHSS (x-4132) immediately for assistance. Cooperation is essential in identifying potentially hazardous materials for proper removal from the area.
Peroxide forming chemicals may not always have expiration dates stamped on the label or container. A good laboratory practice is to mark the container with the date of receipt and/or the date the container was originally opened. By marking the date of opening on the container, this will ensure there will be a point of reference in determining the age of the chemical.
Precautions should be taken when using, storing and handling peroxide formers. Personnel should label the chemicals as known peroxide formers, or as possible peroxide formers and store them in a designated area. Limit the stock of any item to three months supply or less, and discard any remaining stock. Add an oxidation inhibitor to material when it is appropriate and would not compromise the material’s usefulness. Do not distill peroxide formers to dryness and do not distill any material which you suspect has peroxides present.
NOTE: Containers may be hazardous to handle. If you find any peroxides or peroxide formers, which are out of date or in dry, visibly corroded, and/or damaged containers, or the materials are known to be old, questionable, or in poor condition, DO NOT handle them and immediately contact EHSS (x-4132) for assistance.
Common Peroxide Formers (List may not be all inclusive)
Acrylic Acid Tetrafluoroethylene
Acrylonitrile Vinyl Acetate
Butadiene Vinyl Acetylene
Chlorobutadiene (chloroprene) Vinyl Chloride
Chlorotrifluoroethylene Vinyl Pyridine
Methyl Methacrylate Vinylidene Chloride
Acetal Dioxane (p-dioxane)
Cumene Ethylene Glycol Dimethyl Ether
Cyclooctene Methyl Acetylene
Cyclopentene Methyl Cyclopentane
Diacetylene Methyl-i-butyl Ketone
Tetrahydronaphthalene Diethyl Ether
Vinyl Ethers Diethylene Glycol Dimethyl Ether (diglyme)
Divinyl Ether Potassium Metal
Divinyl Acetylene Potassium Amide
Isopropyl Ether Sodium Amide
Class 1: Unsaturated materials, especially those of low molecular weight, may polymerize violently and hazardously due to peroxide initiation.
Class 2: A peroxide hazard upon concentration (distillation/evaporation). A test for peroxide should be performed if concentration is intended or suspected.
Class 3: Peroxides derived from listed chemical compounds may explode without concentration.
All information above is taken from “Prudent Practices in the Laboratory:
Handling and Disposal of Chemicals”, page 56, Table 3.13