Introduction

Purpose

This Hazardous Waste Management Manual (Manual) outlines the policies, procedures and specific responsibilities for the disposal of hazardous waste, medical waste, Drug Enforcement Agency (DEA) scheduled drugs, universal waste, non-hazardous wastes, and other regulated wastes generated at Syracuse University (University). Certain wastes are regulated under a variety of federal, local, and state regulations. The wastes represented in this manual are regulated by the following local, state and federal laws:

  • Hazardous Waste – Resource Conservation and Recovery Act (RCRA)
    • Federal – Code of Federal Regulations Title 40 Parts 260 – 273
    • State – New York Code, Rules and Regulations Title 6 Parts 370 – 376
    • County – Onondaga County Department of Water Environment Protection discharge limits
  • Universal Waste – RCRA
    • Federal – Code of Federal Regulations Title 40 Part 260 – 273
    • State – New York Code, Rules, and Regulations Title 6 Part 374-3
  • Used Oil, Oil Filters and Oily debris
    • State – New York Code, Rules, and Regulations Title 6 Part 374-2
  • Scrap Metal (includes computer and electronic equipment)
    • New York Code, Rules, and Regulations Title 6 Part 371
  • Drug Enforcement Agency Scheduled Drugs
    • Federal – Code of Federal Regulations Title 21 Part 1300 – 1399
    • State – New York State Health Laws Chapter II, Subchapter K, Part 80 and Chapter 878, Article 33
  • Regulated Medical Waste
    • State – New York Code, Rules, and Regulations Title 6 Part 360-10, 360-17
    • State – New York State Public Health Law 1389
  • County – Onondaga County Department of Water Environment Protection discharge limits

The information in this Manual is presented to assist University personnel in safely, compliantly, and efficiently managing chemical and medical waste generated at the University. This Manual should be utilized as a reference to ensure that personnel are appropriately trained, initial hazardous waste determinations are made and waste is properly managed. Environmental Health and Safety Services (EHSS) handles the disposal of all regulated wastes generated by the University and will make all final “hazardous waste” determinations.

Each of the regulations listed in the table of contents has a corresponding section in this Manual that defines the waste, presents examples of waste material, and describes proper handling techniques for the collection of waste at the point of generation. Additional procedures apply to activities by University personnel who are responsible for moving, storing and/or shipping hazardous waste.

The Manual is applicable to all University chemical and medical waste generators.


Materials Covered

Waste stream management described in this manual include:

  • Art & photography waste
  • PCB waste
  • Battery recycling
  • Compressed gas cylinder disposal
  • Chemical waste
  • Facilities maintenance waste
  • Fluorescent (metal halide and high-pressure sodium) lamp disposal
  • Electronic, non-PCB and PCB lighting ballasts
  • Office waste (copier cartridges, etc)
  • Oil and oily debris
  • Unknown waste from chemical processes
  • Construction waste (University property only)
  • Regulated medical waste
  • Scrap metal & electronics waste
  • DEA scheduled drug waste

The procedures in this Manual should also be utilized where appropriate to manage other wastes that have restrictions on disposal, associated hazards, or special procedures involved in their management.  Many wastes that are not regulated as “hazardous waste”, such as ethidium bromide, may cause or contribute to the significant harm of people or the environment if disposed of improperly.  These materials must also be handled through the Hazardous Waste Management Program to assure their proper management and disposal.

This Manual does not include management of radioactive wastes.  Please consult the Syracuse University Radiation Protection Handbook for specific information regarding radioactive wastes. The handbook can be found on the EHSS website under laboratory safety.

This Manual does not include Occupational Health and Safety information.  Please consult the Syracuse University Chemical Hygiene Plan for specific information regarding occupational health and safety procedures. The plan can be found on the EHSS website under laboratory safety.

Regular trash disposal (non-hazardous solid waste) and campus recycling (e.g. paper, plastic, cans, etc.) are not covered in this Manual. Please consult Material Distribution at x-1940 for information regarding disposal of municipal solid waste and metal/electronic recycling.


Goals

Syracuse University’s Hazardous Waste Management Program goals are:

  • To reduce the amount of hazardous waste to the lowest practical quantity;
  • To dispose of wastes in an environmentally and economically responsible manner in compliance with all applicable regulations;
  • To conduct all waste management operations using safe, compliant and professional methodology; and
  • To implement effective waste minimization procedures (including recycling, reuse, product substitution, and treatment) in University operations.

Environmental Health and Safety Services

EHSS coordinates the Hazardous Waste Management Program at the University.  Waste streams from operations conducted in laboratories, art studios, shops or other workplaces at the University must be evaluated prior to disposal. If a waste is determined to be “hazardous”, or otherwise regulated, it must be collected, labeled and stored according to pertinent specific procedures detailed in this Manual. Trained EHSS personnel will remove for disposal waste materials, make a final “hazardous waste” determination and manage the material appropriately.  EHSS is responsible for maintaining contracts with disposal firms, coordinating shipments of regulated wastes, and maintaining documentation of disposal activity.

EHSS specialists in hazardous waste management can provide consultation or arrange a site visit to review individual waste management concerns.  Assistance related to hazardous waste minimization and disposal is available by calling EHSS (x-4132).  Further information is provided at the EHSS website under “Waste Management”.


Policies

Chemical Waste Management Policy

The University is committed to protecting the environment as well as the health and safety of our staff, faculty and students.  Our objective is to promote the safe handling and disposal of all waste in an environmentally sound manner in compliance with federal (USEPA), state (NYSDEC) and local hazardous waste disposal regulations. The University requires that arrangements for all off campus disposal of regulated materials be coordinated by EHSS.  Unusable hazardous materials that are to be disposed of will be managed by EHSS.  EHSS is responsible for maintaining contracts with disposal firms and maintaining documentation of disposal activity.

Principle Investigators (PI) and other supervisory personnel in areas that generate hazardous waste will be responsible to:

  • Provide for personnel all appropriate training, equipment and procedures required to manage any “hazardous waste” generated in the area as outlined in the Manual;
  • Provide for proper storage, labeling and pickup of waste materials;
  • Conduct regular inspections of hazardous waste accumulation areas to ensure compliance with the Manual;
  • Be familiar with the current legal requirements on hazardous waste disposal as outlined in the Manual, and contact EHSS if questions arise; and
  • Conduct operations in accordance with the University “Waste Minimization Guidelines” in the Manual

All waste materials to be collected for disposal must be identified by the generator as to composition and hazardous characteristics.  This information must be provided to EHSS staff prior to removal for disposal.

Generators are required to coordinate management of all “hazardous waste” at the University with EHSS. EHSS will assure hazardous waste management will be performed by properly trained personnel.

Waste Minimization Policy

Syracuse University is committed to waste minimization through the reduction of hazardous materials used, the reduction of the quantity of hazardous materials stored and thus the quantity of hazardous waste disposed. Our objective is to reduce hazardous waste generated at the University to the lowest practically achievable amount. Waste generators should review all hazardous materials in use to determine if they can reduce the quantity of hazardous waste produced through reducing the size of an experiment or by using less hazardous materials. If this is not possible, generators are urged to use acceptable treatment practices to neutralize or quench hazards in the laboratory as part of their laboratory procedure.

By successfully reducing the amount of hazardous waste generated, the University will comply with federal and state mandates to perform waste minimization. The University will also achieve cost savings, increase operational efficiencies and improve the quality of our services while enhancing health and safety.

Training Policy

Every University student and employee who handles or generates hazardous waste is required to properly handle, store, and label hazardous wastes in accordance with applicable federal, state, and local regulations. It is the responsibility of all University personnel who use or handle hazardous material to follow the guidelines and requirements set forth in this Manual. All University personnel and students who handle or generate hazardous waste must attend an EHSS Hazardous Waste Training Session. Dates and registration forms for the EHSS Hazardous Waste Training Sessions are available at the EHSS website.

Chemical Clearance and Area Decommissioning of Laboratory Facilities

All personnel and students who work in laboratory facilities and work with hazardous materials, separating from Syracuse University, must ensure that all hazardous materials (including research samples, solutions, etc), equipment and facilities contaminated with hazardous materials during their use and under their control have been properly decontaminated, disposed of or transferred appropriately in accordance with the University’s Chemical Clearance and Area Decommissioning of Laboratory Facilities guidance and applicable terms of the University’s Chemical Hygiene Plan located on the EHSS website under Laboratory Safety. Departments are responsible to ensure proper hazardous materials clearance and decommissioning of all areas in their custody and control.

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