Section 3: Responsibilities

Hazardous Material Users and Waste Generators

University personnel who use or oversee areas where chemicals are used in normal work practices (e.g. professors, graduate students, teaching and research assistants, facilities maintenance employees, Office of Campus Planning, Design and Construction project managers, etc.) must be able to:

  • Understand the physical and chemical properties, health risks, and precautions required for safely handling each chemical and chemical mixture, by using reference books, articles, Safety Data Sheets (SDS), the University’s Chemical Hygiene Plan, EHSS website, and/or regulatory guidance, etc.
  • Attend appropriate training and related refreshers as required and/or deemed prudent to maintain compliance with applicable laws and Standard Operating Procedures (SOP). Training may be presented by EHSS, Principal Investigators, Government Agencies, etc. “Hazardous Waste Training” is required for all University faculty, students and staff who utilize or oversee areas where chemicals are used in normal work practices.
  • Select and use appropriate personal protective equipment (PPE) and other safety equipment required to work safely with hazardous materials. Maintain and keep up to date the department SDS and department specific safety information required for the University Chemical Hygiene Plan.
  • Learn and follow guidelines for proper:
    • Waste determinations
    • Container selection
    • Container Labeling
    • SAA storage
    • Waste minimization

Principal Investigators, Supervisors and Managers

University personnel who have responsibility for oversight of areas where hazardous chemicals are handled or stored (e.g. professors, graduate students, teaching and research assistants, facilities maintenance employees, Office of Campus Planning, Design and Construction project managers, etc.) must be able to:

  • Ensure that all personnel under your direction who may be exposed during use, storage or may be exposed during an incident involving hazardous materials, understand the physical and chemical properties, health risks, and precautions required for handling each hazardous material. Ensure that they become familiar with available pertinent data concerning the chemicals in their work environment by assuring availability of reference books, articles, MSDS, the University’s Chemical Hygiene Plan, the EHSS website, and written SOP.
  • Attend all appropriate training and refreshers to maintain compliance with applicable laws and SOPs. Ensure all appropriate personnel have attended the proper trainings and refresher trainings when appropriate. Ensure that training is attended in a timely fashion.
  • Conduct regular reviews of the area to ensure proper management of hazardous waste and to prevent accumulation of old, unused, unknown, unlabeled, abandoned or otherwise inherently waste like chemicals. Be available to meet with the EHSS staff during compliance review visits, and annual inspections.
  • Ensure proper selection and use of appropriate PPE and other equipment required to work safely with hazardous materials and hazardous wastes.
  • Ensure that all waste generated is appropriately identified and managed by ensuring guidelines are followed for proper:
    • Preliminary waste determinations
    • Records retention and review
    • Container selection
    • Container labeling
    • SAA storage
    • Waste minimization

Project Managers and Office of Campus Planning, Design and Construction

Syracuse University Office of Campus Planning, Design and Construction project managers with oversight of projects which may require use of hazardous chemicals (such as paint, thinner, solder, cleaners, etc.) during normal work practices must be able to:

  • Ensure that all non University personnel working on their projects comply with EHSS guidelines as set forth in the Multi-Employer Program and this Manual.
  • Ensure that EHSS is notified in advance of any project in which hazardous waste may be generated, for which the University may be responsible. This would include, but not be limited to:
    • Lead based paint (debris, dust, contaminated equipment, plastic, etc.)
    • Contaminated debris (ductwork, flooring, pipes, lab material, etc.)
    • Contaminated wash-water (Wash-water used in decontaminating University owned materials or materials or equipment contaminated with University generated waste)
    • Old or expired chemical product owned or purchased by the University for a specific project
    • Fluorescent lamps (including metal halide and high-pressure sodium), mercury thermostats, brass and lead pipes, and mercury from laboratory sink traps
    • Lighting ballasts including electronic, non-PCB and PCB containing ballasts, PCB materials of concern, etc.
  • Ensure that all potential waste material has been evaluated and a hazardous waste determination has been made prior to beginning work. Work with EHO and/or an approved laboratory to sample and analyze materials suspected of being hazardous waste.
  • Ensure that all chemicals brought in, owned or purchased by the contractor are removed by the contractor prior to completion of any job. The University is not responsible for hazardous waste which is owned by a contractor and should not incur the costs associated with management and disposal of these items.
  • Ensure that personnel under your direction understand the physical and chemical properties, health risks, and precautions required for handling each hazardous material. Ensure that they become familiar with available data concerning the chemicals in their work environment by assuring availability of reference books, articles, SDS, the University’s Chemical Hygiene Plan, the EHSS website, and written SOP.
  • Ensure that all hazardous materials utilized by contractors are used in accordance with labels and SDS information and in a manner to minimize potential exposure to the members of the University Community.
  • Attend all appropriate training and refreshers, as deemed prudent, to maintain compliance with applicable laws and SOPs. Ensure all appropriate personnel have attended the proper trainings and require refresher training when appropriate. Ensure that training is attended in a timely fashion.
  • Conduct regular reviews of the area to ensure proper management of hazardous waste and to prevent accumulation of old, unused, unknown, unlabeled, abandoned or otherwise inherently waste like chemicals. Be available to meet with the EHSS staff during compliance review visits.
  • Ensure proper selection and use of appropriate PPE and other suitable equipment required to work safely with hazardous materials and hazardous wastes.
  • Ensure that all waste generated is appropriately identified and managed by ensuring guidelines are followed for proper:
    • Waste determinations
    • SAA setup (see page 18 of this Manual)
    • WAA (Waste Accumulation Area) setup (contact EHSS for WAA setup guidance)
    • Ensure proper record retention is maintained and available for review by ensuring the following information is kept, at a minimum:
      • Container selection
      • Container labeling
      • SAA storage
      • Waste minimization

Environmental Health and Safety Services

EHSS will:

  • Coordinate disposal services for University generated chemical, hazardous universal, regulated, and medical wastes in compliance with federal, state and local regulations.
  • Maintain storage, shipping, and other related records required by state and federal law.
  • Provide consultation on hazardous waste issues to ensure proper waste determination and management to comply with federal, state and local regulations.
  • Provide timely and efficient waste removal services for University SAAs.
  • Provide periodic visits to review compliance with campus hazardous waste generators at University SAAs.
  • Provide periodic environmental compliance evaluations of University SAAs, and report results to appropriate personnel.
  • Work with the campus hazardous waste generators to develop and implement appropriate hazardous waste management procedures and waste minimization strategies for their specific areas.
  • Consult and provide training on proper practice for the purchase, storage and disposal of chemicals and identified hazardous waste.
  • Understand the legal requirements regarding all regulated waste streams and provide training and consultation on these regulations to University waste generators.
  • Periodically review the University Hazardous Waste Management Program and Manual to ensure it is revised and updated as necessary.
  • Make final waste determinations on University generated wastes.

Training Requirements

University personnel who generate hazardous waste are required to attend initial and periodic training appropriate to their level of responsibility. For many individual waste generators on campus, this training is included as part of the Chemical Hygiene Plan presentations. Attending both the Hazardous Waste Management and the Chemical Hygiene training programs are required of all personnel working in a laboratory setting. EHSS also offers training specific to facilities maintenance personnel annually during training sessions for Physical Plant and for Housing and Food Services.

EHSS will facilitate regularly scheduled Hazardous Waste Management training (initial and refresher) sessions throughout the year. Schedules may be found by visiting the EHSS website. Special training sessions may be requested for groups that have specific needs or unusual hazardous waste management requirements.

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