Federal and New York State regulations allow generators to accumulate hazardous waste at or near the point where it is initially generated. These accumulation points are called Satellite Accumulation Areas (SAA). Up to 55 gallons of hazardous waste or 1 quart of acute hazardous waste (P-listed) may be accumulated at each SAA. When the 55 gallons of hazardous waste or 1 quart of acute hazardous waste limit is reached, the waste must be marked with the date and moved within three calendar days to the Waste Accumulation Area (WAA).
Specific SAA requirements are:
- All SAA must be registered with EHSS by contacting EHSS (x-4132)
- All SAA must be in a secure location that is under the control of the principle investigator, supervisor or manager of the process that is generating the hazardous waste.
- All SAA must be posted with specific signage (contact EHSS x-4132 for the proper signs)
- Immediately contact EHSS (x-4132) if the 55 gallons of hazardous waste or 1 quart of acute hazardous waste limits is being approached.
- See sections 3a – 3c of this Manual for specific hazardous waste container storage and labeling requirements at a SAA
Collection and storage of waste at the SAA is the responsibility of each waste generator. Regulations require identification of hazardous wastes according to specific criteria. The waste generator declares when a material is waste and makes the initial hazardous waste determination, but trained EHSS staff makes the final hazardous waste determination. In order for EHSS staff to make this determination, it is absolutely critical that the chemical components of the waste are clearly and accurately listed on each container label. The proper handling and ultimate disposal technology is determined based upon the information provided upon the SAA Hazardous Waste Label.
Before EHSS staff will pick up a hazardous waste container, the waste generator must sign a University Hazardous Waste Pickup Form and the SAA Hazardous Waste Label on the container must be filled out completely and correctly. Both the University Hazardous Waste Pickup Form and the SAA Hazardous Waste Label have the following Generator’s Certification Statement on them: “I certify that I have successfully completed the Hazardous Waste Training Course provided by the Environmental Health Office. I further certify that the above listed chemical items presented for disposal are accurately described to the best of my knowledge and are labeled and packaged in accordance with the waste handling protocols established by the Environmental Health and Safety Services Office”. By signing the University Hazardous Waste Pickup Form and filling out the SAA Hazardous Waste Label, the waste generator is certifying that the chemical components listed on the container label are accurate and complete.
Following these guidelines for container selection and storage will help to assure safe, compliant, and efficient management and disposal of waste material.
Container Storage Requirements
- Federal and New York State regulations require that all hazardous waste containers are kept tightly closed except when you add or remove material. Do not leave funnels in containers. Do not use containers which cannot be adequately (tightly) closed. Do not use rubber stoppers, corks, parafilm, or glass stoppers as covers.
- Only store waste in clean containers that are free of residue. Use containers that are compatible with the waste materials. Use original containers when possible. Rusty, dented or degraded containers are not acceptable. Do not use beakers, or other labware, coffee cans, milk jugs, or other food and/or beverage containers. Only proper chemical containers in good condition will be accepted for removal.
- Collect only wastes that are compatible within a container. Use separate containers for each of the following types of waste: halogenated organic solvents, non-halogenated organic solvents, corrosive-acid, corrosive-bases, heavy metals, elemental Mercury, reactives, oxidizers, toxic (poisons), acutely hazardous wastes (P-listed).
- Segregate containers according to chemical compatibility.
- Secondary containment is required for waste containers. Inspect regularly for leaking or damaged containers.
- Do not fill containers completely full, leave headspace.
- Contact EHSS (x-4132) when containers are full or if you need the material removed prior to the next scheduled pick-up. Call EHSS to remove the containers within six months, even if the container is not completely full. Call EHSS to remove containers that are not full, if you would like them removed from your area.
- Practice safe laboratory procedures when handling, storing, and adding waste to the containers.
Labeling
Waste materials that have been identified as hazardous waste or are suspected to be hazardous waste must be collected and clearly labeled. The label must describe the container’s contents and the words “Hazardous Waste” must appear on the label. Contact EHSS to obtain University approved SAA Hazardous Waste labels. Use only these labels and make sure all information is complete.
As soon as hazardous waste is place into a container, it must be appropriately labeled as indicated below. The following information must be on the label:
- The words “HAZARDOUS WASTE” must appear on the label.
- PI/Supervisor name.
- Waste Generator name and contact phone number.
- Complete chemical names of all waste in the container must be listed. Full chemical names must be written out. Chemical formulas, acronyms, trade names and abbreviations are not acceptable.
- Estimated proportions of contents – concentration or volume %.
- Label must indicate the hazards associated with the contents of the container (e.g. RCRA characteristic/waste code, etc.)
Do not let chemicals become unknowns – replace labels that are defaced, deteriorated or difficult to read!
Reusing Empty Chemical Containers
- Whenever possible, reuse empty chemical containers to collect hazardous waste.
- If necessary, triple rinse the container with a solvent capable of removing remaining residues. Reuse the solvent for cleaning until it is spent; use fresh solvent only for the final rinse. Solvent (rinsate) will require collection as a hazardous waste, collect as a hazardous waste and contact EHSS for removal.
- Remove, deface or mark over the old label so that any information on it is no longer legible.
- Reuse the container only with compatible new materials or waste.
- Clearly re-label (with the SAA Hazardous Waste labels) the container with the full chemical name of the contents and the estimated proportions of the contents.
Disposal of Empty Chemical Containers
A container is considered “empty” per the RCRA regulation if it has less than one inch of residue or 3% by weight of residual material. Once a material is considered regulatory “empty” it may be discarded in the regular trash. Please do not put empty chemical containers in the recycling stream. Before discarding empty containers:
- If necessary triple rinse the container with a solvent capable of removing remaining residues. Reuse the solvent for cleaning until it is spent; use fresh solvent only for the final rinse. Solvent (rinsate) will require collection as a hazardous waste, collect as a hazardous waste and contact EHSS for removal.
- Remove, deface or mark over the old label so that any information on it is no longer legible.
- Mark the container with the word “EMPTY”.
- Place five 5-gallon or smaller containers into the regular trash.
- Call EHSS to arrange for disposal of large containers, containers contaminated with highly toxic or acutely toxic materials, and other containers you have questions about.