Hazardous Waste

Containers used to collect waste must be in good condition (i.e., free of cracks, punctures, or other defects), have tightly sealing lids, be designed for the type of chemical waste generated (e.g., containers are rated to hold a specific volume and weight), and compatible with the type of waste. An empty chemical container or waste containers provided by EHS may be used to collect waste. If an empty chemical container is used for waste collection, the original label must be completely removed or defaced, and the container must be relabeled with a hazardous waste label.

Hazardous waste labels are in the back of the Safety Records and Resources binder in the laboratory, and are also provided by EHS, or can be printed using a Hazardous Waste Labels.

All chemical waste containers must have a hazardous waste label that specifies the complete chemical name and percent by volume of each constituent.

If chemical waste contains biohazardous or radioactive material, an additional label that contains the appropriate symbol (universal biohazard symbol or radiation symbol) must be attached to the container and the biohazardous or radioactive constituents must be itemized. Information on how to use, manage, and dispose of radioactive materials is found in the section regarding Radiation Safety.

When the waste container is full, no longer needed, or a chemical is removed from storage as waste, the container should be labeled as hazardous waste and moved to the satellite accumulation area.

Satellite accumulation areas are designated areas within the laboratory where hazardous waste is accumulated, stored, and prepared for disposal. Each laboratory that generates hazardous waste must have a satellite accumulation area. PI/LS are responsible for managing the satellite accumulation area and for training laboratory personnel on its use. EHS provides each laboratory with materials and resources to establish and manage a satellite accumulation area, routinely inspects these areas to monitor compliance with waste regulations and assists laboratory personnel with waste management and safety issues.

The satellite accumulation area must be in an area that is mutually acceptable to EHS and the PI/LS. EHS should be notified if the satellite accumulation area is relocated. Satellite accumulation areas can be placed on bench tops, inside a chemical storage cabinet, or in laboratory support rooms. Satellite accumulation areas that are not in plain view must be identified by signage.

All waste in the satellite accumulation area must be properly labeled, stored in secondary containment, and segregated according to chemical compatibility. If wastes in the satellite accumulation area are not properly labeled (e.g., the chemical name is abbreviated), EHS cannot pick up the waste for disposal. A maximum of 55 gallons of non-P-listed waste or one quart of P-listed waste may be accumulated in a satellite accumulation area. If either of these conditions exists, contact EHS immediately to arrange a pickup as the EPA requires this volume of waste be removed from the laboratory within three days.

Laboratory personnel should frequently inspect the satellite accumulation area for:

• Container integrity (e.g., leaks, cracks, open tops);
• Proper hazardous waste labels (i.e., complete chemical name, accumulation date, building, and room number);
• Proper chemical segregation; the presence of one or more incompatible materials requires secondary containment or an additional satellite accumulation area;
• Over-crowding; and
• Volume restrictions of 55 gallons of non-P-listed waste or one quart of P-listed waste.

The following procedures should be used for all chemical waste:

• Never dispose of hazardous waste in the laboratory sink unless authorized to do so by EHS.
• Select an appropriate container for the waste and affix a hazardous waste label with the name of the chemical(s) being accumulated to the container.
• For liquid waste, use a funnel or spigot to transfer the waste into the container and use secondary containment to catch spills.
• Keep containers closed unless adding waste to the container. Open systems should be provided with a sealed waste container.
• Do not fill waste containers to greater than 90% capacity.
• Once the waste container is determined to be 90% full, place the container in the satellite accumulation area or other appropriate storage area (e.g., freezer) using appropriate secondary containment, segregation, and shielding.

EPA 40 CFR 261.33 requires strict management of hazardous waste containing highly acutely toxic chemicals such as; potassium cyanide, sodium azide, 2,4, dinitrophenol, and osmium tetroxide (as listed in the EPA “P” waste code and identified as “P-listed waste”). Laboratory personnel must be able to identify P-listed waste and manage this waste properly. Solid waste (e.g., gloves, disposable pipettes, tubes, and flasks, paper products, and empty containers) contaminated with highly acutely toxic chemicals or P-listed wastes must not be placed in municipal waste. This waste must be placed in a polyethylene bag or appropriate waste disposal container, labeled with a hazardous waste label, and placed in the satellite accumulation area for disposal.

Reactive chemicals that are unstable, including potentially explosive chemicals (e.g., peroxide forming compounds, organic peroxides, etc.), require special handling prior to disposal. These chemicals may require the services of a trained professional to open and stabilize the chemical using special equipment. Do not attempt to move, transport, or stabilize the chemical. Prevent other laboratory users from using the chemical, restrict access to the area, and contact EHS to arrange disposal of these chemicals.

Chemical waste containing biohazardous material must be labeled with a hazardous waste label and a label that contains the universal biohazard symbol with a list of biohazardous constituents. When the container is 90% full, or ready for disposal, the waste should be transferred to the satellite accumulation area or other appropriate storage location. If extra precautions or storage requirements are required when working with the biological agent contained within the waste stream, notify EHS to arrange a pickup immediately.

Chemical waste containing radioactive material (i.e., mixed waste) must be labeled with both a hazardous waste label and a label that contains the universal radiation symbol. The radioisotopes contained in the waste and total activity of the waste must be listed on the label. This waste will be handled as mixed waste, in accordance with procedures outlined in the section regarding Radiation Safety (link).

All cylinders must be considered hazardous unless the valve has been removed. Return all gas cylinders, excluding lecture bottles, to the distributor or manufacturer promptly once they are empty or no longer needed. If this is not possible, or if you have empty lecture bottles, contact EHS.

Chemicals may not be disposed of in the sink or municipal waste unless specific guidance and approval from EHS is received. However, in limited circumstances, it is appropriate to dispose of substances in a laboratory sink or municipal waste.

• Used PPE, paper trash, and other forms of dry laboratory trash that are not contaminated with biological materials, radioactive materials, or acutely toxic chemicals, may be discarded as municipal waste.
• Empty containers, except for containers of acutely toxic chemicals or P-listed waste (which must be treated as hazardous waste), may be disposed of in the municipal waste or broken glass boxes, so long as they meet the following requirements.
• All containers must be completely empty – no free liquid or residue may remain in the container.
• The container must be completely rinsed at least one time.
• Rinsate may be disposed of in laboratory sinks only. Empty rinsed containers must be completely defaced, removed, or otherwise made illegible before being placed into a broken glass box for disposal. Empty containers should not be disposed of in recycling bins.

Broken glass boxes are available from EHS and should be used only to accumulate unwanted, defective, or broken glassware. It is inappropriate to use these containers for anything other than glass waste that meets the criteria in this section. Once the broken glass box is approximately 75% full, tape the seams so that the lid is secure. These boxes should be disposed of in George Mason University dumpsters by placing a work order with Facilities Recycling and Waste Management, 703-993-2525.

DEQ and EPA regulations mandate that George Mason University implement waste reduction strategies whenever feasible. The following methods should be used to reduce the volume of hazardous chemicals in the laboratory to improve safety conditions and to minimize the amount of hazardous waste generated.

• Chemicals should be purchased in the smallest quantities needed for immediate use. This reduces storage space, potential for chemical accidents, and the cost of disposal. Disposal costs can easily offset any savings incurred from purchasing larger quantities.
• Whenever possible, hazardous chemicals should be replaced with less hazardous substitutes to reduce the amount and toxicity of waste.
• Donations and samples of chemicals from other academic institutions, research facilities, and businesses should not be accepted unless an immediate use is planned and the chemicals are suitable for use (e.g., not expired, unstable, or explosive).
• When PI/LS leave or relocate a laboratory at George Mason University, all chemicals under their control must be inventoried and transferred to the PI/LS’s new laboratory, made available to other George Mason University laboratories, or disposed of.
• Experiments should be designed to render waste less hazardous or nonhazardous.
• Microscale techniques should be employed whenever possible to reduce the quantity of hazardous waste generated.