Miami University recognizes and accepts its responsibility to provide proper hazardous waste management for university operations including research, teaching and support functions that generate chemical waste. The Environmental Health and Safety Offices (EHSO) are charged with the responsibility of coordinating Miami University’s Hazardous Waste Management Program. However, hazardous waste management is not the exclusive responsibility of any one department or individual. Persons who generate chemical waste retain the primary responsibility for managing their wastes at the point of generation.

The primary goal in handling and disposal of hazardous waste is to do so in a manner that prevents harm to human health and the environment. Extensive federal, state, and local regulations govern hazardous waste management. The University is covered by these regulations - which are beyond the scope of this guide - but, in general, they regulate the handling, transportation, storage, and disposal of chemical waste. The regulations also require extensive recordkeeping and a “cradle to grave” tracking system, which tracks hazardous wastes from their point of generation through disposal. This allows all waste to be accounted for at any stage between generation and disposal.

Except for the Miami University Hazardous Waste Facility (HWF), which is controlled solely by EHSO, all areas where hazardous wastes are managed are considered satellite accumulation areas. This is a regulatory designation that allows generators in those areas to operate under the minimum of regulatory oversight. As such, the following five points are all that generators need to know to operate in compliance with the law:

1. Containers holding hazardous wastes must be marked with the words Hazardous Waste and/or a description of the specific chemical contents.
2. Containers holding hazardous wastes must be in good condition (i.e., no cracks, leaks, rust, etc.).
3. Containers holding hazardous wastes must be compatible with the waste and any waste mixtures in that container must also be compatible.
4. Containers holding hazardous wastes must be closed at ALL TIMES. The only exception to this is when waste is being added to or removed from the container.
5. Accumulation of hazardous wastes in satellite accumulation areas cannot exceed 55 gallons (per process) at any given time. If an area accumulates acutely hazardous wastes, one quart (per process) is the maximum amount that may accumulate at any given time.

EHSO provides chemical waste handling services including segregation, packaging, transport, and disposal at no cost to individual departments. These services are initiated by completing a Chemical Waste Record (PDF 322KB). The generating location, type, and quantity of each chemical are documented on these forms and maintained by EHSO in a computer database.

All wastes must remain at their point of generation until EHSO personnel arrive to segregate, package, and transport the wastes to the University’s Hazardous Waste Facility (HWF). After arriving at the HWF, wastes are placed into various compatibility groups allowing for safe storage/handling until final disposition. A significant amount of these wastes are consolidated with other compatible wastes into larger containers, thereby reducing overall disposal costs. EHSO staff investigates all possible recycling and reuse options before approving wastes for final disposal. As a small quantity generator of hazardous waste, Miami University is permitted to store regulated wastes for no more than 180 days at a time.

In general, chemicals that are considered wastes at Miami University include: contaminated or spent chemicals that can no longer be used for their intended purpose, outdated or expired chemicals, and chemicals in poor containers (i.e., broken containers, missing labels, etc.). Chemicals, which have not exceeded their shelf life, are in good containers, and could be used by someone else, are not classified as wastes.

As defined by federal and state regulations, a chemical waste is considered a hazardous waste when:

1. Listed in one of four lists that the EPA has generated (see P-list and U-list)
2. Determined to exhibit a characteristic that the EPA has identified as making it a hazardous waste.

The EPA lists include specific chemicals that have been shown to have toxic, carcinogenic, mutagenic, or teratogenic effects on humans or other life forms. Chemicals with physical characteristics such as ignitability, corrosivity, or reactivity are also listed. Because there are over 700 chemicals on these lists and the regulatory principles are not intuitive, determining whether or not a waste is hazardous using EPA lists is a complex task requiring some degree of familiarity with the regulations. When in doubt, any chemical suspected of having any toxic or hazardous properties should be submitted to EHSO for determination and subsequent proper handling and disposal.

Many chemicals that are at least moderately toxic, moderately corrosive or combustible are not regulated as hazardous waste. Although exempt from the hazardous waste regulations, non-hazardous wastes cannot necessarily be placed in the trash or poured down the drain. In most cases, local regulations forbid drain disposal of liquid chemicals except in very minimal quantities. Likewise, only solids that are inert or innocuous may be disposed of in the trash. If you are unsure of a chemical’s regulatory status, contact EHSO prior to disposal. That will ensure Miami University’s continued compliance with federal, state, and local regulations.

High-density polyethylene containers for accumulating waste solvents and other high volume liquid wastes are available from EHSO at no cost to University departments. These containers are distributed based on waste type and volume. EHSO does not provide waste collection containers for chemical wastes produced in smaller quantities. Generally, empty manufacturer’s containers are the best choice for collecting small quantities of hazardous wastes; however, you should avoid using containers that previously held incompatible materials. It is a good practice to wash all containers and allow them to dry completely before using them for chemical waste storage.

Many University operations generate empty chemical containers. Empty containers ranging from small glass bottles to 55-gallon drums are defined by regulation as those having all contents removed by commonly employed practices (i.e., pouring, pumping, scraping, etc.), with no solids or free-flowing liquids remaining in the container. If any material can be poured from the container it must be managed as a chemical waste. Furthermore, any container that has held an acutely hazardous waste (see Appendix A) must be managed as a hazardous waste. Containers determined to be empty in accordance with these guidelines should be defaced and placed in the normal trash.

Gas cylinders are widely used in the University’s teaching and research laboratories and in maintenance and construction operations. University personnel using gas cylinders must make every attempt to return them to the supplier when finished. Suppliers will usually accept empty or partially full cylinders for reuse or recycling at no cost. The best approach is to check with suppliers before purchasing cylinders to be certain that they will pick up used cylinders when new ones are delivered. EHSO suggests not using suppliers who do not provide this service. Disposal of unused gas cylinders can be difficult and extremely expensive.

Thorough maintenance of labels on chemical containers reduces the occurrence of unidentified chemicals. Periodic reviews of your chemical inventory can also help to identify containers with deteriorating labels early. When an unidentified material or waste is discovered, an attempt to identify its contents should be immediately undertaken. Usually the contents can be identified by consulting individuals who work in the area where the unidentified material was found. If this approach fails, EHSO will arrange for analysis/identification through an outside contractor.

Waste disposal should be considered an integral part of any activity that generates chemical waste. If a new research project has the potential to generate waste chemicals in large quantities, contact EHSO ahead of time to plan for proper waste management and disposal. Additionally, if a research project is terminated, prompt disposal of any associated wastes should be arranged through EHSO. The Procedure for Vacating a Laboratory should always be utilized when a Laboratory Worker (faculty, staff, or student) permanently vacates a chemical laboratory.

Effective chemical waste management requires not only safe, sound practices, but also requires extensive efforts to reduce the volume and toxicity of regulated wastes. Waste minimization efforts reduce disposal costs and the environmental impacts associated with chemical wastes. A substantial portion of the hazardous waste produced at Miami University consists of unused, outdated chemicals. Careful planning can reduce purchasing excess amounts of chemicals thereby reducing associated disposal costs.

In many cases, less hazardous chemicals can be substituted for chemicals that have more hazardous properties. These safer alternatives should be utilized wherever possible. Not only does this decrease the University’s overall waste disposal costs, but it also translates to a safer learning and working environment for the faculty, staff, and students of Miami University.