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Hazardous Waste

The office of Environmental Health and Occupational Safety coordinates the collection and disposal of hazardous wastes on all MC campuses, without charge to any department. We maintain a contract with an EPA registered disposal company that sends wastes to EPA registered and legally permitted Treatment, Storage & Disposal facilities. EPA regulations make improper disposal, whether intentional or accidental, punishable by fines and/or imprisonment. By centralizing the collection, packaging, transportation and disposal through a verified contractor, we help everyone at MC to comply with environmental laws. If you have a chemical, biological or radioactive material that you no longer need, please contact the Environmental Health and Occupational Safety office for proper disposal. Remember that the college is a “business” and subject to laws that do not apply to homeowners and residences.

Environmental Health and Occupational Safety partners with academic departments (Bioscience Chemistry, Art, Theater, Landscape Tech, Geology, Physics, etc.) as well as, non-academic offices such as, campus maintenance, grounds, building services, etc. Environmental Specialists communicate with representatives of these departments or operations prior to a waste pick-up. A “hazardous waste generator” can be an individual, a department, or a College campus. Areas at the College that generate hazardous waste include laboratories, art and photography studios, swimming pools, print shops, automotive maintenance areas, paint shops and other facilities.

Scope and Application
The hazardous waste program applies to anyone at the College who generates hazardous waste. It provides guidelines for the proper handling, storage, labeling, and packaging of hazardous wastes prior to their pickup for disposal. It does not cover the special category of infectious waste, for which a separate safety program exists.

Procedures

General Guidelines

All College personnel who generate or dispose of regulated wastes have the following responsibilities:

  1. Select chemicals carefully and know the hazards associated with each and how to handle and store them safely. This information can be found on the Safety Data Sheet (SDS) (formerly called MSDS) that is required for every hazardous material.
  2. Minimize Waste by purchasing only amounts that you expect to use in the foreseeable future. The cost to dispose of an unused chemical often exceeds the purchase price by a substantial amount.
  3. Follow the College waste minimization program. Investigate alternative materials and, if feasible, scale back experiments or other activities to use the smallest amount of hazardous materials possible.
  4. Develop a Standard Operating Procedure for identifying, segregating, collecting, and labeling all hazardous wastes.
  5. Contact Environmental Health and Occupational Safety for guidance. Environmental Health and Occupational Safety will help you to determine if a waste is hazardous and will provide information on appropriate storage containers for your hazardous waste.
  6. Dispose of hazardous wastes within the legal time limit. Contact Environmental Health and Occupational Safety early to be included in the next regularly scheduled pickup.
Who Regulates Hazardous Waste?

Federal and State Environmental Protection laws determine what can be discharged into the air, the water, and the land.

Three federal agencies and two state agencies administer these regulations. The Environmental Protection Agency (EPA) has two major programs that address the disposal of hazardous waste: the Resource Conservation & Recovery Act (1976), known as RCRA, and the Comprehensive Environmental Response, Compensation & Liability Act (1980), known as CERCLA. In addition, certain waste materials and waste-generating processes are regulated through other EPA programs—TSCA, FIFRA, CWA, and CAA. (Check out our More Information section at the bottom of the page)

Maryland Department of the Environment (MDE) enforces EPA regulations, as well as additional State regulations regarding waste disposal. The Department of Transportation (DOT) regulates the transportation of hazardous materials and waste. Finally, the Occupational Safety and Health Administration (OSHA) specifies standards for response to hazardous chemical emergencies, which are enforced by Maryland Occupational Safety and Health (MOSH).

What is a Hazardous Waste?

Hazardous Waste (HZW) is any material that is to be discarded AND contains certain regulated components or is flammable, corrosive, reactive and/or toxic to the environment.

These characteristics are defined in 40 CFR Part 261.22 as follows:

A liquid (other than an aqueous solution containing less than 24% alcohol by volume) with a flash point of less than 60o C (140o F) as determined by a Pensky-Martens closed cup tester using ASTM method D-93-70 or D-93-80; or it is not a liquid and is capable under standard temperature and pressure of causing a fire; or it is an ignitable compressed gas; or it is an oxidizer.

An aqueous waste having a pH </= 2 or >/= 12.5; or a liquid that corrodes steel as described in 40 CFR Part 261.22.

A material that is normally unstable and readily undergoes violent change without detonating; or reacts violently with water; or forms potentially explosive mixtures with water; or when mixed with water, generates toxic gases, vapors or fumes; or a cyanide or sulfide bearing waste that generates toxic gases, vapors or fumes when exposed to pH conditions between 2 and 12.5; or is capable of detonation or explosive reaction.

Using the test procedure specified in 40 CFR Part 261.24, an extract of the material contains one or more constituents at concentrations in excess of those specified in Table I of 40 CFR Part 261.24. (These are heavy metals or specific organic compounds that could be released into ground water.)

The EPA and MDE have identified several hundred chemicals and solid wastes by name as hazardous. If your waste appears on any these lists, it must be handled as hazardous waste. (See "EPA Links" below to view these lengthy documents.)

 If you are not certain whether a particular waste is hazardous, contact the College's Environmental Safety Manager for assistance.

As you can see, these laws are complex and it is easier to let Environmental Health and Occupational Safety take care of the waste material rather than taking a deep dive into the regulations. Please contact us before the waste is generated, so we can help you plan the storage and disposal.

Packing and Storing Hazardous Waste

Universal Procedures

  1. Keep the waste in closed containers that are compatible with their contents. (No hydrofluoric acid in glass, for example.) Often the original container supplied by the manufacturer is fine. Containers must remain closed except when adding waste. (Do not leave funnels in the containers between additions!) Finally, do not overfill containers - allow some head space for expansion of the contents. Use appropriately sized containers.
  2. Example: Hazardous Waste Container Label
    Example: Hazardous Waste Container Label
    Properly label the container with the following:
               *The words "Hazardous Waste."
               *The name(s) of the material(s) included in the waste. The name  of a particular material may be:(1) the process that created the waste (e.g., "Waste acid from copper etching" or "Waste products from Experiment X"), or (2) the manufacturer's name and product number (e.g., "Ace Cleaner #199"), or (3) the known components of mixtures (e.g., "10% battery acid" or "50% antifreeze/water")
  3. Avoid mixing solid and liquid waste.
  4. Do not dilute wastes.
  5. Do not mix waste chemicals without prior approval from the Environmental Safety Manager. Even though the chemicals may be compatible, the cost to dispose of the mixture may be higher than for its component parts. However, if you routinely generate substantial quantities of compatible solvents, contact the Environmental Safety Manager about bulking the waste, as this could provide significant savings to the College.
  6. Do not mix heavy metal solutions with any organic solvent or solution.
  7. Do not pour halogenated and non-halogenated organic solvents into the same container.
  8. Avoid placing wastes from incompatible hazard classes in the same container (e.g., flammables with oxidizers). Some metals also cause problems when mixed with flammable liquids or other organic liquids.
  9. Maintain containers of hazardous waste in a designated storage area prior to pickup for disposal. This area must be controlled by the personnel generating the waste. Regularly check the containers for leakage. If a leaking container is found, use established spill cleanup procedures to clean up the area and transfer the material to a container that is in good condition.
  10. As in any chemical storage area, segregate the containers according to the type of waste. Also, it is always advisable to provide secondary containment in case of spillage.
What Can't Go Down the Drain?

The sanitary sewers are regulated by the Washington Suburban Sanitary Commission (WSSC) at Germantown and Takoma Park/Silver Spring campuses, and by the City of Rockville at the Rockville campus.

Microbiology Stain Waste Container
Microbiology Stain Waste Container
  1. Anything that might damage or interfere with the collection system (corrosives, flammables, solids).
  2. Anything that might damage or interfere with the treatment plant (pathogens, antibiotics, preservatives, toxins, extremely hot waste, too much volume for the plant to handle, dyes & stains).Sanitary Sewer

The sanitary sewer is a system of underground pipes that carries sewage from bathrooms, sinks, kitchens, and other plumbing components to a wastewater treatment plant where it is filtered, treated and discharged. Some liquid wastes may not be a hazardous waste as described by Federal and State regulations, but may not be poured down the drain.

The College follows the requirements in the WSSC Plumbing & Fuel Gas Code (PDF, Get Adobe Acrobat PDF Reader.-Link opens in new window.) , chapter 8 for sanitary sewer discharges.


Special Wastes:

The following materials require special handling by the generator prior to their disposal:

Controlled substances have disposal guidelines under the Food and Drug Administration, and the Drug Enforcement Agency. Some medicines can be very dangerous to handle, such as medicines that are absorbed through the skin from a patch. DO NOT flush medicines down the drain without specific instructions. The Montgomery College Environmental Health and Occupational Safety Office will arrange for disposal of lost, unclaimed medicines turned into the Public Safety Office. Individuals wishing to dispose of personal over-the-counter or prescription drugs may refer to the instructions provided by the Montgomery County Department of Environmental Protection.

Information Technology manages computers, mobile phones and other communication equipment owned by the college. Contact IT Asset Management for disposal.

Pressurized spray cans must have their original content label and/or SDS available at the time of pickup. If possible, use the spray material until the container is empty (no pressure or free liquid). Empty cans are not hazardous wastes and can be put into regular trash. Contact Environmental Health and Occupational Safety if you have questions or concerns, prior to disposal. Do not place intact aerosol cans in the municipal recycling.

Used oil is not hazardous waste, by legal definition, but it is disposed of during hazardous waste pick-ups. Oil that is contaminated with other wastes, or oil drained from cars, vehicles, heavy equipment or hydraulics is collected for disposal by Environmental Health and Occupational Safety's contractor. If you need drums for collecting waste oil, contact Environmental  Safety Specialist at 7-4308.

Gas cylinders have a high disposal cost. Cylinders should be purchased from vendors who will accept them back after use. Buy only the necessary number and use them as soon as possible. (If the pressure in a lecture bottle is equal to atmospheric pressure, the generator can legally declare the container empty and discard it with other non-regulated wastes.) Contact Environmental Health and Occupational Safety if you have questions or concerns, prior to disposal. Do not send a metal cylinder to the municipal recycling unless it is completely emptied with the valve removed. Removing the valve requires placing the cylinder in a vise and using a special tool.  

Most glassware can be disposed of in the trash. Containers that held acutely toxic hazardous waste must be triple rinsed before being placed in the trash. The rinsate must be handled as a hazardous waste. These are often pesticides and other toxic chemicals. The SDS will indicate if it is acutely toxic. Contact Environmental Health and Occupational Safety if you have questions or concerns, prior to disposal.

Universal wastes are hazardous wastes that are commonly used throughout all businesses and in many homes. Regulations for universal wastes encourage recycling and make collection and storage easier. The College may collect and store universal wastes up to 1 year.
Store universal wastes in closed containers. Label the container with:

  1. the words “UNIVERSAL WASTE”,
  2. the contents of the container, and
  3. the date you began collecting the waste.

Do not break or throw fluorescent light tubes in the trash. The College recycles all light tubes. Place the tube in its original carton, if available, and contact your Campus Facilities Office or Environmental Health and Occupational Safety to have it stored appropriately until it can be picked up for recycling. Store compact fluorescent lamps (CFL) separately from tubes.

Fluorescent Lamp Ballasts
Store lamp ballasts in separate containers from the fluorescent tubes. Some ballasts in older fixtures may contain PCB’s. Newer ballasts are marked “PCB-free”.

Most rechargeable batteries contain toxic metals. Lithium batteries are reactive and a potential fire hazard . Separate batteries by type (lead acid, nickel cadmium, mercury, etc.) and store them in different containers. Lead acid batteries should be stored indoors or in an enclosure to keep them out of the rain. Common household alkaline batteries are not hazardous, but can be separated for recycling. The College recycles all batteries.

Insecticides, weed killers, rat poison, mold removers, sanitizers, etc. are all pesticides. Physical controls and cleaning reduce the need for pesticides. Do not purchase and store more material than what is needed for the immediate future. If at all possible, use up the material. Empty containers are not regulated waste.


Coordinating and Scheduling Hazardous Waste Disposal

Environmental Health and Occupational Safety is responsible for coordinating all waste pickups by the hazardous waste contractor. Pickups are normally scheduled four times each year and whenever necessary for special projects.

You may notify the Environmental Safety Specialist that you have materials for inclusion in the next scheduled pickup at any time. Notification may be made by phone (x. 74266) or email. Along with your request, you must submit a completed Hazardous Waste Collection Request Form (PDF, Get Adobe Acrobat PDF Reader.-Link opens in new window.) . This form is available on our Forms page. The completed request must include the storage location; the generating department's name; the size, type and number of containers; and the chemical or product names (see "container labels" above). This form should be submitted as soon as possible and must be in our office no later than 7 days prior to the scheduled disposal date. Last minute additions usually are not permitted.

When a pickup is scheduled for the mutual convenience of the generating department and the contractor, the waste must be accessible for pickup. Neither the Environmental Safety Specialist nor other College employees will collect the wastes prior to the day they are to be removed by the contractor. Consequently, a departmental contact person must be available to provide information and access on the day of pickup.

Federal and State regulations specifically prohibit the transportation, storage and disposal of unknown waste materials. Consequently, unknown chemicals will not be accepted for disposal! Analysis of unlabeled materials may cost thousands of dollars per container. The cost of such analysis will be borne by the generator or generating department. Proper management practices in your department can prevent the generation of unknown wastes. Make sure all hazardous materials and wastes are properly identified when accumulation begins. Do not permit students, faculty or staff to use or leave unidentified materials on College property.

Hazardous Material Spill

Spilled hazardous material and all cleanup materials become hazardous waste.

The generator is responsible for mitigating any damage and minimizing exposure for anyone in the vicinity of the accident. The generator must notify the Campus Security Office of a hazardous materials spill as quickly as possible. This will permit rapid coordination of emergency responses both internal and external to the College.

In addition, State and Federal laws require that certain notifications be made to appropriate officials. The notification is handled by the Environmental Safety Manager. In some cases, cleanup operations may best be handled by professionals, who will be contacted by the Environmental Safety Manager in both emergency and non-emergency situations.

 

What You Need to Know:

  • Identify activities that may generate hazardous waste.
  • Develop a waste minimization program.
  • Develop standard operating procedures for managing hazardous waste.
  • Be aware of College policies and procedures regarding hazardous waste.
  • Ensure that personnel involved in activities that generate hazardous waste understand and follow the waste policies and procedures. Use the online training for hazardous waste.
  • Anticipate and plan so that wastes are disposed of properly at the conclusion of a project.
  • Ensure that all wastes are identified for disposal before the generator leaves the College.
  • Review current activities for the purpose of minimizing the amount of hazardous waste generated.
  • Follow all specified policies and procedures.
  • Properly dispose of all hazardous waste in a timely manner.
  • Ensure that all waste for which he/she is responsible has been identified and disposed of prior to leaving employment or a particular position at the College.
  • Secure and administer contracts for hazardous waste disposal.
  • Coordinate all hazardous waste pickups every 90 days with contractors.
  • Provide technical assistance on proper waste identification, storage and disposal requirements.
  • Maintain disposal records and submit all required reports to the appropriate authorities.

More Information

EPA: Hazardous Wastenew window

Tips

Do not rely on government documents to determine whether a particular waste is considered hazardous waste. Contact Environmental Health and Occupational Safety for assistance whenever you have questions or concerns regarding waste disposal.

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