VIII. Hazardous Materials
Hazardous Waste Management
PURPOSE
Lesley University is committed to protecting the health, safety,
and welfare of faculty, staff, students, and the public and to
protecting the environment through a comprehensive hazardous
substances management program. The elimination of dangerous
combinations of hazardous chemicals in storage, the elimination of
hazardous accumulations of unwanted substances, the improvement of
chemical storage conditions, and the prevention of inappropriate
disposal of chemicals through proper handling and disposal of
hazardous wastes greatly improves overall safety, reduces potential
liability expenses, and protects the environment.
A comprehensive and effective hazardous substances management
program, including hazardous waste reduction (toxics use
reduction), can only be achieved through control of hazardous
substances from the time of purchase through waste generation and
final disposal (cradle-to-grave). Proper and complete documentation
must be practiced at every stage, to promote safety, to meet legal
requirements, to reduce liability, and to provide for the effective
management of hazardous wastes. It is essential for all who use
hazardous substances and generate hazardous wastes to cooperate
fully with the Lesley University Hazardous Substances Management
Program.
GOAL
This policy is to provide for a comprehensive hazardous
substances and hazardous waste management program which most
effectively protects human wealth, safety, and welfare, protects
the environment, and incorporates hazardous waste reduction
techniques. Objectives:
- To maintain control chemicals and hazardous substances to
reduce excessive and wasteful ordering, to meet legal requirements
for the storage and use of all substances including hazardous and
toxic substances, to aid in monitoring hazardous waste generation,
and to eliminate excessive amounts of outdated chemicals.
- To monitor all processes and activities that produce chemical
or biological wastes to determine whether or not the wastes are
hazardous wastes.
- To identify, collect, label, properly handle and store, and
properly transport and dispose of through licensed transporters all
hazardous wastes, universal wastes, and hazardous biological and
bio-medical (biohazard) wastes.
- To maintain, complete documentation of the generation,
accumulation, transportation, and disposal of all hazardous wastes,
universal wastes, and hazardous biological and bio-medical
(biohazard) wastes.
- To incorporate hazardous waste reduction techniques whenever
possible.
- To provide an annual review process for the Guidelines for
Emergency Procedures with the specific purpose of incorporating
changes designed to make the plan more effective and
efficient.
SCOPE
The Lesley University Public Safety Office was created in part
to address the many legal requirements for the proper handling and
disposal of hazardous wastes generated on campus and in part to
address campus wide safety issues. The first and most immediate
tasks were to refine the existing comprehensive chemical inventory
system and to develop a comprehensive hazardous waste management
program for the entire campus. The program effectively manages the
generation, identification, collection, labeling, handling,
accumulation, transportation, and disposal of all hazardous wastes
including universal wastes and biological and bio-medical wastes
(biohazard wastes) as required by law and includes a system of
documentation and record keeping that exceeds legal requirements
thus effectively reducing the liability that Lesley University may
have in this area.
Hazardous waste reduction has been achieved through an ongoing
effort in toxic use reduction through the substitution of less
toxic or non-toxic substances and through the reduction in the
amounts of toxic substances used. Reducing the amounts of toxic
chemicals used in chemistry laboratory experiments, substituting
non-toxic chemicals, having students work in pairs, and using micro
scale chemistry has significantly reduced the amount of hazardous
wastes generated and thus the associated costs of hazardous waste
removal along with reduced costs for chemical purchases. Less toxic
and thus safer cleaning products and other substances used by the
Physical Plant and Facilities are substituted when practical.
The Public Safety Office has developed and conducts a
comprehensive program of hazardous substances management. There are
three main elements of the program:
- Hazardous Substances Inventory: procurement, inventory, and
storage of all chemicals and hazardous substances.
- Hazardous Waste Reduction through Toxic Use Reduction:
elimination of duplication in chemical purchasing, reduction in the
amounts of toxic and hazardous substances used, substitution of
non-toxic or less-toxic substances, and micro-scale and small-scale
chemistry initiatives.
- Hazardous Waste Management: Identification, collection,
labeling, handling, accumulating, and transporting for disposal all
hazardous and universal wastes and all biological and bio-medical
(biohazard) wastes.
1. Hazardous Substances Inventory
The hazardous substances inventory is maintained by the Public
Safety Office. The inventory currently consists of all chemicals
stored and used by the Natural Sciences department. All chemical
purchase orders should be routed through the Public Safety Office
and that they be included in the inventory system. This would
ensure that all chemicals and toxic and hazardous substances would
be properly stored, their amounts and locations would be
verifiable, unnecessary, and duplicative purchasing would be
avoided, increased opportunities for toxic use reduction would be
available, and tracking of material safety data sheets (MSDS's) is
assured.
All material safety data sheets (MSDS's) for chemicals and
hazardous and toxic substances are reviewed and filed in a master
file maintained by the Public Safety Office. Satellite MSDS files
are maintained for substances used in a particular department or
workplace.
2. Hazardous Waste Reduction (Toxics Use
Reduction)
Hazardous waste reduction (toxics use reduction) has
considerable benefits including less risk to faculty, staff, and
students and cost savings for not having to purchase expensive
chemicals, for not having to have control measures and protective
equipment needed to handle the toxic or hazardous substance, and
for not having the cost for disposal of the hazardous waste. It can
be achieved through the elimination of duplication in chemical
purchasing either through a more complete chemical inventory and
purchasing system managed by the Public Safety Offices or through a
review process where all chemical purchases are reviewed by the
Lesley Department of Public Safety. Also, reduction in the amounts
of toxic and hazardous substances used can be achieved through a
determination of the least amounts necessary to meet the particular
needs or through having students work in pairs for chemistry and
biology laboratory experiments thus cutting the amounts of toxic
and hazardous substances in half. The use of micro-scale and
small-scale chemistry for laboratory experiments dramatically
reduces the use of toxic and hazardous substances. Direct
substitution of a non-toxic or non-hazardous substance for a toxic
substance can eliminate a whole hazardous waste stream.
Substitution can be used effectively in certain chemistry
laboratory experiments. Also, laboratory experiments using less
toxic and non-toxic chemicals can be selected over others using
more toxic or hazardous chemicals. Toxics use reduction, in
addition to providing a safer workplace and cost savings in the
purchase and disposal of hazardous chemicals, is an integral part
of the Department of Safety's University Emergency Plan and shall
be reviewed annually for opportunities for improvement.
3. Hazardous Waste Management
Hazardous wastes are identified, collected, labeled, properly
handled and placed in the hazardous waste accumulation area.
Massachusetts Hazardous Waste Regulations, 310 CMR 30.111 (1)
state: "A hazardous waste is a waste, or combination of wastes,
which because of its quantity, concentration, or physical, chemical
or infectious characteristics may cause, or significantly
contribute to, an increase in mortality or an increase in serious
irreversible, or incapacitating reversible, illness, or pose a
substantial present of potential hazard to human health, safety, or
welfare, or to the environment, when improperly stored, treated,
transported, or disposed of, or otherwise managed." Wastes are
identified and labeled as hazardous wastes based on whether they
exhibit one or more of the following characteristics: ignitability,
corrosiveness, reactivity, and toxicity. They are also identified
as hazardous wastes based on listings on specific types or sources
of hazardous wastes, or of acutely hazardous wastes. Hazardous
wastes are grouped according to the Department of Transportation
(DOT) hazard classes and packing groups in preparation for
transporting.
There is an ongoing effort to identify all processes and
activities which produce chemical, biological, and bio-medical
wastes. Information contained in MSDS's pertaining to waste
disposal is often misleading or inadequate or a simple statement
that the substance must be disposed of in accordance with all
applicable federal, state, and local environmental regulations.
Thus, MSDS's should never be used as a guide for proper waste
disposal. The Environmental Health and Safety Office determines
whether or not wastes are hazardous wastes based on federal and
state regulations and, for wastes not regulated by law, on
hazardous properties which could present a potential human or
environmental danger or create legal liability issues for Lesley
University should they be disposed of improperly. A crucial element
in the identification of hazardous wastes is a complete knowledge
of the chemicals used and the processes or activities involved in
generating the hazardous wastes. It is imperative for those who
generate hazardous wastes to provide all information regarding the
chemicals used and the processes or activities involved in
producing the hazardous wastes. Many wastes require basic testing
to determine their properties including the presence of specific
chemicals or groups of chemicals which would identify them as
hazardous wastes. Treatment, including neutralization, of wastes
identified as hazardous wastes under 310 CMR
30.000 is prohibited. Neutralization of non-hazardous
waste between pH 2.0 and pH 12.5 is allowed. Labeling of hazardous
wastes exceeds federal and state requirements and is designed to
provide maximum information for safety, all information necessary
for lab-packing, and maximum protection against any potential
liability. Thus, Lesley University complies with the Massachusetts
Hazardous Waste Regulations (310 CMR 30.000) which exceeds federal
regulations, the federal Clean Water Act, Massachusetts Department
of Public Health regulations, and other applicable federal and
state regulations.
Hazardous wastes which quality as universal waste are managed
according to the Massachusetts Standards for Universal Waste
Management 310 CMR 30.1000. Universal wastes include certain
batteries such as NiCd and silver batteries (button batteries);
pesticides including mercury based pesticides, arsenic based
pesticides, chlorinated pesticides, and banned or suspended
pesticides; thermostats containing mercury; mercury containing
devices such as manometers, switches, water meters, thermometers,
and gauges; and mercury containing lamps. If you are not sure
whether an item is a universal waste, you should consult the Lesley
University Department of Public Safety.
Biological waste and bio-medical waste which as biohazard wastes
are managed under the Massachusetts Department of Public Health
regulations "Storage and Disposal of Infectious or Physically
Dangerous Medical or Biological Waste State Sanitary Code Chapter
VIII" 105 CMR 480.000. The Environmental Health and Safety Officer
is responsible for making sure that the responsible owner of the
satellite accumulation area takes the waste from the satellite
accumulation area and places the waste in the central storage area.
The waste must then be properly handled, packaged, labeled, and
placed in the appropriate accumulation area, and arrangements made
for their transportation to a licensed disposal facility.
The Public Safety Office is responsible for making arrangements
for the lab-packing and transportation of all hazardous wastes.
Transportation and disposal of hazardous wastes is performed by
licensed transporters. All state and federal regulations must be
complied with. Some hazardous wastes are transported in bulk drums,
while most hazardous wastes are lab-packed into open head drums for
transportation and eventual disposal. Documentation is a key
element of hazardous waste management. Label information is of
primary importance for safety, lab-packing information, and
inventory purposes. A hazardous waste inventory list is prepared
prior to transportation and disposal. Hazardous waste manifests are
prepared at the time the hazardous wastes are lab packed and
transported from Lesley University to the hazardous waste facility.
The waste profiles, manifests, and other records as required by law
become the final element of documentation and must be kept in a
central location which is the Environmental Health and Safety
Office.
All documentation including that which is legally required is
maintained for each shipment. The Lesley University Department of
Public Safety is responsible for making arrangements for the
transportation of all universal wastes to recycling facilities.
Arrangements With Local Boards, Departments, Hospitals,
and Emergency Response
Teams:
Massachusetts hazardous waste regulations, 310 CMR 30.351 (9)
(j) (1-4) require generators of hazardous waste to make
"arrangements to familiarize police departments, fire departments,
local boards of health, and emergency response teams with the
layout of the site, properties of hazardous waste handled at the
site, hazards associated with such wastes, places where personnel
at the site would normally be working, entrances to and roads
inside the site, and possible evacuation routes." Also,
"arrangements with state emergency response teams, emergency
response contractors, local boards of health, and equipment
suppliers" must be made as well as "arrangements to familiarize
local hospitals with the properties of hazardous waste handled at
the site and the types of injuries and illnesses which could result
from fires, explosions, or other releases at the site."
Satellite Accumulation Areas
There are a number of satellite accumulation areas (satellite
points) for hazardous wastes generated at specific locations in
Lesley University. One contained is used per waste stream at each
satellite point. Although the maximum capacity of the container
allowed in the regulations is fifty-five (55) gallons, the actual
container size per waste scream ranges from one hundred (100)
milliliters to fifty-five gallons. All satellite points have spill
control material available. The person responsible for the
generation of hazardous waste at each satellite point is
responsible for ensuring that the container for each waste stream
is properly labeled, that the accumulation start date is entered on
the label when the container is full, and that the waste be taken
to the hazardous waste accumulation area within three days.
Most buildings have satellite points for universal waste
(primarily spent fluorescent lamps for recycling).
Hazardous wastes in satellite accumulation areas are also
monitored by the Lesley University Public Safety Office to prevent
the mixing of incompatible wastes, different waste streams, and
types of wastes and the accumulation of incompatible wastes in the
same location. All labels on hazardous waste containers must be
properly completed.
Hazardous Waste Accumulation Area
The hazardous waste accumulation area is located in [?]. The
room also serves as the chemical storage area and has a sealed
floor to provide containment, fire suppression system, sufficient
heating and cooling to provide a temperature of approximately 65 to
70 degrees Fahrenheit. Spill control material is available for all
chemical spills. The room is properly posted with hazard placards
and signs for chemical storage, hazardous waste, and exists.
Emergency telephone numbers are posted near the telephone.
Inspections of the hazardous waste accumulation area are conducted
weekly and an inspection log is kept for each inspection.
Contingency Plan, Emergency Procedures, Preparedness,
and Prevention
Lesley University has the capacity for over 42,000 gallons of
fuel oil in underground storage tanks and has a Spill Prevention,
Control, and Countermeasures (SPCC) Plan as required by 40 CFR 112,
Oil Pollution Prevention. In addition, specific spill control
materials for the substances used and the hazardous wastes
generated are made available at hazardous waste generation sites,
satellite points, and the hazardous waste accumulation area.
Workers at these locations are made familiar with the spill control
materials and emergency systems.
[The Office of Public Safety is currently reviewing these policies and
procedures. Please contact the Office of
Public Safety with any further questions.]
TRAINING
The Massachusetts Hazardous Waste Regulations, 310 CMR 30.000,
requires training for personnel assigned to hazardous waste
management for small quantity generators (SQG's). Section 30.516 of
the regulations states that personnel assigned to hazardous waste
management "shall successfully complete a program of instruction or
on-the-job training that teaches them to perform their duties in a
way that ensures that facility's compliance with 310 CMR 30.000 and
the condition of the facility's license". The instruction shall
include hazardous waste management procedures including contingency
plan implementation. New personnel cannot work unsupervised until
they have received the proper training which must be completed
within six months of their employment of assignment to hazardous
waste management. Personnel shall also have an annual training
review. All training records of current personnel shall be kept
until closure of the facility and those of former personnel shall
be kept for at least three years from the time they last worked at
the facility. A written personnel training plan is required to
ensure compliance with 310 CMR 30.516 (1). To ensure that personnel
are able to respond effectively to emergencies, the training plan,
at a minimum, shall specify how personnel will be familiarized with
the properties and hazardous nature of the hazardous wastes at the
facility and with emergency procedures, emergency equipment,
emergency systems, and personal safety equipment. Procedures for
using, inspecting, repairing, and replacing the facility's
emergency and monitoring equipment; use of automatic waste feed
cutoff systems; communications or alarm systems; response to fire
or explosions; response to potential ground water or surface water
contamination incidents; and shutdown of operations shall be
included where applicable.
Generator status determines training needs. For small quantity
generators (SQG's) a written training plan is not required for
personnel assigned to hazardous waste management. Also, a written
contingency plan is not required. Lesley University is currently a
small quantity generator; however, generator status can change.
Should the college become a large quantity generator, it shall be
university policy that personnel assigned to hazardous waste
management receive formal training within six months of the
generator status change and annual training review thereafter as
required by 310 CMR 30.000. Personnel in SQG facilities responsible
for hazardous waste management can always benefit from training;
more training is better than less.
PROCEDURES FOR HANDLING CHEMICAL WASTE*
[The Office of Public Safety is currently reviewing these policies and
procedures. Please contact the Office of
Public Safety with any further questions.]
HAZARDOUS WASTE AND UNIVERSAL WASTE
- Label waste containers clearly and completely with "CHEMICAL
WASTE", "HAZARDOUS WASTE", or "UNIVERSAL WASTE"; the contents; the
date (accumulation start date**); "HANDLE WITH CARE"; all specific
hazards (flammable, oxidizer, corrosive, toxic, etc.); and all of
the following which may apply: course, experiment, professor, and
room number. Printed labels are available from the Environmental
Health and Safety Office.
- Do not fill waste containers to the top.
- Cap waste containers tightly, especially if any volatile
organic chemicals are present.
- Provide a copy of the laboratory experiment or the chemicals
that went into the waste for each laboratory experiment. The
Environmental Health and Safety Officer will determine whether or
not the chemical waste is hazardous waste and provide the proper
packaging and hazardous waste handling.
- The accumulation start date must be entered on the label of the
container at the satellite point (satellite accumulation area) when
the container becomes full.
Procedures for Handling Biological and Bio-Medical
Waste
- All biological and bio-medical waste, including all treated
biological and bio-medical waste, must be placed in an approved red
bag with an approved biohazard label.
- All sharp objects must be placed in approved sharps containers
with an approved biohazard label.
Labeling
The Massachusetts Right-to-Know Law requires that all containers
of more than five pounds or more than one gallon containing toxic
or hazardous substances in the workplace must be labeled with the
chemical name of the substance. For mixtures, the label must
include the chemical name of each toxic or hazardous constituent if
that constituent comprises one percent or more (two percent or more
if an impurity) of the mixture. Also, labels must be clear,
prominent, in English, and weather resistant. Containers must
include the NFPA symbol with appropriate hazard rating if
available.
The Occupational Safety and Health Administration (OSHA)
regulations, 29 CFR 1910, require that labels include the identity
of the substance (the name of the product as it appears in the
MSDS), health hazard warnings for all hazards (including target
organ health effects), physical hazard warnings (i.e. flammable,
corrosive, oxidizer, and reactive), and for manufacturers and
distributors, the name and address of the responsible party, should
additional information be needed. The policy of the Massachusetts
Department of Labor and Workforce Development, Division of
Occupational Safety is that containers labeled in accordance with
the OSHA Hazard Communication Standard will also be considered to
satisfy the labeling requirements of the Massachusetts
Right-to-Know Law.
The National Research Council recommends labels showing the
contents of the container and associated hazards. There are many
specific labeling requirements both for groups of substances with
specific hazards and for specific individual substances. The many
labeling requirements can occasionally cause confusion and
inadvertent mislabeling. Labeling of toxic or hazardous substances
is a very important function and is essential for your protection
and the protection of your fellow workers and others who might come
in contact with the substance. Even very small quantities of many
substances can be harmful or even cause severe injury or health
risk. Substances placed in temporary unlabeled containers for
immediate use are an accident waiting to happen, should the
container be set down for even a minute and someone not knowing the
contents picking up the container. To avoid confusion and to reduce
risk to yourself and the others in your workplace, the following is
essential:
LESLEY UNIVERSITY Policy
- All containers, regardless of size, must be labeled with the
name of the substance (chemical formulas and structural diagrams
are not legally acceptable).
- To the extent possible, all labels must show the health hazards
and the physical hazards associated with the substance.
- If you find an unlabeled container and are unsure of its
contents, notify the Department of Public Safety at ext. 8888.
ANNUAL REVIEW
The three substances of the Hazardous Substances Management Plan
(Hazardous Substances Inventory, Hazardous Waste Reduction through
Toxics Use Reduction, and the Hazardous Waste Management) shall be
reviewed annually for the purpose of improving this plan and for
making hazardous substances management more effective and
efficient. Annual review checklists shall be developed to aid in
the process. In addition, periodic comprehensive independent
environmental audits shall also review the plan. Changes in the
plan shall be documented as to the reason for the change as well as
the reason for the original language. Thus, a history of the
Hazardous Substances Management Plan can be established with
earlier and subsequently replaced language being documented for
future inclusion in the plan should it be found that it was more
suitable.