22.0 HAZARDOUS WASTE MANAGEMENT
The following sections provide hazardous waste management guidelines and procedures. This chapter covers the following topics:
22.2 General Information
Hazardous waste disposal is governed by the Environmental Protection Agency (EPA) and the Tennessee Department of Environment and Conservation (TDEC) through State and Federal regulations. The purpose of environmentally sound disposal methods is to prevent harm to the water, land, and air. UTIA complies with hazardous waste disposal regulations by means of the Hazardous Waste Management Program, as specified in this section.
All areas that generate hazardous waste must have a door sign which designates where the waste is stored in that area and what type of waste it is. In addition, the location inside the room must be designated by a sign (yellow, black letters, stating: "Hazardous Waste Storage Area.")
22.2.1 Permits and Requirements
UTIA is a "Large Quantity Generator" of hazardous waste. The Institute has two generator permits: one for Veterinary Teaching Hospital, and one for Teaching and Research portions of the Institute. The Safety Office will assist any department or research and education center branch station in determining its hazardous waste disposal needs.
22.2.2 Penalties of Noncompliance
Noncompliance with any hazardous waste regulation may result in substantial fines, penalties, and citations for the University. In addition, individual generators may be personally liable. Generators may be cited or fined for numerous types of violations. Violations range from improperly labeling a waste container to intentionally disposing of hazardous waste incorrectly.
22.2.3 Role of the Department of Environmental Health & Safety and the UTIA Safety Office
The Department of Environmental Health & Safety administers the Hazardous Waste Management Program for all of the Knox campus and the Institute. Compliance with this program is very demanding - it requires full cooperation by all campus entities. The main focus of this program is chemical waste management. The program does not include procedures for the management of radioactive, infectious, biological, or nonhazardous waste. (For questions on these topics, please call the UTIA Safety Office.)
The Department of Environmental Health & Safety (DEHS) arranges for the collection and disposal of waste. DEHS and the UTIA Safety Office also maintain permanent records of all disposed waste. Contact the UTIA Safety Office for information on hazardous waste disposal not found in this section.
22.3 Hazardous Waste Categories
22.3.2 Types of Hazardous Waste
An item is considered waste when the owner determines that the material is no longer useful and needs to be discarded. An item is considered to be hazardous waste if it also meets one or more of the following characteristics:
Individual departments are responsible for properly identifying the hazardous waste they generate and for following University disposal procedures.
22.4 Containers, Tags, and Collection
Proper containment, tagging, collection and disposal are essential to the success of the Hazardous Waste Program.
22.4.1 Filling Waste Containers
Hazardous waste collection containers must be in good condition, must not leak, and must be compatible with their hazardous contents (e.g., do not use metal containers for corrosive waste or plastic containers for organic solvents.) All containers must have suitable screw caps or other secure means of closure. When large waste containers (greater than 10 gallons total volume) are warranted, contact the Safety Office for assistance.
If you are reusing a container to accumulate waste, destroy the original product label. A new label must be placed on the container. EPA regulations require that waste containers be labeled with the identity of the contents and the words "Hazardous Waste." (see below.)
IMPORTANT: Never overfill hazardous waste containers. Expansion and excess weight can lead to spills, explosion, and extensive environmental exposure.
IMPORTANT: Keep all waste collection containers closed except when adding or removing material.
22.4.2 Completing Labels
Follow these guidelines for completing hazardous waste labels:
22.4.3 Collection and Disposal
Collection days are held approximately every three months. Containers with improper caps, leaks, outside contamination, or improper labeling will not be accepted until these problems have been corrected.
It is very important that hazardous waste be disposed of properly. Improper disposal methods for hazardous chemical waste include the following:
Disposing of Empty Containers
- What do I do with empty chemical containers?
- How do I get rid of them?
- Can they be placed in the trash dumpster?
These are questions frequently asked by UTIA personnel. The answer is fairly simple but very important.
EPA regulations stipulate that empty containers must meet the following requirements:
IMPORTANT: Containers that do not meet the requirements mentioned here must be treated as hazardous waste.
22.5 Minimization and Substitution
The cost of commercial waste disposal continues to rise and the amount of waste generated continues to increase. UTIA cannot control disposal costs, but it can reduce the amount of waste generated. The following sections discuss how to minimize waste sources and waste products.
22.5.1 Waste Source Reduction Techniques
Use the following techniques to reduce waste sources:
Segregated waste is safer and easier to dispose of than nonsegregated waste. Mixed waste, for example, must be handled as both radioactive waste and hazardous waste. Each employee who generates waste is personally responsible for the following:
- Halogenated solvents
- Non-halogenated solvents
- Heavy metals
Do not mix non-hazardous waste, such as water, with hazardous waste.
22.7 Special Concerns
Employees who generate hazardous waste must maintain and control their hazardous waste accumulation areas. Special concerns for hazardous waste include the following:
22.8 Ethidium Bromide Disposal
There is no evidence for the carcinogenicity or teratogenicity of this substance in humans, however it is a powerful mutagen and should be handled as a possible carcinogen and reproductive toxin. It may present a hazard if it is poured down the drain untreated or placed in the trash. Ethidium bromide is not regulated as hazardous waste, but is handled as a special waste. The following are the recommended disposal procedures for ethidium bromide:
22.8.1 Electrophoresis Gels, Contaminated Gloves and Other Equipment
Collect ethidium bromide gels, contaminated gloves and other equipment (DRY wastes) as chemical hazardous waste and bring them to the quarterly waste pick-up (NOTE: The gels must not have running liquid in the bottom of the bag). One suggested method to prevent personnel cross-contamination while opening and closing the waste container is to use a lined step-on can as the waste receptacle. When it is time for disposal, place the sealed liner bag in a secondary container such as a bucket, cardboard box, or secondary sturdy bag and put a UT hazardous waste label on the outside of the package. Handle EtBr waste containers like any other hazardous waste - it must be in a container that is labeled and closed unless you are actively adding waste to the container.
Benefits - the can automatically closes and the lid doesn't get handled, which reduces cross-contamination of other surfaces. Use a thick liner bag and do not put sharps in the container that could puncture the bag.
NOTE - Ethidium bromide waste that is not mixed with a biological hazard DOES NOT go in red bags or red containers, should not be labeled with a biosafety symbol, and especially should not be treated in an autoclave. For mixed EtBr and biohazard waste contact the UTIA Safety Officer at 4-1153 or the UT Biosafety Officer at 4-1938 for guidance.
22.8.2 Sharps Contaminated with Ethidium Bromide
Contaminated needles, syringes, etc. must be discarded into a puncture-proof plastic container (must not be red and must not have a biohazard symbol on it) with a lid that closes. It shall be marked as ethidium bromide waste. Do not mix these chemically contaminated sharps in a red biohazard sharps container that may go in the autoclave. Autoclaving chemical waste creates exposure to the chemicals at they heat and volatilize. Dispose of the container as chemical hazardous waste at a waste pick-up.
22.8.3 Ethidium Bromide Solutions
1. Charcoal FiltrationFiltering the aqueous ethidium bromide waste solutions, free of other contaminants, through a bed of activated charcoal is a relatively simple and effective method for removal of ethidium bromide. The filtrate may then be poured down the drain.
There are two simple kits available for charcoal filtration:
a. Funnel Kit
Schleicher and Schuell supply a commercial filter funnel kit that uses a packaged charcoal disk that is graduated for easily tracking the amount of aqueous solution calculated for a fixed quantities of ethidium bromide residue. This product is recommended for dilute solutions such as electrophoresis gel staining buffer (0.5X TBE/0.5 ug/ml EtBr) and is particularly useful for labs that generate large amounts of solutions at a time. The kit is available through Fisher Scientific, Schleicher and Schuell, or VWR.
Filter the ethidium bromide solution through the charcoal filter.
Pour filtrate down the drain.
Place charcoal filter in a sealed bag (e.g., zip-lock) and place with EtBr gels for hazardous waste disposal.
b. The Green Bag
Another simple charcoal filtration method is the Green Bag, manufactured by BIO 101. The Green BagŪ Kit allows rapid and trouble-free concentration of ethidium bromide from large volumes of solutions into a small "tea" bag containing activated carbon which is then conveniently disposed along with other solid hazardous wastes. One kit has the capacity to remove 500 mg of ethidium bromide from solutions (10mg EtBr per "tea bag").
- Place the Green Bag into the ethidium bromide solution.
- Allow to sit for the allotted time.
- Pour filtrate down the drain.
- Dispose of the Green bag with EtBr gels for hazardous waste disposal.
2. Chemical Neutralization
Solutions containing ethidium bromide can be deactivated, neutralized and poured down the drain with copious amounts of water. Deactivation may be confirmed using UV light to detect fluorescence. There are three recognized methods for deactivation:
a. Armour MethodThis is the simplest method, but is somewhat controversial. One study found traces of mutagenic reaction mixtures using this method. (Lunn, G. and E. Sansone, Analytical Biochemistry, vol. 162, pp. 453-458, 1987)
- Combine equal amounts of ethidium bromide solution and household bleach.
- Stir constantly for four hours or let sit for 2-3 days.
- Adjust pH to 4-9 with sodium hydroxide.
Pour down drain with copious amounts of water.
b. Lunn and Sansone MethodFor each 100 ml of ethidium bromide solution:
- Add 5% hypophosphorus acid.
- Add 12 ml of 0.5 M sodium nitrate.
- Stir briefly and let stand for 20 hours.
- Adjust pH to 4-9 using sodium hydroxide.
- Pour down drain with copious amounts of water.
c. Quillardet and Hoffnung MethodThis method uses 0.5 M potassium permanganate and 2.5 M hydrochloric acid. Since chlorine gas may be released in significant concentration, EHS does not recommend using this method.
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