_Hazard Communication Plan_

Appendix G. Hazardous Waste Disposal Information

1. Planning and Purchases

It is your responsibility as generators of hazardous waste to make every attempt possible to minimize the amount produced. To the extent that chemicals can be recovered, recycled, or reused safely there is obvious economic incentive to do so. In addition, materials that are recovered, recycled, or reused do not become a liability problem or a problem for the environment.

The planning of every purchase must include the consideration of the disposal of leftover starting materials and of the products and by-products that may be generated as a result of usage of a hazardous material. Questions to be considered include the following:

Hazardous materials should be purchased in the smallest possible volumes to reduce the amount of unused chemicals that could end up as wastes. As the cost of chemicals and disposal continues to climb, any reduction in volume of chemicals purchased will offer benefits. Keep in mind that the perceived economy of buying in bulk is more than offset by disposal costs for the package and its residues.

2. Recovery and Recycling

The recycling process is exempt from hazardous waste regulation except that waste accumulated prior to recycling must be managed according to accumulation requirements. Distillation is an example of a viable recovery option. All residues such as still bottoms from the recycling process are regulated and must be managed as hazardous waste.

Photographic fixer solutions cannot be discharged to the sink and will be collected for silver recovery. The Environmental Health and Safety Office operates a silver recovery unit in SB-3 McGregory Hall.

Other candidates for recycling include batteries, precious metals, scrap metals, waste oil, and formaldehyde. Every effort must be made to determine if other materials can be reused, recovered, or recycled.

3. Hazardous Waste Identification

The first step in hazardous waste management comes when the two following questions must be answered:

  1. Is this material a waste?
  2. Is this waste a regulated hazardous waste?

The hazardous waste regulations apply to materials only when they become a waste and only if they are deemed hazardous under specific evaluation criteria.

4. Hazard Determination

Once you determine that a chemical material is a waste, it must be evaluated to determine if it is a hazardous waste. Hazardous wastes are defined by the New York State Department of Environmental Conservation (NYDEC) following Environmental Protection Agency (EPA) regulations. Wastes can be hazardous in one of two ways: they are either wastes and spent materials that are hazardous by definition and contained in specific lists, or they exhibit one of four hazardous characteristics: ignitability, corrosivity, reactivity, or toxicity.

a. Listed Wastes

Wastes that are hazardous because they appear on one of four lists are called "listed hazardous wastes". The four lists are categorized as wastes from specific sources (K-list), wastes from non-specific sources (F-list), certain discarded commercial products (U-list), and "acutely hazardous" commercial chemical products (P-list). The F and K lists apply to general processes, while the U and P lists are for reagent chemicals. The P-list category which contains wastes such as cyanides is more rigorously regulated. As a SQG, Colgate cannot generate more than 1 kg/month or store more than 1 kg of waste from the P-list. Generation of acutely hazardous waste must be closely monitored. Mixtures of hazardous and non-hazardous waste are regulated as hazardous waste. So please segregate hazardous and non-hazardous materials whenever possible.

b. Characteristic Wastes

If a waste is not on one of the lists of hazardous wastes , you must determine if the waste possesses one or more of four hazardous characteristics defined below: ignitability, corrosivity, reactivity, or toxicity. Such wastes are called "characteristic hazardous wastes". A generator may use his knowledge based on the materials or processes used or may test the waste to determine if it possesses one of the four characteristics. Personnel who generate chemical waste should have enough general knowledge of the hazardous characteristics of their waste to classify it.

Ignitability

Reactivity

Corrosivity

Toxicity

Good sources for assistance in hazard determination are MSDSs, chemical dictionaries, and labels.

5. Accumulation

An important step in the chemical disposal sequence involves the temporary storage of waste at or near the point of generation. Except when single chemicals are accumulated for recycling or recovery, waste accumulation generally involves bulking several materials into one container.

Please adhere to the following guidelines for safe accumulation of chemical waste:

Some chemicals products that are not regulated as hazardous waste can be disposed of in the sanitary sewer or normal trash. The decision to use one of these methods of disposal must be made after careful consideration of the consequences.

6. Sink Disposal

Sinks and most drains on campus are connected to the local sanitary sewer system with the effluent eventually going to Hamilton's Wastewaste Treatment Facility. Materials that cannot be disposed of via the sanitary sewer are materials that interfere with the treatment systems or chemicals that may cause a danger to the system or human health. These chemicals include but are not limited to:

a. Sink Disposal Procedures

7. Trash Disposal

Non-hazardous solids can be disposed of in the trash (no liquid wastes are allowed in the landfill). As mentioned before, the decision to use the trash must be made after careful consideration of the consequences. Non-hazardous materials will create a hazard if solid particles are inhaled or reach the eyes. A custodian may come in contact with it when he or she empties the trash. Our grounds grew could be exposed to the material when they handle the trash and compact it in the truck. All of our solid waste goes to the Madison County Landfill and will be there essentially forever.

Do not dispose of chemicals loosely in the trash. Minimize potential for exposure by encasing non-hazardous chemicals in bags, boxes, or containers. Never dispose of large amounts of non-hazardous chemicals in the trash. Broken glass should be collected in puncture resistant containers and disposed of in such a way as to protect custodians and the grounds crew. Empty containers that once held a hazardous material will be rinsed clean to remove any residue. All residue containing hazardous waste will be managed as such.

Substances known to be toxic will not be disposed of in the trash even if they are not regulated as hazardous waste.

Last modified: April 08, 1998