February 2006
Hazardous W
Management
Regulatory
Informatio
Common
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of the science laboratory.
School administrators,
science department
personnel, janitorial staff,
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interest and involvement
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also benefit from the
information contained
»ol kit
Hazardous Waste
Management for
School Laboratories
and Classrooms
EPA Region 8 INFORMATION KIT
EPA 908-F-06-001
School Science Laboratories
Most of the waste chemicals resulting from science laboratory experiments
are considered hazardous, so the generation, storage, and disposal of
hazardous wastes must be given special consideration in every
experiment.
This tool kit provides guidelines for proper management of your wastes
and resources to help minimize risks and maintain a safe school laboratory
environment. Integrating these guidelines in your teaching curriculum will
help reinforce to students the importance of lessening the impact to and
protecting the environment.
The following sections address issues that should be considered in the
management of wastes that are generated from science education.
Specific information about mercury, lead, asbestos and polychlorinated
biphenyls is also presented. These hazardous materials may pose
potential concerns in laboratories as well as in other school environments.
This tool kit is not meant to be a comprehensive information source on all
school hazards. For more information about other important topics such
as pesticides, facility maintenance, and environmentally preferable
cleaning products, please visit EPA's Healthy School Environment
Resources web site at http://cfpub.epa.gov/schools/index.cfm.
The regulatory information provided in this tool kit does not itself
represent or replace the applicable environmental regulations for schools;
instead, the information is intended for informational and guidance
purposes only.
Hazardous Waste Management
Everyone associated with the school science laboratory shares the
responsibility to minimize the amount of waste produced, and to dispose
of wastes in a way that has the least impact on human health and the
environment. Prior to generating and managing any wastes, carefully
evaluate each experiment and confirm that your work environment and
disposal methods are safe and in compliance with all applicable
regulations.
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i- Carefully evaluate each experiment to be sure that:
o There is reasonable justification for use of the chemicals
o The potential risks are understood
o Less hazardous substitutes are not available
o The quantities to be used are as small as practical, and
o The waste disposal method is within the capabilities of the
school and in accordance with current regulations;
i- Consider developing a Waste Management Plan;
I Contact your governing regulatory authority (tribal environmental
director, local health department, state, and/or EPA) for assistance;
i- Contact your local fire department or local emergency planning
committee (LEPC) for fire codes and emergency planning
information, and chemical handling assistance if needed;
J- Do not dispose of any materials or wastes in sinks and drains
without prior approval from the local publicly owned treatment
works (wastewater treatment department);
i- Do not dispose of any materials or wastes in sinks and drains if
your school discharges to a septic tank system;
4- Do not dispose of any chemicals in the trash without contacting
your regulatory authority and your solid waste disposal service for
approval;
i- Do not dispose of any chemicals by evaporation in a fume hood or
other location.
Regulatory Information
When wastes are generated from science activities used for instruction,
various regulatory requirements may apply. It is the school's
responsibility to determine if hazardous wastes are being generated and
how the hazardous waste regulations apply. The
following information and links provide resources and
direction for compliance with the applicable regulatory
requirements, but do not serve as a substitute for the
regulations themselves. Some best management
practices are also provided. Proper waste management
will ensure a safer school and protection of human
health and the environment.
It is important to realize that you may be held legally liable for your
hazardous waste and any damage it creates even after it leaves your
school and is transported to a treatment, storage, or disposal facility.
Under the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), commonly known as Superfund, you can be
required to contribute to the costs of cleaning up any contamination
resulting from your wastes wherever they may end up. Therefore, it is
important to ensure compliance with the regulations and that the business
you pay to dispose of your wastes is approved and in full compliance.
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To avoid liability and ensure compliance with regulations:
i- Maintain accurate records from the point of waste generation to
waste disposal, including the final disposition of the wastes;
4- Treat/neutralize wastes yourself in accordance with the rules.
Generators of hazardous waste may be able to treat their wastes
onsite in tanks, containers, or containment buildings without
obtaining a permit if certain requirements are met.
4- Make sure the people you pay to dispose of your wastes are in full
compliance.
o Check the company's compliance status via EPA's
Enforcement and Compliance History Online, or ECHO, at
www.epa.gov/echo/
o Ask them to provide written documentation of all necessary
permits, and maintain copies of these
o Inquire about their record keeping practices for transport
and disposal
o Ask them about their treatment and disposal practices, and
the final disposition of your wastes
o Inquire about any special conditions or minimum pick-up
requirements that may apply to your wastes
o Make arrangements by phone before shipping any amount
Reducing the amount of hazardous waste you produce will be the most
economical and environmentally sound approach to minimizing the
requirements that apply to your school.
i- Please review the section on Waste Minimization and Pollution
Prevention in the "Pollution Prevention Measures for Safer School
Laboratories" (EPA 908-F-06-002) tool kit for tips and
recommendations.
The generation and management of hazardous wastes are specifically
regulated under the Resource Conservation and Recovery Act (RCRA).
Major highlights under this regulation are outlined below in steps as a
general guide for examining the proper management of your wastes.
Please refer to a more complete discussion of the Federal regulatory
requirements for hazardous waste management in the Code of Federal
Regulations (CFR), CFR 40 Parts 260-279, to understand all of the
requirements that may apply to your school.
STEP 1:
Check with your state and tribal environmental offices to
determine how hazardous wastes are regulated. Many state
and tribal programs and regulations can be more comprehensive
and/or more stringent than Federal regulatory requirements.
STEP 2:
When waste is produced, determine whether it is hazardous.
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i- Waste is considered hazardous if it is (a) solid waste defined as a
liquid, solid, semi-solid, contained gaseous material, or combination
thereof, (b) discarded material (no longer usable; will be disposed
of or recycled; will be accumulated, stored, or treated for disposal),
(c) is not excluded from regulation as a hazardous waste, and (d)
meets any of the following criteria:
o It displays certain hazardous characteristics based on the physical
and chemical properties of the waste: ignitability, corrosivity,
reactivity, or toxicity;
o It is listed in the regulations as hazardous.
Hazardous waste may demonstrate more than one characteristic or be
both listed and characteristically hazardous waste.
STEP 3:
Calculate the total amount of a_N of the hazardous waste your school
generates on a monthly basis. The amount you generate will determine
your generator status and the different regulatory requirements that will
need to be met.
In general, the less waste your laboratory produces, the fewer regulations
the school must comply with. Most schools are small generators of
hazardous waste. Note that certain chemicals are considered acute
hazardous waste, such as mercury, so small amounts of these chemicals
can define your generator status.
The following outlines the major requirements for small generators:
1- Conditionally Exempt Small Quantity Generators (CESQGs)
generate less than or equal to 100 kg (220 Ibs) of hazardous waste
or less than or equal to 1 kg (2.2 Ibs) of acute hazardous waste per
month [40 CFR 261.5]. This is roughly less than half of a 55-gallon
drum.
o CESQGs must not accumulate more than 1,000 kg (2,200
Ibs) of hazardous waste at any time
o CESQGs must ensure that their hazardous waste is delivered
to someone who is authorized (state approved, RCRA
permitted, or legitimate recycler) to manage their waste
o Personnel training is not required, however recommended.
i- Small Quantity Generators (SOGs) generate between 100 kg (220
Ibs) and 1,000 kg (2,200 Ibs) per month of hazardous waste [40
CFR 261.5 and 262].
o SQGs must obtain an EPA Identification number (contact
your authorized state for this number)
o SQGs must comply with proper handling requirements for
packaging, labeling (contents, date), marking, placarding,
satellite accumulation, etc.
o SQGs must not accumulate more than 6,000 kg of
hazardous waste for more than 180 days (or 270 days if
waste is to be transported over 200 miles)
o SQGs must comply with the manifest system. A manifest is
a form that tracks waste from its origin to its disposal.
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o SQGs must comply with record keeping and reporting
requirements
o SQGs must ensure that their hazardous waste is delivered to
someone who is authorized (RCRA permitted or legitimate
recycler) to manage their waste
o Basic personnel training is required.
i- Large Quantity Generators (LOGs) generate more than 1,000 kg
(2,200 Ibs) of hazardous waste or more than 1 kg (2.2 Ibs) of acute
hazardous waste per month [40 CFR 262].
o LQG requirements are more comprehensive than for small
generators. Refer to the regulations for LQG requirements.
J- Remember that states and tribes may have additional requirements
for generators. Contact your state or tribe if you are not familiar
with the requirements that may apply to you.
STEP 4:
Store your wastes properly prior to disposal or recycling. All hazardous
wastes should be placed in containers that are in good condition and
compatible with the wastes, and kept closed at all times except when
adding or removing wastes. Hazardous waste containers should be placed
on an impervious surface (pavement, tile) without floor drains.
Follow storage limits and permissible accumulation times according to your
generator category (outlined in Step 3).
i- Keep individual and incompatible hazardous waste streams
segregated:
o Store recyclable wastes like recoverable metals and solvents
separately, as well as separate from nonrecyclable wastes
o Keep nonhazardous wastes separate from hazardous wastes
o Do not mix incompatible wastes (e.g. ignitables and oxidizers);
J- In most cases when a hazardous waste is mixed with a
nonhazardous waste, the mixture will be regulated as a hazardous
waste. Separating these wastes helps limit your total amount of
hazardous waste.
STEP 5:
Land Disposal Restrictions (LDRs) are regulations that minimize hazards
from the land disposal of hazardous wastes. LDRs set treatment
standards for constituents in hazardous wastes, including mercury, which
must be achieved before land disposal [40 CFR 268].
i- LDRs are applicable to SQGs and LQGs, and a possible state
requirement for CESQGs.
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Common School Hazards
The presence of mercury, asbestos, lead, and polychlorinated biphenyls in
schools may present potential health hazards. It is
important to understand the sources of these materials,
routes of exposure, health effects, and the regulations that
apply to their management.
MERCURY
Mercury and its compounds, both organic and inorganic, are serious health
hazards. The most harmful acute exposure occurs through inhalation, but
it is also harmful by absorbance through the skin. Production of mercury
vapor is heightened by heating mercury or by splattering that occurs
during a spill. Symptoms of mercury exposure can include tremors,
emotional changes, headaches, neuromuscular changes, disturbances in
sensations, changes in nerve responses, and performance deficits on tests
of cognitive function. Higher mercury exposures can include kidney
effects, respiratory failure and death. Laboratory sources of mercury
include, among others, thermometers, manometers (barometers), lamps,
lab supplies and chemicals, and batteries.
J- Mercury is regulated by several environmental laws. The regulation
most applicable to your school is the Resource Conservation and
Recovery Act (RCRA).
i- EPA strongly encourages schools to discontinue use of and remove
all mercury compounds and mercury-containing equipment.
4- Mercury wastes are determined hazardous by assessing whether
the wastes are characteristic or listed (see Step 2 above).
1- LDRs and treatment standards apply to mercury contained in
hazardous waste.
J Products containing mercury, such as batteries, thermostats, and
fluorescent lamps or other mercury-containing lamps, are
considered hazardous and may be managed under the Universal
Waste Regulations. The Universal Waste Regulations [40 CFR 273]
streamline collection requirements and decrease regulatory burden,
while promoting proper recycling and management. The primary
benefits of the Universal Waste Rule are that the waste does not
count towards the monthly total of hazardous waste in determining
generator status; there are reduced notification and record-keeping
requirements; and less stringent storage time limits. In Colorado,
for example, wastes may be shipped without a manifest and
shipped by common carrier instead of a hazardous waste
transporter.
ASBESTOS
The presence of asbestos in schools presents the potential for both
intentional and accidental disturbance and exposure. Asbestos is a
naturally occurring mineral fiber that has been added to a variety of
building products to strengthen them and to provide heat insulation and
fire resistance. For the most part, asbestos is safe if it is intact. If
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asbestos is disturbed and fibers are released into the air, they can be
inhaled into the lungs and become a potential health risk. Continued
exposure can increase the amount of fibers that remain in the lung. Fibers
embedded in lung tissue over time may cause serious lung diseases.
J- Asbestos is regulated by the Asbestos Hazard Emergency Response
Act (AHERA), the Toxic Substances Control Act (TSCA), and the
Clean Air Act (CAA).
i- Schools are required to inspect for asbestos-containing material
(ACM), to develop and maintain an up-to-date Asbestos
Management Plan, and to safely manage ACM.
LEAD
The presence of lead in schools may also present a health hazard. The
most common lead hazards in schools are lead-based paint, lab chemicals,
lead dust, and contaminated soil. Other sources of lead hazards are older
plumbing fixtures, vinyl miniblinds, painted toys and furniture made before
1978 that may be painted with lead-based paint, glazes (pottery), and
nearby lead smelters or other industrial sources. Exposure to low levels of
lead can cause nervous system and kidney damage, learning disabilities,
attention deficit disorder, and decreased intelligence. High levels of lead
can have devastating effects on children, including seizures,
unconsciousness, and, in some cases, death.
i- Lead is regulated by the Toxic Substances Control Act (TSCA), the
Resource Conservation and Recovery Act (RCRA), and the Safe
Drinking Water Act (SDWA).
i- Child-occupied facilities must comply with specific standards for
lead paint hazards.
POLYCHLORINATED BIPHENYLS (PCBs)
Polychlorinated biphenyls (PCBs) are mixtures of synthetic organic
chemicals with the same basic chemical structure and similar physical
properties ranging from oily liquids to waxy solids. PCBs were used in
hundreds of industrial and commercial applications including electrical,
heat transfer, and hydraulic equipment; as plasticizers in paints, plastics,
and rubber products; in pigments, dyes, and carbonless copy paper as well
as other applications. The most common type of PCB-containing waste
that may be found in schools is fluorescent light ballasts manufactured
prior to 1979. PCBs are probable human carcinogens (cancer-causing)
and can also cause a series of non-cancer adverse health effects, including
effects on the immune system, reproductive system, nervous system,
endocrine system, and others.
4- PCBs are regulated by the Toxic Substances Control Act (TSCA),
which includes prohibitions on the manufacture, processing, and
distribution in commerce of PCBs; and the Comprehensive
Environmental Response, Compensation, and Liability Act
(CERCLA).
J Fluorescent and high intensity discharge ballasts manufactured
prior to 1979 contain PCBs. Light ballasts should be marked with
either a date of manufacture or a marking by the manufacturer
stating "No PCBs." If neither is found, the ballast must be assumed
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to contain PCBs and be managed according to regulation.
i- The proper method for disposing used ballasts depends on the type
and condition (leaking or non-leaking) of the ballasts, as well as the
regulations in the state where they are removed and discarded.
Under TSCA, non-leaking PCB-containing ballasts may be disposed
in a municipal solid waste landfill. However, to minimize potential
releases to the environment, EPA highly recommends that they be
packed in drums and shipped for disposal to a TSCA landfill, TSCA
high temperature incinerator, an approved hazardous waste landfill,
or to an approved recycler.
i- If your school disposes a pound or more of PCBs (roughly 12-16
fluorescent ballasts) in a 24-hour period, the National Response
Center at 1-800-424-8802 must be notified.
4- Disposers of non-leaking PCB-containing light ballasts are subject
to liability under CERCLA should the municipal landfill where the
ballasts were disposed have releases and become subject to clean-
up.
4- Submersible pumps used for groundwater wells have the potential
to contain capacitors containing PCBs. Contact a state-licensed
well driller to learn whether the pump motor is likely to contain a
PCB-filled capacitor. Licensed pump installers can advise well
owners on leak detection, pump replacement, water supply system
cleanup, and proper disposal of contaminated pumps. Drinking
water samples collected for testing should be sent to a certified
water testing lab.
In addition to hazardous waste regulations in the Resource Conservation
and Recovery Act (RCRA), Subtitle C, and the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA), other
environmental regulations that may apply to your school include:
4L RCRA Subtitle D - solid waste management
J- Emergency Planning and Community Right-to-Know Act (EPCRA)
i- Toxic Substances Control Act (TSCA)
i- Occupational Safety and Health Act (OSHA)
4- Clean Air Act (CAA)
4- Clean Water Act (CWA)
4- Safe Drinking Water Act (SDWA)
4- Asbestos Hazard Emergency Response Act (AHERA)
4- Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA)
4- Department of Transportation (DOT) regulations
4- National Fire Protection Association (NFPA) regulations
4- Municipal and local standards.
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Compliance Assistance
There are many U.S. EPA resources available to provide
additional information on regulatory requirements and waste
reduction methods for hazardous wastes.
U.S. EPA Region 8
Solid & Hazardous Waste Program
1-800-227-8917
http://www.epa.gov/region08/land_waste/rcra/rcracontact.html
o Solid and hazardous waste staff are available to answer specific
questions and provide additional information on hazardous waste
issues
U.S. EPA Healthy School Environments
http://cfpub.epa.gov/schools/index.cfm
o Provides on-line resources to help facility managers, school
administrators, architects, design engineers, school nurses,
parents, teachers and staff address environmental health issues in
schools.
U.S. EPA Small Business Ombudsman Clearinghouse/Hotline
1-800-368-5888
Small Business Division (1808T)
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue NW
Washington, D.C. 20460
(202)566-2822
www.epa.gov/sbo/sboquest.htm
o Helps private citizens and small businesses with questions on all
program aspects within EPA
U.S. EPA National Center for Environmental Publications and Information
1-800-490-9198
www.epa.gov/ncepihom
o Provides access and information about EPA publications
American Indian Environmental Office
www.epa.gov/indian
o Provides information on programs, laws, regulations, grants, and
tribal contacts
Region 8 Tribal Programs and Environmental Directors
www.epa.gov/region08/land_waste/rcra/tribal/trcontacts/
trR8tribes7trr8tribes.html
o Provides direct links to various tribal homepages and or the email
addresses for the tribal environmental coordinators
U.S. EPA RCRA Online
www.epa.gov/rcraonline
o Provides information related to hazardous waste regulations and
RCRA, CERCLA, and EPCRA
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Asbestos Abatement/Management Ombudsman
Hotline: 1-800-368-5888
o Provides information on handling, abatement, and management of
asbestos in schools; interpretation of the asbestos in schools
requirements and publications to explain recent legislation
National Lead Information Center & Clearinghouse
Hotline: 1-800-424-LEAD (5323)
www.epa.gov/lead
o Provides information about lead, lead hazards, and how parents
can help protect their children from lead poisoning
U.S. EPA Hotline List
www.epa.gov/epahome/hotline.htm
o Provides a comprehensive list of all EPA sponsored hotlines
Montana Department of Environmental Quality
Business and Community Assistance Program (BCAP)
www.deq.mt.gov/Recycle/index.asp
o BCAP works with schools on a wide variety of projects, including
environmental management programs
SCHOOL LAB CLEANOUT PROGRAMS IN U.S.
EPA REGION 8
Colorado Consumer Protection Division
www.cdphe.state.co.us/cp
Click on "Guidance on Chemical Management in Schools"
o Colorado provides resources and helpful information on procedures
for conducting an inventory, a list of common hazards and
guidelines for handling hazardous materials, a self-assessment tool
for determining compliance with applicable rules and regulations,
questions and information to obtain from potential hazardous waste
vendors, and a list of hazardous waste disposal companies.
Montana Department of Environmental Quality
Hazardous Waste Program
www.mdeqschoollabs.com
o Montana provides resources and helpful information on proper
management and disposal of hazardous chemicals, related school
science lab links, chemical information, and links to lab clean-out
projects in other states.
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Wyoming Department of Education
www.epa.gov/epaoswer/osw/conserve/2004news/09-rural.htm
o The Wyoming Department of Education (WDE) developed a
cleanout program that requires school districts to match funding
and implement best management practices guidelines. Contacts
are Matt Langenfeld at EPA (303)312-6284, or Bruce Hayes at WDE
(307)777-6198.
U.S. Environmental Protection Agency
Schools Chemical Cleanout Campaign (SC3)
www.epa.gov/epaoswer/osw/conserve/clusters/schools/
index.htm
o The SC3 Campaign provides information about how to remove
potentially harmful chemicals from schools; emphasizes the
implementation of preventive programs such as chemical
management training for lab instructors and microscale techniques;
and raise national awareness about chemical hazards in schools.
References
Battelle Pacific Northwest Laboratories, Battelle Seattle Research Center.
Laboratory Waste Minimization and Pollution Prevention: A Guide for
Teachers.
Chase, J. (1995) Blueprint for a Green School. Scholastic, Inc. New
York.
U.S. Environmental Protection Agency, www.epa.gov/
U.S. Environmental Protection Agency (2000). Environmental
Management Guide for Small Laboratories.
U.S. Environmental Protection Agency. Schools Chemical Cleanout
Campaign (SC3).
Please Note: The inclusion of non-EPA links and their content does not
necessarily reflect the views and policies of the EPA, nor does the mention
of trade names or commercial products constitute endorsement or
recommendation for use. These links are included to maximize the utility
the Internet provides and to better fulfill our role as information provider
and disseminator.
Author: Kendra A. Morrison, U.S. EPA Region 8
Front page graphic (American Indian medicine wheel): Frank Sherwood,
U.S. EPA Region 8
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