Hazardous Waste Guide

I. Chemical Wastes

A regulated chemical waste is defined as a waste that, due to its quantity, concentration, or physical and chemical characteristics may

  • cause, or significantly contribute to, an increase in mortality or an increase in serious or incapacitating illness; or
  • pose a substantial present or potential threat to human health or the environment when improperly treated, stored, transported, disposed of, or otherwise managed.

The disposal of regulated waste and other unwanted chemicals have become increasingly complicated. The U.S. Environmental Protection Agency, the State of Michigan’s Department of Environmental Quality, and Michigan State University regulate the treatment and disposal of chemical wastes at the NSCL.

The purpose of this document is to help you better understand exactly what is and is not a regulated chemical waste. In doing so, we hope that you may be able to design experiments with waste minimization in mind, and dispose of chemical waste generated in your work in a manner consistent with legal requirements.

Characteristic Chemical Wastes

In the Code of Federal Regulations (40 CFR 261.20 - 261.24), the Resource Conservation and Recovery Act (RCRA) defines the four fundamental characteristics of regulated waste as:

  1. Ignitability - Ignitable materials are defined as materials exhibiting one or more of the following characteristics:
    • Liquids that have a flash point less than 60°C (140°F).
    • Materials other than liquids that are capable, under standard temperature and pressure, of causing fire by friction, adsorption of moisture, or spontaneous chemical changes and, when ignited, burn so vigorously and persistently that they create a hazard.
    • Flammable compressed gases, including those that form flammable mixtures with air.
    • Oxidizers that stimulate combustion of organic materials.

    Ignitable materials include most common organic solvents, gases such as hydrogen and hydrocarbons, and certain nitrate salts.

  2. Corrosivity - Corrosive materials are defined as materials meeting one or more of the following criteria:
    • Aqueous solutions with a pH of less than or equal to 2 or greater than or equal to 12.5.
    • Liquid substances that corrode steel at a rate greater than 6.35 millimeters (0.250 inches) per year at a test temperature of 55°C (130°F).

    Most common laboratory acids and bases are corrosive, as well as some amines and solutions of certain metal salts (e.g., a 0.1M aqueous solution of ferric chloride has a pH of 2.0).

  3. Reactivity - Reactive materials are defined as materials meeting one or more of the following criteria:
    • Unstable materials capable of undergoing violent chemical change (without detonating).
    • Materials that react violently with water.
    • Materials that form potentially explosive mixtures with water.
    • Materials that, when mixed with water, generate toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health or the environment.
    • Cyanide or sulfide bearing wastes that, when exposed to pH conditions between 2 and 12.5, will generate toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health or the environment.
    • Materials capable of detonation or explosive reaction when subjected to a strong initiating source or if heated in confinement.
    • Materials capable of detonation or explosive decomposition at standard temperature and pressure.

    Alkali metals, peroxides, and cyanide and sulfide compounds are classified as reactives.

  4. Toxicity - Toxicity is established through the Toxicity Characteristic Leaching Procedure (TCLP), which measures the tendency of certain toxic materials to be leached (extracted) from the waste material under conditions that the waste would be exposed to in a landfill. The current list of toxic substances published by the Environmental Protection Agency includes:

    Arsenic

    Barium

    Benzene

    Cadmium

    Carbon tetrachloride

    Chlordane

    Chlorobenzene

    Chloroform

    Chromium (hexavalent)

    o-Cresol

    m-Cresol

    p-Cresol

    2,4-Dichlorophenoxyacetic acid

    1,4-Dichlorobenzene

    1,2-Dichloroethane

    1,1-Dichloroethylene

    2,4-Dinitrotoluene

    Endrin

    Heptachlor (and its epoxide)

    Hexachlorobenzene

    Hexachlorobutadiene

    Hexachloroethane

    Lead

    Lindane (hexachlorocyclohexane)

    Mercury

    Methoxychlor

    Methyl ethyl ketone

    Nitrobenzene

    Pentachlorophenol

    Pyridine

    Selenium

    Silver

    Tetrachloroethylene

    Toxaphene (chlorinated camphene)

    Trichloroethylene

    2,4,5-Trichlorophenol

    2,4,6-Trichlorophenol

    2-(2,4,5-Trichlorophenoxy)propionic acid (Silvex)

    Vinyl chloride

     
  5. The levels at which these chemicals are regulated in mixtures varies from 0.2 ppm to 400 ppm. For example, solutions that contain mercury at levels above 0.2 ppm are hazardous waste. These levels are very low, so if a waste contains one or more of these components it should be considered a hazardous waste unless analysis following the TCLP method shows that its concentration is below the regulatory limit.
  6. Note that the eight metals listed here are regulated in both their pure forms and as compounds (e.g. lead, lead paint, lead oxide, and tetraethyl lead are all regulated wastes).

B. Listed Chemical Wastes

In addition to defining the characteristics of regulated waste, RCRA also defines (or lists) certain specific waste materials as being regulated. These materials are listed in 40 CFR sections 261.31 (the F List), 261.32 (the K list), and 261.33 (the P and U Lists).

  1. The F List addresses wastes from nonspecific sources (e.g., spent solvents) and is broken down into several subcategories (or codes). Five codes that are commonly applicable to laboratory wastes are:

    The F001 Code - Applicable to all spent solvent mixtures and blends used for degreasing which contained, before use, a total of ten percent or more (by volume) of one or more of the following halogenated solvents:

    tetrachloroethylene

    trichloroethylene

    methylene chloride

    1,1,1-trichloroethane

    carbon tetrachloride

    chlorinated fluorocarbons

    The F002 Code - Applicable to all spent solvent mixtures and blends which contained, before use, a total of ten percent or more (by volume) of one or more of the following halogenated solvents:

    tetrachloroethylene

    methylene chloride

    trichloroethylene

    1,1,1-trichloroethane

    chlorobenzene

    1,1,2-trichloro-1,2,2-trifluoroethane

    ortho-dichlorobenzene

    trichlorofluoromethane

    1,1,2-trichloroethane

     

    The F003 Code - Applicable to all spent solvent mixtures and blends which contained, before use, a total of ten percent or more (by volume) of one or more of the following non-halogenated solvents:

    xylene

    acetone

    ethyl acetate

    ethyl benzene

    ethyl ether

    methyl isobutyl ketone

    n-butyl alcohol

    cyclohexanone

    methanol

     

    The F004 Code - Applicable to all spent solvent mixtures and blends which contained, before use, a total of ten percent or more (by volume) of one or more of the following non-halogenated solvents:

    cresols and cresylic acid

    nitrobenzene

    The F005 Code - Applicable to all spent solvent mixtures and blends which contained, before use, a total of ten percent or more (by volume) of one or more of the following non-halogenated solvents:

    toluene

    methyl ethyl ketone

    carbon disulfide

    isobutanol

    pyridine

    benzene

    2-ethoxyethanol

    2-nitropropane

  2. The K List addresses waste from specific sources (e.g., pink/red water from TNT operations - K047) and is generally not applicable to wastes generated in research laboratories.
  3. The P List addresses unused acutely hazardous materials (e.g., laboratory chemicals having an LD50 of less than 50 mg/kg (oral; rat)). It is applicable to many surplus chemicals that are disposed of by research laboratories. Some examples are nickel tetracarbonyl, phosphine, and osmium tetroxide.
  4. The U List addresses unused hazardous materials (e.g., toxic laboratory chemicals). Like the P list, this is applicable to many surplus chemicals that are disposed of by research laboratories. Some examples are aniline, benzene, and acetone.

    II. Radioactive Wastes

    Radioactive waste is usually limited to low-level radioactive waste from the use of by-product material and naturally occurring or accelerator-produced radioactive material (NARM). By-product material, as defined by the U.S. Nuclear Regulatory Commission (U.S. NRC), is reactor-produced radioactive material and includes most purchased radiolabelled chemicals and sources used for instrument checks and calibrations; NARM includes uranium and thorium salts.

    The use and disposal of by-product material are regulated by the U.S. NRC and Michigan State University under MSU’s broad-scope license. For further information regarding the NSCL’s and MSU’s radiation safety and radioactive waste program, contact the Safety Office (Room 151) prior to your work.

    III. “Mixed” or “Multihazardous” Wastes

    “Mixed” or “multihazardous” waste is waste that contains any combination of chemical, radioactive, or biological hazards. Although many of the principles discussed for chemically hazardous waste also apply here, multihazardous waste requires special management considerations because the treatment method for one of the hazards may be inappropriate for the treatment of another. Disposal options for mixed waste are usually very expensive. For many types of mixed waste, there are no management options other than indefinite storage on site.

    Chemical-Radioactive (mixed) waste is defined by the Environmental Protection Agency as "wastes that contain a chemically hazardous waste component regulated under the Resource Conservation and Recovery Act and a radioactive component consisting of source, special nuclear, or byproduct material regulated under the Atomic Energy Act." Examples of laboratory mixed wastes include:

    1. Used flammable liquid scintillation cocktail.
    2. Phenol-chloroform mixtures from extraction of nucleic acids from radiolabelled cell components.
    3. Certain gel electrophoresis waste (e.g., methanol or acetic acid containing radionuclides).
    4. Lead contaminated with radioactivity.

    IV. Biological Wastes

    Biological waste requires special handling to protect human health or the environment. If improperly treated or handled it may serve to transmit an infectious disease(s).

    If your work will produce biological waste, contact the Safety Office (Room 151) prior to your work.

    A. Microbiological Waste

    Microbiological waste includes:

    1. discarded cultures and stocks of infectious agents and associated biologicals;
    2. discarded cultures of specimens from medical, pathological, pharmaceutical, research, clinical, commercial, and industrial laboratories;
    3. discarded live and attenuated vaccines, but excluding the empty containers thereof;
    4. discarded, used disposable culture dishes; and
    5. discarded, used disposable devices used to transfer, inoculate, or mix cultures.

    Note: In vitro tissue cultures that have not been intentionally exposed to pathogens are exempt from these regulations.

    B. Animal Waste

    Animal waste includes:

    1. carcasses of animals;
    2. body parts of animals;
    3. whole blood, serum, plasma, and/or other blood components from animals; and
    4. bedding of animals intentionally exposed to pathogens.

    C. Human Blood and Blood Products

    Human blood and blood products include:

    1. human blood, serum, plasma, other blood components, and body fluids; and
    2. disposable items contaminated with human blood or body fluids.

    D. Pathological Waste

    Pathological waste includes but is not limited to:

    1. human materials removed during surgery, labor and delivery, autopsy, embalming, or biopsy, including: body parts and tissues or fetuses;
    2. products of spontaneous or induced human abortions, regardless of the period of gestation, including: body parts, tissues or fetuses, organs, and bulk blood and body fluids;
    3. laboratory specimens of blood and tissue after completion of laboratory examination; and
    4. anatomical remains.

    E. Sharps

    Sharps include but are not limited to the following, regardless of contaminate:

    1. hypodermic needles;
    2. hypodermic syringes regardless of use (e.g. used to apply an epoxy);
    3. glass Pasteur pipettes.

    Sharps include but are not limited to the following, when contaminated:

    1. glass pipettes;
    2. broken glassware;
    3. specimen tubes;
    4. blood culture bottles; and
    5. microscope slides.

    Contaminated is defined as the presence or the reasonably anticipated presence of blood, body fluids, or other infectious materials.