Hazardous Waste Management

Bridgewater State College 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 Bridgewater State College 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 health, safety, and welfare, protects the environment, and incorporates hazardous waste reduction techniques.

• 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hazardous and toxic substances, to aid in monitoring hazardous waste generation, and to eliminate excessive amounts of outdated chemicals.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 all elements of the Hazardous Substances Management Plan with the specific purpose of incorporating changes designed to make the plan more effective and efficient.

Scope

The Environmental Health and 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 reduce the liability that Bridgewater State College 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 Facilities Department are substituted when practical.

The Environmental Health and Safety Office has developed and conducts a omprehensive 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 Toxics 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.

Hazardous Substances Inventory

The hazardous substances inventory is maintained by the Environmental Health and Safety Office. The inventory currently consists of all chemicals stored and used by the Chemistry Department and many of the chemicals stored and used by the Biology Department. All chemical purchase orders be routed through the Environmental Health and 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 Environmental Health and Safety Office. Satellite MSDS files are maintained for substances used in a particular department or workplace.

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 Environmental Health and Safety Office or through a review process where all chemical purchases are reviewed by the Environmental Health and Safety Office. 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 Hazardous Substances Management Plan and shall be reviewed annually for opportunities for improvement.

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 or 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, corrosivity, reactivity, and toxicity. They are also identified as hazardous wastes based on listings of 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 Bridgewater State College 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, Bridgewater State College 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 qualify 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 Environmental Health and Safety Office.

Biological waste and bio-medical waste which are 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, packaging, labeled, and placed in the appropriate accumulation area, and for making arrangements for there transportation to a licensed disposal facility.

The Environmental Health and Safety Officer 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 Bridgewater State College 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 Environmental Health and Safety Officer is responsible for making arrangements for the transportation of all universal wastes to recycling facilities.

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 at Bridgewater State College. One container 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 stream ranges from one hundred (100) mililiters to fifty-five (55) 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 to the hazardous waste accumulation area within three days.

Satellite points for hazardous waste are located as follows:

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 Environmental Health and Safety Office to prevent the mixing 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 Conant Science Building in basement. 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°F. 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 exits. 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

Bridgewater State College 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.

Training

The Massachusetts Hazardous Waste Regulations, 310 CMR 30.000, require 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 the 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 or 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. Bridgewater State College is currently a small quantity generator; however, generator status can change. Should the college become a large quantity generator, it shall be college 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 Small Quantity Generator facilities responsible for hazardous waste management can always benefit from training. More training is better than less.

• 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 chemical 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 labeling.
• 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.

• 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 sharps 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 even for a minute and someone not knowing the contents pick up the container. To avoid confusion and to reduce risk to yourself and others in your workplace, the following is essential:

• 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 Environmental Health and Safety Office at ext. 2751.

Annual Review

The three elements of the Hazardous Substances Management Plan, Hazardous Substances Inventory, Hazardous Waste Reduction through Toxics Use Reduction, and 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.