6.8. Hazardous and Potentially Infectious Wastes Management Plan
The
NMHU Waste Management Plan (NMHU WMP) is designed for university operations to comply with federal and state regulations such as those promulgated by the
U.S. Environmental Protection Agency. In addition, the federal Resource Conservation and Recovery Act (RCRA) in 40 CFR 260 series requires that hazardous wastes are identified, isolated/stored, transported, and ultimately disposed of in a manner that prevents waste discharges to the environment. Furthermore, regulations require an on-going program of waste minimization be in place at each facility.
To this end, the chemical/biological hygiene officer, and, the Environmental Health and Safety Committee (EHS) will assist “generators” (or producers of hazardous waste) to manage their own waste in accordance with RCRA regulations. However, it is the generator who is ultimately responsible for assuring that waste generated is managed in a safe and appropriate manner. Any waste material that may, upon contact, present a hazard to one's health or surrounding environment should be treated as a potentially hazardous waste. This includes spent or unused chemicals, cleaning solutions, oils, etc. If there is any doubt whether a material should be treated as hazardous, contact EHS. Only non-hazardous wastes may be disposed in the sewer or trash. For an explanation of terminology described in this section, a list of definitions is provided in the
Hazardous and Potentially Infectious Wastes Management (HPIWM) Plan.
The following information is referenced from
NMHU’s HPIWM Plan.
A. Hazardous Waste Management Responsibilities
On-site Generator - The on-site generator is the person, or activity, that generates a hazardous waste on the campus. Laboratory and studio supervisors are the academic side on-site generators. Various Facilities Management units are also hazwaste generators. The person that supervises a facilities management unit is the on-site generator and responsible for:
- Maintaining adequate hazwaste/medwaste containers at the location where wastes are generated;
- Ensuring hazwaste/medwaste containers are properly labeled;
- Keeping incompatible hazardous wastes (e.g., solvent wastes, oxidizers, etc.) separate during generation and waste storage;
- Supervising and training employees and students about the proper hazwaste/medwaste disposal procedures at the generation site; and
- Arranging for the removal of hazwaste/medwaste containers by the NMHU hygiene officer.
Chemical/biological hygiene officer responsibilities consist of:
- The storage of hazwastes/medwastes prior to disposal;
- The inspection of work areas for compliance with hazwaste/medwaste storage and labeling requirements;
- Arranging for the appropriate disposal of hazwastes/medwastes; and
- Designing and maintaining the cradle-to-grave materials tracking inventory for the main-campus.
Vice-President for Administrative Services and Finance (VPASF) is responsible for ensuring that funds are available for annual disposal of hazardous wastes from all units. The VPASF, or a designee, is the supervisor of the chemical/biological hygiene officer in regards to hazardous materials and hazwaste tracking.
B. Hazardous Waste Management Procedures. In general, the management process begins at the site of hazwaste generation; where hazwastes are separated according to the components and hazardous characteristics of a waste stream. This requires assessment of the waste stream(s) and the hazardous properties of wastes at a generation site. Segregation of wastes is important from 2 standpoints: 1) wastes that have mixed compositions are far more expensive to discard than segregated wastes, and, 2) waste mixtures can lead to serious health and safety consequences when a fire or detonation occurs. Hazwaste receptacles, with container inventory numbers, are conveniently located at each site of hazwaste generation. The containers are labeled with 1) “HAZARDOUS WASTE” in prominent letters, 2) the receptacle inventory number, 3) generator, 4) date of placement at location, 5) location of generation, and 6) the type or characteristic of waste that they receive. Once receptacles are full, the on-site generator contacts the chemical/biological hygiene officer or a disposal company directly, for collection.
Hazwastes may only be transported by a permitted hazwaste transporter. Transporters must have an EPA ID number, which NMHU must verify. Often the transporter is also a TSDF. Each shipment of hazardous waste must be accompanied by a standard hazardous waste manifest with a list of the various materials in a shipment and a designates specific transporter and TSDF.
Hazwaste Assessment must take place on all hazardous properties of wastes generated from a laboratory, studio, and facilities management operation. Material Safety Data Sheets (see
NMHU Hazard Communication Plan) that accompany all initial shipments of pure and formulated chemicals can be used to identify hazards of components of hazwaste streams. Hazwastes are assigned to a specific container type depending on their contents. General types of substances that must be segregated and a standard assessment form (Appendix A) for listing and determining receptacle needs for a given facility/operation are provided in the
HPIWM Plan. Included are specifications for assessing proper procedures for labeling hazwaste receptacles, storing waste, and transferring hazwaste to EHS.
Note: It is in the generator's and department's best interest to maintain meticulous data concerning the waste and strict control over its composition When the generator does not have sufficient knowledge or information to make certification, the wastes must be analyzed at the department's (generator's) expense. The analysis must be performed by a laboratory acceptable to EHS and be sufficient to provide necessary data for the on-site generator to certify the waste. EHS can provide guidance on appropriate analyses, but a comprehensive analysis of an unknown waste can cost well over $1,000.
C. Potentially Infectious Material Wastes. Medical wastes consist of Potentially Infectious Material (PIM), Regulated Medical Waste (RMW), and Non-Regulated Waste (NRW) materials. These materials are clearly defined in the
HPIWM Plan and all generators including faculty, staff and students working in laboratories with such materials should strictly adhere and understand the procedures included in the
HPIWM Plan for identifying, isolating, storing, transporting, and disposing such wastes.
D. Hazardous and Medical Wastes Disposal Procedures. As defined in RCRA, 40 CFR § 261.5, NMHU is currently classified as a Conditionally Exempt Small Quantity Generator (CESQG) because it “generates less than 100 kg of hazwaste per month, or less than 1 kg of “acutely hazwaste per month; or which accumulates less than 1000 kg at any one time, or less than 1 kg “acutely hazwaste”. CESQGs are not required to undertake a permit process like larger quantity generators. Howevever, NMHU is required to follow specific storage thresholds mandated by RCRA including:
- Permitted Transporters, and, Treatment, Storage and Disposal Facilities (TSDF). Hazwaste transporters and TSDFs are required to undergo a permitting process with U.S. EPA. Hazwastes may only be transported on public thoroughfares by a permitted transporter. The EPA transporter identification number must be obtained from a transporter at the time of contract bids, to verify that a transporter is authorized to convey hazwastes. Furthermore, a certification is required to ensure that the transporter has equipment approved to transport hazwastes by the U.S. Department of Transportation (DOT).
- Hazwaste Manifests. RCRA regulations require that generators, transporters, and TSDFs utilize a standard hazwaste manifest form (medwastes do not have the same requirements). The manifest is described in detail in the HPIWM Plan. It is the responsibility of the generator to ensure that hazwastes are actually delivered to a TSDF in a timely manner.
Medwaste Disposal Procedures. Potentially Infectious Material (PIM) can be disposed of by destroying the material through incineration. However, this requires that each department collect the PIM in appropriate containers, store the material, and contact EHS to pickup the material for incineration in an EPA approved incinerator.
If the material is rendered as non-infectious by such means as autoclaving, then the material can be considered a non-regulated waste. Specific steps for autoclaving are required and specified in the
HPIWM Plan. Generally, all autoclaving of PIM must be documented, the autoclaving process verified and inspected annually be a certified inspector.
Large volumes of PIM, which cannot otherwise be treated by autoclaving, must be transported by a EPA permitted medwastes transporter. Wastes must be packaged according to DOT regulations in containers that ensure no leakage of liquid contents, or emergence of sharps. Medwaste transporters are to provide their EPA identification number at the time of bids for services. Medwaste transporters are certified by EPA to have vehicles and procedures for the safe transport of medwastes to disposal sites.
Under no circumstances are any sharps to be discarded into the general trash.
E. Materials Tracking and Inventory (needs concurrence from Comptroller, Business Office, and Central Receiving). Pure chemicals, and formulated chemical products, shall be entered into a campus-wide inventory and tracked from arrival on campus to their final disposition by an academic or facilities management unit. This tracking is mandated by RCRA regulations as the “cradle-to-grave” materials inventory requirement. This information is also of use in determining waste generation locations and the disposition of materials on campus. Certain units (e.g., Facilities Management, Natural Sciences, and Fine Arts) may maintain their own internal inventories that are linked to the global inventory, particularly when materials are dispersed throughout a building, or, across campus. The
HPIWM Plan offers detail information on the following actions:
- Procedures for inputting information into databases on formulated and chemical product information
- Role of Central Receiving in tracking materials and adherence to OSHA chemical storage requirements.
- Responsibilities of the “consumer unit” or Facilities Management Department (e.g., academic unit) in receiving and, storing, disposing, and documenting of chemical or formulated product shipment.
- Role of campus safety officer in annually reviewing the database for consistency and completeness.
F. Waste Minimization. Waste minimization is the process of identification and implementation of ways to reduce the generation of solid and hazardous wastes from normal operations.
Waste minimization is achieved by:
- Proactively identify, at the beginning of a project, means to reduce hazardous waste generation
- Substitute less hazardous materials for materials that must be disposed of as hazardous wastes.
- Reduce the quantities of hazardous substances that lead to hazwastes utilized in processes.
- Internal recycling of certain materials (e.g., solvents that can be recovered and purified, metal recovery by precipitation from aqueous solutions, etc.).
To assist in the minimization of waste, the EHS Committee annually reviews the results of the inventory inspection and hazwaste generation levels reported from the hazwaste inventory. Campus units identified as generating large quantities of hazwastes will be asked to prepare a justification for the quantity generated; and plans for minimization of waste volumes. However, waste minimization may not be feasible in certain situations, and the committee will take this into consideration. On-site generators that are identified as not segregating wastes correctly, from analytical reports by the transporter or TSDF, will be requested to change their hazwaste disposal procedures at the generation site. This can be done with assistance from the chemical/biological hygiene officer. A hazwaste volume assessment is available for estimating hazwastes types that are likely to be produced from a research, construction, or other project in the
HPIWM Plan.
G. General Training of Personnel. All faculty, students, and staff that routinely handle hazardous materials or potentially infectious materials shall be trained in the hazwastes/medwastes handling and disposal procedures for the unit they work within. Faculty will be trained by the chemical/biological hygiene officer in the appropriate hazwastes/medwastes disposal procedures for their specific classes, projects, and research. Laboratory and studio supervisors are responsible for assuring that personnel in their workspaces dispose of hazwastes/medwastes correctly. Consequently, students in classes, and those working on special projects must receive an appropriate level of training by the laboratory or studio supervisor. Facilities Management Department supervisors are responsible for providing training to employees in their units.
A record of the training with the employee’s signature must be kept on file by the employee’s supervisor. In laboratories and studios, the waste management training can be incorporated as part of the training to comply with the chemical hygiene plan.
H. Recordkeeping. Maintaining safety waste management records is part of NMHU’s policy and required by federal and state regulations. The following are records required on hazardous waste material.
- Hazardous Waste Manifests - kept on file by the campus safety officer for 3 years.
- Hazardous waste assessment forms (see Appendix A of HPIWM Plan) - kept by the chemical/biological hygiene officer, until a process or operation at a location changes. When there is a change in project, operation, or process at a location a new assessment shall be completed and review by the chemical/biological hygiene officer.
- Hazwaste Pickup Forms - retained by the campus safety officer with the manifest from a hazwaste shipment for 3 years.
- Training Records - kept with the Chemical Hygiene Plan for a laboratory or studio. The director of Facilities Management will keep training records in facilities management units. A copy of the training records also shall be retained by the campus safety officer 3 years, or, the duration of a specific project.