- Hazardous Waste Management Laws and Regulations
- Roles and Responsibilities
- Hazardous Waste Determinations
- Waste Characterizations
- Generator Responsibilities; Storage and Management Requirements
- Proper Storage of Hazardous Wastes
- Container Labeling and Marking
- Nonhazardous Wastes
- Universal Wastes
- Notify EHS to Schedule Pickup
- Other Regulated Wastes
- Emergency Procedures
The Hazardous Waste Management Program (HWMP) was developed to supplement the overall TMCC EHS system with regards to protecting human health and safety, appropriately managing various site wastes, reducing negative impact to the environment, managing disposal costs, and ensuring regulatory compliance.
The HWMP provides information for the proper management and disposal of three types of waste found at TMCC: hazardous waste, regulated nonhazardous waste and universal waste.
The HWMP will inform faculty, staff, employees and students at TMCC of policies and procedures created to ensure compliance with all laws and regulations surrounding the proper management of hazardous and other regulated wastes.
Hazardous Waste Management Laws and Regulations
Nevada is an EPA Authorized state. State authorization is a rulemaking process that EPA delegates the primary responsibility of implementing the RCRA hazardous waste program to individual states in lieu of EPA. This process ensures national consistency and minimum standards while providing flexibility to states in implementing rules. State statutes are documented in Nevada Administrative Code 459 (NAC 459).
RCRA establishes “Cradle-to-Grave” waste ownership for hazardous waste generators. Once a hazardous waste is generated, the generator is entirely responsible for its proper management until it is destroyed, recycled, or treated.
Roles and Responsibilities
Responsible for the overall implementation the HWMP, showing visible support for the program, and for ensuring a healthy and safe environment for the College's employees and students.
Directors and Area Managers
Responsible for implementing the program in their individual areas and departments, ensuring compliance within their disciplines, labs, areas and shops.
Environmental Health and Safety (EHS)
- Providing assistance to college faculty and staff with the implementation and compliance of the HWMP, including but not limited to training, hazardous waste determinations and classifications, oversight of hazardous waste disposal, sampling and analysis, compliance audits, and assisting with corrective actions when necessary.
- Providing initial and refresher hazardous waste training as necessary.
- Maintaining a hazardous waste manifest master file.
- Maintaining a liaison with the appropriate regulatory authorities (NDEP, EPA, Washoe County and the City of Reno), including submitting information to regulators as required.
- Ensuring that a contract exists with qualified and properly licensed hazardous waste disposal contractor(s) at all times. EHS will perform due diligence and inspections (physical and/or desktop) of hazardous waste disposal contractors and associated facilities with other NSHE institutions to ensure they are in regulatory compliance.
- Coordinating transport schedule with waste disposal contractors for all hazardous waste pickups at all associated campuses and facilities.
Faculty and Staff
- Knowledge and understanding of steps needed to maintain compliance.
- Reducing hazardous waste quantities by reducing, reusing, and recycling, and prudent procurement practices.
- Maintaining proper storage and management of all generated wastes (hazardous, non-hazardous, and universal).
- Ensure waste containers are properly labeled and in good repair. Provide secondary containment when possible, ensuring hazardous wastes or other regulated wastes are not stored outside or in unapproved locations.
- Consistently knowledgeable of the contents of each waste container, and prevent mixing of incompatible wastes that could create dangerous reactions.
- Completing required paperwork/notification to notify EHS that they require waste pickup services.
All employees who manage or handle hazardous waste or other regulated wastes must receive appropriate training. Applicable TMCC employees must obtain basic training before being required to work with hazardous wastes. Refresher training will be completed as needed. TMCC's Continuing Education program offers Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) at the William N. Pennington Applied Technology Center. Furthermore, applicable facilities management personnel must also have annual asbestos and toxic substance training where construction, renovation, or maintenance may cause exposure to asbestos, lead paint, or other potentially hazardous materials as related to waste. This training may include:
- Overview of EPA and NDEP regulations
- Generator responsibilities
- Hazardous waste determination
- Waste classification, labeling, segregation and storage requirements
- Spill cleanup procedures
- TMCC waste disposal procedures
Hazardous Waste Determination
A waste is defined as any material an individual determines is no longer fit for its intended use and is ready to be discarded. Only qualified EHS staff should make waste determinations for any new waste streams.
All waste streams are characterized and profiled through Nevada certified environmental testing laboratories, or profiled through a certified TSD facility. This is typically done in conjunction with waste transport contractors.
All new/proposed products and waste streams must be approved by the Environmental Health and Safety Office. Typical wastes generated and quantities are:
- D001: Ignitable Characteristics
- Spent aerosol cans and associated waste paint
- Small amounts of flammable chemicals generated in the science labs
- D002: Corrosive Characteristics
- Small amounts of corrosive chemicals generated in the science labs
- D008: Lead
- Lead foils used in x-rays generated by the dental technician program
- D011: Silver
- Silver thiosulfate generated by the visual arts department/photography developer
- Bio-Haz/Medical Wastes
- Used Sharps, cadaver preservation fluids, organic bio-wastes generated by the science labs
- Expired pharmaceuticals generated by EMT program
- Universal and Recyclable Wastes
- Used oil and anti-freeze
- Spent lamps and ballasts
- Spent batteries
- Punctured and drained steel aerosol cans
- Non-Haz Regulated Wastes
- Oil contaminated sand/absorbent material
Generator Responsibilities: Storage & Management Requirements
Hazardous chemical wastes are categorized into various hazardous classes. Wastes are not to be mixed unless the generator is sure the mixture will not result in a hazardous compound as defined under 40CFR. Furthermore, different categories of hazardous wastes must not be mixed in the same container in order to prevent dangerous, unwanted reactions or non-compliance. For example, do not combine inorganic heavy metal compounds with organic acid solvents. Never combine oxidizers with organic materials. Combining used antifreeze with used oil can make the mixture classified as hazardous, but used antifreeze alone, and used oil alone, is not considered hazardous. When in doubt about mixing rules, contact the EHS Office for guidance. Any person/department that generates hazardous waste must properly manage it until the hazardous waste contractor manifests and removes the container or TMCC EHS takes possession of the container. Responsibilities include:
- Segregating incompatible waste chemicals. Never mix chemicals that may react or cause an unsafe condition.
- Maintaining proper container management. Only use containers compatible with the wastes' characteristics.
- All containers must be labeled with the containers actual contents. Hazardous waste labels are available through the EHS Office website.
- Container lids shall be securely closed the at all times unless adding or removing waste.
- Never remove a label or tag from a cylinder no matter what the size. Unlabeled containers/cylinders can lead to violations of compliance and fines. Disposal of unlabeled cylinders is also expensive and dangerous to have at any location.
- Notify EHS that you have waste for disposal by email or contact us. You should include information on the type of waste to be picked up. Waste is generally picked up after each semester or more frequently if required.
It is illegal to dispose of hazardous waste in any of the following ways:
- Disposal through the sanitary drain such as sink drain, floor drain or urinal or toilets.
- Evaporation inside or outside a fume hood.
- Disposal in the regular trash.
- Disposal through storm drain, unpaved surface, or on the ground.
Proper Storage of Hazardous Wastes
Hazardous waste storage areas are used to store waste containers prior to shipment. Each individual hazardous waste generator is responsible for care and control of their container storage area(s). Generators in charge of such areas should:
- Ensure the waste containers are assessable to EHS for inspection and pick up.
- Accumulate the wastes in safe, transportable containers that are properly labeled and stored to prevent human exposure to, or environmental release of, hazardous waste materials.
- Ensure that hazardous waste containers are compatible with the hazardous chemical waste content (e.g., do not use metal containers for corrosive waste).
- Use containers that are in good condition and do not leak. Empty chemical glass jugs and bottles can be reused for waste collection provided they have been appropriately rinsed clean and all labels regarding the original contents have been removed or blacked out.
Container Labeling and Marking
Hazardous waste must be labeled appropriately. Hazardous waste labels are available on the EHS website.
EHS will provide guidance when determining if waste streams are hazardous, nonhazardous, regulated waste, or universal waste. When in doubt about mixing rules, contact the EHS Office for guidance.
Universal waste is a subset of hazardous waste. Universal waste regulations were designated to encourage recycling and proper disposal of commonly generated hazardous waste while also reducing the regulatory burden in generating facilities. These waste include:
- Batteries including lead-acid as described in 40CFR 273.2;
- Pesticides as described in 40CFR 273.3;
- Mercury Thermostats as described in 40CFR 273.4; and
- Lamps (mercury, metal halide, etc.) As described in 40CFR 273.5.
Notify EHS to Schedule Pick-up
Hazardous wastes are generally picked up at the end of each semester or more frequently if needed. EHS works with hazardous waste transport contractors to schedule arrival, locations for waste pick-ups, and what replacement supplies will be needed.
Waste generators should complete a Waste Submittal form or contact the EHS Office when you have materials or waste that need removed.
When scheduling a pick-up, ensure that:
- The containers are not sitting in the corridor or areas where accidental release could cause a chemical exposure to students or personnel.
- Containers are labeled and identified by chemical/common name. Chemical formulas are not acceptable.
- Containers of liquid and solid waste are in good condition so that handling can be done in a safe manner and that containers do not leak during transport. Containers must be suitable for the types of chemicals they will hold and must be suitable for storage for at least 180 days. Containers must be closed or sealed in such a manner that leakage will not occur. TMCC's hazardous waste disposal vendors will not pick up containers that are open, have improper caps, leaks, outside contamination, or are not properly identified.
- All hazardous waste containers are properly segregated and clearly marked regarding the contents, hazards, and other pertinent information.
- For lab packs, you must send an online waste submittal form or documentation that includes a list of all chemicals and quantities to the TMCC EHS Office.
Other Regulated Wastes
Dry Solid Materials
Used dry solid materials (paper, rags, towels, gloves, etc.) contaminated with a listed hazardous constituent or with extremely toxic chemicals must be double bagged in heavy duty plastic bags and disposed of as hazardous waste.
Do not use red biohazard bags for chemical wastes.
Used Oil, Oil Filters, and Antifreeze
Used oil is defined by EPA as any oil that has been refined from crude oil, or any synthetic oil, that has been used and as a result of such use is contaminated by physical or chemical impurities. In order to meet the criteria of used oil, it must meet the following:
- Must be derived from crude or synthetic oil;
- Must have been used as a lubricant, coolant, noncontact heat transfer fluid, hydraulic fluid, or for other similar purposes;
- Must not be contaminated with physical impurities and / or chemical impurities as a result of such use.
Used oil should be stored in storage containers or drums. Label all containers and drums with the words "Used Oil." Keep containers and drums in good condition. Do not allow containers to rust, leak, or deteriorate. As a best management practice, keep containers and drums closed unless adding to or removing used oil. Do not mix any hazardous material or waste with used oil.
To be sure that your used oil does not become contaminated with hazardous waste, store it separately from all solvents and chemicals and do not mix with anything. Used oil contaminated with a listed hazardous waste must be managed and disposed of as a hazardous waste. Non-contaminated used oil does not require EPA hazardous waste codes. TMCC sends used oil out for recycling and energy recovery. Used oil can be accumulated indefinitely provided it is not contaminated. Used oil labeling is available on the EHS website. Recycling is also TMCC's preferred disposal method for used oil filters and antifreeze.
Gas cylinders should be returned to the manufacturer/distributor whenever possible. Non-refundable gas cylinders should be labeled and disposed of as hazardous waste. Gas cylinders should always be stored upright. They should also be secured in place to prevent tipping (for tall cylinders two supports/double chains are required). Never remove a label or tag from a cylinder no matter what the size. Unlabeled containers/cylinders can lead to violations of compliance and fines. Disposal of unlabeled cylinders is also expensive and dangerous to have at any location.
Photographic Process Wastes
Photographic waste from the Photo Labs, Dental Hygiene Clinic, and Veterinary Technician Program, contain silver (silver thiosulfate) and may not be poured into the sinks. Those wastes must be treated as hazardous waste.
Unknown Chemical Waste
"Unknown" chemical wastes will be handled by EHS. Place a tag label on the container with "unknown" for the chemical waste description. In addition, market or label the container as "hazardous waste" and date. Then request an EHS pick up of the unknown waste. TMCC EHS will manage the waste as hazardous until testing or generator knowledge can identify the contents.
Sharps (needles, razor blades, scalpel braids, syringes, glass pipettes, etc.) are classified as biological hazardous wastes (bio-waste). These items may not be placed in the regular trash. Sharps must be placed in a "puncture resistant" container or plastic/metal container.
Contractor Generated Waste
Contracts should state that the contractor/vendor is responsible for all hazardous waste storage and disposal generated under contracted work. TMCC is responsible to ensure the proper disposal of any hazardous waste generated from all contracted projects on campus.
Chemical-using personnel and students enrolled in classes where hazardous materials are used or hazardous wastes are generated are required to receive training on the hazards associated with chemical use and how to respond to emergencies. TMCC's Hazardous Communication Program (HAZCOM) requires that TMCC employees be informed of hazardous materials they may use or be exposed to during the course of instruction/work.
In addition, the HAZCOM program requires training on handling spills, releases, and other emergencies. Safety Data Sheets (SDS) or Material Safety Data Sheets (MSDS) are a source of applicable hazard information and shall be maintained for all chemicals used or stored within the lab or workplace. Special cleanup supplies for chemical spills shall be available and employees shall be trained on how to properly use them.
The EHS Office can provide additional information on handling specific chemical spills; call 775-673-7100.
TMCC Hazardous Materials Spill Procedures
Immediate Fire Hazard/Medical Assistance
- Call 911.
- Evacuate the area.
- While awaiting emergency response, call Facilities at 775-673-7100.
Toxic or Hazardous Materials
Toxic or hazardous materials are any substances that endanger the health and safety of employees or the environment. Release of such material is defined as liquid spills, venting and/or re-entry into the air intake, of gases, fumes, vapors or mists, or hazardous solids outside of their normal containers, or the release of pathogens or radioactive material. Depending on the quantity and inherent hazard of the released materials, hazardous materials spills can be broadly classified as incidental or non-incidental:
- Incidental Spill: Spill/release that will not reasonably cause health or safety hazards to employees/students and will not result in any sustained environmental degradation. Responses to incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of the release by responders are not considered to be an emergency within the scope of this plan. Responses to releases of hazardous substances where there is no immediate safety or health hazard (i.e., fire, explosion, or chemical exposure) or hazard to the environment are not considered to be an emergency.
- Non-Incidental Spill: Spill/release that requires a response effort from outside the immediate release area by other designated responders (i.e., trained emergency responders such as mutual aid groups, local fire departments, etc.) because the incident will result, or is likely to result, in an uncontrolled release which may cause high levels of exposure to toxic substances, or which poses danger to employees or the environment requiring immediate attention. Responding to non-incidental spills is considered an emergency response and requires persons who have had 40 hr. Hazardous Waste Operations and Emergency Response training (HAZWOPER) and subsequent 8 hr. annual refresher training to conduct the response, or an outside entity who specializes in emergency response.
Incidental Spill Response
- Verbally notify everyone within hearing distance that a spill has occurred.
- Refer to the Safety Data Sheet for hazard information.
- Put on the appropriate personal protective equipment.
- Confine the spill. If liquid, dike the spill with spill pillows or pigs, then place absorbent material over the contamination. If dry, carefully scoop, sweep or otherwise pick up the spilled material being careful to prevent it from becoming airborne.
- If the spill is on skin or in the eyes, flush thoroughly with running water for a minimum of 15 minutes, then seek medical assistance/evaluation. If the spill is on clothing, you must discard all outer clothing and shower off for a minimum of 15 minutes. Enlist the help of other persons to conduct the spill clean-up.
- Employees will evacuate the danger area, and no one who is not HAZWOPER trained shall assist in handling the emergency.
- If it is safe to do so before evacuating, employees will secure the spill area by performing emergency measures such as diking the spill, turning on hoods, extinguishing ignition sources, and closing doors, as they evacuate the spill area.
Radioactive/Biological Material Release
Do not allow possibly contaminated individuals to leave the spill area if there is a threat of spreading the contamination. Contaminated individuals should be wrapped in blankets or transported in such a way to prevent spread of contamination to coworkers, responding emergency personnel, and the environment.
If injured personnel are sent via ambulance to the hospital, ensure copies of the Safety Data Sheets for the materials involved in the spill incident accompany them. Likewise, if an employee seeks medical assistance at a later date, have him/her take copies of the applicable SDS(s) with them to the clinic.
Acutely Hazardous Waste: Wastes determined by the EPA to possess extremely hazardous properties that make them lethal and very small quantities. These include all "P" listed wastes found in the federal regulations (40 CFR Part 261.33 (e)).
Characteristic Hazardous Waste: Wastes that exhibit one or more of the four characteristics defined by the EPA (40 CFR Part 261 Subpart C); Ignitability, Corrosivity, Reactivity, Toxicity.
Hazardous Waste: Any solid waste listed or identified in Title 40 CFR, Part 261, Subpart C and D or exhibiting the characteristics of ignitability, corrosivity, reactivity, toxicity or specifically listed in part 261.
Listed Hazardous Waste: Includes waste from non-specific and specific industries and commercial chemical products that become hazardous wastes when discarded. Listed wastes have a chemical specific or generic mixture identification number assigned by the EPA. For example; Phenol is U188, a certain chlorinated solvent mixture might be F002 depending of the mixture. Listed wastes consist of a predefined nomenclature defined by the EPA, the K-list, F-list, U-list and P-list.
Recyclable Materials: Wastes that are recycled or able to be recycled. Recycled material is used, reused, or reclaimed.
Solid Waste: Any garbage, refuse, sludge from a waste treatment plant, water treatment plant, or air pollution control facility or other discarded material, including solid, liquid, semi-solid, or contained gaseous material resulting from industrial, municipal, commercial, mining and agricultural operations, and from community and institutional activities.
Universal Waste: Any hazardous waste subject to 40 CFR Part 273 and 30 TAC 335.261 to include:
- Batteries including lead-acid as described in 40 CFR 273.2;
- Pesticides as described in 40 CFR 273.3;
- Mercury Thermostats as described in 40 CFR 273.4;
- Lamps as described in 40 CFR 273.5
Used Oil: Used oil is any petroleum-based or synthetic oil that has been used.