OESO Environmental Programs

In October 2009, Duke University participated in an

EPA voluntary multi-media audit of the campus.
Numerous teaching and research laboratories,
classrooms, cold rooms, film processing rooms,
maintenance areas, boilers, chillers, emergency
generators, and etc. were surveyed during these audits.
During the audit, the following violations were noted:
 Wastes not labeled with “waste (name of chemical)” and dated
 Waste were stored in open containers
 Wastes stored without secondary containment
 Wastes from multiple locations consolidated in one room
 Laboratory Chemical Waste
Practice
Practice covers the following topics:
 Accumulation of waste chemicals
 Container Labeling and Marking

 Container Management

 Storage of Waste

 Acutely Hazardous Chemicals

 Unused, Unopened, or Unknown Chemicals

 Obsolete Chemicals or Substances

 Chemical Inventory

 Sink Disposal of Chemical Substances

Collection of Waste Chemicals
Waste chemicals collected either during the
operation of a process or otherwise accumulated in
the laboratory must be placed into containers that are
in good condition, compatible with the contents, and
able to contain the contents without leaking.
Container Labeling and Marking
Container Contents
Containers used to collect waste chemicals must be
clearly marked with the words “Waste (name of
chemical)”
Containers must be marked or labeled at the time waste
is first placed in the container (label templates can be found
on the OESO EP website)
Container Labeling and Marking
Waste Collection Dates
Containers must have an “open date” listed on the
container label, and when full or no longer being filled,
a “fill date”.
The “open date” is the earliest date that waste is placed
in the container whereas the “fill date” is the date that
the container is filled and will no longer be used to
accumulate waste.
Container Labeling and Marking
 Unused, unwanted, or unopened chemicals that are to be discarded
must be labeled with the words “Waste (name of chemical) and the
date that they were determined to be unwanted or unusable.

 Small or odd shaped containers that are difficult to place a label on

must be placed in a larger sealed container and labeled on the outside.
(zip-lock bags, plastic containers, etc.)

 Containers holding chemicals that cannot be identified by chemical

name, chemical constituents, or process generating the waste must be
labeled as “Waste Unknown” with the date that they are considered to
be no longer needed.
 Unused, Unopened, or Unknown
Chemicals
Chemicals identified by the Lab as no longer needed
and that are unused, unopened, or unknown must be
removed from the laboratory no later than 30
days after being designated as no longer needed.
Container Management
Waste containers must be compatible with their
contents.
Waste containers must be kept closed except when
adding or removing wastes.
Waste containers should be kept clean with no visible
contamination on the outside of the container.
Waste labels and markings must be readable and not
defaced.
Container Management
Areas where waste chemicals are accumulated must have
secondary containment sufficient to collect any incidental
spills from container failure.

Waste containers should not be overfilled. Full containers

must have at least a 10% headspace to allow for expansion.

Filled waste containers must be stored in a secure area

under the control of the operator

Waste containers must be stored for pick up in the room in

which they were generated
Container Management
Filled containers of chemical wastes must be
removed from the laboratory within 90 days of
the accumulation start date or the date a chemical
becomes a waste. In addition, no more than 50
gallons of chemical waste may be stored in a
laboratory at any one time.
Correct labeling and storage of a waste chemical
Container Management
Wastes collected during processes:
 Wastes that are collected as part of a continuous process (such as
HPLC wastes) must be collected via tubes that are fed through a
cap or other container closure to insure that the container is kept
closed. This closure must be a positive closing lid. Parrafilm and
similar closures will not be acceptable.
Containers used to collect waste chemicals on a
frequent, routine basis must be closed when a
procedure or experiment has been completed.
 EXAMPLE: Containers used to collect acetone washes must be
kept closed except when actively adding or removing wastes
from the container.
Correct labeling and storage of a HPLC waste chemical
Acutely Hazardous Chemicals
Commercial chemical products that are considered
“acutely” hazardous when discarded are labeled as “P-
List” waste by the US EPA and are subject to
additional regulatory requirements.
 A list of these chemicals can be found on the Environmental
Programs Compliance Webpage.

 “P-List” chemicals must be segregated into separate

containers, clearly marked with the words “Waste (name of
chemical)”, and labeled with the date waste is first placed
into that container.
Acutely Hazardous Chemicals
• An inventory of the amount (in pounds) of “P-List”
waste accumulated in the laboratory must be
maintained by laboratory personnel.
• An example of a Waste Log can be found on the
Environmental Programs Compliance Webpage.
• The inventory must be included in the Chemical
Waste Pick-Up Request. Laboratories may not
accumulate more than 2 pounds or 1 quart of “P-List”
waste at any time.
• Note: Empty containers of “P-List” chemicals must also be
submitted for pick-up.
 Obsolete Chemicals or
Substances
An obsolete chemical or substance is a chemical or
substance that will no longer be used for its intended
purpose or will not be used again and needs to be
discarded.
 Routine inventory reviews should be conducted to identify
any obsolete chemical or substances at least once per
quarter.
 Any obsolete chemical or substance should be removed from
storage, placed into the Laboratory’s chemical waste storage
area, and properly labeled and marked
 Unknown obsolete chemicals should be handled in the same
manner as an unknown or unused chemical discussed in the
previous slide.
Chemical Inventory
PIs or designated personnel need to develop and
maintain a chemical inventory. The inventory
 Should be reviewed and updated quarterly

Chemicals identified as expired or no longer needed

should be
 removed from storage,
 placed into the Laboratory’s chemical waste storage area,

 properly labeled and marked, and

 removed from the laboratory within 30 days.

 Drain Disposal
 Certain classes of chemicals cannot be poured down the drain – they
must be collected for disposal as hazardous waste. Some of which
include:
 Any flammable liquids with a flashpoint less then 140 oF - including but not
limited to any quantity of gasoline, kerosene, naptha, benzene, toluene, xylene,
fuel oil, ethers, ketones, aldehydes, chlorates, perchlorates, bromates, carbides,
hydrides, and sulfides. This list does not include aqueous solutions of
compounds that have a flashpoint greater than 140 oF.
 Explosive chemicals
 Mercury and mercury compounds
 Radioactive materials
 Photographic used fixer solutions unless they are first passed through a silver
recovery system
 Rinsate from highly hazardous P-listed wastes or any other chemical that would
be classified as a hazardous waste.
 Ethidium Bromide buffer solutions at concentrations greater than 10 µg/ml
 For a complete list see Guidelines For Sink Disposal of Chemical Substances on
OESO EP website for more details
 Drain Disposal
Certain substances in concentrations above what is
listed below can not be poured down the drain without a
permit
 Arsenic – 0.003 mg/l
 Cadmium – 0.003 mg/l

 Copper – 0.061 mg/l

 Cyanide – 0.005 mg/l

 Lead – 0.049 mg/l

 Nickel – 0.021 mg/l

 Silver – 0.005 mg/l

 Total Chromium – 0.050 mg/l

 Zinc – 0.175 mg/l

 Ammonia – 25 mg/l
 Acceptable Substances for
Drain Disposal
Chemicals that can be disposed of down the drain, providing
the solution does not contain prohibited materials, include:
 Aqueous solutions such as salts or buffer solutions within the pH range
of 5.0 to 12.0.
 Solutions with a flashpoint greater than 140F (60 C).
 Chemicals that are water soluble and not hazardous by definition.
 Acids and bases that have been neutralized to fall within the 5.0 to 12.0
pH range.
 Biological liquids that have been treated with disinfectant or
autoclaved.
 Buffer solutions containing less than 10 µg/ml ethidium bromide.
 Aqueous solutions containing alcohols at a concentration of 24% by
weight or less.
 Aqueous solutions containing formalin at concentrations less than 10%
by weight.
Aerosol Can Management
Aerosol cans may be handled as solid (non-
hazardous) waste if they meet the following criteria:
 The aerosol products have been used for their intended purposes
so that when holding the cans upright and pressing down on their
nozzles, not enough product comes out for them to be useful
anymore, and
 No more than 3% of the original net content weight remains in the
cans, or b) No more than one inch of liquid remains in the
bottoms of the cans, and
 The cans did not hold chemical formulations with sole active
ingredients identified in the F027 (used and unused formulations
for wood preserving) or P-list hazardous waste listings.
Aerosol Can Management
Aerosol cans that are not empty or may be hazardous
should be managed according to the Chemical Waste
Management Practices.

Aerosol cans that are still in use are not considered a

waste. Once the user decides they no longer need the
can, the correct disposal path for the can should be
made using the criteria listed above.
 Emergency Planning and
Community Right to Know Act
(EPCRA)
Designed to promote the discovery and mitigation of
risks associated with chemical use; and
To provide a data-gathering process to increase
awareness of chemical risks in the community.

Also requires that operating areas where hazardous

chemicals and substances are present to have, or have
access to, MSDSs for all hazardous chemicals used or
stored.
Targeted EHS Reporting Online
To determine the extent to which EPCRA applies to
your area:
 Complete online reporting of Targeted Extremely Hazardous
Substances (EHS)
 Determine the quantity of targeted chemicals present in your

lab and submit report (must answer 5 TSCA question to

complete report)
 Should be reviewed and updated quarterly

 OESO will compile the reports to determine reporting

requirements to local, state and federal agencies (Tier II)

 Update the report within 30 days of the addition of any

hazardous chemicals or substance to your area.

 Toxic Substance Control Act
(TSCA)
What is it?
Enacted in 1976
Gave EPA the authority to require reporting,
recordkeeping and testing requirements, and
restrictions relating to chemical substances and/or
mixtures
Certain substances are generally excluded from TSCA,
including, among others, food, drugs, cosmetics and
pesticides.
TSCA Compliance at Duke
Unlike hazardous waste handling and most other
environmental laws, TSCA compliance activities
are focused on specific laboratory operating
practices. For this reason, compliance
responsibility rests almost entirely with the
laboratory.
TSCA Compliance at Duke
• If you determine that your lab is not subject to TSCA,
complete the Applicability Form and you are
compliant with the regulation.

• If you determine that you are subject to TSCA

regulations, you may be subject to import/export,
chemical transport, and other facets of the regulation.
Please contact OESO at 684-2794 to discuss you lab’s
potential issues.
• Once you have determined your TSCA status, a TSCA
applicability form must be completed for each laboratory,
submitted to OESO, and a copy must be kept in the Lab.
 The from must be completed even if you are not subject
to the TSCA rules.

 Note – Applicability Form must be updated annually

Environmental Programs Division
Box 3914
684-2794
env.progs@mc.duke.edu
www.safety.duke.edu