Shepherd University is a Conditionally Exempt Small Quantity Generator (CESQG) of hazardous waste per United States Environmental Protection Agency (EPA) and West Virginia Department of Environmental Protection (WV DEP) regulations. As such, the University is limited on the amount of hazardous waste it may generate per month. If monthly hazardous waste limits are exceeded, the University would move into a higher generator category and be required to notify the WV DEP and US EPA and meet the higher generator category requirements. The higher the generator status, the more stringent the University is regulated.
It is essential for the University to have an accurate accounting of all hazardous waste on campus. At Shepherd, the Campus Environmental Safety Coordinator is responsible for tracking the hazardous waste generated on campus to ensure the University is staying within its limits. In order to do this, hazardous waste generators on campus must be actively involved in the hazardous waste management process. This includes participating in training, making hazardous waste determinations (Is my waste a hazardous waste?), container management, labeling, and reporting.
If you are a generator of hazardous waste, non-hazardous chemical waste or are unsure if you are a generator of hazardous waste, please contact Dustin Robbins, so that a review of your waste streams and processes can be made.
Hazardous Waste Training
Regular generators of hazardous waste and universal waste must be trained/informed prior to generating waste. If you or your department are in need of training, please contact Dustin Robbins. Training is essential as it provides generators with knowledge of applicable regulations and generator-specific responsibilities. Without training, generators can put themselves and others at risk and also jeopardize the University’s compliance with applicable hazardous waste regulations.
Hazardous Waste Determination
Shepherd University and its generators of hazardous waste are required to make hazardous waste determinations when generating solid waste. Hazardous waste determinations are made using knowledge of the waste or through analysis of the waste. After receiving hazardous waste training, generators should be able to make waste determinations of their waste streams. The hazardous waste determination process is one of, if not, the most important steps in the hazardous waste management process. Without waste determinations being made or if improper waste determinations are made, generators may manage their waste incorrectly. Additionally, the University would not be able to accurately account for its monthly and total hazardous waste quantities. Not performing waste determinations and incorrect waste determinations can lead to compliance problems as well as an increased risk to environmental and human health.
Each generator at Shepherd University is required to make hazardous waste determinations of the wastes in which they generate. Prior to engaging in actions or initiating processes that generate waste, generators are encouraged to decide if their waste stream(s) will generate hazardous waste. This will enable generators to be better prepared to manage their wastes appropriately.
Hazardous Waste Determination Process
Step 1: Is It “Solid Waste?”
Step 2: Is the waste excluded from regulation as a solid waste or hazardous waste?
Step 3: Is It A Listed Hazardous Waste?
Is the waste specifically listed in RCRA regulations? Listed hazardous wastes appear on four lists which are as follows:
- F-Listed Waste
- K-Listed Waste (Typically not found on college campuses)
- P-Listed Waste
- U-Listed Waste
The listed hazardous wastes (F-, K-, P- and U-Listed) may be found by clicking here.
Step 4: Is It A Characteristic Hazardous Waste?
Does the waste exhibit one or more characteristics of a hazardous waste? The characteristics are as follows:
1. Ignitability (D001): Wastes that are hazardous due to the ignitability characteristic include liquids with flash points below 60°C, non-liquids that cause fire through specific conditions, ignitable compressed gases and oxidizers.
2. Corrosivity (D002): Wastes that are hazardous due to the corrosivity characteristic include aqueous wastes with a pH of less than or equal to 2, a pH greater than or equal to 12.5 or based on the liquids ability to corrode steel.
3. Reactivity (D003): Wastes that are hazardous due to the reactivity characteristic may be unstable under normal conditions, may react with water, may give off toxic gases and may be capable of detonation or explosion under normal conditions or when heated.
4. Toxicity (D004-43): Wastes that are hazardous due to the toxicity characteristic are harmful when ingested or absorbed. Toxic wastes present a concern as they may be able to leach from waste and pollute groundwater. The toxicity of a waste is determined by the Toxicity Characteristic Leaching Procedure (TCLP).
The characteristic hazardous waste codes (Waste Codes D001-43) may be found by clicking here.
Hazardous Waste Determination Sheet
From May of 2001 to May of 2011, colleges, universities and professional schools accounted for the fourth highest non-compliance rate for hazardous waste determinations in the United States [Environmental Protection Agency. (2013). Hazardous Waste Determination Program Evaluation: Final Report (EPA Publication No. 100-K-12-010)]. In order to ensure that generators and the University are meeting the hazardous waste determination requirement and to help guide its generators through the process, a “Hazardous Waste Determination Sheet” has been created. Generators are encouraged to complete the Hazardous Waste Determination Sheet for each waste that they generate. The Campus Environmental Safety Coordinator (CESC) is available to assist generators in completing the Hazardous Waste Determination Sheet. The CESC will keep records of all completed Hazardous Waste Determination Sheets.
Hazardous Waste Container Management
Hazardous waste must be containerized in a sturdy, leak-proof container that is compatible with the waste in which it is holding. Except when adding or removing waste to a container, all waste containers must remain closed at all times. Loose caps and lids are considered “open” and are US EPA and WV DEP violations. Incompatible wastes should never be mixed in the same container. Secondary containment (bins, trays, etc.) are encourage for all hazardous waste containers. Secondary containment should always be used for containers near drains.
Hazardous Waste Labeling
Each container of hazardous waste must be properly labeled. Unlabeled and improperly labeled containers of hazardous waste can lead to US EPA and WV DEP violations. Unlabeled containers are also in violation of other health and safety codes and regulations (e.g. OSHA and NFPA). More importantly, unlabeled or improperly labeled containers of hazardous waste are health and safety hazards. At minimum, each hazardous waste container must be clearly labeled with the following information:
- The words “Hazardous Waste“
- The Contents of the hazardous waste
- The Accumulation Start Date (i.e. date on which the waste was generated)
All hazardous waste containers must be labeled with the words “Hazardous Waste.” The words “Hazardous Waste” indicate that a waste determination has been made of the waste. Hazardous waste containers without the words “Hazardous Waste” can lead to labeling violations and waste determination violations.
Each label must include the contents of each waste container. No abbreviations, chemical formulas or other forms of shorthand may be used when labeling the contents of a hazardous waste container. Smaller containers can be overpacked in larger containers to provide space for the contents of the container to be communicated. Without communicating the contents of a hazardous waste container on a label, the proper handling, storage and ultimate treatment/disposal can be jeopardized. Unknown containers of waste may require an an analysis of the waste to be made which can be expensive to perform.
Accumulation Start Date
The date on which a waste was first accumulated must be on each hazardous waste container. This ensures that waste containers are not held for extended period of times and allows for accurate monthly accounting of waste.
Hazardous Waste Labels (MS Word format for printing on avery labels)
Non-Hazardous Waste Labels
Some materials are not RCRA-regulated hazardous wastes, but may need to be collected and provided to a disposal contractor. Ethidium bromide is an example of a non-hazardous waste that should be collected and provided to a disposal contractor for treatment or incineration. Do not label non-hazardous waste containers with the words “hazardous waste” or use hazardous waste labels on them. Label non-hazardous waste containers for collection with the words “Non-Hazardous Waste” or use the non-hazardous waste label below.
Hazardous Waste / Chemical Waste Pick-Up Request
Timely reporting of any hazardous waste generated at Shepherd is imperative. If you have generated waste and are in need of a pick-up, please complete the Hazardous & Chemical Waste Pick-up Request Form. Provide as much information as possible about the waste(s) when completing the form. Two different waste streams may be requested per form. After filling out the form, right-click the “SEND” button to submit the form. If additional requests are needed, please submit subsequent request forms as needed.
Please note that not all wastes may be able to be moved from a collection site to a central storage location due to storage requirements, container size, or other factors. If this is the case, the waste will be moved on, or just prior to, the next scheduled waste disposal pick-up.
Waste minimization is a vital part of a waste management system. In an effort to minimize wastes from being shipped off site for disposal or recycling, efforts should first be made to see if any unwanted chemical products within a department or group on campus can be used by another. To help facilitate this “chemical exchange” process, employees may contact Dustin Robbins, Campus Environmental Safety Coordinator.