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Hazardous Waste Management

The University has a complete hazardous waste program including the storage, accumulation, disposal, and transportation of hazardous waste as well as technical assistance and training. 

Within the University many departments generate wastes that are toxic, corrosive, reactive, or combustible.  The departments are responsible for storing and later disposing of these items as hazardous waste temporarily in their own location and then through EHS to pick up for quarterly disposal.

Both the Chemistry and Biology Building, Room 223, and the Trainer Natural Resources Building, Room 193, house secured stock rooms, for product storage and waste accumulation. Both keep regular business hours and can assist with any questions about hazardous waste management.

TRAINING is required for any individual involved in the generation, storage, movement, or disposal of hazardous waste on campus. This is generally offered once a year through an outside vendor, or on the job in the related department. At this time, go to https://seminars.veoliaes.com/seminars to register and see available dates and locations.

For more information and questions regarding the University’s hazardous waste program call x 2320.


​Waste

Solid Waste

Solid waste is what most of us think of as "trash" or "garbage" we produce. Despite its name, "solid" waste, it can be solid, liquid or contained gas. Broadly defined, solid waste is any material no longer used for its originally intended purpose, that will be discarded, treated to reclaim its original properties or processed to be used for an alternative purpose.

For more information on properly managing solid waste, please see the following pages and topics.

Dangerous Waste (DW)

Includes the waste which is dangerous to life, health, and the environment. For this reason, it requires special handling and disposal. (See, NR 679, NR 500, NR 447, TSCA for more information.)

Dangerous waste includes,

  • Asbestos
  • Lead Paint
  • Oil
  • Infectious, pharmaceutical, medical
  • Electronics
  • Radioactive materials
  • PCB's

-> DW - Used Oil & Filters and Oil Absorbents

Used Oil:

Used Oil includes,

  • Motor oils
  • Greases
  • Emulsions
  • Machine shop coolants
  • Heating media
  • Brake fluids
  • Transmission fluids
  • Other hydraulic fluids
  • Electrical insulating oils
  • Metal working fluids
  • Refrigeration oils

Containers and above ground tanks used to store used oil shall be labeled clearly with the words "USED OIL", NOT "Waste Oil". NR 679.22(3)

Hazardous Waste label can be used only if oil actually contains something hazardous.

Not leave funnels on oil tanks. Close oil tank tightly with its original cap.

See WI DNR Publication WA 233 Used Oil Management and Satisfying the Rebuttable Presumption for more details.

Used Oil Filters: WI ACT86

Used oil filters are regulated as used oil and lanfill banned since 2011. They should be recycled after adaquately drained. Store in containers that are in good condition and not leaking and label as "Used Oil".

Oil Absorbents: WI ACT 152

Oil absorbents can landfill if:

  • no free flowing oil in the absorbent material
  • absorbents are not hazardous waste

Best management practices: Recycle by sending to energy recovery or oil recovery.

See WI DNR Publication WA 1522 Managing Automative Engine Used Oil Filters and WA1503 Used Oil Filters and Absorbents Landfill Ban Questions and Answers for more details.

-> DW - Infectious Waste

​Infectious waste is solid waste that contains pathogens. It includes:

  • Sharps (needles, lancets, etc.)
  • Bulk amounts of blood and body fluids (OSHA's terms: drippable, pourable, squeezable, flakeable)
  • Microbiological laboratory waste
  • Human tissue
  • Animal infectious waste 

Exposure to infectious waste could contract an infectious disease. Storage must be enclosed container which has a label with an universal biohazard symbol.

Image result for biosafety hazard symbol

See Basic Infectious Waste Requirements for Generators of Small Amounts and Solidifying Infectious Waste for more details.

---> DW - COVID-19 Infectious Waste

COVID-19 waste that contains sharps (or other infectious materials if not disinfected) should continue to go out as medical waste.

See the WDNR's Infectious Waste Regulations page and listed below links for more detail.

-> DW - Pharmaceutical Waste

​Pharmaceutical waste may include, but not limited to:

  • Expired drugs
  • Patients' discarded medications
  • Waste materials containing excess drugs (syringes, IV bags, tubing, vials, etc.)

What is regulated?

  • DEA controlled sunstances
  • Containers that held P-Listed drugs
  • Drugs that are a hazardous waste (mercurochrome, arsenic compounds)

See, WI DNR Health Care Initiative Fact Sheet (PUB WA-1257 2008) - Evaluating & Managing Pharmaceutical Waste and Managing Excess Vaccines.

-> DW - Radioactive Waste

​Radioactive waste is waste that contains radioactive material. These materials may include smoke detectors, exit signs etc. which are used in everday life. Look for radioactive symbol and notices or warnings on the waste material. Call Risk Management x2320 for assistance. And do Not disamble manufactured articles.

Image result for radioactive hazard symbol

-> DW - Electronics

​Computers, computer accessories, TVs, cell phones and other electronics contain harmful materials including lead, mercury, cadmium, chromium, other heavy metals and chemical flame retardants. When landfilled, burned or illegally dumped, these chemicals can leach into soil or groundwater, where they may affect human and environmental health. Improperly handled discarded electronics may also cause health risks to workers at companies that manage the electronics.

Electronic devices covered under the Wisconsin's electronics recycling law ban include: computers and computer peripherals; TVs; desktop printers fax machines; DVD players, VCRs and other video players (DVRs); and cell phones.

See WI DNR PUB-WA 1473 2010 Managing Electronic Wastes Destined for Recycling and "Which Electronics Can I Recycle Under E-Cycle WI?" for more details.

Universal Waste (UW)

Universal Waste​

To encourage and facilitate recycling, Wisconsin's universal waste regulations reduce the hazardous waste management standards for Wisconsin's designated universal wastes by requiring less recordkeeping and allowing longer storage accumulation (max. 1year).

Keys to managing universal waste:

  • TRAIN: Employees who handle universal waste require training. Keep training records.
  • KEEP CLOSED: All containers of used lamps, antifreeze, pesticides and mercury-containing equipment must be closed.
  • LABEL: All containers or individual items must be correctly labelled.
  • DATE: Containers or individual items must be labelled with the date when the item was first placed in the container or the date when the item became waste.
  • REMOVE: Waste must be picked up or taken for recycling within one year of the date on the container.

-> UW - Lamps

Lamps that can be managed as universal waste include:

  • Fluorescent lamps (tube style),
  • Compact fluorescent lamps (CFLs),
  • Mercury vapor lamps,
  • Metal halide lamps,
  • High-pressure sodium-vapor lamps,
  • Ultraviolet lamps,
  • Neon lights,
  • Black lights,
  • LED lamps.

Broken lamps should be placed in closed, leak-proof, non-metal containers and handled as hazardous waste.

Management Practices:

  • Keep containers closed
  • Label and date storage boxes clearly with the words "universal waste lamps," "waste lamps" or "used lamps."
  • Mark the date on which the lamps were placed in storage on the cartons or boxes, or keep records of when lamps were placed in storage.
  • Can store for one year
  • Tape all corners and flaps
  • Keep from breaking
  • Reuse original package

See WI DNR WA-195 Lamp and Bulb Management and WA 653 2001 Management of "Green" Fluorescent Bulbs for more details.

-> UW - Batteries

​Batteries used in many household and office products, as well as motor vehicle batteries, contain a variety of heavy metals and other materials that can be harmful to human health and the environment if not handled properly.

Batteries that may be managed as universal waste include:

  • button batteries
  • lithium and lithium ion batteries
  • rechargable nickel-cadmium batteries
  • nickel-metal hydride batteries
  • sealed lead-acid batteries
  • silver oxide batteries
  • mercury oxide batteries

Alkaline batteries are not hazardous and may be disposed or recycled. See Battery Recycling for Businesses for more details.

Management Practices:

  • Keep containers closed
  • Label and date the container clearly with the words "universal waste-batteries," "waste batteries" or "used batteries"
  • Seperate battery types
  • Isolate battery terminals
  • Keep from breaking
  • Can store for one year

-> UW - Mercury Equipment

​Mercury-containing equipment that can be managed as universal waste includes:

  • Thermostats,
  • Barometers,
  • Mercury switches,
  • Old silver-mercury thermometers,
  • Certain medical equipment.

Broken mercury devices should be placed in closed, leak-proof, non-metal containers and handled as hazardous waste.

Management Practices:

  • Keep containers closed
  • Label and date the container clearly with the words "Universal Waste—Mercury Containing Equipment,” “Waste Mercury-Containing Equipment,” or “Used Mercury-Containing Equipment.”
  • Do not break devices
  • Keep spill kit available
  • Use non-metal rigid containers
  • Can store for one year

See WA 1004-2006 Management of Mercury Containing Equipment for more details.

-> UW - Antifreeze

​Waste antifreeze, also called used engine coolant or used ethylene or propylene glycol, often contains heavy metals such as lead, cadmium and chromium in high enough levels to make it a regulated hazardous waste. Mixing antifreeze with any other wastes may make it ineligible for recycling due to contamination.

Management Practices:

  • Keep containers closed
  • Label and date the container clearly with the words “Used Antifreeze.”
  • Can store for one year
  • Do not mix with other chemicals
  • Illegal to dump in storm water, sewer, septic tank, or absorption field.

See WA 356 Managing Used Antifreeze for more details.

-> UW - Pesticides

​Waste pesticides include those that are cancelled, suspended, banned, recently purchased but unused and pesticide residue that remains in spray tanks. 

All waste pesticides must be kept in closed containers that will not leak or spill under normal conditions.

Original product labels must be attached to containers of waste pesticides, even if the container that stores the residue in is not the original container.

All containers must be correctly labeled as “Universal Waste - Pesticides” or “Waste Pesticides” and have original product labels.

Individual items must be labeled with the date when the user decided the pesticide was waste.

Pesticides must be removed for recycling within one year of the date on the container.

Hazardous Waste

Hazardous Waste​

Hazardous waste is a special class of solid waste that must be managed properly to protect human health and the environment. Federal and state laws regulate how businesses, institutions, governments and other non-households must manage this waste.

Common Hazardous Waste Violations:

  • Not marking containers/tanks as "Hazardous Waste"
  • Accumulating too much hazardous waste at a satellite station
  • Not marking start date of accumulation on the container/tank at the accumulation point.
  • Accumulating hazardous waste on-site for more than 90 days.
  • Open containers 

See WI DNR Management of Hazardous Waste in Wisconsin page for more details.

​Hazardous Waste Requirements

Waste Determination & Recordkeeping

Accurate waste determinations are the first step in ensuring safe management of hazardous waste.

Waste Determination Process:

There are five principal steps in the waste determination process:

  • Identify the waste streams
  • Determine whether the waste stream is a solid waste
  • Determine if the solid waste is excluded
  • Determine whether the solid waste is a hazardous waste under NR 662.011
  • Document the information in steps 1-4: Compile the information used to make the waste determination, including a statement on whether the waste is a hazardous waste. If it is hazardous waste, list the applicable waste codes (D001, F003, U183, etc.) and what the generation rate of this waste is per month.

Listed or Characteristic Hazardous Wastes:

Hazardous wastes can be process wastes, chemicals or compounds designated as "listed wastes" and/or they can exhibit hazardous characteristics (ignitability, corrosivity, reactivity or toxicity). The waste codes outlined below are used to identify and track the wastes on shipping manifests.

Listed Wastes

F-list wastes:

These waste types (F001-F039) typically include certain spent solvents, paint thinners, brake and carburetor cleaners, vapor degreasing and dry cleaning solvents, electroplating wastes, and manufacturing and process wastes. [NR 661.31]

K-list wastes

These waste types (K001-K178) typically come from specific sources such as industrial processes like wood preserving, manufacturing pesticides, organic chemicals and veterinary drugs. [NR 661.32]

P-list wastes

These wastes are identified as acute hazardous wastes (P001-P205) and include discarded commercial chemical products; off-specification species; container and spill residues including unused chemicals such as cyanides, arsenic compounds and several pesticides. These wastes are extremely dangerous to human health and the environment in very small doses or short-term exposure. [NR 661.33]

U-list wastes

These wastes are identified as toxic wastes (U001- U411) and include discarded commercial chemical products, off-specification species, container residues, and spill residues including used chemicals that pose health risks due to their persistence in the environment or their potential for migrating through the environment. These wastes are dangerous to humans and the environment in small doses, but are not as toxic as "P listed" wastes. [NR 661.34]

Characteristic Wastes

Waste Code D001

Ignitability represents the ability of the waste to burn. Liquid wastes are ignitable if their flash point is less than 140 degrees F. Some non-liquids, flammable gases and certain oxidizers also have this characteristic. [NR 661.21]

Liquid wastes w/flash point <140F

Gasoline, xylene, toluene, acetone, benzene, methanol, isopropyl alcohol

Non-liquids

sulfer, oily rag containing drying oils (linseed oil, soya bean oil, tung oil), wetted titanium powder, aluminum powder, magnesium powder, alkali metals

Flammable gases

Propane, acetylene, butane, hydrogen, methane.

Oxidizers

Chlorates, permanganates, inorganic peroxides, organic peroxides, nitric acid in concentrations from 65% to 70%.

 GHS-pictogram-flamme.svg   GHS-pictogram-rondflam.svg   GHS-pictogram-bottle.svg

           Flammable                         Oxidizing                     Compressed Gas

Waste Code D002:

Corrosivity represents the ability of the waste to destroy or deteriorate materials, chemically burn skin, enhance movement of toxic chemicals in the environment, react dangerously with other wastes, or harm fish and other aquatic life. Aqueous wastes (>50% water) are corrosive if their pH is less than or equal to 2 or greater than or equal to 12.5 (e.g., rust remover, descaling products). Liquid wastes (e.g., ferric chloride) are corrosive if they corrode steel by more than one-quarter inch per year. [NR 661.22]

GHS-pictogram-acid.svg

Corrosive

Waste Code D003:

Reactivity is the waste’s tendency to react violently or explode. Wastes are reactive if they are unstable either alone or in the presence of water. These wastes can form explosive mixtures with water and produce dangerous quantities of toxic gases, vapors or fumes when mixed with water or when exposed to mild acids or bases. They can detonate, react or decompose explosively (e.g., hydrogen sulfide, cyanide or sulfide-bearing wastes, lithium-sulfur batteries, nitroglycerin formulations, ethylene oxide, sodium azide, and phosphorous). [NR 661.23]

GHS-pictogram-explos.svg

Explosive

Waste Code D004 - D043:

Toxicity is the ability of hazardous constituents to leach out of the waste. Wastes are toxic if they release or leach any of 39 specified heavy metals, pesticides or other organic chemicals above their regulatory level concentrations (e.g., benzene, carbon tetrachloride, chromium, Chlordane, Endrin, lead, mercury). [NR 661.24]

GHS-pictogram-skull.svg        GHS-pictogram-silhouette.svg

                                     Toxic                                 Health hazard

See WI DNR WA 1152 Waste Determination and Recordkeeping for more details.

Waste Accumulation Areas - Proper Container and Labelling

Mark/Label Containers:

Hazardous Waste: Mark or label the container as "Hazardous Waste" when waste is put into it.

Start Date: Label hazardous waste containers with a “start date” which shows when the first drop of waste was added.

Keep All Containers Closed:

With the exception of when waste is being added to a container, keep the container closed.

Keep Waste in Sturdy, Appropriate Containers:

The containers that use for accumulate hazardous waste in must be sturdy. The containers must also be made of an appropriate material so as not to react with the waste that placing into the container.

Keep Containers Easily Accessible

It is important to maintain enough space between and around containers to easily access. Keeping an aisle open makes inspections and removal easier.

Inspect Containers

Once a week inspect containers for signs of stress, or damage that would lead to leaking or a release of hazardous waste.

Keep Incompatible Wastes Separate and on Impermeable Surfaces

Do not keep containers of incompatible wastes near each other. Ensure that they are labeled properly to avoid any accidental mixing. Do not keep containers of liquid hazardous waste on a surface that has a floor drain.

Prepare Wastes for Shipment

They often supply proper containers, labels and placards to meet DOT requirements. However, it is your responsibility to ensure that any hazardous waste transported from your facility is managed per DOT specifications.

Leaks and Spills

Any leaking containers must be transferred to a non-leaking container immediately. If a spill or a leak occurs, the materials must be cleaned up and properly managed. See Hazardous Substance Spill section for more details about spills.

For more information see DNR Closed Container Guidance for Hazardous Waste Generators.

Inspection and Recordkeeping

​Once a week containers must be inspected for signs of stress, or damage that would lead to leaking or a release of hazardous waste.

Use UWSP EHS - Hazardous Waste Container Weekly Inspection Checklist for your weekly inspection and check for;

  • Containers marked/labeled properly
  • Start date
  • Closed tops
  • Stored 90 days or less
  • No leaks/staining
  • No dents/corrosion
  • Incompatible wastes and materials stored separately
  • Aisle space maintained
  • Secondary containment liquid free

Training Requirements

​Training requirements for the management of hazardous waste, universal waste, and used oil are outlined in the NR 600 series of the Wisconsin Administrative Code. Training employees to safely handle hazardous waste is the most effective and economic way to ensure proper waste management while protecting human and environmental health. The training requirements cover safety and emergency response and must be specific to the employee’s job function.

Training programs must teach hazardous waste management procedures and how to:

  • Document and maintain required records
  • Characterize hazardous wastes
  • Identify appropriate waste containers for storing and shipping
  • Label and mark containers during storage and for shipment
  • Protect employees from hazardous waste
  • Inspect waste-storage areas 
  • Utilize manifests
  • Respond to hazardous waste emergencies and spills

All facility personnel, including office staff and on-site contractors, must be trained on emergency procedures which includes training on UWSP contingency plans and evacuation procedures.

Annual refresher training is required. Please, send the copy of your Hazardous Waste training certificates to EHS office (George Stien Building Rm:127) or scan and email to Ceyda Onaran Kartal (conarank@uwsp.edu) for EHS record keeping.

See DNR Training Requirements and Records: Hazardous Waste Generators, Collection Sites and TSD Facilities for more details.

In-Lab Chemical Disposal Management

Disposal of Used/Unwanted Chemicals

No hazardous wastes are allowed in the normal trash. Hazardous wastes as defined by law include items such as reactive, corrosive, flammable, toxic wastes (meeting certain thresholds), or those specifically listed such as acute wastes. This may include materials used to clean up certain hazardous material spills and containers used to store acute wastes.

There are four primary disposal routes for chemicals at UWSP.
Pick-up by EHS:

This includes:

  • Chemicals in their original containers;
  • Waste flammable solvents (separated into halogenated and non-halogenated);
  • Process by-products, including reaction mixtures (solids and liquids).

The EHS will sort through the chemicals and either redistribute them, store until the hazardous waste contractor picks these up, put down the sanitary sewer (if they meet strict criteria), or (for waste considered to be non-hazardous) place safely into the trash.

Sanitary Sewer Disposal:

Sewer disposal in the lab is allowed for small quantities (less than a liter) of specific types of chemicals. Under no circumstances can any hazardous wastes - as defined by the EPA - go down the drain. Sewer disposal is allowed for aqueous solutions under strict limits. Contact the Chemical Hygiene Officer Kevin Czerwinski (x4154) for approval for sewer disposal.

Dilution to make a hazardous material non-hazardous and therefore sewer- disposable is NOT ALLOWED. For example, diluting ethanol to the point where it is non-flammable for the sake of putting it down the drain is NOT ALLOWED. However, it is acceptable to use a large amount of water to sewer a non-hazardous material.

Under limited circumstances you can neutralize acids and bases and dispose of them down the drain if;

  • It is less than a liter
  • You have an established procedure or
  • You received guidance from EHS.

If the chemical is not water soluble it cannot be put down the drain.

Segregate and Trash:

Minimally contaminated waste which still poses a hazard risk to an uninformed person because of the toxicity of the chemicals can be segregated and trash. Items in this class can go into a landfill with regular trash if you ensure that staff (e.g., custodial staff) are not accidentally exposed. This trash should be collected in a trash bag separate from normal lab trash in the lab and labeled with contents. When the bag is filled it should be placed in a sturdy box for disposal.

The following non-hazardous materials;

  • Any free-flowing, granular, or loose non-hazardous solid materials (such as powders, sand, carbon, absorbents, etc.).
  • Any non-hazardous gel or semi-solid material.
  • Materials excessively contaminated with chemicals (that are non-hazardous waste) and strong odor producing materials (such as towels saturated with strong odor contaminants, vials with small amounts of liquids that could leak, etc.).

must be disposed of by following applicable disposal procedures to prevent risks and avoid creating uncertainty and confusion to those who empty and handle lab wastebaskets.

• Place the item in a tightly closed plastic bag or plastic container and place inside a secondary container such as a closable plastic bag or plastic container that will not leak and then into waste receptacles in the lab. Using one plastic bag may be adequate if that bag is thick enough to prevent incidental tears. Seal and place in a receptacle that is lined with a regular plastic garbage bag.

• Place the item in a tightly sealed container or bag, put into garbage bag, and place it directly into the dumpster. Placing the item directly in the dumpster is recommended if there is a question of possible leakage from the containers.

• Place the items into a collection container (such as a plastic container with tight lid) that can be used to accumulate similar waste over time. This must be labeled properly while being used to accumulate the wastes. When full, follow one of above steps to dispose.

• Other EHS approved method.

Any container suspected of non-compliance by Custodial Department or other personnel is to be set aside, and marked “hold.” The custodian shall notify their Supervisor, and the lab manager and/or EHS is to be contacted and informed by the Custodial Department to investigate and determine proper disposal. See Appendix G-2 (Hold Sign for Regular Garbage Receptacles Under Investigation) of UWSP Chemical Hygiene Plan for the sign that may be customized for this purpose.

• Regular Trash:

Items such as lab wipes, gloves and items not minimally contaminated with low hazard chemicals can go to regular trash.

Please, see UWSP Chemical Hygiene PlanUW-Madison Laboratory Safety Guide, UW-Madison Chemical Disposal Procedure for additional information about specific chemical disposal routes.

Contact the Chemical Hygiene Officer, Kevin Czerwinski (x4154 - kczerwin@uwsp.edu) if you have any questions about determining the best disposal route.

​Spills

Hazardous Substances Spill

​Release of a hazardous substance that impacts or threatens human health or the environment based on its:

  • Quantity - How much in gallons and pounds?
  • Chemical Properties - for response decisions
  • Location - for waterway/wildlife damage potential

 All spills must be cleaned up, but it is generally not necessary to report recent spills that are:

  • less than 1 gallon of gasoline
  • less than 5 gallons of any petroleum product other than gasoline
  • any amount of gasoline or other petroleum product that is completely contained on an impervious surface
  • individual discharges authorized by a permit or program approved under Wis. Stats. Chs. 289 - 299
  • less than 25 gallons of liquid fertilizer
  • less than 250 pounds of dry fertilizer
  • pesticides that would cover less than 1 acre of land if applied according to label instructions
  • less than the federal reportable quantities listed in 40 C.F.R. §§ 117 or 302

See Wisconsin DNR - Hazardous Substance Spills for more information.

Site Responsibilities:

  • Notification to supervisor and Risk Management
  • Assess the incident
  • Ensure additional resources are available
  • Determine the source and extent of contamination
  • Activate Contingency Plan if required

Please, watch UW-Madison Small Oil Spill Cleanup video to see how to cleanup small spills.

UW-Madison Spill Cleanup Video.png

​​ ​
Resources: WI Department of Natural Resources (DNR) and UW-Madison Environmental Health and Safety