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Introduction

Hazardous waste may be generated from laboratory operations, facilities operations and maintenance, construction and renovation activities, photo processing, and a variety of other activities at ASU. Hazardous waste is a particular class of "solid" waste (which includes solid, liquid, or gaseous material) which, if improperly managed, poses a substantial threat or potential hazard to human health and the environment. Typical wastes generated at the ASU include, but are not limited to: spent solvents, waste laboratory chemicals, waste paints and used oil.

Hazardous waste is subject to a complex regulatory scheme to assure that uniform and consistent waste identification, storage and disposal procedures are followed by persons trained in the proper management of these waste substances. In a responsibility that cannot be reassigned to others, the Environmental Protection Agency (EPA) assigns the generator of hazardous waste "cradle to grave" responsibility for the proper management of these substances after the point of generation. This strict liability scheme creates a powerful incentive for regulatory compliance, including waste minimization. In Arizona , the Arizona Department of Environmental Quality (ADEQ) is the agency responsible for the implementation and enforcement of hazardous waste regulations.

Environmental Health & Safety (EH&S) is responsible for assisting ASU with hazardous waste management procedures including waste identification, storage, packaging, manifesting, shipping, disposal, reporting, records keeping and training. This Fact Sheet provides individuals involved in the generation of hazardous waste with an overview of regulatory requirements for the management of these wastes.

Applicable ASU Policies

Applicable Regulations

Summary of Requirements

The scope and complexity of regulatory requirements which generators are subject to is directly related to a generator's "status". A generator's status is based on the quantity of hazardous waste generated per site on a monthly basis. The U.S. EPA and ADEQ have established specific hazardous waste regulations for large quantity generators (LQG), and small quantity generators (SQG). The following summary of requirements provides a general overview of regulatory requirements applicable to most generators of hazardous waste. Contact EPA or ADEQ for additional guidance.

1. Waste Identification: Hazardous waste includes substances that are solids, liquids and gases. The EPA definition of hazardous waste includes substances that possess a hazardous characteristic (e.g. toxic, ignitable, corrosive or reactive with other substances), or substances that are listed as hazardous waste by the EPA on the basis of their usage or chemical constituents . Regulations include specific methodology for the identification of hazardous waste. For your convenience, consider all waste chemical formulations (abandoned, used, out dated, or otherwise waste-like chemicals and formulations) as a hazardous waste unless EH&S determines the particular waste is not a hazardous waste. Contact EH&S for technical assistance at x5-3899 or x5-8554.
   
2. Labeling: Containers which store hazardous waste must be properly and clearly labeled. Labels (available through Lab Stores, EH&S as well as several other campus locations) must include: (1) the words "HAZARDOUS WASTE"; (2) the container contents in words not chemical formulas (e.g. “Methylene Chloride” ); (3) the amount of each waste constituent in the container (total must equal 100%); (4) the name and telephone number of the person generating the waste; (5) the building and room number where the waste is generated and located; (6) the physical state of the waste (e.g. “solid or liquid”); and, (7) the hazard class or category of the waste (e.g. corrosive, flammable, toxic, reactive).
   
3. Accumulation and Storage: Hazardous waste regulations established a two- tiered waste accumulation and storage system: satellite accumulation and main accumulation.

Satellite Accumulation: Hazardous waste accumulation and storage which is at the point of generation and under the control of the person generating the waste is called satellite accumulation. Regulations allow a maximum of 55 gallons of hazardous waste or 1 quart of acutely hazardous waste at each satellite accumulation area. Satellite accumulation containers must be closed at all times except when waste is being added to the container. Hazardous waste containers should be stored in leak-proof tubs or another type of secondary containment within satellite storage areas.

Main Accumulation: Main accumulation and storage of hazardous waste is subject to strict time limitations. Large quantity generators of hazardous waste, such as ASU Tempe, are allowed to store hazardous waste on-site for a maximum of 90 days. The ASU main accumulation area is located in The Engineering Center (ECC 128/134).

Manifesting: Hazardous waste must be shipped with a special shipping paper called a hazardous waste manifest. Each location has a unique EPA Generator ID number that must appear on the manifest.

EH&S is responsible for shipping and managing all hazardous waste manifests.

1. Transportation and Disposal: Hazardous waste may be transported only by a licensed hazardous waste transporter and may be sent only to a licensed treatment, storage and disposal facility (TSDF).
2. Emergency Preparedness and Prevention: In accordance with regulatory requirements, ASU maintains a Hazardous Waste Accumulation Facility Emergency Contingency Plan. This Plan is designed to prevent and to minimize hazards to the public or to the environment from fires, explosions, spills or other unplanned releases of hazardous waste. Hazardous waste regulations also require generators to comply with emergency preparedness and prevention requirements. ASU is also required to make arrangements with local emergency agencies such as the fire department, police department, spill response contractors and State and local emergency planning committees.
3. Waste Minimization: Generators of hazardous waste are required by the EPA to minimize the volume and toxicity of the hazardous waste they generate. Minimization may be accomplished through source reduction, recycling and product substitution. The elements of a hazardous waste minimization may be found in the ASU Pollution Prevention Plan.
4. Recycling: Hazardous waste recycling activities require a permit. EH&S actively pursues viable recycling opportunities for non-hazardous waste including used oil and batteries. To access other ASU recycling programs, go to: http://property.asu.edu/recycle

Training

Employees involved in the management of hazardous waste must possess extensive waste management experience and complete specialized certificate training programs. Employees must be trained within 6 months of hire and annually thereafter. Generators are required to maintain a written program which describes training program contents, who is trained and why, and recordkeeping procedures. EH&S maintains these records. EH&S offers specialized training in Hazardous Waste Management. Training details, times and locations are available at: http://www.asu.edu/uagc/EHS/

Reporting

The following outlines typical reporting requirements for generators of hazardous waste:

• Generators are required to submit an annual hazardous waste report which summarizes hazardous waste generation and management activity for the previous year.
• Hazardous waste manifests must be submitted immediately to ADEQ.
• Any change in generation status or types of hazardous waste generated requires prompt notification to ADEQ.

These reporting requirements are fulfilled by EH&S.

Inspections

Regulations require that hazardous waste main accumulation area be inspected on a weekly basis. EH&S performs these required inspections.

Recordkeeping

Hazardous waste regulations require that the following records be maintained for a minimum of 3 years:

• waste analysis/determination records;
• manifests; and
• Annual reports.

Land disposal restriction (LDR) notifications/certifications, which typically accompany hazardous waste manifests, are required to be maintained for a minimum of 5 years. Manifest and LDR notifications/certifications copies are maintained by EH&S for retention and compilation into an EPA-required Annual Report of waste activities.

Updated 11/21/06

Mailing Address: PO Box 873804, Tempe, Arizona 85287-3804
Contact Email: EHS@asu.edu
Phone: (480) 965-1823
FAX:  (480) 965-0736