Laboratory Hazardous Waste

• Use a container compatible with the waste.
• Do not place chemicals in household product containers, such as food containers.
• Containers designed for solid chemicals should not be used for liquids.
• Do not use containers that previously contained a chemical that is incompatible with the chemical waste.
• Only use containers that show no sign of damage or deterioration.
• Use containers with screw tops or other well-fitted closures. Waste containers must remain closed, except when you are adding waste.
• May use spring-loaded funnels for adding waste to containers, as long as they self-close.

You may reuse containers for compatible chemicals if they are “empty”, which means no pourable content when held upside down. However, the original labels must be crossed out or removed before adding the waste.

Do NOT USE biohazardous-labeled containers or bags for packaging hazardous chemical waste.

Sharp items, such as razors, glass pipettes, and needles used for chemical processes may be placed in a sharps-type container for handling safety. However, all biohazard symbols and labels must be removed or completely defaced. Instead, handle and tag this as chemical hazardous waste.

Label all hazardous chemical waste with a SFSU Hazardous Waste ID tag. As soon as waste is generated and dispensed into a container, fill out the tag.

If you do not know the hazards for your chemical waste, use the SDSs of the component chemicals to determine what they are. For waste disposal purposes, there are four hazard characteristics:

• Ignitable (Flammable)
• Corrosive (pH <2.5 or pH >10)
• Toxic
• Reactive (e.g., contents will strongly react with water or air)

If you know the waste is not flammable, corrosive, water/air reactive, then mark the waste characteristic on the tag as "TOXIC". (There are regulatory reasons for this.)

If the material is still in its original manufacturer’s container and the label is readable, you may affix the hazwaste ID tag and write "see label" for ID and hazard information.

Note that some wastes are assumed to be hazardous or "toxic" by regulation, known as "listed" hazardous waste. Contact EH&S for help is you are unsure.

All waste must be accumulated at the point of generation. Do not generate your waste in one room and transfer to another room. In a large, shared space it is acceptable to have one location for waste accumulation.

• Segregate regulated chemical waste by chemical compatibility guidelines.
• Place waste in a seismically safe area (e.g., not on a windowsill.) Store containers inside a closable cabinet or on a shelf that is anchored and has a lip to prevent containers from sliding off.
• Place liquid waste containers in secondary containment for spill control.
• Waste chemicals may be stored in the same counter or cabinet as "in use" chemicals as long as the waste satellite accumulation part is clearly marked and segregated so they can't be confused.
• Do not accumulate large amounts of waste in the fume hood so that air flow is compromised.

Federal and state regulations limit the amount of time a generator may accumulate hazardous waste. To ensure the university does not exceed to allowable time, SF State has established the satellite hazardous waste area (SAA) accumulation times below:

• Maximum accumulation time: 10 months from the first drop of waste put into container
• Extremely hazardous waste: 1 month
  • Example: cyanides

Note that one-time waste (e.g., unwanted reagent, spill clean-up materials) is NOT satellite accumulation so the the maximum accumulation/storage time this waste container may be on campus is 90 days.

Once your satellite accumulation area is set up, you must manage the containers using best practices such as the ones listed below:

1. Do not over-fill waste containers.
   • Liquid waste is considered "full" when the container is 3/4 to the top to allow room for expansion. Consider drawing a maximum "fill" line on the bottle.
   • Dry waste is considered "full" when the bag is about 2/3 to the top to allow it to be tied securely before lifting it out of the hard-sided collection container.
2. If the container has a tear or is leaking, place it into another container to make it safe to handle.
3. Wipe down the exterior of waste accumulation containers to make it safe for staff to handle.
4. Make sure the hazardous waste ID tag is attached to the container and that it accurately states what is inside. This information is used by the waste contractor to segregate the waste streams for shipment.
5. Do not put "in use" chemical containers or samples inside the waste secondary containment. Waste must be clearly separated from non-waste.
6. When re-using product containers for waste, remove or cover up the old labels so there is no confusion.

Keep waste containers closed when not actually adding or removing waste.

One-time Hazardous Waste

If you are disposing of spill clean-up materials or a chemical/product you no longer need, then this is not "satellite accumulation". The standard hazardous waste rules apply.

1. Write in the date you decide it is a "waste" on the tag under "Accumulation Start Date"
2. Leave the 10-month date blank (since this is not accumulating in the container).
3. Transfer the container to the central haz. waste accumulation area (trailer/shed).
4. It must be off-campus within 90 days. (Tiburon Campus: 180 days)

Note: If you have an older version of the tag, leave the "Container Full Date" blank, as this does not apply to laboratory waste less than 55 gallons in a single container.

Personnel who generate or handle hazardous waste from laboratories are required to complete the following two curricula in CSU Learn:

• Hazardous Waste Handler - Laboratories
• Responding to Chemical Releases at SFSU

Contact the EH&S Office if you need to be assigned this training.

Fun Fact: SF State is a "Generator" of hazardous waste and is not permitted to "store" hazardous waste without a permit.

• The regulations allow generators to "accumulate"  hazardous waste for up to 90 days (large quantity generator) in a central accumulation area before it must be shipped.
• Satellite accumulation rules allow waste to be "accumulated" at the point of generation for up to 1 year before it must be shipped, as long as these satellite rules are followed.

We often use "accumulation" and "storage" interchangeably, but technically they are not the same under hazardous waste regulations.

The Central Accumulation Area is also sometimes called the "90-day" accumulation area as that is the maximum time the waste may "stored".

The Satellite Accumulation Area is under the control of the generator and is in the area where the waste is generated. This is for situations where waste is added to a container over time, such as in laboratory operations.

Fun Fact: The term hazardous waste refers to chemical waste only.

While other wastes generated in labs may pose a hazard and are regulated, they are not included in the term "hazardous waste" which is regulated by the California Hazardous Waste Control Law (and federal RCRA regulations).

Other Regulated Waste

Medical Waste: Regulated by CA Medical Waste Management Act, it includes clinical medical waste, biohazards, biologically-contaminated sharps, and pathology waste.

Radioactive Waste: Regulated by the CA Radiologic Health Branch, it includes sealed and unsealed radioactive materials and contaminated items.

Mixed Waste usually refers to chemical waste that also contains other regulated wastes.