Hazardous Waste Management PlanCONTENTS1. General Policy for Managing Hazardous Waste1a. Mission Statement 1b.Training Initiatives 1c.Pollution Prevention/Waste Minimization Generator Classification 1d. Large Quantity Generator (MCP Hahnemann University) 1e. Small Quantity Generator (Drexel University) 1f. Compliance 2. Hazardous Waste Management Procedures in the Laboratory 2a. Hazardous Waste 2b. Hazardous Waste Identification 2c. Mixed Chemical Waste 2d. Multi-Hazardous Waste 2e. Drain Disposal 2f. Satellite Accumulation Areas (40 CFR 262.34(C)) 2f-1. Allowable Amount Accumulated 2f-2. Labeling 2f-3. Container Types 2f-4. Accumulation Time 2f-5. Inspection 2g. Chemical Pick-Up 2h. Emergency Spill Response Plan for Laboratories 2i. Training 3. Standard Procedures for Removal of Hazardous Waste from Laboratories 3a. Training 3b. Removal Procedures 3b-1. Chemical Pick-Up 3b-2. Transportation 3b-3. Personal Protection 3c. Temporary Accumulation Area 3c-1. Accumulation Time 3c-2. Labeling 3c-3. Allowable Amount Accumulated 3c-4. Incompatibles Storage 3c-5. Container 3c-6. Inspection of the Temporary Accumulation Area 3c-7. Preparedness and Prevention 4. Procedures for Hazardous Waste Removal (Off-Site) 4a. Training 4b. Packing 4c. Labeling and Marking 4d. Placarding 4e. Manifest 4f. Acquisition of Manifests 4g. Number of Copies 4h. Manifest Process 4i. Record Keeping 4j. Completed Chemical Pick-Up Request Forms 4k. Manifest 5. Manifest Filing System 5a. Waste Counting 5b. Inspection Records 5b-1. Container Inspection Records 5b-2. Satellite Accumulation Area Inspection Records 5b-3. Temporary Accumulation Area Inspection Records 5b-4. Temporary Accumulation Area Emergency Equipment Inspection Records 6. Hazardous Waste Reports 6a. Biennial Report 6b. Exception Report 6b-1. Thirty-Five Day Limit 6b-2. Forty-Five Day Limit 6c. Sampling Report 6d. Retention Time 7. Printable Chemical Pick-Up Request Form 1. General Policy for Managing Hazardous WasteBack to Top 1a. Mission StatementTo Anticipate, Recognize, Evaluate and Control environmental hazards at Drexel University while continuously striving to protect human health and the environment, and promote a University setting that is conductive to the highest level of education and research.Back to Top 1b. Training InitiativesUniversity Safety and Health Department believes that training is an integral part in creating an environmentally aware and safe work place. We have integrated our environmental policies and goals into a comprehensive training program that provides:
Back to Top 1c. Pollution Prevention/Waste MinimizationPollution Prevention and waste minimization are terms that refer to the practices that reduce or eliminate the amount of pollutants which would have entered any waste stream or that would have been released into the environment prior to recycling, treatment, or disposal. Drexel University will prevent or reduce the amount and/or toxicity of hazardous waste in the laboratory by using practices and materials that avoid, reduce and control hazardous waste generation at the source.Back to Top Generator Classification1d. Large Quantity Generator (LQG)The LQG classification allows Drexel University to:
Back to Top 1e. Drexel University - Small Quantity Generator (SQG)The SQG classification allows Drexel University to:
Back to Top 1f. ComplianceDrexel University will continue to comply with all Federal, State, and Local environmental laws and regulations.Back to Top 2. Hazardous Waste Management Procedures in the Laboratory2a. Hazardous WasteHazardous 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.Back to Top 2b. Hazardous Waste IdentificationThe University Safety and Health Department will perform identification of hazardous wastes. Since the majority of chemicals used in our facility are reagent grade the identification will be performed using Material Safety Data Sheets, bottle labels, and 40 CFR Part 261 Subpart B, C, and D. A third party contractor will test for the ignitability, corrosivity, reactivity, and toxicity of unknown hazardous wastes.Back to Top 2c. Mixed Chemical WasteThe University Safety and Health Department shall require that only compatible chemical waste be combined into one waste container. Refer to the Laboratory Safety Manual and MSDS for chemical compatibilities.Back to Top 2d. Multi-Hazardous WasteMulti-Hazardous waste is waste that contains any combination of chemical, radioactive, or biological hazards. Any waste stream that presents more than one type of hazard will require special management consideration because the selected treatment technology appropriate for one type of waste may not be appropriate for the other types. Multi-hazardous waste will be evaluated on an individual basis and the constituent that poses the greatest hazard will be given priority.Back to Top 2e. Drain DisposalThe University Safety and Health Department will permit drain disposal of elementary neutralized (pH adjustment of waste that are hazardous only because they exhibit the corrosivity characteristic) acidic and caustic aqueous solutions. The elementary neutralized aqueous solution must have a final pH value between 6 and 9.All drain discharges will be documented on a log sheet located near the point of discharge. The log sheet shall contain the date of discharge, the chemical name, the volume discharged and the pH value. The University Safety and Health Department will collect the log sheet bimonthly. Each log sheet will be kept in a room specific file for one year. The University Safety and Health Department shall prohibit the drain disposal of the following:
Back to Top 2f. Satellite Accumulation Areas (40 CFR 262.34(c))A satellite accumulation area is an area at or near a process that generates chemical wastes. The area must be under the control of the operator of that process.The University Safety and Health Department designates each laboratory as a satellite accumulation area. The laboratory Principal Investigator, Moderator, Chemical Hygiene Officer, is responsible for following the policies of the safety and health department regarding satellite accumulation areas. Back to Top 2f-1. Allowable Amount Accumulated
Back to Top 2f-2. Labeling
Back to Top 2f-3. Container Types
University City -- 215-895-2889 Back to Top 2f-4. Accumulation Time
Back to Top 2f-5. InspectionBack to Top 2g. Chemical Pick-up RequestThe Safety and Health Department shall provide chemical pick-up request forms for each laboratory. Chemical pick-up request forms should be immediately filled out when:
Center City - Fax number - (215)-762-7899 - Martin Bell University City - Fax number - (215) 895-1560 - Phil Leo University Safety and Health Department shall respond to chemical pick-up request within 48 hours of receipt of request. Back to Top 2h. Emergency Spill Response Plan for LaboratoriesThe University Department of Safety and Health shall reference the Hazardous Materials Emergency Response Plan for emergency spill procedures.Back to Top 2I. TrainingUniversity Safety and Health Department will provide training to all university employees/students who handle hazardous waste in laboratories. Each employee/student shall receive training on proper handling of chemicals and emergency response procedures.Initial training must be completed during the first month of employment (refresher training is provided annually thereafter). Hazardous waste training will be conducted as part of the annual laboratory safety training. Additional training sessions can be arranged by calling University Safety and Health Department at: Center City - (215) 762-6506 University City - 215) 762-2889 University Safety and Health Department shall document all hazardous waste training. Training records will be kept for at least three years from the date the employee last worked at the university. Back to Top 3. Standard Procedures for Removal of Hazardous Waste from LaboratoriesOnly properly trained personnel from the University Safety and Health Department shall only perform the removal of hazardous waste from the laboratory. The University Safety and Health Department reserves the right to obtain outside contractor for major waste removals from laboratories.Back to Top 3A. TrainingUniversity Safety and Health personnel and/or contractors who remove hazardous waste from laboratories shall have the OSHA 40 Hour Hazwopper certification.University Safety and Health Department documents training of all personnel. The training records will be kept for at least three years from the date the employee last worked at the university. Back to Top 3B. Removal Procedures3B-1. Chemical Pick-up
Back to Top 3B-2. Transportation
Back to Top 3B-3. Personal Protection
Back to Top 3C. Temporary Accumulation AreaThe University Safety and Health Department shall store all hazardous waste in a central temporary accumulation area. This temporary storage facility complies with subpart DD of the 40 CFR Part 265.The professional engineer certification that the containment building complies with the design standards specified in 40 CFR 265.1101 is in the facility’s operation record. Drexel University has four temporary storage facilities. The location of each temporary storage facility is as follows:
Back to Top 3C-1. Accumulation TimeDrexel University
Back to Top 3C-2. Labeling
Back to Top 3C-3. Allowable Amount Accumulated
Back to Top 3C-4. Incompatibles Storage
Back to Top 3C-5. Container
Back to Top 3C-6. Inspection of the Temporary Accumulation Area
Back to Top 3C-7. Preparedness and Prevention
Back to Top 4. Procedures For Hazardous Waste Removal (Off-site)The University Safety and Health Department shall require all contracted hazardous waste transporters to comply with the requirements set forth by this plan, in addition to the federal, state and local hazardous waste regulations.Back to Top 4A. TrainingThe contracted hazardous waste transporters shall comply with the training requirements listed in 49 CFR Part 172 Subpart H and 49 CFR Part 177.816.The University Safety and Health Department shall inform all hazardous waste contractors on the university’s emergency spill response procedures. Back to Top 4B. PackingThe contracted hazardous waste transporter shall package all hazardous waste in accordance with all Department of Transportation regulations on packaging under 49 CFR Parts 173, 173.12 & Subpart B, 178, and 179.The University Safety and Health Department shall require all contracted hazardous waste transporters to carry emergency spill clean up materials when packing hazardous materials for transportation. Back to Top 4C. Labeling and MarkingBefore transporting the hazardous waste packages, the transporter shall label each package in accordance with Department of Transportation labeling requirements (49 CFR Part 172 Subpart D and E).The transporter shall mark all containers of 110 gallons or less used in transportation with the following words and information displayed in accordance with the requirements of 49 CFR 172.304: "HAZARDOUS WASTE " Federal Law Prohibits Improper Disposal. If found, contact the nearest police or public safety authority or the U.S. Environmental Protection Agency” Drexel University Building name and address Manifest document number Back to Top 4D. PlacardingThe transporter shall placard the transportation vehicle according to Department of Transportation regulations 49 CFR Part 172 Subpart F for hazardous materials.Back to Top 4E. ManifestUniversity Safety and Health Department and hazardous waste transporter will mutually designate on the manifest one primary facility that is permitted to handle the waste described on the manifest.University Safety and Health Department and hazardous waste transporter will mutually designate on the manifest one alternate facility that is permitted to handle the waste in the event an emergency prevents delivery of the waste to the primary facility. University Safety and Health Department shall require the hazardous waste transporter to complete all manifests prior to leaving the site. University Safety and Health Department shall review the completed manifest prior to signing. Back to Top 4F. Acquisition of ManifestsThe transporter shall use the manifest format of the state receiving the hazardous waste. If that state does not supply the manifest then the transporter shall use the Pennsylvania manifest. If neither state supplies the manifest then the transporter shall obtain the manifest from any source.Back to Top 4G. Number of CopiesThe manifest consists of at least the number of copies which will provide the University Safety and Health Department, each transporter, and the owner or operator of the designated TSDF with one copy each for their records and another copy to be returned to University Safety and Health Department.Back to Top 4H. Manifest ProcessThe manifest shall be signed and dated by the initial transporter and University Safety and Health Department. University Safety and Health Department shall retain one copy and give the transporter the remaining copies. A designated representative from the TSDF shall sign the manifest upon delivery and return a copy of the manifest to University Safety and Health Department within 35 days.Back to Top 4I. Record KeepingUniversity Safety and Health Department shall comply with the local, state and federal record keeping requirements. In addition, the safety and health department shall comply with the requirements set forth by this document.Back to Top 4J. Completed Chemical Pick-up Request FormsCompleted chemical pick-up requests forms shall be filed in a temporary filing system until the 89-day waste pick up. Upon completion of the 89-day pick up, the forms shall be filed in a permanent filing system and retained for three years or until Drexel University receives a signed copy from the designated waste facility that received the waste.Back to Top 4K. ManifestUniversity Safety and Health Department shall keep a copy of each manifest signed in accordance with 40 CFR Part 262.23 for three years or until the safety and health department receives a signed copy from the designated facility that received the waste. The signed copy from the designated facility shall be retained as a record for at least three years from the date the waste was accepted by the initial transporter.Back to Top 5. Manifest Filing System
Back to Top 5A. Waste CountingThe transporters packing list and the completed chemical pick up request forms shall be used to total the weight of all hazardous waste generated in each month. The safety and health department shall keep a permanent database of the monthly totals. The content of the database is as follows:
Back to Top 5B. Inspection RecordsUniversity Safety and Health Department shall strictly inspect and document all areas involved in the universities hazardous waste operations.Back to Top 5B-1. Container Inspection Records
Back to Top 5B-2. Satellite Accumulation Area Inspection Records
Back to Top 5B-3. Temporary Accumulation Area Inspection Records
Back to Top 5B-4. Temporary Accumulation Area Emergency Equipment Inspection Records
Back to Top 6. Hazardous Waste ReportsUniversity Safety and Health Department shall file all the required hazardous waste reports to the proper regulatory agencies.Back to Top 6A. Biennial ReportDrexel University shall submit a Biennial report (EPA Form 8700-13A) to the Regional Administrator or state by March 1st of each even-numbered year. The report shall detail Drexel University’s activities during the previous year. The following information shall be included in the report:
Drexel University is not required due to its generator class, to submit a biennial report. However, the University Safety and Health Department will create the report and keep it on file for reference. Back to Top 6b. Exception Report6b1. Thirty-Five Day Limit
Back to Top 6b2. Forty-Five Day Limit
Back to Top 6C. Sampling ReportUniversity Safety and Health Department shall retain all records of any test results, waste analyses, or other determinations for a period of at least three years from the date that the waste was last sent to off-site TSDF.Back to Top 6D. Retention TimeThe periods or retention referred to in this section may be extended automatically during the course of any unresolved enforcement action regarding the regulated activity, or as requested by the EPA Regional Administrator.Back to Top 7. Printable Chemical Pick Up Request FormClick here for a printable PDF version of the Chemical Pick-Up Request FormBack to Top |
||||||||||||||||||||||