Container Management

• Wastes should be identified prior to arriving at the Waste Storage area. Process knowledge of the waste is best made upstream at the point where the waste is generated. Characterizing the wastes at the point of generation will save money on laboratory testing and is often more accurate.
• Waste containers storing unknown or uncharacterized waste should be stored separately until they are characterized and labeled.
• Maintain separate waste containers for compatible waste streams, i.e. acid, bases, oxidizers, organic solvents, radioactive waste, etc.
• Separate containers with incompatible wastes with a berm, tub or other barrier. Store containers in an area that has secondary containment large enough to contain the largest foreseeable release of waste material.
• Log chemicals and quantities added to waste containers as chemicals are added.
• Train personnel on safe procedures to transfer chemicals to waste containers.
• Do not store waste containers where they have the potential to freeze or are exposed to high heat.
• Waste containers should be in good condition.
• Clearly mark the area as a hazardous waste storage area.
• Make sure waste containers are compatible with the waste type they are expected to contain.
• Keep an adequate spill control kit nearby. Kit should be large enough to control the release of the largest type of container in the storage area. Clean up spills quickly.
• When handling waste containers use mechanical aids such as drum lifts, drum hand trucks, and drum dollies. Do not roll drums on their side or edge.
• Make sure container caps are secure.
• Train personnel on spill clean up procedures.
• Maintain good general housekeeping. Keep aisles, and walkways clear.
• Equip waste transport vehicles with spill containment equipment.

Employee Training

Training employees on proper procedures to reduce your school’s impact on the environment is a best practice and in some cases required by regulations. Employee training may include the following:

• Spill response training for personnel who handle hazardous material,
• Fork lift training,
• Storm water pollution prevention education,
• Right-to-know awareness training,
• Use of personal protective equipment,
• Hazardous materials management, and
• Contingency plan implementation for large quantity generators.

Drains

• Maintain good housekeeping. Keep aisles clean and free from litter and debris.
• Store containers in secondary containment to prevent uncontrolled spills.
• Prevent and respond to spills quickly. Do not let material enter the floor drains, the sanitary or storm water collection systems. Keep adequate spill response kits and equipment available to respond to spills of oil, fuel, grease and train responders in proper response procedures.
• Clean up any spill promptly.
• Keep rags, mops, absorbents, and other cleanup supplies readily accessible to all work areas.
• Eliminate floor drains in new construction and cover existing drains.
• Maintain clean equipment by eliminating excessive amounts of external oil and grease buildup. Use water-based cleaning agents or non-chlorinated solvents to clean equipment.

Emergency Planning

Waste storage facilities that are large quantity generators must have and small quantity generators should have a written Emergency Response Plan that addresses the following:

• Identification of potential emergencies
• Roles and responsibilities of management, employees and coordination of roles with potential offsite responders such as police and fire departments or local hazardous materials response teams. Identify facility emergency coordinators and means of contact.
• Description of how emergencies might be recognized and communicated within the facility.
• Identify evacuation routes, safe rally areas and procedures for accounting for personnel, including visitors.
• Describe procedures for activating facility alarms and notifying local emergency response services.
• Describe procedures for personnel to obtain emergency medical treatment and first aid.
• Describe amount and types of training in-house personnel receive to be able to respond to emergencies consistent with the roles and responsibilities identified.
• Provide an inventory of Personal Protective Equipment and other equipment and tools for use in emergency situations.

Emergency Equipment

Typical emergency equipment that would be included at a waste storage facility should include:

• Emergency eyewash stations and showers installed in areas where there is the potential to come into contact with hazardous chemicals. Eyewash stations and showers should have unobstructed access from any point in the area within 10 seconds and be on the same level as the potential hazard.
• Fire extinguishers easily accessible of size and type to be effective against an anticipated fire.
• Fire Blankets
• Fire suppression systems.
• Communications systems including telephones, radios, and alarms.
• Emergency personal protective equipment including SCBA’s, disposable coveralls, gloves, eye protection, short term escape respirators.
• Spill control equipment including, spill pillows, absorbent pads, drum berms, drain plugs, hand pumps, neutralization solutions.
• Air monitoring instrumentation, either portable or fixed systems if needed.
• First aid kit, including burn kit.
• Periodic inspection of equipment to ensure its effectiveness and availability.
• Provide personnel adequate hands-on training in use of emergency equipment to be able to effectively use equipment and respond to emergencies.
• All equipment must be tested and maintained as necessary to ensure that it will function properly in time of emergency.

In addition to the above planning and equipment, drills should be conducted periodically to assess the facilities capabilities to respond to emergencies and identify areas of response weakness. Drills and responses to emergencies should be subject to a follow up critique to identify areas of weakness and corrective actions to be taken.

Inspections

Inspections should examine the waste storage area for:

• Spills
• Leaks
• Container damage
• Rust and corrosion
• Overflows
• Condition of secondary containment
• Operation of monitoring equipment
• Readiness of emergency response PPE and equipment
• Container or tank levels
• Container caps in place and sealed when material in not being added or transferred
• Incompatible materials stored near on another
• Signage is present and legible.

Inspections should be documented with specific findings, recommended corrective actions and assigned responsibilities and time frames for completion of corrective actions. Follow up inspections should include determination of implementation of corrective actions.

Manifests

• Hazardous waste manifests are legal documents and it is recommended that a limited number of personnel be authorized to sign manifests.
• Personnel authorized to sign manifests must be trained in the school’s hazardous waste management, administrative and record keeping procedures.
• Prior to signing the manifest, the authorized individual should verify that:
  · Containers are properly labeled.
  · Correct types and quantities of wastes are listed on the manifest.
  · Containers are in good condition and appropriate for the type of waste.
• Only direct full time employees of the school or university should be authorized to sign hazardous waste manifests. Students, contractors and part-time employees should not sign manifests.

Training

• Development of training courses should be systematic and include the development of a course lesson plan. Course development should include:
  - An assessment of training needs
  - Learning objectives
  - Structured course design and presentation
  - Development of evaluation methods
  - Methods to determine successful completion of the course
• Instructional materials should assist in the educational presentation and be appropriate for the intended student population.
• The physical training environment should be:
  - Safe
  - Comfortable
  - Free from distractions
• Trainers should have adequate technical knowledge to teach the course content, and be familiar with training, delivery methods and adult learning.
• Students should have the opportunity to ask questions about material presented.
• Training for physical activities and skills such as drum handling should include a hands-on skills development and assessment segment.
• Students should be evaluated to assess their level of understanding, skill development and abilities.
• Trainers should be evaluated to assess subject matter knowledge, and presentation skills to assist in course improvement.
• Training records should be readily retrievable and include
  - Date, location and duration of the course
  - Title and description of course content
  - Names of instructors
  - Names of attendees
• When training certificates are issued to attendees they should include the following:
  - Name of the student
  - Title of the course
  - Date and duration of class
  - Statement of successful completion
  - Reference to regulatory citation if training is intended to meet specific regulatory requirement.
  - Name and signature of instructor and date

Waste Reduction

Toxic use reduction and waste minimization activities apply not only to wastes but include the management of releases to air, water, and generation of solid and non-hazardous waste. While specific practices are not addressed by regulation some best practices for a number of environmental areas related to pollution prevention at schools and universities are described below.

Even when not required by environmental regulations, the following best practices are recommended. Although some of the recommended best practices listed below do not apply to activities at a waste storage facility, they are presented here to reinforce that waste reduction is most effective when applied at the point of generation.

Air Quality

• Implement microscale chemistry techniques where possible.
• Make sure the caps and container lids on volatile chemicals are secure.
• Do not store chemicals in laboratory fume hoods.
• Substitute less toxic or less volatile chemicals in processes where possible.

Wastewater

• Review processes and procedures for opportunities to minimize wastewater generation.
• Use organic dishwashing solutions instead of chromic-sulfuric acid mixtures when washing glassware if possible.

Hazardous Waste

• Minimize the amount of chemicals stored in the lab to the minimum quantities needed to avoid having to dispose of chemicals that expire or deteriorate during storage.
• Develop an inventory of chemicals no longer needed in your lab that could possibly be used by another.
• Where possible substitute less toxic chemicals where toxic chemicals are used in a procedure or process.
• Evaluate ways to reduce the amount of toxic chemicals used in lab procedures.
• Explore methods to re-use or recycle spent solvents, unused paints, cleaners, and other chemicals.
• Avoid contaminating non-hazardous waste streams with hazardous, radioactive or biohazardous material.

Radioactive and Mixed Waste

• Use low volume liquid scintillation vials.
• Use radionuclides with short half lives that can be allowed to decay in storage prior to disposal.

Non-Hazardous and Special Waste

• Use two sided copying
• Make procedures, MSDSs, manuals and other documents available electronically
• Use e-mail instead of hard copies
• Share trade periodicals
• Use reusable containers
• Use rechargeable batteries