- 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
- 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.
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.
- Maintain good housekeeping. Keep aisles clean and free from litter and
- 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.
Waste storage facilities that are large quantity generators must have and small
quantity generators should have a written Emergency Response Plan that addresses
- 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
- 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
- Provide an inventory of Personal Protective Equipment and other equipment
and tools for use in emergency situations.
Typical emergency equipment that would be included at a waste storage facility
- 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 should examine the waste storage area for:
- Container damage
- Rust and corrosion
- 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
- 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.
- 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
· 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
- 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.
- 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:
- 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
- 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
- Name and signature of instructor and date
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
- 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.
- Review processes and procedures for opportunities to minimize wastewater
- Use organic dishwashing solutions instead of chromic-sulfuric acid mixtures
when washing glassware if possible.
- 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
- 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