As identified by Brian Karnofsky, Environmental Resource Center, and modified to reflect University conditions.
10. Misclassifying non-hazardous waste as hazardous or misclassifying hazardous waste as non-hazardous. The former will waste your money and the latter can result in big fines. When in doubt, get it tested or get expert advice. Trace contaminants, such as mercury or chloroform in a parts-per-million range, can be a problem and cause a material to be regulated as a hazardous waste. Many companies have classified their major waste streams properly, but misclassify the minor ones that seem to slip through the cracks (and into the dumpster), such as shop towels (flammable or chlorinated solvents), filters, solder (lead or silver), adhesives (flammable), and cleaners (corrosive or solvent). The generator is responsible for identifying the chemical constituents of the waste, and whether that waste will be provided to Environmental Health and Safety for disposal. Based on the information provided, Environmental Health and Safety will advise appropriate management options and will classify the waste as hazardous or nonhazardous.
9. Accumulating hazardous waste too long at accumulation points. This applies primarily to the locations managed by Environmental Health and Safety, but also any locations managed by departments without our knowledge or consent. Because of various regulatory requirements (hazardous waste training, weekly inspection logs, contingency planning, and others), only Environmental Health and Safety should manage such accumulation areas. As a result, all wastes should be picked up from generator locations. For the main campus, a 90-day limit applies and begins when you first began accumulating the waste at your accumulation point (note #8 below regarding satellite accumulation points). The container must be dated when accumulation begins, which starts the 90-day clock. For areas such as the Veterinary School or Centennial Campus, a 180-day limit applies.
8. Accumulating too much waste at a satellite accumulation point (i.e., Agenerator location@, otherwise referred to in regulations as Aat or near the point of generation and under the control of the process operator@). At a satellite, you can accumulate up to 55 gallons without a time limit. Once you exceed 55 gallons, you've got three days to have the waste moved to the appropriate campus accumulation point (i.e., picked up by Environmental Health and Safety). Consider your safety, minimize volumes, and keep your wastes moving. The generator is responsible for ensuring wastes are reported to Environmental Health and Safety in a manner that minimizes the hazards in the work area and maintains volumes below 55 gallons.
7. Missing the mark. Hazardous wastes must be marked with either the words AHazardous Waste@ or the container contents at a satellite accumulation point (generator location), the more information the better. If reusing reagent bottles, make sure the manufacturer's label is defaced, the words AWaste@ or AHazardous Waste@ are marked, and any residues are compatible with the wastes being added. The generator is responsible for marking containers for their contents and defacing any inappropriate labels or markings. Environmental Health and Safety will ensure wastes are appropriately marked with the words AHazardous Waste@ and the accumulation point start date at an accumulation point. Environmental Health and Safety will ensure the EPA hazardous waste warning plus DOT required marks and labels are added before shipping waste off-site.
6. Not manifesting precious metals. If you have precious metals (notably silver) that you are managing under the 40 CFR 266 precious metals standards, don't forget to use a hazardous waste manifest when you ship them to a reclaimer. All recycling contracts or agreements should be reviewed by Environmental Health and Safety to ensure compliance with applicable regulations. Environmental Health and Safety is the only department authorized to sign hazardous waste manifests.
5. Old or missing contingency plan. The University is required to have a contingency plan that spells out what is done in the event of a hazardous waste-related spill, fire, or explosion. Specifically, plans must be available for the University as a whole, and address each accumulation area. The plan must identify not only emergency procedures, but also identify emergency coordinators and emergency equipment. Written agreements must be made with any outside organizations that would be called upon in the event of a hazardous waste incident. Environmental Health and Safety maintains contingency plans for the University as a whole and accumulation areas under its control. Much of the information included in contingency plans is dependent on Safety Plans that are required of all persons who use or store hazardous materials or engage in hazardous activities.
4. Using improper containers. The generator is responsible for accumulating waste in appropriate containers. Containers must be suitable for their contents, including appropriate closures. Liquids should be in screw-capped bottles, carboys, or drums. Solids may be in large-mouth jars, sturdy bags, boxes, or drums. Containers must be in good condition and compatible with their contents. Beverage containers, flasks, and containers with cork, rubber, or ground glass stoppers are not appropriate for waste. Environmental Health and Safety reserves the right to refuse acceptance of waste offered in inappropriate containers until such time that the waste can be properly packaged. Environmental Health and Safety will ensure containers received from generators are appropriately managed, and wastes are packaged for shipment in containers that meet DOT performance-oriented packaging standards.
3. Not keeping your training up to date. Persons working with hazardous materials should receive annual training that addresses storage, use, and disposal of hazardous materials, emergency procedures, and other safety topics specific to their workplace. Environmental Health and Safety will ensure its hazardous waste personnel meet annual hazardous waste training requirements, and maintain documentation for its personnel. The people that work at accumulation points (distinguished from generator locations) or permitted units must receive annual hazardous waste training. Personnel must be thoroughly familiar with waste handling and emergency procedures applicable to their job responsibilities. Keep records of your training for as long as the employees works in a covered job plus an additional three years.
2. Improperly filling out hazardous waste manifests. Hazardous waste manifests must be signed by a duly authorized representative of the University, i.e., Environmental Health and Safety.
1. Not closing containers. Keep containers of hazardous waste closed unless waste is being added or removed from the containers. Although empty bottles may be allowed to dry, it is not acceptable to minimize wastes by venting them in a fume hood, or using Asolar drying@ for solvent-soaked rags. Generators must ensure all containers in their work areas are kept closed.