Re-using and
repurposing a container is an acceptable practice provided the container is of
an appropriate material and configuration and properly prepared for it new
contents. This preparation includes correct labeling.
Discussion:
A worker was
refilling squeeze bottles of methanol for use in a laboratory. While pouring
from a manufacturer’s large amber bottle expected to contain pure methanol, the
employee immediately noticed that the contents were a bright fluorescent pink
(figure 1), and did not match the characteristics of methanol.
A review of the
bottle providing this liquid showed some faint scratch marks over the original
product labeling (figure 2), but nothing definitive was added to indicate what
the new contents were.
Analysis:
A review of the
source bottle indicated that it originated in a nearby facility, and
individuals relocated this bottle, along with several unopened bottles, in an
attempt to reuse chemicals when the directorate initiated a lab cleanout
initiative.
Further review of
past operations in the original building indicated that the pink color was a
result of adding a laser dye to a solvent. The attempted relabeling of the
amber (source) bottle was inadequate to communicate the contents to the new
owner(s).
Nothing indicated
the presence of a laser dye, some of which are toxic or even carcinogenic.
Furthermore, the relabeling would probably be insufficient for use within the
lab by knowledgeable individuals.
//--------------------------------------//
Chemical Waste Management
Chemical waste may include:
- old and/or expired chemicals,
- chemical waste solutions, or
- debris contaminated with chemicals
UVM is committed to
managing its chemical waste in a way that prevents release to the environment.
This means that sink disposal of hazardous
chemicals at UVM must be pre-approved.
Chemical liquids or
solutions disposed of down a UVM drain go directly to Burlington's wastewater
treatment facility and eventually discharged into Lake Champlain. To protect
this area resource, laboratory personnel are prohibited from disposing of the following materials down any UVM drain.
Sink or drain disposal of any chemical
solutions must be pre-approved by Risk Management & Safety by submitting
this online Sink Disposal Request Form.
If you are generating
a waste solution that you believe can go down a lab drain but it is NOT listed
on the Materials Allowed for Disposal, you
must submit an online Sink Disposal Request form. Please be sure
to indicate 100% of the constituents in the solution, even if
the solvent is water.
Per the Environmental
Protection Agency (EPA) and Burlington Public Works Department, laboratory personnel are PROHIBITED from disposing of the
following materials down any UVM drain:
- Flammable Liquids (flash point equal to or less than 140 deg F), reactive or explosive materials;
- Liquids having a pH equal to or less than 5.0, or greater than or equal to 9.5 or other corrosive property capable of causing damage to wastewater facilities;
- Highly viscous materials (e.g. oils) capable of causing an obstruction in the wastewater system;
- Radioactive materials;
- Materials that have or create a strong odor (e.g: hydrogen sulfide, carbon disulfide, ammonia, trichloroethylene, sulfur dioxide, formaldehyde, chlorine, bromine or pyridine);
- Wastewater capable of significantly raising the temperature of the system;
- Grease or oils according to the following
- petroleum > 15 mg/L,
- animal or vegetable > 100 mg/L,
- non-emulsified or "floatable" oils or grease; or
- Pharmaceuticals or endocrine disruptors.
It is acceptable to
discharge non-hazardous aqueous salt and sugar solutions down the drain, but
please err on the side of caution. If you have specific questions about
whether a solution is suitable for sink disposal, email safety@uvm.edu before you dispose of it down
any UVM drain.
Collect
solvents used to clean glassware
Solvents used to
rinse clean glassware (acetone, ethanol, Nochromix, etc) are required to be
collected as hazardous waste and disposed of through UVM's waste disposal
procedures.
Disposal
via evaporation is prohibited
Evaporation of
hazardous materials in a chemical fume hood for the purpose of disposal is
prohibited.
Fume hoods are used
to control exposure to vapors during experimental processes and may increase
the evaporation rate of some of the chemicals being used. To minimize the
potential for air pollution as a result of fume hood use:
- Close caps tightly when not in use,
- Never store chemicals, including wastes, in the fume hood. Clutter and extra materials stored on the fume hood work surface prevents proper movement of airflow and can cause laboratory accidents.
Container
Material
Choose the proper
waste container. The container material, type of cap and size of the container matters. Take a moment to consider the
following:
- Are the waste chemicals compatible with the container material?
- Are the waste chemicals that are going to be mixed together compatible (will not react with each other)?
- Have you checked with Safety staff to make sure that the waste you are combining can be collected together in one waste container and easily disposed?
- Should 2 different waste containers be used instead for the types of waste streams being generated?
- Is the waste required to be collected in a specific size or type of container (e.g. with a vented cap, a 1-gal vs. a 5-gal waste container)?
Email safety staff if
you are unsure about how to collect waste in your area.
Use common sense. If hydrochloric acid was originally
shipped from a distributor in a glass container (or a glass container coated
with plastic), a glass container (or a glass container coated with plastic) may
be the safest choice in which to store a waste hydrochloric acid solution.
30% hydrogen peroxide
solution is shipped from a distributor in a container with a vented cap.
Be sure to purchase and store waste solutions of this material at varying
concentrations in a pressure-relieving container with a vented cap.
|
Improperly choosing a waste container can increase the risk of the
waste container degrading, leaking, or building up unnecessary
pressure, leading to a potential lab injury.
|
Do's and Don'ts of Waste Container
Choices
- Chemical waste containers should be leak-proof.
- Never use empty household or food-grade containers (e.g.plastic milk jugs or juice containers).
- Never use open beakers to collect waste.
- Waste containers should be free of contamination.
- Waste containers must have a screw-top cap that fits. No snap-on caps or glass stoppers.
- Caps must be securely closed when not in use.
- Never store waste chemicals that are corrosive in a metal container. Never use a metal can as a secondary containment bin for corrosive chemicals.
Re-use
of stock chemical containers to collect waste
If you re-use a stock chemical
container to collect waste, be sure that 1) the container has been triple
rinsed, 2) chemicals being added are compatible with chemicals that the
container originally, and 3) place a yellow laboratory waste accumulation
container label on the container once a drop of waste is added.
Clearly label any
reused containers as "EMPTY" until you start using them.
|
Never rinse and re-use an acutely toxic or reactive chemical
container
as a
waste container.
|
Any empty chemical container that held acutely toxic or reactive material, such
as sodium azide, osmium tetroxide or cyanides, is required to be tagged
for waste disposal (see list of acutely hazardous chemicals).
Double labeling causes confusion!
Never place an orange
or green label AND a lab waste accumulation label on a container. Use one or
the other. Consult with Safety staff if you need assistance
with chemical or waste labeling.
Think about how much
waste you will generate within a specific time frame.
For example, if you
estimate that a lab procedure you are conducting will only generate 1-gallon of
a specific waste stream over a one year period of time, then a 1-gallon waste
container may be too large of a choice because lab waste is required to
be picked up for disposal from UVM labs every six (6) months. On the
other hand, if you estimate that a procedure will generate 500 mls of a specific
waste stream in one week and you have hundreds of samples to run, perhaps a
larger waste container makes sense so you only have to have two waste pickups
per year.
Safety staff are
always available to help make these kinds of waste descisions.
UVM
Chemsource Sells Some Waste Containers
UVM Chemsource only sells 1-gallon amber
glass waste containers and 5-gallon (20 liters) plastic containers for liquid
or solid waste collection.
Waste containers cannot be returned to users. 5-gal
waste container customers pay for the initial delivery of a 5-gallon waste
container to help cover our cost. From then on, 5-gallon waste containers are
swapped out at no additional charge.
Labs that need to
collect lab waste in volumes larger than 5 gallons (20-liters) should contact Safety staff before
doing so.
If your lab needs
smaller waste containers, please contact a contracted UVM preferred vendor, such
a VWR or Thermo-Fischer Scientific, to purchase the appropriate size waste
containers for your needs.
UVM's laboratory
safety program requires that laboratory waste that will accumulate over a
period of time be labeled with a Laboratory Waste Accumulation Container
label. This is a requirement of UVM's Laboratory Safety Program and
is clearly noted on the monthly Laboratory Self-Inspection Checklist.
Clearly and
completely filled out laboratory waste accumulation labels ensure
that laboratory staff, Safety staff, custodians, Physical Plant personnel and
emergency responders can identify containers of waste and any chemical hazards
easily.
Waste labeling at UVM
is a two-part procedure:
- Fill out and place a yellow Laboratory Waste Accumulation Container label on any container that is being used to collect waste over time. This label must be filled out and placed on the waste container as soon as one drop of liquid (or solid contaminated debris) is added to the container.
- Once a waste container is full OR 6-months from the waste accumulation start date, it is required that a white Laboratory Waste Tag be filled out and entered online. Be sure to hang the tag on the waste container itself. Entering the lab waste tag online notifies UVM lab waste technicians that there is a waste container(s) ready for pickup and proper disposal.
If you are not
following this procedure, it may cause an accident and your lab and waste are
out of compliance with UVM's Laboratory Safety Program. Please review the details about
this procedure below. Waste accumulation labels and laboratory waste tags are
available from several locations on campus.
Laboratory
Waste Accumulation Container label
The Laboratory Waste
Accumulation Container label must be filled out completely. As part of the
required UVM monthly laboratory self-inspection, visibly inspect waste
container labels.
If the information
written on a waste label is unreadable (has faded over time or chemicals have
dripped on to the label), replace it! A properly filled out laboratory
waste accumulation label includes:
- Full English names to list all of the contents,
- The date that the waste began being collected
- Circles around the appropriate hazard(s) of the contents
Waste container labels must be visible and readable at all
times.
Once a waste
container is full OR the date on the container is approaching a 6-month time
frame, fill out a white muti-part Laboratory
Waste Tag.
List all chemical contents in English (no formulas) and estimated
percentages.
Waste tags are
uniquely numbered. NEVER MAKE UP A TAG NUMBER. After manually filling out
a waste tag,
- Enter the waste tag online,
- Attach the tag to the waste container with tape or the string, and
- Place the containers into a properly labeled storage cabinet with other compatible chemicals. (Do not store waste in a chemical fume hood unless odors are being emitted).
Waste technicians
pick up laboratory waste for disposal 2x per week on main campus. Waste from
off-campus buildings is picked up on the 2nd and 4th Thursday of each month.
Off campus locations include Colchester Research Facility, Rubenstein
Laboratories, Proctor Maple Research Facility, UVM Horticulture Education &
Research Center, etc.
Waste accumulation container labels and
laboratory waste tags are available from several locations on campus or
by contacting safety@uvm.edu.
It is recommended
that labs review all of their chemicals in storage and conduct a cleanout of
old and unused chemicals once per year.
If a lab has more
than 15 or 20 waste containers ready for disposal at one time, please contact
Safety staff to
set up a time for us to meet with you so we can assist with the proper
segregation, tagging and disposal of the waste. In these cases, EACH
container need not be tagged individually. Please meet with your
Laboratory Safety Coordinator before conducting any chemical cleanout.
Lab
Decomissioning
When renovating,
relocating or closing a lab at UVM, it is the responsibility of the
Principal Investigator to make sure that the lab is decommissioned
properly. A Laboratory Clearance Checklist must be completed. Please review
UVM's Lab Decommissioning Procedure.
Key
Requirements:
- Waste containers must be securely closed when not in use.
- All liquid laboratory wastes must be stored in secondary containment in case the primary container fails.
- Never leave a funnel in a waste container unless the funnel itself is designed to be a secure lid.
- Avoid or minimize the storage of waste materials inside a chemical fume hood to preserve space for working safely and to allow for proper airflow within the fume hood.
- Flammable waste should be stored within a flammable safety cabinet and must count towards the fire code storage limits for the lab.
- Do not store waste containers on the floor. In some cases, larger, non-glass containers of waste may be stored on the floor inside of a secondary containment bin. Never block aisles and/or egress and do not create a tripping hazard.
Chemical
waste storage cabinets
Store chemical waste by
hazard with other compatible chemicals in a properly labeled chemical
storage cabinet. Never store waste in a chemical fume hood unless odors are
being emitted (e.g. phenol, chloroform).
Cabinets used for
multiple waste containers that are labeled "Chemical Waste
Storage" must have smaller secondary containment bins inside to separate
incompatible chemicals. Please see the Chemical Storage Guide.
Prevent
leaks
Leave 2 inches of
empty space at the top of waste containers - never overfill.
Waste containers must
be inspected at least monthly, per the self inspection checklist, to assure
that no degradation of the container or its contents has occurred.
A leaking container
must be either packed in a secondary container, or its contents transferred to
another container.
Unknown
Chemicals
"Unknowns"
are chemicals that are found in the lab either with an illegible label or no
label at all. We cannot guess at what these wastes are. There is a strict and
expensive protocol that Safety staff are required to follow in order to manage
this type of waste. Please inspect your chemicals monthly as required by the
Lab Safety Program to eliminate or minimize unknown chemicals in your lab.
Chemically-contaminated
sharps
Sharps contaminated
with hazardous chemicals must be collected in a puncture proof container such
as a sharps box and labeled clearly with a yellow waste accumulation container label. Be sure to list
all of the chemicals that have been in contact with the sharps, circle the
hazard(s), and write the date in which accumulation of the sharps began. Fill
out and enter a waste tag online when the sharps container is 2/3 full; do not overfill.
Do not place chemically-contaminated sharps in a biohazard box.
Containers
of acutely toxic or reactive chemicals
Containers of acutely toxic or reactive chemicals must be securely closed
and tagged for hazardous waste disposal. Never re-use these containers to
collect waste.
Contaminated
debris: broken glassware, gloves, pipettes, etc.
Debris that is
contaminated with hazardous chemicals should be collected in a clear bag or in
a cardboard box lined with a clear plastic bag and tagged as chemical waste for
disposal. Never use a red biohazard bag to collect chemically contaminated
glassware or debris.
Glassware
contaminated with infectious material should be placed in a puncture-proof
container and then placed in a biohazard box. For information about
biological waste please follow this link to the biowaste management page.
Glassware contaminated
with radioactive contaminants should be decontaminated and Radiation Safety staff should
be notified. For information pertaining to radioactive waste management
follow this link to the Radiation Safety Office (RSO)
website.
Mixed
waste
Waste that is
contaminated with both biological material and chemicals should be tagged as a
laboratory waste. Provide specific information on the tag or in the comments box
on the online tag entry page.
Used oil, and
oil-contaminated rags or debris, is regulated in Vermont. This means used oil
and oil-contaminated debris must be collected, labeled and disposed of as
hazardous waste. Used oil may include:
- vehicle crankcase oils, transmission fluids and power steering fluids;
- hydraulic, compressor and straight cutting oils;
- tramp oil and oil drained from evaporators.
The best container
for collecting rags contaminated with used oils (motor oil, linseed oil) or
solvents (thinners, paints) is a metal can with a self-closing lid.
A self-closing lid on the waste collection container can prevent these
types of rags from spontaneous combustion or a spark.
Chemical spills of
2-liters or less can be cleaned up by lab personnel using the Chemical Spill
Kit that is provided by Risk Management & Safety to every lab on
campus.
Debris, such as
contaminated gloves, cardboard, bench pads, glassware, etc should be collected
in a CLEAR plastic bag and tagged immediately with a laboratory
waste tag. Safety staff are always available to consult with lab
personnel about a spill or to assist or perform the spill cleanup itself. Page
Safety staff by calling UVM Service Operations at 656-2560, press 1 to speak to
dispatcher.
Please refer to the UVM Recycling Guide for
details about how these and other items are collected on campus.
Assorted batteries are collected throughout campus in
brown battery buckets or in E-waste (electronic waste) containers scattered
around campus by UVM Recycling. Enter a lab waste tag online when your brown
battery bucket is full; the description on the tag can be "assorted
batteries"; please estimate the amount in "lbs". Larger lead
acid batteries should also be tagged for waste disposal.
Burned out
fluorescent lights, compact lightbulbs,
UV lightbulbs, etc are considered Universal Waste in the State of Vermont and
should be removed from the fixture and carefully placed back inside of the cardboard
box that they came in to prevent breakage. Email safety@uvm.edu or call 656-5408 for intact
lightbulb pickup.
Broken lightbulbs are considered hazardous waste and
should be collected in a clear bag that can be sealed inside of a cardboard
box. Fill out a lab waste tag and enter tag online for pickup.
Mercury Thermometers can be swapped out by Safety staff for
FREE. Be sure to check that new lab equipment does not have a mercury
thermometer inside. Please specify whether you would like a partial or
total thermometer.
Old laboratory
equipment needs to be checked
out by UVM ITS to have hazardous components removed
before the equipment can be safely disposed of as scrap metal or E-waste. Labs
are required to use the Surplus Disposal Form that
is required before disposing of old lab equipment.