Part 100: Introduction

• 100.01 Purpose and Scope
• 100.10 Individual Responsibilities
• 100.20 EHS Personnel Responsibilities
• 100.30 Regulatory Background
• 100.40 University Facilities Located Outside of Moscow

100.01 Purpose and Scope

1. The University of Idaho is committed to providing a safe and healthy environment for all to work and learn. Current trends in federal and state environmental laws and regulations also reflect increasing concern by our society for protecting the environment through responsible hazardous materials disposal. A proactive hazardous materials and waste management program, incorporating federal and state regulations with University procedures and guidelines for the storage, transportation, handling and disposal of hazardous materials, will fill a genuine need for the University community and help facilitate the University's commitment to protecting the environment.
2. Specifically, guidelines and procedures are provided for the proper handling, storage, containment, accumulation and disposal of hazardous materials. Proactive hazardous materials management and waste minimization practices are also a large function of this policy. Proactive hazardous materials management and waste minimization practices attempt to decrease the generation of hazardous wastes and minimize problems associated with the collection, storage, and disposal processes thereby reducing costs and liabilities associated with a hazardous materials disposal program.

NOTE: Radioactive materials/wastes, infectious materials/wastes and asbestos are intentionally excluded from this policy. These materials are addressed in other University policies and procedures. Contact Environmental Health and Safety (EHS) to obtain policy, information and/or guidance for the management of materials/wastes not within the scope of this policy.

100.10 Individual Responsibilities

1. All University faculty, staff and students are responsible for complying with the guidelines and procedures of this policy. Individuals are responsible for properly identifying, characterizing, and preparing their materials for collection and disposal by Environmental Health and Safety (EHS) personnel. Specifically, individuals using hazardous materials must accurately identify and label all materials; accumulate and store materials safely; and request collection of the material by submitting electronic disposal requests to EHS. Every possible effort to minimize the quantity or toxicity of hazardous waste generated must be made by each individual generator by following the waste minimization guidelines provided in this policy. It is the responsibility of all supervisors and instructors to ensure that employees, students, guests, and visitors are aware of and follow the guidelines and procedures of this policy.
2. Hazardous materials are NEVER to be delivered (or sent through the campus mail) to Environmental Health and Safety or the Hazardous Materials Storage Building (HMSB). These materials will be returned to their points of origin and collected only after proper disposal procedures have been followed.

100.20 EHS Personnel Responsibilities

1. EHS personnel are responsible for classifying, collecting, transporting, and disposing of hazardous materials generated by University activities. Other responsibilities include: maintaining hazardous waste records, submitting hazardous waste reports, acting as a liaison with state and federal agencies, providing emergency response to chemical spills and incidents involving hazardous materials, recycling hazardous materials, and providing technical support and training for the University community. It is the responsibility of EHS personnel to confirm whether or not a discarded hazardous material is, or is not, a hazardous waste.

100.30 Regulatory Background

1. The Resource Conservation and Recovery Act (RCRA) of 1976 was passed by Congress to regulate the generation, storage, treatment, transportation, and disposal of hazardous waste in the United States. RCRA set the foundation for the Environmental Protection Agency (EPA), which has the power to promulgate and enforce regulations governing hazardous waste activities within RCRA's guidelines and amendments. EPA regulations can be found in the Code of Federal Regulations (CFR), Title 40. RCRA set a precedent in hazardous waste management by introducing the "cradle-to-grave" concept, which makes generators liable for the hazardous waste they generate from the time of generation, through transportation, and its ultimate disposal. RCRA was amended in 1980 by the Solid Waste Disposal Act, which provided for more stringent enforcement of regulations and steeper fines for violations concerning hazardous waste activities. In 1984, RCRA was again amended by the Hazardous and Solid Waste Act Amendments (HSWA), which initiated a program to restrict and ban the disposal of certain hazardous wastes in landfills, improve landfill quality, regulate underground storage tanks, tighten hazardous waste generator regulations, require thorough inspections of state and federal facilities, and provide specific requirements for the regulation of used oil. In 1995, EPA promulgated the universal waste program to promote the collection and recycling of certain widely generated hazardous wastes, known as “universal wastes.” Universal wastes are subject to special management provisions intended to ease the management burden and facilitate the recycling or proper treatment and disposal of such materials. Four types of waste are currently covered under the universal waste regulations: hazardous waste batteries, hazardous waste pesticides that are either recalled or collected in waste pesticide collection programs, hazardous waste mercury-containing equipment, and hazardous waste lamps.
2. The State of Idaho has received primacy from the EPA to regulate state hazardous waste activities. Primacy allows for a state to operate a hazardous waste program under the guidelines set forth by the EPA regulations but must be at least as strict as those provided by the EPA. Therefore, the University of Idaho follows the guidelines set forth by the EPA as enforced and overseen by the Idaho Department of Environmental Quality (DEQ).
3. The Department of Transportation (DOT), in accordance with 49 CFR and by an EPA/DOT Memorandum of Understanding, regulates the proper packaging and safe transport of all hazardous, infectious and radioactive materials (including hazardous and radioactive waste). DOT regulations instruct shippers how to package, segregate, mark, label, and manifest hazardous materials/wastes for transport in commerce. The University of Idaho must comply with all state and federal regulations, and with procedures set forth by the commercial treatment, storage and disposal facilities accepting our waste for disposal.

100.40 University Facilities Located Outside of Moscow

1. University facilities located outside of Moscow are responsible for following the guidelines and procedures of this policy. Facilities will submit online (web-based) disposal requests to Environmental Health and Safety (EHS). EHS personnel will coordinate the preparation, transportation and disposal of hazardous materials generated at locations outside of Moscow.