Part 500: Hazardous Waste Minimization Practices

• 500.01 General
• 500.10 Legal Requirements
• 500.20 Hazardous Waste Minimization Methods
• 500.30 Receiving Research Samples of Hazardous Materials

500.01 General

1. Reducing the quantity of hazardous waste generated by the University will not only help protect the environment, but will save money in hazardous materials disposal costs, minimize liability, and reduce regulatory requirements of the University. Hazardous waste minimization involves various strategies to reduce the consumption and/or toxicity of hazardous materials used by the University.

500.10 Legal Requirements

1. The Hazardous and Solid Waste Amendments to RCRA in 1984 mandates that all generators of hazardous waste have a hazardous waste minimization plan in action. Large quantity generators of hazardous waste are also required to demonstrate that they are making efforts to minimize the quantity or toxicity of hazardous waste generated at their facility. This policy serves as a formal hazardous waste minimization plan for the University of Idaho.

500.20 Hazardous Waste Minimization Methods

1. Source Reductions - Source reductions involve reducing the quantities of hazardous waste generated by substituting, reducing, and/or eliminating hazardous materials used in a process; or eliminating processes that generate hazardous waste.
1. Eliminating Processes Using Hazardous Materials - Hazardous waste reduction can be achieved by using computers, models and/or instrumentation to achieve the same results without generating hazardous waste (e.g., analytical combustion analysis eliminated Kjeldahl wet chemistry analyses for the determination of total nitrogen in plant samples).
2. Chemical Substitution - Every attempt should be made to find substitutions for hazardous materials in a process to render its waste as nonhazardous (e.g., substituting copper sulfate for mercuric oxide in Kjeldahl analyses making neutralization and waste disposal to the sanitary sewer system possible). Contact EHS personnel for assistance in chemical substitution.
   1. Mercury Thermometers - Whenever possible, mercury thermometers should be replaced with alcohol or other types of thermometers. Extra care should be taken to avoid breaking mercury thermometers and other instruments using mercury.
3. Quantity Reduction - Chemical processes (which cannot be eliminated, etc., or in which chemical substitution is not a viable solution to minimize hazardous waste generation) should be scaled down to reduce quantities of materials used and wastes produced. This practice conserves chemicals along with minimizing the quantity of hazardous waste generated.
2. Recycling - Many solvents (e.g., chloroform, hexanes, and methanol) can be recycled. Every attempt should be made to recycle these solvents, especially if large volumes are used. CAUTION: DISTILLING SOLVENTS CAN BE DANGEROUS. Consult EHS before attempting any solvent recycling. Metallic (liquid) mercury can also be recycled. Solids are more difficult to recycle, but all efforts should be made to recycle them.
3. Chemical Surplusing - Surplusing discarded chemical reagents, many which have not been opened, serves to reduce duplicate purchase and disposal of chemicals. The redistribution of surplus chemicals to teaching, service and research labs would dramatically reduce hazardous waste generation. EHS will periodically circulate a list of surplused chemicals to departments and interested individuals. Surplused chemicals can be claimed on a first come, first serve basis at no cost. Interested parties should contact EHS for the availability of surplus chemicals.
4. Hazardous Materials Acquisition - Purchase hazardous materials in small quantities to eliminate the disposal of large quantities of outdated, unused materials later. If a large quantity of a material is purchased to save money, seek others interested in the same material for a joint purchase. This method of waste reduction especially applies to readily degradable, peroxidizable, hydrolyzable, hygroscopic, reactive and highly toxic materials.
5. Spill and Accident Prevention - Every effort should be made to prevent chemical spills and accidents. Besides the obvious safety considerations, spills increase waste generation and disposal costs. One spill can more than double the amount of material needing to be disposed of as a hazardous waste for a given chemical.
6. Neutralization - Many wastes are classified as hazardous waste only because they meet the characteristic criteria of corrosivity (i.e., the pH is 2 or 12.5). If corrosive wastes do not meet any other characteristic criteria and do not contain any other hazardous constituents, such as heavy metals, pesticides, or any other constituents that would render them hazardous waste, then these wastes can be neutralized (i.e., to a pH between 5.5 and 9) and discarded to the sanitary sewer system as normal waste. If there is any doubt as to the hazardous waste status of a neutralized discarded solution, call EHS for further assistance.
   
   NOTE: Neutralization is NOT a true form of waste minimization but pollution prevention. Wastes that have been neutralized and discarded to the sanitary sewer system must be reported to EHS for record keeping and reporting purposes.
7. Hazardous Materials Labeling - Properly labeling hazardous materials reduces the quantity of hazardous waste generated by eliminating the generation of unknowns. Materials that cannot be identified are not useful to laboratory personnel who lack the time or means to identify them. These materials are discarded and increase the quantity of hazardous waste generated.
   
   NOTE: The generation of unknown materials suggests a need to improve laboratory and hazardous materials management. Investigate lab procedures to determine why unknowns are being generated and find solutions to any problems that surface.

500.30 Receiving Research Samples of Hazardous Materials

1. Hazardous materials (including but not limited to: pesticides, ores and contaminated soil samples, compressed gases, fuels and experimental chemicals) received from industry, other universities, or any other second party for purposes of research, testing, etc., should only be accepted under the condition that the party from which they originated accepts back any unused material.