Part 300: "Non-Regulated," Universal Wastes, and Miscellaneous Hazardous Materials

• 300.01 "Non-regulated" Discarded Chemicals
• 300.10 Universal Wastes
• 300.12 Cathode Ray Tubes (CRTs)
• 300.13 Electronic Equipment
• 300.15 Spent Lead-Acid Batteries
• 300.20 Used Oil
• 300.25 Antifreeze
• 300.30 Unknown Materials
• 300.40 Compressed Gas Cylinders (e.g. Lecture Bottles)
• 300.45 Aerosol Cans
• 300.50 Controlled Substances
• 300.60 Photography and Darkroom Chemicals
• 300.70 Hazardous Household and Commercial Commodities

<300.01 "Non-regulated" Discarded Chemicals

1. Certain materials failing to meet EPA criteria of a characteristic or listed hazardous waste may still present a hazard to people and the environment. These materials may be carcinogenic or exhibit some degree of toxicity. One common example is ethidium bromide. Unless otherwise directed by EHS, all chemicals must be collected and disposed of by EHS personnel.

300.10 Universal Wastes

1. Universal wastes are types of hazardous wastes that are common to all industry groups and facilities. The Environmental Protection Agency established a program to allow less stringent requirements for managing these types of waste, with the two primary goals of encouraging recycling and reducing illegal disposal of universal waste as municipal waste. In Idaho, “universal wastes” include the following hazardous wastes:
   1. Lamps that exhibit a characteristic of a hazardous waste. For example, fluorescent light tubes may contain sufficient mercury to meet the toxicity characteristic [see 200.10 (d)]. Included in this category are fluorescent tubes, compact fluorescent lights (CFLs), UV lamps, high intensity discharge (HID) lamps, neon lights, mercury vapor lamps, high pressure sodium (HPS) lamps, and metal halide lamps.
      1. Environmentally-friendly or TCLP compliant lamps are manufactured so that they do not meet the definition of a hazardous waste, and therefore, are not a universal waste. Lamps listed below may be managed as non-hazardous and disposed in the normal trash in accordance with University of Idaho procedure (see Part 400).
         
         TCLP Compliant Lamps by Manufacturer and Designation
         • General Electric, Ecolux® or ECO
         • Philips, Alto and Alto II™
         • Sylvania Osram), Ecologic or ECO
         
         Incandescent bulbs are NOT hazardous waste and should be disposed in the normal trash.
   2. Batteries that exhibit a characteristic of hazardous waste. Some examples include Ni-Cad, nickel metal hydride, lithium, lithium ion (e.g. laptop computer batteries), mercuric oxide, and silver oxide.
      1. Lead-acid batteries, such as vehicle batteries and sealed lead-acid batteries in emergency lights and some uninterruptable power supplies, are exempt from most of the hazardous waste regulations provided they are sent for regeneration AND are not leaking. Also see 300.15 below.
      2. Alkaline batteries are NOT hazardous wastes and should be disposed in the normal trash.
   3. Mercury-containing equipment (MCE) are devices that contain elemental mercury and include such items as:
      1. Thermometers,
      2. Thermostats,
      3. Manometers.
   4. Pesticides that would meet the definition of hazardous wastes and are either:
      1. Recalled pesticides, or
      2. Stocks of unused pesticides that are gathered and managed as part of a waste pesticide collection program.
2. All universal waste must be managed in a way that prevents leakage, spillage, or other damage.
3. All universal waste must be dated when discarded (i.e. when the decision is made to dispose of the item.
4. All universal waste must be properly labeled with the wording “Universal Waste – Lamps”, “Universal Waste – Batteries”, “Universal Waste – Mercury Containing Equipment”, or “Universal Waste – Pesticides”, as appropriate.
5. Universal waste may be accumulated for no longer than one year.
6. When universal wastes are shipped off-campus, they must be sent to another universal waste handler or a destination facility (a facility that treats, disposes, or recycles universal waste).
7. Refer to 400.80 for specific universal waste disposal procedures.

300.12 Cathode Ray Tubes (CRTs)

1. Cathode Ray Tubes (CRTs) are not universal wastes. Under EPA regulations, CRT is defined as a vacuum tube, composed primarily of glass, which is the visual or video display component of an electronic device. A used, intact CRT means a CRT whose vacuum has not been released. A used, broken CRT means glass removed from its housing or casing whose vacuum has been released.
2. Used, intact CRTs, if recycled, are not otherwise regulated for disposal.
3. Used, broken CRTs, if recycled, must meet the following requirements.
   1. They must be stored in a building with a roof, floor and walls or placed in a container that is constructed, filled and closed to minimize releases of CRT glass to the environment.
   2. The container must be labeled “Used cathode ray tube(s) – contains leaded glass” and “Do not mix with other glass materials.”
   3. They must be transported in a container that meets the above requirements
4. If used CRTs, either intact or broken are NOT recycled, a determination must be made to see if the CRT meets the definition of a hazardous waste.
5. Recycle all CRTs through the Facilities Recycling/Surplus/Solid Waste Division.

300.13 Electronic Equipment

1. Electronic Waste (E-Waste) includes such items as non-CRT video display terminals, computers, printers, copiers, scanners, laboratory equipment, and printed circuit boards.
2. Electronic wastes are not universal wastes.
3. If E-Waste is sent to a recycler, no regulatory requirements attach to the generator of the waste.
4. Whole circuit boards are not regulated if sent for reclamation.
5. All E-Waste must be recycled through the Facilities Recycling/Surplus/Solid Waste Division.

300.15 Spent Lead-Acid Batteries

1. Lead-acid batteries include automotive, marine, and lawn equipment batteries, as well as other sources. Sealed lead-acid batteries are commonly found in emergency lighting, fire and security alarm panels, and certain uninterruptible power supplies (UPSs).
2. To the extent possible, the University of Idaho manages spent lead-acid batteries as hazardous waste exempt from most RCRA management requirements under 40 CFR Part 266, Subpart G. If the batteries are sent for regeneration (i.e. recharging or replacement of the electrolyte), the only requirement is that a hazardous waste determination is made. If the batteries are sent for reclamation (e.g. breaking, cracking, smelting to recover metal values), a one-time Land Disposal Restriction (LDR) notification must be completed.
3. Leaking spent lead-acid batteries must be managed as hazardous waste, subject to all of the regulatory requirements.
4. Refer to 400.70 for specific lead-acid battery disposal procedures.

300.20 Used Oil

1. Used oil is defined by the EPA as any oil that has been refined from crude oil, or any synthetic oil, that has been used and as a result of such use is contaminated by physical or chemical impurities. Used oil is regulated by the EPA but is not considered hazardous waste, unless it is mixed with a listed hazardous waste. Used oil is managed by EHS personnel and is subject to this policy. Please see 400.60 - Used Oil Disposal Procedures.

300.25 Antifreeze

1. Given the physical properties of ethylene glycol, antifreeze is typically not ignitable, corrosive, or reactive, nor does it contain one of the 40 toxicity characteristic constituents. It is not a P-listed or U-listed waste. Consequently, unused antifreeze is probably not a hazardous waste. If it cannot be reused, dispose the antifreeze through EHS.
2. On the other hand, used antifreeze may be a hazardous waste due to lead or other heavy metal content, picked up from the radiator. When drained from radiators, antifreeze may be commingled in a single container, such as a 30-gallon drum, before shipping to a recycler.
3. Keep used antifreeze separated by type (e.g. ethylene glycol and propylene glycol). DO NOT mix used antifreeze with used oil, since this would severely limit recycling options.
4. Submit all antifreezes for collection by Environmental Health and Safety.

300.30 Unknown Materials

1. The generation of unknown materials suggests a need to improve hazardous materials and laboratory management. Because their hazardous characteristics are not known, additional cost, liability and time are associated with the proper disposal of unknown materials.
2. Unknown materials will be accepted by EHS personnel on a charge back basis. Analytical and other costs associated with identification and characterization of unknown materials will be charged to the department or other party that is responsible for generating unknown materials.

300.40 Compressed Gas Cylinders (e.g. Lecture Bottles)

1. Whenever possible, unwanted compressed gas cylinders still under pressure should be returned to the vendor from which they were purchased (see Part 700 - Transporting Hazardous Materials). If the vendor will not accept the cylinder(s) back, submit them to EHS for disposal. "Empty" cylinders should have their valves removed, rinsed thoroughly with an appropriate solvent, labels obliterated, and disposed of as normal trash or recycled.

300.45 Aerosol Cans

1. Aerosol cans pose a unique hazardous waste determination problem because they contain three different types of materials, each of which may be classified as hazardous waste: 1) the can itself, 2) the liquid product contained in the can, and 3) the gaseous propellant (ref. McCoy’s RCRA Unraveled, 2010). In 1987, EPA modified its regulatory position and stated that empty aerosol cans could be hazardous due to the reactivity characteristic (i.e. the empty can could detonate or explode when subjected to a strong initiating source or if heated under confinement.
2. At the University of Idaho, ALL aerosol cans are considered hazardous waste until they are punctured and drained of any liquid, and/or the propellant is released. Once the can is punctured and drained until it is empty, the steel aerosol container may be recycled as scrap metal. However, if the can is to be disposed, a separate hazardous waste determination must be made.
3. All aerosol cans must be submitted to Environmental Health and Safety for proper handling.

300.50 Controlled Substances

1. Controlled substances include barbitals, amphetamines, chloral hydrate and other chemicals that can only be obtained with a valid Drug Enforcement Agency (DEA) license. The disposal of these materials is strictly regulated and must be done under the guidelines set forth by the Idaho Board of Pharmacy and DEA. Drugs purchased prior to being regulated by the DEA can be collected and disposed of by EHS personnel.

300.60 Photography and Darkroom Chemicals

NOTE: Always keep controlled substances under lock and key for liability and safety reasons.

1. Developers, replenishers, and fixers tend to be toxic and/or corrosive. Submit these hazardous materials to EHS for disposal purposes when spent or no longer needed (never discard these materials to the sanitary sewer system or as normal trash). Some photography labs have a silver recovery unit (SRU) to retrieve silver before waste solutions are discarded. If your process does not have a SRU, you will need to accumulate the waste and submit it for disposal to EHS. Silver recovery units serviced by a contract must meet EPA regulations for the recovery of precious metals. For more information on SRUs, contact EHS at 885-6524.

300.70 Hazardous Household and Commercial Commodities

1. A household or commercial commodity is a material that is packaged and distributed for sale through retail or wholesale businesses for consumption by individual, business or household use. Examples include cleaners, disinfectants, lubricants, paints, thinners, degreasers, pesticides, and fertilizers that are sold over the counter in local stores and from mail order businesses. Many of these materials are considered hazardous and are readily available to all consumers. Often, businesses sell these materials without providing MSDSs or any other hazard information about the product. Knowledge of the material's hazardous characteristics and proper disposal methods are left entirely to the individual purchasing them. Submit hazardous household and commercial commodities to EHS for disposal. EHS will accept products that were purchased with University of Idaho funds and are intended for use as part of University of Idaho business. Products that were purchased for personal use (e.g. at your private residence) can be disposed at the Latah County Solid Waste Processing Facility.