Hazardous Waste Management
Proper management and disposal of chemical waste, including EPA-regulated hazardous waste, is an essential component of Columbia University’s overall commitment to environmental sustainability. Environmental Health & Safety (EH&S) recognizes that EPA regulations are complex and sometimes difficult to interpret. EPA’s 2018 Hazardous Waste Generator Improvement Rule added even more requirements for laboratory personnel generating chemical waste, specifically the need to document an accurate hazardous waste determination at the point of generation [e.g., the laboratory Satellite Accumulation Area (SAA)] and indicate the chemical hazards on each hazardous waste label (see: https://research.columbia.edu/sites/default/files/content/EHS/Newsletters/Fall2018.pdf).
EH&S has prepared guidance for Columbia University’s most commonly generated laboratory chemical wastes to simplify the requirement for laboratories to make an accurate hazardous waste determination and identify the hazard characteristics of the waste (https://research.columbia.edu/hazardous-waste-determination). Note, EH&S has listed several chemical wastes that EPA does not specifically regulate as hazardous, but must still be collected for proper disposal through EH&S because they present potential health and/or environmental hazards. These chemicals can now be accurately identified by checking the “Non-Hazardous Waste” box on the revised orange, CHEMICAL/HAZARDOUS WASTE label provided by EH&S.
In addition to EH&S guidance, laboratory staff should refer to the manufacturer’s Safety Data Sheet (SDS) or GHS hazard pictograms affixed to the chemical container (https://research.columbia.edu/content/ghs-hazard-communication) for information about the hazards of each chemical, or use general knowledge of the chemical(s) or chemical process(es) involved in generating the waste or seek assistance from EH&S via firstname.lastname@example.org for additional guidance in making an accurate hazardous waste determination.
In general, EPA defines hazardous waste by certain characteristics or includes them on specific lists. Below is a brief summary of the characteristics and lists, with links to EPA’s website. Remember, Columbia University has a specific policy regarding the drain disposal of chemicals (https://research.columbia.edu/system/files/EHS/Policies/DrainDisposal.pdf), which must always be considered when managing chemical waste.
If any additional questions or clarification is needed in performing the hazardous waste determination please email email@example.com