IU Bloomington Waste Management
IU Bloomington Waste Management
The success of the IU Waste Management Program depends on the cooperation and conscientious efforts of everyone on the IU Bloomington (IUB) campus. IUB EHS collects a wide range of chemical waste from laboratories, shops, offices, etc. for off-site treatment or disposal. This section outlines the general procedures for managing waste from laboratory and non-laboratory operations on the IU Bloomington campus. Waste handling and disposal protocols for specific waste types commonly generated by both of these operations is also included. The procedures and methods provided must be followed to ensure your health and safety, as well as regulatory compliance. If you have any questions, contact IUB EHS immediately.
IUB Laboratory Waste Management
When a chemical waste is first created, its identity must be recorded. Waste accumulation containers are to be labeled at the time the first waste is added. If more waste is subsequently added to a waste container, constituents must be added to the container label as needed. IUB provides EHS Waste Chemical Tags for this purpose. IUB EHS will not accept waste that is not labeled properly. If the waste cannot be identified, the requirements for unknowns will apply.
IUB EHS Waste Chemical Tag information:
IUB EHS Waste Chemical Tags (“tags”) are available at waste collections, from IUB EHS and from the Chemistry and Jordan Hall stockrooms.
Tags must state each chemical constituent in the waste container and corresponding percentages. Waste constituents must be spelled out completely. Avoid acronyms, chemical structures or abbreviations. Provide percentages of all chemicals in a mixture, including water. The percentages must add up to 100%. Please write legibly.
Affix tags to containers with a rubber band or twist tie. Or, an electronic version of the tag can be printed on adhesive stock and affixed directly to disposable containers, Ziploc® bags, or boxes of containers for disposal. An adhesive tag can be affixed to an index card for reusable containers - punch a hole in the corner and attach with a rubber band or twist tie, or place in a sleeve on the side of the container.
A “Hazardous Waste Label” with general contents, and running log of specific container contents, may be used as an alternative to a tag while waste is accumulating in reusable containers, until it is presented to IUB EHS when a completed tag is required. Alternatively, each time a reusable container is emptied by IUB EHS, a new tag can be started, kept in a sleeve on the side of the container, and updated until the next time it is emptied.
- Waste chemicals in their original containers with legible, intact labels do not need to be re-labeled with a tag. However, the materials require a completed Hazardous Waste with Date label (date label) to be affixed on the container in a manner that does not obscure the chemical name. Small containers of the same material can be placed inside a closed Ziploc® bag or box, with a completed waste tag or date label. Note: If the bag or box does not close completely or the materials are different, each container will need a separate tag or date label.
More than one tag per container may be used if extra space is needed. Be sure to fill in information on the top two lines of the continuation tag; sign and date all tags.
Do not date your tag until it is ready for disposal through a waste collection or IUB EHS pick-up. If you have close to 55 gallons of waste in your lab, and a waste collection or IUB EHS pick up is not scheduled within 72 hours, contact EHS immediately. Never exceed 55 gallons of waste storage in any one satellite accumulation area.
Note: If your lab generates this quantity of waste on a regular basis, contact IUB EHS for further guidance.
Wastes collected by IUB EHS may be transported within buildings, on University streets, and eventually off of University property after storage for up to 90 days. Therefore, chemical waste must be packaged in containers suitable for extended storage and transportation.
Acceptable waste containers for common chemicals are as follows:
- Flammable and halogenated solvents: Four-liter glass solvent bottles, four or eight-liter Nalgene bottles, one or five-gallon size metal cans, any safety can, or any original solvent container;
- Strong acids and bases: Glass or compatible plastic bottles up to 4 liters in volume, original bottles preferred;
- Miscellaneous organic and inorganic reagents: Original containers or their equivalent.
- Do not use biohazard bags for storage of chemical waste.
All containers must have tight sealing caps or lids (no Parafilm® or tape). If your waste is in a container that does not close or does not have a lid, you will need to transfer it to an acceptable container before presenting it to EHS. If you have any questions, contact EHS prior to presenting the waste for disposal.
Notes: IUB EHS provides 5 gallon buckets with lids and 1 gallon wide mouth plastic jars that can be used for collection of compatible wastes. If you are going to reuse a chemical container for waste, it is your responsibility to insure that it is completely free of residue from its original contents before adding any incompatible waste to the container, and also that any labeling from the original contents has been removed or completely obscured.
When waste consolidation is not performed properly, it can lead to increased safety risks and expense. However, using these proper procedures for consolidating wastes can be an efficient way to save space and resources. The following must be adhered to when consolidating waste:
Compatible waste from the same or similar processes can be consolidated into one waste container. Never mix incompatible materials together in the same container. Attachment C provides more information on compatibility.
Whenever possible, wastes that are different in form or chemical make-up (solids vs. liquid, solvents vs. aqueous) should be accumulated in separate waste containers.
- Never consolidate wastes consisting of oxidizers, strong acids (such as nitric and perchloric), or water-reactive material with other wastes. These materials should be disposed as individual wastes in the form they are generated.
- Do not mix high hazard waste materials with low hazard waste materials, unless the experimental procedure requires it. Doing so may inadvertently create a large quantity of regulated hazardous waste where a much lower quantity may have existed otherwise.
- If consolidation is unnecessary, you are unsure whether or not your waste is compatible with the waste in an accumulation container, or your waste accumulation container is poorly labeled – do not consolidate. Note:Never assume the contents of unknown or poorly labeled containers, and never consolidate unknown or unidentified wastes with other waste materials.
- See specific waste types for information on consolidating laboratory solvents,acids and bases, and silica gel, as well as management of empty containers and chemically contaminated items.
Proper management of containers is imperative to ensure safety and compliance. All requirements outlined in Attachment B are required in addition to the following:
- Ensure waste containers remain in sound condition as outlined in the section above.
- Keep ignitable waste away from ignition sources.
- Keep the outside of containers free of contamination.
- Do not over-fill containers. Note: Full means 90% or less to allow for expansion within the container.
- Do not use biohazard bags for the storage of chemical wastes.
- Safety cans are mandatory for ignitable solvents and advised for halogenated solvents. Safety cans must be in good working order (i.e. not rusted and able to spring closed and stay tightly sealed) or must be replaced. IUB EHS will request that cans be replaced when non-functioning cans are noted during a waste collection, and will confiscate cans if generators do not comply. IUB EHS does not supply safety cans. Glass bottles are discouraged, but will be accepted from labs that do not generate enough ignitable waste to justify maintenance of a safety can.
- See specific waste types for information on the management of peroxide-forming agents, explosive or shock-sensitive materials, air reactive materials, and sharps.
Once a waste accumulation container is full, or a chemical has been determined to be a waste, it should be presented to IUB EHS for disposal as soon as reasonably possible.
- Laboratories at IU Bloomington may deliver chemicals to IUB EHS staff in Chemistry A027 during predetermined hours for waste collections, or request a pick-up depending upon location. See the online Waste Collection Schedule to determine the procedure for your location.
- Dispose of waste in a timely manner to ensure safety and compliance. Reminder: If you have close to 55 gallons of waste in your lab, it must be presented to IUB EHS through waste collection or pick-up within 3 business days. Contact IUB EHS immediately if these options are not available within that timeframe.
- EHS will not accept waste that is not properly packaged, labeled, and dated. Any container or label corrections must be made before IUB EHS can accept waste. Call IUB EHS for assistance before waste is presented for disposal.
IUB Non-Laboratory Waste Management
Below is a list of waste types common to non-research operations on campus. Information about each waste type can be found in the Specific Waste Types section of the IUB Waste Management guide . This information will guide you in identifying your waste and, for some wastes, in proper management of the waste. Unless the waste specific information indicates otherwise, this section must be followed for all wastes.
- Antifreeze/glycols (under “non-hazardous waste”)
- Asbestos containing materials
- Ballasts (PCB and Non-PCB)
- Cleaners (under “chemical waste”)
- Compressed gases (propane, acetylene, etc.)
- Electronic waste (E-waste)
- Fuels and fuel/oil mixtures (under “chemical waste”)
- Oil (includes cutting fluid, hydraulic fluid, etc.)
- Paint and paint products
- Pool chemicals (under “chemical waste”)
- Spill cleanup debris
- Universal Waste (batteries, fluorescent light bulbs, and mercury devices)
- Unknowns (unlabeled, unidentified materials that need to be disposed)
- Water-based coatings, adhesives, detergents, and surfactants (under “non-hazardous waste”)
Regulations require that all waste containers be labeled to identify the contents. A label must identify the contents of the waste container. The description must be specific enough that a person who does not work in the area could read it and know what the material is and what hazards to expect. Containers must be labeled as soon as the waste is identified or, in the case of an accumulation container like a bucket or a drum, as soon as the first waste is added. Additional content information must be added as additional waste is added. IUB EHS requires that you use the Waste Chemical Tag (Tag) or the Hazardous Waste Label (Sticker) Figure 5B. IUB EHS will provide Hazardous Waste Labels or Tags upon request. Tags can also be printed on adhesive stock using the electronic template.
Unless otherwise stated in this Guide, waste containers should not be dated until you are ready to present them to IUB EHS. You should manage the waste in your accumulation area so that your total quantity of chemical waste (unless designated as non-hazardous by this Guide or EHS) remains under 55 gallons at all times.
Note: If you are approaching 55 gallons of a specific waste that has not been designated as non-hazardous in your accumulation area, and a waste pickup is not scheduled within 72 hours, notify EHS immediately.
Some wastes, such as used oil, PCB ballasts, and Universal Waste have special labeling requirements, and different accumulation time limits. See specific waste type section for these special rules. Chemical waste should be managed as hazardous waste unless otherwise stated in this Guide.
Consolidate wastes wisely
Consolidating waste into fewer containers can seem efficient and can save space and resources if done properly. However, it can lead to increased costs and safety risks if the guidelines below are not followed:
- Accumulate different waste types in separate containers (solids vs. liquids, solvents vs. oil, oil-based paint vs. latex paint). This simplifies tracking of waste constituents in each container for labeling purposes, reduces the risk of reaction between incompatible wastes, and avoids costly generation of excess regulated hazardous waste from potential mixing of non-hazardous wastes with hazardous wastes.
- When possible, avoid re-using plastic containers for liquid waste other than containers provided by or approved by IUEHS. Plastic breaks down over time especially when exposed to adverse weather conditions.
- Choose an accumulation container size that fits the quantity of waste that you will generate in a reasonable amount of time.
Good management of containers in waste accumulation areas increases safety for everyone involved in handling and transporting waste chemicals. All requirements in Attachment B in addition to the following must be practiced to ensure safety and compliance:
- Label container contents.
- Store containers closed.
- Keep containers free of contamination on the outside.
- Check containers for corrosion, leaks or other problems routinely.
- Check product Safety Data Sheets (SDS) for information on ingredients and other hazard information to ensure proper storage with other materials.
- Flammable liquids should be stored in approved containers. Do not store corrosive liquids in metal containers or drums.
- Keep flammable waste away from ignition sources.
- Only fill liquid waste containers to 90% full to allow for expansion.
- Do not accumulate or store waste containers outdoors.
- Do not use red biohazard bags or red sharps containers for storage of any wastes. If you have questions, call IUB EHS.
Containers must be packaged properly to be accepted by IUB EHS.
For containers <5 gallons:
- Each container must have a properly completed, signed, and dated tag attached with a rubber band or twist tie.
- The tag must list all of the ingredients of the waste and their percentages. The percentages must add up to 100%. No acronyms or abbreviations should be used on the tag.
- An SDS may be attached to the container along with the tag if the waste is a chemical product and you do not know all of the ingredients.
- Every effort must be made to ensure that waste containers are sound and that lids are tight sealing, even if that means the waste must be repackaged. If a problem with a container cannot be resolved, the container must be placed into an individual bucket with a lid, and the outside of the bucket must be labeled the same as the container would be. IUB EHS can provide buckets with lids as needed.
For containers >5 gallons (drum quantities):
- Ensure bungs are tightened and there is no bulging from pressure build-up.
- Each drum must have a properly completed Hazardous Waste Label or Waste Chemical Tag unless otherwise indicated in this Guide or by IUEHS.
- If the waste pickup area cannot be accessed with a drum cart, or is only accessible by stairs, waste must be stored in 5 gallon containers or smaller so that they can be carried out.
Once a waste accumulation container is full or a chemical has been determined to be a waste, it should be presented to IUB EHS for disposal as soon as reasonably possible. Keep in mind regulatory accumulation time limits provided for some waste types in the Specific Waste Type section of this document, and remember that storing waste past the time limits can result in regulatory citations for the University.
- Unless otherwise indicated in this Guide or by IUB EHS, waste is picked up by IUB EHS on request during regularly scheduled pickups. See the online Waste Collection Schedule to determine when to expect a pickup after making a request. Once a waste is ready for disposal, ensure that it is packaged, labeled or tagged and dated. Then request a pick-up.
- Dispose of waste in a timely manner. IUB EHS offers ample opportunities for disposal. Safety and compliance is maximized when waste is disposed on a regular basis.
- At the time you present your waste for pickup, make sure that it is properly packaged and labeled. Problems must be corrected by the generator before IUB EHS will accept the waste. Call IUB EHS before you present waste if you have any questions or need assistance.
IUB Management of Specific Waste Types
- Acids or Bases (Laboratory operations only)
This section explains the disposal options for solutions of acids, such as hydrochloric, nitric and sulfuric acid, and bases such as ammonium sodium hydroxide from laboratories. It is best to dispose of concentrated solutions of acids or bases with IUB EHS due to the difficulty of neutralization. Use only disposable containers for waste that will not be neutralized because these containers will not be returned to you. Wastes that have been pre-approved by IUB EHS for neutralization following the neutralization procedures outlined in the In-Lab Disposal Options section are listed in Attachment A. If a material that you want to neutralize is not listed in Attachment A contact IUB EHS for approval.
- Concentrated acids
- <25 ml and approved for sewer disposal in Attachment A - Follow neutralization procedures in Section 4.1 or dispose directly with IUB EHS.
- >25 ml or not approved for sewer disposal – Dispose directly with IUB EHS.
- Dilute acid solutions or concentrated or dilute base solutions with no toxic metals
- Approved for sewer disposal in Attachment A - Follow neutralization procedures in the In-Lab Disposal section of this program or dispose directly with EHS.
- Not approved for sewer disposal – Dispose directly with IUB EHS.
- Dilute acid solutions or concentrated or dilute base solutions containing toxic metals
- Dispose directly with IUB EHS. Many toxic metals are regulated hazardous wastes at very low concentrations, and IUB EHS must make that determination.
Note: Nitric and perchloric acids are not approved for neutralization or consolidation at any concentration.
- Concentrated acids
- Aerosol Cans
Aerosol cans are pressurized, and often contain flammable propellants. Even empty aerosol cans remained slightly pressurized, and should not be thrown away. Refer all aerosol cans to IUB EHS for chemical waste disposal. An exception to this would be non-flammable compressed air dusters, which can be discarded as general refuse, however consult the SDS for the material to ensure the air duster does not contain flammable propellants.
- Air and Water Reactive Materials
Dispose of all air and water reactive materials, such as those listed below, through IUB EHS. Package any liquids separately from solids and note any special hazard and/or handling precautions on the Waste Chemical Label or tag.
- Acetyl chloride
- Lithium metal
- Sodium metal
- Phosphorus (yellow)
- Thionyl chloride
- Calcium metal
- Potassium metal
- Animal Related Materials
Refer to the IU Biosafety Manual for disposal procedures for animals and animal care related materials.
- Asbestos Containing Materials
Asbestos is found in many common materials on the University campus including floor tiles in older buildings, pipe insulation in steam tunnels and older buildings, laboratory equipment, and other building materials. It is usually encountered during repair or renovation projects.
While asbestos is not regulated as hazardous waste, it must be handled and packaged according to particular procedures in order to eliminate respiratory exposure. IUB EHS does not generally handle asbestos disposal unless the material is already in a sealed container. If you encounter asbestos or asbestos containing material that is not already packaged in a container, leave it alone and let your supervisor know so that they can arrange for it to be removed and disposed properly.
- Aqueous Solutions of Toxic Metals
All aqueous solutions containing the following toxic metals must be disposed of by IUB EHS:
Note: For any solutions containing mercury, the Waste Chemical Tag must indicate whether the mercury concentration is less than or greater than 260ppm. If you are unsure, assume >260ppm.
There are three types of light ballasts in use at IUB:
Polychlorinated biphenyls (PCB) containing ballasts are regulated by the Toxic Substances Control Act (TSCA), and must be collected by IUB EHS for disposal. These ballasts are hazardous because of the toxic fluid inside. PCB ballasts are found in older lighting fixtures. Lighting fixtures in campus buildings have been systematically upgraded over the last several years. When the fixtures are upgraded, they no longer use PCB ballasts. Eventually there will be no more PCB ballasts on campus.
IUB EHS will supply drums for collection of PCB ballasts. Employees must ensure that the drums are properly labeled (see Attachment D) and dated. Date drums as soon as the first ballast is added.
PCB ballasts are required to be disposed of within one year from the time that they are removed from service. Call IUB EHS to pick up the drum as it approaches 9 months old even if it is not full so that the disposal time limit is not exceeded.
Non-PCB ballasts can be disposed in the regular trash or salvaged for scrap metal if an outlet is available. IUB EHS does not collect these ballasts.
Electronic ballasts are essentially non-PCB ballasts that contain a Ni-Cd battery. The batteries must be removed and disposed through IUB EHS. These ballasts can be disposed in the regular trash or salvaged for scrap. IUB EHS does not collect them.
- Biological Materials
Refer to the IU Biosafety Manual for disposal procedures for biological materials.
Cardboard recycling at IUB is part of the larger recycling effort coordinated by Building Services and the Office of Sustainability. An FAQ is available on the campus sustainability website.
Cardboard that is grossly contaminated with chemical(s) that exhibit flammable, corrosive, reactive and/or toxic characteristics should be placed in a sealed container and disposed through IUB EHS following the general procedures.
- Chemical Waste
Since IUB EHS determines which chemicals are regulated as hazardous waste, all unwanted chemicals should be managed as hazardous waste when discarded unless specific instructions in this Guide or IUB EHS personnel state otherwise. Areas that generate hazardous chemical waste must follow Satellite Accumulation Area Requirements (Attachment B). All IUB EHS general requirements for waste management must also be followed. Discard chemical waste often to avoid deterioration of containers and labels. Waste must be removed from your satellite location within 3 business days if you accumulate more than 55 gallons. This is a regulatory requirement. Waste pickups can be requested at http://apps.ehs.iu.edu/waste/main.cfm.
Non-laboratory chemical waste may be generated by maintenance, custodial, landscaping, or other facilities operations. Common examples include:
- Aerosols and cylinders such as propane tanks;
- Cleaning compounds (many are corrosive);
- Pesticides with toxic ingredients;
- Mercury and mercury debris;
- Paints (oil based), solvents, stains and adhesives;
- Pool or water treatment chemicals;
- Fuels and fuel/oil mixtures; and
- Spill debris from hazardous chemical spills.
- Chemically Contaminated Items (CCIs)
Chemically contaminated items (CCIs) such as disposable labware and gloves, bench top coverings, pipets, test tubes, aprons, etc. can be put into the normal trash if they are not reactive, ignitable, infectious, or radioactive; the contaminant is not highly toxic; and the material will not cause a nuisance or physical hazard when placed in the trash. If your CCI contaminant is not listed in Attachment A and you are unsure whether normal trash is an appropriate disposal route for your CCIs, contact EHS for approval prior to disposal.
If your CCIs cannot be placed in the normal trash for one of the above reasons, package them in a 5-gallon, 2-ml thick plastic bag (obtained through the Chemistry or Biology stores), which can be placed conveniently inside a 5-gallon plastic bucket. Close the bag with a rubber band, twist tie, or by tying the top when it is full, and label the Waste Chemical Tag as "chemically contaminated items" or "CCIs" and list all chemical contaminants. Call IUB EHS if you have any questions.
Note: All PCB contaminated materials at ³50 ppm must be packaged separately, and given to IUB EHS for disposal with the PCB concentration clearly indicated on the Waste Chemical Tag. See also: PCB’s
- Compressed Gases/Pressurized Liquids
Compressed gas cylinders that are no longer wanted should be disposed in a timely manner to prevent deterioration of the containers, valves, or labels. Leased cylinders should be closed, capped and returned to the original gas supplier. Non-returnable cylinders such as lecture bottles and disposable cylinders must be referred to IUB EHS for disposal. Indicate on the cylinder whether it is at atmospheric pressure, or if it is above 1 atmosphere of pressure. See cost recovery for additional information regarding potential charges for disposable cylinders.
- Controlled Substances
Controlled substances are regulated by the US Drug Enforcement Agency (DEA) on Schedules I-V. These materials require registration with the DEA, careful inventory protocols, and documentation of on-site destruction. For disposal instructions, refer to the IU Controlled Substances Program for Research (Non-Practitioners). IUB EHS performs witness-destructions onsite in the presence of the original registrant and IU Police after proper DEA notification in accordance with regulatory requirements. If for any reason the original registrant cannot be present, IUB EHS will coordinate with the registrant or registrant’s departmental representative (in case of abandoned materials or deceased registrant), IU Police and the local DEA office to arrange for on-site destruction or disposal.
- 2, 4-Dinitrophenol
See: Explosive or Shock-Sensitive Compounds.
- Electronic Equipment
Electronic waste (E-waste) contains toxic metals in components like screens and circuitry, but is exempt from hazardous waste regulations as long as the equipment is intact. Most e-waste is currently managed at IUB by Surplus Stores. Request a pickup of electronic waste by filling out the online Surplus E-Waste Form. If equipment is crushed and leaking, contact IUB EHS for guidance. Examples of common e-waste at IUB include:
- Computer monitors
- Mobile phones
- Video equipment
- Empty Containers
Bottles and containers are considered “empty” when you have removed all contents possible by normal means (pouring, scooping, etc.). Slight residue may remain, but these containers can generally be placed in the normal trash (see table below for exceptions). Some buildings provide a special dumpster for glass containers. Consult building policies or your building safety officer. To prevent re-use, punch a hole in 5-gallon containers or safety cans that are no longer needed, and place in the normal trash dumpster. A non-sparking pick is available in Chemistry A027 during waste collection hours for safely punching holes in metal containers that held ignitable materials.
Empty Container Management Guidance Table
Hazardous/ Chemical/ Pharmaceutical
Remove and discard lid. Pour out all free liquid. Allow residue to dissipate under hood.
Deface labels, place in sealed box, and dispose box in regular trash.
Remove and discard lid. Pour out all free liquid. Allow residue to dissipate under hood.
Deface labels, place in sealed box, and dispose box in regular trash.
Tag and dispose with IUB EHS.
Tag and dispose with IUB EHS.
Arrange return to vendor**
Tag and dispose with IUB EHS*
Tag and dispose with IUB EHS*
Purge according to manufacturer’s guidelines and remove valve, mark as empty, give to
Tag and dispose with IUB EHS.
*Due to the high disposal costs of many materials purchased in cylinders and Sure-Packs, EHS charges the cost of disposal for these items back to the generating department. It is up to each department whether to pass that cost back to the individual researchers.
**Because lease/maintenance and return agreements for returnable cylinders are generally arranged and maintained by parties outside the purview of EHS, if those agreements are abandoned and EHS must arrange disposal or return of these items – costs are charged to the generating department. It is up to the department to decide if they want to pass that cost back to the individual researcher or not.
- Ethidium Bromide
Ethidium bromide is a strong mutagen that in pure form is also highly toxic by inhalation. Ethidium bromide and preparations including stocks and gels are collected by IUB EHS for disposal as chemical waste.
- Explosive or Shock-Sensitive Chemicals
If you have an explosive or shock-sensitive material for disposal, call IUB EHS for assistance. Many of these materials become less stable over time or as they dry out. Therefore, they should never be stored in a desiccator, or under any other condition that would allow for the material to dry out. Do not store unused amounts for an extended period of time. See cost recovery for additional information regarding potential charges for disposal of high-hazard materials. Potentially explosive chemicals include:
- Aged peroxide forming agents,
- Diazo compounds,
- Dinitro compounds,
- Hydrazine compounds,
- Dry picric acid, and
- Fluorescent Light Bulbs
- General Refuse (Trash)
Non-recyclable, non-hazardous refuse (trash) should be placed in designated area trashcans or dumpsters. Liquids and semi-liquids are prohibited from disposal in campus dumpsters and compactors. Broken glass must be placed into a rigid cardboard box and clearly marked with the words “BROKEN GLASS”.
Treated biological waste containers must have indicator tape placed on them in order to confirm they were autoclaved prior to disposal in the general trash. Biohazard symbols must also be defaced.
Dust forming materials must be containerized to eliminate release in the dumpsters and/or compactors.
- Glass Waste
Laboratory glass, whether intact or broken should be disposed in a rigid container such as a cardboard box. Boxes that contain broken glass must be marked with the words “Broken Glass” highly visible on the outside of the container. Ensure all glass bottles are empty and free of chemical residue before placing them into a glass disposal container. Glass is picked up and discarded by Building Services.
Lead has many uses, and is common at IU. The main activity for which lead is encountered by non-laboratory personnel is building renovations that require removal of lead paint.
Lead paint removal projects can generate both stripping solution waste and lead paint debris. Often, the stripping solution is diluted from project activities, but IUB EHS must determine if the solution is corrosive or contains regulated levels of lead. Therefore, stripping solution waste must be collected for testing. Lead paint debris is hazardous for lead content and must also be collected. IUB EHS can provide drums for each waste stream when notified before a lead removal project starts.
IUB EHS collects and recycles free-flowing metallic mercury. Package it in a tightly sealed and leak‑free container. Place broken mercury thermometers in a one-gallon over-pack (obtainable from IUB EHS) or a secured plastic bag and bring to a waste collection or request a waste pickup.
Note: There are alternatives to mercury thermometers, and they should be used whenever possible. In addition, if you use mercury it is imperative that you have a mercury spill kit available.
- Mercury Containing Devices
- Mixed Waste
Mixed wastes are those that pose multiple hazards including biological, chemical and/or radiological. Handling and disposal of mixed wastes can be complex due to overlapping regulatory requirements and restrictions imposed by treatment facilities. IUB EHS cannot dispose of waste that is radioactive, or that poses both chemical and biological hazards.
Radioactive Mixed Wastes
In general, if a mixed waste is radioactive it must be referred to the IUB Radiation Safety for disposal, even if biological or chemical hazards are also present. All waste containers must be fully and accurately labeled, and must be disposed in accordance with all IU Office of Radiation Safety policies and procedures.
Biological and Chemical Mixed Wastes
Wastes that contain a mixture of both biological and chemical components must be evaluated to determine if the chemical in the waste has deactivated/disinfected all biological hazards present. If not, the generator must add an adequate volume of an approved disinfectant that is chemically compatible with the waste such as ethanol, bleach, formalin, etc. The generator of such waste must certify that it has been disinfected, and communicate with IUB EHS the type and volume of chemical disinfectant used.
- Nonhazardous Waste
Most chemical waste is handled by IUB EHS. However, you might have some nonhazardous waste listed as acceptable for sewer or trash disposal in Attachment A of this Guide.
Chemicals (liquids and solids) can be flushed to the sanitary sewer if they are:
- water soluble,
- degradable in the sanitary sewer system, and
Solid chemicals or spill clean-ups that are not water soluble, but are non-toxic, and do not present any other safety hazard or nuisance, can be disposed in the regular trash. All chemicals poured into the sewer must be followed by at least 20 parts water.
Note: If you intend to dispose of more than one liter of a non-hazardous liquid or 5 pounds of solid, or if the material is not listed in Attachment A of this Guide, contact IUB EHS for pre-approval.
Some materials are not hazardous, but still cannot be disposed directly into the trash because of landfill restrictions. The most common restriction encountered is that liquids and semi-liquids are not allowed to be landfilled. Many oils, latex paint, and other water-based materials are non-hazardous and could be landfilled if they were solid, but cannot be when they are liquid.
Spill debris from non-hazardous wastes can be discarded in the trash, as long as all free liquid is absorbed. Minimal amounts of liquid in otherwise empty containers of non-hazardous wastes can be absorbed with kitty litter or other suitable absorbent material and disposed in the trash also.
Common examples of non-hazardous chemical waste include:
- Antifreeze and other glycols;
- Latex paint;
- Non-toxic pesticides (such as dormant oil), fertilizers and plant food;
- Oils (non-PCB) and cutting fluid; and
- Water-based coatings, detergents and surfactants.
Various types of oil, including vacuum pump oil, motor oil, cutting oils, etc., that is not contaminated with solvent or other chemicals, may be referred to IUB EHS for used oil management or arrangements may be made with an approved vendor. Contact IUB EHS for approval of used oil management vendors.
Any used oil that is contaminated with other chemicals must be accurately described and disposed as a chemical waste through IUB EHS. If the oil contains PCB, the generator must indicate such on the label and as part of the chemical description on the waste pick-up request form. The concentration of PCB in parts per million (PPM) should also be listed if known. See also: Polychlorinated Biphenyls, Vacuum Pump Oil
- Paint and Paint Products
Latex paint that is still in good condition, even if the container has been opened, should be referred to Surplus Property for re-distribution or sale. Paint that is no longer useable, contains lead, or is oil based, as well as spray paint, must be referred to IUB EHS for chemical waste disposal. Lead-based paint chips from construction or remediation must also be referred to IUB EHS for disposal. See also: Lead
- Peroxide-Forming Agents
Peroxides are low power explosives and are very sensitive to shock and heat. A variety of organic compounds react with oxygen from the air to form unstable peroxides. One of the following conditions must be met before peroxide formers may be accepted by IUB EHS for disposal. These are requirements enforced by our disposal contractor, as well as good laboratory safety practices.
The material must be less than twelve months old. This information must be marked clearly on the Waste Chemical Tag.
If the material is greater than twelve months old but less than two years old, check for peroxide formation by using peroxide paper stocked at Chemistry Stores. If peroxide formation is less than 100 ppm, add 1 tsp. of hydroquinone per pint of material to prevent the formation of additional peroxides. Mark this information on your waste tag (e.g., "<100 ppm, hydroquinone added") and bring it to an Open House. If peroxide formation is greater than 100 ppm, call IUB EHS for technical assistance.
If the material is greater than 2 years old but less than 5 years old, it should be assessed for other factors such as: duration of exposure to sunlight, volume of container (i.e., "Is it full?"), security of the seal, exposure to changes in temperature, etc. If you do not know the answer to any of these questions, find someone who does. Do not open the container to check for peroxide formation, as the material could be shock-sensitive. Call IUB EHS for technical assistance.
If the container is more than five years old, do not move the container at all. Post a sign reading "DANGER: possible shock-sensitive chemical" and call IUB EHS for technical assistance.
Safety Tips for Peroxide Formers
Date peroxide formers when received and when first opened. In general, discard according to time limitations suggested by the manufacturer. For severe and high peroxide formation hazard chemicals, the storage limitations are:
Severe Peroxide Hazard (Discard within 3 months)
- Diisopropyl ether
- Potassium amide
- Potassium metal
- 1,1-dichloroethylene (vinylidene dichloride)
- Sodium amide
High Peroxide Hazard (Discard within 6 months)
- Diethyl ether
- Ethylene glycol ethers
- Methyl isobutyl ketone
- Vinyl ethers
Avoid exposure to light or air and store in light-resistant containers.
Refrigeration does not prevent peroxide formation.
As is the case with all hazardous chemicals, order only those amounts that you need.
Do not move or attempt to open containers of unknown age. An obvious indicator of peroxide formation is evidence of needle-like structures or crystals in the liquid. However, dangerous peroxides may be present without obvious crystal formations. Peroxide crystals may have formed on the cap and threads. Call IUB EHS for assistance.
Never distill peroxide-forming solvents.
See also: Explosive or Shock-Sensitive Chemicals
Non-controlled legend (prescription), over the counter and research drugs should be referred to IUB EHS for disposal. See also: Controlled Substances for disposal of DEA scheduled materials.
- Picric acid
See: Explosive or Shock-Sensitive Chemicals
- Polychlorinated Biphenyls (PCBs)
PCBs are synthetic chemicals manufactured until 1979 when they were banned in the United States. PCBs can be found inside heat transfer systems, hydraulic systems, transformers and lighting ballasts manufactured before that time. IUB EHS must collect and dispose of PCB containing fluids, equipment, research chemicals and contaminated debris. If you need to dispose of equipment that contains oil, dielectric fluid, hydraulic fluid or other potential sources of PCBs, please note the date that the equipment was taken out of service, and any information that can help EHS determine the date the equipment or fluid was manufactured. If fluid suspected of containing PCBs has leaked from equipment, follow campus emergency procedures to report a chemical spill immediately.
See also: Ballasts, Oil
- Radioactive Waste
All radioactive materials and waste must be handled and disposed in accordance with the IU Office of Radiation Safety policies and procedures. More information can be found at http://ehs.iu.edu/topics/radiation-safety/index.shtml.
A collaboration of student groups, IU Management, and diligent employees have made Indiana University's Bloomington Campus recycling program one of the best in the nation. Internally, the Physical Plant recycles tires, automotive batteries, all metals, refrigerant CFCs, antifreeze, motor oil, wooden pallets, and most organic materials. For more information, visit: http://www.iu.edu/~phyplant/operations/building-services/recycling/index.shtml.
- Refrigerant and Equipment
Refrigerants such as Freon® must not be released into the atmosphere, and must be properly removed from equipment such as air conditioners, refrigerators and freezers. At IUB, refrigerant reclamation is managed by the Physical Plant.
Various sharps are generated on campus, such as needles, razor blades, and broken glassware. Although most are not regulated as hazardous waste, they do require special handling for safety reasons. Regardless of contamination, sharps should be placed in puncture-resistant, cardboard or plastic containers and labeled as “sharps” prior to disposal unless your building procedures specifically allow for alternative handling. Manage sharps in the following manner:
- Chemically contaminated sharps that are grossly contaminated with hazardous chemicals should be collected in puncture-proof containers, marked as “Sharps contaminated with “______________” and sealed tightly. These sharps should then be disposed through IUB EHS.
- Biohazard sharps: Metal and glass sharps contaminated with biological materials should be packaged and disposed according to the IU Biosafety Manual.
- Radioactive sharps: Metal and glass sharps contaminated with radioactive materials should be packaged and disposed according to the IUB Radiation Safety Manual.
- Uncontaminated metal sharps: Containers should be puncture proof, labeled as “Nonhazardous waste sharps” and sealed tightly. Dispose in the normal trash.
- Uncontaminated glass sharps: At some buildings, these may be placed directly in glass dumpsters with no special labeling or container requirements. If no glass dumpster is available, package in a puncture proof container, label as “Nonhazardous waste sharps”, seal tightly, and place in the normal trash.
Note: Sharps containers are sold in chemistry stores, the biology stock room and lab supply catalogues. Red biohazard sharps containers are prohibited. Clear sharps containers with a biohazard symbol should be used for biohazard sharps and green or blue containers or white buckets should be used for nonhazardous sharps.
Packaging, Labeling, and Disposal of Sharps Waste
Closed sealed box or plain (non-red) puncture resistant container
Hazardous Chemical Waste
Tag with the description:
Sharps contaminated with:
Request pickup by IUB EHS or bring to a waste collection.
Closed sealed box or plain (non-red) puncture resistant container or nonhazardous sharps bucket in lab
“Non-hazardous Waste Sharps”
“Non-hazardous Sharps – Solid Waste”
Take to building dumpster.
- Silica Gel
Amorphous silica gel is widely used at IUB as column packing media especially in the Chemistry department. EHS disposes of approximately one ton per year of this material. EHS has determined it to be nonhazardous, but it is dusty and has a nuisance odor if disposed in the dumpsters. Therefore, we require it to be disposed through IUB EHS.
Silica gel can be accumulated in 5 gallon plastic buckets or 1 gallon plastic jars depending on your rate of generation. IUB EHS has containers available during waste collections or by request to be delivered at the time of waste pickups. Store all containers closed and label "waste silica gel." Only gel should be accumulated in these containers – no plastic wrap, instruments, gloves, bench paper, or other debris.
Note: If you use pyridine in your chromatography procedure, you must separate the silica gel from that procedure from any other silica gel that you generate, and indicate pyridine as a component of the waste on the Waste Chemical Tag.
- Sodium Azide
See: Explosive or Shock-Sensitive Chemicals
- Solvents (Laboratory operations only)
Due to the large volume of organic solvents generated at IUB, EHS consolidates these materials from the small containers received from numerous laboratories into large drums to be shipped to off-site waste vendors. This results in a significant cost-savings for the University as well as addressing safety, compliance, and convenience issues in the labs. To facilitate this program, you must follow the procedures below.
- Place your organic solvents in a safety can. The safety cans are reusable, and will be emptied during the waste collection and returned to you. Very small generators can use other containers if a safety can is not practical.
- Label your safety can with the words “hazardous waste” and some description of the contents as soon as any waste is put into them. This is a regulatory requirement.
- Start a waste tag or a content log for your safety can or container as soon as the first material is added to it so that you will be able to account for 100% of the chemical composition of the container.
- Waste must have a pH between 3 and 11 or it will be rejected. Because we are comingling your waste with other solvents, we need to ensure compatibility using pH as a gauge.
Safety Can Use
Note: Safety cans with broken springs or other defects make them no longer operable as safety cans, and will not be returned. Safety cans are to be used for solvents only. The following should NOT be placed in your safety cans in any concentration:
- Acid and base solutions - If you have large volumes of solvents with low or high pH, you may use safety cans and neutralize the waste before offering to EHS according to the neutralization procedures outlined in the IU Wate Management Guide. Waste with a pH less than 3 or greater than 11 at the time it is presented for disposal may be rejected. Also, be sure to allow 24 hours after neutralization before disposal to insure that the pH has stabilized and the heat of reaction has dissipated.
Note:If a solution is warm to the touch when presented for disposal in a reusable container, it may be rejected or you may be asked to leave the container until the next waste collection.
- Aqueous solutions of toxic organic chemicals - If your procedures are such that water is mixed with solvents during the course of a reaction, it is okay to put in a safety can with other solvents. Do not add primarily aqueous solutions to solvents in a safety can.
- Metals (e.g., Sb, As, Ba, Cd, Cr, Pb, Hg, Ni, Se, Ag)
- Inorganic cyanides
- Oxidizers or reducers
- Reactive substances – This includes air and water reactive chemicals, as well as materials that are known to react badly with organic solvents.
- Stench compounds – Safety cans are to be poured in our processing area using local exhaust, and returned to you while you wait. Stench compounds which include all sulfides, thiols, mercaptans, some amines, butyric acid, valeric acid, etc., overwhelm the exhaust system. Odors accumulate in the processing area and can escape into the general building ventilation. Safety cans with stench compounds will be taken for disposal without return. They will not be poured in the IUB EHS waste processing area.
- Spill Debris
For liquid spills that meet all of the reporting exception criteria listed in spill procedures section of the IU Waste Mangement Guide, absorb with spill pads, disposable towels, or other absorbent material and place them into a sealed container or leak resistant bag. After absorption, use a small amount of soap and water to clean spill surfaces and dry thoroughly. For solids, sweep up the spill with a broom and dustpan. Collect the material into a plastic or glass container or Ziploc® bag. Do not use a shop vac or vacuum cleaner.
- For inert, non-hazardous chemical spills, place in a sealed container, including the broken chemical container, contaminated towels, etc. for general trash disposal. Be sure all liquid spills are fully absorbed into the absorbent material.
- For spills involving material that must be collected by IUB EHS, the debris must be in a closed container with a Waste Chemical Tag described as “Spill debris containing…” and a detailed list of the contents. Include everything in the container such as broken glass or metal if present, water, paper towels, etc.
- Universal Waste
Some waste materials meet the definition of a hazardous waste, but the EPA provides an exemption for certain materials destined for recycling. However, generators of Universal Waste must still comply with rules for accumulation, including segregation of waste types, labeling, and time limits. This section lists general information for each type of waste that can be managed as Universal Waste for recycling.
Notes: Spill debris from Universal Waste must be managed as a hazardous chemical waste through IUB EHS. Attachment D contains some sample label templates that can be printed and used to meet the labeling requirements.
Fluorescent light bulbs come in different sizes and shapes; long, straight lamps used in ballast operated light fixtures, or compact fluorescent bulbs used in place of incandescent bulbs. All fluorescent bulbs or lamps contain a small amount of mercury. Bulbs known as “green” or “green tip” contain mercury in low enough amounts to be exempt from waste regulations. They can be distinguished from higher level mercury bulbs by their green endcaps or other markings. Collecting green lamps along with regular lamps for Universal Waste recycling is strongly encouraged, but not required. Upon request, IUB EHS can provide a list of green bulbs by brand and model number. Bulbs that are not “green” must be managed as Universal Waste.
General Rules for Universal Waste Bulbs:
(A printable guidance document is available at the IUB EHS website.)
- All bulbs must be stored in a closed container to protect against breakage as soon as they are collected.
- Each container must be marked with the words “Universal Waste” and a description such as “Used Bulbs” or “Used Lamps” as soon as the first bulb goes into the container.
- Each container must be marked with the date that the first bulb went into the container.
- Each container must be shipped offsite to an authorized Universal Waste handler before one year from the date marked on the container to avoid violation of the regulations.
- If a bulb breaks before it is placed into a container, it is no longer a Universal Waste. The debris from the cleanup of the broken bulb must be managed as hazardous waste.
*The bulb cleanup procedure can be found at the IUB EHS website.
Disposal of Fluorescent Bulbs at IUB by location:
- Physical Plant - bulbs from fixture lighting in areas maintained by physical plant are collected, stored, and shipped by Building Services and Zone Maintenance personnel.
- Residential Programs and Services (RPS) - bulbs from fixture lighting in areas maintained by RPS are collected, stored, and shipped by RPS personnel.
- All other areas or buildings at IUB - bulbs from fixture lighting from all other areas aside from physical plant and RPS must be collected and stored according to the rules above for Universal Waste bulbs. Offsite shipping arrangements must be made by the department responsible for the area or building.
- IUB EHS – specialty bulbs from any campus location, including bulbs from specialized fixtures such as some outdoor lighting, sodium discharge lamps, high intensity discharge lamps, and mercury vapor bulbs, are managed by IUB EHS. Package and label bulbs according to the general rules for Universal Waste bulbs and request pickup from IUB EHS within 9 months.
Note: While EHS does not manage the storage and disposal of all bulbs at IUB, we do provide oversight of the Universal Waste program. We may inspect any accumulation and storage areas and require corrections to packaging and labeling if they do not meet the regulatory requirements. We also provide training to departmental personnel.
IUB EHS has chosen to manage all batteries as Universal Waste. There is a separate recycling exemption that applies to lead acid batteries only, and alkaline batteries are non-hazardous. From a practical standpoint, though, it would be impossible to get the University community to sort their batteries consistently enough to rely on, and there is not enough cost or regulatory burden savings to justify sorting them ourselves to manage them separately.
General Rules for Universal Waste Batteries:
(A printable guidance document is available at the EHS website.)
Batteries should be in good condition and non-leaking. If there is visible evidence of corrosion, they must be placed in a closed container (a lid with a hole is not considered closed). This is a regulatory requirement. If there is no visible evidence of corrosion or leaking, a lid is not required on the container.
Each battery or container must be marked with the words “Universal Waste” and a description of the material such as “used batteries”, or “spent batteries” as soon as it is collected or the first battery goes into the container. See Attachment D for a template of printable 2”x 4” labels.
Each battery or container must be marked with the date that it was collected or the first battery went into the container.
Each battery or container must be shipped offsite to an authorized Universal Waste handler for disposal before one year from the date marked to avoid violation of the regulations.
Battery Disposal at IUB
IUB EHS manages battery disposal at IUB. Request a pickup at www.ehs.iu.edu. Building Services maintains battery-recycling containers around campus for employees and University community members to use. These containers must be managed according to Universal Waste rules as soon as the first battery goes into them no matter where they are located on campus. IUB EHS may inspect any of these areas periodically to insure compliance with the regulation.
Note: While EHS does not manage the accumulation and collection of all batteries at IUB, we do provide oversight of the Universal Waste program. We may inspect any accumulation areas and require corrections to packaging and labeling if they do not meet the regulatory requirements. We also provide training to departmental personnel.
Mercury Containing Devices
Mercury containing equipment includes devices, items, or articles, which contain elemental mercury that is integral to their function, and contained in ampules or otherwise enclosed intact. Examples are:
Mercury switches, and
Specialty meters, regulators, and gauges.
These devices have been given an exemption from full hazardous waste regulation to be managed as Universal Waste as long as they are properly recycled. Devices must be intact and not leaking mercury to qualify for the exemption. Devices that contain mercury should never be thrown in the trash or sent to surplus.
Note: The Universal Waste exemption does not apply to metallic mercury that is not contained in a device or to mercury-contaminated debris.
General Rules for Universal Waste Mercury Devices:
(A printable guidance document is available at the EHS website.)
Devices and equipment must be placed in containers such as buckets or drums provided by IUB EHS, or in boxes that can be closed securely.
Mercury must not be leaking from the equipment.
Containers must be closed at all times when a device is not being added.
Containers must be labeled with the words “Universal Waste – mercury-containing equipment” and the date that the first item was added.
Each container of mercury-containing equipment being managed as Universal Waste must be shipped off campus to an authorized Universal Waste handler before one year from the date marked on the container to avoid violation of the regulations.
Disposal of Mercury Devices at IUB:
EHS manages the off-site disposal of mercury-containing equipment. In order to insure that containers are shipped off campus before one year to remain in compliance with regulations, pickups should be requested at http://apps.ehs.iu.edu/waste/main.cfm for all containers once their dates reach 9 months. EHS may inspect accumulation areas periodically to insure compliance with Universal Waste requirements.
EHS has chosen not to use the Universal Waste exemption for hazardous pesticides because it does not have any significant effect on the University’s regulatory burden or costs. Hazardous pesticides, and those that non-hazardous such as dormant oils and insecticidal soaps, should be managed as chemical waste.
Unlabeled or poorly labeled containers of chemicals or products in areas where hazardous materials are used or stored represent serious legal and safety problems for the University. They must be assumed hazardous unless evidence or certification to the contrary can be obtained.
Without an accurate description, it is difficult to characterize the hazards presented and dispose of the material legally and safely. Disposal companies will not accept chemical waste without an analysis or specifically defined characterization of hazards.
It is the responsibility of the person generating a waste to accurately keep track of the contents of containers so that the material can be described adequately for the disposal vendor when it is discarded. If proper labeling and records on containers are not maintained and an adequate description cannot be provided; or if the disposal company requires further analysis, EHS will charge-back the generating department. See cost recovery for additional information.
- Vacuum Pump Oil
Uncontaminated vacuum pump oil should be referred to IUB EHS for recycling. Contaminated vacuum pump oil should be marked or labeled as a waste chemical with the words “Used Pump Oil” and, if known, “contaminated with (list all known chemical contaminants)”. See also: Oil
Under normal circumstances, IUB EHS does not charge for the cost of waste handling and disposal services to academic or research groups. However, IUB EHS reserves the right to charge the department of waste generators who incur regulatory fines as a result of non-compliance with this Guide, or who require services that result in significant costs for IUB EHS or to the University as a whole such as:
Disposable Cylinders: Many cylinders can be returned to the manufacturer for refill or recycling in quantities as low as 1lb. In most cases, disposable cylinders (non-returnable) with remaining pressure, product or product residue must be referred to IUB EHS for waste disposal. Empty cylinders can only be discarded as general refuse or scrap metal if they once contained an inert, non-toxic gas and are proven to be at atmospheric pressure by valve removal or puncture. IUB EHS reserves the right to charge back special handling or disposal charges incurred per disposable cylinder to the responsible department. Check with your department representative for returnable options before purchasing a disposable cylinder.
High-hazard Waste: Unstable, reactive or peroxide-forming chemicals that are improperly stored, mixed with incompatible materials or otherwise mishandled can pose serious risks, including fire or explosion. Due to the high-hazard nature of these materials, IUB EHS must contract special services for stabilization, transportation and disposal at an extremely high cost. IUB EHS reserves the right to charge back for specialized high-hazard waste management services per container.
Laboratory Chemical Moves: Personnel must comply with campus specific guidelines for inter and intra-building chemical moves found in the IU Hazardous Materials Transportation Program. The program provides detailed procedures for notification of IUB EHS, timeframes, and preparation of materials. Preparation and move assistance from IUB EHS personnel is also available with adequate notification for a fee that includes time and materials. Responsible departments must ensure that guidelines are followed so that all chemicals, wastes, and contaminated items are identified and managed properly before a lab is vacated. IUB EHS charges the responsible department for any unreasonable costs incurred for the cleanout of labs that do not comply with the proper procedures.
Mercury: As part of the University’s waste minimization effort, and due to the high cost of disposal, all non-essential uses of mercury are prohibited at Indiana University. Authorization for essential uses of mercury and/or mercury compounds must be obtained from IUB EHS. Details are outlined in the Mercury Reduction/Elimination Program. Charges related to disposal and/or spill cleanup of unauthorized mercury will be referred back to the generating department.
Unknown Fingerprinting: All chemical materials must be fully identified and labeled by the generator with adequate information for IUB EHS to determine potential hazards and a proper disposal method. Unidentified chemicals are expensive to dispose, and dangerous to emergency responders. IUB EHS reserves the right to charge the responsible department for each container of unknown material. The amount charged is determined by IUB EHS based on the cost of characterization and disposal. To avoid these charges, trained laboratory personnel may opt to perform their own unknown fingerprinting for unknowns <5 gallons in size using the IUB Unknown Characterization Procedure.