IU Regional Campus Waste Management
IU Regional Campus Waste Management
The success of the IU Waste Management Program depends on the cooperation and conscientious efforts of everyone at Indiana University. IUEHS provides guidance and helps manage the disposal of 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 regional campuses. 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 IUEHS for your respective campus.
The Guidelines for IU Regional Campus Waste Management is divided into three sections. For specific information follow the links to each section:
IU Regional Campus Laboratory Waste Management
The following general requirements apply to waste generated by laboratory operations. Laboratories generate a large variety of waste types. Those waste types shall be managed as hazardous waste unless otherwise specified by this Guide or IUEHS staff.
Identify and label
Note: All waste containers must be labeled! Containers are to be labeled at the time the first waste is added, and subsequently add constituent names as needed.
Chemicals in original containers with intact labels do not need to be relabeled unless they are difficult to read. Small bottles may be labeled by any means which completely identifies the contents of the bottle, such as placing the small container(s) in a labeled, Ziploc® bag.
Pre-printed, Waste Chemical Labels are available from IUEHS. Labs can create, print and secure custom labels to the container; as long as all of the constituents contained in the waste and approximate concentration of each is provided. Avoid acronyms, chemical structures or abbreviations. Provide percentages of chemicals in a mixture, including water.
Waste Chemical Label information:
Waste Chemical Labels are available from IUEHS for your respective campus.
Waste Chemical Labels must state each chemical constituent present in the waste container and corresponding percentages. Waste constituents must be spelled out completely — no abbreviations, formulas or structures. Please write legibly.
Additional Waste Chemical Labels may be used, if necessary. Sign and date all Waste Chemical Labels used to identify the waste.
Affix Waste Chemical Label(s) to container(s) securely.
Fill in an accumulation date when the container is “full” and advise the Laboratory Safety Coordinator for your school/department. Note: “Full” is 90% of container capacity to allow for expansion.
Wastes managed by IUEHS are transported within buildings and on University streets. Therefore, chemical waste must be packaged in containers suitable for transportation. Acceptable waste containers for common chemicals are as follows:
Flammable and halogenated solvents: Four-liter glass solvent bottles, one or five-gallon size metal cans or plastic carboys, 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.
Note: Contact IUEHS for approval to use waste containers larger than 5 gallons in size. All containers should be approximately 90% full and must have tight sealing caps or lids (no Parafilm®). Wastes that are not packaged according to these specifications will not be managed by IUEHS until corrected.
Consolidating waste into fewer containers can seem efficient, and can save space, resources, and even cost if done properly. However, it can lead to increased costs and increased safety risks if the guidelines below are not followed:
- Do not mix incompatible materials together in the same waste container. Attachment C provides more information on compatibility.
- Oxidizers, strong acids (such as nitric and perchloric), and any water-reactive material, should never be consolidated with other waste at any concentration.
- When possible, different wastes (solids vs. liquid, solvents vs. aqueous) should be accumulated in separate waste containers. This does not preclude mixing wastes that could obviously be mixed together, such as compatible solvent waste.
- Do not mix high hazard rated materials with low hazard rated materials as wastes if the experimental procedure does not require it. Doing so may inadvertently create a large quantity of regulated hazardous waste where a much lower quantity may have existed otherwise.
- If you don’t have a need to consolidate, are unsure whether or not your waste is compatible with the waste in your waste accumulation container, or your waste accumulation container is poorly labeled – don’t consolidate.
Note: Never assume the contents of unknown or poorly labeled containers, and never consolidate unknown or unidentified wastes with other waste materials.
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 guidelines must be practiced to ensure safety and compliance.
- Ensure waste containers are appropriate and in sound condition.
- Keep containers closed at all times, unless actively adding waste.
- Do not put corrosive waste in metal containers, as the containers will corrode and leak as well as evolve flammable hydrogen gas.
- Accumulate non-solvent waste streams (acids, metals, etc.) separately from solvents. Solvents should be free of all other wastes, including aqueous wastes and water not mixed during the same procedure.
- Separate incompatible materials. Acids must be kept separate from bases and cyanides, organic material separate from oxidizers, etc. Refer to Attachment C for more information on chemical compatibility.
- 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.
- Keep ignitable waste away from ignition sources.
- Check product Safety Data Sheets (SDS) for information on ingredients and other hazard information to ensure proper storage.
- Do not accumulate or store waste containers outdoors.
- Label the container immediately upon adding chemicals to the container.
- Full or ready to dispose of wastes shall be properly maintained in the department accumulation area. IUEHS staff will assist staff and help coordinate chemical waste disposal activities on a periodic basis. Should you have waste materials that are in immediate need of disposal, please contact IUEHS for your respective campus.
- Manage the waste in the accumulation area so that the total quantity of chemical waste (unless designated as non-hazardous by this Guide or IUEHS) remains under 55 gallons at all times.
Note: If you are approaching 55 gallons of waste in the accumulation area and a waste pickup is not scheduled within 72 hours, notify IUEHS immediately.
Once a waste accumulation container is full or a chemical has been determined to be a waste chemical, it should be placed in the designated accumulation area and presented to IUEHS for disposal as soon as reasonably possible.
Advise the Laboratory Safety Coordinator for your school/department when the accumulation container or waste chemical is placed in the designated accumulation area (provide information on container type, its contents and the quantity of material). Please keep in mind time limits provided for some waste types in the Management of Specific Waste Types and the Hazardous Generator Table below. Storing waste past these time limits can result in regulatory citations for the University.
Each regional campus maintains its own generator status with the Indiana Department of Environmental Management. The Hazardous Generator Table summarizes restrictions/limitations/time limits for various generator statuses. Contact IUEHS for more information about the generator status for your respective campus and any restrictions/limitations/time limits that may apply. IUEHS personnel will frequently check-in with Laboratory Safety Coordinators to facilitate compliance.
- Dispose of waste in a timely manner. IUEHS offers ample opportunities for disposal. Safety and compliance is maximized when waste is disposed of on a regular basis.
- At the time you present your waste to IUEHS for disposal, make sure that it is properly packaged and labeled. IUEHS will not accept waste that is not properly packaged, labeled, and dated.
|Hazardous Waste (HW)||Acute Hazardous Waste (AHW)||Accumulation||Time Limit|
|Conditionally Exempt Small Quantity Generator (CESQG)||Generates no more than 100 kg (220 lbs) of HW in a month||Generates less than 1 kg (2.2 lbs) of AHW in a month and less than 100 kg (220 lbs) of material from the cleanup of a spillage of AHW||Accumulates less than 1,000 kg (2,200 lbs) of HW, less than 1 kg (2.2 lbs) of AHW, and less than 100 kg (220 lbs) of material from the cleanup of a spillage of AHW||NONE|
|Small Quantity Generator (SQG)||Generates more than 100 kg (220 lbs) but less than 1,000 kg (2,200 lbs) of HW in a month||Generates less than 1 kg (2.2 lbs) of AHW in a month and less than 100 kg (220 lbs) of material from the cleanup of a spillage of AHW||Accumulates less than 6,000 kg (13,200 lbs) of HW, less than 1 kg (2.2 lbs) of AHW, and less than 100 kg (220 lbs) of material from the cleanup of a spillage of AHW||180 days|
|Large Quantity Generator (LQG)||Generates 1,000 kg (2,200 lbs) or more of HW in a month||Generates 1 kg (2.2 lbs) or more of AHW in a month and more than 100 kg (220 lbs) of material from the cleanup of a spillage of AHW||Accumulates 1 kg (2.2 lbs) or more of AHW and 100 kg (220 lbs) or more of material from the cleanup of a spillage of AHW||90 days|
IUB Non-Laboratory Waste Management
Non-laboratory operations, such as facilities maintenance, information technology support, and academic or administrative offices, often generate similar types of waste. This section outlines the general requirements for managing non-lab waste materials. Additional guidance on handling and disposal of specific waste types is found in the following section.
A list of common waste types at IU facilities can be found in the Management of Specifice Waste Types seciton of this document. 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, steps 2-6 of this section must be followed for all wastes.
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 contents information must be added as additional waste is added. IUEHS requires that you use the Waste Chemical Label. IUEHS will provide Hazardous Waste Labels, as needed.
Unless otherwise stated in this Guide, waste containers should not be dated until you are ready to present them to IUEHS. 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 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 the Management of Specifice Waste Types seciton of this document, under each specific waste type for these special rules.
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:
Ensure waste containers are appropriate and in sound condition.
Keep containers closed at all times, unless actively adding waste.
Do not put corrosive waste in metal containers, as the containers will corrode and leak as well as evolve flammable hydrogen gas.
Accumulate non-solvent waste streams (acids, metals, etc.) separately from solvents. Solvents should be free of all other wastes, including aqueous wastes and water not mixed during the same procedure.
Separate incompatible materials. Acids must be kept separate from bases and cyanides, organic material separate from oxidizers, etc. Refer to Attachment C for more information on chemical compatibility.
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.
Keep ignitable waste away from ignition sources.
Check product Safety Data Sheets (SDS) for information on ingredients and other hazard information to ensure proper storage.
Do not accumulate or store waste containers outdoors.
Label the container immediately upon adding chemicals to the container.
Full or ready to dispose of wastes shall be properly maintained in the department accumulation area. IUEHS staff will assist staff and help coordinate chemical waste disposal activities on a periodic basis. Should you have waste materials that are in immediate need of disposal, please contact IUEHS for your respective campus.
Containers must be packaged properly to be accepted by IUEHS.
For containers <5 gallons:
Each container must have a properly completed, signed, and dated Waste Chemical Label attached securely.
The Waste Chemical Label must list all of the ingredients of the waste and their percentages. The percentages must add up to 100%. No acronyms or abbreviations are to be used on the Waste Chemical Label.
An SDS may be attached to the container along with the Waste Chemical Label 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.
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 chemical, it should be placed in the designated accumulation area and presented to IUEHS for disposal as soon as reasonably possible. Advise IUEHS for your respective campus when the accumulation container or waste chemical is placed in the designated accumulation area (provide information on container type, its contents and the quantity of material). Please keep in mind time limits provided for some waste types in the Specific Waste Types section and the Hazardous Waste Generator Table. Storing waste past these time limits can result in regulatory citations for the University.
Each regional campus maintains its own generator status with the Indiana Department of Environmental Management. The Hazardous Waste Generator Table summarizes restrictions/limitations/time limits for various generator statuses. Contact IUEHS for more information about the generator status for your respective campus and any restrictions/limitations/time limits that may apply.
• Dispose of waste in a timely manner. IUEHS offers ample opportunities for disposal. Safety and compliance is maximized when waste is disposed of on a regular basis.
• At the time you present your waste to IUEHS for disposal, make sure that it is properly packaged and labeled. IUEHS will not accept waste that is not properly packaged, labeled, and dated.
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 listed in Attachment A. If a material that you want to neutralize is not listed in Attachment A contact IUEHS for approval.
- Concentrated acids
- <25 ml and approved for sewer disposal in Attachment A - Follow neutralization procedures or dispose directly with IUEHS.
- >25 ml or not approved for sewer disposal – Dispose directly with IUEHS.
- Dilute acid solutions or concentrated or dilute base solutions with no toxic metals
- Approved for sewer disposal in Attachment A - Follow neutralization procedures or dispose directly with EHS.
- Not approved for sewer disposal – Dispose directly with IUEHS.
- Dilute acid solutions or concentrated or dilute base solutions containing toxic metals
- Dispose directly with IUEHS. Many toxic metals are regulated hazardous wastes at very low concentrations, and IUEHS 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 IUEHS 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 IUEHS. 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 containing materials (ACM’s) are commonly found in older University buildings. Examples can include floor tiles, pipe insulation, plaster and caulk. The presence of asbestos in a building does not mean that occupant health is at risk. As long as ACM’s remain in good condition, exposure is unlikely.
Do not remove or disturb asbestos containing materials. If asbestos or asbestos containing materials are found, immediately report the nature and location of the material to IUEHS for evaluation. Whenever possible, isolate the asbestos containing material by restricting access to the area in which it is found.
- Aqueous Solutions of Toxic Metals
All aqueous solutions containing the following toxic metals must be disposed of by IUEHS:
Ballasts are used in fluorescent bulb light fixtures. Ballasts from lighting maintenance activities may contain polychlorinated biphenyls (PCB). The other two types are non-PCB and electronic ballasts.
PCB ballasts contain a toxic liquid and are regulated by EPA’s Toxic Substance Control Act (TSCA). Only ballasts manufactured before 1979 contain PCB. All ballasts should be inspected for a marking that states in some way that the ballast does not contain PCB. If no such wording is located, the ballast(s) must be referred to IUEHS for disposal. Non-PCB ballasts can be discarded as trash or scrap metal. See also: Polychlorinated Biphenyls
Non-PCB ballasts can be discarded as general refuse or salvaged for scrap metal if an outlet is available. IUEHS does not manage or dispose of these.
Electronic ballasts contain a Ni-Cad battery that must be removed. Refer the battery to IUEHS for disposal. Discard the ballast as general refuse or salvage metal scrap. IUEHS does not manage or dispose of these.
Most batteries are regulated by the Environmental Protection Agency as Universal Waste, which are special regulations for hazardous waste batteries designated for recycling. However, University operations that sporadically generate spent batteries from laptops, cell phones, or other electronic devices should segregate batteries by type. Most batteries are marked with a symbol or abbreviation that indicates battery type. Manage batteries in the following manner:
Alkaline – Unfortunately there is limited net value to recycling alkaline batteries. These are not regulated, and can be discarded in the general refuse (trash). Some regional campus facilities have collection containers where these can be deposited for disposal separate from general refuse (trash).
For the following battery types, tape the terminals and dispose through IUEHS or Facility Services/Physical Plant (FS/PP), as appropriate, for your respective campus.
If collecting batteries for recycling in a container over a period of time, follow Universal Waste rules for labeling and accumulation time limits.
- Biological Materials
Biological materials, including unfixed human or animal tissue, must be treated according to approved protocols (either autoclave or chemical disinfectant) before disposal. Autoclave indicator tape must be used and the universal biohazard symbol must be defaced to confirm that the waste has been treated. Biological materials and fixed tissues that are chemically treated or otherwise mixed with chemicals must be referred to IUEHS for waste disposal. Refer to the IU Biosafety Manual for disposal procedures for biological materials for more information.
Cardboard recycling at the regional campuses is part of the larger recycling effort coordinated by FS/PP and/or sustainability committees.
Cardboard that is grossly contaminated with chemical(s) that exhibit flammable, corrosive, reactive and/or toxic characteristics must be placed in a sealed container and disposed through IUEHS following the general procedures above, as appropriate.
- Chemical Waste
Since IUEHS determines which chemicals are regulated as hazardous waste, all unwanted chemicals must be managed as hazardous waste when discarded unless specific instructions in this Guide or IUEHS personnel state otherwise (see Annex 1).
Departments that generate hazardous chemical waste must follow Satellite Accumulation Area Requirements (Attachment B). All IUEHS general requirements for waste management must also be followed. Discard chemical waste often to avoid deterioration of containers and labels.
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.
Follow all general requirements in the non-laboratory section of the document for any of the above materials or any other chemical product to be discarded, and check this section for any additional requirements for specific waste types.
- 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 IUEHS 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 plastic bag which can be placed conveniently inside a 5-gallon plastic bucket. The bag should be at least 2ml thick. Close the bag with a rubber band, twist tie, or by tying the top when it is full, and label the Waste Chemical Label as "chemically contaminated items" or "CCIs" and list all chemical contaminants. Call IUEHS if you have any questions.
Note: All PCB contaminated materials at ³50 ppm must be packaged separately, and referred to IUEHS for disposal with the PCB concentration clearly indicated on the Waste Chemical Label.
- 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 IUEHS for disposal. Indicate on the cylinder whether it is at atmospheric pressure, or if it is above 1 atmosphere of pressure.
- 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. If for any reason controlled substances cannot be witness-destroyed on site by the original registrant, arrangements need to be made in advance with IUEHS. IUEHS 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 for controlled substances on-site destruction or disposal. See the IU Controlled Substances Program for Research (Non-Practitioners).
- 2, 4-Dinitrophenol
This chemical (2, 4-DNP or α-Dinitrophenol) poses an explosive hazard when it becomes dry. It must be wetted to at least 15% water for shipment. Thus, this chemical must never be stored in a desiccator or under any other conditions that would allow for the material to dry out such as storing it for an extended period of time. Unwanted 2, 4-DNP must be disposed of in a timely manner. Do not touch 2, 4-dinitrophenol that appears old or dried out. You must contact IUEHS, and we will come evaluate the material.
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. If equipment is crushed and leaking, contact IUEHS for guidance. Most e-waste is currently managed at the regional campuses by Indiana University Information Technology Services (UITS). Examples of common e-waste at regional campuses include:
- Computer monitors,
- Mobile phones,
- Video equipment,
- Speakers, and
- Empty Containers
Bottles and containers are considered “empty” when you have removed all contents possible by normal means (pouring, scooping, etc.). There may still be some residue clinging to the inside walls of the container, but these may be placed in the normal trash. Punch a hole in 5-gallon metal containers or safety cans that are no longer needed, and place directly in the normal trash dumpster. This will prevent their reuse.
Empty Container Management Guidance Table
Hazardous/ Chemical/ Pharmaceutical
Pour out all free liquid.Remove lid.Allow residue to dissipate under hood.Remove all hazard warning labels.Put in sealed box.Dispose of box in regular trash.
Pour out all free liquid.Remove lid.Allow residue to dissipate under hood.Remove all hazard warning labels.Put in sealed box.Dispose of box in regular trash.
Label and dispose with IUEHS.
Acutely Hazardous(P-Listed) Waste
Label and dispose with IUEHS.
Dispose as biological waste. See IU Biosafety Manual for more information.
Arrange return to vendor. See Compressed Gas Cylinder Safety Program for more information.
Label and dispose with IUEHS. See Compressed Gas Cylinder Safety Program for more information.
Label and dispose with IUEHS
Purge according to manufacturer’s guidelines and remove valve, mark as empty, refer to IUEHS.
Label and dispose with IUEHS.
- 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 IUEHS for disposal as chemical waste.
- Explosive or Shock-Sensitive Chemicals
A number of relatively common chemicals can become unstable and pose an explosion hazard when dried out, stored improperly or stored for extended periods. These materials require special handling. By adhering to IUEHS approved practices, the threat inherent to these materials can effectively be controlled. IUEHS asks that each department carefully review and adhere to the practices listed for each of the following: 2, 4-Dinitrophenol, Peroxide Formers, Picric Acid and Sodium Azide.
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, IUEHS must contract special services for stabilization, transportation and disposal at an extremely high cost. If you have potentially explosive or shock-sensitive chemicals for disposal, contact IUEHS for assistance.
- Fluorescent Light Bulbs
Mercury containing lamps such as compact fluorescent, UV or projector lamps may be referred to IUEHS for disposal. Broken mercury lamps are considered hazardous waste. If broken on a non-carpeted floor, the lamp should immediately be swept up with a broom and dust pan, collected into an airtight plastic bag, labeled, and referred to IUEHS for disposal.
- 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.
- Glycol Solutions
Propylene glycol can be drain disposed to the sanitary sewer in accordance with the sewer disposal guidelines found in this Guide. Ethylene glycol must be referred to IUEHS for chemical waste disposal.
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. Contact IUEHS for more information on handling and disposal.
IUEHS 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 or a secured plastic bag and refer to IUEHS for proper management.
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.
- 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. IUEHS 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 IUEHS the type and volume of chemical disinfectant used. More information can be found in the IU Biosafety Manual.
- Nonhazardous Waste
Most chemical waste is handled by IUEHS. 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 IUEHS 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, must be referred to IUEHS or FS/PP, as appropriate for your respective campus for recycling. Any used oil that is contaminated with other chemicals must be accurately described and disposed as a chemical waste through IUEHS.
If the oil contains PCB, the generator must indicate such on the label and as part of the chemical description on the Waste Chemical Label. 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
A variety of chemicals can form highly explosive peroxide compounds when exposed to air. Peroxides are sensitive to heat, friction, impact, and light and are among the most hazardous chemicals encountered in the laboratory. Care must be taken to prevent the formation of peroxides in these chemicals.
Preventing the formation of peroxides is dependent on inventory control of peroxide-forming chemicals. Most of these materials are distributed with inhibitors to drastically slow peroxide formation. These are usually effective until the container is first opened. To prevent peroxide hazards, peroxiding-forming chemicals must be dated both upon receipt and upon opening. These materials must also be discarded as waste through IUEHS within the timeframes listed below.
The material must be less than twelve months old. This information must be marked clearly on the Waste Chemical Label.
If the material is greater than twelve months old but less than two years old, check for peroxide formation by using peroxide test strips. If peroxide formation is detected, mark the test result in parts per million (PPM) on the Waste Chemical Label, along with the date tested. Request a waste pick-up immediately. If peroxide formation is greater than 100 ppm, immediately call IUEHS 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; security of the seal; and exposure to changes in temperature. 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 IUEHS immediately 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 IUEHS 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
- Pesticides and Residues
Pesticides are regulated by the EPA under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA). This regulation restricts the distribution, sale and use of pesticides. Certain “restricted use” pesticides can only be applied by individuals who are certified and trained. Un-used toxic pesticides and their residues should not be thrown away or poured into the drain. All toxic pesticides and containers with pesticide residues must be referred to IUEHS for waste chemical disposal.
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
Picric acid, also known as trinitrophenol, is commonly used in laboratories. This compound is relatively stable in the form in which it is commercially distributed. It is ordinarily sold with 10% water added to stabilize it. However, picric acid can become explosive when allowed to dry out, or when it forms certain metal salts. The following steps should be taken to safely handle and store picric acid.
- Never allow picric acid to be stored in containers with metal lids, or to come into contact with any metal.
- Add water as needed to containers of picric acid to prevent the material from drying out. Never place picric acid inside a desiccator!
- Never attempt to open an old or dried out container of picric acid. This material must be referred to IUEHS for evaluation and disposal immediately.
If you are using other polynitroaromatic compounds, contact IUEHS for information on handling and storage.
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. IUEHS manages and disposes 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 IUEHS 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.
Regional campuses have single-stream recycling for many items including plastics, paper, aluminum cans, steel and tin containers and cardboard. Labeled bins can be found in buildings throughout campuses. Contact FS/PP or the sustainability committee for your respective campus for more information on recycling efforts.
- 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 prior to disposal.
Also, ensure that all chemical containers, specimens, etc. have been removed from refrigerators and freezers. Dispose waste chemical items according to this Guide. Ensure all refrigerated equipment used for biological, chemical or radioactive purposes is fully decontaminated and deface any of hazard markings before making arrangements for pick-up.
All sharps must be stored in appropriate, rigid containers that guard against puncture and injury. Potentially infectious or biologically contaminated sharps must be treated through autoclave before discarding into campus trash. Autoclave indicator tape must be used and the universal biohazard symbol must be defaced to confirm that the waste has been treated.
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.
- Sodium Azide
Sodium Azide, although not inherently unstable, may form highly explosive heavy metal azides if contaminated or used improperly. Disposal of sodium azide solutions to the sewer may lead to the formation of lead or copper azide in plumbing. Several serious explosions have occurred as a result of improper disposal of sodium azide. Care should also be taken that sodium azide is not heated rapidly or stored in containers with metal lids.
See: Explosive or Shock-Sensitive Chemicals
- Spill Debris
For liquid spills that meet all of the reporting exception criteria listed in the Spill Response Section of this Guide, absorb with spill pads or disposable towels 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 paper or cloth towels or spill pads.
For spills involving material that must be managed by IUEHS, the debris must be in a closed container labeled 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.
Refer all strong oxidizers and reducers to IUEHS for disposal. Keep these items separate from each other, and box separately when disposing.
- Chromic acid (fresh)
- Metallic chlorates
- Metallic nitrates
- Metallic perchlorates
- Metallic permanganates
- Perchloric acid
- n-Butyl lithium
- Sodium hydride
- Metallic sulfides
- Calcium hydride
- Stannous chloride
- Temperature Controlled Substances
Some chemicals must be stored at constant, low temperatures to maintain their stability or integrity. These can include organic peroxides, self-reactive solids, and highly volatile compounds that must be kept cold in order to prevent thermal decomposition, fire and explosion, or container pressurization. For temperature controlled substance waste disposal:
- Keep the material in appropriate cold storage according to the manufacturer.
- Note the required temperature range needed to maintain stability of the waste and the specific location of the waste when contacting IUEHS for disposal.
- You must store potentially flammable materials in specialized refrigerator/freezers. These materials are prohibited from storage in regular, household-type refrigerator/freezer units.
- 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.
General Rules for Management of Universal Waste Batteries
These rules apply to maintenance areas where batteries may be stored before proper recycling/disposal. The general requirements for Universal Waste Batteries are:
- Inspect batteries for condition issues such as corrosion, cracks or leaking. Regulations require that leaking batteries must be placed in a closed container with tight-fitting lid. Batteries with no condition issues can be placed in an open container.
Note: Large lead-acid batteries found in vehicles and forklifts are not completely sealed at the top (they are “spillable”); thus they must be stored upright. Do not store spillable batteries outdoors or near floor drains. These batteries contain sulfuric acid. If a lead-acid battery tips over and spills, follow campus emergency procedures for chemical spills.
- Label each battery or battery container with words “Universal Waste”, and a description such as “Spent Battery” or “Used Batteries”, as soon as the first battery is collected - or first goes into the container.
- Date - Each battery or container must be marked with the date that the first battery was collected and/or put into the container.
- Dispose - Each battery or container must be shipped off-site to an authorized Universal Waste handler within 12 months of the above date. To ensure compliance with this regulation, all Universal Waste batteries must be referred to FS/PP or IUEHS as appropriate for your respective campus.
General Rules for Universal Waste Bulbs:
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 standard mercury bulbs by their green end-caps or other markings. Collecting green lamps along with regular lamps for Universal Waste recycling is encouraged, but not required.
- All bulbs must be stored in a closed container to protect against breakage as soon as they are collected.
- Use boxes that the bulbs came in or round fiber drums provided by the disposal vendor. Make sure to use a box or drum that is long enough to fully cover the entire length of the bulbs in the container.
- 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 within 12 months of the above date 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. Refer all broken lamps to IUEHS for disposal in a closed container with a Waste Chemical Label that states “Broken Mercury Bulb Debris”.
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, it will result in a more costly disposal for the University, and ultimately to you as the generating campus/department/individual.
- Vacuum Pump Oil
Uncontaminated vacuum pump oil should be referred to FS/PP or IUEHS as appropriate for your respective campus. 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)”. Contaminated pump oil must be referred to IUEHS for disposal as a waste chemical.
See also: Oil