All waste must be evaluated to determine whether or not it is regulated as a “hazardous waste” under the Environmental Protection Agency’s (EPA) Resource Conservation and Recovery Act (RCRA). Through RCRA regulations, EPA requires that all hazardous waste be properly identified, labeled, stored, treated and disposed. From a regulatory standpoint, the United States Environmental Protection Agency (EPA) and the Indiana Department of Environmental Management (IDEM) defines a hazardous waste as:
- A listed hazardous waste (specifically identified by an alpha-numeric code from one of four lists maintained by EPA), or
- Waste that exhibits certain hazardous characteristics (also identified with an alpha-numeric code) as determined by standardized testing procedures.
IUEHS always makes the determination as to whether or not a waste is regulated by RCRA. Often, this is based on information provided on the waste container. Safety Data Sheets (SDS) can be used to help determine whether or not expired or discarded commercial products are regulated as hazardous waste. Occasionally, a waste sample must be analyzed to obtain more detailed information before a determination can be made. Annex 1 details the RCRA regulatory requirements under which IUEHS makes hazardous waste determinations.
For practical purposes, IU employees should manage all chemical waste as hazardous unless otherwise specified in this Guide; or IUEHS has specifically made an evaluation and determined that a waste can be managed in another way. It is important to note that some wastes are restricted from sewer or landfill disposal even if they are not regulated by RCRA as hazardous waste. Specific disposal guidance for the most common waste streams generated at IU can be found throughout this Guide.
It is also important to understand the following key concepts:
- Satellite Accumulation Areas (SAAs) are what EPA calls individual locations, including laboratories, where hazardous waste is generated. The requirements for SAAs can be found in Attachment B.
- Indiana University facilities are subject to routine, unannounced regulatory inspections on an intermittent basis. IDEM typically conducts these inspections; however the EPA also has this authority. Inspectors visit SAAs as part of the inspection process. Always be courteous and cooperative with regulatory inspectors if they visit your area.