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 variety 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.

Identify and Label

All waste must be identified and labeled!

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. Tags should not be dated until the container is ready to transfer to IUEHS. IUB provides a printable waste tag template that must be used to identify waste materials and to fulfill IU’s waste minimization obligations. 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:

  • A printable template for IUB EHS can be found at this link: Waste Chemical Tags (“tags”).

  • 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, twist tie, or tape. 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 it is presented to IUEHS to be emptied and the completed tag is provided to IUEHS. Neither the Hazardous Waste Label nor the waste tag should be dated until the container is ready to transfer to IUEHS.

  • 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 when the waste is ready to transfer to IUEHS.

  • Do not date your tag until it is ready for disposal through a waste collection or IU B 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 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.

IUB EHS Hazardous Waste Label

Hazardous waste label

Non-laboratory operations, such as facilities maintenance, information technology support, and academic or administrative offices, are distinctly different from laboratories in the types and quantities of waste that they generate as well as the physical facilities and locations on campus. 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 specific waste types section of this guidance document.

IUB Management of Specific Waste Types

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 identified in the In-Lab Disposal Options section of the guide 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 guide or dispose directly with IUB EHS.
    • Not approved for sewer disposal – Dispose directly with IUB EHS.
  • Dilute acid solutions or concentrated or dilute base solutions containingtoxic metals
    • Dispose directly with IUB EHS. All toxic metals ingredients must be identified on the waste chemical tag. Many toxic metals are regulated hazardous wastes at very low concentrations, and IUB EHS must make that determination. See Aqueous Solutions of Toxic Metals tab below for a list of metals that cannot be sewer disposed.

Note: Nitric and perchloric acids are not approved for neutralization or consolidation at any concentration.

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, after consulting the SDS for the material to ensure the air duster does not contain flammable propellants. All aerosol cans for disposal with IUB EHS must have a completed tag or date label.

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
  • Bromine
  • Phosphorus (yellow)
  • Thionyl chloride
  • Calcium metal
  • Potassium metal
  • Trichlorosilane

Refer to the IU Biosafety Manual for disposal procedures for animals and animal care related 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 IUB EHS for evaluation. Whenever possible, isolate the asbestos containing material by restricting access to the area in which it is found.

All aqueous solutions containing the following toxic metals must be disposed of by IUB EHS:

  • Aluminum
  • Chromium
  • Nickel
  • Arsenic
  • Copper
  • Selenium
  • Barium
  • Lead
  • Silver
  • Cadmium
  • Mercury*
  • Zinc

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 lamp ballasts in use at IUB:

PCB Ballasts

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

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

Electronic ballasts are essentially non-PCB ballasts that contain a Ni-Cd battery. The batteries must be removed and disposed through Facility Operations. These ballasts can be disposed in the regular trash or salvaged for scrap. IUB EHS does not collect these ballasts.

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 managing them separately.

See Universal Waste for more information.

General Rules for Universal Waste Batteries:

  • 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. A printable label template is available online at http://www.ehs.iu.edu/topics/waste-management/chemical-waste/waste%20label%20templates.shtml.
  • 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

Facility Operations manages battery disposal at IUB. 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. Contact Building Services for a recycling container or for more information.

Note: While EHS does not manage the accumulation and collection of 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.

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. “Cardboard Only” dumpsters are located at the receiving docks of many campus buildings. A Recycling 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 in the general procedures for laboratories.

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 from IUB EHS personnel state otherwise. Areas that generate hazardous chemical waste must follow the Satellite Accumulation Area Requirements in Attachment B, as well as, all IUB EHS general requirements for waste management identified in this guide. 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.

Laboratory Operations

Follow all general requirements for any chemicals or chemical wastes to be discarded, and check for any additional requirements for specific waste types.

Non-Laboratory Operations

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 for any of the above materials or any other chemical product to be discarded, and check Section 5.3 for any additional requirements for specific waste types.

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 IUB 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-size plastic bag, at least 2-ml thick (obtained through the Chemistry or Biology stores). These bags can be placed conveniently inside a 5-gallon plastic bucket for in-lab accumulation. Remove the bag from the bucket and close with a rubber band, twist tie, zip tie, or by tying the top when it is full. Label the Waste Chemical Tag as “chemically contaminated items” or “CCIs” and list all chemical contaminants. Contaminated concentrations can be listed as “trace”. 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 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 fuel bottles must be referred to IUB EHS for disposal. Indicate on the cylinder whether it is at atmospheric pressure (empty), or if it is above 1 atmosphere of pressure (not empty). See cost recovery for additional information regarding potential charges for disposable cylinders.

See also: Aerosols tab

Contractors may generate a variety of wastes during construction and renovation projects. It is the responsibility of the contractor to ensure that these wastes are accumulated on site in accordance with all applicable regulations, and disposed properly by the time the project closes. However, in the case of regulated wastes, IUEHS reserves the right to approve or reject proposed disposal methods and/or facilities. For hazardous waste (such as lead paint debris), universal waste, and PCB waste, IUEHS must be provided with signed disposal documentation within five days of receipt by the designated disposal facility. For hazardous waste disposal, a representative of IUEHS must be contacted to sign the Uniform Hazardous Waste Manifest unless the contract specifically designates the contractor as an agent of Indiana University for purposes of signing manifests.

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 has been made, 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 the case of abandoned materials or deceased registrant), IU Police and the local DEA office to arrange for on-site destruction or disposal.

See: Explosive or Shock-Sensitive Compounds.

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
  • Printers
  • Mobile phones
  • Video equipment
  • Speakers
  • Laptops

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
Contamination TypeResidue AmountContainer TypeHandling Procedure
Non-Reactive/ Chemical/ PharmaceuticalMinimal/ NoneGlassRemove 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.
Minimal/ NonePlasticRemove and discard lid. Pour out all free liquid. Allow residue to dissipate under hood.
Deface labels and dispose in regular trash.
Gross ContaminationAllTag and dispose with IUB EHS.
Air or Water-Reactive ChemicalAnyAllPurge container so that residue is eliminated or no longer reactive, deface labels, and dispose in regular trash.
Put sealed box for trash disposal if the container is glass
OR
Tag and dispose with IUB EHS
Acutely Hazardous (P-Listed) WasteAnyAllTag as “empty container, last contained ________” and dispose with IUB EHS
BiologicalAnyAllDispose as biological waste.
RadioactiveAnyAllDispose as radioactive waste
GasAnyReturnable CylinderArrange return to vendor**
GasAnyNon-Returnable CylinderTag and dispose with IUB EHS*
Gas/Pressurized liquidAnySure-PackTag and dispose with IUB EHS*
Gas/Pressurized liquidNoneSure-PackPurge according to manufacturer’s guidelines and remove valve, mark as empty, give to IUB EHS.
AerosolsAnyAerosol canTag 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 is a strong mutagen that, in its pure powder form, is also highly toxic by inhalation. Although solutions at the concentrations typically used in electrophoresis are relatively low toxicity, ethidium bromide preparations including stock solutions and gels are collected by IUB EHS for disposal as chemical waste.

Solutions, gels, and contaminated solids such as filter paper, gloves, and pipette tips, must be accumulated separately. Solutions and gels must be accumulated and disposed in rigid containers, while contaminated solids may be accumulated in plastic bags for disposal. One-gallon wide-mouthed plastic jars and five-gallon plastic buckets are available from IUB EHS for waste accumulation.

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:

  • Peroxide-forming agents past the holding times indicated in section 3.17 of the Chemical Hygiene Plan (especially if they are in degraded containers or have been exposed to heat, light, or air),
  • Distilled peroxide forming agents,
  • Diazo compounds,
  • Dinitro compounds,
  • Hydrazine compounds,
  • Nitrocellulose,
  • Dry picric acid, and
  • Trinitrotoluene.

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. Bulbs that are not “green” must be managed as Universal Waste. Collecting green lamps along with regular lamps for Universal Waste recycling is encouraged, but not required. Bulbs that are not “green” must be managed as Universal Waste.

See: Universal Waste for more information.

General Rules for Universal Waste Bulbs:

  • All used 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. Fill containers carefully to avoid breaking bulbs.
  • 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. A printable label template is available online at http://www.ehs.iu.edu/topics/waste-management/chemical-waste/waste%20label%20templates.shtml.
  • 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. Follow the general requirements set out in Section 5.2 of this Guide for management and disposal of hazardous waste.

*The bulb cleanup procedure can be found at the IUB EHS website.

Disposal of Fluorescent Bulbs at IUB by location:

  • Facility Operations - bulbs from fixture lighting in areas maintained by Facility Operations 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 Facility Operations 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 or contractor responsible for the area or building, and shipping documents must be available to IUB EHS upon request.
  • 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 a 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.

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 autoclave indicator tape placed on them in order to confirm they were autoclaved prior to disposal in the general trash. Biohazard symbols must be completely marked out or removed.

Dust forming materials must be containerized to eliminate release in the dumpsters and/or compactors.

Glass, whether intact or broken, should be disposed in a rigid container such as a cardboard box unless it is placed in “Glass Only” dumpster. Boxes that contain broken glass must be marked with the words “Broken Glass” highly visible on the outside of the container before they are placed into a general use dumpster. Broken glass accumulation buckets are located in many labs that can be emptied into glass dumpsters. Ensure all glass bottles are empty and free of chemical residue before placing them into a dumpster or glass accumulation bucket.

Lead has many uses, and is common at IU. The most common lead wastes at IU outside of laboratories are lead paint debris, lead acid batteries, and lead sheeting.

Lead acid batteries are managed by Facility Operations. Lead sheeting should be recycled with a reputable metal salvage facility.

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 and tested for lead content by a reputable analytical laboratory prior to disposal. Lead paint debris is hazardous for lead content and must also be collected and disposed.

Mercury and mercury compounds are limited by the IU Mercury Reduction and Elimination Program, to approved essential uses. If you have mercury or mercury compounds that have not been approved, you must seek approval or dispose of them with IUB EHS.

Free-flowing metallic mercury must be accumulated in tightly sealed and leak-free containers.

Broken mercury thermometers should be placed in a one-gallon over-pack (obtainable from IUB EHS) or a secured plastic bag and bring to dispose with IUB EHS. Spirit, or other non-mercury, thermometers should be used whenever possible to avoid the contamination and exposure issues associated with mercury.

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:

  • Thermostats,
  • Thermometers,
  • Barometers,
  • 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.

See Universal Waste for more information.

General Rules for Universal Waste Mercury Devices:

  • 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. A printable label template is available online at http://www.ehs.iu.edu/topics/waste-management/chemical-waste/waste%20label%20templates.shtml.
  • 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 must be requested for all containers once their dates reach 9 months. Pickups can be requested online at the IUB EHS website. EHS may inspect accumulation areas periodically to insure compliance with Universal Waste requirements.

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 decayed in-lab according to IUB Radiation Safety protocols first. If you will be generating a radioactive mixed waste with a long-lived isotope, you must contact IUB EHS before you begin generation or as soon as you know you have it if it was unintentional. All waste containers must be fully and accurately labeled with the date of generation, the isotope, and the chemical or biological components.

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 or fixative that is chemically compatible with the waste such as ethanol, bleach, formalin, etc. The generator of the waste must certify that it has been disinfected, and communicate with IUB EHS the type and volume of chemical disinfectant or fixative used.

Laboratory Operations

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
  • non-toxic.

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.

Non-Laboratory Operations

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. Oil containers must be labeled as “used oil” while being accumulated.

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

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.

For lead-based paint chips, see: Lead

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 agents. Most of these materials are distributed with inhibitors to drastically slow peroxide formation. Inhibitors are usually effective until the container is first opened. To prevent peroxide hazards, the storage and use guidelines in section 3.17 of the Chemical Hygiene Plan (CHP) must be followed for all potential peroxide-forming chemicals identified in Appendix B of the CHP. These materials must be disposed through IUB EHS in accordance with the following restrictions.

  • All Class A peroxide-forming agents must be disposed of within 3 months of opening or by the expiration date for unopened containers. Contact IUEHS to schedule a pick-up.
  • Class B or C peroxide-forming agents be disposed within 12 months of opening or by the expiration date on the label. This information must be marked clearly on the Waste Chemical Tag.
  • For all peroxide-forming agents, if the material is transferred from the original container to another container and is not used immediately, the second container must be marked with the date that the original container was opened. These containers must follow the same disposal time limits as the original containers.
  • Distilled peroxide-forming agents that have not been used must be disposed at the first available opportunity following the standard disposal procedures outlined in this Guide.
  • If you have a peroxide-forming agent that falls outside the above guidelines or shows visible signs of container degradation or potential crystal formation, leave the container alone, and call IUB EHS for technical assistance.

* IUB EHS is required by our waste disposal vendor to test each container of peroxide-forming agent for peroxide formation. Any result >10ppm could be subject to treatment as a high hazard material for disposal at significantly increased cost. Additional costs incurred for disposal of peroxide-forming agents may be charged back to the lab if they result from mismanagement of the materials in the lab. See Section 5.4 of this Guide for more information on IUB EHS cost-recovery for high hazard materials.

See also: Explosive or Shock-Sensitive Chemicals

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.

In its solid form, picric acid can be explosive if it dries out sufficiently. Never store solid picric acid in a desiccator.

See: Explosive or Shock-Sensitive Chemicals

Dilute solutions of picric acid are not explosive, and may be disposed as chemical waste. (See: Chemical Waste).

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

All radioactive materials and waste must be handled and disposed in accordance with the IU Office of Radiation Safety policies and procedures.

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: https://facilityoperations.indiana.edu/services/building-services.html.

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 Facility Operations.

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 must be placed in appropriate, rigid containers that guard against puncture and injury (no Ziploc bags), 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 must be collected in puncture-resistant 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 procedures outlined in 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 must be packaged in puncture-resistant containers, labeled as “nonhazardous waste sharps” and sealed tightly. Dispose in the normal trash.
  • Uncontaminated glass sharps, must be packaged in a puncture-resistant container, labeled as “nonhazardous waste sharps”, and sealed tightly. Dispose in the normal trash. These sharps may be placed directly in glass dumpsters with no special labeling or container requirements, if one is available at your building. This category includes sharps that are minimally contaminated with non-reactive chemicals.

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
Contamination TypePackageLabelingDisposal
BiologicalSee IU Biosafety ManualSee IU Biosafety ManualSee IU Biosafety Manual
ChemicalClosed sealed box or plain (non-red) puncture resistant containerHazardous Chemical Waste
Tag with the description:
Sharps contaminated with: “________________”
Request pickup by IUB EHS or bring to a waste collection.
RadiologicalSee IUB Radiation Safety ManualSee IUB Radiation Safety ManualSee IUB Radiation Safety Manual
UncontaminatedClosed sealed box or plain (non-red) puncture resistant container or nonhazardous sharps bucket in lab“Non-hazardous Waste Sharps”
Or
“Non-hazardous Sharps – Solid Waste”
Take to building dumpster.

Amorphous silica gel is widely used at IUB as column packing media especially in the Chemistry department. IUB generates approximately one ton per year of used silica gel. IUB EHS has determined it to be nonhazardous, but it is dusty and has a nuisance odor if disposed in the dumpsters. Therefore, it is required to be disposed of through IUB EHS.

Used 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.

See: Explosive or Shock-Sensitive Chemicals

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.

Safety Can Use

  • Place your organic solvents in a safety can. The safety cans are reusable. They will be emptied by IUB EHS and returned to you. Very small generators can use other containers if a safety can is not practical. Be mindful of the fill line on the can. It is difficult to pour liquid from an overfull can without spilling.
  • 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. IUB EHS can provide a Hazardous Waste Label (figure 5B) for this purpose.
  • 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.

Note: Safety cans with broken springs or other defects make them no longer operable as safety cans. Inoperable can 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.
  • Unknowns
  • 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 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. If you have a safety can that contains stench compounds, and you want to keep it, IUB EHS can provide a 5-gallon bucket that you can take back to your lab and use your fume hood to transfer the contents. These wastes will not be poured in the IUB EHS waste processing area.

Wipes and rags contaminated with solvents are subject to hazardous waste exemptions in certain circumstances. Wipes and rags contaminated with common solvents like turpentine and mineral spirits may be disposed in the regular trash as long as they are not dripping liquid.

Note: Waste wipes and rags that contain solvents, oil based paints or oils should be placed in a covered metal container and taken to a dumpster at the end of each day to minimize odors and accumulation of combustibles.

Wipes and rags contaminated with one or more of these solvents:

AcetoneMethyl ethyl ketone
n-ButanolMethyl isobutyl ketone
ChlorobenzeneMethylene chloride
CreosolsTetracholoethylene
CyclohexanoneToluene
1.2-Dichlorbenzene1,1,2-Tricholorethane
Ehtyl acetateTrichloroethylene (*for reusable wipes only)
Ethyl benzeneXylenes
2-Ethoxyethanol
Isobutyl alcohol
Methanol

The above must be collected and accumulated according to the following guidelines:

  • They must be accumulated in your area in non-leaking containers that are closed at all times except when wipes and rags are being added.
  • The accumulation containers must be labeled with the words “excluded solvent-contaminated wipes” or with other words that accurately describe the container contents.
  • The containers must be shipped off-site for disposal within 180 days of the date that the first wipe or rag was placed in the drum. To ensure that this time limit is being heeded, IUEHS requires the containers to be dated when the first material is added, and for the containers to be transferred to IUEHS or to a reusable wipe/rag laundry service within 5 months.
  • Wipes and rags must not contain free liquids when they are offered for disposal.
  • If you use a laundry service for reusable wipes or rags, you must maintain the following information and make it available to IUEHS for inspection:
    • Name and address of the laundry service.
    • Shipment records showing that the 180-day accumulation time limit is being met.
    • A description of the process that you use to make sure that the wipes or rags contain no free liquids when shipped off-site.

For liquid spills that meet all of the reporting exception criteria listed in spill procedures section of the IU Waste Management 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 placed in a closed container with a Waste Chemical Tag described as “Spill debris containing _______.” with the identity of the material that was spilled filled in.

Some waste materials meet the definition of a hazardous waste, but the EPA provides an exemption if they are destined for recycling. These wastes are referred to as Universal Waste. They are subject to less stringent documentation and recordkeeping requirements as well as extended accumulation time limits. Generators of Universal Waste must still comply with rules for accumulation including segregation, labeling, and container management. See Fluorescent Bulbs, Batteries, and Mercury-Containing Devices for specific requirements for each waste type. IUEHS has chosen not to use the available 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 are non-hazardous such as dormant oils and insecticidal soaps, should be managed as chemical waste.

Attachment D contains some sample examples of labels that can be used to meet the labeling requirements. IUB EHS also has printable label templates available online.

Note: Spill debris from Universal Waste must be managed as a hazardous chemical waste through IUB EHS.

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.

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

Cost Recovery

IUB EHS changes auxiliary and administrative departments for the direct disposal costs of waste that they generate. Under normal circumstances, IUB EHS does not charge for the cost of waste handling and disposal services for academic or research groups. However, IUB EHS reserves the right to charge the department of any waste generator who incurs regulatory fines as a result of non-compliance with this Guide, or who require services that result in significant costs to IUB EHS or to the University as a whole. Services that commonly result in charges include:

Cylinder Disposal: 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 Disposal: 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 Disposal and Spill Response: 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.

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