IU Indianapolis Waste Management

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 EHS for chemical waste disposal. An exception to this would be non-flammable compressed air dusters, which can be discarded as general refuse, however consult the SDS for the material to ensure the air duster does not contain flammable propellants.

Dispose of all air and water reactive materials, such as those listed below, through EHS. Package liquids separate from solids, and note any special hazard and/or handling precautions on the Waste Pick-up Request Form.

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

Animal related materials such as waste food, water, bedding and animal carcasses should be handled through the Indiana University Laboratory Animal Research Center (LARC) unless the materials are contaminated with hazardous chemicals. Animal-related materials that are contaminated with hazardous chemicals must be referred to EHS for disposal. All chemical contaminants and potential biological hazards must be communicated to EHS by the generator.

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 EHS for evaluation. Whenever possible, isolate the asbestos containing material by restricting access to the area in which it is found.

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 collected for disposal through EHS. 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. EHS does not collect them.

Electronic ballasts contain a Ni-Cad battery that must be removed. Refer the battery to EHS for disposal. Discard the ballast as general refuse or salvage metal scrap. EHS does not collect 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 trash.

For the following battery types, tape the terminals and dispose through IUPUI EHS by submitting an online pick-up request:

• Lead-acid –Follow the chemical spill reporting procedures in the IUPUI Emergency Procedures Handbook for leaking lead-acid batteries.
• Lithium – Primary lithium and rechargeable Lithium-ion batteries are potentially reactive, and pose a fire hazard.
• Nickel-cadmium
• Nickel-metal hydride
• Mercury

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, 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 EHS for waste disposal. More information can be found in the IU Biosafety Manual.

Clean, dry cardboard boxes that have been broken down flat can be recycled in campus single-stream recycling bins or recycling dumpsters. This includes pizza boxes that are free of food scraps. Wax coated cartons or contaminated cardboard items are not acceptable for recycling and should be discarded in the trash as general refuse. Cardboard that is grossly contaminated with hazardous chemicals should be placed in a sealed container and referred to EHS for waste disposal.

The disposal of hazardous wastes is regulated by the Environmental Protection Agency (EPA) Resource Conservation and Recovery Act (RCRA). Consult Attachment A for chemicals that require EHS collection. Chemicals known to present mutagenic, teratogenic, or carcinogenic hazards as indicated on the SDS must also be referred to EHS for disposal. Attachment A also lists chemicals eligible for lab for acid-base neutralization, or drain disposal of non-hazardous chemicals. These methods are limited to chemicals that meet the parameters outlined in the In-Lab Dispoal section of this Guide. No liquid or semi-liquid wastes of any kind are permitted in campus dumpsters or compactors.

Chemically contaminated items can include pipettes, cuvettes, spill debris, etc. Disposal guidance for non-infectious, chemically contaminated sharps and debris is found here.; See also: Empty Containers

Compressed gas cylinders that are no longer wanted should be disposed in a timely manner to prevent deterioration. Leased cylinders should be closed, capped and returned to the original gas supplier. Non-returnable cylinders such as lecture bottles and disposable cylinders should be referred to EHS for disposal. Indicate on the cylinder whether it is at atmospheric pressure, or if it is above 1 atmosphere of pressure.

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 EHS. EHS will coordinate with the registrant or registrant’s departmental representative (in case of abandoned materials or deceased registrant), IU Police and the local DEA office to receive controlled substances for on-site destruction or disposal. See the IU Controlled Substances Program for Research (Non-Practitioners).

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 should 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 should be disposed of in a timely manner. Do not touch 2, 4-dinitrophenol that appears old or dried out. You must contact EHS, and we will come evaluate the material. See also: Explosive or Shock-Sensitive Compounds.

Electronic equipment (E-waste) includes electrical or battery operated devices, or appliances such as computers or lab equipment, that often contain toxic heavy metals. E-waste should never be thrown in the general trash, compactors or dumpster, but are to be referred to IU Indianapolis Surplus Property for recycling. The Surplus Property policy for computers can be found at https://surplus.iupui.edu/services/computers.html.

Before sending E-waste to surplus, remove any accessory items such as light bulbs, batteries, thermometers, etc. from equipment.& Also ensure that all chemical containers, specimens, etc. have been removed from laboratory equipment. Dispose items according to this waste Guide. Ensure E-waste previously used for biological, chemical or radioactive purposes is fully decontaminated, and deface or remove any hazard markings.

Refrigerators and freezers must be drained of refrigerant before prior to surplus pick-up. You must call (317) 278-1900 to request this service, which is provided by Campus Facilities Services (CFS). Note that CFS does charge a fee to recover their recycling and disposal charges. See also: Surplus Property Items.

Empty chemical containers cannot be recycled by normal means. However, some empty containers can be re-used to hold waste. Otherwise, empty containers from inert, non-hazardous reagents should be placed into a glass waste box or trash bin.

Chemicals that have been deemed acutely toxic by the Environmental Protection Agency (EPA) are assigned to a list of regulated hazardous wastes known as the P-list. P-listed waste containers are regulated as a hazardous waste, even when empty. All P-Listed containers must be disposed through Environmental Health and Safety as chemical waste. P-listed chemicals are defined as commercially available pure grades, any technical grades of the chemical, or all commercial formulations with a P-listed chemical as its sole active ingredient.

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 EHS for disposal as chemical waste. Detailed guidance on Ethidium Bromide handling and disposal can be found here.

If you have an explosive or shock-sensitive material for disposal, call 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 Section 5.4 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 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

Mercury containing lamps such as compact fluorescent, UV or projector lamps should be referred to EHS. 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 EHS for disposal. If a mercury lamp is broken in a carpeted area, use the IU Indianapolis Emergency Procedures Handbook flipchart to report it as a chemical spill. Never use a regular vacuum cleaner or shop-vac to clean up broken mercury lamps.

See also: Universal Waste for campus maintenance operation protocols.

Non-recyclable, non-hazardous general 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.

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.

All lead and lead compounds should be referred to EHS for recycling or disposal. This includes lead compounds, scrap metal, lead-acid batteries, x-ray aprons, etc. Lead-based paint or paint scrapings from construction or abatement activities must also be referred to EHS. Items or furnishings suspected of being covered with lead paint must also be referred to EHS for evaluation.

The Mercury Elimination/Reduction Program requires all non-essential uses of mercury be eliminated on campus unless prior authorization from the IU Indianapolis Laboratory Safety Committee has been granted. This includes the use of mercury thermometers, mercury devices and mercury containing chemical compounds. All unapproved or waste elemental mercury, mercury devices, mercury contaminated items, and mercury compounds must be referred to EHS for disposal.

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. EHS cannot dispose of waste that is radioactive, or that poses both chemical and biological hazards.

Radioactive Mixed Wastes
In general, if a mixed waste is radioactive it must be referred to the IU Indianapolis 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 Radiation Safety Procedures Manual.

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 EHS the type and volume of chemical disinfectant used.

More information can be found in the IU Biosafety Manual.

Most chemical waste will need to be handled by EHS. However, you might have some nonhazardous waste, listed as acceptable for sewer or trash disposal in Attachment A of this Guide; they can be flushed to the sewer with water or disposed in the regular trash.

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.

Note: If you intend to sewer dispose a material is not listed in Attachment A of this Guide, contact EHS for pre-approval.

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 EHS for recycling. Any used oil that is contaminated with other chemicals must be accurately described and disposed as a chemical waste through 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

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 pesticides and their residues should not be thrown away or poured into the drain. All pesticides and containers with pesticide residues must be referred to EHS for chemical waste disposal.

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 EHS for chemical waste disposal. Lead-based paint chips from construction or remediation must also be referred to EHS for disposal.

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 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 for chemical disposal.
• 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 EHS for technical assistance.

* IUEHS 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 IUEHS cost-recovery for high hazard materials.

See also: Explosive or Shock-Sensitive Chemicals

Non-controlled legend (prescription), over the counter and research drugs should be referred to EHS for disposal. See also: Controlled Substances for disposal of DEA scheduled materials.

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 a sold with greater than 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 need 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 should be referred to EHS for evaluation and disposal immediately.

If you are using other polynitroaromatic compounds, contact EHS for information on handling and storage. See also: Explosive or Shock-Sensitive Chemicals

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 a sold with greater than 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 need 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 should be referred to EHS for evaluation and disposal immediately.

If you are using other polynitroaromatic compounds, contact EHS for information on handling and storage. See also: Explosive or Shock-Sensitive Chemicals

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. 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. More information can be found in the Radiation Safety Procedures Manual.

IU Indianapolis has single-stream recycling for many items including plastics #1-7, paper, aluminum cans, steel and tin containers and cardboard. Labeled bins can be found in buildings throughout campus. More information can be found on the IU Indianapolis Office of Sustainability’s recycling web page.

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 surplus pick-up. You must call (317) 278-1900 to request this service, which is provided by Campus Facilities Services (CFS). Note that CFS does charge a fee to recover their recycling and disposal charges.

Also, ensure that all chemical containers, specimens, etc. have been removed from refrigerators and freezers. Dispose waste chemical items according to this waste Guide. Ensure all refrigerated equipment used for biological, chemical or radioactive purposes is fully decontaminated, and deface any of hazard markings.

See also: Surplus Property Items

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 discard into campus trash, which are collected by Campus Facilities Environmental Services staff. Autoclave indicator tape must be used, and the universal biohazard symbol must be defaced to confirm that the waste has been treated. Additional disposal guidance for non-infectious, chemically contaminated sharps and debris is found on the EHS website under Environmental Management.

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 also: Explosive or Shock-Sensitive Chemicals

For liquid spills that meet all of the reporting exception criteria listed in the Spill Procedures of this Guide, absorb with spill pads or disposable towels (do not use messy absorbent powders or chemical spill neutralizers such as carbon powder, soda ash, sand or vermiculite), 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 non-hazardous chemical spills, place in a sealed container. Include broken chemical container, contaminated towels, etc. into the general trash for disposal. Be sure all liquid spills are fully absorbed into paper or cloth towels or spill pads.

For spills involving material that must be collected for chemical waste, refer to EHS in a closed container labeled as "Spill debris containing…" and list a detailed composition of the debris. Include everything in the container such as broken glass or metal if present, water, paper towels, etc.

If laboratory furniture or equipment is contaminated with a chemical from an inadvertent chemical release, you must contact EHS to evaluate decontamination or disposal options. If property is damaged by chemical spill, Campus Facilities Services must be contacted at 317-278-1900 to evaluate the need for repairs once the spill has been remediated, and if necessary, has been cleared by EHS for re-occupancy.

Refer all strong oxidizers and reducers to EHS for disposal. Keep these items separate from each other, and box separately when disposing.

Strong oxidizers:

• Chromic acid (fresh)
• Metallic chlorates
• Metallic nitrates
• Metallic perchlorates
• Metallic permanganates
• Perchloric acid

Strong reducers:

• n-Butyl lithium
• Calcium hydride
• Metallic sulfides
• Sodium hydride
• Stannous chloride

Unwanted Indiana University property such as furniture, computers, laboratory equipment, etc. must be referred to Surplus Property. Note: Ensure all items are free of chemicals, residues or any other potential hazards. Deface or remove any hazard markings. Surplus also collects electronic waste (E-waste) such as laboratory equipment, computers and printers for recycling. See Electronic Equipment for more specific information. You can arrange a pick-up at no charge for most items, read Surplus policies and procedures, and fill out the Surplus Pickup Request Form.

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 in the Comments/Questions field found at the bottom of the Waste Pick-up Request Form.

• You must store potentially flammable materials in specialized refrigerator/freezers. These materials are prohibited from storage in regular, household-type refrigerator/freezer units.

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. IU Indianapolis manages fluorescent lamps and batteries as Universal Waste. See Attachment D for printable labels.

Note: Spill debris from Universal Waste must be managed as a hazardous chemical waste.See also: Batteries, Fluorescent Light Bulbs

General Rules Management of Universal Waste Batteries

These rules apply to maintenance areas where batteries may be stored before EHS pick-up. 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 IUPUI EHS for pick-up within 9 months.

General Rules Management of Universal Waste Fluorescent 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 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. Refer all broken lamps to EHS for disposal in a closed container with a waste chemical label that states “Broken Mercury Bulb Debris”.

Waste that is not labeled or accurately described in a way that allows IUPUI EHS to determine what hazards it poses and how it should be disposed is deemed an “unknown” waste. Unknowns must be analyzed by EHS to determine their basic chemical hazards through a time-consuming chemical fingerprinting process. Due to the extra time, cost and resources associated with fingerprinting unknowns, EHS reserves the right to charge departments a cost-recovery fee per unknown container. All fees will be discussed with the generator and their department before they are charged.

IU Indianpolis disposes unknown wastes once fingerprinted via a hazardous waste vendor. The vendor puts limitations on the size of unknowns. Thus, EHS cannot receive unknown materials in containers larger than 1 gallon, or solids larger than 1 kilogram. Larger amounts must be broken down into smaller quantities by the generator.