Waste Policies and Procedures Manual - 2003 Edition
This manual was prepared
for use within ISU. It is intended for use by, and applies to, ISU
employees, staff, visitors, and students. If this manual or any portion
of it is used elsewhere, neither its authors nor the University accept
responsibility for its contents.
1.1 Purpose and
The purpose of this manual is to provide important hazardous waste information
for Idaho State University (ISU). Proper hazardous waste management
is important in order to provide healthy and safe working conditions for
faculty, staff, and students, to protect the environment, and to ensure
compliance with applicable federal, state, and local laws and regulations.
If there are situations that this manual does NOT address, or if there
are questions regarding the procedures it contains, contact a hazardous
waste specialist at the ISU Technical Safety Office (TSO), extension 2310.
For emergency situations, after normal working hours, or weekends, please
refer to the table of phone numbers on the BACK COVER of this manual or
in Appendix O.
Please note that this document is not a general hazardous material safety
manual. Safe acquisition, storage and use of hazardous materials
is handled by the College, Department, or other applicable unit within
the University, with guidance by the ISU Safety Committee. This manual
is applicable to the generation, minimization, storage, recycling and disposal
of hazardous waste only. Nevertheless, many of the safe work practices
and information identified in this manual for the handling of hazardous
waste are applicable to hazardous materials in general. This manual
was prepared for use within ISU. It is intended for use by, and applies
to, ISU employees, staff, visitors, and students. If this manual
or any portion of it is used elsewhere, neither its authors nor the University
accept responsibility for its contents.
Infectious waste policies and procedures for ISU can now be found in a
separate manual entitled, “Infectious Waste Policies and Procedures Manual”.
A copy of this manual may be obtained at any time by calling TSO at extension
Laws and Regulations
In 1976, Congress enacted the Resource Conservation and Recovery Act (RCRA)
to protect human health and the environment from improper hazardous waste
management practices. ISU falls under RCRA and other environmental
laws and regulations, including the Toxic Substances Control Act (TSCA),
Superfund Amendments and Reauthorization Act (SARA), Clean Water Act (CWA),
Clean Air Act (CAA), Emergency Planning and Community Right-to-Know Act
(EPCRA), and Idaho General Safety and Health Standards (IGSHS). Thus,
it is very important to not discard as ordinary trash any reagents, chemical
solutions, chemical mixtures, industrial products, infectious wastes, contaminated
rags, or any items containing or contaminated with substances which may
be regulated under one or more of these programs.
It is the responsibility of University personnel to follow the procedures
in this manual. The University is subject to state and/or federal
inspection at any time. The University and individuals can
be cited for failure to comply with hazardous waste regulations.
Conviction can result in civil or criminal penalties, depending upon the
seriousness of the violation.
1.3 Waste Generator
RCRA regulations exempt two categories of small quantity generators from
some of the hazardous waste regulations, primarily those concerning record-keeping
and reporting. These are the Conditionally Exempt Small Quantity
Generator (CESQG) and the Small Quantity Generator (SQG). Under
RCRA, a small quantity generator is defined as an entity which produces
less than 1,000 kilograms but more than 100 kilograms per month of hazardous
waste and/or less than 1 kilogram per month of acute hazardous waste.
A CESQG is an entity which produces less than 100 kilograms per month of
hazardous waste and/or less than 1 kilogram per month of acute hazardous
waste. Acute hazardous waste is identified in RCRA regulations with
a “P” prefix. These wastes are listed in Appendix E.
RCRA requires each waste generator to obtain an Environmental Protection
Agency (EPA) identification number for its activities that occur within
a contiguous area. Idaho State University has six EPA identification
numbers for its areas. The main Pocatello campus is defined as a
SQG and the five satellite campuses are classified as CESQGs. This
means that ISU must follow the regulations for both CESQGs and SQGs.
The five CESQG sites are the Aircraft hangar located at the Pocatello Airport,
the Edward F. Dowling building at Benton and Main, the School of Applied
Technology Diesel Mechanics building on South Second Avenue, the Research
and Business Park, and the Center for Higher Education on Science Center
Drive in Idaho Falls.
1.3.1 Small Quantity
It is very important for the main ISU campus to retain its SQG status.
There are significantly increased administrative reporting requirements
which are applicable to large quantity generators (LQGs) that the University
would like to avoid, as well as higher disposal costs associated with larger
volumes and more frequent disposal of hazardous wastes.
It is unlikely ISU will exceed the 1,000 kg/month quantity of hazardous
waste generation given current levels of generation. However, there
are a number of both research related and industrial chemicals present,
or capable of being prepared, which are listed as acute hazardous, or "RCRA
P-listed," once they have been declared as waste. If Idaho State
University were to exceed the generation of 1 kg/month for these wastes,
a status of LQG would have to be established. A list of these acute
hazardous materials, or RCRA P-listed is in Appendix E of this manual.
Please do NOT generate a RCRA P-listed waste without FIRST contacting the
TSO. Other researchers on the campus may also be generating RCRA
P-listed waste, and the combined total could potentially exceed the 1 kg/month
threshold. TSO staff are able to answer questions concerning P-listed
Careful management of all hazardous materials from purchase to disposal
will ensure that ISU does not lose its SQG status, and keeps hazardous
waste disposal costs to a minimum. Please buy and use only the smallest
quantity of any hazardous material which is necessary. In most cases,
it is far more expensive to dispose of hazardous material as waste than
it is to purchase it as new material. Other departments on campus
may be willing to sell or exchange small quantities of materials.
Section 2.1.2 and Section 9 of this manual discusses other ways of minimizing
hazardous waste generation.
Exempt Small Quantity Generator Status
It is equally important that ISU does not lose its CESQG status for its
remaining locations. A CESQG must not generate more that 100 kg/month
of hazardous waste or more than 1 kg/month of acutely hazardous waste (RCRA
P-listed). The ISU CESQG locations in Pocatello generate primarily
recyclable wastes in the form of spent cleaning solvents and used oil.
Reporting is still required by the State of Idaho for these locations,
as well as the possibility of EPCRA and SARA reporting, depending upon
quantities. Please help ISU keep its CESQG status for these locations
by maintaining or reducing the waste quantities generated.
Idaho State University
Campus Box 8106
785 S. 8th St. PS Rm 101
Pocatello, ID 83209
Phone: (208) 282-2310 or
Fax: (208) 282-4649