1.1  Purpose and Scope
     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 2310.

1.2  Environmental 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 Status 
      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 Generator Status
      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 wastes.
      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.

1.3.2  Conditionally 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. 

Technical Safety Office Idaho State University Campus Box 8106 785 S. 8th St. PS Rm 101  Pocatello, ID 83209 Phone: (208) 282-2310 or 282-2311 Fax: (208) 282-4649