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Hazardous 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.


     Any material which is to be discarded, abandoned, or accumulated prior to recycling is considered a waste.  Some major categories of hazardous materials and potentially hazardous wastes are provided below, including examples.  If you are uncertain about a particular waste, please contact TSO at x2310.
     Because it is impossible to provide a complete classification of all possible hazardous waste in this manual, please contact the TSO at x2310 before discarding any chemical or other potentially hazardous waste that you generate. Waste is not to be transported anywhere or placed in front of the Temporary Accumulation Area (bldg. 16 B) by anyone that is not TSO staff.  Waste will not be transported by TSO staff unless it is in a container that complies with all regulations.  A discussion of proper containers can be found in Section 6.3.1 of this manual.
5.1  Unknowns
     Perhaps the most expensive and time-consuming group of potentially hazardous waste is the unknown.  If no identity can be assigned to a material, or it cannot be determined by process knowledge, the unknown must be subjected to analytical procedures that can cost ISU many hundreds of dollars and take several weeks to complete.  The cost for these analyses is generally borne by the TSO, unless abuse of this service is detected.  Most unknowns can be avoided by using standard laboratory protocol: 

  • label each container as to its contents, date received or prepared, and concentration.
  • obtain MSDSs from the manufacture and have them on hand.  For newly purchased materials the ISU purchasing department will route MSDSs provided by the manufacturer to the department that bought the materials.
     Unknowns should NOT be placed in an SAA or transported by TSO staff to the TAA until an analysis of the unknown has been completed.  Exposure of certain material to weather extremes can create dangers of fire, explosion, or container rupture and subsequent expensive cleanup activities and potential for environmental contamination. 

5.2  Abandoned Material 
     Material that has been abandoned, or for which ownership cannot be identified, may be hazardous waste.  If the identity of the material is not known, it is treated as an unknown (Section 5.1).  If the identity of the abandoned material is known, notify the TSO at x2310 for characterization and pick-up.  Abandoned material that is deemed hazardous must be stored properly upon discovery.

5.3  Questionable Purity
     Material with questionable purity cannot be expected to be used in either a teaching or research capacity.  While some of these materials may be hazardous waste once they are characterized, others often are not, but still must be disposed of properly.  The TSO will assist individuals with this task to ensure safe and environmentally sound disposal practices.

5.4  Expiration Date Surpassed
      Some materials have specified expiration dates which must be observed for a variety of valid reasons, which include purity, safety, and regulatory concerns.  For example, peroxide forming chemicals, some of which are listed in Appendix G, have expiration dates which should not be exceeded under any circumstances.  In addition, manufacturers often supply expiration dates on labels of materials that are related to potency or even composition changes that occur with time, temperature, or other storage conditions.  These dates should always be observed, and if they are exceeded, the material is to be considered a waste and characterized to see if it meets hazardous characteristics.     

5.5  Materials from Discontinued or Completed Activities
     When these materials are no longer useful, they may be considered hazardous waste.  However, another possibility is to recycle them by identification through the ChemSwap program or department transfer.  Each Department Material Manager or laboratory supervisor should attempt to determine whether a material they need is available elsewhere on campus before buying more from an outside vendor.  This will help reduce the financial burden on both initial cost and ultimate disposal cost when it is eventually declared as a hazardous waste.  Some examples of these kinds of activities include:

  • A principal investigator or researcher leaves the University.
  • Lab work on specific projects is completed.
  • The responsibility for a lab or work area changes.
      It is very important to clean chemicals out of a laboratory BEFORE a principal investigator or researcher leaves the University.  Unknown or questionable chemicals left in laboratories are very expensive to test.  Please consult with TSO personnel concerning the fate of these materials and the procedures to be followed to ensure proper closure of a laboratory or program within a lab.

5.6  Excess Stock
     Excess stock with no likelihood of use either by their current owners, the department, or others elsewhere on campus, is considered waste.  Careful planning when purchasing materials can reduce the volume of excess material that must ultimately be managed as hazardous waste.  Some helpful ways to accomplish this goal are presented in Section 9, entitled "Hazardous Waste Minimization Programs".

5.7  Spent Cleaning and Wash Solvents
     Spent cleaning and wash solvents are almost always considered hazardous waste, because either the solvent itself or the materials which contaminate the solvent are considered hazardous.  There are options as to the types of solvents and processes used which may not be regulated as hazardous waste.  Currently, spent solvents from automobile, diesel, aircraft, or other parts washers at ISU are recycled under a monitored program. Other generators of spent solvents should contact the TSO for waste solvent management options.  Rags used in these processes also become a hazardous waste when using a hazardous solvent.  These rags must be stored in a closed and labeled container in a SAA.  Laundering of these rags may not be an acceptable alternative.  TSO can help identify whether or not these rags can be laundered for reuse.

5.8  Waste Paints and Stains
     Waste paints and stains which contain hazardous metals in the specific D-list on Appendix D or hazardous solvents which may be flammable, must be considered hazardous waste.  Old paint cans meeting these characteristics which have hardened contents must also be presented for proper disposal.  Most water-based latex paints currently are not considered to be hazardous, but may not be acceptable to a municipal solid waste landfill.  Currently, TSO solidifies latex paint before arranging for disposal at the landfill.  Spray paints may also meet the hazardous criteria. Please consult the TSO for proper disposal information.

5.9  Motor Oil and Filters
     Regulation on used motor oil and filters are subject to change.  Currently, oil is recycled, but properly drained filters are disposed of as ordinary trash.  The State of Idaho regulates these items.  If you have questions concerning either the regulatory status or recycling options, contact the TSO.  Oil must be recycled through a recycler that has obtained an EPA identification number.  All oil must be drained from filters before the filter can be recycled or disposed of.  Proper drainage procedures consist of punching a hole in the filter and letting it drain for 24 hours.  All containers used to store used oil for any length of time must be marked with the words “USED OIL”.

5.10  Mercury and Mercury Compounds
     Metallic mercury is commonly found in instrumentation such as thermostats, thermometers, and barometric pressure equipment.  Bulk quantities of metallic mercury or mercury sulphide can usually be recycled.  However, articles contaminated with mercury or its compounds must be disposed of as hazardous waste.  The TSO has collection containers for the recycling of mercury and mercury sulphide compounds.
     Cleanup of a mercury spill from a broken thermometer generates large quantities of mercury-contaminated waste that is very costly to dispose of.  For the University, it is far less expensive to obtain an electronic or environmentally friendly thermometer than to pay disposal costs of a broken mercury thermometer.  The TSO recommends that you do not buy new mercury-containing equipment for use at ISU when good alternatives are available. 
     Mercury compounds are currently very expensive to dispose of and many are P-listed wastes.  Every attempt to find alternatives to using mercury compounds should be made.  The cost per gram of disposal is approximately 50 to 200 times the purchase cost.  If you have mercury compounds to dispose of, consider sulphide precipitation as a final step in your process.  Currently, mercury sulphide is the only mercury compound which is accepted for recycling.

5.11  Electrical Transformers
     Older electrical transformers often contain PCB dielectric oils.  In the past, great expense has been incurred in testing for and disposing of these fluids from equipment that has been donated to the University.  DO NOT ACCEPT DONATED ELECTRICAL EQUIPMENT UNTIL IT HAS BEEN EVALUATED BY TSO PERSONNEL FOR HAZARDOUS MATERIALS!  The cost to dispose of contaminated donated equipment is very high and can be avoided if equipment is properly evaluated prior to acceptance.

5.12  Fluorescent Light Ballasts
     The Technical Safety Office currently receives all waste light ballasts collected by various Maintenance and Operations (M&O) personnel.  Once collected, these ballasts are characterized by the Technical Safety Office as to whether they contain PCBs.  This characterization is determined by the specific manufacturer and date of manufacture.  Under the Toxic Substance Control Act, the manufacturing of ballasts containing PCBs after 1979 is prohibited.  
     Today manufacturers of fluorescent light ballasts cannot legally produce PCB containing ballasts under TSCA.  Ballasts which do not have PCB material can be recognized by the following:

  • have the label "NO PCBS"   or
  • have a manufacturing date which is later than 1979   or
  • are General Electric with a serial number starting with "8G" or ending in "W".
5.13  Donated or "Free" Hazardous Material 
     ISU has spent thousands of dollars on hazardous waste disposal of "free" hazardous material donated to the University.  Do not accept any donated hazardous material from any outside source without first consulting with TSO. 

5.14  Electrical Batteries
     Spent or unwanted batteries may be classified as hazardous waste, mainly due to their toxicity characteristics (RCRA D-listed waste).  Batteries are subject to the toxicity characteristic leachate procedure (TCLP) to determine whether or not they are hazardous waste.  Because these batteries are manufactured within specified tolerances, a representative sample may be used for a waste characterization for a given brand and type of battery.  
     Batteries highlighted in Appendix T have been determined to be a hazardous waste when spent or unwanted, and are subject to the hazardous waste guidelines in Section 6 of this manual.  
     Spent lead-acid batteries, such as motor vehicle batteries are not subject to federal hazardous waste regulations provided that they are reclaimed as described in 40 CFR 266.80.  Contact TSO for the names of local lead-acid battery recyclers.   Non-hazardous waste batteries do not need to be accumulated in a SAA nor are they subject to storage time constraints associated with hazardous waste.  However, batteries should be stored in a secondary container, such a polyethylene tub to prevent contamination to the environment and should not be accumulated.  Contact  the TSO for transportation of these batteries to a recycling facility.
     Batteries that are hazardous waste should have a label attached with the words “USED BATTERY” in the chemical description.  Call TSO to pick up the hazardous waste battery if it cannot be placed in a SAA.  If the battery is leaking, it must be placed in a sealed container.

5.15  Photographic and Radiographic Solutions
     Spent material used in developing X-ray films and photographic negatives and prints contain silver compounds from dissolution of the emulsion on print paper.  These silver compounds are regulated under both RCRA and the City of Pocatello NPDES pre-treatment standards, and must be recycled.  For large generators, silver may be removed from waste streams at the point of generation and recycled.   For smaller generators, the liquid wastes may be transported off site for recycling.  Solutions containing spent silver that can be recycled should be labeled with the words “Used Fixer”.  Please contact TSO personnel for details.
     Some photographic developing solutions may contain organic compounds that meet hazardous criteria.  These solutions must be disposed of as hazardous waste and may not be able to be recycled.

5.16  Electrical Lamps
     Some electrical lamps contain hazardous materials, such as mercury, and require proper management when no longer needed.  

5.16.1  Sodium Vapor Lamps
     Sodium vapor lamps contain metallic sodium, which represents a fire and explosion hazard when exposed to either moist air or water.  These lamps should not be disposed of as normal trash, and must not be broken.  Please take them to the Heat Plant, where barrel storage is located.  Contact TSO personnel for assistance.

5.16.2  Mercury Vapor Lamps
     Mercury vapor lamps contain small quantities of metallic mercury and/or mercury compounds that are considered hazardous waste under RCRA.  These items must be collected for proper disposal.  Contact the TSO personnel for collection and transportation of these vapor lamps.

5.16.3  Fluorescent Lamps
     Fluorescent light tubes contain a small amount of mercury that requires them to be tested by the toxicity characteristic leachate procedure (TCLP) for hazardous waste determination.  There is insignificant data yet as to whether or not fluorescent light tubes in general pass or fail the TCLP. However, fluorescent light tubes that fail the TCLP must be currently managed as a hazardous waste.  The GE fluorescent light tubes purchased under contract by ISU have been tested and found to pass the TCLP.  Accordingly they are managed as ordinary trash.  In order to prevent breakage during handling, it is recommended that spent fluorescent light tubes be placed in original packaging material prior to disposal. 
5.17 Contaminated Materials 
     Materials contaminated with a hazardous waste may also become a hazardous waste.  Spill cleanup material, PPE, laboratory bench coverings, chemical storage cabinets, glassware, rags, etc., must all be evaluated before disposal into ordinary trash.  Construction materials are often overlooked as being a hazardous waste.  Any ductwork from fume hoods should be evaluated for hazardous materials before disposal. 

Hazardous / Infectious Waste  |  Radiation Safety  |  Laser Safety  |  Mission  |  MSDS
Contact TSO  |  Emergency Response Instructions
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


Page Updated: 1/1/03