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.
6.0 RCRA HAZARDOUS
Proper hazardous waste management is a process that involves both personnel
in the unit generating the waste and the TSO personnel. It involves
the identification and characterization of a waste stream, proper containment
and storage of the waste in a designated Satellite Accumulation Area (SAA),
inspection of the containers in an SAA and the SAA itself on a regular
basis, and scheduling for removal of the waste streams from an SAA as required
by regulation. Details of what an SAA is, how to create one, and
procedures for waste removal from the ISU campus are given below.
This information on SAAs is designed for those who generate waste on a
regular basis. Information is also presented on occasional or spot
generation of hazardous waste for those who fall into that category.
If you generate hazardous waste infrequently, have questions about whether
you need to establish a SAA, or questions about your active SAA, call the
TSO at x2310 for information and assistance.
Close coordination between the persons involved with a SAA and TSO personnel
is vital for effective waste management, minimization, and disposal from
waste generated at ISU. Your cooperation with all procedures is essential
to the future of laboratory work and scientific research at ISU.
6.1 Satellite Accumulation
Area (SAA) Definition
A SAA is defined in 40 CFR 262.34, but is interpreted differently by each
of the 10 EPA regions in the U.S. It allows for accumulation of up
to 55 gallons of hazardous waste or 1 quart of acute hazardous waste (P-listed)
"..at or near any point of generation where wastes initially accumulate."
EPA region 10 defines this location as being within the room where a waste
is first generated, and thus, it cannot pass through a doorway to a hall
or be moved to another waste SAA, even though it may contain a compatible
or identical waste stream. Thus, a separate SAA must be created for
each laboratory or room where a waste stream is generated; more than one
SAA may also be needed in the same room if incompatible waste streams which
need to be separated for safe storage are generated in that room.
It is important to not overlook laboratory complexes. A doorway is
the boundary, even if the doorway leads to a smaller room in the complex
and not a hallway. If you have any questions concerning the definition
of an SAA or its characteristics, contact the TSO at x2310.
6.2 SAA Documentation
Various forms of documentation are used to help manage the SAA. These
include a "SAA Registration" form, a "Satellite Accumulation Area" sign,
a "Emergency Response Instruction" label, and a SAA packet (or binder)
"ISU Waste Management Guidelines"
"Chain of Custody" form
"Hazardous Waste" labels
"SAA Inspection" form
ISU Hazardous Waste Policies
and Procedures Manual (recommended)
All forms and labels can be obtained from the TSO at no cost to the department.
Examples of each of these can be found in Appendices L to R. Other
forms and labels can often be found in SAA binders. Examples of these
include: Hazardous Chemical labels, informative lists (such as Peroxide
Forming Chemicals, and incompatibility of laboratory chemicals), segregation
of incompatible chemical instructions, MSDSs, and information about the
NFPA fire diamond.
The SAA Registration / Termination form is used to both initiate
or terminate a SAA with the TSO. This form is used by the TSO to
predict the amount and frequency of hazardous waste generation, identify
any unusual characteristics that would require special handling, and also
to provide contact information for the responsible personnel. When
all registration information on the form is completed, it is sent to the
TSO for inclusion in the records. Occasionally the TSO will request
updated information to include with this form.
The Satellite Accumulation Area label should be placed on the outside
door of the SAA enclosure. It is designed to be highly visible and
provide notification to occupants of a room as well as for emergency responders
that hazardous waste is stored within the enclosure.
The Emergency Spill Response Instructions labels are either adhesive-backed
or included in the cover of the SAA binder. The adhesive backed labels
should be applied to the surface near the entrance(s) to a SAA, near a
telephone or exiting door in the room containing the SAA (or nearest available
telephone), and near the SAA area. These instructions are to be followed
by those who discover a leak or spill of material at a SAA location.
The ISU Waste Management Guidelines form is a quick reference document
of SAA management responsibilities. It should be only used as a guidance
document and does not replace this manual.
The Chain of Custody form is used to record information on the hazardous
waste container, which is placed in a SAA. It also provides the official
record of transfer of wastes from the area of generation to the TAA.
Please press firmly with an ink pen when filling out a Chain of Custody
so that all carbon copies can be read.
The Hazardous Waste label is also used to properly identify waste
chemicals and their physical properties as well as identify them for inventory
purposes. It is of utmost importance that the hazardous waste labels
are completed accurately. Improper or false labeling may lead to
a serious accident.
The SAA Inspection form is used to record the weekly inspection
certification of a SAA by TSO personnel. A signature on this form
indicates that the SAA and its contents have been inspected for leaks,
compatibility, proper containment, and spills.
The Incident Notification form will be filled out by TSO personnel
when a policy of this manual has not been followed. The purpose of
the form is to inform the SAA personnel that a policy has not been followed,
so that corrective actions may occur and proper policy can be followed
in the future. This form is typically used when laboratory personnel
can not be located and notified of the incident immediately during an SAA
inspection. This form may also be used when incidents are repeated.
Please fill out all documentation carefully and accurately. The information
provided by SAA coordinators, SAA managers, and SAA waste generators is
relied upon by others to provide information they need to work safely with
the waste, and to ensure regulatory compliance.
6.3 SAA Creation
Creation of an SAA is both simple and convenient. For each SAA, a
SAA coordinator and a SAA manager (it may be the same individual) is designated.
The SAA manager should ensure that a waste is properly characterized and
contained before it is placed in the SAA, and that the required paperwork
is accurately filled out. The SAA coordinator must certify that the
waste stream has been properly identified and that the Chain of Custody
form is signed when the waste stream is removed from an SAA for proper
waste disposal. The TSO has prepared SAA packets which contain all
the forms and labels needed to originate and operate each SAA. Examples
of things found in the packets are found in Appendices L to R at the end
of this manual. TSO staff prefer to be involved in the creation of
the SAA directly in order to provide training to the manager and guarantee
that TSO receives all the required paperwork and has access to the room.
It is important for an SAA to be formally included on the list of sites
inspected by the TSO. When a new SAA is needed, please complete
a SAA registration form. TSO will work with you to choose the site
and help define what waste streams can be considered compatible in the
SAA. SAAs should be kept in a locked room. Once an SAA is accepted,
the TSO will notify the SAA coordinator and it will be included on the
weekly inspection route of the TSO. These steps must be completed
prior to any hazardous waste being created and placed in an SAA.
6.3.1 Proper Containers
Hazardous wastes that are placed in an SAA must be in a proper container.
A proper container is one that meets the following regulations:
40 CFR 264.171 Condition
If a container holding hazardous waste in not in good condition (e.g.,
severe rusting, apparent structural defects) or if it begins to leak, the
owner or operator must transfer the hazardous waste from this container
to a container that is in good condition or manage the waste in some other
way that complies with the requirements of this part.
40 CFR 264.172
Compatibility of waste with containers.
The owner of operator must use a container made of or lined with materials
which will not react with, and are otherwise compatible with, the hazardous
waste to be stored, so that the ability of the container to contain the
waste is not impaired.
40 CFR 264.173
Management of containers.
(A) A container holding hazardous waste must always be closed during storage,
except when it is necessary to add or remove waste.
(B) A container holding hazardous waste must not be opened, handled, or
stored in a manner which may rupture the container or cause it to leak.
In addition to the federal regulations, ISU requires that no foodstuff
containers be used to hold a hazardous waste. This is a precautionary
measure to prevent accidental ingestion or improper disposal.
Contact the TSO for more information concerning proper containers or if
you need help in locating a proper container. We recommend that whenever
possible hazardous wastes are stored in the original hazardous chemical
bottles and are appropriately labeled as waste with any added components
also marked on the label. TSO staff will gladly return empty waste
containers to the department after the waste shipment, so long as prior
arrangements have been made to do so. TSO does not have room to store
empty waste containers for departments.
6.4 SAA Management
The persons who work with SAAs are the waste generator, the SAA manager,
the SAA coordinator and TSO staff. It is also important that students
working in the laboratory containing an SAA understand these procedures
and safety practices. TSO has prepared training material for students
and TAs working in laboratories and training is available upon request.
Use of a SAA must be limited to the SAA Coordinator, SAA Manager, Generator,
and TSO personnel. This will help prevent placement of an unidentified
or uncharacterized waste into an SAA. Rooms containing SAAs should
be locked when unattended.
6.4.1 Waste Generator
A person who is directly responsible for creating a hazardous waste is
referred to as the Waste Generator. Generators are normally the laboratory
workers, whether they are students, technicians, or faculty. They
are to notify their SAA Manager and TSO of laboratory activity that may
potentially generate a hazardous waste. They should be trained how
to utilize the SAA management system and are responsible for handling their
waste according to this manual and all training provided to them.
Spot generation also occurs at this University. Spot generation refers
to a one time or infrequent generation of hazardous waste. Any department
on campus may have spot generation occurring. When spot generation
occurs, TSO staff should be notified immediately so that the hazardous
waste can be transferred to the TAA.
6.4.2 SAA Manager
Each SAA will have a specific person referred to as the SAA Manager.
Generally, this is the laboratory's principal investigator or laboratory
supervisor. The SAA manager is specifically responsible for:
6.4.3 SAA Coordinator
obtaining SAA training of lab
all material placed within the
the general safety of the SAA
proper labeling of waste containers
maintaining/filing Chain of
notifying the TSO of needed
Each SAA will have a designated SAA Coordinator, generally the materials
manager or department safety coordinator. The SAA Coordinator is
usually responsible for several SAAs. This person has the responsibility
assure that proper management is accomplished, the SAA Coordinator should
assist teachers and researchers in making sure that these guidelines are
being followed and answer any questions regarding SAA management.
This may include coordinating actions between the TSO and their department
and taking responsibility for all paperwork related to SAA operation such
as assuring that the hazardous waste is labeled correctly and that hazardous
waste container is recorded on the “Chain of Custody” form properly.
The SAA Coordinators should assist the SAA Managers in setting up the SAA
with the proper “Satellite Accumulation Area” label, and taping the SAA
boundaries with black and yellow tape provided by TSO.
providing materials needed for
assisting researchers in characterizing
coordinating waste pickups where
providing training to stockroom
acting as liaison between the
department and TSO
6.4.4 Technical Safety
Safety Office has the sole responsibility for:
TSO personnel will look for evidence of corrosion, incompatible waste,
leaks or spills, uncapped containers, unsecured SAA areas, and any incomplete
forms or labels. Any problems will be reported to the SAA Coordinator
for possible corrective action.
providing SAA packets to departments
final waste characterization
hazardous waste removal
hazardous waste transportation
hazardous waste disposal
placing the "Start Date" and
"EPA #"on waste containers
weekly SAA inspections
6.5 Hazardous Waste
ISU’s hazardous waste containment policy includes, but is not limited to,
the original container should be used if it shows no signs of deterioration.
However, some older original containers may not meet current standards,
even if they are intact. The responsibility for transferring chemicals
into proper containers belongs to SAA personnel.
All hazardous waste must be
properly stored in compatible containers that prevent rupture or leakage
of the material contained.
Containers should not be filled
beyond the neck or should have at least one inch headroom to allow for
Containers should be made of
material that does not react with or absorb the contents and have a screw
cap of similar material properties.
The cap must be in "new" condition,
with no cracks or any signs of deterioration. ALL WASTE CONTAINERS MUST
BE CAPPED DURING STORAGE, EXCEPT WHEN ADDING OR REMOVING WASTE.
No foodstuff containers may
be used to store hazardous waste even if they are compatible with the material.
See Section 6.3.1 for an explanation of this policy.
It is the department’s responsibility for supplying hazardous waste containers,
however TSO will assist in locating an empty container. TSO may chose
to provide reusable five gallon carboys for some waste streams. These
carboys that are provided to laboratories by TSO should not be filled past
the indicated mark. This is a new system that allows for easier bulking
of the waste when it comes time for shipment as these containers become
heavy and difficult to maneuver when full. Several departments have
requested that TSO save some of the hazardous waste containers for hazardous
waste containment re-use. Most hazardous wastes are bulked into 55G
drums for shipment so retaining some empty containers is possible if TSO
is notified ahead of time.
Each SAA must have secondary containment such as a tub or drum that will
contain, at least, the quantity of the largest container. Each SAA
is allowed to contain several separate waste streams, as long as they are
chemically compatible. If separate waste streams are not compatible,
they are to be separated by a physical barrier to prevent interaction in
the event of a leak or spill. A separate secondary containment unit may
be all that is needed to prevent interaction of some chemicals.
6.6 Hazardous Waste
Properly labeled waste containers are critical for managing hazardous waste
in a manner that is safe and compliant with regulatory requirements.
Each waste container must be labeled with the following:
meet these requirements, the SAA packet contains proper "Hazardous Waste"
labels required for each container that contains a EPA regulated chemical
waste. When a container is first placed in the SAA, the "Chain of
Custody" number, the "ISU #", the "Chemical Name" of the waste stream,
the "Physical State" of the waste, and the location information of the
waste must be filled in by the person generating the waste.
the words, "HAZARDOUS WASTE"
the waste generator’s name,
building and room number where the material was generated.
the chemical constituents contained.
A generic title may be used only if specific waste profiles have been established
with the Technical Safety Office (i.e., in teaching labs or long term research
Once a container is considered full, all remaining information should be
filled in on the label by the SAA manager, except the "Start Date” and
“EPA Number”. This is filled in by TSO personnel and indicates the
date a waste enters the TAA. This is very important, as there is
no time limit on waste being kept in a SAA, but there is a time limit for
waste stored in a TAA. Assistance in completing this information
can be obtained from MSDS or TSO personnel.
6.7 SAA Monitoring
/ Waste Tracking
ISU is in a transition phase with electronic tracking systems. Although
the Hazardous Material Tracking Program (HMTP) is still available, TSO
currently tracks hazardous waste using a Microsoft Access database program
designed by TSO staff. The HMTP has proven to be difficult and slow
to use. TSO is planning to procure a new chemical tracking program
that will allow for all current and incoming chemicals on campus to enter
the database and be tracked from their shelf location to their eventual
disposal location. Other chemical information such as health and
safety data may also be included with the software. This program
will be customizable to the University’s specifications and accessible
from every internet linked computer on campus. TSO will provide training
on the use of this program as soon as it is available.
6.8 Procedures for
Satellite Accumulation Areas
The following procedures assume that the identity of a waste stream is
known. For unknowns, please contact TSO personnel.
When a new waste stream is identified,
the SAA coordinator should obtain a SAA folder which has all the required
forms and labels for a SAA.
The SAA manager should characterize
the waste using either technical data or process knowledge; this may require
assistance from the waste generator or TSO.
The SAA coordinator should complete
the "SAA Registration" form and receive notification from the TSO that
the SAA is ready for waste storage.
The SAA manager or generator
ensures that proper containers are used for waste, that a "Hazardous Waste"
label with the required information is placed on each hazardous waste container
and that the required information is entered on the "Chain of Custody"
When hazardous waste removal
from the SAA is required, the hazardous waste coordinator should notify
the TSO. TSO personnel will pick up the waste after the SAA manger
or SAA coordinator has completed "Chain of Custody" form and TSO personnel
sign the "Chain of Custody" form indicating receipt of the waste containers.
A copy of the "Chain of Custody" form is left at the SAA as evidence that
the waste has been accepted by TSO. The TSO also picks up waste without
having been called by SAA personnel when it is time for shipments.
The hazardous waste is then
transported by TSO personnel, as soon as reasonably achievable, to a storage
facility called a Temporary Accumulation Area (TAA). This transportation
is only done by TSO personnel and only while using ISU-owned vehicles.
Once a waste container arrives at the TAA, the individual containers are
segregated according to their chemical compatibility and hazard class.
For Waste Removal From ISU Campus
procedures are followed for shipment of wastes.
The hazardous waste is packaged
for shipment to an EPA approved treatment/storage/disposal (TSD)
Each container is identified
and labeled according to Department of Transportation(DOT) hazard class
After the hazardous waste is
taken by the broker for transportation to a TSD facility, aprintout of
the shipment is obtained from a shipment tracking program and placed in
a per-shipment file by TSO personnel.
When a waste stream has been
properly disposed of by the TSD facility, a "Certificate of Disposal" is
provided by the waste broker as further evidence that a waste stream has
been disposed of in accordance with all applicable regulations. These
are also kept by the TSO personnel in a per-shipment file.
6.10 Spot or
Occasional Hazardous Waste Generation
Some hazardous waste generation occurs as a result of the infrequent or
one-time activities that do not warrant the creation of a SAA. Many
of the responsibilities and activities listed in section 2.4.3 through
2.4.5 are still required of spot or occasional generators. TSO personnel
should be contacted for assistance whenever a potentially hazardous waste
6.11 Hazardous Waste
Laboratory research using samples of actual hazardous waste to investigate
the efficiency of treatment or recycling are termed Treatability Studies.
Researchers may use a limited amount of hazardous waste as a sample in
a treatability study. These samples are exempted from the general
hazardous waste regulations but are subjected to the treatability study
regulations in 40 CFR 261.4 (e) and (f). If samples contain radioactivity
as well as hazardous chemical wastes, the investigator must be approved
as a "Responsible User" by the ISU Radiation Safety Committee and the Responsible
User's program must encompass the amounts and types of radioactive materials
The treatability study regulations include limitations on quantity, allowed
study processes, and duration of study/storage period. The regulations
also state that proposed treatability studies are subject to regulatory
oversight. The Idaho Department of Environmental Quality (IDEQ) and
the TSO must be notified no less than 45 days in writing before a project
begins. The principal investigator for each project must provide
IDEQ with a contractual Treatability Study agreement with the funding
agency and sample provider (prior to obtaining any sample material).
In addition, the principal investigator must provide copies of all correspondence
with IDEQ to the Technical Safety Office.
It may be desirable to conduct preliminary studies using new chemicals
instead of actual hazardous waste. Studies with new chemicals are
not subject to the special treatability study regulations. However,
any hazardous waste created during the conduct of the study must be handled
according to the regular ISU procedures.
The principal researcher must work closely with the Technical Safety Office
to assure regulatory compliance (e.g., a list of reporting requirements
can be obtained from the TSO). The TSO will offer technical and regulatory
assistance to researchers interested in conducting Treatability Studies.
The principal investigator should notify the TSO of planned Treatability
Studies as soon as feasible.
The TSO must submit an annual report to IDEQ covering all ISU treatability
studies. In order to collect information for this report, treatability
study principal investigators are required to submit a yearly Treatability
Study Progress Report to the TSO by December 31 of each year. The
format of the report can be obtained from the TSO.
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