HAZARDOUS WASTE GENERATION
Cradle to Grave: What You Need to Know

As many educational and hospital facilities managers know, hazardous waste generators are ultimately responsible for the disposal of waste “from cradle to grave,” including identification, storage, removal and documentation of proper disposal. Improper waste management can result in significant fines and penalties from the U.S. Environmental Protection Agency (EPA) and state Departments of Environmental Protection (DEP), even for the smallest quantities of waste.

High as the consequences are, however, sometimes the necessary personnel are not aware of what constitutes hazardous waste within their facility, or how to properly store it prior to professional pick-up. These wastes can lurk unnoticed and undocumented until problems arise, either in the form of regulatory fines or spills that need professional, emergency cleanup.

Wastes can be categorized as hazardous if they exhibit one of the following
four characteristics: ignitability, corrosivity, reactivity, or toxicity.

How is Hazardous Waste Categorized?
Educational and hospital facility managers must be sure to determine the hazardous composition of any waste material generated. This includes waste that is accumulated on the property for any period of time before removal, waste placed directly in on-property regulated treatment or disposal units, waste that is packaged and transported away from the facility, and waste generated as still bottoms or sludges. Wastes can be categorized as hazardous if they exhibit one of the following four characteristics: ignitability, corrosivity, reactivity, or toxicity. Many wastes that should be categorized as hazardous materials are mistakenly considered as benign, so special care is needed to properly identify all substances.

Common Hazardous Waste Generated by Schools
The most active hazardous waste-generating areas of a school include science rooms and laboratories, industrial arts, graphic art and printing classes, and maintenance operations (facilities). The most prolific areas, science labs, can produce:
• Flammable liquids such as acetone, a solvent
• Oxidizers such as nitrates
• Reactives like picric acid, a reagent for staining samples
• Toxics such as cyanides or phenol, a chemical embalmer
• Corrosives for general lab reactions and mediums

Other common hazardous wastes include developers, fixers, dyes and petroleum-based inks produced by graphics arts classes, degreasing and petroleum-based solvents and polyurethane sealers in wood and metal shops, paint thinners, adhesives/ glues, and oil-based paints in art classes, and paints and oils in maintenance shops.

It is also important to note that most school laboratories utilize centralized acid neutralization tanks, employing one of two common systems to store waste. Older buildings most commonly use a system that includes limestone in the neutralization tank because it reacts with acid to form a salt sludge. Tanks installed after 2001 have most likely moved from limestone to the two-phase liquid system, which injects acids and bases into a tank to stabilize the pH levels. Both of these systems require regular (usually annual) maintenance from licensed professionals in order to prevent leaks, back-ups, or gaseous odor build-up, which may cause health hazards and incur fines.

Common Hazardous Waste Generated by Hospitals
Common forms of hazardous waste generated most frequently by hospitals include chemotherapy drugs, mercury-containing wastes such as vapor-lights, thermometers, gastric tubes, and sphygmomanometers, nicotine in smoking cessation products, epinephrine, and nitroglycerin. Also included are solvents such as acetone, methanol, toluene, xylene, and methylene chloride from departments such as pharmacies, morgues, pathology labs, and histology labs. Other substances qualified as hazardous waste may surprise you, such as rubbing alcohol and some mouthwashes like Listerine due to flammability. Pharmaceutical waste and debris is also an often-overlooked waste stream, as are pH neutralization systems, common in hospitals that contain labs.

Generator Status
Several categories of generator status exist for hospital and educational facilities, which govern the regulations required by the EPA for storage and disposal (please note that some states have more stringent regulations in addition to these). They include:
• Conditionally Exempt Small Quantity Generator (CESQG) – Generate 220 pounds (100 kilograms) or less per month of hazardous waste, or 2.2 pounds (1 kilogram) or less per month of acutely hazardous waste
• Small Quantity Generator (SQG) – Generate more than 220 pounds (100 kilograms), but less than 2,200 pounds (1,000 kilograms), of hazardous waste per month
• Large Quantity Generator (LQG) – Generate 2,200 pounds (1,000 kilograms) of waste or more per month, or more than 2.2 pounds (1 kilogram) of acutely hazardous waste per month; coordination with local fire officials is required with this status

Most school facilities and hospitals will likely be categorized as a CESQG, which requires the following steps per the EPA and/or state regulatory agencies:
• Identify all the hazardous waste generated
• May not accumulate more than 2,200 pounds (1,000 kilograms) of hazardous waste at any time
• Must ensure that hazardous waste is delivered to a person or facility that is authorized to manage it; written documentation must be kept for three years

Since less than one kilogram of acute hazardous waste is allowed per month for a CESQG, be sure to carefully monitor these specific wastes to ensure compliance. Acute hazardous waste is waste that is considered to present a substantial hazard whether managed properly or not, and may be fatal to humans in low doses or carry specific toxicities (examples include epinephrine syringes, acetone, creosote, cyanides, formaldehyde, mercury and urethane).

An important note, especially for hospital generators, is that the generator status is determined at the facility level, not the building or clinic level. This means that small clinics may be required to comply with the larger generator status of an umbrella facility, if these facilities are located on contiguous land or structures or under the control of the same owner/ operator. This is a point that is often overlooked in hospital hazardous-waste management and may result in fines, so be sure to double check this status and any possible state-level exemptions that may have been granted.

Also, be aware that a generator status may change from month-to-month in response to changing levels of hazardous waste. Hospitals carrying out efforts such as remodeling x-ray areas with lead shielding or schools conducting periodic laboratory and storage room cleanouts may see this happen in a certain month. All generators are responsible for the requirements of the current status.

Storing and Shipping Waste
Storage requirements in place for SQGs and LQGs are recommended for CESQGs as well, though not regulated. These include two types of storage areas.

Satellite Accumulation Areas: At or near the point of hazardous waste generation, the EPA stipulates that these areas are allowed to temporarily store waste for up to 72 hours after a container is completely filled before being moved to the main storage area. The satellite accumulation area must be under control of the process operator and can total up to 55 gallons of non-acute hazardous waste or one quart of acute waste. Labeling requirements exist for waste in these areas, which must be properly identified immediately upon generation. Individual states may have different regulations and should be referenced to ensure compliance.

Main Accumulation Areas (MAAs) or Main Hazardous Waste Storage Areas: These areas are required by the EPA to comply with regulations such as distance from a property line and the closest floor drain. Each container must be marked with the words “Hazardous Waste” with a specific description of contents and containers must be kept sealed, except for when adding and removing wastes. Again, individual state requirements may vary.

When shipping wastes off-site, CESQGs are required to ensure delivery of their hazardous waste to a treatment, storage and disposal facility (TSDF), a recycler, or an appropriate state-authorized solid waste facility. Failure to ensure this delivery or sending waste to another facility can result in loss of exemption and the generator will afterwards be treated as an SQG. SQGs are not allowed to send wastes to a municipal landfill and are also required to comply with additional packaging, labeling manifest and management requirements.

All shipped waste must be accompanied by a manifest, a multi-part form designed to track hazardous waste from generation to disposal. Most states require a specific manifest form, so contact the hazardous waste management agency in your particular state (the state that will be receiving the waste shipment). You may receive assistance with the manifest from your transporter or facility and can also use third-party software applications to create manifests and track waste.

Due to the high regulation and possibility for regulation infractions, it is important to use a transporter and TSDF that is trustworthy, experienced and licensed.

Reducing Waste
In order to help avoid additional disposal costs, the threat of potential spills, health or safety hazards or record- keeping requirements, look at reducing or eliminating as many waste streams as possible.

A review of purchasing procedures can help reduce waste generation. Solutions on this end can include looking for lesstoxic alternatives to materials commonly used, buying more suitable sizes and types of containers, curtailing the acceptance of samples to avoid accumulation, evaluating mechanical equipment for efficiency and centralized purchasing to eliminate unnecessary purchases.

It can also help to identify excess or mismanagement in receiving and inventory control procedures, including proper dock employee training to prevent property losses, using quality, reliable suppliers, setting inventory limits, maintaining proper temperature and humidity in storage facilities and reducing the number of similar products purchased. Also, be sure to control access to hazardous raw materials by designating central personnel – this can ensure all employees interacting with waste have been properly trained and will use materials only for their intended purpose and in the necessary amount.

Geoffrey A. Brown, Ph.D., is a vice president at ENPRO Services, a New England-based environmental service company that specializes in the remediation and management of oil and hazardous materials. Dr. Brown specializes in the assessment and remediation of complex oil and hazardous material release sites. He has more than 20 years of experience in the environmental field, with both environmental consulting/contracting firms and the Massachusetts Department of Environmental Protection.