Hazardous Waste Disposal GuideOnce a material is deemed no longer useful and is ready for disposal it is necessary to consider whether it can be safely and legally put in a dumpster for landfilling, poured down the drain or set aside as a hazardous waste for special disposal.
Campus employees have a responsibility to manage their wastes appropriately not only because of the desire to protect our natural resources but also because of legal restrictions which control disposal. This guide is intended to provide you with the information you need to dispose of waste materials properly.
If you are unsure of correct disposal methods or have additional questions please call the University Safety Manager at ext. 2273.
What is Hazardous Waste?
The Wisconsin statutes define waste as any liquid, solid, or gaseous material that can no longer be used for its originally intended purpose because it has become contaminated or has been used in some process. A waste is also any material which is still usable for its originally intended purpose but which you decide to discard. Regulations (Wisconsin Administrative Code Chapter NR 600) define a hazardous waste in two ways: listed hazardous waste and characteristic hazardous waste.
Listed Hazardous Wastes
These are specific wastes that are classified as hazardous in the regulations. These listed wastes are found in the four tables which have been reprinted in the appendix. Each listed waste has a hazardous waste number which starts with the letter "F", "K", "P", or "U."Characteristic Hazardous Waste
"F" Waste - waste that results from production or waste treatment process, are discarded chemical products or are contaminated with a specific chemical.
"K" Waste - waste that results from specific production or waste treatment processes. The campus rarely has this type of waste.
"P" Waste - waste chemicals that are considered acutely hazardous when discarded because they can be extremely dangerous to human health or the environment. Cyanides and arsenic as well as some pesticides are found in this table. "P" wastes are of particular concern on the UWGB campus since a small quantity of this waste can make the difference between our classification as a large quantity generator versus a small quantity generator.
"U" Waste - waste which is considered toxic but not acutely hazardous. Examples include phenol, formalin, chlorobenzene, aniline dyes and carbon tetrachloride.
The majority of hazardous waste which the campus generates is characteristic hazardous waste. It is not included on any of the lists mentioned above but is considered hazardous because it exhibits one of the four characteristics mentioned below.Empty Containers
Ignitable - a liquid with a flash point less than 140 Fahrenheit, an ignitable compressed gas or oxidizer, or other material that can cause fire through friction absorption of moisture or spontaneous chemical changes, Common examples include used oil-based paint, used paint thinner, adhesives and mineral spirits.
Corrosive - a water containing liquid with a pH less than or equal to 2.0 or greater than or equal to 12.5, or a liquid that corrodes plain carbon steel at a rate greater than 6.35 mm per year. Examples include waste rust removers and waste battery acids.
Reactive - a waste that is normally unstable, readily undergoes violent changes without detonating, reacts violently with water, forms a potentially explosive mixture with water, or generates toxic gases or fumes when mixed with water or noncorrosive materials, is incapable of detonation or explosive reaction, or is a forbidden Class A or Class B explosive.
Toxic - A waste is TC hazardous if (according to the Toxicity Characteristic Leaching Procedure) it exceeds the regulatory levels for any of the eight metals, six pesticides or 25 organic chemicals listed in the appendix under toxic substances. This list includes metals like chromium, lead, mercury, silver and organic chemicals like benzene, chloroform, methyl ethyl ketone, and butadiene.
If you have a waste which is listed in one of the tables or exhibits one of the characteristics mentioned above, do not place it in a dumpster for landfill. Hazardous waste must be shipped with the campus hazardous waste shipment. Contact the University Safety Manager, ext. 2273, for proper disposal.
Empty containers that formerly contained hazardous waste can be put in the dumpster for landfill. A container is empty if all waste has been removed by the methods commonly used to empty that type of container (e.g. pouring or pumping).In addition, the container must have less than one inch of waste remaining, or 3% or less by weight of waste remaining if the container holds 110 gallons or less or .3% or less by weight or waste remaining if the container holds more than 110 gallons. Containers that held acutely hazardous waste ("P" wastes) must be triple rinsed to be considered empty. Rinse water is considered hazardous if it has any of the characteristics mentioned above.Mixtures
If you mix one gallon of a hazardous waste with one gallon of a nonhazardous waste you now have two gallons of hazardous waste and you have doubled the disposal costs. According to the mixture rule, nonhazardous waste that is mixed with listed hazardous waste is automatically hazardous waste. Therefore, do not mix your wastes. Dilution of characteristic hazardous waste to make it nonhazardous is considered treatment and is subject to regulatory requirements. The campus does not have a license to treat hazardous wastes. The only exception to the treatment restriction is simple neutralization which is discussed under sewer disposal.
Material Which May Be Safely Placed in a Landfill
Many solid chemicals may be safely disposed via the normal trash if the containers are tightly capped and of good integrity. Examples are given on the list below. If disposal is intended of more than five pounds of any one of these chemicals, contact the campus Hazardous Waste Coordinator for further evaluation.
| Acid, Ascorbic
Aluminum Oxide Amino
Acids, alpha and salts
Ferrous Ammonium Sulfate
Potassium Sodium Tartrate
| Potassium Sulfite
SDS (sodium dodecyl sulfate)
Sodium Ammonium Phosphate
What Can Be Sewered?
Waste disposal would be greatly simplified if all liquid waste could be poured down the drain. However, common sense tells us that some things shouldn't end up in Green Bay. What can or cannot be poured down the drain is regulated by the Green Bay Metropolitan Sewerage District. The METRO Sewerage System must comply with the Clean Water Act and other State and Federal Regulations which limit discharge. Regulations concerning sewer use are found in the Green Bay Metro Sewer Use Ordinance, adopted May, 1993. The material below covers the main points of the ordinance which may apply to campus employees. If you want a copy of the complete ordinance please contact Jill Fermanich, ext. 2273.
It is easier to describe what should not be disposed of via the sanitary sewer rather than what is allowed. It is important that a distinction is made between a sanitary sewer and a storm sewer. Storm sewer run-off typically goes directly into the river/bay, therefore it is very important that liquids are not disposed of via a storm sewer. Sanitary sewerage is pre-treated before being discharged into the river/bay. The most current Sewer Use Ordinance specifically prohibits the following from being disposed of via a sanitary sewer:
- Very hot (> 150o F) or very cold ( < 32o F) liquids. Generally benchtop quantities of very hot or very cold liquids used in academic laboratories can be poured down the drain since all campus liquids wastes are mixed together and liquid temperatures will moderate before leaving the campus.
- Waste which creates a fire hazard (flash point < 140 oF) - check the MSDS or label for this information. Flammable solids and gases should also be excluded from sewerage.
- Volatile substances such as gasoline, kerosene, naptha, benzene, toluene, xylene, ethers, alcohols, ketones, aldehydes and peroxides. Benzene concentrations shall not exceed 0.5 mg/L.
- Solid or viscous material which is likely to cause obstruction to sewer flow e.g. mud, straw, plastics, wax, wood, animal guts
- Liquids with a pH < 5 or > 9. Campus personnel can neutralize acids and bases and then pour down the drain. See comments below on neutralization.
- Radioactive wastes which do not comply with the National Pollutant Discharge Elimination System
- Petroleum oil, nonbiodegradable cutting oil, or products of mineral origin
- Strongly colored solutions
- Certain heavy metals as listed below with restrictions on concentration and quantity. If both concentration and quantity amounts are exceeded, liquid waste cannot be sewered:
Academic institutions tend to discharge small quantities of a variety of substances as opposed to the industrial discharge of large quantities of a limited number of substances. It is possible that small quantities of one of the above prohibited items may be safely sewered. However, before you do this, contact the UWGB University Safety Manager, Jill Fermanich, ext. 2273, who will seek permission from the METRO Sewerage District.
If you accidentally discharge one of the prohibited substances in a sanitary sewer, the campus must notify the METRO Sewerage District. Please contact Jill Fermanich, ext. 2273, if this occurs.
Material Which May Be Safely Sewered
- alcohols (methyl-, ethyl-, propyl-, isopropyl-, "reagent" alcohol) acetone, and glycerine - If the concentration is less than 24% alcohol by volume benchtop quantities may be flushed down the drain of a chemical sink with 20 volumes of water. However, it is not allowable to dilute alcohol for the purpose of rendering it non-hazardous.
- dilute, < 20%, aqueous solutions of potassium chlorate or sodium chlorate
- dilute, < 20%, aqueous solutions of the following chemicals
| AciAcid, Ascorbic
Amino Acids, alpha and salts
Ferrous Ammonium Sulfate
Methyl Salic ylate
Potassium Carbonate Potassium Iodide
|Potassium Sodium Tartrate
SDS (sodium dodecyl sulfate)
Sodium Ammonium Phosphate Sodium Benzoate
Thymol Tin Oxide
If liquids meet all standards for the sanitary sewer except for pH, campus employees may neutralize the solution before pouring down the drain. Use proper equipment. Goggles, gloves, apron, and hood are required. Add neutralizing agent slowly, stirring constantly. If you are not familiar with neutralization techniques, do not attempt to neutralize solutions. Call the Hazardous Waste Manager for assistance. Report neutralization activities to the University Safety Manager for regulatory reporting.
Acidic solutions ( pH <5)Note: For highly concentrated acids, neutralization with a relatively dilute basic solution will take a very large volume of base and a long time. In this case, consider neutralization using a concentrated basic solution with plenty of ice for an ice bath, performed slowly, and carefully and with constant stirring. Monitor the temperature of the solution with a suitable thermometer to ensure that the solution doesn't get too hot. The same is true for neutralizing some concentrated bases.
Adjust the pH to 5-9 using a dilute solution (e.g. KOH, NaOH, NaHCO3). Use a pH meter, indicator solution, or pH paper to determine the pH.
Flush down the drain of a chemical sink with 20 volumes of cool water.
Basic solutions ( pH > 9)
Adjust pH to 5-9 using a dilute solution (e.g. HCl, H2SO4, HNO3 ). Use a pH meter, indicator solution, or pH paper to determine pH.
Flush down the drain of a chemical sink with 20 volumes of cool water.
Disposal of Hazardous Waste
If you are generating a waste that can neither be sewered or landfilled, you are generating a hazardous waste. Satellite accumulation is a regulatory term that refers to hazardous waste being collected by, and kept under the control of the person who generates it. Therefore, if you are generating and collecting hazardous waste you must adhere to the following satellite accumulation requirements until the waste is transferred to the Campus hazardous waste disposal facility:Disposal to Atmosphere
Who Pays For Disposal? At this time the majority of waste disposal costs are covered by a general campus waste disposal account. However there are two major exceptions to this:
- Clearly label waste containers and identify hazardous constituents as they are added to the container (e.g. "hazardous waste organic solvents, contains toluene and xylene"). Appropriate labels can be obtained from the University Safety Manager.
Use only containers that are in good condition and made of, or lined with, a material that will not react with, or be incompatible with, the waste being stored.
- Keep the waste containers closed at all time, except when adding or removing waste; open funnels sitting in the opening of a waste container is considered an open container by regulatory agencies.
- Handle and store waste containers properly to prevent rupture or leakage.
- Do not mix hazardous waste with nonhazardous waste. Do not mix incompatible wastes.
- Know what is required of you by your Campus emergency response plan should a spill occur; keep suitable spill control equipment on hand and keep emergency phone numbers posted in your lab or work area. See the Emergency Response section of this guide for additional information.
- Once a container is full, date the container and contact the University Safety Manager, 2273, to ensure the waste is transferred to the Campus hazardous waste storage site within three days.
- Units funded by auxiliary funds are responsible for their waste disposal costs.
- Disposal costs for hazardous wastes generated by a funded research project must be included in funding requests.
Disposal of liquids or discharge of hazardous vapors, gases, fumes and dusts to the atmosphere is not considered a disposal method. Laboratory hoods should not be used to evaporate materials from open chemical containers.
The EPA has broad powers to enforce waste minimization based on the Hazardous Solid Waste Amendments of 1984. As a small quantity generator, the campus certifies they have made a good faith effort to minimize waste generation each time a manifest is signed.
It is important that all persons and departments generating hazardous waste consider how they can contribute to the waste minimization effort. The goal is to either prevent the formation or production of pollutants at the source or reduce the amount of hazardous waste that is generated.
Basic waste minimization options include:
If you have (or will be doing) any of the above please contact Jill Fermanich so this information can be used to document campus commitment to waste minimization.
- waste stream segregation
- good housekeeping
- inventory control/ordering chemicals in smaller containers
- material substitution
- using smaller scale
- modifying specific experiments
The campus is no longer allowed to place most batteries in the normal trash. Current policies on battery disposal apply only to businesses (such as UW-Green Bay). Homeowners are encouraged to bring their waste batteries to Brown County Household Hazardous Waste Facility at 2561 S. Broadway, Green Bay (492-4950) for proper disposal.-Top-
The following is a battery disposal guide for batteries generated by campus operations:
- Alkaline Batteries
- Alkaline batteries include AAA, AA, A, C, D and 9 volt.
- Disposal: Normal Trash
- Lead Acid Batteries
- Lead acid batteries are found in autos, trucks, etc.
- Disposal: Do not place in normal trash. Exchange old battery for new one at dealer or contact Jill Fermanich, ext. 2273, for recycling.
- Button Batteries
- Button batteries are found in watches, calculators, cameras and other small equipment. They can contain silver oxide, mercury, lithium or cadmium. These materials are considered hazardous waste. Contents can be determined by reading original battery packaging.
- Disposal: Do not place in normal trash. Either return to dealer, who sold the battery, for recycling (prior arrangement required) or contact Jill Fermanich, ext. 2273, for hazardous waste disposal. Button batteries can only be recycled if they are segregated on the basis of metal content. To facilitate this, try to get into the habit of keeping the original packaging to refer to once the battery is spent.
- Lithium Batteries
- Lithium batteries are found in some electronic equipment. See original packaging for content information.
- Disposal: Do not place in normal trash. Either return to dealer, who sold the battery, for recycling (prior arrangement required) or contact Jill Fermanich, ext. 2273 for hazardous waste disposal. Keep lithium batteries separate from other batteries when collecting.
- Nickel Cadmium (NiCad) Batteries
- NiCad batteries are found in items including medical equipment, pagers, and cellular telephones. Check original packaging for content information.
- Disposal: Do not place in normal trash. Either return to dealer, who sold the battery, for recycling (prior arrangement required) or contact Jill Fermanich, ext. 2273 for hazardous waste disposal. Keep NiCad batteries separate from other batteries when collecting.
Fluorescent lamps contain small quantities of mercury and other metals that are harmful to the environment and to human health. If these lamps are burned or thrown into landfills, the mercury and lead in them can be released into the environment, where contamination problems may occur. UW-Green Bay sends the following lamps off campus for recycling:Infectious Waste
Collection of used fluorescent lamps is handled by Operations since they are responsible for bulb replacement. If your department generates any of the above lamps which should be sent out for recycling please contact Operations or Jill Fermanich. Avoid breakage of lamps. Similar to battery disposal policies, fluorescent lamp disposal requirements apply to businesses. Homeowners are encouraged to bring their spent fluorescent lamps to the Brown County Household Hazardous Waste Facility, 2561 S. Broadway, Green Bay (492-4950) for recycling.
- fluorescent lamps
- sodium-vapor lamps
- high- and low-pressure mercury vapor lamps
- high intensity discharge (HID) lamps
Infectious waste is regulated under the recently enacted Chapter NR 526, Medical Waste Management. A waste is considered to be an infectious waste if it falls in one of the following categories:Photographic Waste
Items which generally are not considered infectious waste include the following:
- Sharps, as follows:
- Contaminated sharps which are both infectious and may easily cause punctures or cuts in the skin, including but not limited to: hypodermic needles, syringes with needles attached, scalpel blades, lancets, broken glass vials, broken rigid plastic vials and laboratory slides. Contaminated means they have come in contact with blood or other potentially infectious material.
- Unused or disinfected sharps which are being discarded, including hypodermic needles, scalpel blades, lancets and syringes with needles attached. Note: Only "contaminated" broken glass, plastic vials, laboratory slides, etc. are considered infectious waste. However, all discarded sharps (contaminated or not) such as hypodermic needles, scalpel blades, lancets and syringes with needles attached are considered infectious was
- Bulk blood and body fluids from humans. "Bulk blood and body fluids" means drippable or pourable quantities or items saturated with blood or other potentially infectious materials. In making this determination ask yourself whether blood or other potentially infectious material is drippable, squeezable, pourable or flakeable.
- Human Tissue
- Microbiological laboratory waste
Note: Microbiological waste means cultures derived from clinical specimens or laboratory equipment which has come in contact with these cultures.
- Tissue, bulk blood or body fluids from an animal which is carrying a zoonotic infectious agent.
- Items soiled but not saturate with blood of body fluids from humans (application of the drippable, squeezable, pourable, flakeable rule).
- Tissue, blood, body fluids or cultures from an animal which is not known to be carrying or experimentally infected with a zoonotic infectious agent.
- Animal manure and bedding.
More than one treatment option is available for infectious waste. Sharps are collected and sent off campus for incineration to comply with Chapter NR 526. The remaining infectious waste is autoclaved (steam sterilization) and then disposed of as normal trash.COLLECTION AND HANDLING
- Infectious waste should be segregated and contained in an enclosed area until it is treated.
- Sharps should be placed in a puncture-proof and leak-proof container with a sealable lid. The outside container must be labeled with a visible biohazard emblem (fluorescent orange background with contrasting color - typically black - biohazard symbol). Red sharps containers are commercially available.
- Other infectious waste should be placed in an infectious waste bag (leak proof) with a biohazard label.
- Contact either Mark Damie, Biology Lab Technician, or Health Services to arrange for disposal.
The campus reclaims silver from photographic waste. Although the Metropolitan Sewerage District currently does not limit silver discharge, the campus does silver reclamation to prevent possible contamination of our natural resources. If your department generates photographic waste which contains silver, please contact Jill Fermanich, ext. 2273, to arrange for reclamation. There is no charge to departments for this service. Generally all other photographic waste can be disposed via the sanitary sewer.Radioactive Waste
Radioactive waste cannot be disposed of via typical hazardous waste disposal options such as incineration. Very few sites will accept radioactive waste for disposal. As a result, disposing of radioactive waste is expensive. Before generating any radioactive waste, please contact Jill Fermanich to discuss disposal options and costs. In addition to potential waste disposal requirements, work with radioactive isotopes requires compliance with our NRC license and prior approval from the Campus Radiation Safety Committee.
Emergency Procedures - Chemical Spill or Release
When an accidental chemical spill or release occurs the UWGB employee on the scene (staff, instructor, researcher, laboratory technician, etc.) decides whether to treat the situation as a nonemergency chemical (simple) spill or as an emergency spill. Knowledge of the hazards associated with the spilled or released chemical is required to make this determination. An emergency is any immediate threat to personal safety and health, the environment, or property that cannot be controlled and corrected safely and easily by the individual at the scene. Emergencies generally include injury, fire, explosion threat, toxic conditions, illness (e.g. heart attack or stroke), and property damage threat. Use the Chemical Spill Assessment flowchart to help make the determination of whether a spill/release constitutes an emergency. A spill or release that meets criteria as an emergency should not be handled by campus employees. For emergency spills, the area should be evacuated and Public Safety (2300) should be called for assistance.
If a spill or release is discovered by an Operations employee or an employee not familiar with the incident and a hazard evaluation cannot be made, the spill or release should be treated as an emergency. Call 2300. A person unfamiliar with a chemical substance and its hazards should not attempt any type of clean-up or containment.
It is important that all employees understand that once a spill or release is considered an emergency, containment and clean up of the spill will be coordinated by the Green Bay Fire Department.
The following section explains how to handle a nonemergency or simple spill or release in the laboratory.
B. Simple Spill Clean up
- A spill containment/clean up plan should be established to handle chemicals you use in the laboratory. Consideration must be given to the maximum amount used and concentrations of chemicals. Familiarize yourself with spill clean up equipment available. If necessary obtain sufficient supplies to handle potential spills.
- The person causing a spill or release is responsible for clean up to the extent of his/her ability. Laboratory technicians may be available for assistance but they are not responsible for clean up. Persons who work with chemicals are expected to know how to safely clean up spills of these chemicals.
- Prevent the spread of dusts and vapors. If the substance is volatile or can produce airborne dusts, close the laboratory door and increase ventilation (through fume hoods, for example) to prevent the spread of dusts and vapors to other areas.
- Neutralize acids and bases if possible. Spills of most liquid acids or bases, once neutralized can be mopped up and rinsed down the drain (to the sanitary sewer). However, be careful because the neutralization process is often vigorous, causing splashes and yielding large amounts of heat. Neutralize acids with soda ash or sodium bicarbonate. Bases can be neutralized with citric acid or ascorbic acid. Use pH paper to determine when acid or base spills have been neutralized.
- Control the spread of the liquid. Contain the spill. Make a dike around the outside edges of the spill. Use absorbent materials such as vermiculite, cat litter, or spill pillows.
- Absorb the liquid. Add absorbents to the spill, working from the spill's outer edges toward the center. Absorbent materials, such as cat litter or vermiculite, are relatively inexpensive and work well, although they are messy. Spill pillows are not as messy as other absorbents, but they are more expensive. Note that special absorbents are required for chemicals such as hydrofluoric and concentrated sulfuric acids.
- Collect and contain the cleanup residues. The neutralized spill residue or absorbent should be scooped, swept, or otherwise placed into a plastic bucket or other container. For dry powders or liquids absorbed to dryness, double bag the residue using plastic bags. Additional packaging may be required before the wastes can be transported from your laboratory. Be sure to label containers.
- Dispose of the wastes. Keep cleanup materials separate from normal trash. Contact Jill Fermanich, 2273, for guidance in packaging and labeling cleanup residues. Promptly place cleanup wastes in an appropriate hazardous waste receptacle.
- Decontaminate the area and affected equipment. Ventilating the spill area may be necessary. Open windows or use a fan unless the area is under negative pressure. IN some instances, your environmental health and safety officer can test the air to ensure that hazardous vapors are gone. For most spills, conventional cleaning products, applied with a mop or sponge, will provide adequate decontamination.
C. Special Precautions
When a mercury spill occurs, first cordon off the spill area to prevent people from inadvertently tracking the contamination over a much larger area. Generally, a special mercury vacuum cleaner provides the best method of mercury spill cleanup. Do not use a regular vacuum cleaner, because you will only disperse toxic vapors into the air and contaminate your vacuum cleaner. If a special mercury vacuum is not available, first use an appropriate suction device to collect the big droplets, then use a special absorbent to amalgamate small mercury droplets.
- Flammable liquids. Remove all potential sources of ignition. Vapors are what actually burn, and they tend to accumulate near the ground. Flammable liquids are best removed though the use of spill pillows or pads. Spill pads backed with a vapor barrier are available from most safety supply companies. Because flammable liquids will probably be incinerated, avoid using inert absorbents such as cat litter. All used absorbent materials should be placed in heavy-duty poly bags, which are then sealed, labeled, and disposed through your facility's hazardous waste management program. Before resuming work, make sure the spill has been adequately ventilated to remove flammable vapors.
- Volatile Toxic Compounds. Use appropriate absorbent material to control the extent of the spill. Spill pillows or similar absorbent material usually work best because they do not have the dust associated with cat litter, vermiculite, or corn cobs. Place all used absorbent materials in heavy-duty poly bags. Seal the bags, label them and hand them over Jill Fermanich, 2273. Again, make sure the spill area has been adequately ventilated before resuming work.
- Direct Contact Hazards. Carefully select suitable personal protective equipment. Make sure all skin surfaces are covered and that the gloves you use protect against the hazards posed by the spilled chemical. Often it is a good idea to wear two sets of gloves: one as the primary barrier, the second as a thin inner liner in the event the primary barrier fails. When the cleanup is complete, be sure to wash hands and other potentially affected skin surfaces.
- Mercury Spills. Mercury spills rarely present an imminent hazard unless the spill occurs in an area with extremely poor ventilation. The main exposure route of mercury is via vapor inhalation. Consequently, if metallic mercury is not cleaned up adequately, the tiny droplets remaining in surface cracks and crevices may yield toxic vapors for years.
Report all hazardous waste spill incidents to the University Safety Manager, 2300. Major incidents are almost always preceded by numerous near misses.