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Home > Departments > Environment, Health & Safety > EH&S Programs > Chemical Safety > Managing Hazardous Chemical Waste > Top EPA Violations

Top EPA Violations

Top Most Prevalent Laboratory Hazardous Waste Problems Identified in EPA Audits

These problems and their listed solutions should be used as guidelines for all campus laboratories.

Maintenance

  • Containers of stock chemicals seen in poor condition.
  • Chemicals are unmanaged in labs or are abandoned when investigators or students leave labs.

Ensure that containers of stock chemicals are in good condition, labels are intact, and free from dust and residues. If there is no plan to use stock chemicals, then they should be disposed of as hazardous waste.

Check all areas in the lab, including shelves, under sinks and in locked cabinets, to make sure that there are no old chemicals or chemical waste materials. The EPA considers chemicals that are outdated, unused for a lengthy time, or in degrading containers to be hazardous waste. Also, when a PI moves out of a lab space, he or she is responsible for disposal of all chemicals. Otherwise, the department may be responsible for any costs related to identification and disposal of chemicals.

Labeling

  • Containers not labeled when wastes first added, informally labeled, or not labeled as waste at all.
  • Hazardous Waste labels not properly filled out.

Use the UB hazardous waste label. Follow the directions on the back of the label.

Use full chemical names – no formulas or abbreviations.

Add a label just prior to placing the very first drop of waste into the container. Make sure as much of the label is filled out as possible. The start date should be the date that the first drop of waste is added to the container.


Storage

  • Satellite Accumulation Areas (SAA) are not being located “at or near the point of generation”
  • Waste chemicals area being stockpiled in areas that are not under the control of the generator
  • Chemicals and wastes are being stored without caps and/or with funnels in them
  • Secondary containers are not being used

Waste chemicals should be accumulated close (within line of sight) to the place the experiment is conducted.

Waste chemicals should not be stored in departmental-common rooms, interstitial spaces, mechanical rooms, cold rooms, etc. Generators must maintain control of chemical waste until it is picked up by EH&S.

Waste containers should be stored in chemically resistant trays or tubs (secondary containers) so that any leaks will be contained. Segregate incompatible waste by using separate secondary containers for each compatibility group.

Disposal

  • Chemical wastes are being improperly disposed into drains. Some equipment or experiments are hard piped into drains.
  • Hazardous waste is being evaporated into the air or into the fume hood.
  • Some materials (such as solder, partially full aerosol cans, mercury amalgam contaminated materials, chemicals containing gels, etc.) are being disposed of in regular trash.

Drain disposal of chemical wastes is prohibited for a number of reasons. The few exceptions are detailed in the EH&S handout “Guidelines for Drain Disposal of Laboratory Waste”. Check your instruments and experiments and ensure that no chemicals are being discharged to the sanitary sewer drains.

Evaporation of chemicals is not an accepted method of waste disposal!

Check Material Safety Data Sheets, and manufacturer’s instructions for disposal instructions. Contact EH&S for help in determining proper disposal methods.