Wellesley College is committed to pollution prevention and the management of hazardous and solid wastes in compliance with applicable regulations.
It is Wellesley’s goal to (a) reduce these wastes; (b) reuse or recycle them, when possible, and (c) manage them safely, and in accordance with the law.
Hazardous materials and wastes generated on campus range from soiled and oily rags to toxic laboratory wastes and are handled by a wide variety of trained faculty and staff. The following information is designed to provide an introduction to the proper management and disposal of wastes on campus. These wastes should never be poured down the drain.
To everyone who may play a role in the generation and management of these wastes, please remember the following basic tenets of good management:
1. Compliance and safety is everyone’s job.
2. Manage the accumulation of wastes only at designated areas.
3. The EHS Department is available for assistance and guidance. Please contact:
Justin Finne , Environmental Health and Safety Officer at ext. 2762
Chemical Waste Segregation
Emergency Response Information
Gas Cylinder Disposal
Hazardous Waste – Definition
Hazardous Waste – Accumulation Areas (MAA’s and SAA’s)
Hazardous Waste – General Information
Hazardous Waste – Manifest
Hazardous Waste - Training
Paint Management - Oil and Latex Paints
Pollution Prevention & Waste Minimization
Toner & Ink Cartridges
All batteries used on campus will be sent off-site to a recycling facility. Batteries can be dropped off at the following locations:
• Residence Hall Bell Desks
• Physical Plant – First Floor
• Knapp Media Center
• Sage Hall Foyer (Observatory entrance)
• Jewett Arts Center - by Art Department's Main Office
• Tradeshops Building - Universal Waste Room
Contact EHS at x 2762 if additional battery storage locations are needed.
Refer to the Biological Safety Plan's section on Waste Disposal for the proper disposal of biohazardous waste.
The plan above covers proper storage, treatment and disposal of medical or biologoical waste. This includes blood and blood products, pathological waste, infectious agents, contaminated animal waste, sharops and biotechnology by-product effluents. Definitions of each of these materials can be found at the Department of Public Health Regulations at 105 CMR 480.010.
Waste containers should be physically separated according to this compatibility chart.
• Acids - Inorganic
• Acids - Organic
• Bases - Alkaline
• Bases - Flammable
• Flammable Liquids
• High Hazard Peroxide Formers
• Mercury or any solutions containing
• Metals or Solutions Containing
• Photo Fixer; Developer; Other
• Silica Gel
• Solvents-Non-halogenated organic
• Water Reactive Compounds
Other Resources: Prudent Practices in the Laboratory by the National Research Council. You can also perform a “google” search on ‘chemical compatibility storage’ for several resources.
Outside contractors are responsible for the removal of any waste they create. It is recommended that clear guidelines be established on project scope documents. Project Managers must ensure that waste generated is removed from campus and disposed of according to federal, state and local regulations.
In the event of a hazardous material release, take the following actions.
Minor Chemical Spill – a small spill (e.g., <1 Liter) in your immediate work area that does not pose a significant risk of harm. Spill kits are provided in many work areas for minor chemical spills. Make sure you are familiar with the location of the nearest spill kit.
1. Alert people in immediate area of spill.
2. If you clean up the spill, be sure to use the appropriate Personal Protective Equipment (PPE), such as safety goggles, gloves and long-sleeved lab coats.
3. Confine spill to a small area by circling the spill with absorbent and work inward. Use the appropriate kit to neutralize and absorb inorganic acids and bases.
4. Collect residue and place in container, label and dispose of as chemical waste. Check with your supervisor or EHS if it should be managed as a hazardous waste.
Major Chemical Spill - 1 Liter or Greater (and likely to produce a harmful concentration in the air)
1. Attend to injured or contaminated persons and remove them from exposure.
2. Alert people in the immediate area to evacuate.
3. If spilled material is flammable, turn off ignition and heat sources if you can do so without putting yourself at risk.
4. Close the door(s) to isolate the area.
5. Call Campus Police at Ext. 5555 from a safe location.
6. Campus Police will contact EHS who will secure a trained clean up crew to manage and dispose of spilled material.
1. Alert people in the immediate area.
2. Vacate the area and pull the fire alarm on your way out of the building.
3. Contact campus police at Ext. 5555 once you are in a safe location.
KEY PHONE NUMBERS
Wellesley College Campus Police – Ext. 5555 or 911 for all emergencies
Science Center Main Office Ext. 3000
EHS Office at Ext. 3882 or 2762
When disposing of equipment review the following prior to disposal.
1. Was the equipment used in radioactive experiments or used to store radioactive materials- Does it have a radiation sticker or is there a radioactive source in the equipment- If yes contact EH&S.
2. Could the equipment be contaminated with hazardous chemicals- If possible, the equipment should be thoroughly cleaned prior to disposal.
3. Was the equipment used with biohazardous material- If yes, the equipment should be decontaminated with appropriate cleaners prior to disposal.
4. If the equipment is a refrigerator or freezer or other type of equipment that could contain freon, contact Facilities at ext. 2767 to remove the freon prior to disposal.
5. Does the equipment contain oils, antifreeze or other types of chemicals- If yes, the chemical/oil should be drained prior to disposal. The drained material should be put into labeled hazardous waste containers. Contact EH&S for disposal.
6. If the equipment could contain asbestos, such as an oven, the EH&S Office should be contacted for disposal.
7. After following the above steps, make sure all hazard stickers are removed prior to disposal. (eg. "biohazard" or "flammable")
9. After following the above procedures, the equipment should be ready for pick up and disposal. If appropriate, place a workorder with Facilities.
1. Most five foot tanks are rented. When empty, these tanks are usually exchanged. Each department is responsible for this function.
2. Small lecture size gas cylinders should be returned to the manufacturer once empty. Keep manufacturer labels intact. If the manufacturer does not accept empty cylinders contact EHS at ext 2767 for disposal.
3. If gas samples, called “spuds” are received, arrangements should be made for return to the manufacturer. The department accepting these samples is responsible for this function.
4. Releasing contents of a cylinder as a disposal method, is strictly prohibited.
Fluorescent lamps contain mercury. All fluorescent lamps on campus must be treated as Universal Waste and sent off-site to a licensed disposal facility. CFLs (compact fluorescent lamps) and small spiral bulbs can be dropped off at the following locations as noted. All other bulbs are handled by Facilities.
- Residence Halls - at the Bell Desk
- Knapp Media Center - CFLs only
- Sage Hall Foyer (Observatory Entrance) CFLs only
- Trades Building - Universal Waste Room
Contact EHS at ext 2762 if more locations for lamp storage are needed.
All small handheld electronics used on campus will be sent off-site to a recycling facility. They can be dropped off at the following locations:
• Residence Hall - Bell Desks
• Physical Plant – First Floor
• Knapp Media Center
• Sage Hall Foyer (observatory entrance)
• Outside Jewett Art Office
•Tradeshops Building - Universal Waste Room
Contact EHS at ext 2762 if more locations for electronic storage are needed.
EPA regulations define a hazardous waste as a “solid waste or combination of solid wastes, which because of its quantity, concentration, or chemical, or infectious characteristics may (1) cause or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible illness or (2) pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of or otherwise managed.” EPA also states a waste is hazardous if it is “ignitable, corrosive, reactive or toxic”, or fits one of these lists: (1) Non-Specific Source Wastes (F Codes); (2) Discarded Commercial Chemical Products, Off-Specification Species, Container Residues and Spill Residues; (3) Acute Discarded Waste [in its original form](P Codes); (4) Toxic Discarded Waste [in its original form] (U Codes).
Two important federal acts are:
RCRA: The Resource Conservation & Recovery Act passed in 1976. It empowered the Environmental Protection Agency (EPA) to regulate the disposal of solid and hazardous waste. In Massachusetts, the Department of Environmental Protection (DEP) oversees this program. In 1984, the Hazardous & Solid Waste Amendments banned hazardous waste from landfills.
CERCLA: The Comprehensive Environmental Responsibility, Compensation and Liability Act, known as Superfund was enacted in 1980. This law makes the original generator of a waste responsible for that material forever, from "cradle to grave".
Main Accumulation Area (MAA): An area on campus where hazardous wastes are collected and managed prior to off-site shipment. Greater than 55-gallons of hazardous waste can be accumulated in MAAs. Check the following weekly:
• Containers Closed tightly
• No signs of leakage
• No signs of corrosion
• Segregated properly according to compatibility
• Proper aisle spacing
• Labels marked “Hazardous Waste”
• Labels indicate chemical constituents, hazards and date entered into storage.
• Signage indicating space a "Hazardous Waste" is visible
• Contact phone numbers available and posted
• Spill clean up supplies should be immediately available
• General Area secure (ie. locked)
• Floor/Shelving in good shape
Satellite Accumulation Area (SAA): An area that is at or near the site of generation of hazardous waste. The SAA must be under the control of a designated person who works in the immediate work area. Storage is limited to one container per wastestream, which can not exceed 55 gallons. The management requirements are less stringent than for a Main Accumulation Area but must be checked weekly.
• Containers in secondary containment
• Containers fully and properly labeled
• Containers closed at all times except when adding or removing chemical
• Containers properly segregated
• Containers in good condition
• Area secure
• SAA signage posted
• Only one container per waste stream/type
A hazardous waste contractor provides turnkey services for Wellesley College to safely and appropriately manage hazardous waste generated on-site. EHS manages the contract for all campus operations.
• Segregate hazardous chemical waste according to compatibility.
• Choose appropriate impervious containers for storage.
• Flammable wastes should only be stored in 1 gallon containers except for 2.5 gallons stored in fireproof rated cans.
• All containers must be properly labeled with waste labels. Complete chemical names must be used. Hazard info should be noted.
• Date the container when full or when ready for disposal.
• In a SAA, only one container at a time may be used to collect one waste stream (one type of waste).
• Waste containers must be kept tightly closed at all times except when pouring in waste. Funnels may only be inserted when pouring in waste.
Under EPA/DEP Hazardous Waste regulations, it is specified that a hazardous waste manifest must be used for the shipping of hazardous waste. The manifest must accompany the waste wherever it goes.
To ship hazardous waste off the premises, the waste must be properly packaged and labeled. The College contracts an outside company to analyze, certify, package and or label our drums and containers, as required by the U.S. Department of Transportation (USDOT). The contractor will transport the waste. Transporters must have an EPA identification number. The waste is then shipped to a facility permitted or authorized by the EPA to accept hazardous waste.
You must be approved by EH&S to sign a manifest - periodic trainings are required.
1. A Uniform Hazardous Waste Manifest will be used for each waste shipment.
2. Once the contractor is done packaging the shipment, they will record all materials to be disposed of on all or one of these forms: 1) packing slips, 2) hazardous waste manifests, and 2) land ban forms.
3. You will be provided with all documentation. Check the manifest before signing for:
• Correct US EPA ID NO. – contact EHS at ext 2762 for number
•All sections are complete and legible.
• Ensure that in section 5 – your ‘department/name’ or ‘EHS Office’ is indicated . This will ensure that the final manifest signed by the destination site is sent back on a timely basis.
• The generator (you) sign section 15.
4. The contractor will leave you with paperwork. Copy documentation and send all originals directly to EHS (see item 2 above). EHS will send required documentation to the State.
5. If/when you receive the "Designated Facility to Generator" copy in the mail, send original to EHS, take a copy for your files.
The only way to ensure that the College is meeting ‘Small Quantity Generator Status’ threshold quantities set by DEP is by totaling all waste generated on campus on a monthly basis. The number indicated on the waste manifest is the only way to accomplish this task.
All generators who are responsible for hazardous waste management in their area/department must receive annual awareness training. EHS will schedule this on an annual basis. Topics covered include generator status, hazardous waste determination, hazardous characteristics, accumulation and storage requirements, transportation procedures, manifests, land disposal restrictions, waste minimization, emergency response, and recordkeeping.
If your department would like to schedule a training session, please contact EHS at x 2762.
• Oil based paints and stains contain volatile organic compounds (VOCs) that vaporize at room temperature; vapors may be toxic when inhaled.
• Oil based paints and stains are flammable - store away from sources of sparks or heat.
• Old oil based paints and marine paints may contain lead, mercury, chromium or cadmium, which are toxic to humans, animals and the environment.
• Containers should be opened in a well-ventilated area. Wear appropriate respirator (must be approved by medical professional to wear a respirator – contact EHS) when pouring off or mixing large volumes of oil-based paints.
• Identify leftover paint as latex or oil-based. Latex paint is labeled as such or has instructions to clean up with water. Oil based paint may be labeled: alkyd, contains solvents, clean up with mineral spirits, combustible, or enamel.
• Pourable paint may be reused, unless it contains lead. To test if paint is still good, paint a small test area on clean surface and allow to dry for 48 hours. Place a piece of masking tape over the paint and pull off. If paint comes off on the tape, the paint is no longer good.
• To store usable paint for long periods of time, cover the opening of the paint can with a piece of plastic wrap and seal the lid tightly. Store the can upside down and away from heat.
• Do not store latex paint outside or in unheated area. Frozen latex paint cannot be reused.
• Do not put liquid paint in the trash or down the drain.
• Do not dry out oil based paints, stains, or wood finishes to dispose of in the trash. The volatile chemicals are air pollutants.
For surplus latex or oil-based paints:
• Take to the municipal surplus paint collection program, if available.
• If the paint is usable and there is a reasonable quantity, try to donate it to a community service organization or theater group.
• Latex paint can be disposed of as trash if dry. To dry small amounts, remove lid and let the paint dry in the can. For larger amounts, mix in speedi dri or pour one-inch layers of paint in a cardboard box lined with a plastic bag. Stir the paint occasionally to speed drying. Put completely dried paint in the trash.
• Hardened oil-based paint can also be disposed of in the trash.
• If no reuse or recycling option is available or convenient for oil-based paints, they should be saved for hazardous waste collection.
Information from: http://www.mass.gov/
Chemical Redistribution – Available in the Science Center for research chemicals. Unopened or unused portions of chemicals may be redistributed. Contact Harold Clark if you have unwanted chemicals to add to a redistribution program.
End of Process Treatment
End of process treatments can be incorporated. This can include neutralization procedures or other standard practices outlined in many reference materials. Contact EH&S for further info and reference documents.
Periodic inventories of chemical supplies, inventory control, and purchase of minimal quantities are all ways to manage chemicals in your area.
Use of micro-scale techniques or a decrease in the use of hazardous materials can reduce the amount of waste generated.
Use of non-hazardous and less toxic chemicals in your area is a safe and environmentally friendly way to reduce chemical hazardous waste.
Segregation and Characterization
Hazardous and non-hazardous waste should not be mixed. Follow guidelines on the proper segregation of hazardous waste to minimize costs.
Employees and students should all be made aware of the above concepts to reduce waste generated.
To protect yourself and others from injury from sharps, place all needles, pasteur pipettes, syringes, suture needles, scalpels, and razor blades into standard sharps containers. These containers are constructed of a thick red plastic and labeled with the biohazard symbol. Place sharps containers in convenient locations near work areas so they will be used. Do not overfill the sharps containers. When containers are ¾ full, close the box, and contact the designated coordinator in your building for a pick-up. All sharp containers are sent off-site for disposal.
Contact EH&S for MAA or SAA signage which is required to be posted by all accumulation areas.
• No Smoking Signs must be posted by all MAA’s.
• “No Pouring Chemicals Down the Drain” signage available for sink areas.
Used toner and ink cartridges may be sent back to the manufacturer. Most manufacturers are including return boxes for shipment with orders. Ink jet cartridge mailers are available in Physical Plant, first floor. Stop by or email firstname.lastname@example.org for a mailer.
Questions on disposal may be directed either to the distributor, manufacturer or EH&S.
• Material that cannot go to a regular landfill, so cannot be disposed of in the regular trash.
• Requires special handling procedures
• Must use a licensed disposal contractor.
• Lamps and Bulbs that contain mercury or lead.
o Examples include fluorescent, neon, mercury vapor.
• Cathode Ray Tubes or CRTs contained in computer screens and television sets.
• Batteries to include nickel-cadmium, nickel metal-hydride, lithium and small sealed lead acid batteries. See "BATTERY WARNING - FIRE DANGER" poster above.
• Larger lead acid batteries for cars and generators are to be recycled by the vendor providing the new battery.
• Thermostats that contain a mercury.
• Certain unused pesticides.
• Universal Waste must be kept in containers or packages.
• Containers must be kept closed and lack evidence of leakage, spillage, or damage.
• It is recommended that box dividers are used to avoid breakage.
• Designated storage areas must be set up to manage universal wastes on campus
• Waste lamps must be put in appropriate storage at the end of each work shift and placed in designated universal waste accumulation areas.
• The waste itself or the package must be labeled:
“Universal Waste - _____________” (type of waste) and the date the accumulation started.
Accumulation Time Limits
All universal wastes must be disposed of within one year of teh accumulation start date.
• To ensure disposal within one year, EHS maintains an inventory of all Universal Waste accumulation areas and the oldest container within each area across campus.
Releases, Spills, or Breakage
• Must be immediately contained, cleaned up and the material disposed of properly.
• Must track waste shipments and generation to know ‘waste status’.