Section Contents

Disposal of chemical waste (hazardous waste), radioactive materials, biological agents, universal and electronic wastes must be in accordance with procedures established by Environmental Health & Safety (EHS).



8.1.2 SCOPE
8.1.6a Characteristics
8.1.6b Liquid Waste
8.1.6c Examples of Hazardous Waste
8.1.6d Examples of Waste That Do Not Fall Under HWMP
8.1.7a Labeling Containers
8.1.7b Waste Storage Areas
8.1.7c Container Management
8.1.7d Weekly Inspections


8.1.1 Introduction

The Resource Conservation and Recovery Act (RCRA) is the federal law that governs the handling of hazardous wastes. The Environmental Protection Agency (EPA) and the District of Columbia have developed regulations for compliance with RCRA. The District's regulations are in some instances more stringent or broader in scope than the EPA regulations.

This Hazardous Waste Management Plan (HWMP) serves as a guide for handling hazardous wastes generated at The Catholic University of America (CUA). The goal of the HWMP is to handle hazardous waste in a safe, efficient, and environmentally sound manner and to comply with local and federal regulations.


8.1.2 Scope

This plan applies to each department at CUA that generates hazardous wastes. It covers labeling, storage, transportation, inspections, and record keeping.


8.1.3 Chemical Hygiene Officer

Each department that generates hazardous waste must designate an individual or individuals to be its Chemical Hygiene Officer (CHO). CHOs will be responsible for ensuring that their departments comply with hazardous waste regulations. They will be trained to do so by EHS.

There are two groups of CHOs at CUA: (1) CHOs who manage Hazardous Waste Accumulation Areas and (2) CHOs that do not manage Hazardous Waste Accumulation Areas.

  1. CHOs who manage Hazardous Waste Accumulation Areas:
    • Work in departments that generate hazardous waste on a regular basis, or
    • Work in departments that generate hazardous waste in quantities greater than 5 gallons every 90 days, or
    • Work in departments that generate highly hazardous waste.

    These departments include: Chemistry, Biology and Vitreous State Laboratory (VSL).

  2. CHOs that do not manage Hazardous Waste Accumulation Areas:
    • Work in departments that infrequently generate hazardous waste
    • Work in departments that generate hazardous waste in quantities less than 5 gallons every 90 days.
    • The CHOs in these departments must contact EHS at x2698 anytime hazardous waste is generated or if there is concern regarding hazardous waste generation. EHS will pick up material in question within seven calendar days following contact.

    These departments include, but are not limited to: Architecture, Athletics, Art, Drama, Engineering, Facilities Maintenance, Law, Library, Music, Nursing, Campus Programs, Psychology.


8.1.4 Responsibilities


  • Maintain the HWMP, based on regulatory changes and the needs of the CUA community.
  • Assist in implementing the HWMP on campus.
  • Train generators and CHOs in the proper handling of hazardous waste.
  • Remove hazardous wastes from their storage areas upon notification by the CHO.
  • Arrange for the transportation and disposal of hazardous waste from campus within 180 days after a waste is deemed hazardous.
  • Be the central repository for record keeping of all documents related to the accumulation, transportation, storage, treatment, and disposal of hazardous wastes.

Head of Hazardous Waste Generating Departments:

  • Designate an individual or individuals to be Chemical Hygiene Officers.
  • Ensure CHOs receive training.
  • Implement this plan in the department.


  • Be familiar with the HWMP.
  • Attend training provided by EHS.
  • Identify or deem waste as hazardous waste.
  • Work with their CHO to properly label, segregate and store hazardous wastes.

Chemical Hygiene Officers (Appointed by the Department Head):

  • Attend initial and annual training in Hazardous Waste Management.
  • Assist EH&S to implement the HWMP.
  • Establish waste storage areas in the department with the assistance of EH&S.
  • Assist generators to properly label, store, and segregate hazardous waste.
  • Inspect waste storage areas weekly to ensure hazardous waste is properly labeled, stored, and segregated.
  • Contact EH&S to collect and remove hazardous waste from the Hazardous Waste Accumulation Areas in a timely manner.
  • Assist EH&S to identify hazardous waste to be removed from campus within 90 days.
  • Maintain accurate files of inspection logs, and training documentation.


8.1.5 Generator Status

The University is regulated on the quantity of hazardous waste produced monthly. According to D.C. regulations, because the University generates more than 100 kilograms but less than 1,000 kilograms of hazardous waste per a calendar month, we are classified as a Small Quantity Generator. As such, we are permitted to accumulate hazardous waste on campus for no more than 180 days. The hazardous waste must be properly shipped from campus for disposal or treatment within that 180 days.


8.1.6 Hazardous Waste Determination

Solid Wastes:

Solid wastes are materials that are no longer used and are set aside for disposal. Solid wastes include abandoned items, those that are ready to be disposed, or those that are ready to be recycled. They do not include nuclear sources or domestic sewage, among other exceptions. Solid wastes may be solid, liquid, or gas.

Chemicals no longer suitable for use are subject to hazardous waste regulations. Some examples include:

  • Chemicals that are no longer used, e.g., past the expiration date
  • Chemicals with obliterated labels, e.g., corroded, faded, or smeared
  • Chemicals with no labels, e.g., sample vials, jars, or beakers
  • Samples that cannot be identified

Hazardous Waste:

RCRA defines a hazardous waste as a solid waste that because of its quantity; concentration; or physical, chemical, or infectious characteristics may cause or significantly contribute to an increase in serious; irreversible; or incapacitating, reversible illnesses or pose a substantial present or potential hazard to human health, safety, or welfare or to the environment when improperly treated, stored, transported, used, or disposed of or otherwise managed.

A solid waste is a hazardous waste if it is not excluded from regulations and it meets any of the following descriptions:

  • Solid waste that exhibits one or more of the hazardous waste characteristics (termed a characteristic waste): ignitability, corrosivity, reactivity, or toxicity. (See Section 6.1)
  • Solid waste that is identified on any of the hazardous waste lists (termed a listed waste): non-specific source wastes (F list), specific source wastes (K list), commercial chemical products (P and U lists). (See Section 6.2)
  • Solid waste that is a mixture of a solid waste and one or more listed hazardous wastes.
  • A mixture of solid waste and one or more characteristic hazardous wastes.
  • Residues derived from the treatment of listed hazardous waste.

If there is uncertainty as to whether or not a solid waste is hazardous, deem the waste hazardous and apply the HWMP or contact EHS for assistance. 

8.1.6a Characteristics


A solid waste that has any of the following properties displays the characteristic of ignitability and is considered a hazardous waste:

  • A liquid, other than an aqueous solution containing less than 24 percent alcohol by volume, with a flash point below 60oC (140oF)
  • A non-liquid, capable under standard temperature and pressure, of causing fire through friction, absorption of moisture or spontaneous chemical changes, and when ignited burns so vigorously and persistently that it creates a hazard
  • An ignitable compressed gas, which includes gases that form flammable mixtures at a concentration of 13 percent or less in air
  • An oxidizer, such as permanganate, inorganic peroxide, or nitrate that readily stimulates combustion of organic materials


A solid waste that has any of the following properties displays the characteristic of corrosivity and is considered a hazardous waste:

  • Is aqueous and has a pH less than or equal to 2 or greater than or equal to 12.5, using EPA-specified or approved test methods
  • Is a liquid and corrodes steel (SAE 1020) at a rate greater than 6.35 mm (0.25 inch) per year at a test temperature of 55oC (130o F)


A solid waste that has any of the following properties displays the characteristic of reactivity and is considered a hazardous waste:

  • Is normally unstable and readily undergoes violent change without detonation
  • Reacts violently with water
  • Forms potentially explosive mixtures with water
  • When mixed with water generates toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health or the environment
  • Is a cyanide or sulfide bearing waste that generates toxic gases, vapors, or fumes when exposed to pH conditions between 2 and 12.5
  • Is capable of detonation or explosive reaction when subject to a strong initiating source or if heated in confinement
  • Is readily capable of detonation, explosive decomposition, or reaction at standard temperature and pressure
  • Is an explosive, as defined in 49 CFR Sections 173.51, 173.53 or 173.88


A waste exhibits the characteristic of toxicity when EPA-defined test procedures indicate that an extract from a representative sample of the waste contains contaminants listed in the table below at a concentration equal to or greater that the given value in the table.

Maximum Concentration of Contaminants for the Toxicity Characteristics


Chemical Abstracts Service (CAS) Number

Regulatory Level (mg/L)









Carbon Tetrachloride












200.0 a


200.0 a


200.0 a


200.0 a










0.13 b


Heptachlor (and its epoxide)




0.13 b












Methyl ethyl ketone








5.0 b














2,4,5-TP (Silvex)


Vinyl chloride


a If o-, m-, p-Cresol concentrations cannot be differentiated, the total cresol concentration is used. The regulatory level of total cresol is 200 mg/L.
b Quantitation limit is greater than the calculated regulatory level. The quantitation limit therefore becomes the regulatory level.

8.1.6b Listed Waste

A solid waste is a listed hazardous waste if it is not excluded from regulation and it is identified on any of the lists in 40 CFR 261 Subpart D. These lists include:

  • Hazardous waste from nonspecific sources (F List).
  • Hazardous waste from specific sources (K List).
  • Discarded commercial chemical products, off specification species, container residues, and spill residues thereof (P List and U List).

Hazardous Waste from Nonspecific Sources

Wastes on EPA's F List: These are wastes EPA has determined to be hazardous but not generated by a particular industry or manufacturing process.

Hazardous Wastes from Specific Sources

Wastes on EPA's K List: These are wastes from particular industries that EPA has determined to be hazardous.

Discarded Commercial Products, Off-Specification Species, Container Residues, and Spill Residues

This classification of hazardous waste includes certain commercial chemical products having the generic names listed on the P and U lists when they are discarded or intended to be discarded. Materials on the P list are classified as acute hazardous waste and materials on the U list are classified as toxic waste.

The following materials on the P List or the U List are classified as hazardous wastes if they are intended for disposal:

  • The material itself, including commercially pure grades and technical grades of the material that are produced or marked for commercial or manufacturing use
  • A formulated product in which the chemical is the sole active ingredient
  • Off-specification commercial chemical products or manufacturing intermediates, which, if specifications were met, would have the generic name, listed
  • Residues remaining in a container or in a container liner that has held any of the materials on the P or U list, unless the container is empty
  • P or U listed materials contained in products, which are applied to the land in lieu of their original intended purpose
  • P or U listed materials that are produced for use as (or as a component of) a fuel, distributed for use as a fuel, or burned as a fuel.
  • Spill residues of P and U listed materials, including contaminated soil, contaminated water, and other debris resulting from the cleanup of a spill of any of the items listed above

Examples of commercial chemical product hazardous wastes include products with the generic names listed on the P and U lists from research laboratories (expiration dated or unused reagents intended for disposal), photography laboratories, and analytical laboratories. These items become hazardous waste when a decision has been made that they must be discarded or disposed of. For example, when the commercial products' expiration date has been reached or when they are no longer needed, it becomes hazardous waste.

8.1.6c Examples of Hazardous Waste at CUA

Include, but are not limited to:

  • Solvents used for parts cleaning or degreasing
  • Paint thinners and paint removing compounds
  • Organic solvents
  • Battery acid and other waste acids
  • Phenol wastes
  • Wastes containing metals such as lead, chromium, silver, or cadmium
  • Mercury waste
  • Paints
  • Inks
  • Pigments
  • Glazes
  • Dyes
  • Adhesives
  • Cements
  • Lubricants
  • Photographic film processing waste
  • Laboratory wastes
  • Ethidium Bromide
  • Water treatment chemicals
  • Compressed gas cylinders
  • Residues of spill materials
  • Household cleaning supplies
  • Used oil contaminated with PCBs or chlorinated refrigerant oil
  • Pesticides

8.1.6d Examples of Wastes That Do Not Fall Under HWMP

  • Biomedical waste
  • Nuclear/radioactive waste


8.1.7 Hazardous Waste Handling

Once solid waste is identified as hazardous waste by the generator, the CHO, or EHS, it must be handled in accordance with the HWMP. Hazardous waste must not be: disposed or recycled with other forms of trash or waste, burned or allowed to evaporate into the air, disposed or diluted in water, disposed on or buried in the land.

An appropriate container (bottle, jar, etc.) must be used to accumulate waste. It must be labeled as discussed in Section 7.1 at the time the first drop is added to the container.

Hazardous waste containers must be kept closed except when adding or transferring waste and the contents of the containers must be compatible with the container. Hazardous waste containers must be segregated based on the hazards of the waste.

Hazardous wastes must be stored in designated Hazardous Waste Accumulation Areas; these areas must be equipped with secondary containment in the form of bins or a berm that would contain the waste in the event of a spill. A "Hazardous Waste Accumulation Area" sign must be posted at waste storage areas to indicate the presence of hazardous waste. The room that has a waste storage area will have access to a phone, access to an emergency eyewash and/or shower, basic spill cleanup equipment, a fire extinguisher, adequate aisle space, and a spill contingency plan. Weekly inspections of the waste storage area are required and the inspection must be documented in the logbook.

8.1.7a Labeling Containers

A chemical container must be labeled "Hazardous Waste" at the time its content is designated "waste." A container is designated hazardous waste by the owner when it is ready for removal.

Prior to designation as "Hazardous Waste," the by-products of an experiment should have a blue "Chemical By-product" label listing the constituents of the bottle and the date. The date on the "Chemical By-product" label should be the date that the first drop of material is added to bottle.

Hazardous waste may not be stored outside of a waste accumulation area. Once a chemical by-product is deemed waste, it must be moved to a waste accumulation area immediately and a "Hazardous Waste" label must be added. After a material has been designated "Hazardous Waste" it may only be moved by HAZWOPER trained personnel. 

The accumulation start date on the hazardous waste label is the date that the material was placed in the waste accumulation area and deemed waste. 

The person who identifies the hazardous waste is responsible for labeling the container that stores the waste with the "Hazardous Waste" sticker or tag supplied by EHS.

If a sticker is too large for the container, use a tag in its place. Attach the tag with a rubber band, wire, or string, etc. to ensure the tag stays with the hazardous waste it is identifying. Use only a sticker or a tag to label but not both.

If a mistake is made on the sticker after it has already been attached to the container, use a one-line cross out with initial and date to modify and add the correction. Do not place a new sticker on top of an old sticker, unless changing the old one would make it illegible.

If a mistake is made on the tag, discard the old tag and complete a new one immediately. Deface the tag and dispose of the old tag in the trash.

If a container already has a label that identifies content and hazards (e.g., a manufacturer's label), place the sticker on a location that does not cover that label, or use a tag. Regardless of the label existing on the container, place a completed hazardous waste sticker or tag on the container once the contents are deemed hazardous waste.  If you are unsure of the contents of the waste, contact EHS for assistance.

To complete the label (sticker or tag), follow these steps.

Generator: _________________________________
Bldg.: ______________________ Room: _________
Dept.: ______________________ Ext.: __________
Accumulation Start Date: _________________
Chemical %Volume







Please contact EH&S at x2698 for waste pickup.


Hazardous waste tags are also available for labeling of bottles and containers that hold hazardous waste. The tags contain the same information as the stickers, but are smaller and printed on two sides. Below are front and back images of the tags.




Dept________________________ Ext________
Start Date_______________________________
___Flammable ___Corrosive ___Oxidizer
___Toxic ___Reactive ___Carcinogen


Chemical %/Volume
Contact EHS at x2698 for waste pickup



The individual who generates the waste is deemed the generator. Write the person's name legibly into this space on the label.

Bldg. and Room:

Identify the building and the room inside that building where the waste was generated. If the room does not have a number, describe the location, e.g., custodial closet or mechanical room.


Identify the department in which the generator is employed at the University.


Identify the on-campus telephone extension of the person who generated the waste. If a direct number is not available, write in the department's central extension, e.g., for facilities, it may be the Facilities Service Center at x5121.

Accumulation Start Date:

This is the date the chemical is placed in the hazardous waste accumulation area.

Check all that apply:

To the best of your ability, identify the hazards associated with the hazardous waste. The hazard information should be identified on the container's label.

  • Flammable hazards: Flammable substances are those that readily catch fire and burn in air. They may be solid, liquid, or gaseous. A common fire hazard is a flammable liquid or the vapor produced from such a liquid. Examples: acetaldehyde, acetone, diethyl ether, toluene, methyl alcohol.
  • Corrosive hazards: Corrosive substances cause destruction of living tissue by chemical action at the site of contact and can be solids, liquids, or gases. Examples: sulfuric acid, aqueous solutions of sodium hydroxide and solid form of sodium hydroxide, ammonia gas, nitrogen dioxide, phenol.
  • Oxidizer hazards: Oxidizing substances promote combustion of other materials thereby causing fire either of the oxidizing substance itself or of other materials. Examples include: chlorine, hydrogen peroxide
  • Toxic hazards: Toxic substances are poisonous and cause adverse effects on living systems. Toxic effects of chemicals can occur after single, repeated, or long-term exposure. Examples: mercury, hydrogen cyanide.
  • Reactive hazards: Reactive substances may release great quantities of energy from a chemical reaction at a rate too great to be absorbed by the immediate environment. There are water reactive materials that react violently with water, such as sodium metal, aluminum bromide, or calcium oxide. There are also pyrophoric materials that oxidize rapidly in oxygen or moisture and ignite, such as some finely divided metals.
  • Carcinogens: Carcinogens are agents that cause cancer. Carcinogens are defined by OSHA and by the International Agency for Research on Cancer (IARC). Examples: arsenic, benzene, diethylstilbestrol, ethylene oxide, formaldehyde.

Chemical and %/Volume:

To the best of your ability, identify the contents of the container. It may contain 100% of one chemical or it may contain a variety of chemicals, e.g., from a student laboratory in which the jar was used to accumulate different but compatible compounds. Write out the chemical names; do not use chemical formulas to identify the contents.

8.1.7b Waste Storage Areas

Hazardous Waste Accumulation Areas are defined as accumulation points for hazardous waste generated on campus. The accumulation of waste is not to exceed 90 days. The CHO, with assistance from EHS, will designate Hazardous Waste Accumulation Areas in locations where waste is generated. The CHO should consult with persons who work in the room where a potential Hazardous Waste Accumulation Area will be located to determine waste generation habits. The Hazardous Waste Accumulation Area must be placed next to or near the process that generates the hazardous waste, and the person who operates that process or area must control the hazardous waste placed in the Hazardous Waste Accumulation Area.

Hazardous Waste Accumulation Areas can be in a laboratory fume hood, on a counter top, or in a cabinet. They should not be placed in front of or behind doors or windows, blocking means of egress, suspended from equipment, or in close proximity to a sink or drain.

Aisle space must be maintained to allow the unobstructed movement of emergency equipment and personnel into all areas where waste is stored. Adequate aisle space is determined based on the types of emergency equipment that is necessary to respond to fires, spills, releases, or explosions of the waste materials on site.

The room that houses the waste storage area should be equipped with:

  • Access to a device capable of summoning emergency assistance, e.g, a telephone or a hand-held two-way radio.
  • Spill contingency plan
  • Spill control equipment
  • Fire Extinguisher
  • Eye wash and safety shower

EHS will maintain a database of Hazardous Waste Accumulation Areas on campus. Designated Hazardous Waste Accumulation Areas will be marked with a "Hazardous Waste Accumulation Area" sign. A room diagram will be posted indicating the location of the Hazardous Waste Accumulation Area. EHS will distribute necessary signage. Hazardous Waste Accumulation Areas can be added or removed based on changes in hazardous waste generation habits.

8.1.7c Container Management

Containers used to collect hazardous waste must be compatible with the substance they contain. Glass or Nalgene jars are appropriate for most wastes. Do not use soda bottles, food containers or other containers that could be confused with consumer products.

To avoid a hazardous chemical reaction, do not place incompatible wastes in the same container. Do not place hazardous waste in an unwashed container that previously held an incompatible material. If you do not know if a waste is incompatible with the waste already in a container or with the container itself, contact EHS for assistance.

Separate hazardous waste containers that store wastes that may be incompatible. Use secondary containers to separate incompatible wastes. Depending on the quantity and types of hazardous waste produced, several different secondary containment bins can be provided for use. Secondary containment bins ensure that in case of a spill, the hazardous waste is contained. The secondary container should be large enough to hold 100 percent of the contents of the largest hazardous waste container in that bin.

EPA has published a list of potentially incompatible waste components and materials along with the harmful consequences of mixing those materials together. This list does not include every possible hazardous chemical reaction, but should be used as a guide in packaging and storing these materials. If you are unsure about the incompatibility of certain wastes in your area, contact EHS for assistance.

 The list indicates the potential consequences of the mixing of a GROUP A material with a GROUP B material.

Compatibility Table



Acetylene sludge

Acid sludge

Alkaline caustic liquids

Acid and water

Alkaline cleaner

Battery acid

Alkaline corrosive liquids

Chemical cleaners

Alkaline corrosive battery fluid

Electrolyte, acid

Caustic wastewater

Etching acid liquid or solvent

Lime sludge and other corrosive alkali

Pickling liquor and other corrosive acids

Lime wastewater

Spent acid

Lime and water

Spent mixed acid

Spent caustic

Spent sulfuric acid

Potential consequences: Heat generation; violent reaction.





Any waste in GROUP 1-A or 1-B













Zinc powder


Other reactive metals and metal hydrides


Potential consequences: Fire or explosion; generation of flammable hydrogen gas.





Any concentrated waste in GROUP 1-A






Metal hydrides




SO2Cl2, SOCl2, PCl3, CH3SiCl3


Other water-reactive waste

Potential consequences: Fire, explosion, or heat generation; generation of flammable or toxic gases.




Concentrated GROUP 1-A or 1-B wastes


GROUP 2-A wastes

Halogenated hydrocarbons


Nitrated hydrocarbons


Unsaturated hydrocarbons


Other reactive organic compounds


Potential consequences: Fire, explosion, or violent reaction.




Spent cyanide and sulfide solutions

GROUP 1-B waste

Potential consequences: Generation of toxic hydrogen cyanide or hydrogen sulfide gas.


Keep hazardous waste containers closed unless adding or removing waste.  If you use a funnel to transfer waste, remove the funnel after the transfer and close the container. A closed container is one whose contents would not spill if the container were knocked over. Depending on the design of the container, it may be properly closed by firmly applying a screw-on cap, bung, drum ring, etc.  Using tin foil, cork, paper towels, etc. are not considered ways of properly closing a container.

Use an overpack drum or container for containers that may leak or cannot be closed.  Overpack containers must also be compatible with the waste, be sealable, and may be filled with vermiculite to occupy extra space. Overpack containers for hazardous waste are available from several manufacturers, including Grainger.

When adding waste to a container, do not completely fill the container.  Leave space for the contents to expand. Containers and chemicals may expand or contract based on temperature. Transfer of hazardous waste is not recommended. If a transfer is necessary, ensure adequate spill response equipment is available, wear personal protective equipment (PPE), and use adequate transferring mechanisms, e.g., a funnel.

Ground ignitable hazardous waste to prevent sparks from igniting flammable vapors. Use a bonding wire and a ground wire when transferring flammable liquids into containers to prevent sparks caused by the buildup of static electricity during pouring operations.

Empty Containers                                                                                                                                      A container that held a P-listed waste is empty if it has been triple-rinsed using a solvent capable of removing the waste. Any rinsate must be collected as hazardous waste, but the container can be disposed of as regular trash. The alternative is to place the entire container in the Hazardous Waste Storage Area and label it as "container with residual from (insert the P-listed waste here)," as well as all other necessary information on the hazardous waste labels.

If the container did not hold a P-listed waste, the container is empty when all contents have been removed that can be removed by using common practices such as pouring, pumping, and aspirating. The container can be disposed of as regular trash if:

  • No more than one inch of residue remains on the bottom of the container or inner liner
  • For a 110 gallon container or less, no more than 3% of the total capacity of the container remains
  • For a container larger than 110 gallons, no more than 0.3% of the total capacity of the container remains

A compressed gas cylinder is empty when the pressure in the container approaches atmospheric pressure. Many compressed gas cylinder suppliers recycle compressed gas cylinders as part of their contract.  Check with your supplier. 


8.1.7d   Weekly Inspections

CHOs are required to perform weekly inspections of Hazardous Waste Accumulation Areas, using a multi-week inspection form developed by EHS. EHS recommends that each CHO establish a schedule for inspections to ensure they become routine. For example, establish Wednesday mornings as the designated inspection time, and every week perform the inspection at that time.

Keep the inspection form adjacent to the Hazardous Waste Accumulation Area, either in a binder or in a covered, protective folder.

Use the form for a maximum of eight weeks. Use one form per Hazardous Waste Accumulation Area. The form consists of nine questions to guide you through the inspection. For any question that is answered with a "no", corrective actions must be noted at the bottom or on the back of the form.

When a form is complete, start a new inspection form. At that time, photocopy the completed form (both sides as necessary), mail the copy to EHS, and file the original.

Once a Hazardous Waste Accumulation Area has been established, a weekly inspection of that area is required, regardless of the quantity of waste in the storage area. Even if no waste has been added to a storage area, an inspection is still required.

The exception to this rule will be the December holiday break when the University is officially closed. CHOs will not have to perform the weekly inspection during that holiday break. EHS will complete a waste pickup prior to the closure to ensure the majority of all waste is removed from the Hazardous Waste Accumulation Areas. EHS will document this via a memorandum at that time. It is the CHOs responsibility to resume inspections the week following the holiday break when the University reopens.

If the CHO for a designated Hazardous Waste Accumulation Area is not able to complete the weekly inspection due to absence, it is his/her responsibility to ensure the inspection is completed. A database of CHOs, established by EHS, will be available.


8.1.8       Contingency Plan

The HWMP documents the University's commitment to manage hazardous waste to minimize the possibility of a release of hazardous waste into the environment. As part of this commitment, we maintain equipment on-site to facilitate spill cleanup and protect human health and the environment. In addition, to address emergency issues and large releases, we have made arrangements with the CUA Department of Public Safety, the local fire department, and an emergency spill response company.

The University has a Spill Prevention, Control, and Countermeasure (SPCC) Plan per EPA regulations. Each Hazardous Waste Storage Area is required by law to have in place a Contingency Plan designed to help manage spill response and emergency situations related to hazardous waste management.

The Contingency Plan for each Hazardous Waste Accumulation Area will be designed by EHS in consultation with the CHO for that area.

The Plan will include:

  • A list of names, addresses, and phone numbers (office and home) of all persons qualified to act as emergency coordinator
  • A list of all emergency equipment at the Hazardous Waste Accumulation Area such as fire extinguishing sytems, spill control equipment, communications systems, decontamination equipment, and emergency eye wash and showers
  • The location and a physical description (schematic drawing) of each item, including the Hazardous Waste Accumulation Area
  • An evacuation plan for facility personnel where there is a possibility that evacuation could be necessary

The Contingency Plan will be specific to a Hazardous Waste Accumulation Area and must be maintained at that Hazardous Waste Accumulation Area. The diagram will be posted at the door(s) to the room where the Hazardous Waste Accumulation Area is located. Revisions or amendments, when necessary, must be made in conjunction with EHS.


8.1.9       Pick-up Schedule

As a large quantity generator, the University must not accumulate a hazardous waste for more than 180 days. Therefore, it is imperative that hazardous waste that is stored in Hazardous Waste Accumulation Areas are managed in an organized and systematic manner to ensure compliance with the 180-day regulation.

It is the responsibility of the CHO to contact EHS to arrange a hazardous waste pick-up from the Hazardous Waste Storage Area. EHS will remove the waste from the storage area and transport the waste to the central hazardous waste accumulation point located in the campus Grounds Maintenance Complex. If EHS cannot transport the waste to the central accumulation point, we will arrange to have it removed from the Hazardous Waste Accumulation Areas using a qualified vendor. Keeping within the 180-dayclock, EHS will arrange for hazardous waste removal from campus using a qualified waste transportation and disposal company.

To guarantee 100 percent compliance with the 180-day regulation, EHS recommends using the weekly inspection form as a tracking calendar. The form is designed for sixteen consecutive weeks or 112 days of Hazardous Waste Accumulation Area inspections. When the form is completed, contact EHS to pick-up any hazardous waste from the Hazardous Waste Accumulation Area.

Even if a container was recently classified as hazardous waste and the 180-day clock just began, if it is at the end of the sixteen-week schedule, contact EHS.

If there is no waste in the Hazardous Waste Accumulation Area, there is no need to contact EHS.

No matter the quantity of hazardous waste in the Hazardous Waste Accumulation Area, send a copy of the completed inspection form to EHS for recordkeeping purposes.

To arrange for pick-up from the Hazardous Waste Accumulation Area, contact EHS via phone or email (CUA-EHS@cua.edu).

Prior to pick-up, ensure in-house recordkeeping is compete. Ensure inventories and inventory numbers used to track chemicals are updated. Each department is responsible for its own recordkeeping.


8.1.10      Training

Every Chemical Hygiene Officer (CHO) will receive annual training, or when new hazards are added to the CHO's responsibilities, in the hazardous waste management practices applicable to our University. EHS will provide the training for CHOs. EHS trainers will receive annual hazardous waste training from an independent firm. Generators of hazardous waste will receive Laboratory Safety Training or Hazard Communication Training based on either 29 CFR 1910.1200 or 29 CFR 1910.1450 depending on their work practices. Both Laboratory Safety Training and Hazard Communication Training will include a segment on the Hazardous Waste Management Plan (HWMP).

Newly hired employees will receive training on Hazardous Waste Management within 6 months of hire.  New employees are tracked with the assistance of applicable laboratory managers and Human Resources and contacted by EHS staff to ensure that all necessary training requirements are met within a timely manner.

Hazardous waste management training will include a review of the regulatory requirements set forth by the EPA, DOT, and OSHA. The training will focus on the details of the HWMP as described in this document, including proper hazardous waste handling and recordkeeping, and emergency procedures and equipment.


8.1.11      Recordkeeping

Document all waste management activities.

Documentation requirements:

  • Proof of annual training in hazardous waste management will be documented on sign-in sheets and will be filed by EHS and maintained per regulatory requirements
  • Weekly inspection forms must be managed by the CHO, filed, and saved for three years
  • Photocopies of the weekly inspection forms will be managed by EHS, filed. and saved for three years
  • All other hazardous waste documentation relating to shipment, regulatory reports, and land disposal records will be maintained by EHS for at least three years


8.1.12      Waste Minimization

Wherever feasible, the generation of waste is to be reduced or eliminated as expeditiously as possible. Implementing a comprehensive waste minimization program may reduce the generator status of the University and therefore reduce the compliance requirements.  It can reduce potential environmental liabilities and help protect the environment through more efficient resource utilization. It also reduces expenses by reducing waste treatment and disposal costs, raw material purchases, and other operating costs.

Benefits of waste minimization include economic savings, increased environmental integrity, decreased exposure to toxic materials, and an improved image for the University.

There are many ways to prevent or minimize hazardous waste generation. This list provides some ideas for waste minimization techniques.

  • Develop a running inventory of chemicals on hand
  • Use the inventory to track unused chemicals for possible use by other departments
  • Maintain a limited inventory of chemicals on hand so those chemicals do not expire or deteriorate and necessitate disposal
  • Purchase only the quantity of chemicals and materials needed. Find the minimum unit required for the work planned and order accordingly. Due to the high cost of chemical disposal, any savings realized by purchasing chemicals in bulk quantities are quickly erased when even a portion of the chemicals cannot be used and must be discarded.
  • Reduce or eliminate the use of highly toxic chemicals in lab experiments
  • Establish reasonable waste minimization goals within your department
  • Perform laboratory experiments on a microscale whenever feasible
  • Unopened and uncontaminated, unused portions of chemicals that you no longer need may find use elsewhere on campus
  • Reuse or recycle spent solvents
  • Recover metal from catalyst
  • Initiate procedures to reduce mercury use; e.g., replace mercury-bearing instruments with alternatives
  • Polymerize epoxy waste to a safe solid
  • Replace chromic acid cleaning solutions with Alconox or a similar detergent
  • Recycle office equipment such as computer monitors
  • Clean with detergents and enzymatic cleaners rather than sulfuric acid/potassium dichromate cleaning solutions or ethanol/potassium hydroxide cleaning solutions
  • Use citrus-based cleaners/degreasers instead of flammable/toxic solvents like acetone/benzene

Waste handling options and the priority in which they should be considered are illustrated below.







8.2 Radioactive Materials

Refer to Radiation Safety Manual, Appendix D.


8.3 Biological Wastes

Refer to EHS Manual, Section 9 Biosafety (9.8 Biohazardous Waste Disposal) 


8.4 Universal Waste

The requirements for this Universal Waste (UW) Management Plan are based upon the EPA regulations found in 40 CFR 273.

Universal Wastes are those hazardous wastes, which are "universal" to most work environments.  Currently, the list of universal wastes consists of five categories of wastes at the federal level.  This program describes general management requirements for all UW and focuses on each UW with specific management requirements.  These include prohibited and allowed activities; procedures for notification; management, labeling and accumulation time limits; training and responses to releases; shipping documentation; and record-keeping.

Universal wastes at the federal level include the following items:

  • Fluorescent lamps (federally regulated)
  • Mercury-containing equipment (federally regulated)
  • Batteries (federally regulated)
  • Pesticides (federally regulated)
  • Aerosol cans (federally regulated)

The University has a dedicated central location located at the Columbus Law School, Room 133A for accumulation and storage of UW.

Environmental Health & Safety (EHS) Responsibilities:

  1. Maintain records associated with UW shipments, including analytical results conducted on any containers or shipments.
  2. Maintain records associated with any training or briefings for individuals who manage UW.
  3. Periodically inspect accumulation areas to ensure containers are properly labeled, closed and are not leaking or damaged.
  4. Establish a central accumulation area for universal waste and separate collection containers for different types of batteries.
  5. Schedule and maintain regular shipments of universal wastes using a reputable vendor.

Facilies Maintance & Operations (FMO) Electrical Shop Staff Responsibilities:

  1. Properly remove all UW from the solid waste stream.
  2. Package all used lamps back into manufacturer’s containers when replacing lamps.
  3. Properly label each UW container with quantity, lamp type and date.
  4. Ensure lids are closed except when UW are being added or removed.
  5. Periodically inspect accumulation areas to ensure containers are properly labeled, closed and not leaking or damaged.

Accumulation Time Limits:                 

UW can be accumulated for up to year from the date the UW became a waste.  The University will transport all stored UW containers from the campus using a reputable transporter to a permitted, offsite recycle, treatment, or disposal facility.  All UW will be managed according to local, state, and federal law and every effort will be made to reduce the potential long-term financial and legal liability to the University.

The amount of time that a UW has been accumulated must be demonstrated, in one of the following ways:

  • Direct marking of the universal waste;
  • Marking the container the waste is in with the earliest date that waste began accumulating in that container;
  • Marking a designated accumulation area with the earliest date that waste began accumulating in that area;
  • Keeping an inventory that identifies the date that each universal waste became waste; or
  • Keeping an inventory that identifies the earliest date that a universal waste became waste in a designated accumulation area.

UW Management Requirements:             

As with other hazardous waste, proper storage and handling of UW is critical to ensuring personnel safety and compliance with appropriate regulations.  General management requirements for all types of UW are as follows:

  • UW cannot be disposed of as municipal wastes (trash) or residual wastes;
  • UW may not be diluted or treated, except in response to a release;
  • UWs must be managed in a way that prevents a release of any component;
  • If containment of a UW is required, the container will be closed at all times except when adding or removing waste, the container must be compatible with the UW and its contents, and free of defects, design characteristics or damage that would lead to leakage, spillage or other environmental releases; and
  • UW stored outside must be covered, to prevent precipitation from coming into contact with the waste.

Requirements for Batteries:

A battery either becomes UW on the date that it is removed from service, because it is no longer operable, or because it is no longer wanted or needed.

The materials of construction of the anode, cathode, and the electrolyte determine the waste battery’s regulatory status: 

Table I.  Common battery types that should be handled as UW, and their uses.


Battery Type




·         Most common battery type, found in cell sizes AAA to D

Nickel/Cadmium (NiCd)

·         Some laptop computers

·         Rechargeable 9-volt, AA, or D cell batteries

·         Some walkie talkies

Lithium ion or nickel hydride

·         Cell phones

·         Cameras

·         Newer laptop computers

Lead acid batteries

·         Cars and motorcycles

·         Deep cycle electric backup power for lights and communications

·         (Sealed lead acid batteries can be as small as a D-cell battery.)

Mercury or silver oxide

·         Hearing aids

·         Watches


Batteries have traditionally contained large amounts of mercury and other heavy metals, which pose numerous threats to the environment.  If disposed in a landfill, these metals could leach into ground water reserves and possibly contaminate surface waters and living organisms.

* Since the mid-1980s, an ongoing effort by manufacturers has been made to reduce mercury content in alkaline batteries. As of 2000 there has been a 97 percent reduction. Alkaline batteries at Catholic University are collected and managed as universal waste.

Key Management Issues of Batteries:

  • Batteries should be segregated into categories when storing and when a request for a pick-up is made. (Battery type is usually indicated on battery labels.)  Note:  Battery types may be mixed in one container, although it is not recommended.
  • To prevent a buildup of heat or sparks, batteries larger than 9-volt should be stored such that the terminals are not touching. It is best to tape off all terminals to prevent contact.
  • Store in a container that is closed except when adding or removing batteries.
  • Each battery, container of batteries, or battery accumulation area must be labeled with the date that the battery was taken out of service, and one of the following: Universal Waste—Battery(ies),or  Waste Battery(ies); or Used Battery(ies).
  • Separate any UW battery that shows evidence of leakage, spillage, or damage that could cause leakage in another container. The container must also be closed, structurally sound, compatible with the contents of the battery, and must lack evidence of leakage, spillage, or damage that could cause leakage.

Requirements for Mercury-Containing Devices:

Devices containing only mercury, such as mercury switches, older thermostats, sphygmomanometers, thermometers, manometers, or pressure gauges that are unbroken, may be managed as UW.  Call EHS Chemical Hygiene Officer 2698 or email cua-ehschem@cua.edu to have it picked up.  If the device is a result of work being done on campus in a location where it would otherwise be left, you may bring the device directly to your own work area, provided you double bag the device.  This will help prevent any possible release of mercury should it be dropped.

To manage a mercury-containing device as a UW, the following requirements must be met:

  • Mercury containing devices that show any sign of leaking, spilling, or damage that could cause spillage must be stored in a container that is closed structurally sound container, compatible with the waste, and free of defects that could cause a leakage.
  • Ampules containing mercury may be removed from a mercury containing device if:
    • Ampules are removed in a manner designed to prevent breakage of the ampules;
    • Ampules are removed only in or over a containment device;
    • A mercury clean-up system is in place to transfer any spilled mercury to a container that meets the requirements of 40 CFR 262.34;
    • The area where the ampule is removed is well ventilated and monitored to ensure compliance with applicable OSHA exposure levels for mercury[1];
    • Employees removing ampules are familiar with proper waste mercury handling and emergency procedures, including transfer of mercury from containment devices to appropriate container;
    • Removed ampules are collected and stored in appropriate containers;
    • Removed ampules are stored in closed, non-leaking containers that are in good condition; and
    • Removed ampules are packed in a container with packing materials adequate to prevent breakage during storage, handling and transportation.
  • If any waste is generated from mercury containing device breakage or emptying of ampules (ampules themselves, spill clean-up debris, ), the Individual must determine if it exhibits the characteristic of hazardous waste for mercury. If the waste does meet the characteristic, it must be managed as a hazardous waste.

[1]  OSHA Vacated PELs: Mercury: TWA 0.05 ppm [0.5 mg(Hg)/m3 TWA (vapor)]; NIOSH: REL: 0.005 ppm (0.05 mg(Hg)/m3); ACGIH Threshold Limit Value (TLV): Mercury: 0.0025 ppm [0.025 mg(Hg)/m3 (TWA), skin].

Mercury containing devices or mercury device storage areas must be labeled with the date that it was removed from service and one of the following: Universal Waste: Mercury-Containing Device(s), Waste Mercury-Containing Device(s), or Used Mercury-Containing Device(s).


Requirements for Fluorescent Lamps:

A lamp becomes a waste on the day that it is removed from service, either because it is burned out or is no longer wanted or needed. 

Proper Management of Lamps includes:

  • UW lamps must be protected to prevent breakage, leaks or damage. This is best accomplished by returning them to the original shipping container (with protectant baffles) and ensuring that the box is closed to prevent damage.  Do not mix new and used bulbs in the same container.
  • Containers must be closed, structurally sound, compatible with the contents of the lamps and must not show evidence of leaks, spills or damage that could cause releases of mercury or other hazardous substances.
  • Lamps may not be intentionally crushed or dismantled.
  • If lamps are unintentionally broken, the broken lamps and residue must immediately be cleaned up using proper mercury clean up procedures, the area decontaminated, and the debris placed in a container. If the broken lamps and clean-up debris exhibit a characteristic of hazardous waste, it must be managed as a hazardous waste.
  • Lamps or lamp accumulation areas must be marked with the date it is removed from service and one of the following: Universal Waste—Lamp(s), Waste Lamp(s), or Used Lamp(s).

Security Measures:

The following security measures will be provided at all outdoor storage areas for UW:

  • An artificial or natural barrier that completely surrounds the universal waste storage area to prevent unauthorized entry by people or livestock;
  • An entry that is controlled at all times; and
  • A sign at all entries to the storage area with the legend Danger – Unauthorized Personnel Keep Out or other words indicating that only authorized personnel are allowed entry and that the area is potentially dangerous.

Response to Releases:

The handler of UW must immediately contain all releases of universal wastes and other residues from UW.

The handler of UW must determine whether any material resulting from the release is hazardous waste, and if so, must manage the hazardous waste in compliance with all applicable requirements of 40 CFR parts 260 through 272.  The handler is considered the generator of the material resulting from the release, and must manage it in compliance with Title 40 CFR Part 262.


The UW generator should keep a record of each shipment of universal waste in the EHS Hazardous Waste Manifest book, maintained by the Chemical Hygiene Officer.

The record can be in the form of a log sheet, an invoice, a manifest, a bill of lading or another type of shipping document.  The record must include the following information:

  • The name and address of the universal waste handler;
  • Destination facility;
  • Quantity of each type of universal waste; and
  • Date of shipment.

These records will be kept for at least three years from the date of shipment.


8.5 Electronic Waste

The University strives to route all equipment with electronics through a process to divert them from landfills.  This diversion can be accomplished in several ways, which results in lowering the cost to buy new equipment, maximizing the revenue from sales and reducing the cost by lowering the frequency of bulk trash collection containers being emptied.

The Electronics Waste Program is primarily run and coordinated by the University's Asset Manager working out of the Environmental Health, Safety & Risk Management office under the Facilities Planning and Management division.

Upon notification from any University office of equipment or furniture that is no longer needed, the Asset Manager inspects the equipment for the following:

  • type, location, quantity, size and weight of equipment;
  • presence of any hazardous materials associated with the equipment; and
  • time frame from the end user of when the equipment needs to be removed.

All hazardous materials are first removed by the University's Chemical Hygiene Officer and/or Radiation Safety Officer before the equipment is moved from its current location. Then, any equipment smaller than a full-sized refrigerator is moved to one of two collection points for further evaluation. Such evaluation shall include a combination of partial disassembly and at least one full start-up cycle. Larger equipment is fully evaluated in its current location prior to being moved for re-use or permanent disposal.

If the equipment is found to be reliable, safe and able to be supported by appropriate University services, a notice is sent to the Academic Vice President's office seeking any interested departments. If the equipment isn't supported, but otherwise reliable and safe, it is sold to any interested party and permanently removed from campus, with a signed General Counsel-approved release.

If the equipment isn't safe or reliable, it is first cannabalized for useful and/or regulatory-required components then shrink-wrapped to a pallet or large shipping container. Regulatory components are placed in a designated area for processing by the University Chemical Hygiene Officer.

Proceeds from sales are deposited into the University's General Fund, with 6% remitted to the District of Columbia for sales tax. The University is only exempt from sales tax on the purchase of supplies and equipment.

The University contracts to a vendor to remove all palletized electronics approximately 2-3 times per year, depending on the volume of equipment turned in. The vendor is required to recycle 100% of the shipment including the pallet and shrink-wrap, since there is a no-landfill clause. The vendor reports a total weight recycled for each shipment. The University Asset Manager annually reports these weights to the University's Assistant Director for Campus Facilities and Sustainability Initiatives.


8.6 References