| Scope:
This policy is prepared in accordance with the requirements of the Resource Conversion and Reclamation Act (RCRA), the Federal Environmental Protection Agency (EPA), 40 CFR §260-268, Massachusetts General Law (MGL) c. 21C, the Hazardous Waste Management Act; the Massachusetts Department of Environmental Protection (DEP) 310 CMR 30; and the Amherst College Environmental Health and Safety Committee.
Purpose:
Amherst College is committed to the safe and proper handling, storage, and disposal of all hazardous waste generated at Amherst College. This policy is written to provide the management process for hazardous waste.
Applicability:
All departments, employees, visitors, and subcontractors at Amherst College.
Definitions:
Hazardous Waste - Byproducts of society that can pose a substantial or potential hazard to human health or the environment when improperly managed. Possesses at least one of four characteristics (ignitability, corrosiveness, reactivity, or toxicity), or appears in EPA 40 CFR § 261, and DEP 310 CMR 30, Occupational Health and Safety (OSHA) 29 CFR, or Department of Transportation (DOT) 49 CFR.
- I. Hazardous Waste Generator Classification
Amherst College Departments have designations as Conditionally Exempt Small Quantity Generator, (EPA)/Very Small Quantity Generator (DEP). Biology, Chemistry, Fine Arts, Physical Plant, and Physics have received EPA generator numbers as follows:
- Biology MV4135422314 Life Sciences Building
Chemistry MV4135422342 Merrill Science Center, 4th & 5th Floors
Fine Arts MV4135422365 Fayerweather Building
Geology * Earth Science Building
Neuroscience Life Sciences Building, 1st Floor
Physical Plant MAD066985367 Physical Plant Building
Physics MV4135422251 Merrill Science Center, 1st & 2nd Floors
Psychology * Merrill Science Center, 3rd Floor
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- *Hazardous wastes of the Geology and Psychology Departments are manifested under Chemistry's EPA number due to the extremely small quantity of hazardous waste generated annually.
+Hazardous wastes of the Neuroscience Department are manifested under Biology's EPA number due to the extremely small quantity of hazardous waste generated annually.
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- II. Satellite Accumulation Areas (SAA)
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- A. Academic Departments
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- 1. Biology and Neuroscience Departments
The Biology and Neuroscience Departments have Satellite Accumulation Areas designated in each research and teaching laboratory.
- 1st Floor Life Sciences Building
Laboratory 103
Prof. Heather Masonjones, x8381
Laboratory 104
Maureen Manning, x8328
Laboratory 111
Prof. John Baird, x5828
Laboratory 112
Prof. Sarah Turgeon, x2625
- Laboratory 113
Prof. John Baird, x5828
Laboratory 138
Prof. Ethan Temeles, x8322
Laboratory 145
Prof. Stephen George, x2477
Laboratory 146
Prof. Jill Miller, x2168
- 2nd Floor Life Sciences Building
Laboratory 203-205
Prof. Jill Miller, x2168
Laboratory 207
Prof. Ethan Temeles, x8322
Laboratory 215
Prof. Stephen George, x2477
Laboratory 223
Prof. Ethan Clotfelter, x2252
Laboratory 234
Prof. Julie Emerson, x8381
- 3rd Floor Life Sciences Building
Laboratory 306
Prof. Dominic Poccia, x2198
Laboratory 314
Prof. Patrick Williamson, x2143
Laboratory 319
Prof. Dominic Poccia, x2198
Laboratory 336
Prof. Dominic Poccia, x2198
- 4th Floor Life Sciences Building
Laboratory 406
Prof. Richard Goldsby, x2045
Laboratory 414
Prof. David Ratner, x2248
Laboratory 420
Prof. Caroline Goutte, x8321
Laboratory 432
Prof. David Ratner, x2248
- 2. Chemistry Department
The Chemistry Department has Satellite Accumulation Areas designated in each research and teaching laboratory.
- 4th Floor Merrill Science Center:
Laboratories 404, 419, 421, 425, 426
Kristi Ohr, x2736
Laboratory 429
Prof. David Hansen, x2731
5th Floor Merrill Science Center:
Laboratory 500
Prof. David Hansen, x2731
Laboratories 505
Prof. Patricia O'Hara, x2732
Laboratory 513
Prof. Sandra Burkett, x2730
Laboratory 514
Prof. David Hansen, x2731
Laboratory 515
Prof. Anthony Bishop, x8316
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- 3. Fine Arts Department
The Fine Arts Department has a Satellite Accumulation Area designated.
Richard Scorpio, x5784
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- 4. Geology Department
The Geology Department has a Satellite Accumulation Area designated.
Laboratory
Prof. Anna Martini, x2067
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- 5. Physics Department
The Physics Department has two Satellite Accumulation Areas designated.
Laboratory Room 107
Laboratory Room 123
Robert Bartos x2689
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- B. Management of Hazardous Wastes
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- 1. Deciding what is Hazardous Waste
Laboratory reaction products which the researcher chooses not to retain, excess reagent hazardous material, or any other unusable or unneeded laboratory hazardous material shall be declared hazardous waste.
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- 2. Treatment of Hazardous Waste
- Treatment of hazardous waste must be done in accordance with Policy # 21.0, Laboratory Hazardous Waste Treatment policy.
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- 3. Hazardous Waste Compatibility
- Only compatible hazardous wastes may be placed into a given container. See the Chemical Hygiene Plan for a compatibility list.
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- 4. Labeling Hazardous Waste Containers
- Once hazardous material is declared as hazardous waste, the following steps must be followed:
- a. Hazardous Waste Characteristics
Such declared hazardous waste shall be placed into an appropriate container, i.e. compatible with the hazardous waste; its characteristic hazard determined and must be noted on the appropriate hazardous waste label.
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- b. The hazards are as follows: Ignitable, Reactive, Corrosive, and Toxic as defined by 40 CFR of the EPA regulations.
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- 1. Characteristic of ignitability
Any liquid having a flash point less than 60°C, any non-liquid capable of causing fire at standard temperature and pressure through friction, absorption of moisture or spontaneous chemical changes. Any solid waste having EPA Hazardous Waste Number D001.§ 261.21 of 40 CFR and/or MSDS
information.
- 2. Characteristic of corrosiveness
Any aqueous liquid having a pH less than or equal to 2 or greater than or equal to 12.5. Any solid waste having EPA Hazardous Waste Number D002.§ 261.22 of 40 CFR and/or MSDS information.
- 3. Characteristic of reactivity
Any solid waste which is normally unstable and readily undergoes violent change without detonation; reacts violently with water; forms potentially explosive mixtures with water; generates toxic gases, vapors, or fumes with water; is a cyanide or sulfide which can generate toxic gases, vapors, or fumes at pH values between 2 and 12.5; is capable of detonation if heated; is capable of detonation at standard temperature
and pressure; or is a forbidden explosive. Any solid waste having EPA Hazardous Waste Number D003. § 261.23 of 40 CFR and/or MSDS information.
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- 4. Characteristic of toxicity
Any hazardous waste identified by the MSDS information as toxic or any compound noted in § 261.24 of 40 CFR. Any hazardous waste having EPA Hazardous Waste Number D004 through D0043 as listed in Table 1 § 261.24 of 40 CFR at the regulatory levels of contamination.
- For any help in determining the hazardous waste characteristic, contact the Chemical Hygiene Officer at x2736. Note: The EPA Hazardous Waste Number is not assigned at the Satellite Accumulation Area but will be assigned when the hazardous waste is moved to the Main Accumulation Area.
- c. The IUPAC name or common name of the hazardous waste must be written on the label along with the quantity (mL, gms) added to the container. No chemical symbols are allowed to describe the hazardous waste.
- 5. Storage of Hazardous Waste in the SAAs
- a. All hazardous waste containers must always be located in the secondary containment bins at the SAA.
b. No container having declared hazardous waste can be unlabelled at any time.
c. Two or more hazardous waste containers having contents which are incompatible with contents of the other containers can not be placed into a single secondary containment bin. They must be stored separately.
d. Within an SAA, two or more containers having identical hazard waste contents is not permitted at any time.
e. Partially full hazardous waste containers in the SAA are not to be dated. When the container is full, date the container.
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- 6. Movement of Full Hazardous Waste Containers to the MAA.
- a. When a hazardous waste container is full, Rick Mears, x8189 or Kristi Ohr, x2736 must be notified so that the full container may be moved to the MAA within three days.
b. All hazardous waste containers moved to the MAA must have covered secondary containment and be fitted with appropriate safeguards to prevent spills and container breakage.
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- C. Weekly Inspection
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- 1. Each SAA is required to be inspected weekly by the responsible person(s) for the SAA.
2. The inspection characteristics are defined in Policy 8.2, Satellite Accumulation Area Management Policy. Any deficiencies are to be corrected immediately.
3. SAA weekly inspections must be documented in accordance with Amherst College best business practices and the Satellite Accumulation Area Management Policy, 8.2.
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- III. Main Accumulation Areas (MAA)
There are two MAAs on Campus as described below.
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- A. Merrill Science Center
- The MAA in Merrill Science Center is under direct control of Kristi Ohr, x2736. This MAA provides hazardous waste storage for all academic departments.
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- 1. Receipt of Hazardous Waste from the SAAs
- a. Receipt Log
- 1. All hazardous waste containers are to be assigned a container number which is simply a sequential number for identification of a given container and the container size noted in the log.
2. Each container is dated with the receipt date and entered into the log.
3. The proper EPA Hazardous Waste Number is to be assigned and entered on the container and in the log.
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- 2. Storage
- a. Containers are to be placed into secondary containment bins for safekeeping until removal by a TSD. Hazardous waste must be removed within 180 days of the receipt to the MAA.
b. Unauthorized personnel are not allowed into the MAA.
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- 3. Inspection
Weekly inspections are required at the MAA and must be documented. The inspection characteristics are defined in Policy 8.1, Main Accumulation Area Management Policy. Any deficiencies are to be corrected immediately.
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- B. Physical Plant
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- The MAA at Physical Plant is under direct control of Rick Mears, x8189. This MAA provides hazardous waste storage for the Fine Arts Department and is the Universal Waste MAA for the Campus.
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- 1. Receipt of Hazardous Waste from the SAAs
- a. Receipt Log
- 1. All hazardous waste containers are to be assigned a container number which is simply a sequential number for identification of a given container and the container size noted in the log.
2. Each container is dated with the receipt date and entered into the log.
3. The proper EPA Hazardous Waste Number is to be assigned and entered on the container and in the log.
- 2. Storage
- a. Containers are to be placed into secondary containment bins for safekeeping until removal by a TSD.
b. Unauthorized personnel are not allowed into the MAA.
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- 3. Inspection
Weekly inspections are required at the MAA and must be documented. The inspection characteristics are defined in Policy 8.1, Main Accumulation. Area Management Policy. Any deficiencies are to be corrected immediately.
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- IV. Shipment of Hazardous Waste from Amherst College
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- A. Transport, Storage, and Disposal Contractor (TSD)
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- Amherst College acknowledges its responsibility for cradle to grave ownership of its hazardous waste stream and will only contract with licensed TSDs or Hazardous Waste Brokers who are permitted by EPA, DEP, and DOT agencies to perform such services.
- Amherst College will not allow any hazardous waste to leave its facilities except through approved TSDs and Hazardous Waste Brokers.
- Currently Amherst College uses the services of:
- Chem Venture/Cycle Chem
General Chemical Corporation
Triumvirate Environmental
- B. Manifests
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- 1. Amherst College will only ship hazardous waste from its MAAs using approved manifests.
2. Manifests will be prepared jointly by the hazardous waste contractor and the person responsible for the MAA.
3. The responsible person for the MAA will check for accuracy and completeness and assure the requirements of the Land Disposal Restrictions.
4. The responsible person for the MAA will ensure that the appropriate copies of the manifests are sent to the TSD receiving state DEP and to the Commonwealth of Massachusetts DEP.
5. The responsible person for the MAA will assure that page 3 of the manifest is received at Amherst College within 45 days from the TSD.
6. The responsible person for the MAA will assure that the Certificates of Disposal are received from the TSD when available.
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- V. Training
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- A. Responsibility
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- 1. It is the responsibility of the Environmental Heath and Safety Manager to schedule and provide training for all persons on Campus who require hazardous waste and safety training as a part of their normal job functions.
2. Any person who has need to handle or use hazardous material and has not had the required training shall notify the Environmental Heath and Safety Manager x8189 for training.
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- B. Applicability
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- 1. No person at Amherst College may handle hazardous waste without the training noted below.
2. Research undergraduate students and teaching assistants (TA) will receive modified hazardous material and safety training to conform with the requirements of 40 CFR (EPA) and 29 CFR (OSHA).
3. Research faculty, post-doctoral persons, laboratory supervisors, any employee who must handle hazardous material as part of normal duties, graduate students from any program associated with Amherst College, e.g. Molecular and Cellular Biology (MCB) students and visitors who are on Campus for time periods exceeding one month will receive annual hazardous material and safety training to conform with the requirements of 40 CFR (EPA) and 29 CFR (OSHA).
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- C. Record keeping
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- 1. Records of training will be maintained for each person trained. Information in the record will include the course, date attended, and next training date where applicable.
2. Records will be maintained by the Environmental Heath and Safety Manager for three years.
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- VI. Subcontractors
- Subcontractors to Amherst College who in the performance of any contract requiring the use of hazardous material which will lead to the generation of hazardous waste will be required to demonstrate certification of hazardous waste training.
- Subcontractors to Amherst College will be required as a part of their contract to obtain a temporary EPA generator in the performance of any contract requiring the use of hazardous material which will lead to the generation of hazardous waste.
- Subcontractors will be required to remove all hazardous waste which they generate under the contract.
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Environmental Compliance 