Environmental Health & Safety

Resoure Conservation and Recovery Act (RCRA)


In 1976, through the Environmental Protection Agency, Congress enacted a national policy for the treatment, storage, and disposal of hazardous waste in an effort to minimize present and future threat to human health and the environment. This Act, known as the Resource Conservation and Recovery Act (RCRA), was specifically designed to reduce improper treatment, storage and disposal of hazardous waste and prevent past practices such as "out of sight, out of mind." RCRA is overseen and enforced by the EPA.

RCRA Objectives

  • Protect human health and the environment
  • Conserve material and energy sources
  • Reduce or eliminate hazardous waste generation

Hazardous waste is any solid, liquid, or gas waste that may cause or significantly contribute to serious illness or death, or that poses a substantial threat to human health or the environment, when improperly managed. Because of our operations, both academic and support, Amherst College has on site many materials that fall under this category.

The four major parts of RCRA that establish statutory requirements for managing hazardous waste are:

  • Subtitle C - Hazardous Waste Regulations
  • Subtitle D - Nonhazardous Waste Regulations
  • Subtitle I - Underground Storage Tank Regulations
  • Subtitle J - Medical Waste Regulations

Subtitles D, I and J are all covered in other areas of training such as Universal Waste, the Spill Prevention Control and Countermeasures Act, and the Exposure Control Plan, respectively. See the Environmental Health and Safety web page at the Amherst College Environmental Health and Safety Policies and Procedures Page for additional information.

Subtitle C is dealt with in this RCRA training. Under Subtitle C the generator (Amherst College), our transporter of hazardous waste, and our treatment, storage, and disposal facilities are strictly regulated. If you are being asked or required to take this training, then you are being asked to play a very significant role in the College's ability to handle, store, transport, and use hazardous materials and the wastes we generate from them.

Amherst College (the core campus) is what the EPA and Massachusetts would classify as a "Large Quantity Generator" of hazardous waste. This means we may generate in one month:

  • greater than 2200 lbs of hazardous waste, and
  • greater than 2.2 lbs of acutely hazardous waste

Furthermore our generator status allows us to keep the material in our Main Accumulation Area (MAA) for not more than 90 days.

Amherst College has been granted special permission by the state Department of Environmental Protection to have additional generator status permits. Because of support buildings and areas like the Golf Course, College Hall Print Shop, the Observatory, and the Lord Jeffery Inn, all of which generate hazardous materials but are located outside the Campus Core, the relocation of waste to an MAA for these sites was of concern. By law, Amherst College would not be able without special permits, to relocate the waste they generate off-site to our waste storage facility. Our Small Quantity Generator status does not permit transport over Route 9 or Route 116. The Golf Course, College Hall Print Shop, Observatory, and the Lord Jeffrey Inn each generate less than 220 lbs or 27 gallons of Hazardous Waste per month, and have no acutely hazardous waste on site. Very Small Quantity Generators (VSQGs) can store waste for an unlimited period of time, but cannot accumulate more than 1,320 lbs at any one time.

Do not confuse "Hazardous Waste" with "Hazardous Materials." Hazardous Material is usable material that still has value to the College. It can be utilized again. The word "waste" implies the material cannot be used, or has no value to the College. 

The term Hazardous Waste does not apply solely to laboratories such as those in Biology, Chemistry, Geology, and Psychology. Hazardous Waste can include paints (including lead paint waste), turpentine, battery acid, and in Massachusetts all types of oil, including motor, vacuum pump and even non-recyclable vegetable oil.

Amherst College is a generator of hazardous waste, as are most other college and universities. Similar to business and industry, the College uses chemicals, oils, paints, and other similar materials until completely consumed in a process or until they no longer can be recycled or utilized again, at which time they become hazardous waste.

Cradle-to-grave is a very important term to remember. Any hazardous material that becomes a hazardous waste at the College is our responsibility from the time we receive or create it. Even after is has been removed from the campus by a licensed hazardous waste company, we assume complete responsibility for it, regardless if it:

  1. leaks during transportation,
  2. is not disposed of properly,
  3. is buried underground,
  4. becomes an EPA Superfund site, or
  5. is mishandled in any way; unless otherwise destroyed (i.e. water treatment or incineration) it remains our problem.

Congress, through RCRA, under the EPA can impose liabilities and create remedies to correct problems that we and/or others create. It is extremely important that the College follow all of our policies and procedures as Best Management Practices to reduce any risk and potential liability as it pertains to Hazardous Waste identification, storage, and transportation.
Solid Waste, Hazardous Waste, and Hazardous Waste Codes

Solid/Universal Waste that is not considered to be hazardous waste by the EPA includes:

  • agricultural wastes, (if are deliberately returned to the soil as fertilizer)
  • cement kiln dust waste
  • household waste
  • utility wastes from coal combustion
  • oil and gas exploration drilling waste

Universal waste is regulated under special standards promulgated by the EPA. Like hazardous waste, universal waste must be properly handled, labeled, and packaged as required by federal and state regulations.

Universal waste includes but is not limited to:

  • batteries: specifically alkaline (Amherst College requirement), nickel cadmium, gel type, and rechargeable batteries,
  • fluorescent, sodium vapor, and mercury vapor lamps and lights (incandescent bulbs are exempt), mercury thermometers, mercury manometers, and
  • computer monitors and television tubes

Universal waste storage is permitted on-site in an approved area for a period of not more than one year.

  • Boxes, containers and drums used for universal waste must be labeled (e.g. "Universal Waste -- Batteries") and a start date.
  • Containers must be able to completely contain the universal waste, shall be structurally sound, and shall be able to be closed when full.

Faculty, staff and students must be aware of proper handling, storage, transportation, and emergency procedures for universal waste.

Amherst College is a Small Quantity Generator of universal waste. The College tracks our universal waste control program using logs, invoices, and manifests. Records of the College's recycling program and shipments (including universal waste) are maintained by the Recycling Coordinator at the Physical Plant.

Recycling areas and containers are available in each building. For additional information on universal waste, see the Environmental Health and Safety web page, or contact Paul Thornton, Recycling Coordinator at 542-8369.

A Hazardous Waste is any solid, liquid, or contained gas identified in 40 CFR (Code of Federal Regulations) 261, which:

  • is discarded,
  • has served its intended use, or
  • is a manufacturing by-product.
Hazardous Waste has one or more of the following 4 different characteristics.
  1. Corrosivity – a material with a primary hazard (solid, liquid or gas) that causes visible destruction or irreversible damage to skin tissue at the point of contact, or that has a severe corrosion rate on steel or aluminum.
  2. Ignitability – a material with the primary hazard (solid, liquid, or gas) of fire ignition or flammability; ignitable material has a flashpoint of 60.5ºC (141ºF) or less.
  3. Reactivity – a material that is normally unstable or which reacts with water, heat sources, or other materials to generate toxic vapors or fumes; or is potentially explosive; or is a Class A or Class B explosive
  4. Toxicity – a material which has a primary hazard (solid, liquid or gas) that is or has the potential to be toxic to human beings the environment, or which is presumed to be toxic to humans and/or the environment because of the effects on laboratory animals in the categories of oral, dermal, or inhalation toxicity.
EPA has identified three other categories of solid waste that must be considered hazardous waste until proven otherwise:
  • mixed wastes,
  • abandoned materials, and
  • "waste-like" materials, including bottles and cans that appear as though they are no longer used due to dust accumulation.

Under RCRA, the EPA has created specific codes for Listed Wastes that further assist in their identification for transportation, storage, and disposal purposes. Spent waste materials are broken down into the following categories:

  • D001 Ignitable
    • liquids with flash points of less than 141°F
    • spontaneously combustible solids
    • compressed gasses that are ignitable
    • oxidizers
  • D002 Corrosive
    • aqueous solution with a pH of less than 2.0 or greater than 12.5
    • liquid that corrodes steel at a rate of 0.25" per year
    • This classification does NOT include solids.
  • D003 Reactive
    • unstable material
    • reacts with water
    • explosives
    • generates toxic gas
    • cyanide or sulfide bearing waste
  • D004-D043 Toxic
    • Chemical substances identified in the table. When the TCLP result is greater than the concentration given, the waste is regulated for that substance.
    • Substances include
      • RCRA metals
      • pesticides
      • organic solvents
      • chlorinated solvents
  • F-codes for non-specific source wastes
    • F001 The following spent halogenated solvents used in degreasing:
      1. all spent solvent mixtures/blends used in degreasing the above halogenated solvents or those solvents listed in F002, F004, and F005;
      2. and still bottoms from the recovery of these spent solvents and spent solvent mixtures.
    • F002 The following spent halogenated solvents:
      1. all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above halogenated solvents or those listed in F001, F004, F005;
      2. and still bottoms from the recovery of these spent solvents and spent solvent mixtures.
    • F003 The following spent non-halogenated solvents:
      1. all spent solvent mixtures/blends containing, before use, only the above spent non-halogenated solvents;
      2. and all spent solvent mixtures/blends containing, before use, one or more of the above non-halogenated solvents, and a total of ten percent or more (by volume) of one or more or those solvents listed in F001, F002, F004, and F005;
      3. and still bottoms from the recovers of these spent solvents and spent solvent mixtures.
    • F004 The following spent non-halogenated solvents:
      1. all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above non-halogenated solvents or those solvents listed in F001, F002, and F005;
      2. and still bottoms from the recovery of these spent solvents and spent solvent mixtures.
    • F005 The following spent non-halogenated solvents:
      1. all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above non-halogenated solvents or those solvents listed in F001, F002, or F004;
      2. and still bottoms from the recovery of these spent solvents and spent solvent mixtures.
  • K-codes for specific source wastes, unless excluded under 40 CFR 260,20 and 260.22
    • industry specific type wastes, usually associated with manufacturing or processing, not normally used in education settings
    • not chemical specific
    • petroleum refining wastes and bottom sediment sludge from treatment of waste water by the wood preserving industry are K-code wastes.
  • U-codes for toxic hazardous waste (if not combined/mixed with other materials) when discarded include, but are not limited to:
    • U002 Acetone
    • U003 Acetonitrile
    • U008 Acrylonitrile
    • U019 Benzene
    • U031 1-Butonol
    • U211 Carbon Tetrachloride
    • U044 Chloroform
    • U056 Cyclohexane
    • U122 Formaldehyde
    • U151 Mercury
    • U188 Phenol
    • U220 Toluene
    • U239 Xylene
P-codes for acutely hazardous wastes that are:
  • discarded
  • off-specification products
  • container residues
  • spill clean-up residues
  • for example:
    • P005 Allyl Alcohol
    • P056 Fluorine
    • P074 Nickel Cyanide
    • P104 Silver Cyanide
    • P105 Sodium Azide
    • P106 Sodium Cyanide
    • P120 Vanadium Oxide

Generator of Hazardous Waste

 

It is the responsibility of the generator (faculty and staff) to determine if a solid waste is hazardous or not. For all teaching and research laboratories, shops, photo dark rooms, and studios on campus nearly all of the "solid waste" is considered to be hazardous.

Because of our "Large Quantity Generator" status, Amherst College is not permitted to treat by destruction, neutralization or dilution. Absolutely nothing from a laboratory, shop or studio can be disposed of into a drain or other sanitary sewer inlet.

Sinks in laboratories and other areas where hazardous waste may be located are posted with signage that indicates no dumping of any material, which is considered to be hazardous, is permitted.

Dumpsters across campus are also posted with signage that strictly prohibits the disposal of computer monitors, hazardous materials including chemicals, batteries, oils, televisions, fluorescent light bulbs/ballasts etc. into the containers.

Amherst College is committed to reducing the amount of hazardous waste that we generate, either through reduction of storage or the process of recycling. If faculty and/or staff decide they are no longer in need of a hazardous waste material they can advertise its availability online by email or similar, by word of mouth and/or postings in an effort to reduce the waste stream and associated cost.

Subtitle C
The most significant part of the Resource Conservation and Recovery Act is Subtitle C. Subtitle C established the national hazardous waste management program, sections 3001-3023.

Section 3001 - Requires EPA to promulgate regulations identifying hazardous wastes, either by listing specific hazardous waste or establishing characteristics of hazardous wastes.

Section 3002 - Requires hazardous waste generators must comply with a set of standards authorized by RCRA. They include, but are not limited to:

  • Handling waste appropriately
  • Preparing manifests for tracking the shipment of waste to treatment, recycling and disposal facilities.

Section 3003 - Requires persons who transport hazardous waste to comply with regulations for labeling, proper hazardous waste management, completion, distribution and maintenance of manifests, and safe transportation to a licensed Treatment Storage and Disposal Facility (TSDF). The transporter must comply with Department of Transportation (DOT) regulations as they pertain to container labeling, placarding of vehicles and spill response.

Section 3005 - Requires the owners of TSD facilities to obtain permits that dictate how the operation shall be managed and operated.

Section 3006 - The RCRA law makes each state responsible for the federal RCRA program. Massachusetts must administer and enforce a program that is at least as stringent as the EPA program. States that receive waste generated in Massachusetts must assume the same responsibilities, but never be less stringent than the federal RCRA requirements.

Sections 3007-3008 Authorizes site inspection and enforcement of the federal RCRA regulations.

The RCRA objectives are to control and reduce the generation of hazardous waste. One of the most important goals is to eliminate any type of land disposal of hazardous waste to protect the environment. It should be the least favored method of disposal for any company as it could easily end up in a future EPA Superfund site, for which the generating company could be financially responsible.

Amherst College contractually requires the following from our hazardous waste transporters: land fill disposal of our hazardous waste is not permitted unless disposal cannot be accomplished by any other EPA approved methods such as incineration, water treatment, or neutralization. An example of a waste that can be land filled is asbestos, as it cannot be destroyed by other methods.

All hazardous waste generated at Amherst College must be controlled while on Campus property and safely transported for its final destruction or recycling in a manner that minimizes the present and future threat to human health and the environment.

Manifests


Significant parts of RCRA are paperwork and training requirements. Manifests are records of a hazardous waste shipment. They are designed to track hazardous waste from Amherst College to our hazardous waste transporter, and then to the appropriate disposal facility. They include the required DOT information, such as what the material is, the EPA hazard designations, amount being shipped, destination, who sent it, the name of the hazardous waste transportation company, and the method that will be used to dispose of the waste. Manifests are required for each shipment of hazardous waste as well as state specific regulated waste. Non-hazardous waste may also be shipped out using a manifest.

In Massachusetts, waste oil and vegetable oil that cannot be recycled are shipped out as hazardous waste using a hazardous waste manifest.

Manifests are extremely important documents for Amherst College and are required for every shipment of hazardous and state regulated waste. They must be completely, and accurately filled out, signed by the transportation company, the College (as the generator), and the state and site that accepts our hazardous waste. Since September of 2006, the EPA manifest forms. The Transportation, Storage, and Disposal Facility (TSDF) also defined as the "Designated Facility" is responsible for the first four copies of the six part form.

Amherst College must use the EPA manifests, which are provided to the College under contract by our hazardous waste transporter.

Copies of the manifest must be distributed as follows:

  1. Designated Facility mails to destination state agency if required)
  2. Designated Facility mails to generator state agency if required)
  3. Designated Facility mails to generator (for recordkeeping)*
    • 310-CMR states that a copy of page # 3 (“Destination Facility Return to Generator”) must be sent to the Department of Environmental Protection (DEP) in Boston, within 30 days after receiving our copy from the facility or 45 days after the initial manifest date.
  4. Designated Facility Copy (retains for records)
  5. Transporter Copy (retains for records)
  6. Generator Copy (retains for records)

*The generator must receive copy #3 of the manifest within 30 days.

If not received by the generator within 30 days, the generator must notify the TSDF immediately, requesting the required paperwork.

If copy #3 is not received within 45 days, Amherst College is required to notify the EPA.

Waste Profiles

Amherst College is often required by the waste transporter to provide a Waste Profile for the material we intend to ship out. Profiles are used by the TSDF to identify:

  1. Waste constituents
  2. Waste generating process
  3. Chemical and physical properties of that waste
  4. Proper waste code constituents and characteristics
  5. Any DOT shipping information
The profile can sometimes be substituted with a Material Safety Data Sheet (MSDS) if the hazardous waste is a single chemical for which we have an MSDS. In most cases, however, the waste that we generate has many constituents that cannot be identified by a single MSDS. For those containers of hazardous waste with more than one chemical, the college must provide a legitimate profile in order to transport, handle, and dispose of the waste.

The profile must have the following information:

  • Name of the hazardous waste
  • Process generating the waste
  • Composition of waste
  • Chemical and physical characteristics of the waste
  • Waste codes (contact Chemical Hygiene Officer)
  • DOT shipping information (contact Chemical Hygiene Officer)
  • Generator certification (contact Chemical Hygiene Officer)

The waste profile is generally prepared by the Amherst College transporter under contract using the past history and testing of waste normally generated in our laboratories and shops. It must be completed for each generated waste. The profile describes each hazardous waste stream for use by the TSDF.

The generator is ultimately responsible for the waste profile and chemical analysis.

Generator Status - Main Accumulation Area
Amherst College, because of our site specific setup, requires a different generator status for our facilities creating hazardous waste outside the campus core (those sites located on the opposite sides of routes 9 and 116 from the main campus). Buildings such as College Hall, Lord Jeffery Inn, and the Amherst Golf Club are classified as Very Small Quantity Generators (VSQG).

The VSGQ generator status, otherwise known as Conditionally Exempt allows the College to transport hazardous waste, by trained employees across a public way, in this case, routes 9 and 116. Personnel in Recycling, Special Services and Environmental Health & Safety who have been trained in accordance with RCRA requirements are permitted to transport this material over a public way, following the right hand rule, provided the route is contiguous with the college.

Under VSQG status, the Amherst Golf Club, College Hall Print Shop, the Observatory, and the Lord Jeffery Inn are unable to generate more than 100 kilograms (220 pounds) each month. VSQGs can treat their waste, if trained, through the process of neutralizing or destruction, provided they follow polices and procedures already in writing. Any deviation from written policies and procedures could be considered a violation in accordance with the State Department of Environmental Protection and Federal EPA Regulations. EPA can fine and cite Amherst College is such cases.

The remainder of the campus, referred to as the "Core" is registered with the Massachusetts DEP (MADEP) as a Large Quantity Generator, because we collectively generate more than 2,200 lbs of hazardous waste monthly, the majority of which is related to lead paint waste. The departments at the "Core" include, but are not limited to Biology, Chemistry, Facilities, Geology and Physics. In addition to our departments referred above, the Facilities Department requires all Amherst College Contractors and Sub-Contractors to properly dispose of any hazardous waste including oils, lead paint chips and wood through the MAA at the Facilities Building for proper disposal methods and for regulatory record keeping purposes.

Large Quantity Generators are not permitted to;

  1. treat hazardous waste to reduce volume or hazard
  2. store a container in the MAA for a period of 90 days or more
  3. transport waste across a public way such as College Street, Northampton Road or South Pleasant St.

Main Accumulation Areas (MAA) are areas on campus where we can accumulate hazardous waste for a period of not more than 90 days awaiting shipment to a TSDF. The three Main Accumulation Areas are:

  1. Merrill Science Room 130B
  2. Earth Science Room 023
  3. Hazardous Material Storage Building Bay 4
The Main Accumulation Areas have limited access. Only personnel trained to handle, store and transport hazardous materials and waste can access the MAAs.

Because of our generator status, Amherst College is required to perform inspections of the Main Accumulation Area. Amherst College conducts the inspection on a weekly basis and records the results in accordance with our Best Management Practices.

Considerations in storage area management must include:

  • Adequate space between aisles
  • Area properly delineated from other storage
  • Signage
    • Hazardous Waste
    • No Smoking
  • Containers
    • Containers labeled and facing forward
    • Laboratory and Safety Information card
  • Weekly inspection of MAA performed
  • A phone immediately available for emergency notification
The inspection of the Main Accumulation Area shall include:
  1. Door Signage
    1. Main Accumulation Area – Hazardous Waste
    2. Warnings
    3. Hazards
    4. Name of Emergency Coordinator and Telephone Number
      • Work telephone number
      • Emergency telephone number (after hours)
  2. Telephone Location
    • Emergency telephone numbers
      • Ambulance
      • Fire
      • Police
      • Emergency contact(s)
      • Physical Plant Service Desk
  3. Fire Extinguisher
    • Appropriate type - ABC
    • Inspection tag, in date
  4. Facility Security
    • Door locked and accessible to trained personnel only?
  5. Secondary Containment
    • Adequate size to contain a spill?
    • Are materials compatible?
    • Floor free of drains, cracks, gaps, etc.?
  6. Leaks or Spills
    • No evidence of leaks or spills?
  7. Berms
    • Is the room, floor or area able to contain a spill and prevent the migration of hazardous materials and wastes to locations outside the Main Accumulation Area?
  8. Containers must be:
    • In good condition without leaks, damage, or signs of deterioration.
    • Facing forward
    • Suitable containment for the type of waste (i.e. corrosives should not be placed in metal drums)
    • Covered or capped (exception: when being emptied or filled)
    • Labeled with the appropriate information, including but not limited to:
      • A Hazardous Waste label
      • Name of specific material and quantity with characteristic identifiers
      • There can be no abbreviation or symbols
      • Type of hazard (i.e. corrosive, ignitable, reactive, toxic)
      • Date accumulation in the container began (The container's age cannot be more than 90 days (3 months))
      • EPA Generator Number
      • Name and address of the generator - Amherst College
      • Waste code (e.g. MA99, D004, P01)

Main Accumulation Areas (MAA) are areas on campus where we can accumulate hazardous waste for a period of not more than 90 days awaiting shipment to a TSDF. The three Main Accumulation Areas are:

  1. Merrill Science Room 130B, Earth Science Room 023, and
  2. the Hazardous Material Storage building, Bay 4, which is located behind the Facilities Garage.
The Main Accumulation Areas have limited access. Only personnel trained to handle, store and transport hazardous materials and waste can access the MAAs.

Because of our generator status, Amherst College is required to perform inspections of the Main Accumulation Area. Amherst College conducts the inspection on a weekly basis and records the results in accordance with our Best Management Practices.

Considerations in storage area management must include:

  • Adequate space between aisles
  • Area properly delineated from other storage
  • Signage
    • Hazardous Waste
    • No Smoking
  • Containers
    • Containers labeled and facing forward
    • Laboratory and Safety Information card
  • Weekly inspection of MAA performed
  • A phone immediately available for emergency notification
The inspection of the Main Accumulation Area shall include:
  1. Door Signage
    1. Main Accumulation Area – Hazardous Waste
    2. Warnings
    3. Hazards
    4. Name of Emergency Coordinator and Telephone Number
      • Work telephone number
      • Emergency telephone number (after hours)
  2. Telephone Location
    • Emergency telephone numbers
      • Ambulance
      • Fire
      • Police
      • Emergency contact(s)
      • Physical Plant Service Desk
  3. Fire Extinguisher
    • Appropriate type - ABC
    • Inspection tag, in date
  4. Facility Security
    • Door locked and accessible to trained personnel only?
  5. Secondary Containment
    • Adequate size to contain a spill?
    • Are materials compatible?
    • Floor free of drains, cracks, gaps, etc.?
  6. Leaks or Spills
    • No evidence of leaks or spills?
  7. Berms
    • Is the room, floor or area able to contain a spill and prevent the migration of hazardous materials and wastes to locations outside the Main Accumulation Area?
  8. Containers must be:
    • In good condition without leaks, damage, or signs of deterioration.
    • Facing forward
    • Suitable containment for the type of waste (i.e. corrosives should not be placed in metal drums)
    • Covered or capped (exception: when being emptied or filled)
    • Labeled with the appropriate information, including but not limited to:
      • A Hazardous Waste label
      • Name of specific material and quantity with characteristic identifiers
      • There can be no abbreviation or symbols
      • Type of hazard (i.e. corrosive, ignitable, reactive, toxic)
      • Date accumulation in the container began (The container's age cannot be more than 90 days (3 months))
      • EPA Generator Number
      • Name and address of the generator - Amherst College
      • Waste code (e.g. MA99, D004, P01)
Appendix A - Satellitte Accumulation Area Rules
Appendix A Generator Status - Satellite Accumulation Area

A Satellite Accumulation Area is a room specific location for the temporary placement of hazardous waste. Every laboratory facility, studio, shop or other facility that generates hazardous waste is required to have a Satellite Accumulation Area. These areas must be located in the rooms where the waste is actually generated. Waste cannot be relocated to an SAA in another building facility or laboratory.

Depending on the type of waste and its hazards, the largest quantity that could be placed in a SAA is 55 gallons. However, the hazard may dictate otherwise: a 55-gallon drum of a flammable liquid waste would not be permitted in any College laboratory or shop, for fire safety reasons. (SAAs can hold no more than a single quart of "Acutely Hazardous Waste.") Containers that do not exceed the size or quantity referenced above can remain in the SAA until filled. There is no time frame for containers in an SAA. The Chemical Hygiene Officer and Environmental Health and Safety Manager are available to assist with the determination of what the waste material is and how much can be temporarily stored in a laboratory, shop and/or studios.

Any container of waste that has been placed in the SAA can remain there until full. When full (pint, liter gallon, five gallon etc.), the container must be removed within three days, and shall indicate the date of placement into the MAA.

The person responsible for the SAA has only three days to have the waste removed or relocated to a Main Accumulation Area. If the laboratory, facility or room has two bottles with the same contents in the SAA, the laboratory, facility or shop shall be considered out-of-compliance, as only one bottle of the "same" waste material or mix of wastes is permitted.

Like the MAAs, Amherst College requires SAAs to be inspected weekly. The inspection must be performed by an SAA Trained Amherst College faculty, staff or student, in accordance with both the Federal Environmental Protection Agency (EPA) and the Massachusetts Department of Environmental Protection. The SAA inspection must include:

  1. Secondary Containers
    • A chemical resistant container that will contain a spill from a broken, leaking or otherwise damaged primary container
    • The secondary containers must be labeled "Hazardous Waste"
    • The area in which the secondary container is placed must be properly identified, demarcated.
    • A sign over the SAA should indicate
      • Satellite Accumulation Area
      • Hazardous Waste
  2. Compatible Materials
    • Only materials that are compatible can be placed in the same secondary container
    • A list of incompatible chemicals can be found in Appendix A of the SAA Police at the Environmental Health & Safety website.
  3. Single bottle, drum, or container in place
  4. Inspection Form Review
    • Is the form present on site?
    • Has it been checked off each week
    • Does it cover all parts of the required inspection
  5. Containers
    • Must be facing forward
    • Cannot be leaking or spilled
    • Must be labeled properly 
      • Appropriate color code label with hazard
        • Blue label – solids or liquid mercury
        • Red label – aqueous solutions
        • White – halogenated organic compound and solvents
        • Yellow – nonhalogenated organic compounds, solvents, vegetable or petroleum based oils.
      • The EPA Generator number must be on the label
      • Chemical contents must be labeled in full
        • Abbreviations, symbols are not permitted
      • The chemical specific quantity of each material must be on the label
      • The type of hazard must be checked or otherwise identified
        • Corrosive, Ignitable, Reactive, or Toxic
In addition to proper labeling, every bottle in the SAA must be capped or covered, unless actively being filled or discharged. Bottles, cans, or other containers left uncovered or inadequately covered or capped are considered to be non-compliant, and could result in citation or fine. Only one container is allowed for each specific waste or mix of wastes in the SAA, i.e., two containers having identical waste are not allowed at the same time.

 
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