Hazardous Waste Management

This program describes the procedures and guidelines for the accumulation, storage and disposal of hazardous waste at California State University, Northridge (CSUN).

I.  Purpose/Scope

• Purpose:  It is the policy of California State University, Northridge that all hazardous waste management be conducted in accordance with Cal-OSHA,  Cal-EPA and Federal EPA standards and other regulatory guidelines that may apply.  No person shall accumulate, store, treat or dispose of hazardous materials or wastes at CSUN without following these procedures.
• The purpose of this program is to establish procedures for the management of hazardous waste.
• Scope:  This program applies to all persons who handle hazardous materials at CSUN. 

II.  Definitions

• Acutely Hazardous Waste:  Commercial chemical products, manufacturing chemical intermediates, or off-specification chemical products or manufacturing chemical intermediates referenced in 22 CCR Section 66261.33(e).  These are often referred to as “P” and “U”, EPA listed hazardous wastes.
• Chemical Waste: Chemicals which may have been used in a process or experiment and are contaminated or no longer necessary, or chemical byproducts of a process or experiment that have no further research, equipment or facilities value, and which may be disposed.
• Discarded Material: Any material that is relinquished, recycled, or considered inherently waste-like.
• Disposal:  (a) the discharge, deposit, injection, dumping, spilling, leaking or placing of any waste or hazardous waste into or on any land or water so that such waste or hazardous waste or any constituent thereof may enter the environment or be emitted into the air or discharged into any waters, including ground waters; (b) the abandonment of any waste.
• Extremely Hazardous Waste: Any hazardous waste or mixture of hazardous wastes which, if human exposure should occur, may likely result in death, disabling personal injury or serious illness caused by the hazardous waste or mixture of hazardous wastes because of its quantity, concentration or chemical characteristics.
• Hazardous Material: Any chemical or radioactive material used in research, custodial, physical plant maintenance, grounds, or educational activities, etc., which poses a health and safety threat to employees and/or students or a threat to the environment as a result of improper handling or disposal methods, or accidental discharge.
• Hazardous Waste: Any discarded material in any form that is: not excluded as a waste or hazardous waste, is not a “listed” hazardous waste, and does not exhibit a characteristic of a hazardous waste.  Essentially, a discarded material is considered a hazardous waste unless it can be demonstrated that it is NOT a hazardous waste.
• Medical Waste: This waste is composed of waste that is generated or produced as a result of diagnosis, treatment, immunization of human beings or animals; research pertaining to the production or testing of biologicals, biohazardous waste; or sharps.
• Mixed Waste: Mixed waste is waste that contains a hazardous waste component and a radioactive material component.
• Radioactive Waste: All radioactive isotopes that are no longer needed for educational or operational purposes.
• Retrograde Materials: Any hazardous material which is not to be used, sold or distributed for use in an originally intended or prescribed manner or for an originally intended or prescribed purpose and which meets any one or more of the following criteria: (1) has undergone chemical, biochemical, physical or other changes due to the passage of time or the environmental conditions under which it was stored; (2) has exceeded a specified or recommended shelf life; (3) is banned by law, regulation, ordinance or decree; (4) cannot be used for reasons of economics, health or safety or environmental hazard.
• Satellite Accumulation:  Accumulation of as much as 55 gallons of hazardous waste, one quart of acutely hazardous waste or one quart of extremely hazardous waste at or near any point of generation, provided the generator does not hold the waste on site for more than one year from the initial date of accumulation.  (An exemption to the 90 day storage requirement for the management of small quantities of waste)
• Universal Waste:  Universal wastes are usually items commonly thrown into the trash by households and small businesses (such as batteries, thermostats, lamps, CRT’s (computer monitors) and some electronic equipment) that contain listed hazardous waste components.
• Waste:  Any discarded material of any form (for example, liquid, semi-solid, solid or gaseous). 

III.  Exemptions/Exclusions

None.

IV.  Responsibilities

• Environmental Health & Safety (EHS):
  • Develop, maintain and manage the “Hazardous Waste Management” program.
  • Provide information, guidance or assistance to any department or employee concerning hazardous waste determination, storage, disposal or training issues.
  • Work cooperatively with hazardous waste generators to address hazardous waste concerns that require corrective action(s).
  • Conduct inspections and maintain records of the Hazardous Waste Storage Area.
  • Pick up hazardous waste when requested and arrange for off-campus disposal.
  • Maintain appropriate records required by this program.
• Department / College:
  • Develop internal procedures to ensure effective compliance with requirements of this program.
  • Make an initial hazardous waste determination at the time waste is generated.
  • Conduct weekly Satellite Accumulation Area inspections and maintain records.
  • Notify EH&S if generating undetermined hazardous waste.
  • Arrange for hazardous waste picks up with EH&S.
  • Maintain appropriate records required by this hazardous waste management program.

V.  Training

All individuals who work with hazardous waste must be trained to work safely with the materials being handled. This initial training will be conducted either by the department generating hazardous waste or through EH&S. This initial training is supplemented with annual refresher training.  Both initial and refresher training are documented, and the EH&S Depatment will inspect this documentation as part of regularly scheduled assessments. 

VI.  Forms Used

• Hazardous Waste Determination Process Form
• Hazardous Waste Labels  [formatted for Avery label 5164]
• Hazardous Waste Labeling Diagram
• Waste Lamps  [formatted for Avery label 5164]
• Waste Batteries  [formatted for Avery label 5164]
• Hazardous Waste Pickup Scheduling Page
• Hazardous Waste Transfer Form
• Satellite Accumulation Area Inspection Form
• Online Tool
• Hazardous Waste Storage Area Inspection Form

VII.  Procedures

• Department Creating Hazardous Waste (i.e. Waste Generator):
  • Evaluate the process and identify those by-products and wastes which cannot be re-used or recycled.
  • Use the Hazardous Waste Determination Process Guide and knowledge of the materials used in the process to determine if the by-products and wastes are hazardous wastes.
  • If using Satellite Accumulation;
  • Containment of Hazardous Waste:
  • Containers shall be of a material that is chemically compatible with waste(s), fitted with a closure device and kept closed when not in active use.
  • Secondary containment device(s) should be used for all liquid wastes.
  • Labeling of Hazardous Waste:
  • All containers must be labeled and dated when they are first put into service (i.e. when the first drop of waste is placed in the container).
  • Hazardous Waste Labeling Diagram provides instructions and guidelines for filling out the label.
  • Storage of Hazardous Waste (Satellite Accumulation):
  • Satellite Accumulation must be at or near the point of generation.
  • No more than fifty-five (55) gallons of a hazardous waste stream, one-quart acutely hazardous waste or one quart of extremely hazardous waste may be accumulated.  Once a satellite accumulation limit is reached, the hazardous waste must be transferred to the campus’ waste accumulation storage (90 day) area within 3 days.
  • Incompatible wastes must be separated.
  • Secondary containment must be used for all liquid containers to prevent spills or leaks.  Incompatible wastes shall not be stored within the same secondary containment device.
  • Maximum satellite accumulation time, (regardless of quantity) is 270 days.
  • Inspection of Satellite Accumulation Area:
  • Satellite accumulation areas must be inspected weekly.  Record the results of the inspection on Satellite Accumulation Area Inspection Form.
  • Satellite Accumulation Areas must be inspected for leaks, deteriorating containers or new wastes without proper labeling.
  • Initiate corrective actions for all deficiencies.
  • The inspector must initial the Satellite Accumulation Area Inspection Form verifying the inspections were completed and retain the document.
  • Hazardous Waste Transfer & Pick-Up:
  • It is the responsibility of the waste generator to arrange a hazardous waste pickup with EH&S.
  • The waste generator must submit a completed Hazardous Waste Transfer Form to EH&S prior to the waste pickup.  The Transfer Form must include chemical/waste name, amount of waste to be disposed of, preparation date and hazard class of the hazardous waste.
  • Internal disposal and/or treatment of hazardous materials will only be permitted under the direct supervision and written authorization of the EH&S Director and only when it can be proven that the methods for disposal and/or treatment are in accordance with the EPA and other City, State, and Federal regulations.
• Environmental Health & Safety (EH&S):
  • Must review and endorse department’s Hazardous Waste determinations.
  • Containment of Hazardous Waste:
    • Containers shall be of a material that is chemically compatible with waste(s), fitted with a closure device and kept closed when not in active use.
    • Secondary containment device(s) should be used for all liquid wastes.
  • Labeling of Hazardous Waste:
    • All containers must be labeled and dated when they are first put into service (i.e. when the first drop of waste is placed in the container).
    • Hazardous Waste Labeling Diagram provides instructions and guidelines for filling out the label.
  • Storage of Hazardous Waste (Satellite Accumulation):
    • Satellite Accumulation must be at or near the point of generation.
    • No more than fifty-five (55) gallons of a hazardous waste stream, one-quart acutely hazardous waste or one quart of extremely hazardous waste may be accumulated.
    • Incompatible wastes must be separated.
    • Secondary containment must be used for all liquid containers to prevent spills or leaks.  Incompatible wastes shall not be stored within the same secondary containment device.
    • Maximum satellite accumulation time, (regardless of quantity) is 270 days.
  • Inspection of Satellite Accumulation Area:
    • Satellite accumulation areas must be inspected weekly.  Record the results of the inspection on Satellite Accumulation Area Inspection Form.
    • Satellite Accumulation Areas must be inspected for leaks, deteriorating containers or new wastes without proper labeling.
    • Initiate corrective actions for all deficiencies.
    • The inspector must initial the Satellite Accumulation Area Inspection Form verifying the inspections were completed and retain the document.
  • Inspection of Waste Accumulation Storage (90 Day) Area:
    • Waste Accumulation (90 day) area must be inspected weekly.  Record the results of the inspection on Hazardous Waste Storage Area Inspection Form.
    • Initiate corrective actions for all deficiencies.
    • The inspector must initial the Hazardous Waste Storage Area Inspection Form verifying the inspections were completed and retain the document.
  • Hazardous Waste Storage Area:
    • Hazardous wastes collected from the Campus are transported and stored in the main Hazardous Waste Storage Area located in the Physical Plant Management Yard.  The general area is secured by a locked perimeter fence and within this area are two designated hazardous waste storage areas which are also locked. 
    • Do not leave ANY wastes by or near the storage area.  Contact EH&S at X2401 for access to the area.
  • Universal Waste Handling:
    • Segregate the wastes by type (battery, lamp, thermostat, etc.).
    • Place the universal waste in a compatible container and label the container when the universal waste was first placed in the container.
    • Inspect Universal Waste using the Satellite Accumulation requirements in section VII.
  • Radioactive & Mixed Waste Handling:
    • Refer to the CSUN Radiation Safety Manual for additional information and guidelines.
  • Medical Waste Handling:
    • Refer to the CSUN Medical Waste Management Plan for additional information and guidelines. 

VIII.   Guidelines/Rules

Any waste product that results from the use or accidental spillage of a hazardous material(s) is considered hazardous waste unless the waste generator can demonstrate otherwise.  Therefore, such waste cannot be disposed of in the municipal trash or campus waste water systems.  The disposal of any waste materials (that originally contained hazardous materials or laboratory chemicals) as “non-hazardous waste,” without the approval of EH&S, is prohibited.

Any employee working with hazardous waste shall also be trained in the CSUN Chemical Hygiene Program, OSHA Hazard Communication or Hazardous Materials Handling.

 In the event of a minor accidental spill or release of a hazardous material or waste, knowledgeable and experienced department personnel may clean-up the materials.  Contact EH&S for guidance if in doubt regarding major spill/release emergency procedures.  For additional information, refer to the University’s “Hazardous Materials Incidents, Prevention and Preparedness Emergency Response” located in the EH&S Office.  As a backup, our hazardous waste disposal contractor has emergency response capability and can respond to hazardous materials emergencies.

Hazardous waste generators shall acquire and stock hazardous spill cleanup kits.  It is the responsibility of the hazardous materials user to pay for and to ensure that cleanup materials exist.  The suggested clean-up kit should contain the following: (Material marked with “*” are available from EH&S.)

• Absorbent materials (Diatomaceous earth) *
• Acid Neutralization materials (Sodium Sesquicarbonate) *
• Base Neutralization materials (Citric Acid) *
• Containers (five gallon pail, 17 gallon drum) *
• pH indicators
• Gloves, suitable for the materials being handled
• Protective apron
• Eye Protection, (safety goggles, face shield)
• Tools (plastic scraper, dust pan, broom, etc)

IX.  References

• California Code of Regulations, Title 22, Division 4.5, Chapter 10 "Environmental Health Standards for the Management of Hazardous Waste"
• California Code of Regulations, Title 22, Division 4.5, Chapter 23, “Standard for Universal Waste Management”
• Code of Federal Regulations, Title 40, Part 260, “Hazardous Waste Management System"
• Code of Federal Regulations, Title 40, Subchapter R “Toxic Substances Control Act” (TSCA)
• CSUN Radiation Safety Manual
• CSUN Medical Waste Management Plan

X.  Revision Record