Hazardous chemical waste may be generated from laboratory operations, facilities operations and maintenance, construction and renovation activities, photo processing, and a variety of other activities at the Institute.
Hazardous chemical waste may be generated from laboratory operations, facilities operations, maintenance, construction and renovation work, shops and clubs, and other activities at the Institute.
What makes chemical waste hazardous? Anything that would hurt people, wildlife and the environment if thrown away in the normal trash or discharged into our water or air.
The information presented below is intended to be a summary, so please refer to the Hazardous Waste Management and Hazardous Waste Disposal Standard Operating Procedures available at ‘Forms and SOPs’ section of the website. Always reach out to MIT EHS at 617-452-3477 for guidance.
Common Hazardous Wastes
Common hazardous wastes generated at the Institute include:
Used solvents, acids, bases and other laboratory reagents. Most used laboratory reagents must be collected as hazardous waste.
Waste oils and lubricants generated by a variety of operations including motor vehicles, elevators, plant maintenance, lab equipment, etc.
Unused chemicals such as laboratory reagents, paints and aerosol cans that are no longer needed or unusable.
PCBs, lead paint, contaminated rags and wipes, and broken mercury-containing lamps (i.e. fluorescent lamps).
The Environmental Management Program (EMP) is responsible for assisting Institute personnel with hazardous waste management procedures including disposal. EMP is available to assist with waste identification and storage issues.
Determining if a Chemical Waste is a Hazardous Waste
The more complicated explanation of what makes a waste hazardous is based on two factors:
Some waste chemicals are listed by the EPA or Department of Environmental Protection as dangerous and therefore must be collected and disposed of as hazardous,
Some waste meet one of four characteristics that qualify them as hazardous
Listed Hazardous Wastes:
Includes halogenated and non-halogenated solvents common to laboratories and shops, and often regulated at 10% concentration or higher before use.
Common Examples at MIT: acetone, trichloroethane, trichloroethylene, methanol, toluene, xylene, ethylbenzene.
Includes un-used containers of a long list of chemicals. Generally speaking, chemical waste streams which include a U Listed chemicals should be collected as hazardous waste.
Common Examples at MIT: acetonitrile, ethyl acetate, chloroform, hydrazine, formaldehyde.
Includes those materials which EPA considers acutely toxic. Additional management steps are involved in the disposal of these materials.
Common Examples at MIT: sodium azide, osmium oxide.
You can see/sort/search these lists here: Listed Wastes
Tip: search for chemical names Chemical Abstract Service (CAS) numbers. Always contact EHS with any questions.
Characteristic Hazardous Wastes
There are four characteristics which a chemical waste could exhibit which would trigger management as hazardous waste:
Hazardous waste that is classified as ignitable includes the following:
Hazardous waste that is classified as ignitable includes the following:
Liquids with a flashpoint of less than 60° C / 140° F
Solids that burn spontaneously (ex: un-used activated carbon)
Flammable compressed gas (ex: hydrogen, propane)
Oxidizers (ex: hydrogen peroxide, nitric acid)
Hazardous waste that is classified as reactive includes the following:
Materials that tend to be unstable at normal temperatures and pressures (ex: dry picric acid),
Water reactive materials (ex: sodium, lithium),
Explosives (ex: some marine flares, rocket fuels),
Cyanide or sulfide bearing wastes
Hazardous waste that is classified as toxic contains one or more of 40 specific contaminants included in the TCLP (Toxicity Characteristic Leaching Procedure) table:
Arsenic
Barium
Benzene
Cadmium
Carbon Tetrachloride
Chlordane
Chlorobenzene
Chloroform
Chromium
O-Cresol
M-Cresol
P-Cresol
Cresol
2,4-D
1,4 Dichlorobenzene
1,2 Dichloroethane
1,1 Dichloroethylene
2,4 Dinitrotoluene
Endrin
Heptachlor
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
Lead
Lindane
Mercury
Methoxychlor
Methyl ethyl ketone
Nitrobenzene
Pentachlorophenol
Pyridine
Selenium
Silver
Tetrachloroethylene
Toxaphene
Trichloroethylene
2,4,5 Trichlorophenol
2,4,6 Trichlorophenol
2,4,5-TP (Silvex)
Vinyl Chloride
In Massachusetts, the following materials must also be managed as toxic hazardous wastes:
Waste Oil (excluding oil of animal or vegetable origin)
Polychlorinated Biphenyls (PCB)
Hazardous waste that is classified as corrosive includes:
Aqueous solutions with pH less than or equal to 2 or greater than or equal to 12.5,
Solids which when mixed with water would result in an aqueous solution with a pH less than or equal to 2 or greater than or equal to 12.5, and
Liquid that corrodes steel at a rate greater than 6.35 mm per year (0.25 inches per year) at a test temperature of 55°C (130°F).
Examples include:
Strong acids and bases
Alkaline degreasers
Water/wastewater treatment chemicals
Examples include:
Strong acids
Alkaline degreasers
Water/wastewater treatment chemicals
Any debris that is contaminated with this material
Overview of Regulatory Requirements
The following is applicable to most generators of hazardous waste.
Labeling
Hazardous waste containers must be properly and clearly labeled.
Labels must include:
The words “Hazardous Waste”
The container contents (e.g. “Waste Oil, Ethanol, Acetone, etc.”):
Full English words only
No formulas or abbreviations
No trade names (ex: WD40 should be labeled ‘petroleum hydrocarbons’)
The hazards associated with the waste (check the boxes for ‘ignitable’, ‘corrosive’, ‘reactive’, and/or ‘toxic’ whichever apply)
The approximate percentages (%) for mixtures, if possible, should be provided
Bldg/Room#, Generator, PI
The date the container became full (the date no more waste will be placed inside)
EMP provides Hazardous Waste (HW) labels (red tags), however other labels might be used with EMP approval.
Accumulation and Storage
Hazardous waste regulations establish a two-tiered waste accumulation and storage system:
The place where hazardous chemical wastes are accumulated in containers is called a satellite accumulation area (SAA).
Rules for SAAs include:
They must be located at or near the point where the chemical waste is generated.
The person generating the chemical wastes must be responsible for control of the SAA.
A maximum of 55 gallons of hazardous waste or 1 quart of acutely toxic hazardous waste at each.
Only one container is allowed per waste stream; the first must be filled and dated prior to starting an additional container of the same waste stream.
Satellite accumulation containers must be tightly closed unless waste is being added to the container.
Full containers can only be stored in the satellite accumulation area for a maximum of three days before being transferred to a storage area.
Secondary containment, usually plastic trays, must be used for all liquid chemical waste containers.
Only labeled chemical wastes can be placed inside the secondary containers in an SAA.
Incompatible chemicals cannot be stored in the same secondary container.
A sign must be present to identify each SAA. This is done with a green sticker affixed to the secondary container or to the wall adjacent to the SAA. Note: SAA stickers must be removed if a secondary container is to be re-purposed. Instructional signage can be found here, feel free to print and hang at SAAs as a useful reminder.
All SAAs must be inspected weekly; typically by an EHS Rep as part of a Level I inspection.
Main Accumulation Areas (MAAs) are where full chemical waste containers go when they are taken from satellite accumulation areas (SAAs). MIT can store hazardous waste on site for up to 90 days, or 180 days in some cases, before sending waste materials for final disposal.
The areas must meet the same requirements as the satellite accumulation areas, with a few exceptions which are generally more stringent.
There are no limits to the amount of hazardous waste stored in these areas.
Dates are required on every label.
Weekly inspections must be documented.
These locations also meet more stringent requirements with respect to Contingency Plan documentation requirements, which EHS manages.
Disposal
When a hazardous chemical waste container becomes full, it is dated and then brought to the Main Accumulation Area (MAA) area in one of two ways:
In most areas, a hazardous waste pickup request is submitted on-line, and EHS removes the full, dated container from the SAA.
Some hazardous waste generators have access to their own Main Accumulation Area, and can transport full, dated containers themselves.
A full, dated container must be removed from the SAA within 3 days, so pickup requests and waste transfers must happen immediately upon a container becoming full.
Emergency Preparedness & Prevention
MIT maintains a Hazardous Waste Contingency Plan and has implemented preparedness and prevention procedures to minimize the threat of spills or fires involving hazardous waste and to facilitate effective response to emergency situations that do arise.
To ensure your own safety and the safety of those around you:
Be aware of the dangers associated with each hazardous waste stream you generate and know the locations of spill control equipment available in your area.
Familiarize yourself with your site-specific emergency response and evacuation plan.
Review spill kit information and ensure you have one on hand.
Training
Anyone involved in the generation or management of hazardous waste must complete a training program prescribed by the Institute at least once every 12 months.
Inspections
Regulations require that hazardous waste areas (SAA and storage areas) be inspected on a weekly basis.
Personnel managing satellite accumulation areas are responsible for conducting their area’s inspection. EMP conducts the weekly inspection of all less than 90-day storage areas.
Management of Specific Hazardous Waste Streams
This section outlines management regulations for the following waste streams:
While they don’t typically fall under the category of ‘laboratory’ operations, shops and maker spaces are areas where regulated chemical wastes are often generated. What follows is some guidance on the types of wastes often encountered, and strategies for managing them. Rules for determining which wastes are hazardous and for labeling, collecting and disposing chemical wastes are detailed elsewhere, and remember that anyone who generates hazardous wastes at MIT needs training every year.
EHS is happy to come directly to your shop and help set up a chemical waste management area for the specific wastes you generate, including providing collection containers and custom signage for your area.
3-D Printing Wastes: The type of hazardous wastes generated during 3-D printing depends on the type of printing done and the process used to wash or finish the parts:
Finishing Washes / Baths: Printed parts are often washed in a caustic (high-pH) bath or a solvent (often isopropanol) bath. Used caustic and solvent must be collected as hazardous waste and disposed of via the EHS waste disposal program, and collection is best done in a 5-gallon ‘carboy’ available from EHS.
Resins: Left-over / un-cured resins are often toxic to people or the environment, and so should be collected for disposal as chemical waste. Un-cured resins left over from SLA or Polyjet printers can be collected in a bucket/barrel available from EHS.
Metals: Waste from any project that includes arsenic, barium, cadmium, chromium, lead, mercury, selenium or silver must be collected as hazardous waste. Also of concern are any very small (< 100 um) raw (haven’t yet been exposed to atmospheric oxygen) metals due to the risk of fire during oxidation. Contact EHS if you have a process which uses powdered metals.
Paints: If the liquid base of the paint is water (latex paint) then paint can be left open until the water evaporates, then the solidified pigment/can is OK for disposal as normal trash. However, if the liquid base of the paint is oil or a non-water solvent, then the can must be tightly closed and disposed of through the EHS hazardous waste program. Contact EHS if your shop has a stockpile of old paints to get rid of.
Solvents: Solvent chemicals such as turpentine, acetone and alcohols are ‘ignitable’ chemicals and must be collected for disposal through the EHS chemical waste program. It is typically OK to mix these wastes into a single container that EHS can provide.
Oil and Cutting Fluid: In Massachusetts, oil is always a ‘toxic’ hazardous chemical waste (unless from an animal or vegetable source). This includes cutting fluids used in lathes and similar equipment – even ‘biodegradable’ fluids – because they are considered oils. So all lubricating oils, oils from pumps and compressors, and cutting fluids must be collected for disposal through the EHS hazardous waste program. EHS can provide drums or barrels for collecting these wastes in your shop.
Metal Shavings: Because oil is a hazardous waste, metal shavings which are oil-soaked should be collected and disposed as hazardous waste for disposal through EHS. Shavings can be allowed to drip/shed oil so that they can be recycled, provided the drips/shed oil is collected as hazardous waste. EHS can help provide drums/containers for oil collection.
Rags: Spent shop rags typically fall into two categories:
Oily Rags must be collected as hazardous waste only if they are ‘saturated’; if they would drip oil if wrung/squeezed tightly, then they are hazardous waste and must be collected in a bucket that EHS can provide.
Solvent/Stain Rags which have been used with a chemical that is not oil, and which is a hazardous waste when disposed, must also be collected and disposed of as hazardous waste. EHS can provide a bucket to collect these wastes.
Note: some soiled rags pose a significant threat of fire – rags with linseed oil being primary among them. Contact EHS if you will be using rags with linseed oil, tung oil or pine oil, as specific collection practices are required.
Aerosol Cans: Which are not completely empty (i.e. absolutely no propellant and no product left inside) are typically not regulated as hazardous wastes. However, most shop-related aerosol cans have ignitable propellants, oil or solvent based ingredients, or some other hazardous property which requires collection if not completely empty. EHS can provide a bucket or barrel to collect waste aerosol cans for disposal through the hazardous waste program.
Pigments: The colors in glazes and pigments used in ceramics and art applications are sometimes created using toxic heavy metals. In these cases the waste pigments/glazes must be collected as hazardous wastes and disposed of through EHS. When purchasing these types of materials, always select the ones without toxic heavy metals (arsenic, lead, cadmium, chromium, mercury, etc.) as they are MUCH safer to work with.
Filters: Filters which separate out/collect material which is hazardous waste become hazardous waste themselves when it’s time for disposal. Examples include oil filters (oil is a hazardous waste), filters used at lead soldering locations and paint spray booth filters (the paints are often hazardous wastes). Spent filters must be collected for disposal through EHS, and can often be combined in containers with rags and other hazardous waste debris.
Photo Chemicals: There are some specific rules that dark room operations must follow, including safety and water discharge rules. From a hazardous waste standpoint, spent fixer is heavily laded with toxic silver and must be collected as hazardous waste. Contact EHS if you’d like to set up a photo-processing operation.
Waterjets: Waterjets use very sharp silicate minerals referred to as ‘garnet’ to cut metals and other objects. While spent garnet is almost never regulated hazardous waste (unless lead or stainless steel is cut in waterjet), it is heavy and difficult to manage. EHS can provide drums to collect spent garnet and also assist in finding contractors to do the shoveling/removal. Note that because of contaminants in the water flows, waterjets cannot be set up in places that do not have dedicated industrial wastewater collection systems. Contact EHS for help in siting and setting up a new waterjet.
Lead Soldering: Wastes generated which contained or are contaminated with lead solder must be collected as hazardous chemical waste for disposal through EHS. This includes left over solder, solder drops, and spent filters from air filtration units.
Certain manufactured articles contain toxic chemicals that, when disposed, would result in these articles becoming hazardous waste.
Because these items are ubiquitous in industry and households, pose relatively low-level hazards, and can be recycled, they can be managed as ‘Universal Wastes’ under a less burdensome set of management practices.
Universal Waste items include:
Used mercury containing light bulbs, such as fluorescent and UV light bulbs
All used rechargeable batteries including sealed lead-acid batteries — remember to tape the terminals to your 9V and lithium batteries to prevent fires during storage and transportation
Mercury-containing equipment such as thermostats, thermometers and mercury switches
If you have Universal Waste that needs to be removed from your office or laboratory:
Contact your local Repair & Maintenance Zone and/or place a request through Atlas.
If placing a request via Atlas , select “Full Catalog” in the left menu and then search on “Service Requests”.
Note: contact EHS for disposal of damaged batteries and broken bulbs.
If you work in an MIT lab and have one or two small items for removal; such as, a light bulb from your Bio-Safety Cabinet, please feel free to place a waste collection request online for the onsite hazardous waste vendor to remove this safely for you.
See the Universal Waste Management SOP for detailed guidance on management of these wastes at MIT.
Lithium, Sodium, and Potassium Metals and Powders
Within the glove box, or controlled environment, containerize the waste materials and completely submerge them in oil.
Remove the waste container from the glove box or controlled environment.
Label it with a red tag.
Spell out the chemical constituents.
Indicate “ignitable and reactive” as the associated hazards.
Date the container.
Place it in the lab’s SAA.
Place a waste collection pick up request online for hazardous waste removal.
*If working with these materials, please work with EHS to prepare a process specific SOP to ensure safety requirements are met. This process will also ensure you have the appropriate fire extinguishing method available for these water reactive chemicals.
Highly Hazardous Reactive Wastes For Stabilization
Some reactive materials are capable of violent or explosive decomposition (e.g., lethal shock-wave, extreme heat, flame or explosive gas). Special care must be observed when purchasing, managing and handling these materials..
Peroxide forming chemicals, such as THF and ethers, must be disposed of before the peroxide concentration exceeds 20 ppm:
Do not buy uninhibited reagents unless absolutely necessary
Test for peroxide concentration according to MIT policy
Picric acid, 2,4-Dinitrophenol and other reagents must be kept wet or they become unstable. Do not allow these materials to dry out.
Sodium azide is highly toxic and reactive. It must never be allowed to contact metal objects and must never be included in acidic solutions (sodium azide solutions must always be basic).
Reactive acids such as aqua regia and piranha solution require special handling once they’ve been generated. Please read and follow the MIT SOPs for use and disposal of these materials.
If you need to get rid of a waste that is highly reactive or explosive there may be a charge associated. Contact the EHS Office at (617) 452-3477 for details or via email at environment@mit.edu.
Chemical hazardous waste that is generated from laboratory equipment, such as HPLC units, should be collected as follows:
Use a 5-gallon carboy with a quick-connect (available from EHS) or with a right-sized hole in the cap. Secure the discharge line(s) from the machine in the top of the quick connect, or insert them into the hole in the cap of the carboy.
Remember that when the machine is not in use the quick connect should be disconnected, or the cap with the hole should be replaced with the intact cap.
Label the carboy with a hazardous waste label, making sure to clearly list the constituents and hazards (ex: hexane, methanol. Ignitable).
Place the waste container inside a secondary containment tray, and make sure the green ‘Satellite Accumulation Area’ sticker is on the tray.
Make sure you monitor the level of waste in the container so that overflows do not happen. You will be required to cleanup any overflowed material and dispose as hazardous waste.
When it is time to replace the waste container, make sure you replace the quick-connect or perforated cap with the intact cap, then submit a waste pickup request.
Syringes, razor blades and Pasteur pipettes should never go into the regular trash. In many cases these sharps can go into the red biohazard sharps containers (even if they don’t pose a biological hazard). However, in some cases they should be collected as hazardous chemical waste:
A sharp which is chemically contaminated. Of specific concern are sharps which were used with acutely hazardous wastes (P list), particularly-hazardous chemicals, heavy metals, and odiferous/smelly chemicals.
A syringe which is not completely empty (i.e. the plunger is not completely depressed) or a Pasteur pipette with liquid chemical remaining inside.
To collect sharps as hazardous waste:
Select a puncture-proof container with a tight-closing lid. Glass bottles with screw tops, 5-gallon carboys or sharps containers provided by EHS are good options. Never use plastic mayo jars for sharps collection.
Accumulate your hazardous waste sharps as you would any other hazardous chemical waste; in a SAA with a closed container, etc.
On the label write SHARPS prominently, then be sure to write the name of the chemicals the sharps are contaminated with.
Note: Glass bottles should be triple-rinsed and disposed of in a glassware box. Clean, broken glass should also go into the glassware box. Only contaminated broken glass should be placed into hazardous waste sharps containers.
In some cases, solid items which become contaminated with chemicals during use should be collected as hazardous waste:
Any disposable item which is used to clean up a chemical spill. Examples could include wipes, paper towels, and gloves.
Any disposable item (i.e. you will throw it away instead of cleaning and re-using) which has known become contaminated with a chemical. Good examples are silica from chromatography columns, or nitrile gloves with contamination on them.
Certain items are prohibited from disposal in the contaminated debris ‘black bucket’ waste containers:
Liquids
Sharps
Pyrophoric residues
Metal Powders
Strong Oxidizers
Mercury-contaminated items
Empty Bottles
Non-contaminated trash
To collect solid debris as hazardous waste:
Select an appropriate container with a tight-closing lid. Plastic mayo jars and 5-gallon black buckets with liners are good choices.
Accumulate your hazardous waste solids as you would any other hazardous chemical waste; in a SAA with a closed container, etc.
On the label write DEBRIS or SOLIDS prominently, then be sure to write the name of the chemicals the solids are contaminated with and check the appropriate hazard box.
If using a black 5-gallon bucket with a liner to accumulate these wastes, make sure the bucket stays closed during accumulation (with the lid screwed on), and that the bag is twisted closed and tucked inside the bucket prior to requesting a waste pickup. Buckets with bags hanging out will not be picked up for disposal.
Some chemically contaminated solids should be accumulated separately from other hazardous waste solids:
Items contaminated with pyrophoric chemicals (lithium, magnesium, potassium etc.) should be accumulated according to the rules for reactive metals (see above).
Heavy metal (mercury, chromium, arsenic, lead, etc.) contaminated solids should be kept separate from other wastes.
Photo and film processing operations (including X-rays) on campus generate scrap film and two primary liquid waste streams — developer and fixer. These wastes can be regulated by the DEP as a hazardous waste and/or by the Massachusetts Water Resources Authority (MWRA) as industrial waste water.
There are reporting requirements for all locations which discharge photographic waste to the drain. It is critical that these locations be reported to the EHS office and should be reviewed prior to installation.
If you are working in photo and film processing make sure that:
Un-used photographic chemicals that are no longer needed are collected and disposed of as a hazardous waste.
Spent developer can usually be discharged to drain with no treatment, but the safety data sheet (SDS) should be reviewed to ensure that no MWRA regulated constituents are in the developer.
Spent fixer should be treated, as it typically contains silver at levels classifying it as a hazardous waste and also may exceed allowable MWRA discharge limits for silver and pH.
Film, negatives, and paper may also contain levels of silver or other materials which would classify them as a hazardous waste. This is not typical for general photography, but specialty films such as X-ray or aerial photography film, or old (pre-1951) movie film should be evaluated for hazardous characteristics prior to disposal.
Hazardous chemical waste may be generated from laboratory operations, facilities operations, maintenance, construction and renovation work, shops and clubs, and other activities at the Institute.
What makes chemical waste hazardous? Anything that would hurt people, wildlife and the environment if thrown away in the normal trash or discharged into our water or air.
The information presented below is intended to be a summary, so please refer to the Hazardous Waste Management and Hazardous Waste Disposal Standard Operating Procedures available at ‘Forms and SOPs’ section of the website. Always reach out to MIT EHS at 617-452-3477 for guidance.
Common Hazardous Wastes
Common hazardous wastes generated at the Institute include:
Used solvents, acids, bases and other laboratory reagents. Most used laboratory reagents must be collected as hazardous waste.
Waste oils and lubricants generated by a variety of operations including motor vehicles, elevators, plant maintenance, lab equipment, etc.
Unused chemicals such as laboratory reagents, paints and aerosol cans that are no longer needed or unusable.
PCBs, lead paint, contaminated rags and wipes, and broken mercury-containing lamps (i.e. fluorescent lamps).
The Environmental Management Program (EMP) is responsible for assisting Institute personnel with hazardous waste management procedures including disposal. EMP is available to assist with waste identification and storage issues.
Determining if a Chemical Waste is a Hazardous Waste
The more complicated explanation of what makes a waste hazardous is based on two factors:
Some waste chemicals are listed by the EPA or Department of Environmental Protection as dangerous and therefore must be collected and disposed of as hazardous,
Some waste meet one of four characteristics that qualify them as hazardous
Listed Hazardous Wastes:
Includes halogenated and non-halogenated solvents common to laboratories and shops, and often regulated at 10% concentration or higher before use.
Common Examples at MIT: acetone, trichloroethane, trichloroethylene, methanol, toluene, xylene, ethylbenzene.
Includes un-used containers of a long list of chemicals. Generally speaking, chemical waste streams which include a U Listed chemicals should be collected as hazardous waste.
Common Examples at MIT: acetonitrile, ethyl acetate, chloroform, hydrazine, formaldehyde.
Includes those materials which EPA considers acutely toxic. Additional management steps are involved in the disposal of these materials.
Common Examples at MIT: sodium azide, osmium oxide.
You can see/sort/search these lists here: Listed Wastes
Tip: search for chemical names Chemical Abstract Service (CAS) numbers. Always contact EHS with any questions.
Characteristic Hazardous Wastes
There are four characteristics which a chemical waste could exhibit which would trigger management as hazardous waste:
Hazardous waste that is classified as ignitable includes the following:
Hazardous waste that is classified as ignitable includes the following:
Liquids with a flashpoint of less than 60° C / 140° F
Solids that burn spontaneously (ex: un-used activated carbon)
Flammable compressed gas (ex: hydrogen, propane)
Oxidizers (ex: hydrogen peroxide, nitric acid)
Hazardous waste that is classified as reactive includes the following:
Materials that tend to be unstable at normal temperatures and pressures (ex: dry picric acid),
Water reactive materials (ex: sodium, lithium),
Explosives (ex: some marine flares, rocket fuels),
Cyanide or sulfide bearing wastes
Hazardous waste that is classified as toxic contains one or more of 40 specific contaminants included in the TCLP (Toxicity Characteristic Leaching Procedure) table:
Arsenic
Barium
Benzene
Cadmium
Carbon Tetrachloride
Chlordane
Chlorobenzene
Chloroform
Chromium
O-Cresol
M-Cresol
P-Cresol
Cresol
2,4-D
1,4 Dichlorobenzene
1,2 Dichloroethane
1,1 Dichloroethylene
2,4 Dinitrotoluene
Endrin
Heptachlor
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
Lead
Lindane
Mercury
Methoxychlor
Methyl ethyl ketone
Nitrobenzene
Pentachlorophenol
Pyridine
Selenium
Silver
Tetrachloroethylene
Toxaphene
Trichloroethylene
2,4,5 Trichlorophenol
2,4,6 Trichlorophenol
2,4,5-TP (Silvex)
Vinyl Chloride
In Massachusetts, the following materials must also be managed as toxic hazardous wastes:
Waste Oil (excluding oil of animal or vegetable origin)
Polychlorinated Biphenyls (PCB)
Hazardous waste that is classified as corrosive includes:
Aqueous solutions with pH less than or equal to 2 or greater than or equal to 12.5,
Solids which when mixed with water would result in an aqueous solution with a pH less than or equal to 2 or greater than or equal to 12.5, and
Liquid that corrodes steel at a rate greater than 6.35 mm per year (0.25 inches per year) at a test temperature of 55°C (130°F).
Examples include:
Strong acids and bases
Alkaline degreasers
Water/wastewater treatment chemicals
Examples include:
Strong acids
Alkaline degreasers
Water/wastewater treatment chemicals
Any debris that is contaminated with this material
Overview of Regulatory Requirements
The following is applicable to most generators of hazardous waste.
Labeling
Hazardous waste containers must be properly and clearly labeled.
Labels must include:
The words “Hazardous Waste”
The container contents (e.g. “Waste Oil, Ethanol, Acetone, etc.”):
Full English words only
No formulas or abbreviations
No trade names (ex: WD40 should be labeled ‘petroleum hydrocarbons’)
The hazards associated with the waste (check the boxes for ‘ignitable’, ‘corrosive’, ‘reactive’, and/or ‘toxic’ whichever apply)
The approximate percentages (%) for mixtures, if possible, should be provided
Bldg/Room#, Generator, PI
The date the container became full (the date no more waste will be placed inside)
EMP provides Hazardous Waste (HW) labels (red tags), however other labels might be used with EMP approval.
Accumulation and Storage
Hazardous waste regulations establish a two-tiered waste accumulation and storage system:
The place where hazardous chemical wastes are accumulated in containers is called a satellite accumulation area (SAA).
Rules for SAAs include:
They must be located at or near the point where the chemical waste is generated.
The person generating the chemical wastes must be responsible for control of the SAA.
A maximum of 55 gallons of hazardous waste or 1 quart of acutely toxic hazardous waste at each.
Only one container is allowed per waste stream; the first must be filled and dated prior to starting an additional container of the same waste stream.
Satellite accumulation containers must be tightly closed unless waste is being added to the container.
Full containers can only be stored in the satellite accumulation area for a maximum of three days before being transferred to a storage area.
Secondary containment, usually plastic trays, must be used for all liquid chemical waste containers.
Only labeled chemical wastes can be placed inside the secondary containers in an SAA.
Incompatible chemicals cannot be stored in the same secondary container.
A sign must be present to identify each SAA. This is done with a green sticker affixed to the secondary container or to the wall adjacent to the SAA. Note: SAA stickers must be removed if a secondary container is to be re-purposed. Instructional signage can be found here, feel free to print and hang at SAAs as a useful reminder.
All SAAs must be inspected weekly; typically by an EHS Rep as part of a Level I inspection.
Main Accumulation Areas (MAAs) are where full chemical waste containers go when they are taken from satellite accumulation areas (SAAs). MIT can store hazardous waste on site for up to 90 days, or 180 days in some cases, before sending waste materials for final disposal.
The areas must meet the same requirements as the satellite accumulation areas, with a few exceptions which are generally more stringent.
There are no limits to the amount of hazardous waste stored in these areas.
Dates are required on every label.
Weekly inspections must be documented.
These locations also meet more stringent requirements with respect to Contingency Plan documentation requirements, which EHS manages.
Disposal
When a hazardous chemical waste container becomes full, it is dated and then brought to the Main Accumulation Area (MAA) area in one of two ways:
In most areas, a hazardous waste pickup request is submitted on-line, and EHS removes the full, dated container from the SAA.
Some hazardous waste generators have access to their own Main Accumulation Area, and can transport full, dated containers themselves.
A full, dated container must be removed from the SAA within 3 days, so pickup requests and waste transfers must happen immediately upon a container becoming full.
Emergency Preparedness & Prevention
MIT maintains a Hazardous Waste Contingency Plan and has implemented preparedness and prevention procedures to minimize the threat of spills or fires involving hazardous waste and to facilitate effective response to emergency situations that do arise.
To ensure your own safety and the safety of those around you:
Be aware of the dangers associated with each hazardous waste stream you generate and know the locations of spill control equipment available in your area.
Familiarize yourself with your site-specific emergency response and evacuation plan.
Review spill kit information and ensure you have one on hand.
Training
Anyone involved in the generation or management of hazardous waste must complete a training program prescribed by the Institute at least once every 12 months.
Inspections
Regulations require that hazardous waste areas (SAA and storage areas) be inspected on a weekly basis.
Personnel managing satellite accumulation areas are responsible for conducting their area’s inspection. EMP conducts the weekly inspection of all less than 90-day storage areas.
Management of Specific Hazardous Waste Streams
This section outlines management regulations for the following waste streams:
While they don’t typically fall under the category of ‘laboratory’ operations, shops and maker spaces are areas where regulated chemical wastes are often generated. What follows is some guidance on the types of wastes often encountered, and strategies for managing them. Rules for determining which wastes are hazardous and for labeling, collecting and disposing chemical wastes are detailed elsewhere, and remember that anyone who generates hazardous wastes at MIT needs training every year.
EHS is happy to come directly to your shop and help set up a chemical waste management area for the specific wastes you generate, including providing collection containers and custom signage for your area.
3-D Printing Wastes: The type of hazardous wastes generated during 3-D printing depends on the type of printing done and the process used to wash or finish the parts:
Finishing Washes / Baths: Printed parts are often washed in a caustic (high-pH) bath or a solvent (often isopropanol) bath. Used caustic and solvent must be collected as hazardous waste and disposed of via the EHS waste disposal program, and collection is best done in a 5-gallon ‘carboy’ available from EHS.
Resins: Left-over / un-cured resins are often toxic to people or the environment, and so should be collected for disposal as chemical waste. Un-cured resins left over from SLA or Polyjet printers can be collected in a bucket/barrel available from EHS.
Metals: Waste from any project that includes arsenic, barium, cadmium, chromium, lead, mercury, selenium or silver must be collected as hazardous waste. Also of concern are any very small (< 100 um) raw (haven’t yet been exposed to atmospheric oxygen) metals due to the risk of fire during oxidation. Contact EHS if you have a process which uses powdered metals.
Paints: If the liquid base of the paint is water (latex paint) then paint can be left open until the water evaporates, then the solidified pigment/can is OK for disposal as normal trash. However, if the liquid base of the paint is oil or a non-water solvent, then the can must be tightly closed and disposed of through the EHS hazardous waste program. Contact EHS if your shop has a stockpile of old paints to get rid of.
Solvents: Solvent chemicals such as turpentine, acetone and alcohols are ‘ignitable’ chemicals and must be collected for disposal through the EHS chemical waste program. It is typically OK to mix these wastes into a single container that EHS can provide.
Oil and Cutting Fluid: In Massachusetts, oil is always a ‘toxic’ hazardous chemical waste (unless from an animal or vegetable source). This includes cutting fluids used in lathes and similar equipment – even ‘biodegradable’ fluids – because they are considered oils. So all lubricating oils, oils from pumps and compressors, and cutting fluids must be collected for disposal through the EHS hazardous waste program. EHS can provide drums or barrels for collecting these wastes in your shop.
Metal Shavings: Because oil is a hazardous waste, metal shavings which are oil-soaked should be collected and disposed as hazardous waste for disposal through EHS. Shavings can be allowed to drip/shed oil so that they can be recycled, provided the drips/shed oil is collected as hazardous waste. EHS can help provide drums/containers for oil collection.
Rags: Spent shop rags typically fall into two categories:
Oily Rags must be collected as hazardous waste only if they are ‘saturated’; if they would drip oil if wrung/squeezed tightly, then they are hazardous waste and must be collected in a bucket that EHS can provide.
Solvent/Stain Rags which have been used with a chemical that is not oil, and which is a hazardous waste when disposed, must also be collected and disposed of as hazardous waste. EHS can provide a bucket to collect these wastes.
Note: some soiled rags pose a significant threat of fire – rags with linseed oil being primary among them. Contact EHS if you will be using rags with linseed oil, tung oil or pine oil, as specific collection practices are required.
Aerosol Cans: Which are not completely empty (i.e. absolutely no propellant and no product left inside) are typically not regulated as hazardous wastes. However, most shop-related aerosol cans have ignitable propellants, oil or solvent based ingredients, or some other hazardous property which requires collection if not completely empty. EHS can provide a bucket or barrel to collect waste aerosol cans for disposal through the hazardous waste program.
Pigments: The colors in glazes and pigments used in ceramics and art applications are sometimes created using toxic heavy metals. In these cases the waste pigments/glazes must be collected as hazardous wastes and disposed of through EHS. When purchasing these types of materials, always select the ones without toxic heavy metals (arsenic, lead, cadmium, chromium, mercury, etc.) as they are MUCH safer to work with.
Filters: Filters which separate out/collect material which is hazardous waste become hazardous waste themselves when it’s time for disposal. Examples include oil filters (oil is a hazardous waste), filters used at lead soldering locations and paint spray booth filters (the paints are often hazardous wastes). Spent filters must be collected for disposal through EHS, and can often be combined in containers with rags and other hazardous waste debris.
Photo Chemicals: There are some specific rules that dark room operations must follow, including safety and water discharge rules. From a hazardous waste standpoint, spent fixer is heavily laded with toxic silver and must be collected as hazardous waste. Contact EHS if you’d like to set up a photo-processing operation.
Waterjets: Waterjets use very sharp silicate minerals referred to as ‘garnet’ to cut metals and other objects. While spent garnet is almost never regulated hazardous waste (unless lead or stainless steel is cut in waterjet), it is heavy and difficult to manage. EHS can provide drums to collect spent garnet and also assist in finding contractors to do the shoveling/removal. Note that because of contaminants in the water flows, waterjets cannot be set up in places that do not have dedicated industrial wastewater collection systems. Contact EHS for help in siting and setting up a new waterjet.
Lead Soldering: Wastes generated which contained or are contaminated with lead solder must be collected as hazardous chemical waste for disposal through EHS. This includes left over solder, solder drops, and spent filters from air filtration units.
Certain manufactured articles contain toxic chemicals that, when disposed, would result in these articles becoming hazardous waste.
Because these items are ubiquitous in industry and households, pose relatively low-level hazards, and can be recycled, they can be managed as ‘Universal Wastes’ under a less burdensome set of management practices.
Universal Waste items include:
Used mercury containing light bulbs, such as fluorescent and UV light bulbs
All used rechargeable batteries including sealed lead-acid batteries — remember to tape the terminals to your 9V and lithium batteries to prevent fires during storage and transportation
Mercury-containing equipment such as thermostats, thermometers and mercury switches
If you have Universal Waste that needs to be removed from your office or laboratory:
Contact your local Repair & Maintenance Zone and/or place a request through Atlas.
If placing a request via Atlas , select “Full Catalog” in the left menu and then search on “Service Requests”.
Note: contact EHS for disposal of damaged batteries and broken bulbs.
If you work in an MIT lab and have one or two small items for removal; such as, a light bulb from your Bio-Safety Cabinet, please feel free to place a waste collection request online for the onsite hazardous waste vendor to remove this safely for you.
See the Universal Waste Management SOP for detailed guidance on management of these wastes at MIT.
Lithium, Sodium, and Potassium Metals and Powders
Within the glove box, or controlled environment, containerize the waste materials and completely submerge them in oil.
Remove the waste container from the glove box or controlled environment.
Label it with a red tag.
Spell out the chemical constituents.
Indicate “ignitable and reactive” as the associated hazards.
Date the container.
Place it in the lab’s SAA.
Place a waste collection pick up request online for hazardous waste removal.
*If working with these materials, please work with EHS to prepare a process specific SOP to ensure safety requirements are met. This process will also ensure you have the appropriate fire extinguishing method available for these water reactive chemicals.
Highly Hazardous Reactive Wastes For Stabilization
Some reactive materials are capable of violent or explosive decomposition (e.g., lethal shock-wave, extreme heat, flame or explosive gas). Special care must be observed when purchasing, managing and handling these materials..
Peroxide forming chemicals, such as THF and ethers, must be disposed of before the peroxide concentration exceeds 20 ppm:
Do not buy uninhibited reagents unless absolutely necessary
Test for peroxide concentration according to MIT policy
Picric acid, 2,4-Dinitrophenol and other reagents must be kept wet or they become unstable. Do not allow these materials to dry out.
Sodium azide is highly toxic and reactive. It must never be allowed to contact metal objects and must never be included in acidic solutions (sodium azide solutions must always be basic).
Reactive acids such as aqua regia and piranha solution require special handling once they’ve been generated. Please read and follow the MIT SOPs for use and disposal of these materials.
If you need to get rid of a waste that is highly reactive or explosive there may be a charge associated. Contact the EHS Office at (617) 452-3477 for details or via email at environment@mit.edu.
Chemical hazardous waste that is generated from laboratory equipment, such as HPLC units, should be collected as follows:
Use a 5-gallon carboy with a quick-connect (available from EHS) or with a right-sized hole in the cap. Secure the discharge line(s) from the machine in the top of the quick connect, or insert them into the hole in the cap of the carboy.
Remember that when the machine is not in use the quick connect should be disconnected, or the cap with the hole should be replaced with the intact cap.
Label the carboy with a hazardous waste label, making sure to clearly list the constituents and hazards (ex: hexane, methanol. Ignitable).
Place the waste container inside a secondary containment tray, and make sure the green ‘Satellite Accumulation Area’ sticker is on the tray.
Make sure you monitor the level of waste in the container so that overflows do not happen. You will be required to cleanup any overflowed material and dispose as hazardous waste.
When it is time to replace the waste container, make sure you replace the quick-connect or perforated cap with the intact cap, then submit a waste pickup request.
Syringes, razor blades and Pasteur pipettes should never go into the regular trash. In many cases these sharps can go into the red biohazard sharps containers (even if they don’t pose a biological hazard). However, in some cases they should be collected as hazardous chemical waste:
A sharp which is chemically contaminated. Of specific concern are sharps which were used with acutely hazardous wastes (P list), particularly-hazardous chemicals, heavy metals, and odiferous/smelly chemicals.
A syringe which is not completely empty (i.e. the plunger is not completely depressed) or a Pasteur pipette with liquid chemical remaining inside.
To collect sharps as hazardous waste:
Select a puncture-proof container with a tight-closing lid. Glass bottles with screw tops, 5-gallon carboys or sharps containers provided by EHS are good options. Never use plastic mayo jars for sharps collection.
Accumulate your hazardous waste sharps as you would any other hazardous chemical waste; in a SAA with a closed container, etc.
On the label write SHARPS prominently, then be sure to write the name of the chemicals the sharps are contaminated with.
Note: Glass bottles should be triple-rinsed and disposed of in a glassware box. Clean, broken glass should also go into the glassware box. Only contaminated broken glass should be placed into hazardous waste sharps containers.
In some cases, solid items which become contaminated with chemicals during use should be collected as hazardous waste:
Any disposable item which is used to clean up a chemical spill. Examples could include wipes, paper towels, and gloves.
Any disposable item (i.e. you will throw it away instead of cleaning and re-using) which has known become contaminated with a chemical. Good examples are silica from chromatography columns, or nitrile gloves with contamination on them.
Certain items are prohibited from disposal in the contaminated debris ‘black bucket’ waste containers:
Liquids
Sharps
Pyrophoric residues
Metal Powders
Strong Oxidizers
Mercury-contaminated items
Empty Bottles
Non-contaminated trash
To collect solid debris as hazardous waste:
Select an appropriate container with a tight-closing lid. Plastic mayo jars and 5-gallon black buckets with liners are good choices.
Accumulate your hazardous waste solids as you would any other hazardous chemical waste; in a SAA with a closed container, etc.
On the label write DEBRIS or SOLIDS prominently, then be sure to write the name of the chemicals the solids are contaminated with and check the appropriate hazard box.
If using a black 5-gallon bucket with a liner to accumulate these wastes, make sure the bucket stays closed during accumulation (with the lid screwed on), and that the bag is twisted closed and tucked inside the bucket prior to requesting a waste pickup. Buckets with bags hanging out will not be picked up for disposal.
Some chemically contaminated solids should be accumulated separately from other hazardous waste solids:
Items contaminated with pyrophoric chemicals (lithium, magnesium, potassium etc.) should be accumulated according to the rules for reactive metals (see above).
Heavy metal (mercury, chromium, arsenic, lead, etc.) contaminated solids should be kept separate from other wastes.
Photo and film processing operations (including X-rays) on campus generate scrap film and two primary liquid waste streams — developer and fixer. These wastes can be regulated by the DEP as a hazardous waste and/or by the Massachusetts Water Resources Authority (MWRA) as industrial waste water.
There are reporting requirements for all locations which discharge photographic waste to the drain. It is critical that these locations be reported to the EHS office and should be reviewed prior to installation.
If you are working in photo and film processing make sure that:
Un-used photographic chemicals that are no longer needed are collected and disposed of as a hazardous waste.
Spent developer can usually be discharged to drain with no treatment, but the safety data sheet (SDS) should be reviewed to ensure that no MWRA regulated constituents are in the developer.
Spent fixer should be treated, as it typically contains silver at levels classifying it as a hazardous waste and also may exceed allowable MWRA discharge limits for silver and pH.
Film, negatives, and paper may also contain levels of silver or other materials which would classify them as a hazardous waste. This is not typical for general photography, but specialty films such as X-ray or aerial photography film, or old (pre-1951) movie film should be evaluated for hazardous characteristics prior to disposal.
