Chemical Waste

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
• Flammable compressed gas
• Oxidizers
• Materials with National Fire Protection Association (NFPA) or Hazardous Materials Identification System (HMIS) flammability hazard rating of 3 or 4

Hazardous waste that is classified as reactive includes the following:

• Materials that tend to be unstable at normal temperatures and pressures
• Water-reactive materials
• Explosives
• Cyanide or sulfide-bearing wastes

Examples include:

• Pyrophoric metals such as sodium
• Cyanide wastes
• Ethers
• Peroxides

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

Hazardous waste that is classified as corrosive includes:

• Aqueous solutions with pH less than 2 or greater than 12.5
• 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
• Alkaline degreasers
• Water/wastewater treatment chemicals
• Any debris that is contaminated with this material

Hazardous waste accumulation, which is at the point of generation and under the control of the person generating the waste, is called satellite accumulation (SAA).

Chemical compatibility is critical in waste management, both within the collection container and within the secondary containment containers in these accumulation areas.

SAA regulations include:

• A maximum of 55 gallons of hazardous waste or 1 quart of acutely hazardous waste at each satellite accumulation area
• Only one container is allowed per waste stream
• Satellite accumulation containers must be closed unless waste is being added to the container
• Full containers should be dated and can be stored in the satellite accumulation area for a maximum of three days before being transferred to a storage area
• Once the full container is dated and a request for removal is placed, a new container of the same waste stream can be started
• Bottles of hazardous waste, which are properly labeled, must be stored in an appropriate secondary container in a designed SAA

The EHS Office provides green SAA stickers for such purposes. Satellite accumulation areas are visually inspected by the lab each week to ensure compliance.

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 storage 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 the labels once the first drop of waste is added to the container
• Documented inspections are required weekly

These locations also meet more stringent requirements with respect to state regulatory Contingency Plan documentation requirements, which EHS manages.

If your department, lab, or center (DLC) requires one of these storage locations, contact the EHS Office and a representative of EMP Hazardous Waste Program will provide guidance and training, as well as, inspect your storage area on a weekly basis.

Universal wastes are a special classification of hazardous waste and tend to meet the following criteria:

• They are widespread among industry and households
• They are commonly found in medium to large volumes
• They exhibit low-level hazards to human health and the environment
• They contain hazardous materials that may be recycled

If universal waste items are not managed under the universal waste regulations (310 CMR 30.1000), they may be accumulated, collected, transported, stored, treated and disposed of in compliance with the hazardous waste regulations (310 CMR 30.000).

Federal and state regulations outline requirements for identifying, handling, storing, labeling, and recycling universal waste. These waste streams 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

Massachusetts regulations include additional items such as Cathode Ray Tubes and Lead Acid Batteries to be managed similarly to Universal Waste items.

EHS provides guidance for maintaining compliance and offers annual training to those managing Universal Waste streams on campus, specifically within the Department of Facilities.

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”
• Select “Create Request” and then select “Recycling” to submit your request

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.

Any elemental mercury and devices containing elemental mercury should be collected in a container to prevent breakage and mercury spills.

Contact EHS for assistance via email at environment@mit.edu.

Lithium, Sodium, and Potassium Metals and Powders

• Working within the glove box, or controlled environment,  contain and completely submerge the waste materials in mineral oil
• Label the container with a red tag, spelling out the chemical constituents, indicating “ignitable and reactive” as the associated hazards, and dating the container
• Place it in the lab’s SAA and submit a waste collection pick up request for removal.

If working with these materials, please work with EHS to prepare a lab/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.

Dry Picric Acid

Surplus dry picric acid should be made safe for removal from the lab by wetting the material prior to placing a waste collection request.

Please follow these steps to safely and effectively wet the dry picric acid:

• Wear the appropriate personal protective equipment (PPE) for this process —lab coat, nitrile gloves, and safety glasses – and conduct all work within a chemical fume hood
• Fill a 1 gallon (1G) “mayo” container halfway with DI water, and place it in the fume hood.
• Place the dry picric acid container into the 1G container of DI water and allow it to sit and absorb the water for at least 24-hours or until the DI water turns yellow
• Once the water has turned yellow, open the 1G container in order to access the bottle of picric acid and open the bottle of picric acid to allow the chemical bottle to be submerged into the water
• Close the 1G container with the submerged picric acid bottle, red tag the bottle (picric acid, water; corrosive) and request a pickup from the lab’s SAA or place in the lab’s MAA

Contact EHS for assistance/questions/concerns regarding this process.

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 handling these materials and wastes and precautions must be implemented.

An example of a material requiring a stabilization by a licensed environmental vendor includes peroxide forming chemicals with peroxides well over 100ppm or those with crystals formed inside or on the cap of the bottle.

If you need to get rid of a waste that is 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:

• Collect in a compatible container
• Label with red tag
• Clearly identify constituents on red tag and indicate associated hazards
• Place the container in a secondary containment bin with a green SAA sticker
• Use a quick connect for 20L containers or larger in order to provide a closed container, or
• Drill a fitted hole in 4L or smaller bottle cap for tubing, which must be a tight fit to provide a closed container

Chemically contaminated sharps include: needles (with or without syringe attached), razor blades, and pipette tips.

If these are contaminated during use with chemicals, they must be collected in a proper container with compatible materials.

Examples  of chemically contaminated sharps that should be kept separate from general sharps include:

• Pyrophoric chemicals (lithium, magnesium, potassium, etc)
• Heavy metals (mercury, chromium, lead, arsenic, etc.)
• Strong acids (sulfuric & nitric acid)
• Acutely Hazardous (P-Listed)

Label waste with a red tag, listed with associated constituents and mark toxic for the hazard. Store in a closed container within or near a labeled SAA.

Saturated wipes and paper towels, contaminated gloves and glassware, broken glass, and spill cleanup materials contaminated during use with chemicals or from spill cleanup, must be collected in a proper container with compatible materials.

Examples of chemically contaminated debris to keep separate from general debris stream include:

• Pyrophoric chemicals (lithium, magnesium, potassium, etc)
• Heavy metals (mercury, chromium, lead, arsenic, etc.)
• Strong acids (sulfuric & nitric acid)
• Acutely Hazardous (P-Listed)

Label waste with a red tag, indicating debris (or solids), at least three chemical constituents, and associated hazard(s). Store in a closed container within or near a labeled SAA.

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 wastewater.

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

There are two general approaches for fixer treatment on campus:

• Point of generation — Some labs have installed silver recovery devices at the point of generation, integrated with automated film processors and employing metered flow through a media which traps the silver; the cleaned fixer is typically then combined with the developer to adjust the pH and discharged directly to drain
• Collection for centralized treatment — Some labs rely on the EHS office to collect their fixer waste for treatment in a central unit managed by the Environmental Management Program

Treatment at the point of generation will typically be required for any newly installed photographic or film processing.

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.

Contact the Environmental Management Program of the EHS office with any questions concerning your photographic waste.