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.
What makes a waste hazardous? The simplest explanation is anything that would hurt people, the environment, and wildlife if just thrown away in the normal trash or discharged into our water or air.
Common Hazardous Wastes
Common hazardous wastes generated at the Institute include:
Used solvents
Waste oils and lubricants generated by a variety of operations including motor vehicles, elevators, plant maintenance, etc
Unused chemicals and other hazardous substances, such as strong acids & bases, paints, aerosol cans, etc. that are no longer needed or unusable
Used ethylene glycol and other coolants
PCBs, batteries, lead paint and other miscellaneous materials including, contaminated rags and wipes, broken mercury-containing lamps (i.e. fluorescent lamps) and thermometers
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.
Characteristics of Hazardous Wastes
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
The four characteristics are:
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
Overview of Regulatory Requirements
The following is applicable to most generators of hazardous waste.
Labeling
Containers, which store hazardous waste, must be properly and clearly labeled.
Labels must include:
The words “Hazardous Waste”
The container contents (e.g. “Waste Oil, Ethanol, Acetone, etc.”)
The hazards associated with the waste (e.g. “Toxic”)
The approximate percentages (%) for mixtures, if possible, should be provided
Bldg/Room#, Generator, PI
Once a satellite accumulation container becomes filled, the date must be written on the label; and collected within three days (consecutive).
The EHS Office Environmental Program (EMP) provides Hazardous Waste (HW) labels (red tags), however other labels might be used as well with EMP approval.
Accumulation and Storage
Hazardous waste regulations establish a two-tiered waste accumulation and storage system:
Satellite accumulation
Storage areas
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.
Disposal
Where available, full hazardous waste containers can be transferred from the satellite accumulation area to the storage area. If your DLC does not have a storage area you can request one.
A waste chemist will come to your lab and pick up your waste. Please be very specific about the waste, adding notes about the waste and specifically where it is located in the lab in the comments section. You can also request supplies you may need through the chemical waste pick up form, like replacement five-gallon pails, secondary containers, or labels/red tags.
Emergency Preparedness & Prevention
In accordance with regulatory requirements, the Institute maintains Hazardous Waste Contingency Plan for the Cambridge campus. MIT has also implemented preparedness and prevention procedures to minimize threat of fire or explosion and has developed hazardous waste contingency plan addressing emergency response.
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 management of hazardous waste must complete a training program, which covers applicable hazardous waste regulations. EMP provides hazardous waste training sessions.
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.
Hazardous Waste Streams
This section outlines management regulations for the following waste streams:
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.
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:
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:
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.
What makes a waste hazardous? The simplest explanation is anything that would hurt people, the environment, and wildlife if just thrown away in the normal trash or discharged into our water or air.
Common Hazardous Wastes
Common hazardous wastes generated at the Institute include:
Used solvents
Waste oils and lubricants generated by a variety of operations including motor vehicles, elevators, plant maintenance, etc
Unused chemicals and other hazardous substances, such as strong acids & bases, paints, aerosol cans, etc. that are no longer needed or unusable
Used ethylene glycol and other coolants
PCBs, batteries, lead paint and other miscellaneous materials including, contaminated rags and wipes, broken mercury-containing lamps (i.e. fluorescent lamps) and thermometers
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.
Characteristics of Hazardous Wastes
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
The four characteristics are:
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
Overview of Regulatory Requirements
The following is applicable to most generators of hazardous waste.
Labeling
Containers, which store hazardous waste, must be properly and clearly labeled.
Labels must include:
The words “Hazardous Waste”
The container contents (e.g. “Waste Oil, Ethanol, Acetone, etc.”)
The hazards associated with the waste (e.g. “Toxic”)
The approximate percentages (%) for mixtures, if possible, should be provided
Bldg/Room#, Generator, PI
Once a satellite accumulation container becomes filled, the date must be written on the label; and collected within three days (consecutive).
The EHS Office Environmental Program (EMP) provides Hazardous Waste (HW) labels (red tags), however other labels might be used as well with EMP approval.
Accumulation and Storage
Hazardous waste regulations establish a two-tiered waste accumulation and storage system:
Satellite accumulation
Storage areas
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.
Disposal
Where available, full hazardous waste containers can be transferred from the satellite accumulation area to the storage area. If your DLC does not have a storage area you can request one.
A waste chemist will come to your lab and pick up your waste. Please be very specific about the waste, adding notes about the waste and specifically where it is located in the lab in the comments section. You can also request supplies you may need through the chemical waste pick up form, like replacement five-gallon pails, secondary containers, or labels/red tags.
Emergency Preparedness & Prevention
In accordance with regulatory requirements, the Institute maintains Hazardous Waste Contingency Plan for the Cambridge campus. MIT has also implemented preparedness and prevention procedures to minimize threat of fire or explosion and has developed hazardous waste contingency plan addressing emergency response.
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 management of hazardous waste must complete a training program, which covers applicable hazardous waste regulations. EMP provides hazardous waste training sessions.
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.
Hazardous Waste Streams
This section outlines management regulations for the following waste streams:
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.
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:
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:
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.