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Health & Safety Manual - Environmental Safety

3.3 Chemical/Hazardous Waste

3.3.1 No Drain Disposal Policy
3.3.2 Classification and Identification of Hazardous Waste

3.3.2.1 Listed Hazardous Waste
3.3.2.2 Characteristic Hazardous Waste
3.3.2.3 Wastes Not Defined as Hazardous by USEPA but Prohibited from Drain Disposal by Columbia University Policy

3.3.3 Procedures for the Collection and Removal of Hazardous Waste

3.3.3.1 Hazardous Waste Collection Requirements
3.3.3.2 Hazardous Waste Removal
3.3.3 Procedures for the Collection and Removal of Hazardous Waste
3.3.3.1 Hazardous Waste Collection Requirements
3.3.3.2 Hazardous Waste Removal
3.3.4 Laboratory Glassware and Chemical Containers

3.3 Chemical/Hazardous Waste

EH&S coordinates the disposal of all chemical waste generated at Columbia University. The following procedures apply to all chemical substances generated during laboratory activities, as well as all other University business operations, that are classified as hazardous based on the information below.  Radioactive Waste (see section 3.5) or Regulated Medical Waste (section 2.12).

3.3.1 No Drain Disposal Policy

Columbia University has a No Drain Disposalpolicy for Chemical/Hazardous Waste.  Any chemical or material that matches any of the characteristics described in section 3.3.2, or is a possible carcinogen, mutagen, or reproductive toxin, or may otherwise be harmful to the human health or the environment, regardless of quantity, must never be drain disposed. If you are unsure, call EH&S for assistance.

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3.3.2 Classification and Identification of Hazardous Waste

Hazardous Waste is any unwanted material with properties that make it potentially harmful to human health or the environment.  The definition of waste materials includes spent reaction products, expired virgin materials, and materials that have no reasonably foreseen intended use.  A Hazardous Waste may be any material that is specifically listed in the federal or state regulations or exhibits at least one of four characteristics—ignitability, corrosivity, reactivity, or toxicity. 

  • 3.3.2.1 Listed Hazardous Waste - Listed Hazardous Wastes are specifically defined in federal and state regulations (See NYSDEC Part 361 and 40 CFR 265). They include chemicals from specific processes such as cleaning solvents or degreasers (i.e., acetone, ethyl acetate, methylene chloride, xylene), toxic chemicals (i.e. heavy metals), and acutely toxic chemicals, (i.e., cyanides, osmium tetroxide, epinephrine).
  • 3.3.2.2 Characteristic Hazardous Waste - In the EPA scheme of classification, there are four types of Characteristic Hazardous Waste.
    • Ignitable Waste: chemicals likely to cause a fire or exhibit the characteristic of a strong oxidizing agent, such as solvents.
    • Corrosive Waste: chemicals with a high or low pH and which can also severely damage skin or corrode metal.
    • Reactive Wastes: chemicals that react with air and/or water to produce toxic gases or are explosive.
    • Toxic Waste: heavy metals, and certain solvents.

  • 3.3.2.3 Wastes Not Defined as Hazardous by USEPA but Prohibited from Drain Disposal by Columbia University Policy- Any materials with the potential to harm human health or the environment must be collected and managed as a Chemical/Hazardous Waste, even if not specifically cited as such by the USEPA or NYSDEC.  Examples include, but are not limited to, solid sodium hydroxide and gels containing ethidium bromide.

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3.3.3 Procedures for the Collection and Removal of Hazardous Waste

All Hazardous Wastes must be managed in accordance with USEPA and NYSDEC regulations; no volume of waste is excluded from these requirements including trace amounts of reagents used for sterilization, such as alcohol.  Since the hazardous waste management regulations are complex and lengthy, EH&S created the 5 L’s as a quick reference guide for complying with these regulations.

  • 3.3.3.1 Hazardous Waste Collection RequirementsHazardous Waste must be collected in sealable, labeled containers that are compatible with the waste being collected.  Waste containers must bear an official EH&S Hazardous Waste Label that is completed in its entirety.  The Hazardous Waste Label must contain complete information about container contents at all times; for example, no abbreviations or formulas are permitted.  The Hazardous Waste collection containers must be periodically checked for leaks and may not be moved from one laboratory room to another lab.  Hazardous waste must be stored at the “point of generation” near to where the waste is generated (i.e. hazardous waste may not be stored in hallway closets).

LDEO sample Hazardous Waste label

CUMC sample
Hazardous Waste label

Morningside & Nevis sample Hazardous Waste label

  • 3.3.3.2 Hazardous Waste Removal - Hazardous Waste may only be removed from laboratories by EH&S personnel or EH&S approved vendors.  Hazardous Waste pickup requests should be submitted to EH&S via online chemical waste pickup request prior to completely filling the containers to prevent overflow, typically when 80% - 90% full.  Pickups may be requested via the online pickup request form on the EH&S website. It should be noted that at LDEO and Morningside, the chemical waste pickup request may be used to request regulated medical waste supplies and services.  At the Medical Center campus, this request must be placed with Facilities Operations office via an online service request.  At Nevis, this request must be made directly by the laboratory to the vendor.

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3.3.5 Laboratory Glassware and Chemical Containers

Containers that held acutely toxic (P-list) materials must be treated as hazardous waste (see section 3.3.3).

Empty chemical bottles make excellent hazardous waste collection containers, but lab employees must ensure that the waste stream being collected is compatible with the container.  If reusing a container for this purpose at the Morningside campus, ensure that the ChemTracker barcode is not covered by the waste label.  The barcodes for chemical bottles that will be reused for waste collection must have the barcodes removed prior to reuse.  These barcodes must be removed by lab employee and submitted to ChemTracker staff for removal from the ChemTracker system.

To dispose of unwanted empty chemical containers, rinse the container with tap water, if necessary, and deposit it in specially designated plastic-lined cardboard Glassware Disposal Box located in the lab. The Glassware Disposal Boxes may be obtained through ChemStores or the Biology Stock Room staff at Morningside.  For all other campuses, the boxes may be purchased directly from a general supplier of laboratory materials. Glassware and containers must be completely empty of chemicals and residue.  Close the box once filled and place it in the hallway for Facilities Operations to recycle.  At the Morningside campus, empty barcoded chemical containers must be collected in order to be removed from the Principle Investigator’s ChemTracker inventory by being placed in the hallway yellow bins. See the Morningside Chemical Container and Labware Disposal Policy for more information.  

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