Risk Management & Safety

What is Hazardous Waste?

A Hazardous Waste, is defined by the United States Environmental Protection Agency in Title 40 of the Code of Federal Regulations (40 CFR) section 261.3. Briefly stated, it says "It exhibits any of the characteristics of hazardous waste identified in subpart C..." or "It is listed in subpart D of this chapter..." Subpart C (40 CFR 161.20 through 261.24) describes four characteristics of hazardous wastes, while subpart D (40 CFR 261.30 through 261.35) contains lists of chemicals and processes that generates hazardous wastes. It is important to remember that a material must first be a waste before it can be a hazardous waste.

Characteristics of Hazardous Waste

There are four characteristics that pertain to what a hazardous waste is; if a waste has one or more of the following four characteristics, it is then a hazardous waste.

Ignitability

The characteristic of ignitability carries the waste number D001. Wastes that are regulated as a hazardous waste due to the characteristic of ignitability include:

  • Liquids with a flash point less than 140 F
  • Solids that are capable (under standard temperature and pressure) of causing fire through friction, absorption of moisture or spontaneous chemical change, and when ignited burns so vigorously and persistently that it creates a hazard.
  • Compressed gases that are ignitable as defined by the Department of Transportation (DOT).
  • An oxidizer as defined by the DOT.

Corrosivity

The characteristic of corrosivity carries the waste number D002. Wastes that are regulated as a hazardous waste due to the characteristic of corrosivity include:

  • Aqueous solutions with a pH of 2 or less (acids)
  • Aqueous solutions with a pH of 12.5 or greater (bases)
  • Liquids that corrode carbon steel

Reactivity

The characteristic of reactivity carries the waste number D003. Wastes that are regulated as a hazardous waste due to the characteristic of reactivity include:

  • A material that is normally unstable and readily undergoes violent change without detonating.
  • A material that reacts violently with water.
  • A material that forms potentially explosive mixtures with water.
  • A material that when mixed with water, it generates toxic gases.
  • Certain cyanide or sulfide bearing materials.
  • A material that is capable of detonation or explosion, or other DOT regulated explosives.

Toxicity

Below are the elements/compounds that are currently regulated as hazardous wastes when present in a waste at or above the concentration listed.

Waste No. Name Containment Regulatory Level (mg/L)
D004 Arsenic 5.00
D005 Barium 100.00
D018 Benzene 0.50
D006 Cadmium 1.00
D019 Carbon Tetrachloride 0.50
D020 Chlordane 0.03
D021 Chlorobenzene 100.00
D022 Chloroform 6.00
D007 Chromium 5.00
D023 o-Cresol 200.00
D024 m-Cresol 200.00
D025 p-Cresol 200.00
D026 Cresol 200.00
D016 2,4-D 10.00
D027 1,4-Dichlorobenzene 7.50
D028 1,2-Dichloroethane 0.50
D029 1,2-Dichloroethylene 0.70
D030 2,4-Dinitrotoluene 0.13
D012 Endrin 0.02
D031 Heptachlor (+epoxides) 0.01
D032 Hexachlorobenzene 0.13
D033 Hexachlorobutadiene 0.50
D034 Hexachloroethane 3.00
D008 Lead 5.00
D013 Lindane 0.40
D009 Mercury 0.20
D014 Methoxychlor 10.00
D035 Methyl ethyl ketone 200.00
D036 Nitrobenzene 2.00
D037 Pentachlorophenol 100.00
D038 Pyridine 5.00
D010 Selenium 1.00
D011 Silver 5.00
D039 Tetrachloroethylene 0.70
D015 Toxaphene 0.50
D040 Trichloroehtylene 0.50
D041 2,4,5-Trichlorophenol 400.00
D042 2,4,6-Trichlorophenol 2.00
D017 2,4,5-TP (Silvex) 1.00
D043 Vinyl Chloride 0.20

Listed Hazardous Waste

The lists of hazardous waste are composed of hundreds of chemicals, chemical mixtures, and the processes associated with their use. There are four different lists; each list is identified by the letters "F", "K", "P" or "U". If a chemical is included in a specific list, then when it, or any mixture of it, becomes a waste, it will be a hazardous waste.

The "F" List

The "F" list contains 39 separate waste numbers, but regulates hundreds of chemicals from nonspecific sources. This includes (but is not limited to) solvents used in degreasing, solvents in general, distillation of certain chemicals, plating solutions and wastewater treatment residues.

The "K" List

The "K" list contains 151 separate waste numbers, but it regulates wastes from specific sources. The sources include organic and inorganic chemical processes, pesticide manufacturing, and petroleum refining.

The "P" List

The "P" list contains 122 separate waste numbers, and each waste number is associated with a specific chemical, when they are discarded commercial chemical products, off-specification species, container residues or spill residues. Many common chemical wastes are regulated by the "P" list. The "P" listed wastes are identified as being acutely hazardous.

The "U" List

The "U" list contains more than 250 separate waste numbers, and each waste number is associated with a specific chemical, that are commercial chemical products, manufacturing chemical intermediates, or off-specification commercial chemical products.

Proper Waste Management

The proper management of all hazardous wastes is mandatory. It is required by Federal and State laws, University policy, and by the need to protect the environment for future generations. The laws and policy define how wastes need to be managed as to protect the environment for future generations. Simply stated "What you landfill or pour down the drain today, you may be eating or drinking tomorrow"; it makes sense to manage all wastes properly.

Four Steps to Waste Management

There are many steps to proper waste management, but you should be concerned with the following: identification; containerization; and accumulation.

  1. Identification: It is very important to identify the wastes that you or your Department generates. If a waste is not properly identified or characterized, it can't be managed.
  2. Containerization: It is very important that hazardous wastes are containerized. This helps ensure that they do not evaporate or spill into the environment.
  3. Accumulation: Most colleges and departments on campus, (art, biology, chemistry, engineering, physics, theater, etc.) have areas where hazardous wastes are accumulated until an adequate amount is ready for disposal. These areas are designated "satellite accumulation areas" (SAA). State and Federal hazardous waste regulations allow for "satellite accumulation" of hazardous waste as listed in 40 CFR Section 262.34(c). This allows for up to 55 gallons of hazardous waste or 1 quart of acutely ("P" listed) hazardous waste to be accumulated at or near the point of generation. Containers in which hazardous waste is to be put must be in good condition (e.g., without leakage, rust, dents or other structural defects), must be compatible with the waste they contain, remain closed at all times unless there is addition or removal of waste, and must be clearly labeled with the words "Hazardous Waste." Generation of more than 55 gallons of hazardous waste must be removed and placed at the UNLV Hazardous Waste 90-Day Facility within three days. Also, a satellite accumulation area must be inspected weekly by the generator of the waste, documenting the condition of containers and area and ensuring proper labeling and handling practices are conducted.
  4. Call for Help If you or anyone in your Department has a question about waste management, call the Department of Risk Management & Safety at 895-4226. If you have an after-business hours emergency, contact the Department of Public Safety at 911.

Hazardous Waste Labeling

As previously stated, all hazardous wastes must be identified and labeled indicating what they are. Below is a discussion of the Federal and State requirements, and how wastes are to be labeled here at UNLV.

Federal Law requires that all containers of hazardous waste be identified and labeled as such. This is specified by the US Environmental Protection Agency, as found in 40 CFR. Part 262, Subpart C of this regulation (40 CFR 262), Pre-Transport Requirements, is where the labeling, marking and accumulation of containers of waste are detailed. Below is an important portion of the text:

40 CFR 262.34

  1. "A generator may accumulate as much as 55 gallons of hazardous waste or one quart of acutely hazardous waste listed in Section 261.33(e) in containers at or near the point of generation where wastes initially accumulate, which is under the control of the operator of the process generating the waste, without a permit or interim status and without complying with paragraph (a) of this section provided he:
    1. Complies with Sections 265.171, 265.172 and 265.173(a) of this chapter; and
    2. Marks his containers with either the words "Hazardous Waste": or with other words that identify the contents of the containers
  2. A generator who accumulates either hazardous waste or acutely hazardous waste listed in Section 261.33(e) in excess of the amounts listed in paragraph (c)(1) of this section at or near the point of generation, with respect to that amount of excess waste, comply within three days with paragraph (a) of this section or other applicable provisions of this chapter. During the three-day period the generator must continue to comply with paragraphs (c)(1)(I) through section (ii) of this section. The generator must mark the container holding the excess accumulation of hazardous waste with the date the excess amount began accumulating."

UNLV Hazardous Waste Label

The UNLV Hazardous Waste Label is used to track the waste, and helps ensure that all regulated wastes are managed and disposed of properly. The label is described, line-by-line, below:

  • Accumulation Start Date: Enter the date that waste was filled
  • Generator Information:In this space, please print your name, telephone number, department, building, and room number.
  • Waste Composition Information: This is the location for where the description of the substance or waste is placed. Be sure to put the common or chemical name, and its approximate quantity. Do not abbreviate or use chemical formulas. Example: Photochemicals containing silver would be described as Spent Developer and Fixer, Contains Silver.
  • Hazardous Properties check boxes: most of the regulated wastes generated at UNLV are hazardous wastes. Place a check mark in the appropriate box. If unsure, contact the Department of Risk Management & Safety at 895-4226 for assistance.

If you have any questions or problems with completing the Hazardous Materials Identification Tag for any of your regulated wastes, contact the Department of Risk Management & Safety at 895-4226 as soon as possible.

Common Wastes

Below is a non-comprehensive list of hazardous and non-hazardous wastes generated at UNLV, and the applicable waste codes.

Waste Type Codes
Art DebrisD005, D006, D007, D010, F003, F005
Chemistry 116 WasteD002, D004, D006, D007, D008, D009, D010
EthanolD001
Flammable Aqueous SolutionsD001, D035, F002, F003, F005
FormaldehydeState Regulated Waste
Mercury DebrisD009
Nickel-Cadmium BatteriesD006
PhotochemicalsD010, D011
Refrigerant OilF002

Industrial Wastes

Industrial wastes include many common wastes that are not hazardous wastes, but still need to be managed more strictly than regular trash. Below is a discussion of some of the industrial wastes found at UNLV.

Used Oil

Under the 1994, Nevada Division of Environmental Protection used oil regulations, generators of used oil are required to provide for on-site management and record keeping in addition to those requirements currently enforced. Also, in the regulations, are additional requirements for bulking and blending facilities used by those transporting used oil. Most of the federal used oil management regulations as listed in 40 CFR 279, are incorporated into the Nevada regulations for used oil. However, the State of Nevada more stringently regulates mixing wastes and materials with used oil. Nevada regulations can be found in Chapter 444 of the Nevada Administrative Code. Used oil is any oil refined from crude oil, or synthetic oil, that has been used and as a result of the use is physically or chemically contaminated. Used oil, if generated in the State of Nevada, is not considered a hazardous waste if it is collected to be recycled or burned for energy recovery.

Used oil is jointly managed by the UNLV Motor Pool and Environmental Health and Safety. If you generate a waste oil, contact RMS to arrange for characterization and proper disposal or recycling.

Managing Used Oil

Departments on the university campus that generate used oil such as the motor pool must collect and appropriately store the oil. Any laboratories using vacuum pumps also generate used oil. Storage of used oil includes tanks or containers which are in good condition (e.g., without leakage, rust, dents or other structural defects). Included on these storage facilities should be the words, "Used Oil." Weekly inspections should be preformed and documented, indicating the relative condition of the containers as well as the general area of storage.

Mixing Provisions

Newly adopted Nevada regulations allow for the mixing of specific non-hazardous materials with used oil. Waste gasoline may be mixed with used oil, provided the resultant mixture does not exhibit any of the following characteristics of a hazardous waste- ignitability, reactivity, corrosivity or toxicity. Waste diesel fuel as well as non-waste diesel fuel may also be mixed with used oil.

Other mixtures with used oil not allowed under the used oil regulations must be managed as a hazardous waste. However, this is not the case if the resultant mixture is shown to be non-hazardous, recycled or burned for energy recovery. It is very important to consult with the company handling the waste oil mixture to ensure that they can accept and properly manage it.

Non-hazardous wastes mixed with used oil is allowed provided there is sufficient documentation which is to remain on-site and available for at least three years from the date of mixing.

Managing Used Oil Spills

Isolated spills of used oil may be controlled with sorbent material such as kitty litter, vermiculite, or any synthetic adsorbent provided the mixture of used oil and sorbent does not contain any free liquid. This mixture may then be disposed of as a solid waste if no free liquid remains.

Used Oil Filters

Terne is an alloy of tin and lead and functions as a plating for some oil filters. Terne filters are used in buses, heavy duty construction vehicles and tractor-trailers. Because of the lead concentration in terne-plated filters, these filters must be managed as a hazardous waste. However, for such vehicles as automobiles, vans and light duty trucks, non-terne oil filters are used.

Under EPA's final rule effective June 19, 1992, non-terne plated used oil filters are exempt from hazardous waste regulation if the oil filters have been gravity hot-drained. The EPA recommends a hot-drain time of 12 hours and defines "hot-drained" as drained near engine operating temperature and above 60 degrees Fahrenheit. The following methods are acceptable for exemption from hazardous waste regulations:

  • Puncturing the filter anti-drain back valve or the filter dome end and hot-draining.
  • Hot-draining and crushing.
  • Dismantling and hot-draining.
  • Any other equivalent hot-draining method which will remove used oil.

No determination has yet been made regarding fuel filters, transmission oil filters or specialty filters.

Antifreeze

Antifreeze is generated mostly in part from motor vehicle maintenance performed on campus. If the antifreeze is recycled, no waste determination is necessary, but the documentation of the recycling (receipt or bill of lading) must be kept on file.

Wipers & Rags

Cloth wipers and rags are widely used for cleaning applications in several departments on the university campus such as art, publications, engineering, physics and the motor pool. The wipers and rags generated in these departments are contaminated with solvents, inks, oil or grease and therefore must be managed appropriately.

Federal hazardous waste regulations as listed in 40 CFR, Section 262.11, requires that generators of theses contaminated wipers and rags determine prior to disposal, whether a hazardous or non-hazardous waste has been generated. If these wipers and rags are not laundered for reuse, several criteria apply to determine if it is a hazardous waste. Several cleaning solvents are listed in the Code of Federal Regulations as hazardous wastes. These solvents have waste number's F001, F002, F003, F005 and include tetrachloroethylene, methylene chloride, 1,1,1-trichloroethane, xylene, acetone, toluene and methyl ethyl ketone. Also, if any of the listed solvents or solvent mixtures constitute 10% of the total, the wipers and rags are managed as a hazardous waste due to the level of toxicity as well as the potential for ignitability through friction or spontaneous chemical changes.

Contamination with other substances such as heavy metals, other organics and pesticides are also possible during use and may render the wipers and rags a hazardous waste. Heavy metals include cadmium, chromium, barium, lead, mercury or silver. Determination of whether or not these wipers and rags are hazardous or non-hazardous may be needed if any of these contaminants are expected.

Once wipers and rags are determined to be a hazardous waste, they need to be regulated as such. Requirements for regulation include a closed container, label describing the contents, and accumulation time requirements.

Wipers and rags which are laundered for reuse, are not considered a hazardous waste and are not regulated by The Nevada Division of Environmental Protection. However, the following guidelines must be followed for this exemption:

  • Contaminated cloth wipers and rags must be free of any liquid which can be removed by wringing or dripping.
  • Contaminated cloth wipers and rags must be stored in sealed containers at all times during on-site storage, transportation to a laundering facility and storage prior to treatment at a laundering facility.

Possible options to consider when using wipers and rags are to change to paper wipes in order to reduce quantity and management costs and to use alternative non-hazardous solvents and materials to reduce the generation of hazardous wipers and rags. A list of alternative chemicals is available from the Business Environmental Program.

Fluorescent Lamps

Fluorescent lamps and High Intensity Discharge lamps (HID's) are used as a lighting source throughout the UNLV campus. Under Federal and State regulations, a business is responsible for determining whether each waste generated is hazardous or non-hazardous; typically fluorescent lamps and HID's contain some mercury vapor, which may cause the lamp to be a hazardous waste when no longer useful. The Nevada Division of Environmental Protection considers a combined total of 25 or fewer spent fluorescent lamps or HID's per month to be a de minimis rate.

UNLV RMS has begun characterization of the lamps generated on campus. If you require this information, please contact the Hazardous Materials Safety Office at (702) 895-2929.

Light Ballasts

Light ballasts are found in the fluorescent lamp housings, and are located in almost every office or room on campus. Ballasts sometimes fail and need to be removed, or other times they are replaced with a more energy-efficient light fixture. Either way, it is very important to manage waste light ballasts correctly. Older light ballasts contain Poly Chlorinated Biphenyls (PCB's) which are strictly regulated. All non-PCB ballasts are labeled by the manufacturer as either "Non-PCB" or "No-PCB." If a ballast does not state that it does not contain PCB's it is assumed that it does. Light ballasts can be divided into four groups:

  • Non-Leaking Non-PCB: these can be placed into the normal trash.
  • Leaking Non-PCB: these must be managed as an industrial waste - place into a labeled shipping container.
  • Non-Leaking PCB: these can be placed into the normal trash or managed as an industrial waste - place into a labeled shipping container.
  • Leaking PCB: these must be managed as an industrial waste - place into a labeled shipping container.

Aerosol Cans

Many UNLV Departments use aerosol cans during normal business; cleaning, painting and printing tend to generate spent aerosol cans. A can that is empty (all product has been used for its intended purpose and the pressure in the can is reaching atmospheric pressure) may be disposed of as a non-hazardous waste.

Occasionally, an aerosol can become plugged or the material is no longer useable. Federal and State regulations require that these aerosol cans be managed differently than empty cans. The cans may be a hazardous waste due to the pressure contained in the can or the contents may pose a hazard.

Most aerosol cans can be safely and properly emptied with an aerosol can puncturing and emptying device. This service is free of charge. If you have any aerosol cans, contact RMS at 895-4226 to arrange for disposal and/or recycling.

Batteries

Batteries are generated in almost all areas of the University. There are four different types of spent batteries generated; Alkaline, Lithium, Nickel-Cadmium and Lead-Acid.

Alkaline Batteries

Typically: "AAA," "AA," "C," "D" size batteries

Most all Alkaline batteries in use today are "low-mercury," and can be disposed of in the normal trash. Previously, many alkalines contained an appreciable amount of mercury, which causes the battery to be regulated as a hazardous waste. If you are not sure if your waste alkaline batteries are "low-mercury," contact the RMS Department office at 895-4226, and a determination will be made.

Lithium Batteries

Typically: Watch/Computer batteries

All spent or unwanted Lithium batteries are managed as a hazardous waste. This is due to the reactivity potential of the Lithium. Contact RMS if you need to dispose of this type of battery.

Nickel-Cadmium (NiCad) batteries

Typically: Rechargeable "AAA," "AA," "C," "D" sizes, Cellular phones, Radio, Power Tool batteries

All spent or unwanted NiCad batteries are managed as a hazardous waste. This is due to the toxicity of the Cadmium. Contact RMS if you need to dispose of this type of battery.

Lead-Acid Batteries

Typically: Automotive and special-purpose rechargeable batteries.

All spent or unwanted Lead-Acid batteries are batteries are managed as a hazardous waste. This is due to the toxicity of the Lead, and the corrosivity of the acid. Contact RMS if you need to dispose of this type of battery.

This document was last modified on July 06, 2015.