The proper disposal of waste and/or unwanted chemicals at Brown University is taken very seriously. Disposal of waste in compliance with all applicable federal, state and local regulations is required. Hazardous Wastes are defined in the Brown University Hazardous Waste Compliance Guidelines. These wastes are required to be managed through the EPA’s “cradle-to-grave” tracking process to ensure proper disposal in compliance with all EPA regulations from the point they are initially generated to their ultimate disposal through the best available, EPA approved waste treatment technologies. The responsibility for the identification and handling of wastes within each initial waste generation area, also known as a Satellite Accumulation Area (SAA), necessarily rests with the individuals who have created the waste. Once waste has been identified in an area and all requirements pertaining to the management and storage of that waste have been met, the Office of Environmental Health and Safety will manage the pick-up, removal, and ultimate disposal of the waste.
The 10 Steps
A Summary of Hazardous Waste Requirements for all SAAs:
- Determine if the waste is an EPA defined solid waste (e.g., chemical substance that is no longer in use).
- Determine if that solid waste is a regulated hazardous waste.
- Listed Wastes - F, U, or P
- Characteristic Waste – Ignitable, Corrosive, Reactive, or Toxic
- Keep Hazardous Waste at or near the point where it is initially generated. (e.g., in the same room)
- Ensure your waste area does not exceed accumulation volume limits.
- 55 gallons of hazardous waste or
- 1 quart of acutely hazardous waste (P-Listed)
- Containers used or reused to collect hazardous waste must be:
- In good condition
- Compatible with the waste being added
- Easily resealable (e.g., twist on lid)
- No inappropriate containers (e.g., food containers, recycling bins, or glassware disposal boxes)
- Containers must be closed when not actively collecting waste (e.g., funnels must be removed).
- Label hazardous waste containers with the Brown University orange hazardous waste label including:
- Full constituent names (e.g., no abbreviations or chemical formulas)
- Approximate percentages of each constituent
- Generator’s name or supervisor of the area or project
- Mark the hazard(s) of the waste: Ignitable, Corrosive, Reactive, or Toxic
- Ensure wastes are placed in secondary containment (e.g., red trays are available in stockrooms).
- Only store compatible wastes together (e.g., segregate containers of incompatible wastes).
- Contingency Plan – In the event of an emergency chemical release or spill:
- Alert all personnel to evacuate the area
- Call Brown Public Safety 24 hour emergency number: (401) 863-4111
- Move a safe distance away and tend to injured personnel if possible
- Remain on scene to provide first responders with a firsthand account
Reminder: Red secondary containment trays and orange hazardous waste labels are available in all the stockrooms on campus at no charge for hazardous waste collection purposes only.