FAO 9.02pr - Hazardous Waste Management Procedures :

This procedure applies to all staff, students, volunteers, vendors, and visitors and is in place to ensure that all hazardous waste generated is properly identified, designated, and managed.

Waste Minimization: Reduce or eliminate waste by planning procedures that use less toxic chemicals, by using micro-techniques, or by recycling unwanted chemicals to other areas of campus, as needed and appropriate. Proper labeling and documentation must accompany all transfers.

Storage: Hazardous waste may only be stored in designated waste accumulation areas on campus. Designated areas include the Hazardous Waste Accumulation Area in the Cedar Building and the Satellite Accumulation Areas. Strict storage quantities, procedures, labeling, record keeping, and storage time limits apply to both of these areas. They are regulated by the State of Washington’s Department of Ecology (DOE) and WAC 173-303.

Labeling: Specific hazardous waste labeling is required for waste containers, storage areas, and transport vehicles. (see Detailed Procedures, item 3)

Hazardous Waste Coordinator (HWC): The college appoints and trains a Hazardous Waste Coordinator to properly manage the handling, storage, and disposal of hazardous waste. The HWC appointed for Edmonds College is the Environmental Health and Safety (EHS) Program Coordinator in the EHS/Recycling Department.

Record keeping: Strict record-keeping requirements for manifests, inspections, and storage quantities and limits are required. (see Detailed Procedures, item 10)

Inspections: Periodic inspections of waste storage areas are required.

Disposal: Disposal methods are strictly regulated. Employees will not dispose of chemical waste by pouring down sink drains, pouring onto the ground, placing in the common trash or recycling containers, evaporation, or dilution. Hazardous waste generated at Edmonds College must be disposed of through the state’s licensed hazardous waste contractor.

Shipment: As hazardous wastes are highly regulated, hazardous waste pick-ups and transport are to be arranged only through the campus HWC. The HWC must be present to oversee waste pick-ups, to sign the contractor shipping manifests, and ensure proper handling, packing, and labeling of the waste. (see Detailed Procedures, item 8)

Training: Training is required for hazardous waste generators and those involved with handling, storing, and shipping of hazardous wastes. See WAC 173-303-330. 

Training must teach personnel to:

• perform duties in compliance with WAC 173-303;

• perform dangerous waste management procedures relevant to the positions in which they are employed;

• respond effectively to emergencies.

Ensuring employee training and maintaining records of training that meets this requirement is the responsibility of the supervisor.  

DESCRIPTION
PROCEDURE DETAILS

RESPONSIBILITIES

Administrators, work area managers, and supervisors whose administrative units use, generate, store, or otherwise impact hazardous materials and waste are responsible for:

1. Monitoring the work area(s) for which they are responsible to assure these procedures are in place and maintained.

2. Assuring that all areas that purchase, handle, or generate hazardous materials and waste have qualified hazardous waste handler support.

3. Providing employee training programs that ensure compliance with WAC 173-303.

4. Developing a written training plan (example) for all hazardous waste handlers that include the following documents and records:

• ​​Documented job title, job description, and name of employee filling each job. Job description must include requisite skills, education, other qualifications, and duties for each position.
• Written description of the type and amount of both introductory and continuing training required for each position.
• Records documenting that facility personnel have received and completed the required training. Training records must be maintained at the facility for current personnel until closure of facility, and former employee training records must be kept at least three years from date last worked at the facility.

The Facilities Department is responsible for reviewing this procedure annually and establishing and implementing updates as regulations and safety standards change.

The HWC is responsible for assisting departments by collecting, designating, recycling, and disposing of chemical waste. The HWC provides departments with information on waste minimization and instructions for preparing chemical wastes for recycling or disposal. Tasks include:

1. Maintain training and certification required to meet regulatory requirements and implement program.

2. Review and recommend updates to this regulation annually and implement procedures to ensure regulatory compliance.

3. Designate waste, following all applicable regulatory requirements and the guidelines of this regulation, and ensure appropriate hazardous waste labels are attached to all waste materials.

4. Coordinate all off-site waste transportation and disposal arrangements:                                           
   • Inspect condition of transport vehicles prior to loading waste for offsite shipment.
   • Complete, sign, and maintain copies of hazardous waste manifests.
   • Complete, sign, and maintain copies of Land Disposal Restriction Certifications for each manifested shipment.​
   • Assure the return of the signed original manifest within 45 days.
   • Complete, sign, and maintain copies of all records for five years on all biohazardous waste, regulated waste, and non-hazardous waste for the college.

5. Order and maintain an adequate supply of waste containers, waste labels, personal protective equipment (PPE), and other related supplies for managing hazardous waste.

6. Collect and transport waste from the Satellite Accumulation Area(s) to the Hazardous Waste Accumulation Area. 

7. Verify that weekly inspections of all waste accumulation areas are performed and documented.

8. Ensure all waste containers in the waste accumulation areas are dated with accumulation start date.

9. Prepare and submit annual Hazardous Waste Reports to the Washington State DOE.

10. Log waste, including materials that have been transported to the Hazardous Waste Accumulation Area from Satellite Accumulation Areas, into the Waste Accumulation Log and maintain current records in accordance with regulations.

11. Keep manager apprised of program status and arrange for the disposal or recycling of waste in accordance with regulations.

12. Ensure that the waste accumulation area(s) are in compliance with all applicable regulations.

13. Maintain current spill response plan for waste accumulation area(s).

Hazardous Waste Handlers includes anyone on campus who purchases or generates a material classified as hazardous waste and is responsible for compliance with all relevant regulations, policies, and procedures related to the safe handling, storage, and containment of hazardous materials in their work areas. They must:

1. Maintain training and certification required to meet regulatory requirements, and implement procedures indicated in this program.

2. Ensure safety; persons with access to hazardous waste materials must have adequate supervision and guidance at all times.

3. Coordinate with the HWC on implementation of the required storage and disposal procedures.

4. Maintain waste accumulation areas in compliance with all regulations.

5. Ensure that waste generated in the work area is properly stored and labeled.

6. Ensure that a completed label (see Detailed Procedures, item 3) is attached to each container containing any amount of hazardous waste. Labels and assistance can be acquired from the HWC.

7. Ensure Safety Data Sheets (SDS) accompany all waste streams generated per container. Indicate discontinued materials and locations where no longer in use to the HWC at time of pick up.

8. Arrange for the disposal or recycling of waste when containers or waste accumulation area(s) are nearing capacity by generating a Facilities Department Work Order Request for pick up. Coordinating details with the HWC is required.

9. Ensure that an adequate supply of waste containers, labels, and other related supplies needed for handling and managing waste generated in the work area are available.

Employees and students must follow all applicable procedures as specified within this procedure when handling and disposing of hazardous waste.

REQUIRED PRACTICES

1. All chemical waste and process waters shall be considered suspect hazardous waste until designated otherwise by the HWC.

2. Materials listed on the Waste Stream List are managed as hazardous waste. Intentional disposal of these materials by any of the following methods is not allowed:
   • pouring down sink drains;
   • pouring onto the ground;
   • placing in the common trash or recycling containers;
   • evaporation;
   • dilution.                                               
3. Specific waste that does meet college treatment criteria will be managed as hazardous waste. Those that do must be neutralized, and meet all the requirements of regulatory agencies, with a complete disposal log maintained. Log must include hazardous waste handler name, date, amount, and method of disposal used.

4. No smoking, eating, drinking, or storage of food, medication, or tobacco products is permitted in chemical or waste handling areas.

5. Materials labeled as hazardous waste shall be handled only by trained hazardous waste handlers.

6. Only trained, HM-126F certified employees shall be involved in activities directly associated with the shipment of hazardous waste. Training to be renewed annually.

7. All areas where waste is accumulated must be provided with secondary containment that prevents the accidental release of hazardous materials. Secondary containment must remain clean and dry at all times.

8. All containers that hold flammable raw material or waste must be stored in an approved flammable materials storage cabinet that is electrically grounded and has self-closing doors, or within an approved flammable materials storage room, when not in use.

9. In waste accumulation areas, a minimum aisle space of 30 inches is required between rows of waste. A row of containers must be no more than two containers wide, except along a wall, where a row must not be more than one container wide.

10. Incompatible waste materials must remain separated at all times and may not be stored in such a way that accidental commingling could occur.

11. Good housekeeping shall be maintained in all waste accumulation areas.

12. Weekly inspections are required for all areas where containers are stored to ensure no leaking or deterioration of the containers or the containment system has occurred. An inspection log is required including at least the date, time of inspection, printed name, and handwritten signature of inspector, notation of observations, date and nature of repairs, or remedial action taken. Log must be maintained at the facility for at least five years.

13. At no time shall a container larger than five gallons or total accumulation greater than 55 gallons of waste be allowed to accumulate in any Satellite Accumulation Area.

14. All sharps must be contained in an approved, puncture-proof container prior to proper disposal by an approved biowaste disposal company and all manifests must be kept on file a minimum of five years.

DETAILED PROCEDURES

1.    General Waste Handling

• Appropriate PPE shall be worn during all handling and transporting of waste as determined by the hazards of the material. At a minimum, approved safety glasses and appropriate gloves shall be worn.
• Materials must be placed in secondary containment during transport.
• Transfer of waste from open containers shall be performed under a fume hood or within a well-ventilated work area. If, during transfer, a strong chemical reaction occurs (fumes, vapors), immediately stop, evacuate, and cordon off area; contact an appropriate hazardous waste handler and notify the Edmonds College Security Officer on duty.
• Hazardous waste shall not be mixed without prior approval by a trained hazardous materials handler and the HWC. If unauthorized mixing of waste is suspected or known to have occurred, immediately contact the HWC for evaluation.

2.    General Requirements for Waste Containers

• All containers which previously held acidic or basic liquid materials must be triple-rinsed before disposal.
• All clean, empty containers must have the labels and all other markings removed or defaced prior to disposal.
• All containers which held hazardous chemicals and still contain even trace amounts of chemical must be handled as hazardous waste.
• All containers with a capacity of one quarter inch or greater which contained material that heavily coats the container walls will be handled as hazardous waste.
• All waste containers shall be in good general condition; free of cracks, holes, dents, leaks, bulging, corrosion, or other defects or deterioration. The exterior surfaces of containers shall be free of chemical contamination.
• Leaking containers shall be placed into a closed secondary container or the contents repackaged.
• Waste containers, empty or otherwise, shall never be stored outdoors.
• Containers shall be compatible with the waste material to be placed into them.
• All waste containers shall be tightly closed except when material is being added or removed. All closures must be adequate to prevent leakage or other release.
• Waste containers shall not be filled to capacity. A minimum 10% head space is required and five inches of headspace for a 35 gallon drum.
• A Waste Accumulation Log shall be maintained for each container of waste in the Hazardous Waste Accumulation Area. 

3.    Labeling of Hazardous Waste Containers

• Each waste container must have a hazardous waste label  attached and be properly and legibly identified with, at minimum, the words “Hazardous Waste” prominently displayed on the container, a description of the material, and the primary hazard of the material. For all waste containers held in the Hazardous Waste Accumulation Area, the accumulation start date is also required.
• All other markings must be removed or defaced prior to affixing a hazardous waste label on a container.

4.    Waste Sampling and Protocol for Analysis

• Sampling methods used to designate suspect hazardous waste shall be those that comply with the regulations of the Washington State DOE.
• Composite samples shall be used whenever possible.
• Initial sampling of waste for designation shall be performed within five working days of notification of generation.
• Analytical laboratories will conduct all required testing, according to the requirements of WAC 173-303-110. Environmental Protection Agency (EPA) certified laboratories are recommended.

5.    Waste Designation

• Methods used to designate waste materials shall be acceptable to the DOE and shall follow the procedures of WAC 173-303-070 through 104.
• All hazardous waste shall be designated before disposal.
• Re-evaluation of waste stream designation shall be repeated upon vendor request, when a change in the process generating the waste occurs, or at minimum annually.
• Some materials in original containers may be designated using the SDS for the material. Consult the HWC to verify.
• The results of waste designation shall be recorded in the Profile file for the waste.

6.    Containers Whose Contents are Unknown

• If the contents of a container are unknown, do not handle, move, or otherwise disturb the container.
• Do not add any additional material to the container.
• Contact the HWC to schedule sample analysis by approved method, and disposal.

7.    Waste Accumulation Area Inspection

• Weekly inspections are required of all areas where containers are stored to ensure no leaking or deterioration of the containers or the containment system has occurred. A Weekly Waste Area Inspection form, including the date, time of inspection, printed name, and handwritten signature of person performing the inspection, notation of observations, date and nature of repairs or remedial action taken is required. Log must be maintained at the facility for at least five years.
• The inspection log shall be maintained within the waste accumulation area for reference by area personnel.
• Deficiencies which present a hazard are communicated to the hazardous waste handler(s) responsible for the accumulation area.
• All documented deficiencies must be corrected within an appropriate time frame. Completion of corrective actions must be verified on the inspection form with date and initials.

8.    Hazardous Waste Shipments

• The accumulation time shall not exceed 180 days for total waste quantities under 2200 pounds in the Hazardous Waste Accumulation Area.
• Prior to shipment vented bungs or fill gauges on drums must be replaced with a non-vented bung, and containers must be sealed and leak-proof.
• Waste shipments shall be prepared and performed in accordance with Department of Transportation and applicable destination state regulations.
  • All hazardous waste shipments shall be documented with a hazardous waste manifest.
  • A Land Disposal Restriction Certification shall be completed for each manifested waste shipment.

9.    Hazardous Material Spills

In the event of a hazardous material spill:

• Safety is the first consideration. Never do anything that places yourself or others at risk.
• If qualified, contain the spill if possible.
• If safe to do so, identify the spilled material(s), retrieve corresponding SDS, and provide to response team.
• Contact the area supervisor and appropriate hazardous waste handler, who in turn shall notify Security. If the area supervisor is not available, contact Security directly.

10.    Records

• Documentation including manifests, non-hazardous, regulated, e-waste, bill of lading, and land disposal restriction certificates shall be kept by the Facilities Office. These records shall be retained indefinitely.
• Operating records shall be kept by the Facilities Office. These records shall be retained indefinitely.
• Inspection records shall be kept by the Facilities Office. These records shall be retained indefinitely.
• Profiles shall be kept by the Facilities Office. These records shall be retained indefinitely.

DOE

Drumcode

Empty Container

EPA

Exempt Waste

Hazardous Waste Accumulation Area

Hazardous Waste Handlers

HM-126F Certified Employee

Profile

Satellite Accumulation Area

Secondary Containment

Sharps

Triple-Rinse

RELATED POLICIES AND PROCEDURES
FAO 1.0 Pollution Control Policy

FAO 1.01pr Pollution Control Procedures

FAO 9.0 Hazardous Materials Management Policy

FAO 9.01pr Hazard Communication Program

SOURCE INFORMATION
(was) 6.5.100 R103 Hazardous Waste Management Procedures

Washington State “Dangerous Waste Regulations” WAC 173-303

Department of Transportation Hazardous Materials Regulation CFR 49, Subchapter C, Parts 171-177

Training Requirements for Transportation of Hazardous Materials CFR 49 172.704

CONTENT OWNER. The primary responsibility for this policy belongs to:
Vice President for Human Resources and Operations

PRIMARY CONTENT CONTRIBUTOR (Director/Dean)
Director of Facilities and Capital Projects

REVIEW PERIOD
Yearly.

REVIEW HISTORY
2021-Oct 18  Amended to update content owner

2019-Jan 28  Approved by President’s Leadership Team

2018-Mar 02  Revised

1996-Oct 21  Adopted