Hazardous Chemical Waste is regulated by the EPA under the Resource Conservation and Recovery Act (RCRA). These EPA regulations have very specific requirement that must be followed. These requirements, as they apply to NYU, are outlined below.
> Hazardous Waste Characteristics
> Containers & Labels
> Drain Disposal
> Potentially Explosive Materials
> Non-Hazardous Chemical Waste
> Routine Waste
> Solid Wastes That May Be Hazardous
> Spill Cleanup Material
A Hazardous Waste, as defined by EPA, is any waste that exhibits one or more of the following hazard characteristics: Ignitability, Corrosivity, Reactivity, or Toxicity, or is a Listed Waste (PDF). Such a waste is subject to all EPA hazardous waste labeling, storage and disposal regulations.
Ignitability (Flammability) (40 CFR 261.21)
An ignitable or flammable waste is one that:
- Has a flash point of less than 140
- Is a non-liquid capable, under standard temperature and pressure,
of causing fire through friction, absorption of moisture, or spontaneous
chemical changes, and, when ignited, burns vigorously and persistently.
- Is an ignitable compressed gas.
- Is an oxidizing substance.
Flash point - the minimum temperature at which a liquid can give off vapors that can ignite.
Corrosivity (40 CFR 261.22)
A corrosive waste is one that:
- Can destroy or burn skin tissue
- Is capable of corroding steel at a rate greater than 0.25 inches
- Has a pH of less than 2.0 or greater than or equal to 12.5.
Reactivity (40 CFR 261.23)
A reactive waste is one that:
- Is normally unstable and can readily undergo violent change without
- Can explode or react violently with water or other wastes; or
can become unstable.
- When mixed with water, generates toxic gases, vapors, or fumes,
in a quantity sufficient to present a danger to human health or the environment.
- Is capable of detonation or explosive reaction if subjected to
a strong initiating source (impact) or if heated under confinement.
- A cyanide or sulfide solution that generates a toxic gas between pH of 2 and 12.5.
Toxicity (40 CFR 261.24)
A toxic waste is one that is dangerous to humans, animals, aquatic life or the environment.
Hazardous Materials and Hazardous Wastes must be managed in a way that prevents a spill or release. Regulated hazardous waste must be labeled, collected and stored in approved containers.
Containers must be:
- Compatible with the waste being stored.
- Leak-proof, in good condition, and capable of being sealed tightly.
- Closed at all times during accumulation except when it adding waste.
- Properly labeled.
- Have the words "Hazardous Waste"
- The chemical composition (PDF) of the waste. If a mixture, all components must be listed and their approximate precentage (totalling 100%)
- The primary hazard (ignitable, corrosive, reactive, or toxic).
- The location where the waste was generated and a contact name.
- The date the container becomes full and is ready for disposal or removal to the waste room.
The New NYU Hazardous Waste Label (DOC) should be used for all waste chemicals, particularly mixtures. It is designed so that it can be either printed directly off the website using Avery Shipping Labels #6878, or downloaded and filled in electronically before printing.
If you regularly generate the same waste, it is advisable to download the label and fill in your waste stream information electronically to save repeatedly completing identical labels.
Click on the following link to see a sample of a Completed NYU Hazardous Waste Label (PDF).
If you are disposing of pure material that is still in its original container and the manufacturer's label is in tact and legible, then you do not need to complete a full NYU Hazardous Waste Label. However, you still must label the container as follows:
- The words "Hazardous Waste",
- The primary hazard (ignitable, corrosive, reactive, or toxic), and
- The date of removal to waste room (if located in the Main Complex) or the date you called to request a pick-up, if located elsewhere on campus.
Click to see an example of a Pure Product Hazardous Waste Label (PDF).
Click here (DOC) to view and print labels for such waste.
Hazardous waste must be located at or near the point of generation and under the control of the person generating the waste.
To ensure safe and compliant storage, segregate incompatible materials (incompatibility charts) and store chemicals or waste in secondary containment, in accordance with EPA and FDNY requirements.
Hazardous waste must be disposed of through Environmental Health & Safety. Environmental Health & Safety maintains a contract with an outside contractor for the compliant disposal of hazardous waste.
Wastes generated within the Silver Complex (Silver, Brown or Waverly buildings) should be brought to the Waste Room during regular waste room hours.
For disposal of wastes generated outside the Silver Complex call Environmental Health & Safety to schedule a pickup from your location or complete a Hazardous Waste Pickup Request Form (PDF) (for an example of a completed form, click here Hazardous Waste Pickup Request Example (PDF)) and return it to Environmental Health & Safety at least 4 days prior to the next scheduled hazardous waste pick-up. Complete this form also if you know you have a lab cleanout coming up and will have a large volume of waste to be removed.
Hazardous Waste can be brought to the Waste Room (Brown 1158) every Wednesday and Friday from 2:15pm - 3:15pm . All waste must be properly labeled and dated prior to bringing it to the waste room and those transporting the waste must have received the Annual Hazardous Waste Training within the previous year.
Solids, oil and other viscous substances SHALL NOT be discarded down the drain or into the sewer system. Only water-soluble, non-hazardous laboratory chemicals, and urine or fecal homogenates, which meet the following criteria, may be flushed, with large volumes of water, into the New York City sewer system:
If unsure whether the substance meets the above criteria, consult the substance's MSDS or call Environmental Health & Safety.
Click the link for a list of Explosive Laboratory Chemicals and Potentially Explosive Chemicals (PDF).
Potentially Explosive Materials are reactive chemicals or substances that can explode or enter violent reactions releasing large amounts of light, heat, and/or gases. Reactive Materials are defined by the following four categories:
- Explosives are substances that can detonate or decompose rapidly and violently at room temperatures. Gentle heat, light, mild shock, and chemical action can initiate these explosive reactions. Potential peroxide-forming chemicals such as Tetrahydrofuran, ethers, Acetaldehyde, Picric Acid, and 1,4-dioxane are a few examples of Explosive Materials.
- Strong Oxidizing Agents are capable of detonation or explosive decomposition under conditions of strong heat, confinement, or a strong shock. Perchlorates, inorganic nitrates, chlorates, chromates and the halogens are examples of some strong oxidizing agent groups.
- Water Reactives are chemicals that combine with water or moisture in the air to produce heat, flammable explosive or toxic gases. These chemicals present a severe fire hazard because sufficient heat is often released to self ignite the chemical or ignite nearby combustibles. In addition, contact with the skin can cause severe thermal and alkali burns. Examples of some water reactive groups strong acids and bases, alkali metals (sodium & potassium, hydrides, & carbides).
- Air Reactives ignite spontaneously in air at temperatures below 130 degrees F. Finely divided metal powders that do not have a protective oxide coat may ignite when a specfic surface area is exceeded. The degree of reaction depends on the size of the particle, its distribution, and surface area. Examples of some air reactive chemicals are white phosphorus, fine zirconium powder and activated zinc.
According to FDNY requirements (RCNY 10-01), it shall be the duty and responsibility of the laboratory permit applicant or designee, to clearly record on the container, in indelible ink, the opening date of the following chemical groups (failure to do so will result in a written violation):
- Picrics originating at less than 10% hydration;
- Peroxides; (arrange to have these chemicals tested at least once every six months)
- Potential peroxide-forming materials;
- Polymerizing chemicals that react violently in polymerization or become hazardous after polymerization; and
- Any other material stored or used which are known to deteriorate or to become unstable or reactive.
Dispose within one year of opening.
If the waste material does not meet any of the criteria of the hazardous waste characteristics then the waste is not hazardous. However, that does not mean that it is not regulated in any way. Reveiw the disposal procedures for the different wastes listed on the waste disposal page. If you cannot find the information you need and are still unsure how to handle the waste, contact Environmental Health & Safety.
Routine Wastes are wastes that are generated repeatedly, regardless of
the frequency or quantity. Environmental Health & Safety would appreciate your
assistance in identifying these wastes in order to:
1. develop specific labels for these wastes, so that labs do not have to repeatedly fill in the same information, and
2. create a more accurate inventory of wastes produced.
To assist us in developing labels specifically for your routine wastes, Environmental Health & Safety requests that you complete a Routine Waste Form (PDF). Please complete a separate form for each waste stream produced on a regular basis. For each constituent of the waste stream, the approximate percentage MUST be provided. If the actual percentage is likely to change with each batch, please provide the percentage range. An example of a Completed Routine Waste Form (PDF).
Completed forms can be returned to Environmental Health & Safety by faxing 212-995-4932 or by mailing to: Environmental Health & Safety, 285 Mercer Street, 2nd Floor. There is no limit to the number of Routine Waste Forms that you may submit, but ONLY submit a form for the wastes that will be generated on a regular basis. For all other wastes, please continue to use and complete the regular NYU Hazardous Waste Label.
If you have any questions or would like to request Routine Waste Labels, please contact Environmental Health & Safety at extension 81450.
Any solid wastes, including but not limited to aerosol cans, paint cans, metal filings, painted, stained or treated woods and dusts, paper towels, absorbent materials, used gloves or any other solid wastes that could be potentially contaminated with hazardous materials, must be characterized prior to disposal, to determine if they exhibit any of the hazardous waste characteristics.
Areas where hazardous materials are used, such as laboratories, art studios and workshops, photo-developing areas, and maintenance areas must evaluate the solid wastes generated in their areas and determine if any may be contaminated with hazardous substances. Those wastes that may be contaminated must be evaluated and a hazardous waste characterization made prior to disposal.
All materials (paper towels, absorbent materials, PPE, etc.) used to clean up a chemical or waste spill should be considered to exhibit the same characteristics as would the chemical or waste that was spilled. If the substance spilled was a hazardous chemical or waste, the cleanup materials would be considered a hazardous waste and must be handled as such and disposed of through Environmental Health & Safety. See the procedures above for Disposal.
Any oil spill cleanup material shall also be collected, labeled and disposed of as Non Hazardous Waste through Environmental Health & Safety. See the procedures above for Disposal.
A controlled substance or DEA drug is any substance listed in the Controlled Substances Act, in the Code of Federal Regulations (21 CFR, Part 1300). Disposal of a controlled substance that is outdated, excess or no longer intended for use. Disposal also refers to controlled substance that is residual (often referred to as waste) or has been contaminated through use or spills.