In November 2016, the US Environmental Protection Agency (EPA) finalized revisions to the Resource Conservation & Recovery Act (RCRA) thereby changing how hazardous waste is handled. The Hazardous Waste Generator Improvement Rule became effective in Pennsylvania on June 1, 2017. Three changes in the new rule directly affect faculty, students, and staff at Temple University. Environmental Health & Radiation Safety (EHRS) has updated Temple University’s Hazardous Waste Management Program to meet the new requirements.
- Determine if the material to be disposed is hazardous at the point of generation. Previously, EHRS made this decision on behalf of laboratory personnel and waste generators after the waste material was picked by EHRS personnel (or designee). Generators of hazardous waste must now make this decision at the point of generation. EHRS developed a new hazardous waste tag to include information that will assist generators in making this waste determination at the point of generation. The new hazardous waste tag can be viewed here.
- Label hazardous waste containers with the words “Hazardous Waste” and an indication of the hazards. The new hazardous waste tags provide check boxes for generators to identify specific waste streams (where applicable) and to identify the hazardous characteristics of the material.
- Maintain a spill kit in each location where hazardous waste is created. This change has minimal impact on campus because shops, studios and labs already have material on hand to clean up a minor spill. The change does encourage personnel to re-evaluate the work area, identify the types of material likely to spill, and maintain a spill kit that is appropriate for the material used.
Other important changes regarding how Temple University manages hazardous waste on its campuses will be implemented by EHRS on behalf of the campus community and will not require any additional actions by the individual waste generator.
Frequently Asked Questions:
- Why are we getting new hazardous waste tags?
- The EPA changed the labeling rules, effective in Pennsylvania on June 1, 2017. The new tags ensure that Temple University meets this new requirement.
- When do we start using the new hazardous waste tags?
- Start using the new tags as soon as you get them. EHRS is visiting laboratories, shops and studios as quickly as possible to provide the new tags.
- When will you visit my area?
- Can we use the old labels up first?
- No, the old labels do not meet the new rules. Start using the new tags as soon as you get them.
- What do we do with the old labels?
- Throw them in the regular trash.
- Why did the style of label change to a tag?
- The tag needed to be larger in order to accommodate the additional required information. We have also received multiple request from University personnel in the past to go to a tag style.
- What if I don’t know whether the waste is hazardous or not?
- If you can’t make a determination from the original container, Safety Data Sheets (SDS) or other available reference material, the safest decision is to assume its hazardous and mark it as a “Poison”
- Are there tools to help me determine if the waste is hazardous?
- Yes, this information is on the original container label or in the Safety Data Sheet (SDS).
- Do we still need to describe the contents since we are already identifying the chemical hazards?
- Yes, this information is necessary for EHRS to determine the proper disposal process.
- Do I have to put a hazardous waste tag on hazardous waste that is in the original container?
- Yes, the hazardous waste label must have the word “Hazardous Waste” and an indication of the hazard. The new hazardous waste tags meet the new rules.
- How do I tag small sized containers?
- The revised rule requires that a completed tag is placed on each waste container. Follow one of the 3 options listed below:
- Place or tape a competed hazardous waste tag to each container.
- Place small container(s) into a zip-lock bag and tag the bag or drop the completed tag inside the bag.
- Place small container(s) that are similar or the same inside a bag or bigger container (such as a sturdy box). The completed tag can then be paced on the bag (as described above) or the bigger container.