Ball State University
OP-25: Hazardous Waste Management

Waste minimization is any action that reduces the amount and/or toxicity of chemical wastes that must be shipped off-site for disposal as hazardous waste. The success of any waste minimization program is dependent on the conscientious participation of every individual at Ball State University.

There are three methods of waste minimization followed at Ball State University:

Source Elimination:
Remove the source of the waste by eliminating the process or practice or by substituting another process that does not generate a waste, or generates only a secondary material that can be used as a raw material in another process. For example, some laboratory demonstrations necessitate the use of chemicals that are toxic or inherently dangerous to handle. Sometimes these demonstrations can be eliminated, reproduced by other means, or video demonstrations utilized rather than performing laboratory displays that generate hazardous wastes requiring disposal.

Source Reduction:
The second most desirable method of waste minimization is source reduction. This is any activity that reduces the generation of chemical hazardous waste at the source. This can be accomplished by good materials management, substitution of less hazardous materials, and good laboratory procedures. Examples include:

•Implement a waste minimization policy and train all employees and students.
•Re-evaluate procedures to see if a less hazardous or non-hazardous reagent could be used.
•Centralize purchasing of chemicals through one person in the department or laboratory.
•Date chemical containers when received so that older ones will be used first.
•Keep MSDS’s for chemicals on file.
•Inventory chemicals and identify their location at least once a year.
•Perform laboratory experiments or demonstrations on a smaller or micro-scale.
•Update inventory when chemicals are purchased or used up.
•Purchase chemicals in the smallest quantities needed.
•Label all chemical containers to prevent the generation of unknowns.
•When considering a new procedure, obtain the chemicals needed from another lab or purchase small quantities initially.
•Consider the use of pre-weighed or pre-measured reagent packets where waste generation is high.
•Avoid the use of reagents containing arsenic, barium, cadmium, chromium, lead, mercury, selenium and silver.
•Eliminate the use of chromic acid cleaning solutions altogether. Use non-hazardous solutions such as Alconox and Pierce RBS35.
•Substitute red liquid (spirit-filled), digital, or thermocouple thermometers for mercury thermometers when it is feasible.
•Consider using detergent and hot water or citrus based products for cleaning parts instead of solvents.
•Use latex-based paints which are typically non-hazardous. Excess latex paints should be
recycled. Excess non-latex paints must be handled by EHS as a hazardous waste.
•Utilize vendors that will recycle used antifreeze. Some vendors will recycle the antifreeze on site so the antifreeze never leaves the site.
•The use of coal-fired boilers was discontinued so that no coal ash is being generated which eliminated the need for disposal.
•An evaporator was purchased and installed for disposal of those wastewaters from aquatic research that could not be discharged to the public sewerage system due to chemical contaminants from the studies This greatly reduces the amount of these wastes being disposed by evaporating the water component.
•Unused latex paints, if not reclaimed and excessed for auction, are treated to allow evaporation of the water component to reduce the quantity of materials disposed.

Recycling:
The third most desirable approach is recycling. When a waste material is used for another purpose, treated and reused in the same process, or reclaimed for another process, it is considered recycling. Examples include:
•When solvent is used for cleaning purposes, use contaminated solvent for initial cleaning and fresh solvent for final cleaning.
•Purchase compressed gas cylinders (including lecture bottles) only from manufacturers who will accept empty cylinders.
•Return excess pesticides to the distributor.
•Have a silver recovery unit installed in photography laboratories. The unit removes the silver from the fixer solution.
•Do not contaminate used oil with solvents because this prevents the oil from being recycled.
•Increase solvent reuse through the use of solvent redistillation.
•Recirculate unused or excess chemicals within the department.
•Collect metallic mercury for reclamation.
•The use of coal-fired boilers was discontinued so that coal ash is no longer being generated which eliminated the need for disposal.
•An evaporator was purchased and installed for disposal of those wastewaters from aquatic research that could not be discharged to the public sewerage system due to chemical contaminants from the studies. This greatly reduces the amount of these wastes being disposed by evaporating the water component.
•Unused latex paints, if not reclaimed and excessed for auction, are treated to allow evaporation of the water component to reduce the quantity of material to be disposed.

Chemical wastes are handled and disposed similarly whether or not they are classified as "Hazardous Wastes" with proper identification and handling regardless of their status. BSU has developed written plans and training programs for building maintenance activities, as well as those chemical and biological wastes from laboratories (including art studios). These programs are available for review on the EHS website at: http://cms.bsu.edu/about/administrativeoffices/riskmanagement/ehs/envhealth
All chemical wastes are accumulated in secure locations for routine pickup and disposal by our chemical waste vendor, Tradebe Environmental Service.

A web-based chemical inventory system, ChemTracker, is available for use by all departments, laboratories, trade shops, and building maintenance supervisors for tracking inventory and locations of chemicals and products. This system allows identification of surplus or unwanted materials.

Recycling programs have been instituted for RCRA "Universal Wastes" such as batteries and lamps. These are collected throughout campus and the shops, accumulated in our Central Stores Warehouse, and shipped off-site as needed for recycling by Veolia Environmental Services. A central drum storage area is maintained for accumulation of "Used Oil" from campus activities to supplement the used oil accumulation tanks serving the BSU Garage. These oils are routinely collected for recycling by Heritage Crystal Clean, LLC.

The framework for hazardous waste regulation was established in 1976 by the Federal Resource Conservation and Recovery Act (RCRA). RCRA was enacted by Congress to protect human health and the environment from improper management of hazardous waste. RCRA introduced the concept that the generator of a waste is responsible for proper waste management from “cradle-to-grave” (i.e. from the laboratory to the waste’s ultimate destruction). RCRA regulations may be found in 40 CFR Parts 260-279.
At Ball State University, all chemical waste disposal is managed by the Environmental Health and Safety (EHS) Office of Risk Management, Insurance and Safety. Hazardous chemicals are not allowed to be disposed of in the drains (without EHS and Muncie Sanitary District approval), in the trash, or by evaporation. All chemical wastes are required to be held in the generating location (this location may be either a “Satellite Accumulation Area” or a laboratory) for subsequent pick-up and disposal by EHS and the waste disposal vendor (currently Tradebe Pollution Control Industries, Inc).

There are specific regulatory requirements for the individuals, laboratories, or shops, that generate and accumulate chemical waste. These individuals must properly identify and label all hazardous wastes in their workplace. They must properly store and submit requests to the EHS for disposal of chemical wastes.
Laboraties (including art studios and educational technology shops) are to follow the BSU Laboratory Waste Management Plan, while shops and building maintenance personnel are to follow the BSU Waste Management Plan, both of which establish the criteria for identification, characterization, accumulation, labeling, containerizing, and handling chemical wastes.
Finally, they must minimize the amount of waste generated and recycle whenever possible. The purpose of this document is to assist labs, shops, and the various academic Departments with this regulatory compliance. Every lab and shop on campus is subject to unannounced inspections by both the Federal Environmental Protection Agency (EPA) and the Indiana Department of Environmental Management (IDEM). Lack of compliance can result in a Notice of Violation and, potentially, fines or other penalties.

The University maintains centralized hazardous waste accumulation areas or buildings on the north and south campuses for accumulation of wastes removed from shop or building maintenance activities or laboratories. These waste accumulation areas are maintained and inspected weekly by the EHS Office. In order to minimize illicit or improper disposal of chemical wastes, wastes are removed from shops or laboratories as requested through the EHS Office, and quarterly chemical waste pickups are scheduled and announced in advance to allow collection, neutralization, or bulking prior to removal by the waste vendor. This also allows the opportunity to identify "waste" or excess materials that are unused products (cleaning and maintenance supplies) to BSU Central Stores for subsequent sale at auction.

NA

See paragraphs above.

For the year ending December 31, 2014, Ball State recycled 34,937 lbs. of e-waste.

Ball State University contracts with Creative Recycling Systems, Inc. (CRS Holding of America - Florida) to recycle, reuse and process the university’s unwanted e-waste (e.g., PCs, laptops, monitors, printers, copiers, fax machines, scanners and networking equipment). CRS adheres to the industry’s highest environmental, health, and safety standards to eliminate workplace exposure to harmful toxic metal contamination. CRS uses the latest automated recycling technology, has ISO 14001 Certification for environmental management systems, and conducts audits of its end markets. CRS also holds OHSAS 18000 Occupational Health and Safety Management Systems Certification for managing safety in the work environment. CRS securely removes proprietary information and their data sanitization methods exceed U.S. Department of Defense specifications for security and electronic disposal. Their state-of-the art recycling equipment shreds and separates electronics into their original materials of plastics, steel, aluminum, precious metals, and glass. No water is used in the process. All air emissions through the system are collected and cleaned with 24 air filters and nine HEPA filters. No air is discharged outside of their facility.

Guiding Document: Ball State University Waste Management Guide