Indiana University Indianapolis
OP-21: Hazardous Waste Management

- WASTE MINIMIZATION COORDINATOR Each department shall assign a representative to serve as waste minimization coordinator(s) for specific areas, sections, laboratories, etc. within the department. Coordinators shall serve as resources for other departmental staff, facilitate implementation of waste minimization techniques within the area and may monitor and evaluate the effectiveness of the waste minimization program. - WASTE MINIMIZATION TECHNIQUES All University employees should objectively evaluate waste minimization opportunities in their work area. The following waste minimization techniques are to be considered when evaluating opportunities for minimizing the volumes of waste produced: - PURCHASING CONTROL - Order only the volumes of materials necessary to complete the desired activity or project. - Purchase smaller lots of materials on a more frequent basis. Purchase only volumes that can be utilized during a defined period of time (e.g. every 3 or 6 months) Utilize suppliers that can offer quick delivery of needed materials. - Purchase chemicals in smaller containers for easier management of unused chemicals unless it is known for certain that bulk volumes can be used expeditiously. - Be aware of any physical property of the material or chemical that may preclude long- term storage of the material. (e.g. peroxide formation). - Establish a centralized purchasing system within the department or area to monitor chemical purchase in an effort to avoid duplicate orders. - INVENTORY CONTROL - Attempt to redistribute unused materials and chemicals to other campus users. Objectively evaluate the potential use of chemicals offered for redistribution by other campus users. - Attempt to return unused, unopened materials to vendor for credit. - Ensure all containers containing chemicals, whether virgin or waste, whether in the original or secondary container, are labeled at all times. - OPERATIONAL CONTROLS - Periodically review each experimental or research protocol to assure that chemical usage is minimized. - Reduce chemical usage in experimentation through the use of microscale techniques whenever practical. - Evaluate less hazardous substitutes whenever feasible. Examples include but are not limited to: - Making double-sided photo copies when practical. - Promoting the use of recycled and recyclable materials such as non-glossy, non-colored paper stock. - Utilizing water-soluble, biodegradable scintillation fluids in place of solvent-based fluids. - Utilizing specialty, biodegradable glass cleaning detergents in place of sulfuric acid/chromic acid cleaners. - Utilizing a heat gun in place of chemical-based paint strippers. - Utilizing specimens preserved in less toxic preservatives in place of those preserved in formaldehyde-based preservatives where feasible. - Utilizing aqueous-based degreasers in place of chlorinated solvent or petroleum-based degreasers where feasible. - Avoiding wet chemistry techniques when practical. - Reclaim and reuse materials when feasible (e.g., utilizing spent solvent for initial gross cleaning step and utilizing fresh solvent only for the final rinse).(e.g. Having a naphtha- based parts washer serviced by a reputable service company that reclaims the spent degreaser). - Neutralizing corrosive wastes as a final step of an experiment or procedure. - Avoid mixing hazardous and non-hazardous wastes. - RECYCLING - Participating, to the fullest extent possible, in University-sponsored recycling programs. These programs include: - Paper recycling - Beverage can recycling - Cardboard box recycling - Nickel/Cadmium and larger lead/acid battery recycling - Fluorescent light tube recycling - NONCOMPLIANCE/PENALTIES The Department of Environmental Health and Safety may, at its discretion, refer costs incurred from the disposal of wastes generated by actions contrary to the principles of pollution prevention and waste minimization back to the producing or generating department. In the event the University is cited and fined by federal, state or local regulatory agencies for actions or activities contrary to waste minimization or pollution prevention regulations, the department(s) involved in the citation may be accountable for payment of the issued fine. Staff, faculty, students and guests of the University whose willful actions violate pollution prevention and waste minimization regulation may be held criminally and civilly liable for their actions. Any person affected by any such cost or fine assessment may appeal the assessment provided that a written request for such a review is submitted to the current Chairperson of the IUPUI Environmental Safety Committee within thirty (30) days of issuance of the assessment. Department of Environmental Health and Safety will provide a written, itemized assessment of the incurred penalties to the responsible department or party(ies) and a copy of the IUPUI Environmental Safety Committee Appeals Procedures. All appeals will be acted upon and reviewed in accordance with the established IUPUI Environmental Safety Committee appeals review procedures. In addition, the University may initiate disciplinary actions, up to and including dismissal, against any staff or faculty found to be in violation of this policy. http://ehs.iupui.edu/enviromental.asp?content=waste-minimization-and-pollution-policy

By means of an on-line request system (the Environmental Management Waste Disposal Form http://ehs.iupui.edu/waste-manifest.asp), generators of campus chemical wastes can readily request the collection of their waste material. Upon receipt of the on-line request, EHS staff visits the location and collects the waste material from the point of generation. The material is transported to a central processing area where the waste is further segregated and prepared for the off-site shipment to permitted hazardous waste treatment and disposal facilities for final disposal. For locations which have processes that produce consistent volumes of chemical wastes, EHS offers routine chemical wastes pick-ups without the submission of the Manifest form. EHS also offers a container exchange program these locations. The campus maintains a contract with a nationally-recognized hazardous waste contractor to provide for the disposal of collected chemical wastes. Waste which are amenable for recycling are directed towards recycling efforts. All other wastes are incinerated in a permitted hazardous waste incinerator in an effort to reduce the long-term liability of the wastes for the University and to provide for the highest degree of protection to the environment. The IUPUI hazardous waste operations are inspected on a regular basis by state and federal regulatory representatives. The University waste management practices are consistently found to be compliant with local, state and federal regulations. To date, the campus has never incurred a significant regulatory citation.