University of Kansas
OP-25: Hazardous Waste Management

The University of Kansas has adopted hazardous materials waste management procedures for the proper management of hazardous materials generated by the University as an integral part of the University’s Environmental Health & Safety Management Program. University policy requires that all materials being used by a laboratory or laboratory-related unit to be disposed in accordance with the Hazardous Materials Waste Management Program. Users shall keep the generation of hazardous materials at a level “as low as reasonably achievable”, minimize the proportion of unavoidable hazardous materials waste, recycle or reclaim hazardous materials either in the lab or through the services of Environmental Health & Safety, segregate hazardous materials waste streams to make further management activities more feasible and economical, and where allowed by EHS and regulations, treat waste to reduce the volume and degree of hazard. All faculty, staff, and students are required to be aware of their responsibilities identified in the manual. Failure to comply is disciplinable; regulatory non-compliance may be a violation of State and/or Federal Laws; a department or school of the University shall be held liable by the Provost Office for any fee or penalty imposed by a regulatory agency upon the campus for improper storage, labeling or disposal of hazardous waste to the extent that the fee or penalty imposed arises out of the activities of the department or school.

Users are required to collect all hazardous material wastes and residues per established procedures and contact the Department of Environmental Health & Safety to have the materials removed. EHS then disposes of hazardous wastes through a contracted, 3rd party, permitted TSDF. Users are prohibited from placing empty “potentially contaminated” hazardous materials containers into normal trash baskets, placing “Sharps” into normal trash receptacles unless packaged according to the requirements, and disposing of classified materials into the sanitary sewer system. Special disposal is required for any materials which meet the definition of a hazardous chemical as defined in the OSHA Hazard Communication Standard (29 CFR 1910.1200), any materials which exhibit the characteristics of hazardous waste as identified in 40 CFR 261 Subpart C or are listed as hazardous waste in 40 CFR 261 Subpart D under the Federal Resource Conservation and Recovery Act, any materials meeting the definition of a biohazard, any materials meeting the definition of a radioactive material, any materials meeting the definition of Laser/Associated Waste or any other materials which are believed by the User/Supervisor to pose some danger to human health, safety, or the environment.

The University has not had any significant releases in the past 3 years. Two events were reported to the Kansas Department of Health & Environment (KDHE) in that period: 1) Diesel fuel spill: Approximately 80 gallons of fuel were spilled on the ground. The Environment, Heath & Safety staff and Facilities Services staff were deployed to cleanup spilled material. A minor amount did make its way to adjacent ditch which leads to a creek due to adverse weather (rain) during incident. Oil absorbent booms were placed at multiple locations in the ditch and creek to help prevent and remove fuel sheen. 2) Fluorescent Lamps: Universal Waste spent fluorescent lamps were placed in the scrap metal recycling dumpster. EHS staff removed all bulbs (intact and broken) from the dumpster, which generated about 1 55-gallon drum of debris.

The Environmental Health and Safety Program has operated as a centralized, campus-wide surplus chemical inventory and redistribution point for fifteen years. The program maintains a current listing of available materials on their website for labs to request them to be re-distributed to them for use. Users are advised to return unused chemicals to unit stockrooms or make them available for others to use. Users are also encouraged to check with all campus departmental stockrooms for available materials before purchasing new items. EHS routinely picks up chemicals from across campus and attempts to redistribute them at no cost. Most of the chemicals eligible for redistribution are free and available on a first come, first served basis.

KU Information Technology provides a way for obsolete, unused or unwanted electronic equipment or data storage devices to be securely recycled. All sensitive and proprietary university or customer information is completely removed from computer and thumb drives before disposing of them in an environmentally safe manner.

All eWaste is collected staff and brought to the Computer Center warehouse for sorting and hard drives and media are separated for degaussing. From there the hard drives are sent to a scrap metal recycling center for shredding. Media (such as CDs and floppy discs) are sent to Cintas for shredding. All other items are palletized and wrapped for transport to Asset Life Cycle for recycling/disposal. eWaste staff uses dollies/carts for removing recyclables from the premises. Any heavy items are removed using 2-3 staff. Pallet jack and forklift is used for moving pallets. Gloves are used as needed. CRTs are stacked on pallets and wrapped to ensure safety during transport.