Virginia Commonwealth University
OP-20: Hazardous Waste Management

Laboratories are responsible for only 0.1-1.0% of the total hazardous waste that is generated in the United States according to EPA estimates, but this comparatively low volume of waste is characterized by an enormously greater chemical diversity than industrial waste streams. In a university and hospital system such as VCU/VCU Health Systems, chemicals are used in operations of diverse magnitude and complexity and thus amounts and varieties of the wastes vary accordingly. As a generator of hazardous waste, the VCU community has both moral and legal obligations to ensure hazardous waste is handled and disposed of in ways that pose minimal potential harm to health and the environment. Since most lab work which uses chemicals eventually produces hazardous waste, generators the VCU/VCU Health system community needs to ensure that the waste is handled, transported, and disposed of in ways that minimize both short term and long-term harm to health and the environment and complies with state and federal regulations. For these reasons, a hazardous waste management program has been established by EHS-SRM to fulfill the following objectives:
a. Protecting the environment and preserving the health and safety of employees, students, patients, visitors, and the surrounding community.
b. Complying with applicable regulations.
c. Establishing laboratory practices for reducing types and quantities of hazardous wastes.
d. Educating the VCU community in the proper handling and disposal of hazardous wastes.
e. Demonstrate outstanding environmental stewardship to the surrounding community.

This hazardous waste management program includes the following protocol for waste minimization:

Waste Minimization
• Waste minimization is a fundamental method of reducing escalating disposal costs and burden to the environment. There are a number of ways in which those who generate chemical wastes can help in the chemical waste minimization effort.
• Some useful waste minimization practices include the following:

•  Reduce the amount of chemicalsordered to decrease disposal of expired chemicals.
  
  
  • One important aspect of a chemical waste management program is implementing the “less is better” concept. This concept is directed at buying only quantities of materials that will be readily consumed.
  
  
  

• Consolidate compatible chemical wastes.
  
  
  • Waste materials should be consolidated to the extent possible to reduce the number of containers to be disposed of.
    • CAUTION: Only chemicals that are compatible with each other may be consolidated into one container.
  
  
  

• Do not abandon chemicals in laboratories dispose of chemical waste as needed.
  
  
  • University guidelines and procedures dictate that departing researchers are responsible for coordinating with their departments to remove and/or recycle any materials remaining in the laboratory
  
  
  

• Consult EHS if a new research project requires unusual or especially hazardous chemicals.
  
  
  • In order to ensure appropriate disposal of hazardous chemicals, EHS should conduct a review of these chemicals and how they may impact disposal procedures. Some chemicals require special disposal precautions and in order to minimize these wastes, a consultation with EHS would be beneficial. 
  
  
  

Protocols have been developed which instruct, in a step-by-step process, how chemical waste is to be disposed of on both campuses of the university.

The VCU Environmentall Health and Safety Hazardous Waste managment program applies to all laboratory personnel, principal investigators, core facilities, and any other departments (art studios, Facilities
shops, etc.) that produce chemical or hazardous waste as a function of routine work duties. Anyone who produces hazardous waste is called a generator and the place (room, lab, etc.) where this hazardous waste is generated is called the “point of generation". The responsibility to ensure that all hazardous wastes are adequately identified before being offered to EHS-SRM for disposal rests with the generator (PI/Manager/User).Safety and Risk Management (EHS-SRM) administers this program to handle and dispose of waste according to regulatory requirements, to protect student and employee health, and to protect the environment. Hazardous waste disposal methods employed by EHS-SRM meet or exceed regulatory requirements established by the Virginia Department of Environmental Quality (DEQ) and the U.S. Environmental Protection Agency (EPA).

There have not been in the last 3 years.

VCU Safety and Risk Management performs routine and unannounced inspections to determine compliance with health and safety policies and procedures. This includes reviewing and confirming Lab Manager inventory to encourage the reuse or redistribution of unused or unneeded laboratory chemicals.

Departments Surplus e-waste items. The Physical Plant Dept. of General Services pick-ups the electronics items for delivery to PPD-Surplus Property Warehouse. Depending upon the condition of the electronic equipment it is either sold for reuse through the VCU Gov Deals Program or the materials are recycled. E-waste generated by students can be donated to the VCU Free Store for reuse by other students.