Waste Restrictions, Laws and Regulations
Anyone who generates chemical waste while conducting research at a University of Illinois at Urbana Champaign facility is responsible for disposing of it through the Division of Research Safety (DRS) chemical waste disposal program. It is illegal to dispose of toxic waste and hazardous waste in the trash or down the sanitary sewer (sink drain). The definitions of toxic waste and hazardous waste are provided below. The only chemical waste materials that do not have to go through the DRS for disposal are those identified in the section Liquid Non-Hazardous (Chemical) Waste Disposal as liquid, non-hazardous waste, which may be poured down the sanitary sewer (sink).
Chemical waste should never be sent off campus for disposal without prior authorization from DRS. The Campus Administrative Manual (CAM) states, "Campus personnel shall not initiate off-site shipments of chemical waste without first consulting with the DRS in order to ensure the waste is being transported and disposed of legally, and that the amount of waste disposed of is properly recorded on the University's annual Illinois Environmental Protection Agency report (see policy number V-B-4.1)."
All chemical waste that is placed in the trash, whether toxic, hazardous, or non-hazardous, is potentially regulated as Illinois Special Waste (see below) and therefore, should not be disposed of in the trash until a waste determination and non-special waste certification is made by DRS personnel.
In addition to the toxic and hazardous waste disposal restrictions and the Illinois Special Waste disposal restrictions, the Urbana-Champaign Sanitary District (UCSD) places restrictions on sanitary sewer disposal.
Instructions for completing a request for the collection of chemical waste through the DRS chemical waste disposal program are found in the section Procedures for Requesting Chemical Waste Disposal.
Definition of Toxic (Chemical) Waste
This waste guide defines a toxic waste as:
- Waste that has an oral-rat LD50 toxicity value lower than 500 mg/kg, or
- Waste that is a carcinogen, mutagen, teratogen, or is identified as a possible carcinogen, mutagen or teratogen (check the Safety Data Sheet for information).
If the waste is a mixture and there is uncertainty as to whether the mixture meets these criteria, dispose of it through the DRS chemical waste disposal program.
Definition of Hazardous (Chemical) Waste
Hazardous (chemical) waste must be disposed of through the DRS chemical waste disposal program.
The Environmental Protection Agency (EPA) has defined a hazardous waste as a "solid waste" or combination of solid wastes that may, because of its quantity, concentration, or chemical or infectious characteristics:
- Cause or significantly contribute to an increase in mortality or an increase in serious irreversible or incapacitating reversible illness;
- Pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of, or otherwise managed.
NOTE: The EPA defines "solid waste" as any solid, liquid, or gas that is disposed of, abandoned, or discarded.
How to Determine If a Chemical Waste is a Hazardous Waste
Wastes are defined as hazardous by the EPA if they exhibit one of four characteristics listed in 35 IAC Part 721 Subpart C [40 CFR Part 261 Subpart C] (characteristic wastes) or if they are specifically named on one of four lists of hazardous wastes located in 35 IAC Part 721 Subpart D [40 CFR Part 261 Subpart D] (F, K, P, U). The definitions of the characteristic hazards are listed below and are followed by the EPA lists of hazardous waste.
A waste is classified as a hazardous waste if it meets the definition for any of the characteristic hazards of ignitability, corrosivity, reactivity, or toxicity.
Waste that exhibits any of the following properties:
- A liquid (other than an aqueous solution containing less than 24% alcohol by volume) with a flashpoint less than 140°F (60°C);
- A non-liquid capable, under normal conditions, of causing fire through friction, absorption of moisture or spontaneous chemical changes and, when ignited, burns so vigorously and persistently that it creates a hazard;
- An ignitable compressed gas per Department of Transportation (DOT) regulations;
- An oxidizer per DOT regulations.
Waste that exhibits either of the following properties:
- An aqueous waste with a pH ≤ 2 or ≥ 12.5,
- A liquid that corrodes steel at a rate > ¼ inch per year at a temperature of 130°F (55°C).
Waste that exhibits any of the following properties:
- Normally unstable and readily undergoes violent change without detonating;
- Reacts violently with water;
- Forms potentially explosive mixtures with water;
- When mixed with water, generates toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health or the environment;
- A cyanide- or sulfide-bearing waste that, when exposed to pH conditions between 2 and 12.5, can generate toxic gases, vapors, or fumes in a quantity sufficient to present a danger to human health or the environment;
- Can detonate or generate and explosive reaction if it is subjected to a strong initiating source or is heated under confinement;
- Is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure;
- Is a forbidden explosive, or is a Division 1.1, 1.2 or 1.3 explosive as defined in 49 CFR 173.50 and 173.53.
Wastes that contain concentrations of any of the toxicity characteristic constituents greater than or equal to the applicable regulatory level as listed here.
A waste is also hazardous if it appears on one of the following four waste lists published by the EPA. These listed wastes are known to be harmful to human health and the environment when not managed properly, regardless of their concentrations.
- The F list (non-specific source wastes),
- The K list (source-specific wastes),
- The Plist and the U list (discarded commercial chemical products).
Waste Laws and Regulations
Federal, state, and local laws and regulations governing waste disposal are in place to protect human health and the environment. Violating these laws can result in a citation of the U of I or of the individual responsible for the violation and may cause harm to a person or the environment. Each person using chemicals in the workplace is responsible for being aware of the regulations. DRS can provide campus personnel with the information and resources they need to understand the regulations.
The following laws govern the disposal of chemical wastes:
Resource Conservation and Recovery Act (RCRA)
This 1976 law gave power to the EPA to establish regulations that govern the disposal of solid and hazardous waste. In Illinois, the Illinois EPA (IEPA) is authorized to enforce the regulations.
RCRA regulations that apply in Illinois can be found in the Illinois Administrative Code (IAC), Title 35, on the Illinois Pollution Control Board's website.
Comprehensive Environmental Responsibility, Compensation and Liability Act (CERCLA)
This 1980 law, also known as Superfund, gave power to the EPA to establish a liability system in which the generator of the waste is responsible for that material forever. This means that if a waste is disposed at a particular site and clean-up is needed in the future, the waste generator may be asked to cover part of the clean-up costs. This "cradle to grave" responsibility motivates waste generators to select a waste disposal company that:
- Provides the best technology for destroying the material (e.g., disposal technology that completely recycles or destroys the material is preferred to landfill);
- Has a good history of compliance (no outstanding EPA or Occupational Safety and Health Administration (OSHA) violations that would indicate a problem with handling the waste or the safety of the employees);
- Has adequate insurance and financial stability to cover costs if a clean-up is necessary.
Hazardous and Solid Wastes Amendments (HSWA)
These amendments were made to the original RCRA law. They prohibit land disposal (landfill) of untreated wastes and set standards by which all hazardous waste must be treated before disposing of it via wastewaters or via land disposal. To comply with HSWA and determine if the regulations will be met, generators should know how their disposal company will treat and dispose of their waste.
Illinois Special Waste
Illinois special waste includes hazardous waste, potentially infectious medical waste (PIMW), industrial process waste, and pollution control waste.
The IEPA considers university and college research as well as maintenance activities to be industrial processes. This means that all chemicals (hazardous or non-hazardous) to be disposed of from the U of I that cannot be disposed of down the sanitary sewer qualify as industrial process waste and are classified as Illinois Special Waste unless a non-special waste certification is made. DRS is responsible for making the non-special waste certification. Therefore, the IEPA requires all labs to send all chemicals, hazardous or non-hazardous, to DRS for proper disposal according to IEPA regulations.
Urbana-Champaign Sanitary District (UCSD) Restrictions for Sewer Disposal
The Urbana-Champaign Sanitary District wastewater discharge requirements that regulate the disposal of chemical waste down the sanitary sewer (sink drain) are listed in Article V of Ordinance 678. The ordinance may be found at http://www.u-csd.com/ordinances.htm. The DRS chemical waste disposal program complies with UCSD wastewater discharge requirements.
How the U of I Complies with These Laws
The goal of the DRS chemical waste disposal program is to simplify regulatory compliance for campus waste generators. To be sure they are complying with the regulations, they need to follow the guide as well as some additional guidelines:
- On all chemical waste containers, put clear labels, in English, indicating the contents. Use complete chemical names; abbreviations and chemical formulas are not permitted. Labeling should be done the first time waste is placed in a container (see the section Chemical Waste Collection and Storage for labeling requirements).
- Keep all chemical waste containers closed except when adding waste.
- Dispose of all chemical wastes through the chemical waste disposal program unless the chemical is a liquid and is identified in the section Disposal of Liquid Non-Hazardous Chemicals as a non-hazardous chemical that may be poured down the sanitary sewer (sink drain).
- Use chemical waste pickup request web portal to request a chemical waste pick up, and provide complete information about the wastes on the forms.
- Do not allow waste to accumulate; do not store more than 55 gallons of hazardous waste. Have waste regularly removed by DRS.
Last Update: 9/1/2016