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Hazardous Waste

  • Contractors shall assure that all hazardous chemicals or materials are handled and disposed of in accordance with federal and state regulations. For assistance, contact Environmental Health & Safety at 540-231-2982, 540-231-2510, 540-231-6321, or 540-231-3220.
    • The contractor shall not ship any “hazardous” or “universal” wastes without Environmental Health & Safety notification and approval. Proper paperwork with correct EPA identification numbers, addresses, and emergency contact information must be submitted. 
    • Where a hazardous waste disposal manifest is required by regulation, the contractor shall contact the  hazardous material program manager at 540-231-2982 to assure that manifesting, storage, and the proposed disposal method and site meet university requirements. 
    • Bills of Lading manifests, and LDRs must be signed by the hazardous material program manager, or designated representative, for all shipments of “hazardous” or “universal” waste, excluding asbestos. Refer to construction specifications for asbestos abatement for relative information.
  • Hazardous waste includes such items as:
    • Bulbs: The following procedure is to be used for 4- and 8-foot fluorescent bulbs, High-Density Discharge Bulbs (mercury bulbs), and U-tubes:
      • Bulbs should be placed in manufactured boxes.
      • When the first bulb is put in the box, a Universal Waste Label shall be placed on the outside of the box. Fill in contents and date.
      • When not actively putting bulbs in the box, the lid shall be closed and sealed.
      • Keep boxes inside, in a dry location, away from water.
      • Environmental Health & Safety will not approve the use of a fluorescent bulb crusher. 
    • Mercury-contaminated materials: All mercury-contaminated materials must be treated as “hazardous” waste and disposed of according to state and federal regulations. All sink traps located within research buildings are suspected to potentially be contaminated with some mercury. Anyone working on sink traps/drains on campus should wear appropriate personal protective equipment, such as eye protection, face shield for splash protection, gloves, and disposable coveralls, as applicable. Contact Environmental Health & Safety if these items are discovered. 
    • Ballasts: PCB and non-PCB ballasts shall be placed into UN-approved 55-gallon drums for disposal and shipped on a hazardous waste manifest. The lid on the drum shall be secured unless actively adding to the drum. There is a one-year time limit to dispose of the drum, beginning when the first ballast went into it.  
      • Ballasts are considered to be PCB ballasts if the label says it is, or the label does not say “No PCBs.”
      • Non-PCB ballasts will have “no PCBs” written on the ballast. These should be placed in a separate drum (UN-approved) for recycling. 
    • Broken Fluorescent/HIDs/U-Tubes that are unintentionally broken shall be placed into an UN-approved poly drum. These may be considered “hazardous” waste and should be treated as such due to the possible release of mercury vapors.
      • When not actively adding to the drum, the lid shall be on and secure.
      • The drum must be labeled “Broken Fluorescent Bulbs” and indicate the date the first bulb was placed in the drum.
      • There is a one-year time limit to dispose of the drum, beginning when the first ballast went into it.  
    • Lead Paint: Waste from scraping, grinding, or peeling is considered “hazardous” waste and shall be stored in an UN-approved drum with the lid securely fastened. This drum must be labeled as “Lead Paint Chips,” and locked in an area away from public access.
      • Core samples from suspected lead-based paint containing materials, such as walls, doors, and door casings, shall be taken prior to demolitions and sent for TCLP analysis. An Environmental Health & Safety representative shall be present for any sampling activities.
      • All sampling results shall be copied to Environmental Health & Safety for proper waste disposal determination. 
    • Miscellaneous chemicals: Any chemical found during demolition shall be handled as “hazardous” waste.  Examples include cylinders, bottles, cans with liquid, spill cleanup, etc.