Phone: (239) 590-1414
Fax: (239) 590-1033
FGCU shall take every precaution when handling hazardous chemicals and wastes to avoid hazards to human health and the environment.
The University will manage all waste in accordance with applicable regulations, with the goal of remaining a Very Small Quantity Generator of hazardous waste. To remain exempt from the full hazardous waste regulations that apply to generators of larger quantities, the University must comply with three basic waste management requirements:
Chapter 403.704 and 403.721, Florida Statutes, and Chapter 62-730, Florida Administrative Codes, Rules of the Department of Environmental Protection (DEP); Title 40, Code of Federal Regulations, Chapters 260 ~ 271, 273 and 279.
Violating these rules for transportation, treatment, storage, or disposal of hazardous wastes can result in cash fines and/or criminal imprisonment.
Link to the DEP Hazardous Waste booklet.
It shall be the responsibility of the departmental supervisor, instructor, and/or laboratory supervisor to ensure the proper management, and storage of all hazardous wastes generated by their respective department, laboratory, or research operation. The instructor, laboratory supervisor, or other departmental supervisor shall ensure that all hazardous wastes are identified, as defined below, at the point of generation and properly stored, labeled and dated.
Environmental Health and Safety:
Environmental Health and Safety collects hazardous wastes from generators in a timely manner; verifies appropriate identification and labeling information; provides appropriate temporary storage, and arranges for transportation and disposal of the waste in a safe and legal manner.
Emergency Notifications and Emergency Response:
State and Federal regulations 40 CFR 262.34(d)(4) require that the University develop and maintain an Emergency Response Plan to address spills, fires and other emergencies associated with hazardous waste.
An emergency contact shall be appointed who has authority to take appropriate action and is on call 24 hours per day. The Emergency contact for the University is the Director of Campus Police and Safety. In the case of a true emergency, the University Police should be called at 590-1911, or extension 1911 from any campus telephone. A list of other contacts and phone numbers in order of contact is listed at the end of this section.
Spills and releases of certain chemicals in excess of their Reportable Quantities (RQ) require immediate notification of the National Response Center and the State Warning Point. Environmental Health and Safety or other designee should be contacted immediately if a large amount of a substance has been spilled or released.
Spills of small quantities occur on occasion. In most cases these spills can and should be handled by FGCU laboratory or shop personnel in a safe manner. Spilled materials and absorbents must be handled as a hazardous waste if applicable criteria are met as defined above under definitions under Listed Hazardous Waste.
Spills that cannot be handled safely by laboratory or shop personnel should be referred to Environmental Health and Safety who will contact the proper agencies.
Spills of large quantities, extremely hazardous substances, or any spill that is an immediate threat to personal safety or the environment shall be handled through the Emergency Notification System. That system shall be activated as follows:
List of Emergency Contacts:
Campus Emergency Number: extension 1911
Inform the emergency contact of the exact location, situation, chemicals and quantities involved.
Steven Moore, Director, University Policy and Safety, Office No. 239-590-1919
Rhonda Holtzclaw, Director, Environmental Health & Safety, Office No. 239-590-1037
As used in this policy, the following terms shall have the assigned meaning:
Solid Waste - For purposes of this program, a solid waste may be any solid, liquid, or containerized gas, which no longer has an appropriate and legal intended use for the University. For a legal definition, refer to the Federal Solid Waste Disposal Act (SWDA).
Hazardous Waste - Any solid waste (as defined by the Federal Solid Waste Disposal Act) which possess hazardous characteristics, such as ignitability, corrosiveness, reactivity, or toxic characteristics (TCLP) as defined by the Code of Federal Regulations (40 CFR 261~262). Please be aware that management practices often cause wastes to deviate from their original forms. Know your source, generation activity, and types of waste formed to assist with determinations.
"Listed Hazardous Waste"- Any chemical or product as listed in 40 CFR 261.31 - 261.33. Listed wastes are divided into four categories, according to their origin, often referred to as "P", "F", "K", and "U" wastes. Listed wastes are always hazardous regardless of their chemical composition-no testing is required to identify them.
Flammable/Ignitability Characteristic Waste - Any waste with a flash point of less than 140°F (60°C) that can create fires and includes liquids or friction sensitive substances under certain conditions. (Common flammable materials include acetone, toluene, methanol, ethers, isopropanol, duplicating fluids, rubber cement glue, paint thinner or mineral spirits, oil based paints and stains, rubbing alcohol, nail polish remover, many aerosol containers such as spray paints and adhesives, and solvent-soaked rags.)
Corrosive Characteristic Waste - Any type of waste which has a pH of less than 2 (acidic) or greater than 12.5 (basic), or corrodes steel at a rate specified by EPA. (Corrosive wastes may include sulfuric acid, hydrochloric acid (muriatic acid), sodium hydroxide, HTH, chlorine, lye, lime, battery acid, drain openers (Drano) and other products that contain strong acids or bases, which include many cleaning products.)
Reactive Characteristic Waste - Any waste which is unstable, can readily undergo a violent change, reacts violently with water, is capable of detonation or explosive reaction, or contains sulfides or cyanides that have the potential for generating toxic fumes or vapors. (Examples of reactive wastes include sodium and potassium metal, dry picric acid, compounds that form explosive peroxides, cyanide plating operations and anything pressurized i.e. propane tanks, aerosol cans, flares, fireworks, ammunition, etc.)
Toxic Characteristic Waste (or TCLP) - Any waste identified through an EPA method (Toxic Characteristic Leachate Procedure) that has the potential of forming a leachate that may cause groundwater contamination. If any product contains a constituent greater than a specified concentration as determined by the TCLP, it is a hazardous waste. (Examples are products that contain benzene (many petroleum based products), cadmium (nickel cadmium batteries), lead (lead batteries and lead paints), silver (spent photofixer, silver nitrate), chromium, mercury (mercury batteries, fluorescent light tubes), rat poison, weed killers, and antifreeze, etc.)
Mixtures - A mixture of a listed waste and any other waste will remain regulated as a listed waste regardless of the percentage of the listed waste in the mixture. A mixture of a characteristic hazardous waste and any other waste will only be considered hazardous if the resultant mixture exhibits a hazardous waste characteristic. Even if resultant mixtures do not exhibit a characteristic of hazardous waste, they may still require further treatment before proper disposal.
Derived-From (By-Product) Wastes - A result of treatment, storage, or even proper disposal, residues of hazardous waste can be generated from the original hazardous waste. The hazardous status of residue, such as a sludge, ash, or filter, depends on the type of hazardous waste from which it is derived. Just as with mixtures of hazardous waste, if a residue is derived from a listed hazardous waste, or exhibits a characteristic of hazardous waste, then it is regulated under RCRA as a hazardous waste.
Contaminated Media and Debris - Environmental media (i.e. soil or ground water) contaminated by a listed hazardous waste must be managed as that listed waste regardless of the concentration of waste they contain. Media and debris contaminated with a characteristic hazardous waste must be managed as a characteristic hazardous waste only if they exhibit a hazardous waste characteristic.
Storage Area - This is a regulated area in which all containers must be labeled, dated, and inspected weekly, in which hazardous wastes are temporarily stored while awaiting transport to a licensed disposal facility. These hazardous waste storage areas have limits which are defined by the facility's current status as follows: VSQG generator storage limits are nearly indefinite (provided hazardous waste storage is never more than 1000 kg), SQG generator up to 180 days, and LQG generator up to 90 days.
Satellite Accumulation Area - A temporary storage and collection area of hazardous waste, near the point of generation, which is under direct control of the person or operator generating the waste. Waste in an approved satellite accumulation area is exempt from the 180-day time limit if other requirements are met. (NOTE: Subject to considerable interpretation and constraints by various regulators).
Very Small Quantity Generator (VSQG) - The Code of Federal Regulations (CFR) Title 40, Section 261.5 defines a VSQG as a generator of less than 100 kilograms per calendar month (100kg/mo) of hazardous wastes or 1kilogram per calendar month (1kg/mo) of acutely hazardous waste. At no time can a VSQG have greater than 1000 kg of hazardous waste in storage.
Small-Quantity Generator (SQG) - A generator of hazardous wastes whom generates between 100 kg and 1000 kg of waste (or less than 1 kg of acutely hazardous waste) in a calendar month. At no time can a SQG have greater than 6000 kg of hazardous waste in storage.
Large-Quantity Generator (LQG) - A generator of hazardous waste who generates greater than 1000 kg (or greater than 1 kg of acutely hazardous waste) in a calendar month.
Procedures for Departments Generating Hazardous Wastes:
Do's and Don'ts:
Procedures for the Scientific Stores- Teaching Labs:
Procedures for Environmental Health and Safety (EH&S):
Waste minimization is federally mandated for hazardous waste generators. Each department of Florida Gulf Coast University shall take reasonable and appropriate actions to minimize the amount of hazardous waste generated by their operations, teaching, and research. Waste minimization techniques shall include, but are not limited to:
It is important that waste management be an integral part of all your operating procedures. Implementing 'EcoPurchasing' means considering attributes such as: recycled contents, toxicity, reusability, durability, and repairability, before you buy a product.
All hazardous chemical waste must be identified at the source. A material does not become waste until it can no longer be used for its intended purpose. The collection container must be suitable and be able to be sealed or closed tightly. All containers must be labeled "Hazardous Waste" and list their solvents and characteristic components.
FGCU will use State and Federal regulations 40 CFR 262.34(a)(4) and 40 CFR 265.16 as guides for the required training that will be provided to all individuals who generate hazardous waste.
Training shall be provided to all faculty, staff, and OPS student assistants performing activities, which generate or potentially generate a hazardous waste.
Training shall be provided by supervisors of areas in which hazardous waste is generated.
Hazardous waste training provided by other facilities or recognized organizations (e.g. University of Florida TREEO Center, Georgia Tech Continuing Education) will be evaluated on a case by case basis to determine if required topics have been covered. However, in all cases, individuals must be trained in specific procedures used by the University.
Training topics to be covered will include, at a minimum, the following:
Examples of Hazardous Waste: (Including special waste that must be separated from normal trash)
If you are unsure whether or not waste material may be classified as a hazardous waste, please contact Environmental Health and Safety.
Routine Contacts for Hazardous Waste Collection or Information:
Rhonda Holtzclaw, Director, Environmental Health and Safety, 590-1037; email@example.com
Beth McMasters, CSP, EH&S Specialist; 239-590-1036; firstname.lastname@example.org
Additional Information: Additional information may be obtained from the following sources:
Pollution Prevention and Waste Minimization in Laboratories; Reinhardt, Peter, et al; CRC Press Lewis Publishers; Boca Raton, FL; (1996)
Rev. 1/2017 R. Holtzclaw