Chemical Safety

Chapter 8 Procedures for Requesting Chemical Waste Disposal

The procedures for requesting chemical waste disposal have been developed to comply with the regulations of the Illinois Environmental Protection Agency (EPA) and the U. S. EPA. The EPA regulations require the Division of Research Safety (DRS) to receive a complete and accurate inventory of the chemical wastes to be recycled or disposed of from the campus waste generator prior to the collection of the chemical waste. This provides DRS with the opportunity to review the inventory to evaluate any potential hazards, incompatibilities and also to assign the appropriate EPA codes to each waste. If inaccurate information is provided to DRS, the safety of the DRS personnel picking up the waste is endangered as well as those who manage your waste prior to its final disposal. Inaccurate information also puts UIUC at risk for a lawsuit if an accident should occur in the transportation of chemical waste off-campus or at the ultimate disposal facility because a waste container was mislabeled or misidentified.

In addition, the EPA requires DRS to track each waste container from the location where it is produced until it leaves campus for recycling or disposal.

The DRS staff will enter the inventory into the waste tracking system; print a label for each container of waste; and then mail these labels back to the generator along with the date DRS will arrive to collect the properly labeled containers.

Campus waste generators should receive the ChemTrak labels and a notice when the waste will be collected within two weeks of mailing DRS the properly completed pickup request form(s).

A note about DEA controlled substances
DRS does not hold a DEA (Drug Enforcement Agency) registration and therefore cannot pick up any DEA controlled substance. Please refer to the DEA Controlled Substance Guidance Document or Chapter 6 for additional information on the disposal of DEA Controlled Substances.

Use the correct ChemTrak form to request a pickup
Follow the steps below to determine the correct chemical waste pickup request (ChemTrak) form to use for requesting chemical waste collection. Please note: using the wrong ChemTrak form will delay the disposal of your waste. Click on the form name to download the appropriate form. Please follow the instructions on the second page of a given form when completing the request form. ChemTrak forms are found at the end of this chapter.

• Step 1. Is the waste identified (not an unknown)?
  Yes: Proceed to Step 2.
  No: Characterize the waste using the screening procedures for unlabeled chemicals as documented in Chapter 5. Then proceed to Step 7.
  
  
• Step 2. Is the waste a mixture?
  Yes: Proceed to Step 3.
  No: Proceed to Step 4.
  
  
• Step 3. Is the mixture listed on the Generic Mixtures List (Appendix B) or has it previously been assigned a “UI #”?
  Yes: Proceed to Step 7.
  No: Fill out form CWM-TRK-03: “Request to Establish a New Waste Chemical Mixture.” A CWM-TRK-01 form will also need to be submitted to request a collection of a new mixture. (CWM-TRK-03 describes the mixture's chemical composition; CWM-TRK-01 describes the size of containers, amount in the containers, etc.)
  
  
• Step 4. Is the waste a small container (original size less than 100 grams or milliliters)?
  Yes: Create an inventory list of all the bottles and fill out form CWM-TRK-04: “Request for Pickup of Small Containers of Chemicals.” The inventory must be sent with the form to be processed.
  No: Proceed to Step 5.
  
  
• Step 5. Is the waste a multi-hazard waste (radioactive and/ or biological hazards present in addition to chemical)?
  Yes: See the multi-hazard wastes instructions in Chapter 7.
  No: Proceed to Step 6.
  
  
• Step 6. Is the waste on the Individual Chemicals and Products List (formerly Master Chemical List) (Appendix A)?
  Yes: Proceed to Step 7.
  No: Fill out form CWM-TRK-02: “Request for Pickup of Chemical Waste Without Assigned University ID Numbers.”
  
  
• Step 7. Fill out form CWM-TRK-01: “Request for Pickup of Chemical Waste.”

EPA regulations allow for two methods of verifying waste content: chemical analysis and generator knowledge. As it would be cost prohibitive to analyze every chemical waste container produced at UIUC, the campus has negotiated with the Illinois EPA to allow the use of generator knowledge. The signature required on all ChemTrak forms demonstrates to the Illinois EPA that a responsible person has identified the contents of each container. This signature is only used for the internal (on campus) transfer of chemicals; when waste must be shipped off-campus, a member of the DRS staff must be notified so they can provide the required signature. Chemical waste should never be sent off-campus without notifying DRS in advance . The Campus Administrative Manual (CAM) states, “Campus personnel shall not initiate off-site shipments of chemical waste without first consulting with the Chemical Safety Section 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).”

Using the Individual Chemicals and Products List (formerly Master Chemical List) (for single chemicals)
DRS has created a database called the Individual Chemicals and Products List (formerly Master Chemical List) for chemical waste management (Appendix A ). It contains data on over 12,000 individual chemicals arranged alphabetically. This list provides guidance to the DRS staff for handling waste chemicals. As a condition of the permit DRS has with the Illinois EPA, the chemical name and its related information, such as physical hazard, transportation requirements, etc., must be included in the database before accepting waste at the Special Materials Storage Facility (SMSF).

To use the Individual Chemicals and Products List (formerly Master Chemical List), look up the name of your chemical, then list the “UI#” and chemical name on the appropriate ChemTrak form. The list is in alphabetical order.

If you do not find your chemical in the Individual Chemicals and Products List (formerly Master Chemical List), you must complete form CWM-TRK-02: “Request to Pickup a Chemical Waste without a UI#.” A unique UI# will be assigned to your chemical. All subsequent requests for a pickup of the same chemical should be made on form CWM-TRK-01: “Request for Pickup of Chemical Waste.”

Using the Generic Mixtures List (for chemical waste mixtures)
If the waste you wish to dispose of is a mixture, the mixture must have a UI#. A list of generic mixtures appears in Appendix B. To find a mixture on the list, alphabetize the chemicals present in your mixture and look for a matching set of chemicals.

If you do not find your mixture, or it falls into one of the exceptions listed in the instructions of Appendix B, you must complete form CWM-TRK-03: “Request to Establish a New Waste Chemical Mixture.” A unique “UI#” will be assigned to your mixture. All subsequent requests for pickup of the same mixture should be made on form CWM-TRK-01: "Request for Pickup of Chemical Waste."

Lecture bottle gases
If the waste you wish to dispose of is a lecture bottle (partially full or empty), check the list of gases in Appendix C to determine the appropriate UI#. Since lecture bottles are a relatively new waste stream being accepted by DRS for disposal, the list is currently not long. If you do not find the specific gas you have on the list, submit a pickup request on form CWM-TRK-02.

Small containers (original size less than 100 grams or milliliters)
To request disposal of containers that ORIGINALLY contained LESS than 100 grams or milliliters (even if still full), use form CWM-TRK-04: “Request for Pickup of Small Containers of Chemicals” and attach an inventory of the containers to the form. The CWM-TRK-04 form will not be processed without an attached inventory.

If there are less than 5 small containers in your inventory - do not use the CWM-TRK-04 form, instead use the CWM-TRK-01 form. The CWM-TRK-01 should also be used for any container of mercury or mercury compounds.

Containers greater than 100 grams or milliliters must be handled in accordance with the normal chemical waste disposal procedures, even if there is very little material left in the container. Containers with residues still may be regulated as hazardous waste, if the chemical is listed on the EPA's Acute Discarded Waste List or the Toxic Discarded Waste List. See Chapter 9 for the decontamination of empty container procedures.

Labeling wastes (with DRS Labels)
Using the information from the ChemTrak forms, the DRS staff will generate labels for each container and a laboratory waste manifest. The labels will be sent back to the generator via campus mail with a letter indicating the scheduled collection date. The generator must then apply the labels to the appropriate container. (The order of the labels will be exactly the same as your ChemTrak request - so keeping your containers in the order listed until your labels arrive will make applying them easier.) Do not apply the ChemTrak label in such a manner that the original container label is obscured, if possible. Labels should be applied with the text reading horizontal and the barcode oriented vertically. Containers that do not have a unique ChemTrak label will not be collected.

DRS collection of waste from campus
Generally, your waste collection will be within a week from the date we send the ChemTrak labels to you.

If possible, wastes will be collected in the morning (9 a.m.-12 p.m.) of the designated pickup day. However, the DRS staff may continue pickups in the afternoon if there are too many to complete in the morning. Please make the area where your waste is stored accessible during those times and have a responsible person available during pickup. The expected collection date will be enclosed with the ChemTrak labels sent through campus mail.

Two DRS staff members will pick up the prepared waste for disposal. They will confirm that all the containers are labeled properly and check off the items on a preprinted laboratory waste manifest. Secondary containment is used by DRS for the containers so there is no need to box them prior to pick up, except for silica gel as described in Chapter 6. Chemical waste that is stored in boxes will only prolong the inspection process.

Containers that have not been properly prepared for pickup will not be taken. Containers that do not meet the chemical waste container guidelines of Chapter 6 will also not be accepted.

RAL Weekly Jerrican Pickup Program
The RAL Weekly Jerrican Pickup Program is a weekly solvent waste collection for laboratories in the Chemistry department at UIUC that generate oil, non-halogenated and halogenated solvent waste. The weekly collection is for Jerricans only, and only for laboratories in the Chemistry department at UIUC that generate more than one Jerrican of solvent waste every two weeks. The regular ChemTrak waste pick up program (using CWM-TRK-01 and CWM-TRK-03 forms) must be used for other waste containers and for labs that generate less than one Jerrican of solvent waste every two weeks. Jerricans will be returned as long as the Jerrican is in good condition. See Appendix E for further information.

Forms required for waste pickups
Please use the most current forms available when submitting a waste disposal request. The ChemTrak forms are available for downloading from the DRS website:

CWM-TRK-01 - For chemicals and mixtures that already have a UI#:
Word (fill-in form) or PDF Format.
CWM-TRK-02 - For chemicals that do not have a UI#:
Word (fill-in form) or PDF Format.
CWM-TRK-03 - For mixtures that do not have a UI#:
Word (fill-in form) or PDF Format.
CWM-TRK-04 - For small containers (containers must be less than 100ml or 100g in size):
Word (fill-in form) or PDF Format.
CWM-TRK-05 - For RAL Weekly Jerrican Pickup:
Word (fill-in form) or PDF Format.