Hazardous Materials and Waste Management              UPPS No. 04.05.06

Issue No. 7
Effective Date: 07/10/2008
Review: October 1 E3Y

Attachments I, II, III, IV

 

01.       POLICY STATEMENTS

01.01  Hazardous materials and hazardous waste can pose a threat to students, employees, visitors and the environment if managed improperly. To minimize the possibility of such threats, appropriate practices and procedures are essential. The purpose of this policy is to establish a hazardous materials and hazardous waste management program.

01.02  Environmental Health, Safety and Risk Management (EHS&RM) has primary responsibility for the University’s hazardous materials and waste management program. The Director of EHS&RM (or designee) is authorized to take action to assure compliance with applicable regulations and policies and to minimize physical and environmental threats on university property (whether owned or leased). This includes having delegated authority from the President to order the cessation of activities or operations, as needed, to administer this policy.

01.03  The University is registered as a hazardous waste generator by the Environmental Protection Agency (EPA) and the Texas Commission for Environmental Quality (TCEQ). Procedures outlined in this UPPS are designed to promote the protection of health and the environment by compliance with applicable regulations.

01.04  Hazardous materials and waste that are not properly packaged and labeled may not be transported.  

01.05  University employees who transport regulated quantities of hazardous materials or hazardous waste are required to maintain a valid Texas commercial driver’s license.

01.06  Non-compliance with hazardous materials and hazardous waste regulations can result in violations being charged against the University by regulatory agencies, as well as the assessment of fines and other costs.

Disciplinary action may be taken against university personnel or students who do not comply with this policy and associated regulations.

02.       DEFINITIONS

02.01  Hazardous Materials – any materials that may present a health or physical hazard to individuals when handled in the normal course of their work.

02.02  Hazardous waste – any substance identified or listed as a hazardous waste by the administrator of the United States Environmental Protection Agency (EPA), 40 CFR 261, Identification and Listing of Hazardous Waste. 

02.03  Biohazard waste – any contaminated waste material that is capable of transmitting disease to workers or handlers.

02.04  Departmental Hazardous Waste Generator – any department or activity associated with the University with processes or experiments resulting in a hazardous waste.

02.05  Management Program – related to this policy, management encompasses the functions of acquisition and use of hazardous materials and disposal of hazardous waste.

02.06  University Hazardous Waste Management Unit – a university facility that is registered with TCEQ for storage of hazardous waste prior to shipment for disposal.

02.07  Spill Prevention Plan – a written policy that includes emergency procedures for spill prevention and clean up of hazardous materials or hazardous waste. 

02.08  Chemical Hygiene Plan – a written program developed and implemented by the department which sets forth procedures, equipment, personal protective equipment, and work practice that 1) are capable of protecting employees from the health hazards presented by hazardous chemicals used in that particular work place and 2) meet Occupational Safety and Health Administration (OSHA) requirements.

02.09  Departmental Hazardous Materials Coordinator – an individual who is designated by the academic department chair or account manager to act as liaison with the EHS&RM for proper management of hazardous materials used or waste generated by their department.

03.       HAZARDOUS MATERIALS MANAGEMENT PROCEDURES

03.01  Hazardous materials or materials which may become hazardous waste must be handled in such a way as to protect that health and safety of university students, personnel, property, and the environment.  (See also UPPS No. 04.05.05, Hazard Communication Program.)

03.02  Purchase of Hazardous Material

a.   Hazardous materials should be purchased in a manner that minimizes the quantity of hazardous materials in the work area and hazardous waste generated.

b.   Because of federal and state regulations regarding the procurement of hazardous materials, all such purchases must be via an approved university purchase order. Use of alternate approved university procurement methods, including procurement cards (P-cards) to purchase hazardous materials is strictly prohibited.

c.   Departments should coordinate their hazardous material purchases with other university departments, to minimize individual departmental quantities ordered and stored while realizing the cost saving from volume purchases.

03.03  Hazardous materials must be stored in a safe and secure area that cannot be accessed by unauthorized individuals. 

03.04  Appropriate supervision and training is required for all situations in which hazardous materials are utilized at the University. (See also UPPS No. 04.05.05, Hazard Communication Program).

04.       HAZARDOUS WASTE DISPOSAL PROCEDURES

04.01  Management of hazardous waste for disposal is strictly limited to Environmental Health, Safety and Risk Management. University departments or areas that handle hazardous materials and hazardous waste are not authorized to undertake disposal procedures without contacting Environmental Health, Safety and Risk Management.

04.02  The disposal of hazardous waste by hazardous waste generators is strictly controlled by local, state and federal regulations. All university departments, activities, and personnel shall be familiar with and comply with applicable regulations regarding the safe handling, labeling, and disposal of hazardous waste. These include:

a.   31 TAC Chapter 335, Industrial Solid Waste, and Municipal Hazardous Waste Regulations; TCEQ. http://www.tceq.state.tx.us/index.html.

b.   40 CFR, Parts 260 through 265, Identification and Listing of Hazardous Waste; EPA. www.epa.gov

c.   29 CFR, Part 1910; Occupational Safety and Health Standards Act (OSHA). www.osha.gov

d.   UPPS No. 04.05.05, Hazard Communication Program.

e.   City of San Marcos Wastewater Pre-treatment Ordinance. www.ci.san-marcos.tx.us

04.03  Biohazard waste generated at the University is to be collected in approved biohazard bags or containers. Biohazard waste requires special treatment on site at the generation point, when feasible. If treatment cannot be performed on site, EHS&RM will assist departmental generators in securing an appropriate means of disposal.

04.04  Timeframe for disposition of hazardous waste – removal of hazardous waste from a university department or area should be accomplished within 72 hours of being characterized as hazardous waste. Departments or areas that have hazardous materials or materials which may become hazardous waste must contact EHS&RM to arrange for disposal. Generally, the items will be moved to a designated hazardous waste unit.

04.05  Hazardous waste will be stored in a designated university hazardous waste management unit where an authorized contractor can remove the waste for disposal. Alternatively, EHS&RM may arrange for the authorized contractor to pick up hazardous waste directly from a university department or activity. Hazardous waste must be properly characterized prior to removal from the generating department or area.

04.06  Departmental hazardous waste generators must continually monitor the hazardous waste being generated in their area and coordinate with EHS&RM to have the waste removed as it is generated.

05.       RESPONSIBILITIES

05.01  Environmental Health, Safety and Risk Management (EHS&RM) has primary responsibility for the following duties associated with the management program for hazardous materials and waste:         

a.   Act as the custodian of required regulatory records for EPA, Department of Transportation (DOT) and TCEQ.

b.   Provide, as office of record, all necessary reporting requirements to local, state, or federal agencies as it pertains to the management of hazardous materials and waste.

c.   Coordinate disposal of all university hazardous waste, including acting as liaison between the hazardous waste generator (university department or activity) and the hazardous waste disposal contractor. EHS&RM also develops specifications and obtains bids, in accordance with university purchasing guidelines, for the University’s hazardous waste disposal service.

d.   Assist department heads, account managers and other university personnel in managing their departments’ hazardous materials and waste. This includes interpreting applicable regulations, coordinating or conducting personnel training, and establishing coordinated inspections of work areas.

e.   Identify university departments or activities which are Hazardous Waste Generators based on the use of hazardous materials in the work area that are not used up in a process or equipment and which require disposal. Ensure that each hazardous waste stream is properly characterized for inclusion in the University's Notice of Registration (NOR) to the TCEQ. University activities that have been identified as hazardous waste generators are listed in Attachment I, List of Generators.

f.    Coordinate with TCEQ, EPA and DOT, as required, to resolve matters relating to the regulation of hazardous waste.

g.   Assist departmental hazardous materials coordinators to develop spill prevention plans, chemical hygiene plans, prepare hazardous waste for disposal, and assist emergency response agencies to control a spill or potential chemical hazard.

h.   Review and approve departmental chemical hygiene or spill prevention plans.

05.02  Department Heads and Account Managers – all university department heads, account managers, and other personnel who are responsible for a department or activity in which hazardous materials are utilized or in which hazardous waste is generated have primary responsibility for assuring that applicable federal, state and local regulations and university policies and procedures are followed. Other responsibilities include:

a.   Maintain a Work Area Chemical List (WACL) and Material Safety Data Sheet (MSDS) file. Identify those chemicals that contain hazardous ingredients and require the use of appropriate personal protective equipment (PPE), while insuring that storage, handling, and disposal is performed in accordance with university procedures. (See also Hazardous Communication Program, UPPS No. 04.05.05).

b.   Confer with the Environmental Health, Safety and Risk Management to assure that their department’s hazardous materials and waste management practices conform to applicable regulations and policies.

c.   Assure that personnel and students who are involved in the acquisition, handling, use, experimentation, or disposal of hazardous materials or waste are properly supervised and trained. This includes ensuring that these individuals use appropriate protective clothing and equipment, are informed about the materials involved, and know proper spill control prevention procedures. 

d.   Assure proper identification of waste chemicals, containerization, labeling, and storage within the department.

e.   Report hazardous chemicals to be processed for disposal to EHS&RM for coordination of pick up, storage, transport, and disposal. To facilitate removal and disposal of the hazardous materials or waste from the work area the following requirements must be met:

1)    Prepare a Chemical Removal Request Form (Attachment II Waste Pick Up) listing each chemical item to be disposed of. The request form will be forwarded to Environmental Health, Safety and Risk Management.

2)    Unknown chemicals will have to be tested to characterize the waste stream.

 

f.    Designate a departmental hazardous waste coordinator.

05.03  Environmental Health Specialist (EHS) – designated EHS&RM personnel may perform a variety of duties associated with the University’s Environmental Health and Safety Program.  With regard to the management and disposal of hazardous materials and waste, this may include the following:

a.   Check the Waste Chemical Data Sheet for completeness, identify the proper waste stream, and prepare chemical labels (Attachment III – Chemical Label) to be applied to the containers.

b.   After assessment of the waste data, the EHS will come to the work area to verify the chemical data and insure the chemical is in a suitable container. If the chemical is ready for disposal, the EHS will apply the chemical label to the container and arrange for removal of the waste.

06.       PROCEDURES FOR HANDLING AND PREVENTING SPILLS OF HAZARDOUS MATERIALS OR WASTE

06.01  All spills of hazardous materials or waste must be immediately reported to Environmental Health, Safety and Risk Management. Spills of hazardous materials will be handled in accordance with the instructions on the respective MSDS (information provided with each chemical purchased from the manufacturer).

06.02  All departments or activities with hazardous materials and waste must have a spill prevention plan implemented within the work area. All personnel in the work area will be familiar with the plan. At a minimum, the spill prevention plan will:

a.   Require posting of the following information next to telephones that may be used to summon emergency assistance. This shall include the:

1)   name and telephone number of the emergency coordinator (EHS&RM and representative from the department); 

2)   location of fire extinguishers, eye wash stations, and emergency showers;

3)   location of spill control material and cleanup supplies;

4)   the telephone number of the San Marcos Fire Department.

b.   Require training of all personnel in spill prevention and clean up procedures for the hazardous materials and waste being generated;

c.   Require availability of necessary spill control materials to contain the spill;

d.   Require use of personal protective equipment (PPE) in the use and clean up of hazardous materials or waste; 

e.   Require personnel to report spills to their supervisor, the University Police Department and to Environmental Health, Safety and Risk Management.

06.03  A copy of the department or activity spill prevention plan must be readily available to Environment Health, Safety and Risk Management for their review and approval. It is suggested that consideration be given to posting the spill prevention plan on the departmental web site.

06.04  Spill prevention plans may be specific to individual departments or activities, or may be standardized for an entire college or division or other area with common needs and activities. Standardization of plans within colleges, departments, or areas can be beneficial to their employees, as well as to Environmental Health, Safety and Risk Management.

07.       HAZARDOUS MATERIALS AND WASTE MANAGEMENT PROGRAM

07.01  The University’s Hazardous Materials and Waste Management Program includes initiatives to reduce the quantity of hazardous waste generated.  The Source Reduction/Water Minimization Plan (SR/WM) as presented in Attachment IV is prepared to comply with Senate Bill 1099 and includes the components required by the Texas Commission of Environmental Quality in TAC 35 Subchapter Q.

08.       REVIEWERS OF THIS UPPS

08.01  Reviewers of this UPPS include the following:

Position                                                         Date

Director, Environmental Health, Safety   October 1 E3Y

and Risk Management

 

Dean, College of Health Professions      October 1 E3Y

 

Director, Student Health Center                October 1 E3Y

 

Associate Vice President for Facilities     October 1 E3Y

 

Associate Vice President for Research   October 1 E3Y

and Government Relations

 

University Attorney                                      October 1 E3Y

09.       CERTIFICATION STATEMENT

This UPPS has been approved by the following individuals in their official capacities and represents Texas State policy and procedure from the date of this document until superseded.

Director, Environmental Health, Safety and Risk Management; senior reviewer of this UPPS

Vice President for Finance and Support Services

President