Chemical Safety

Chapter 3 Restrictions and Waste Definitions

The restrictions on how chemical waste is to be disposed can be very complex and difficult to understand. The Division of Research Safety (DRS) is here to assist you by having a chemical waste disposal program that reduces the burden for campus personnel of complying with the restrictions on the disposal of chemical waste. If you generate chemical waste, you are responsible for disposing of your waste through the DRS chemical waste disposal program. The only chemical waste that does not have to go through DRS for disposal is any chemical identified as a liquid, non-hazardous waste in Chapter 4, which may be disposed via the sanitary sewer (sink).

If you are interested in the specific restrictions on chemical waste disposal - please read on.

Chemical waste should never be sent off-campus for disposal 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 )."

The disposal of toxic waste and hazardous waste in the trash or down the sanitary sewer (sink drain) is illegal. The definitions of toxic waste and hazardous waste are provided below.

All chemical waste, whether toxic, hazardous or non-hazardous, are potentially regulated as Illinois Special Waste if placed in the trash, and therefore should not be disposed of in the trash until a waste determination and Non-Special Waste certification is made by DRS personnel. Illinois Special Waste is further defined later in this chapter.

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. The UCSD sanitary sewer disposal requirements are defined at the end of this chapter.

Instructions for completing a request for the collection of chemical waste through the DRS chemical waste disposal program are found in Chapter 8.

Definition of toxic (chemical) waste

Toxic (chemical) waste must be disposed of through the DRS chemical waste disposal program.

For the purposes of this manual, a toxic waste is defined as:

• a waste that has an oral-rat LD ₅₀ toxicity value lower than 500 mg/kg
  or
• a waste that is a carcinogen, mutagen, teratogen, or is identified as a possible carcinogen, mutagen or teratogen (check MSDS for information).

If the waste is a mixture, and it is uncertain whether the mixture would meet these criteria, it is recommended that the waste be disposed of 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, which because of its quantity, concentration or chemical, or infectious characteristic may:

1. cause, or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible illness or;
2. pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, disposed of, or otherwise managed.

NOTE: EPA defines "solid waste" as any solid, liquid or gas which is disposed of, abandoned or discarded.

How to determine if your chemical waste is a hazardous waste

A waste is classified as a hazardous (chemical) waste if it meets the definition for any of the characteristic hazards of ignitability, corrosivity, reactivity or toxicity. A waste can also be a hazardous (chemical) waste if it appears on one of the EPA lists. The definitions of the characteristic hazards are listed below and are followed by the EPA lists.

Ignitability (D001):

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 spontaneous combustion
• an ignitable compressed gas per Department of Transportation (DOT) regulations
• an oxidizer per DOT regulations

Corrosivity (D002):

Waste that exhibits any of the following properties:

• an aqueous waste with a pH ≤ 2 or ≥ 12.5; or
• a liquid that corrodes steel at a rate ≥ ¼ inch per year at a temperature of 130° F (55°C)

Reactivity (D003):

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
• is a cyanide or sulfide bearing waste which, 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
• is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if heated under confinement
• is readily capable of detonation or explosive decomposition or reaction at standard temperature and pressure
• is a forbidden explosive, Class A explosive or Class B explosive per DOT regulations

Toxicity (D004-D043):

Waste that exhibits any of the following properties:

When extraction of the material using an EPA specified protocol (toxicity characteristic leaching procedure or TCLP) shows excessive levels of the chemicals shown below

Contaminant	Regulatory Level (mg/L)	EPA Number
Arsenic	5.0	D004
Barium	100.0	D005
Cadmium	1.0	D006
Chromium	5.0	D007
Lead	5.0	D008
Mercury	0.2	D009
Selenium	1.0	D010
Silver	5.0	D011
Endrin	0.02	D012
Lindane	0.4	D013
Methoxychlor	10.0	D014
Toxaphene	0.5	D015
2,4-D	10.0	D016
2,4,5 TP (Silvex)	1.0	D017
Benzene	0.5	D018
Carbon tetrachloride	0.5	D019
Chlordane	0.03	D020
Chlorobenzene	100.0	D021
Chloroform	6.0	D022
o-Cresol	200.0	D023
m-Cresol	200.0	D024
p-Cresol	200.0	D025
Cresol	200.0	D026
1,4-Dichlorobenzene	7.5	D027
1,2-Dichloroethane	0.5	D028
1,1-Dichloroethylene	0.7	D029
2,4-Dinitrotoluene	0.13	D030
Heptachlor (and its hydroxide)	0.008	D031
Hexachlorobenzene	3.0	D032
Hexachlorobutadiene	0.5	D033
Hexachloroethane	3.0	D034
Methyl ethyl ketone	200.0	D035
Nitrobenzene	2.0	D036
Pentachlorophenol	100.0	D037
Pyridine	5.0	D038
Tetrachloroethylene	0.7	D039
Trichloroethylene	0.5	D040
2,4,5-Trichlorophenol	400.0	D041
2,4,6-Trichlorophenol	2.0	D042
Vinyl chloride	0.2	D043

A waste is also hazardous if it is named on one of the three lists that follow, which were developed by the EPA:

1. Non-specific source wastes
2. Acute discarded wastes
3. Toxic discarded wastes.

Non-Specific Source Wastes

[Note: this list only applies to chemicals that have been used.]

Non-Specific Source Waste Description	EPA Code
The following spent halogenated solvents used in degreasing: Tetrachloroethylene, trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride, and chlorinated fluorocarbons; all spent solvent mixtures/blends used in degreasing containing, before use, a total of ten percent or more (by volume) of one or more of the above halogenated solvents or those solvents listed in F002, F004 and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixutures	F001
The following spent halogentated solvents: Tetrachloroethylene, methylene chloride, trichloroethylene, 1,1,1,-trichloroethane, chlorobenzene, 1,1,2-trichloro-1,2,2-trifluoroethane, ortho-dichlorobenzene, trichlorofluoromethane, and1,1,2-trichloroethane; all spent solvent mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or more of the above halogenated solvents or those listed in F001, F004, or F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures.	F002
The following spent non-halogenated solvents: Xylene, acetone, ethyl acetate, ethyl benzene, ethyl ether, methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, and methanol; all spent solvent mixtures/blends containing, before use, only the above spent non-halogenated solvents; and, a total of ten percent or more (by volume) of one or more of those solvents listed in F001, F002, F004, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures.	F003
The following spent non-halogenated solvents: Cresols and cresylic acid, and nitro-benzene; all spent solvent mixtures/blends containing before use, a total of ten percent or more (by volume) of one or more of the above non-halogenated solvents or those solvents listed in F001, F002, and F005; and still bottoms from the recovery of these spent solvents and spent solvent mixtures.	F004
The following spent non-halogenated solvents: Toluene, methyl ethyl ketone, carbon disulfide, isobutanol, pyridine, benzene, 2-ethyoxyethanol, and 2-nitropropane; all spent solvent mixtures/blends containing, before use a total of ten percent or more (by volume) of one or more of the above non-halogenated solvents or those solvents listed in F001, F002 or F004; and still bottoms from the recovery of these spent solvents and spent solvent mixtures.	F005

Acute and Toxic Discarded Waste Lists

[Note: These two lists only apply to chemicals that have not been used (unspent)]

• View Acute Discarded Waste list
• View Toxic Discarded Waste list

Any container to be disposed of, containing a chemical from either list in their original form (i.e. as purchased) is regulated as a hazardous waste. Empty containers of these chemicals are also regulated as hazardous waste (cannot go in trash), unless the container has been triple rinsed. See Chapter 9 for further information on the decontamination of empty chemical containers. The rinse from a container containing a chemical from the Acute Discard Waste List must be saved and disposed of through the campus chemical waste disposal program (see Chapter 8 for instructions on requesting a chemical collection).

Materials contaminated with these chemicals (original product only) from a spill (paper towels, gloves, soil, etc.) are also regulated as hazardous waste.

Due to the large size of the lists, they are provided as separate Excel files. The lists incorporate CAS numbers of chemicals and also multiple names used for the same chemical for searching convenience.

Illinois Special Waste

Illinois special waste includes hazardous waste, potentially infectious medical waste (PIMW), industrial process waste, and pollution control waste.

At first glance it would look like none of those categories would fit a non-hazardous chemical to be disposed of at UIUC. However, the Illinois EPA includes university and college research and maintenance in the catagory of industrial process. This means that all chemicals (hazardous or non-hazardous) to be disposed of from UIUC (that cannot be disposed of down the sanitary sewer) would qualify as an industrial process waste and are classified as Illinois Special Waste until a Non-Special Waste certification is made. DRS can make the Non-Special Waste certification; therefore all labs are required to send all chemicals, hazardous or non-hazardous to DRS for proper disposal according to Illinois EPA regulations.

Urbana-Champaign Sanitary District (UCSD) restrictions for sewer disposal

The use of the sanitary sewer for the disposal of chemical wastes is based upon an ordinance adopted by the Urbana-Champaign Sanitary district. Specific disposal requirements are as follows:

• pH of the waste solution must be between 6 and 10 before pouring down the sanitary sewer (sink drain).
• Noxious or malodorous gases or substances capable of creating a public nuisance cannot be poured down the sanitary sewer (sink drain).
• Limits for metals and other constituents in the waste solution (prior to any dilution) before pouring down the sanitary sewer (sink drain) are as follows:

Constituent	Concentration (mg/L)
Arsenic	0.1
Barium	100
Cadmium	0.04
Chromium (+6)	0.3
Chromium (Total)	2.3
Copper	1.5
Cyanide	1.2
Lead	0.8
Mercury	0.0005
Nickel	2.7
Selenium	0.04
Silver	0.1
Zinc	3.1