| Table of Contents |
| 3.1 Introduction |
| 3.2 Hazardous Waste Management |
| 3.3 Chemical Reuse Program |
| 3.4 Sanitary Sewer Wastewater / Drain Disposal |
| 3.5 Stormwater Management |
| Related Documents |
3.1 Introduction #
Most waste products are regulated by state and federal agencies. Items that CANNOT be disposed of into our regular trash waste stream (i.e., anything that will end up in a trash dumpster or down a sewer drain) includes: chemicals, radiological materials, paints, solvents, oils, batteries, tires, drums, gas cylinders, fluorescent light tubes, electronics, refrigeration equipment, infectious materials, unpackaged sharps, asbestos containing materials, lead containing materials, recyclable metals, or anything characterized as hazardous.
Any questions about what can or cannot be put into the regular waste stream should be directed to EHS
3.2 Hazardous Waste Management #
Generators of hazardous waste are required to comply with extensive and complex rules and regulations promulgated by federal, state and local regulatory agencies. These rules regulate chemical waste storage, labeling, packaging and disposal. Management of hazardous waste is both a critical compliance and health & safety responsibility. Each generator of chemical waste at U-M is responsible for the proper management of their wastes.
The Hazardous Waste Disposal Program for U-M is coordinated by EHS Hazardous Material Management (HMM) (734)763-4568. The University requires all chemical, biohazardous, and radioactive wastes be disposed through EHS HMM.
In addition to hazardous waste pickup, EHS HMM assists the University community in maintaining compliance with regulations pertaining to waste management and disposal. Specific services include:
- Technical advice on identification, labeling and manifesting of waste.
- Emergency response to accidental spills.
- Chemical cleanouts.
- Technical advice and training on emergency response to spills.
- Waste disposal supplies.
- Pollution prevention/waste minimization.
Chemical Waste #
Wastes are picked up by EHS HMM upon request by calling (734)763-4568. All waste must be properly packaged, labeled and manifested. Evaporation in a chemical fume hood is not an option. Waste must be called in for pickup within 60 days of the accumulation start date on the container waste label. This will ensure that the waste will be sent for disposal prior to the 90-day regulatory limit.
No hazardous wastes may be poured down the drain to any sewer unless specific permission is given by EHS HMM. The U-M waste disposal procedures allow only non-regulated/non-coagulating sugars and salts to be poured down a sanitary drain. All other chemicals are considered hazardous by the U-M.
Chemicals must be in a waste container compatible for the specific class of chemicals. Waste containers must be properly labeled and should be the minimum size that is required. There should be at least 10% (of the volume of the container) of headspace in the liquid waste container to avoid a buildup of gas that could cause an explosion or a container rupture.
Container Management – Containers must be:
- In good condition (free of defects, cracks, rust, etc.)
- Compatible with the waste in them
- Stored CLOSED (containers can only be open while actively adding or removing waste, and cannot be stored open with a funnel)
- Handled and stored so containers do not rupture or leak
- Inspected weekly for leaks and defects
- Stored so incompatible wastes are separated or contained from each other by physical barriers
Chemical waste containers are available to labs free of charge through EHS HMM. They can be ordered by calling (734) 763-4568.
In addition to the U-M Chemical Waste web page the following procedures are provided to assist generators at the U-M in complying with essential practices for proper management and disposal of chemical wastes:
Aqueous/Organic – Do not intentionally mix aqueous waste with organic waste after generation if each waste stream is generated separately. If a mixture of aqueous and organic waste is generated in combination as part of an activity, do not attempt to separate the bi-phase solutions prior to disposal.
Aqueous Solutions – Keep acids separate from bases. List each anion and cation in the solution. Of particular importance are the metals, cyanide and sulfide. Avoid including organics, if possible.
Cyanides and Sulfides – Keep these materials separate from other wastes. Label and manifest thoroughly. These may include pure compounds or aqueous solutions. Call EHS HMM at (734)763-4568 to schedule a special pick-up.
EP (Extraction Procedure) Toxic Metals – Organic wastes are burned — both solids and liquids. These metals and their compounds cannot, by law, be incinerated. Keep these materials separate from all other wastes and label thoroughly. The following metals (in metallic or compound form) should never be discarded with organics:
| Arsenic | Copper | Selenium |
| Barium | Lead | Mercury |
| Cadmium | Mercury | Thallium |
| Chromium | Nickel | Zinc |
Explosive Materials – Explosive materials, such as picric acid with less than 10% water and its derivatives, or certain azo-compounds or perchlorates, must be separated from all other wastes and packaged individually. Notify EHS HMM for a special pickup of these items.
Hazard Classes – Separate hazard classes are required to keep incompatible chemicals apart, which might otherwise react and create an extremely hazardous situation. If placing several bottles or vials of different, partially used chemicals in a bucket or wide mouth jar, or if placing several different liquids in a waste bottle, try to utilize a separate hazard class for each container. Please note that free liquids should not be disposed in buckets.
Separate organics from inorganics, liquids from solids, and if possible, halogenated organics from non-halogenated organics. Also refer to chemical compatibility charts above.
Labels – Each different chemical in the container must be listed on the hazardous waste label (include quantity of all waste regardless of class or toxicity). The month, date and year must be placed on the label to indicate when waste was first put into the container. The department contact information, building EPA ID number and the manifest document number must also be put on the label.
Lecture (Compressed Gas) Bottles – Check before ordering that the manufacturer will take the lecture bottle back for disposal. EHS HMM prefers that all lecture bottles are emptied prior to sending for disposal. The lecture bottle must have the word “empty” written on the bottle. Most landfills will not accept lecture bottles unless they are emptied, purged, and cut in two.
Liquids/Solids – DO NOT combine liquid and solid chemical wastes in the same container. Use separate containers. EHS HMM recommends disposing liquids in gallon jugs.
Place solids in wide mouth jars or buckets. Solid wastes contaminated with chemicals may include paper towels, Kim wipes, gloves, weigh boats, capillary tubes, glassware, etc. Non-contaminated glass can be placed in a glass refuse box or cardboard box. The container must be labeled as “Non-contaminated Glass” and will be picked up by Custodial Services.
Metallic Mercury – Keep metallic mercury and other materials contaminated with metallic mercury separate from all other wastes and label properly.
Organometallics – Organometallic wastes, especially those containing any of the EP toxic metals (see above), must be kept separate from all other wastes and labeled.
Polychlorinated Biphenyls (PCBs) – Keep PCB and other PCB-contaminated materials separate from all other wastes.
Pyrophoric Materials – Pyrophoric materials must be separated from all other wastes and packaged individually.
Sharps and Needles – Discarded sharps and needles must be placed in a puncture-proof waste container. Needles must not be bent, sheared, or replaced in the sheath or guard following use. Once the container is 3/4-full, seal the container shut so that it is air-tight. Label the container with a “Sharps” label or write “Sharps” on the container exterior. Only chemically contaminated sharps require a hazardous waste label and manifest.
Water-Reactive Chemicals – Keep water reactive chemicals separate from all other wastes. Label and manifest for pick-up by EHS HMM.
Additional information and guidance on chemical waste disposal is available on the EHS website.
Biohazardous Waste #
Biohazardous waste includes any waste material with the presence or reasonably anticipated presence of blood or infectious material or any waste material containing or contaminated with liquids of human or animal origin, but not including urine.
Proper biohazardous waste management practices are essential in protecting human health and the environment. The HMM program can assist generators in developing a waste management plan to address collection and disposal of biohazardous solids, liquids, pathological and sharps waste. See the Biohazardous waste guidance document for additional information.
Special Waste #
Due to their delicate nature, inherent instability or extreme toxicity, special waste cannot be disposed using normal procedures. Common waste streams that fall into this category include:
- Explosives
- Shock sensitive and peroxide forming chemicals
- Polychlorinated biphenyls (PCBs)
- Dioxins
- Department of Transportation “Forbiddens”
Battery Waste #
All battery sizes and types must be disposed of through the EHS HMM Battery recycling program. Batteries cannot be disposed of in the general trash.
Proper Segregation and Disposal of Low-Level Radioactive Waste (LLRW) #
Disposal of the various forms of low-level radioactive waste (LLRW) is complex, extremely difficult, and very costly. Waste minimization and segregation are critical to reducing costs, ensuring regulatory compliance, maintaining a safe work place, and protecting the environment. All radioactive waste generators must adhere to the waste minimization and waste segregation procedures established by EHS HMM. EHS HMM will collect and process the various forms of radioactive waste generated at the University of Michigan provided the waste is properly segregated packaged and identified according to the methods detailed in the Proper Segregation and Disposal of Low-Level Radioactive Waste (LLRW) document.
Environmental Management #
Ongoing operations must employ sound environmental practices to provide environmental stewardship and limit liabilities. EHS works with departments to reduce or eliminate concerns and maintain compliance with the constantly changing regulations. Examples of the assistance EHS provides to promote environmental stewardship include:
Refrigerants #
To comply with EPA regulations, University of Michigan (U-M) personnel and outside contractors must contact the Facilities Maintenance, Air Conditioning Shop when installing or removing equipment containing chlorofluorocarbons (CFCs) or hydrochlorofluorcarbons (HCFCs).
The Air Conditioning Shop tracks and disposes of refrigeration appliances containing the following CFCs and HCFCs.
| Ethane | Ethylene | HP-81 | MP-39 | MP-66 |
| Poly Cold Mix | Propane | R-11 | R-114 | R-12 |
| R-123 | R-13 | R-134A | R-13B1 | R-22 |
| R-23 | R-290 | R-401 | R-401A | R-401B |
| R-402B | R-404A | R-406A | R-408A | R-409A |
| R-414B | R-500 | R-502 | R-503 | R-50-50 |
| R-507 | R-AZ50 |
Complete the U-M HVAC Refrigerant Equipment Input Form 1A and contact the Facilities Service Center at (734) 647-2059 before installing or removing equipment containing CFCs or HCFCs.
Other Regulated Wastes #
The University of Michigan (U-M) recycles the following universal waste:
- Batteries
- Bulbs (lamps)
- Ballasts
- Consumer electronics
These items cannot be disposed of through regular waste streams. Contact EHS for more information.
Controlled Substance Disposal #
The U-M Office of Research (UMOR) administers the Controlled Substances in Research Oversight Program. Please follow the guidance provided by UMOR for the proper handling, storage, and disposal of Controlled Substances. Contact the EHS Hazardous Materials Management (HMM) office at (734)763-4568 for proper disposal of all controlled substances.
Mercury Elimination Program – The University of Michigan has successfully removed over 6,000 mercury thermometers and 3,000 pounds of elemental mercury from our campus since 2002. Through the Green Purchasing Program of the U-M Procurement Services department we have entered into an agreement with Fisher Scientific to replace mercury thermometers with non-mercury devices. For technical assistance our Fisher Scientific representative can be reached at (989)708-4103 or by e-mail at [email protected].
Sustainability in Labs – The Office of Campus Sustainability (OCS) works with labs to promote and practice sustainable operations in a more standardized way. The Sustainable Lab Recognition Program is a collaborative effort between OCS and individual labs that are interested in integrating some or all of the following practices into their research operations: pollution prevention, recycling, waste minimization, green chemistry, and green purchasing. A list of labs on campus that have achieved certification is available. To schedule an appointment for an individual consultation with OCS, contact EHS at (734) 647-1143.
3.3 Chemical Reuse Program #
The Chemical Reuse Program provides U-M research and teaching labs with an opportunity to obtain desired chemicals and solvents free of charge. EHS stores the unexpired and unused surplus chemicals in a repository for redistribution. Through this program labs can request a chemical, donate a chemical, or request a standing order. This program is intended to serve the U-M community only.
Requesting Chemicals, Equipment, and Materials: Below is a list of the available chemicals, equipment, or materials. The available items are distributed on a first come, first serve basis.
- Chemical (MI Safety Portal Chemical Inventory, look at “ChEM Reuse Program’s Chemical Inventory” under “Reports” for a list of chemicals we have available, then email requests to [email protected])
- Equipment and Material (Mark your selections and submit form. Hint: if you press Ctrl + F, a search box will display to assist you in looking for a specific item.)
You may also email requests and questions to [email protected]. They are happy to put requests on a “wishlist” if not currently in our inventory and contact you if it comes in.
Donating to the ChEM Reuse Program: The ChEM Reuse Program enables researchers and teaching labs to:
- Donate chemicals, equipment, or materials that are no longer needed. All items must be in good condition and functioning. Chemicals must be in properly labeled containers, unexpired, and be able to be stored at room temperature.
- If you have large quantities of excess materials (such as during a lab closure or move) request an Office of Campus Sustainability representative to visit your lab to assess excess materials for possible donation.
Email the Office of Campus Sustainability at [email protected] describing your donation. Please include your location, description of items, and preferred pi
3.4 Sanitary Sewer Wastewater / Drain Disposal #
Wastewater discharged from inside U-M facilities flows into the sanitary sewer system and is treated at the Ann Arbor Wastewater Treatment Plant (AAWWTP) prior to discharge into the Huron River watershed. Pouring other materials (pollutants) down the drain such as chemicals, metals, solids, and oils can interfere with the treatment process. More information on general procedures for drain disposal is available on the EHS website.
The following criteria must be met prior to disposing any wastewater into the sanitary sewer system:
- All wastes must comply with the limits established in the Ann Arbor Sewer Use Ordinance
- Liquids Only
- No hazardous wastes
- No Michigan hazardous wastes or Liquid Industrial By-Products
- No radioactive wastes
- No untreated biohazardous wastes
If discharges from facilities cannot meet these limits, pretreatment systems may be required to remove the pollutant loading. When using and disposing chemicals, consider the following practices:
- EHS should evaluate any chemical processes to determine the proper disposal methods. Contact EHS by calling 936-1920 to determine if the materials involved in a process may be discharged to the sanitary sewer. All unused chemicals must be properly disposed through the EHS Hazardous Materials and Remediation Services program (HAZMAT) by calling 763-4568.
- You must collect all other chemicals, chemical rinses, and residuals for disposal as chemical waste.
- Acids and bases that have a pH between 5 and 10 may be disposed down the drain. Anything with a pH outside this range must be disposed of through HAZMAT. Contact EHS at 763-4568 for information regarding acid and base neutralization.
- Buffers and isotonic saline solutions are safe to dispose down the sanitary sewer in small quantities only. Large quantities of solutions that contain organic matter, such as IV solution, may exert increased oxygen demands on the treatment processes at the WWTP and should not be disposed to the sanitary sewer. Solids are limited by the sewer use ordinance and can plug drains; any solids present in these solutions must be collected for alternative disposal.
- Contact EHS for questions about what can and cannot go down the drain or for a review of your disposal procedures.
- Blood and blood products can be rinsed down the drain. Blood that is known or suspected to contain infectious agents should be bleached prior to disposal. All solids such as tissues and blood clots should be collected and disposed of as biohazardous waste. Blood contaminated with chemicals should as be disposed of as biohazardous waste.
- Dumping excess or leftover chemical product down a drain is prohibited. If excess or unwanted product exists, HAZMAT should be contacted for proper disposal. Any wastes that are collected for disposal by HAZMAT should be segregated.
EHS HAZMAT will pick up liquid chemical, biomedical, and radioactive wastes as well as sharps. Ensure that all waste generated in the lab is placed in the appropriate waste containers.
3.5 Stormwater Management #
Storm sewer drains (typically any sewer drain located outside of a building) do not go to the wastewater treatment plant, but go straight to the local river (e.g., the Huron River). Disposal of anything other than water is prohibited to storm sewer drains.
Equipment that does not have any chemical, radioactive, oil, or grease residues may be washed outside on the grass, away from storm drains. Use only water to wash the item and allow the water to drain into the ground. Do not use any detergents or chemicals. If large equipment must be cleaned or if chemicals must be used, contact EHS Environmental Protection and Permitting at (734) 647-1143 for a consultation and an evaluation of your options for disposing the wash water.