Hazardous
Materials and Hazardous UPPS
No. 04.05.06
Waste
Management Issue
No. 8
Effective
Date: 12/14/2012
Review:
October 1 E3Y
01. POLICY STATEMENTS
01.01 Hazardous materials and hazardous waste can
pose a threat to students, employees, visitors and the environment if not 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 & Risk
Management (EHS&RM) has primary responsibility for the university’s
hazardous materials and hazardous 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 university 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 hazardous 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. Employees at Texas State authorized to
transport chemicals are Materials Management staff and EHS&RM staff. Hazardous materials transported by government
employees for non-commercial purposes are not subject to the Hazardous
Materials Regulations in 49CFR Parts 171-180.
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. Hazardous
materials become hazardous waste when they are discarded or no longer needed or
used for their intended purpose.
02.02 Hazardous Waste – any substance identified or
listed as a hazardous waste by the administrator of the United States Environmental
Protection Agency, 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 cleanup of hazardous
materials or hazardous waste.
02.08 Chemical Hygiene Plan – a written program
developed and implemented by the department that 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 EHS&RM
for proper management of hazardous materials used or hazardous waste generated
by their department.
03. HAZARDOUS MATERIALS MANAGEMENT PROCEDURES
03.01 Hazardous materials or materials that 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 Materials
a. Hazardous materials should be purchased in a
manner that minimizes the quantity of hazardous materials in the work area and
hazardous waste generated. Any request for purchase of a hazardous chemical
from any department must be approved through the EHS&RM department. EHS&RM
will review the purchase request and provide approval if the chemical is not
being requested in large quantities or is a chemical having high regulatory
consequence. These chemicals may be regulated by more than one program, have
high toxicity or high legal consequences for mismanagement.
b. Because of federal and state regulations
regarding the procurement of hazardous materials, all such purchases must be
approved through the university’s purchasing system. 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.
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 EHS&RM. University departments or areas that handle
hazardous materials and hazardous waste are not authorized to undertake
disposal procedures without contacting EHS&RM.
04.02 The disposal of hazardous waste by hazardous
waste generators is strictly controlled by local, state and federal
regulations. All university departments utilizing hazardous materials 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; and
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 Time frame for disposition of hazardous waste
– Hazardous waste must be removed from the university’s Hazardous Waste
Management Unit within 90 days of placement in the unit. Departments or areas
that have hazardous materials or materials which may become hazardous waste
must contact EHS&RM to arrange for disposal.
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 EHS&RM has
primary responsibility for the following duties associated with the management
program for hazardous materials and hazardous 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 hazardous 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
that are hazardous waste generators based on the use of hazardous materials in the
work area that are not consumed and that require disposal. EHS&RM will also
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
identified in the List of Generators;
f. Coordinate with TCEQ, EPA and DOT, as
required, to resolve matters relating to the regulation of hazardous waste; and
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.
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 UPPS No. 04.05.05, Hazardous
Communication Program);
b. Confer with EHS&RM 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 hazardous 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 hazardous
waste from the work area the following requirements must be met:
1) Prepare a Chemical Removal Request Form (Waste Pick Up) listing each
chemical item to be disposed of. The request form will be forwarded to EHS&RM.
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 hazardous waste, this may include the
following:
a. Provide chemical labels (Hazardous Waste Label) to the departments.
These will be applied to the containers as waste in initially generated and
collected by the generators;
b. Inspect waste collection and storage areas in
departments to ensure compliance to TCEQ and EPA regulations; and
c. Collect waste containers from the generator
departments on a weekly basis and transport them to the university’s Hazardous
Waste Management Unit.
06. PROCEDURES
FOR HANDLING AND PREVENTING SPILLS OF HAZARDOUS MATERIALS OR HAZARDOUS WASTE
06.01 All spills of hazardous materials or hazardous
waste must be immediately reported to EHS&RM. 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 hazardous 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; and
4) the telephone number
of the San Marcos Fire Department.
b. Require training of all personnel in spill
prevention and cleanup procedures for the hazardous materials and hazardous
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 cleanup of hazardous materials or hazardous waste; and
e. Require personnel to report spills to their
supervisor, the University Police Department and to EHS&RM.
06.03 A copy of the department or activity spill prevention
plan must be readily available to EHS&RM for their review and approval. It
is suggested that consideration be given to posting the spill prevention plan
on the departmental website.
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 EHS&RM.
07. HAZARDOUS MATERIALS AND HAZARDOUS WASTE
MANAGEMENT PROGRAM
07.01 The
university’s Hazardous Materials and Hazardous Waste Management Program include
initiatives to reduce the quantity of hazardous waste generated. The
Source Reduction/Water Minimization Plan (SR/WM) as presented in Pollution Prevention
Plan
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
& 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
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 & Risk Management; senior reviewer of this UPPS
Vice President for
Finance and Support Services
President