Hazardous Waste Minimization Requirements

EPA defines waste minimization as the reduction, to the most feasible extent, of hazardous waste that is subsequently treated, stored and disposed of. Waste minimization includes any source reduction or recycling activity undertaken by a generator that results in either the reduction of the total volume or quantity of hazardous waste, or the reduction of toxicity of hazardous waste, or both, so long as the reduction is consistent with the goal of minimizing the present and future threat to human health and the environment.

The main ideas behind waste minimization are toxicity, volume reduction and material substitution. Toxicity reduction means reducing the degree of hazard associated with the raw material that, consequently, reduces the degree of hazard of the waste. Material substitution means the use of lesser or even nontoxic materials.

The South Carolina Hazardous Waste Management Regulations and the ever rising costs for disposal, dictate that all possible efforts be taken to eliminate or reduce the generation of hazardous waste. Clemson University departments are responsible for assessing each source of hazardous waste within their operations and for establishing control measures to ensure that the least possible amount of waste is generated.

In anticipation of future hazardous waste minimization audits by SCDHEC, each department should record any efforts undertaken for hazardous waste reduction and submit the documentation to the Hazardous Waste Officer on an annual basis. Waste reduction action is to be implemented by an effective combination of the following methods:

  • Non-hazardous reagents shall be substituted for hazardous reagents where possible, to avoid generating hazardous waste.
  • Current equipment that produces a hazardous waste stream and can be replaced by a new technology that reduces or eliminates that waste stream shall be given high priority in the selection and procurement of replacement equipment.
  • No greater quantity of a hazardous reagent shall be procured than will be necessary to satisfy immediate planned usage. Unused chemical overstock constitutes a large portion of hazardous waste generated at Clemson University.
  • Any written agreement entered into by a department with an industrial client, where hazardous reagents or samples are supplied for specific research or experimental use on behalf of that client, shall include a provision for return of the unused amounts to the client for appropriate disposal.
  • Any agent of a department shall not accept donations of chemicals unless immediate planned usage is confirmed for the entire amount.
  • Chemical reaction systems shall be preplanned and designed so that by-products and effluent may be rendered non-hazardous in the process, prior to reaching waste status.
  • Upon application of hazardous reagents such as paints, pesticides, etc., the entire volume of material shall be applied or an additional area shall be identified where any remaining excess can be properly applied at the same rate, so that the entire amount can be depleted.
  • Upon termination of an employee or separation of a student, the exit process shall include immediate collection of all chemical reagents and waste residues used by or in the possession of that person. Prior to separation, the department is responsible for documenting the identity of each chemical reagent collected.

The intent here is to ensure that unused chemicals are returned to the department chemical stores and placed on inventory for continued use, wherever possible. Also, this procedure can help prevent the need for future analysis of “unknown” chemicals.

Until an effective chemical stock management program is introduced throughout Clemson University, old chemical stock will be a major portion of the waste stream. Some of this old stock is hazardous waste. Other constituents of this old stock may not meet the definition of hazardous waste. However, these wastes usually cannot be accepted into local sanitary or solid waste landfills. In order that liabilities are minimized, these chemical wastes are given to a hazardous waste disposer and classified managed as non-RCRA regulated wastes. From a regulatory standpoint, these unused chemicals are not hazardous wastes. From a cost standpoint, disposal of these chemicals as wastes may cost as much as the disposal of hazardous waste.