Haz Waste Online Training

May 2010
Introduction
What is a Hazardous Waste?—Hazardous wastes
include discarded chemicals, reagents, oil paints and
thinners, unusable chemicals, unidentified
chemicals, chemicals who’s properties have changed
with time, and left-over reagents and by-products
from previous employees, students, and professors.
Where are Hazardous Wastes found?—Hazardous

wastes obviously occur in labs, but can also be found
in art, facilities, grounds, and other non-laboratory
locations.
Location Location Location
Within a lab or shop where waste is generated, it may be
collected at the point of generation if identified as a “Satellite
Accumulation Area” (SAA).
 When a room, area, or building separate from the point of

generation has been identified as the location to accumulate
hazardous waste it must labeled as a “Hazardous Waste
Accumulation Area.”
JMU has SAA areas within labs and Hazardous Waste

Accumulation areas identified in the Chemistry/Physics
Building, ISAT Building, Burruss, and adjacent to the
Housekeeping Trailer on Grace St.
Containers in the Hazardous Waste
Accumulation Area
When a container with chemicals is no longer
needed, the chemical has been spent, or a waste
container from a satellite accumulation area is full, it
must be immediately moved to the Hazardous Waste
Accumulation Area.
The container must specify the following:

• Contents
• The words “Hazardous Waste”
• The date the container entered the
Hazardous Waste Accumulation Area
Documentation
Hazardous Waste Accumulation Areas are required to have the
following:
Weekly Inspection that verifies that the containers are intact and not
leaking, are closed, labeled appropriately, and dated
Up to date inventory indicating what materials are in the space and the
date on the container (a.k.a. when they were ‘accumulated’).
If during the weekly inspection some aspect of the area is found ‘non-compliant (i.e.
containers aren’t dated or don’t have the words “hazardous waste”), immediately correct the
problem. If the problem cannot be immediately corrected, note the issue on the inspection
form and indicate what corrective measures are being pursued. Once the issue is addressed,
indicate as such on the inspection form.
SAA
Satellite Accumulation Areas are not required to maintain a formal inventory nor
inspection log. However, the contents of the containers must be known, the
containers must be of suitable integrity and kept closed when not in use, and the
total volume in a SAA cannot exceed 55gal.
Tracking Waste Accumulation
JMU’s contiguous campus is classified as a Small
Quantity Generator (SQG) of waste. To maintain
that status, the University cannot
• Generate more than 1000kg of hazardous waste
per month
• Generate more than 1kg of P-listed* waste in a
month
• Store waste for longer than 180 days
For these reasons, an accurate inventory of the waste stored in

the accumulation areas is vital.
*P-listed waste are the acutely toxic waste streams like cyanide salts and
solutions, sodium azide, osmium tetroxide, nicotinic acid, etc..
Tracking Waste Accumulation
JMU properties which have the potential to generate waste,
but which are not contiguous to the main campus include:
The Studio Art Center

Memorial Hall
Bus garage and Alternative Fuels Lab
Each of these locations is classified as a “Conditionally Exempt

Small Quantity Generator” (CESQG). To remain a CESQG,
each location must ensure that no more than 100kg (220lbs) of
waste is generated in a month, never to exceed 1000kg
(2200lbs) total. JMU personnel are not authorized to
transport waste from these locations.
Waste Removal and Transport
A properly licensed waste contractor will package and remove
waste from each of the Hazardous Waste Accumulation Areas
as well as directly from the CESQG locations (i.e. The Studio
Art Center, Memorial Hall, and the Bus Garage/Alt. Fuels
Lab).
Within the contiguous campus, JMU personnel may transport

hazardous wastes such as paints, lubricants, and other
maintenance or facilities-derived materials. However, JMU
personnel are NOT authorized to transport any waste from the
CESQG locations nor should they be transporting any
laboratory-generated wastes or chemicals.
Emergencies
If there is a small spill, you may intervene to mitigate and/or
clean up only under the following conditions:
 The identity of the spilled material is known.

and
 The hazards of the spilled material are known.
and
 The area is sufficiently large and/or ventilated so as to
assure the small spill will not generate a hazardous
environment (i.e. IDLH or LEL conditions).
and
 You feel comfortable doing so.
If any of these conditions are not met, evacuate the area

and report the spill by calling JMU Police from a cell
phone at 568-6911 or from a JMU landline at x6911
Spill Clean-up
Small spills, which meet the aforementioned criteria, may be
cleaned up with a universal absorbent like vermiculite or clay
(kitty litter) or other materials suitable for the type and
volume of the spill.
Once utilized, the absorbent material must be packaged in a

container suitable for the contents and treated as hazardous
waste (a.k.a labeled, dated, placed in appropriate area).
If you are unsure about the proper clean-up method,

evacuate the area and report the spill by calling JMU
Police from a cell phone at 568-6911 or from a JMU
landline at x6911
Summary
Satellite Hazardous Waste Conditionally Exempt
Accumulation Accumulation Areas Small Quantity
Areas (SAA) Generator (CESQG)
 must be at the  locations are separate  locations are not

point of waste from point of generation contiguous to campus
generation (like in a  have a time limit of and include Memorial
science lab or 180days Hall, Studio Center, Alt.
maintenance shop)  contiguous campus is Fuels Lab/Garage
 have a volume limited to accumulating no  limited to haz waste
limit of 55gal total, more than 2200lbs accumulations less than
but not a time limit (1000kgs) of haz waste 220lbs (100kgs) per
 once containers and 2.2lbs (1kg) of p-listed month
are full they must be waste per month to
moved to the maintain small quantity
Hazardous Waste generator status
Accumulation Area
Responsibilities
ALL employees must be thoroughly familiar with proper waste
handling and emergency procedures that are relevant to their
job responsibilities, both during normal facility operations as
well as during emergencies.
Instructors, research advisors, and supervisors are responsible

for ensuring students understand their obligations with regard
to handling all types of waste and know appropriate emergency
procedures pertaining to any hazardous waste they work with
or around.
Conclusion
By following the aforementioned rules, JMU can safely manage
its hazardous waste in compliance with applicable DEQ and
EPA regulations.
If you have any questions about the materials presented in this training, or
about handling waste and associated documentation for your area, please
contact Marcella Mullenax, JMU’s Environmental Health Coordinator, at
[email protected] or 8-4959.

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May 2010

Where are Hazardous Wastes found?—Hazardous

 When a room, area, or building separate from the point of

JMU has SAA areas within labs and Hazardous Waste

The container must specify the following:

For these reasons, an accurate inventory of the waste stored in

The Studio Art Center

Each of these locations is classified as a “Conditionally Exempt

Within the contiguous campus, JMU personnel may transport

 The identity of the spilled material is known.

If any of these conditions are not met, evacuate the area

Once utilized, the absorbent material must be packaged in a

If you are unsure about the proper clean-up method,

 must be at the  locations are separate  locations are not

Instructors, research advisors, and supervisors are responsible

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