ENVIRONMENTAL SAFETY POLICY

Subject: Waste Disposal

Effective Date: February 1, 1997
Approved: Robert Martin, Vice Chancellor

Policy: 7

PURPOSE AND BACKGROUND:

The incorporation of this policy into campus waste handling practices is intended to prevent the inadvertent yet preventable contamination of campus refuse with potentially hazardous materials or wastes.

The 1990 Amendments to the Resource Conservation and Recovery Act expands the scope of wastes which are regulated hazardous wastes. This broadening of the hazardous waste definition dictates that all campus dumpster or compactor units are kept free of all wastes which contain free or semi-free liquids and free of all wastes exhibiting infectious or hazardous characteristics.

SCOPE:

This policy applies to all producers and handlers of campus refuse. This policy applies to all staff, faculty, students and guests of the University community.

This policy applies to all waste which is hazardous, special or infectious as defined by regulation or as determined by the Department of Environmental Health and Safety.

This policy applies to all waste which is radioactive as defined by regulation or as determined by the Office of Radiation Safety.

This policy applies to all waste which is regulated pharmaceutical waste as defined by regulation.

This policy applies to all waste that exists solely as a liquid product or contains liquid or semi-liquid components that could be released into the surrounding environment when placed into a dumpster or compactor unit.

POLICY:

All IUPUI staff are responsible for assuring that all waste discarded in campus dumpsters or compactor units are free of untreated infectious waste, special waste, hazardous waste, regulated radioactive waste, regulated pharmaceutical waste, and other miscellaneous liquid or semi-liquid wastes.

Untreated infectious waste, liquid or special waste, hazardous waste, radioactive or pharmaceutical waste are not to be discarded in campus dumpsters or compactor units.

Producers of campus refuse are responsible for the proper segregation of wastes into six primary waste categories.

DEFINITIONS:

- General Refuse Waste - disposal is coordinated by Campus Facility Services in accordance with state and federal regulations. General refuse waste includes:
- Food waste
- Metal products (excluding metals such as Arsenic, Barium, Cadmium, Chromium, Lead, Mercury, Selenium, Silver)
- Paper, cardboard and newsprint
- Plastic products
- Rubber and leather products
- Scrap wood
- Textile products
- Yard waste

- Pharmaceutical Waste - determination and disposal are established by Pharmacy guidelines and state and federal regulations. Pharmaceutical waste includes:
- Antineoplastic or Cytotoxic Drugs as defined by the U.S. Food and Drug Administration (FDA).
- Controlled Substances as defined by the U.S. Drug Enforcement Administration (DEA).
- Legend Drugs as defined by the U.S. FDA.
- Live Virus Vaccine

- Infectious Waste - determination and disposal are established by departmental protocols in accordance with local and state regulations.

Infectious waste includes any waste item that is contaminated with a disease agent potentially capable of transmitting a communicable disease to humans.

Infectious waste can be divided into three primary groups. These include:
•Liquid wastes such as blood, other bodily fluids or culture media which is known or suspected to be contaminated with a disease agent.
•Soft materials such as dressings, bandages, bedding, toweling etc. that are saturated to the point that they are capable of releasing blood, body fluids or other potentially infectious materials when handled or compressed.
•Any object, commonly referred to as sharp, that has been contaminated with blood, body fluids or other infectious agent which could penetrate the skin or could do so if broken.
Examples of sharps waste include:
•broken glass
•pipettes (glass and hard plastic)
•scalpel blades
•lancets

- Liquid or Special Waste - determination and disposal are coordinated by the Department of Environmental Health and Safety in accordance with local, state and federal regulations. Liquid or special waste include but is not limited to:
- Bacteriocidal or sanitizing solutions
- Concrete and asphalt sealants
- Degreasing agents
- Floor sealers, waxes and strippers
- Heating or air-conditioning treatment solutions
- Lubrication oils
- Paints, latex and oil-based
- Related paint products including thinners, solvents and strippers
- Pesticide or herbicide products
- Sludge wastes, including cooling tower sludges
- Vehicle maintenance fluids
- Water treatment solutions

- Radioactive Waste - determination and disposal are coordinated by the Radiation Safety Office in accordance with local, state and federal regulations. Radioactive waste includes, but is not limited to:
1. General laboratory refuse (e.g., gloves, glassware, paper, plastic, etc.) that is contaminated with radioactive materials.
2. Liquid wastes which include a radioactive material component, and
3. The remains of animals that contain radioactive materials as a result of administration of such material for research.

Radioactive waste is required to be labeled in accordance with procedures established by the Radiation Safety Office and typically exhibits the universal radiation precaution symbol for radiation.

- Hazardous or Chemical Waste - determination and disposal are coordinated by the Department of Environmental Health and Safety in accordance with local, state and federal regulations. Hazardous or chemical waste includes but is not limited to any stock chemical or chemical reagent that may inhibit one or more of the following physical hazards:

•Corrosivity - The material has a pH, whether acidic or basic, that will corrode steel or injure human tissue. This includes materials with a pH less than 5 or greater than 10, regardless of the strength of the acid or base.
•Ignitability - The material presents a significant fire hazard at room temperature.
•Reactivity - The material reacts violently with water; forms potentially explosive mixtures with water; generates toxic gases, vapors or fumes when mixed with water; or is unstable and can undergo a violent physical change.
•Toxicity - The material exhibits a significant characteristic of toxicity to human health or the environment.

PROCEDURES:

The Department of Environmental Health and Safety will be responsible for assisting producers of wastes with the proper categorization and disposal of their waste.

Waste producers will be responsible for the proper segregation of their waste. Only wastes which meet the criteria of being general refuse waste or treated infectious waste are to be disposed of in campus dumpsters or compactor units.

Procedures for the proper classification, packaging, labeling, and disposal of radioactive waste have been developed by the Radiation Safety Office. Such procedures are specified in the “Radiation Safety Procedures Manual,” published by the Radiation Safety Office.

Pharmaceutical Waste disposal guidance is available through campus pharmacies or the Department of Environmental Health and Safety.

- Controlled Substances - The handling and disposal of Controlled Substances are tightly controlled by the regulations of the U.S. Drug Enforcement Administration (DEA). The proper handling and disposal of Controlled Substances remains the sole responsibility of the DEA Registrant who originally purchases the material. Disposal guidance is available through the Department of Environmental Health and Safety.

- Antineoplastic Drugs are to be referred to the Department of Environmental Health and Safety as hazardous wastes as specified below.

- Legend Drugs and Live Virus Vaccines - Campus pharmacies or the Department of Environmental Health and Safety will provide guidance and assistance with the proper disposal of Legend Drugs.

Producers of Infectious Waste are to contact their respective Department of Building Services to schedule the pickup and treatment of infectious waste items. All infectious waste shall be kept separate from other wastes. Guidance on the determination and proper handling of infectious waste can be found within department guidelines, IUPUI-IUMC Laboratory Safety Manual or by contacting the Department of Environmental Health and Safety.

All other waste, except radioactive waste, is to be referred to the Department of Environmental Health and Safety for proper classification or disposal. Producers are to follow established and approved protocols for proper waste processing as defined for hazardous wastes within the "IUPUI-IUMC Laboratory Safety Manual" and the "Waste Disposal Guidelines" published by the Department of Environmental Health and Safety.

- Waste pickup will be initiated by completing a Hazardous Materials Manifest. Manifests with instructions may be obtained from the Department of Environmental Health and Safety (EHS).
- Completed manifests are to be returned to EHS. Upon receipt, EHS will schedule a pickup of the waste material.
- Wastes are to be packaged in containers suitable for the waste material. All wastes are to be labeled as to the specific contents.
- Wastes that may undergo dangerous decomposition or reactions are to be kept separate from other waste items.
- EHS staff will ensure that the waste is disposed of in accordance with applicable local, state and federal regulations.
- Additional handling information is available in the "IUPUI-IUMC Laboratory Safety Manual" and "Waste Disposal Guidelines."
- All exceptions to the procedures will be approved by the Director of the Department of Environmental Health and Safety or his designee.

The Department of Environmental Health and Safety may, at its discretion, refer costs incurred from the improper handling or disposal of any waste back to the producing or generating department. This cost will end with the proper transfer of the waste to the department or office as defined within this policy and compliance with other waste handling and disposal guidelines approved by the Environmental Safety Committee.

In the event the University is cited and fined by federal, state or local regulatory agencies for action or activities related to improperly disposed waste, the department(s) involved in the citation may be accountable for payment of the issued fine.

Any person affected by any such cost or fine assessment may appeal the assessment provided that a written request for such a review is submitted to the current Chairperson of the IUPUI Environmental Safety Committee within thirty (30) days of issuance of the assessment.

The Department of Environmental Health and Safety will provide a written, itemized assessment of the incurred costs to the responsible department or party(ies) and a copy of the IUPUI Environmental Safety Committee’s Appeals Procedures.

All appeals will be acted upon and reviewed in accordance with the established IUPUI Environmental Safety Committee appeals review procedures.