Hazardous Waste
written by: Aaron Landry, Terra Peavie, Chris Lempsis
The actual measurement of hazardous waste is extremely difficult because the polluters are generally responsible for recording disposal methods and amounts. If spillage or illegal dumping occurs it is the responsibility of the party at fault to report the incident. Thus the closest approximations of hazardous waste disposals are the polluter's records. On Tulane's campus there are several departments which handle hazardous materials. The Environmental Health and Safety department has guidelines on the handling and disposal of wastes, but the actual adherence to these standards remains uncertain. The vehicular maintenance department of physical plant is responsible for the disposal of several potentially hazardous wastes. The department maintains that the materials are collected and placed into tanks unseparated, which are collected by Westside Oil Company. Specific figures were unavailable concerning the exact amount of the waste that was disposed. The physical plant is also responsible for the maintainance of the grounds. Insecticides are used rarely and used for specific pests rather than blanket spraying. The ones used are not supposed to be toxic to mammals and are not used while bees are pollinating. The fungicides are reportedly used very rarely but are not environmentally friendly as they contain carbon tetrachloride. The herbicide most used is Round-Up which is not an environmental problem as it breaks down quickly. MSMA is used at certain times and doesn't have much residual effect. Others are used very rarely and in limited quantity. Fertilizers are used to some extent and their effects are seen in the nutrification of surrounding waterways.
For the janitorial work on its facilities, Tulane has contracted Jani King. Tulane and Jani King have very good existing guidelines for the disposal and handling for the cleaning products used. However, it is noted that there is a high turnover rate for the employees, and it is questionable whether they are sufficiently trained to handle the chemicals properly. Nearly all of the chemicals in use specify the use of gloves and goggles while in contact, and some of the floor strippers pose a significant threat to health (if not handled properly). In watching several of the employees it was discovered that gloves and goggles are rarely, if ever. Also none of the cleaning products are bio-degradable, and most of the containers are required to be rinsed thoroughly before disposal.
The chemistry and biology departments are other potential polluters. The chemistry department is currently conducting the first major inventory of chemicals used in their laboratories. (The inventory will not be completed until the end of the semester, according to Dr. Fields, the laboratory supervisor.)
Tulane has compiled a list of environmental guidelines for its departments and affiliates. These guidelines address various issues. One of particular relevance is the disposal of solid hazardous waste. Tulane indicates that any waste that exhibits ignitability, corrosivity, reactivity, or toxicity is a danger. As well, the wastes listed in 40 CFR 261, those that are a mix or solid and hazardous wastes, and those that are disposed of through burning before recycling are all designated to be disposed by the Office of Environmental Health and Safety (OEHS). Tulane has gone further to recommend specific guidelines and procedures. The following is an amended list of guidelines and procedures that Tulane personnel and authorized agencies are to follow:
a. Determine if the material is a hazardous waste.
b. Properly mark the waste according to hazardous waste classifications.
c. Notify OEHS that hazardous waste needs to be picked up or bring the waste to the hazardous waste storeroom in the Medical School to await proper disposal by a qualified agency.
d. If the waste is infectious, place it in a red bag for destruction in the TMC incinerator. If it is sharp, place it in a sharps container that can be obtained through the purchasing office.
e. Animal carcasses should be sealed in plastic bags and returned to the Vivarium for incineration.
f. If the hazardous waste must be stored, it should be handed over to OEHS for proper storage until enough material has been collected for bulking.
g. Recycle unwanted chemicals to others within the University who can use them.
h. Redistill solvents for reuse when possible.
Expanded guidelines for the classification and disposal of hazardous waste are listed in the Tulane University Policy and Procedure Manual.
As well as having a list for classification and disposal procedures, certain equipment must be employed in storage facilities:
a. P.A. system or manual fire alarm system
b. Telephone or two-way radio
c. Appropriate portable fire extinguishers within 10 feet of door outside storage area
d. Spill control and decontamination equipment
e. Water supply with adequate volume and pressure to supply water hose streams
The Fine Arts department has separate guidelines tailored to the unique needs of the department. A majority of these wastes are less of a direct threat to the persons in contact with them, thus the difference in some ways of disposal. The following is an amended list of guidelines:
a. Used solvents, towels, rags, and other flammable debris must be placed in approved waste containers and disposed of daily.
b. Large quantities of used solvents such as turpentine and other paint thinners must be transferred to DOT 35 gallon drums or other containers approved by OEHS.
c. Do not pour hazardous liquids into sinks or drains.
d. Handling of any art-related materials that are too hazardous for any exposure must be channeled through OEHS.
Tulane has a Hazardous Communication Plan and Policy. It is based on the Right to Know premise. Access to the written Hazardous Communication Program is available to employees, their designated representatives, and other parties having a need to view this document. However, it should be duly noted that as of yet, no information regarding inventories of hazardous materials usage has been provided to any of the authors of this particular document on the hazardous waste disposal of Tulane University.