Waste management and shipping

EHS hazardous waste management team ensures compliance with the ASU’s various environmental and hazardous waste regulations and manages regulated waste.

The team performs waste minimization and resource conservation, focusing on reducing the volume and toxicity of hazardous waste materials and waste generated on campus.

Hazardous waste may be generated from laboratory operations, facilities operations and maintenance, construction and renovation activities, photo processing and other activities at ASU. Hazardous waste management procedures, including waste identification, storage, packaging, manifesting, shipping, disposal, reporting, records keeping and training that apply to state, federal and local requirements

Please inspect your waste periodically to ensure that containers are closed and free of leaks. Environmental Health and Safety maintains all waste records.

Biological, hazardous and universal waste is routinely picked up Monday through Friday. Complete the following steps to schedule a waste pick-up:

1. Do not fill the waste container beyond the bottom of the container’s neck to avoid spills.
2. Complete a hazardous waste tag and attach it to your waste container.
3. Fill out the online hazardous waste pick-up request form. 
4. Note: If you have waste in one location that totals more than 55 gallons or a total of one quart of all acutely hazardous waste, add a note in the comments section of the request to ensure proper pick-up support.

Applicable guidelines

• ASU biological waste handling procedures.
• Chemical hygiene plan.
• Hazardous waste management compliance guidelines.

Applicable regulations

• Arizona Administrative Code, Article 14, Biohazardous Medical Waste and Discarded Drugs.
• NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acids.
• U.S. Department of Labor, 29 CFR § 1910.1030, OSHA Blood-borne Pathogens Exposure Control.

Summary of requirements

Regulatory requirements applicable to generators of biological waste include the following:

1. Biological wastes such as blood, body fluids, tissues, tumors, human cell lines, recombinant or synthetic nucleic acids, bacteria, and other microorganisms should be placed in red or orange bags and autoclaved. Autoclaved bags should then be placed in a red bag or red drum for hazardous waste personnel to pick up.
2. EHS requires that nothing hazardous goes in the trash or down the drain. All liquid biological waste must be labeled with a hazardous waste tag and treated as chemical waste.
3. EHS may require the use of a yellow drum instead of a red drum. EHS will determine when a yellow drum is needed. Biological waste placed in yellow drums must be bagged.
4. Sharps such as needles, syringes, pipettes, pipette tips, scalpels, slides and coverslips must be placed in a rigid, leak-proof, puncture-resistant container with a secure locking cap.
5. When a red drum, yellow drum, sharps container or liquid hazardous waste is ready for removal, please submit an online hazardous waste pick-up request.

Applicable guidelines

• Chemical hygiene plan.
• Hazardous waste management compliance guidelines.

Applicable policies

• EHS 401: Hazardous waste management.

Applicable regulations

• 40 CFR parts 260 through 271.
• A.A.C. R18-8-260 et seq.

Summary of requirements

Regulatory requirements apply to generators of hazardous waste.

• Waste containers: Containers are available through EHS and must be clean and compatible with the waste being stored and kept closed at all times except when adding waste.
• Labeling: Containers that store hazardous waste must be properly and clearly labeled. Containers must:
  • Be marked with the words hazardous waste.
  • Include the name and amount of each waste constituent in the container. The total must equal 100%.
  • Include the physical state of the waste, such as solid or liquid.
  • Include the hazard class or category of the waste, such as corrosive, flammable, toxic and reactive.
• Hazardous waste tag: Waste tags are available through EHS, and each container must have a completed hazardous waste tag attached before EHS picks it up.
• Satellite accumulation: Hazardous waste accumulation in the lab must be at or near the point of generation and under the control of the person generating the waste. Satellite accumulation containers must be closed at all times except when waste is being added to the container.
• Nothing hazardous goes down the drain, and nothing hazardous in the trash.
  • All chemical waste is considered hazardous waste.

EHS will help classify your shipment, complete shipper declaration forms, commercial invoices and FedEx airway bills, assist with package selection and consult about international shipments and customs requirements.
 
Before submitting the request to EHS, email the Office of Industry Research and Collaboration to see if a material transfer agreement is required.
 
International shipments may require export permits, and the recipient may require import permits. Please plan accordingly. Please email the ASU Office of Research Integrity for international shipments only for a pro forma BOL.

Anyone shipping packages using dry ice must complete the EHS dry ice training before shipping.

ASU uses a large variety of electronic lamps. The Environmental Protection Agency considers spent lamps hazardous, and used lamps are known as universal wastes. Examples of standard electronic lamps that are universal wastes include intact fluorescent, high-intensity discharge, neon, mercury vapor, high-pressure sodium, metal halide lamps and incandescent lamps. The hazardous constituents of concern in electronic lamps are the heavy metals used in manufacture, such as mercury and lead.

The EPA regulates universal wastes under the Resource Conservation and Recovery Act, which is the same law that defines hazardous waste. This rule streamlines the hazardous waste regulation requirements for hazardous waste lamps. Electronic lamps must be handled correctly; EPA and state regulators consider unmanaged lamps hazardous waste.

Applicable guidelines

• Hazardous waste management compliance guidelines.

Applicable policies

• EHS 401: Hazardous waste management.

Applicable regulations

• 40 CFR part 273.
• A.A.C R18-8-273 et seq.

Summary of requirements

Regulatory requirements apply to generators of universal waste. Complete the following steps to handle mercury-containing lamps properly:

1. Carefully remove the lamp from the light fixture.
2. Place the lamp into the cardboard box or sleeve from which it arrived. Cardboard drums are also provided for this purpose.
3. Fold over end flaps and close with appropriate tape.
4. Mark the container appropriately with the words used mercury lamps and generation date.
5. Carefully move the filled and labeled container to the campus accumulation point for this waste in a manner designed to prevent lamp breakage or submit a hazardous waste pickup request.

 Employees who work with biological and chemical materials, ship dry ice or work in academic and research labs must complete training, including an annual refresher.

Those who have the potential to be exposed to bloodborne pathogens should complete the basic Bloodborne pathogens training. Those who handle, use and work with biologicals must complete the Comprehensive Biosafety Tri-University training.

Please use the EHS Training Determination Tool if you have questions about specific training requirements. Visit the EHS training webpage for more information.