Hazardous Waste Management

Bates College has created this plan as guidance to faculty, staff, and students who work with hazardous chemicals and hazardous wastes in laboratories. This plan also addresses regulatory obligations established by the Code of Federal Regulations (CFR) Title 40 Part 264 Subpart D and the Occupational Safety and Health Administration of the Department of Labor when it promulgated 29 CFR 1910.1450 (Occupational exposure to chemicals in laboratories), as well as several other applicable regulations.

This plan is for use by laboratory supervisors where “laboratory use” of hazardous chemicals and the generation of hazardous waste takes place. Laboratory Supervisors are required to develop lab specific Standard Operating Procedures (SOPs) for their work spaces. These procedures will address the use of specific hazardous chemicals and equipment or practices unique to their work space. Refer to Appendix D for a template which can be used to develop an SOP.

Research and teaching laboratories in Bonney Science Center, Dana Hall, and Carnegie Science Hall are subject to the requirements of this plan.

The following representatives of Bates College are responsible for establishing policies, providing resources and implementing the plan. See Appendix C for a listing of specific responsibilities for each role.

  • Senior Staff: responsible for approval of all Bates College policies.
  • Bates EHS: Emergency Coordinator (EC) as defined in the Chemical Hygiene Plan (CHP) and Hazardous Waste Contingency Plan (HWCP); EHS develops, maintains, and implements the CHP; assists Laboratory Supervisors with monitoring and compliance with the plan and with assessing risk, including certifying laboratory hazard assessments.
  • Laboratory Supervisors: responsible for developing chemical hygiene and standard operating procedures (SOPs) and hazard assessments for laboratories where they are conducting research or teaching; they are responsible for students, staff, or visitors who may be conducting maintenance or cleaning operations within their laboratory.
  • Chemical Hygiene Officer (CHO): Develop, review and revise the CHP. Train applicable lab employees and students, and manage waste disposal.
  • Employees: responsible for understanding and complying with laboratory SOPs where they are assigned to work.
  • Students: responsible for understanding and complying with SOPs in laboratories where they are working or learning.
Hierarchy of Controls

Hierarchy of hazard control is a system used in industry to minimize or eliminate exposure to hazards. It is a widely accepted system promoted by numerous safety organizations. This concept is taught to managers in industry, to be promoted as standard practice in the workplace. In order of importance, the hierarchy of controls is:

  1. Elimination: Physically removed the hazard—is the most effective hazard control.
  2. Substitution: Involves replacing something that produces a hazard (similar to elimination) with something that does not produce a hazard.
  3. Engineering Controls: These do not eliminate hazards, but rather isolate people from hazards (i.e. fume hood)
  4. Administrative Controls: Changes to the way people work through programs, policies, and procedures.
  5. Personal Protective Equipment: The least effective means of protecting people from hazards, and should only be used when all other controls cannot safely eliminate the hazard.
Storage of Chemicals

Hazardous chemicals must be properly labeled, segregated by hazard type and stored in appropriate containment. Hazardous chemicals may not be stored on shelve above work surface or above eye level. Refer to special precautions and protocols in Safety Data Sheets (SDSs). Storage areas will be routinely inspected to ensure safe conditions are maintained and hazards will be addressed immediately. Refer to Appendix E for chemical storage guidelines.

Flammables and Combustibles

The maximum quantities of flammable and combustible materials which can be stored in a laboratory are regulated by OSHA and NFPA 30 and 45. Proper containers are identified in these standards.

Materials will be protected from sources of ignition or reaction including but not limited to: open flames, smoking, cutting and welding, hot surfaces, frictional heat, sparks, spontaneous ignition, and radiation heat.

Hazardous waste may be generated through the experiments conducted in each laboratory. Once generated, it is stored in an appropriate sealed/labeled container, in secondary containment, in a designated lab hood/storage area such as the Satellite Accumulation Area (SAA). Incompatible wastes shall be stored separately. SAAs will be established and maintained in accordance with Appendix F.

No hazardous waste will be discharged to the sewer system via sink or floor drain without a license to do so. Bates College is NOT licensed for this.

The Laboratory Supervisor must characterize the waste by ensuring the container is properly labeled to reflect the contents, and will ensure the container used for waste storage is both appropriate, in good condition and compatible with the contents. Waste characterization is important to ensure proper waste storage and disposal, once the container leaves the SAA.

When containers in the SAA are full, they are transported to the corresponding Main Accumulation Area (MAA) and are logged in, dated, labeled, and stored until the next 90-day shipment takes place. MAAs will be established and maintained in accordance with Appendix G.

SAA inspections will be conducted and documented a minimum of once a week. MAA inspections will be conducted and documented a minimum of once a day. Inspections are documented using the form provided in Appendix H.

Laboratory supervisors will ensure that lab spaces are kept free of clutter or other tripping hazards or items such as sharp objects that could cause injury. This includes but is not limited to labs, exit corridors, storage rooms, instrumentation rooms, etc. Spaces should be kept clean and in a dry condition, unless warranted by research. Identified hazards should be marked and occupants of the space will be notified to avoid the area until repairs can be made. Any areas that need repair will be reported to Facility Services via the work order hotline at 786-6449.

Bates Facility Services will ensure that walking and working surfaces are designed to hold the intended load, or total weight of occupants and equipment. Qualified personnel will make this determination.

All Bates community members have a shared responsibility to ensure that egress pathways remain accessible and clear, to allow for safe building evacuation in the event of an emergency.

Ladders and stepstools used in a lab will be maintained in good condition in accordance with 29 CFR 1910.23(b) and (c), and will be inspected before each use. Any such equipment that is damaged will immediately be removed from service until it is either repaired or replaced. Ladders that will be used near energized electrical parts shall have non-conductive side rails.

The primary source of guidance for selection of personal protective equipment (PPE) shall be Safety Data Sheets. Laboratory supervisors are responsible for conducting hazard assessements and determining what type of PPE is required. Supervisors must also ensure that users are trained in proper care and use of required PPE. This includes, at a minimum, goggle, face shields, gloves, and aprons. Supervisors must ensure that required PPE is available in a variety of sizes and each user obtains a proper fit.

Defective or damaged PPE must be replaced immediately. Bates will provide PPE at no cost to employees. If fume hoods do not provide adequate protection and/or ventilation from chemicals or equipment being used, immediately suspend activities in the lab and contact to CHO/EC. See Appendix I for additional information on types of PPE.

Laboratory Supervisors must conduct orientation sessions for all employees and students during initial lab sessions. These orientations must address the location and safe use of emergency equipment and supplies. This included but is not limited to the following:

  • Eyewash Stations: must be kept clean and unobstructed. A person with chemicals in their eyes must be able to reach and activate the unit within ten seconds of chemical contact. Eyewash and emergency are located in each lab and storage area where chemicals are present. Each station should be flow checked monthly.
  • Safety Showers: chemical safety showers must accessible within ten seconds and be unobstructed at all times. A person splashed with a chemical must remain in the shower for a minimum of 15 minutes.
  • Fire Extinguishers: fire extinguishers are located within 50 feet of work spaces where fires might occur. Clear access to fire extinguishers must be maintained at all times. Extinguishers are selected and distributed based on the classes of anticipated workplace fires. Only trained personnel may use a fire extinguisher. Contact Bates EHS to schedule training. Fire extinguishers are inspected monthly by a licensed and certified inspector. Fire extinguishers are maintained in accordance with NFPA 10.
  • Sprinkler System and Fire Alarm Control Panel (FACP): all science buildings are sprinklered and have fire alarm control panel systems that is supervised by the Lewiston Fire Department dispatch. Inspections and maintenance of these systems is coordinated by Facility Services. Each system is inspected by a licensed and certified inspector.
  • Bates Emergency Response: all Bates emergencies are dispatched through the Security Office, which is staffed 24 hours every day, 7 days a week. For emergencies, Security can be reached:
    • by dialing 6111 from any campus phone
    • by dialing 207-786-6111 from any off-campus or cell phone, or
    • by using one of the blue light phones located near hazardous waste generating areas, or other blue light phone located throughout campus
  • Spill Kits: lab supervisors must ensure that appropriate spill kits and/or absorbent materials are available for their labs. Consult the SDS for recommended or required types of spill kits for chemical use.
  • First Aid Kits: lab supervisors may keep a basic first aid kit in their labs. First aid kits will not be maintained by EHS. Any incident requiring more than basic first aid should be reported to Bates Security, who will then dispatch Bates EMS or United Ambulance.

All hazards, real or potential, must be clearly marked with appropriate labels and signs per the CHP. Hazardous chemical container original labels must be maintained. Exception: Small containers of chemical preparations for teaching laboratories which are created and controlled by the Lab Supervisor do not need compliant labels as long as they are removed from the lab at the end of the teaching session. Exit signs and emergency equipment signs must be visible and maintained in legible condition. Hazardous waste storage areas (SAA and MAA) must have appropriate MEDEP or EPA required signs and labels.

Any chemicals leaving the science building for shipment off campus, must be labeled per Department of Transportation (DOT) requirements and the package must include a safety data sheet.

Standard Operating Procedures (SOPs) prepared by laboratory supervisors are intended to provide guidelines for safe handling of hazardous chemicals. This section addresses basic requirements for developing and implementing SOPs.

Format

SOPs must be clear, concise, and consistent. The standardized template provided in Appendix D will help laboratory supervisors to meet these requirements. This format should be used to create procedures for each specific class of hazardous chemicals (flammables, corrosives, toxics, oxidizers, or any other “particularly hazardous substances).

Laboratory Specific Standard Operating Procedure

Each laboratory supervisor must develop operating policies for their specific laboratory based on the materials and conditions that prevail there. These procedures should include, but not limited to, visitors, working alone, specialized emergency equipment or spill kits, personal protective equipment, chemical storage, chemical transport, chemical container labeling, spill response, waste storage, notification instructions, emergency response, and general housekeeping. These laboratory specific SOPs are to be used for initial training and must be readily available for review.

Periodic Inspections

SOPs must reflect changes that occur in laboratories and must, therefore, be reviewed at least annually. In lieu of changing a lab SOP a “Special Project SOP” may be created and used for the duration of the project. Special project SOPs must include a termination date or a review date. Laboratory supervisors are responsible for ensuring that SOPs are being followed. An inspection checklist is available in Appendix H for use in laboratory inspections. The CHO/EC has compliance review authority and must inform College Administration of lapses in laboratory compliance, SOPs, and College Policy.

Training Responsibility

Laboratory supervisors must ensure that employees and students who enter and/or use their laboratory are trained on the hazards in their lab. This training will generally use SOPs, both generational and lab specific, to explain the hazards and the appropriate precautions. To fulfill OSHA and College requirements all training must be documented. Documentation must include the date, the trainer(s)’ name(s), laboratory supervisor’s name, the lab room number, the building and the SOP title(s) used or a brief summary of topics covered. Documentation must be kept for five years and must be immediately accessible in case of regulatory inspection. See Appendix L for suggested training topics and a sign in form for documentation training.

All incidents/accidents involving hazardous chemicals or wastes shall be immediately reported to Bates Security at 6111. Use an office phone or emergency blue light phone located throughout the hallways. Security will contact the CHO/EC and Bates EHS, who will coordinate internal and external response as needed. Bates Security and Bates EHS maintains a list of Regulatory Authority phone numbers, and will make the actual notifications needed for any accident/incident.

Spills

  1. Use dedicated or universal spill kits to contain and absorb spills.
  2. Wear personal protective equipment (PPE).
  3. Make certain materials in the spill kit will not react with released chemical.
  4. Label the waste generated from the spill “Hazardous Waste”.
  5. Remove waste from site and store in the Main Accumulation Area.
  6. Log in the waste using the provided form located in the MAA.

Large quantity spills of hazardous materials will be collected, packaged, labeled, manifested and transported off-site by a Bates College Licensed Hazardous Waste Contractor.

Updated 1/27/26