Office of Risk Management and Environmental Health and Safety

Hazardous Waste Management Manual

Purpose of Environmental Health and Safety

The purpose of the Environmental Health and Safety (EH&S) at the University of Northern Iowa is to promote good practices in matters relating to the health, safety and environment within the university.  UNI EH&S maintains a reference library on local, state and federal regulations and provides assistance to the campus in regard to and in interpreting these regulations.


The purpose of this manual is to assist university employees and students with the safe management and disposal of hazardous materials. The University Environmental Health and Safety Office coordinates training in hazardous waste management, identification of hazardous materials, waste minimization procedures and collection of and proper disposal of hazardous waste in accordance with federal and state regulations.

The goals of the hazardous waste management program are to:

  • protect the health and safety of university employees and students
  • protect the health and safety of the general public
  • protect the environment
  • comply with state and federal regulations

It is the responsibility of the department head to ensure their personnel are aware of any hazards associated with the materials they may be working with and are regularly trained in the proper use of personal protective equipment (PPE) that is necessary while handling hazardous material.  It is also the department head’s responsibility to ensure their faculty, staff and students are properly trained in university waste handling procedures.

Finally, the department head must expect all departmental personnel to follow these procedures.

Definition of Terms

The following are the definitions of some terms that are frequently used when dealing with hazardous chemicals and wastes.

Acutely Hazardous Waste - hazardous chemicals that have the ability to cause a harmful effect after a single exposure.  Such wastes are listed as P-wastes by the Resource and Recovery Act (RCRA).

Carcinogen - substance or physical agent that may cause cancer in humans or animals.

Corrosive - substance that causes visible destruction or permanent skin changes in human skin tissue at the point of contact.

Generator -where the waste materials come from and who is responsible for the waste.

Halogenated Waste -any waste that contains one or more of the following elements: fluorine, chlorine, bromine, iodine, or astanine.  If a waste is non-halogenated it does not contain any of these elements.

Hazardous Materials -any substance or compound that has the capability of producing adverse effects on the health and safety of humans and/or the environment.

Health Hazard -where there is statistical evidence that when a person is exposed to a chemical, he or she may develop acute or chronic health problems.

Ignitable -a solid, powder, liquid, or a gaseous waste that has a flash point of less than 140 ° F (60 °C).

Oxidizer -A substance that gives up oxygen easily to stimulate combustion of organic material.

Reactive Material-materials that are unstable or undergo rapid or violent chemical reaction when exposed to air, water or other materials.  These materials often generate toxic gases or vapors when mixed with water or exposed to pH conditions between 2 and 12.5.  Reactive materials can also form potentially explosive mixtures with water, and are capable of detonation or explosive reactions when heated or subjected to shock.

Secondary Containment - a berm, dike or containment unit used to contain waste in a storage area in case of spill.  It must be able to accumulate the volume of the largest container in the containment area.

SB-1 (Storage Building 1) -is the designated permanent hazardous waste storage facility for the University of Northern Iowa.

Waste Minimization Procedures

Institutions are encouraged by the EPA to explore alternatives that will minimize their use of hazardous chemicals.  Waste minimization not only saves the university money but also promotes a safer work environment by minimizing the possibility of harmful exposure and the chance of potentially dangerous accidents.  Possible minimization procedures are:

  • Maintain a proper inventory of chemicals.  This prevents ordering more chemicals than needed.  It also provides a system for the proper storage of chemicals as well.
  • Order on an “as needed” basis or only order when the supply is nearly depleted.
  • Never order in bulk unless it will be used in less than 1 year.  If you only need a few grams do not order one kilogram.  This ensures the chemical viability and reduces storage space.
  • When obtaining samples from a company, ask for only the amount you need to complete the project.  This prevents the excess from being declared as hazardous waste.
  • Substitute hazardous chemicals with non-hazardous ones.  Chemicals used for cleaning glassware such as chromic acid can be replaced with non-hazardous agents such as spark-leen or alconox.
  • Whenever possible do not mix non-hazardous wastes with hazardous wastes.  When this occurs the non-hazardous waste becomes hazardous.  Small quantities of hazardous wastes mixed with non-hazardous wastes will also increase the volume of waste produced.
  • Use non-mercury containing equipment. Order either alcohol or digital thermometers and barometers instead of those that contain mercury.  Mercury containing thermostats should be replaced with those that are digital.

Hazardous Waste Management

The University of Northern Iowa generates many different types of waste.

Examples of waste generated on the UNI campus are:

  • Flammable, toxic, reactive and corrosive waste from the Departments of Biology, Chemistry or Technology
  • Glazes containing heavy metals, paint and paint solvents from the Art Department and Paint Shop
  • Unused chemicals
  • Chemicals originating from Departmental cleanouts
  • Samples of Industrial Chemicals from the Industrial Technology Center

It is the generator’s responsibility to properly dispose of laboratory chemicals at the university. Building Services employees are not to handle these chemical wastes even if considered nonhazardous.

Definition of Hazardous Waste

Hazardous waste consists of those solid wastes which meet one or more of the specific characteristics listed below or are included in one of several EPA promulgated lists.  These wastes include: wastes from nonspecific sources (F list), acutely hazardous waste (P list), and hazardous waste (U list).  These lists can be viewed on the EPA website.

Hazardous Waste Characteristics

For a material to meet the hazardous waste criteria, it must meet one or more of the following criteria:

Ignitability – DOO1

Ignitable wastes are capable of causing or intensifying a fire through routine handling.  They must have one or more of the following characteristics:

  • must have a flashpoint of less than 140°F (60° C).
  • oxidizers such as nitrate salts and peroxides.
  • solid capable of causing fire through friction, absorption of moisture, or spontaneous chemical changes.
  • flammable gas such as hydrogen.
  • flammable liquids organic solvents such as toluene, acetone, and benzene.
Corrosivity – D002

A waste is classified as corrosive if it exhibits one of the following characteristics:

  • a liquid which has a  pH £ 2 or ³ 12.5 is classified as corrosive. (Local restrictions only allow pH between 5 and 9 to be placed in the sewage system.)
  • Has the ability to corrode steel.
Reactivity – D003

Wastes are determined to be reactive if one or more of the following characteristics are exhibited:

  • capable of detonating if heated or struck.
  • capable of detonating at standard temperature and pressure.
  • reacts violently with air or water.
  • is a cyanide or sulfide bearing compound that have the potential to form toxic gases, vapors or fumes between a pH of 2 and 12.5.
  • forms explosive mixtures with water.
  • generates toxic gases, vapors, or fumes when mixed with water.
  • Normally unstable and undergoes violent change without detonating.
  • DOT explosive
Toxicity – D004-D043

Wastes are determined to be toxic if one or more of the following characteristics are exhibited:

  • determined to be toxic by the Toxicity Leachate Characteristics Procedure (TCLP).  The extraction procedure shows regulated concentrations of one or more of the 39 constituents. This list may be viewed at the EPA Website.

Management of Specific Waste Types

The following are recommended techniques and procedures for dealing with specific types of wastes.  If there are any questions please contact the Environmental Health and Safety Office.

Nonhazardous Waste

Liquid chemical wastes should never be poured down the sink or solid waste placed in the trash unless it is certain the waste is considered non-hazardous to human health or the environment.  Liquids determined as non-hazardous should be diluted at a ratio of at least 20 parts water to 1 part liquid waste.  Non-hazardous solids should be placed in separate receptacles double lined with trash bags and labeled as non-hazardous waste.  Chemical waste should never be placed in normal trash cans.  If it is not certain whether the chemical is hazardous, contact the Environmental Health and Safety Office.

Acids and Bases

The following are the recommended procedures for the neutralization of dilute acids such as hydrochloric, sulfuric and nitric acids and dilute bases such as ammonium hydroxide.  The neutralization of experimental procedures whenever possible.

  • Do not neutralize acids such as hydrofluoric, perfluoric and chromic acid.  These acids are either highly toxic or considered a strongly oxidizing acid and are collected by EH&S.
  • Perform steps slowly and ensure you are wearing chemical splash goggles and proper gloves. 
  • Keep containers cool while neutralizing.
  • Add acid to water; never water to acid.
  • Perform in large plastic beaker or pail.
  • Acid neutralization: add acid to large amounts of ice water and base (sodium carbonate, calcium hydroxide, or 8 M sodium hydroxide)
  • Base neutralization: add base to large amounts of water in a large plastic beaker then add a solution of 1 M hydrochloric acid.
  • Neutralize until reaction is completed or between pH 5 and 9 then flush with at least 20 times the volume of the waste being poured.
Hazardous materials
High Hazard Chemicals

These chemicals are those that require some sort of neutralization prior to being shipped for disposal.  These include certain peroxide forming compounds, organic peroxides, reactive azides, class 4 oxidizers, and multinitrated compounds.  If there is a question whether a chemical is one of those listed above, please contact the Environmental Health and Safety Office.  Such material will be specifically dealt with according to the instructions of the Hazardous Waste Vendor contracted by the University of Northern Iowa.

Unwanted Chemicals

If it is determined that a chemical or chemicals do not have any further use within the department or have expired, please record the list of chemicals you wish to dispose of on the form in Appendix A and forward it to the EH&S office.  EH&S will collect all unwanted chemicals for possible campus redistribution or ensure they are properly disposed of.

Solvent Wastes

Halogenated (chloroform and methylene chloride) and non-halogenated solvents (such as propanol, toluene and methanol) should be kept separate whenever possible.  EH&S collects all solvent wastes.

Organic Wastes

Whenever possible, halogenated and non-halogenated organic wastes should be kept separate.  Solid wastes should be kept separate from liquid wastes.  EH&S collects all hazardous organic wastes.

Inorganic Wastes

Inorganic wastes containing compounds of silver, mercury and chromium should be kept separate when possible from other types of waste and placed in their respective containers.  Waste containing barium, lead and cadmium may be mixed with each other.  EH&S collects all hazardous inorganic wastes.

Restricted Wastes

Chemical wastes containing elements of nickel, zinc, or copper, with the exception of those containing nitrate salts, are not considered hazardous wastes by the EPA; however, these chemicals are designated as ‘Restricted Waste’ under the Harmful Waste Ordinance from the Cedar Falls Department of Public Works.  Restricted wastes are collected by EH&S.

Aerosol Cans

Empty aerosol cans in which both propellant and liquid have been completely depleted may be placed in the trash.  All others are collected by EH&S.

Gas Cylinders

Compressed gas cylinders and propane tanks should be returned to their suppliers.  Full or partially full lecture bottles and in good condition should be redistributed to other areas in the college. Those lecture bottles which are no longer needed and are not returnable to the vendor or lecture bottles exhibiting signs of deterioration will be collected by EH&S.  If gas is no longer present with the regulator valve fully open, the cylinder may be discarded in the university refuge containers.  The regulator must be removed to show that the cylinder is indeed empty.

Paint Waste and Stains

EH&S collects all paints and paint products.  This includes inks, stains, oil based, latex and acrylic paint.

Rags and Paper Towels

Paper towels used for cleanup of paints and oil may be thrown away in university refuse containers so long as no free flowing liquid remains   Paper towels may be wrung out to ensure all liquid is gone.  Remaining paint or used oil should be disposed of in appropriate containers which are collected by EH&S.  EH&S recommends using cloth rags in place of paper towels for these may be cleaned by an approved cloth cleaning service. 

Art Supplies

Many chemicals, glazes, paints and inks contain solvents or heavy metals.  These are collected by EH&S staff.


Nanoparticles and materials must be considered toxic waste even though the properties have not yet been fully investigated.  EH&S staff collects all nanomaterial waste.

Photographic Waste

Some fixers, developers, stabilizers and old film are often considered hazardous waste depending upon chemical constituents.  Contact EH&S for a proper waste determination and proper disposal method. Old and spent photographic film may be recycled for its silver content. Blanket wash is considered hazardous waste. EH&S collects all photographic waste.

Unknown waste

Every effort should be made to determine contents of waste containers; however, if unmarked or unlabeled containers are discovered, the container will be labeled with university EH&S Waste Description Tags.  Name of product will be marked as “Waste for Characterization.”  This will notify EH&S that a waste characterization needs to be determined.  EH&S will contact the approved vendor for waste characterization. 

Hazardous Waste Packaging and Labeling

Container requirements

The importance of proper containers cannot be overemphasized.  Containers that are not compatible with the type of waste pose a significant danger to university employees, students and the general public.

General Guidelines

The following is a list of guidelines for selecting and managing proper containment for hazardous waste.  If wastes are not placed in accordance with the following rules, collection will not take place until the situation is remedied.

  • Container must be compatible with waste (see Container Selection), clean, and in good condition.
  • Container cap must be screw type, tight fitting and lined and in good condition—corks and stoppers are not allowed.
  • The container must have proper head space-1.5 inches for wide mouth containers, 3 inches for tapered or boston round containers.
  • The container must be labeled appropriately.
  • Barrels, carboys and safety tins should be no more than 4/5’s full and in good condition.
Container Selection

The following criteria have been established for the collection of hazardous materials and should be strictly observed.

  • Original chemical containers are considered acceptable for use in disposing of hazardous and non-hazardous liquids and solids.
  • Solid Wastes-place in original containers, place in plastic pales or wide mouth plastic high density polyethylene (HDPE) bottles or chemical glass containers.
  • Aqueous solutions: glass bottles and HDPE plastic bottles. 
  • Plastic milk jugs, glass stoppered bottles, plastic soda bottles and food containers are not considered acceptable waste containers.
  • Metal cans are never considered as a method of collection of corrosive materials
Mixing of wastes

It is extremely important not to mix incompatible chemicals and substances together.  The result could be fire, explosion or the generation of toxic or flammable gas.  It is recommended to always separate waste by hazard class and always consult the Safety Data Sheet before combining different types of wastes.

Proper labeling

It is important that hazardous waste be labeled for several reasons. 

  • Protect the safety of university employees and students.
  • Ensure regulatory compliance with OSHA and the EPA.
  • Keeping waste from being mixed with incompatible material.
  • Improves handling efficiency.
  • Labels must contain the complete chemical name of the container.  Chemical formulas and/or symbols are not acceptable.
Waste labeling

EH&S tags may be found at departmental offices or by contacting the Environmental Safety Specialist via email or by phone at 3-3445. The green tags are for use with waste chemicals, containers with deteriorated labels or ones that are poorly labeled. Waste container labels are not needed for un-wanted chemicals or for sample size containers. The following information must be filled out by the generator: 

Front Side of Tag
  • Check either Hazardous Waste or Non-Hazardous Waste using the hazard information given to you by the Hazardous Waste Management Manual, the Safety Data Sheets or by the label or labels of the original container.
  • The approximate amount of waste that will be offered either when the container has been filled or when collection of waste is completed.
  • The Start Date is when collection of waste begins.
  • The name of the person and phone number who is ultimately responsible for the waste being accumulated.  This person must either be a staff or faculty member.
  • The building and room number, department and departmental mailing code where the waste is generated.
  • Circle all pictograms that represent the hazards of the waste that is generated.  This can be determined again by the SDS sheet.  Below is each pictogram and its associated hazard.
Back Side of Tage
  • Place the full name, and the amount or percentage of each chemical that is in the container.  Chemical symbols or abbreviations are NOT acceptable.  
Waste Storage

Waste materials should always be stored in a cool, dry location separated by hazard class.  Waste storage areas should be locked when not manned.

Packaging requirements

In order for chemical waste to be safety transported to the permanent waste storage facility, guidelines have been developed by the University EH&S Office.

The guidelines are:

  • Compressed gas cylinders will only be transported with valve caps on.  Lecture bottles must be packed in a sturdy shipping box packed with packing peanuts.
  • Pump and hydraulic oil should be collected separately and poured back into their original containers or collected in 5 gallon safety cans and labeled as “Used Oil.”
  • Drums, safety cans and pails that are used for hazardous waste do not require any additional packaging to be transported to the permanent waste storage facility (SB-1).  Safety cans and pails must have handles for transport.
  • Container must seal tightly.  If unsure apply a virtual “Tip Test.”  If the container were to tip over, would the container leak.  Parafilm, plastic wrap, aluminum foil, or duct tape are not considered an acceptable means of closure
  • A SDS sheet must be provided for every known type of hazardous waste that is shipped.
Request for Hazardous Waste Pickup

When hazardous waste is ready for pick-up, complete the form found on Appendix A. When received, the waste will be inspected for proper labeling and containerization to ensure it is ready for transfer to the permanent hazardous waste storage facility (SB-1).  EH&S will then either pick up the waste or make arrangements to have Transportation complete the transfer.

Universal Wastes

All rechargeable, lead acid and automotive batteries must be collected for recycling.  Alkaline batteries may be recycled or placed in the trash. 

Recycling locations are as follows:

  • ROD library entrance, Schindler Education Center main lobby, CEEE atrium, Wellness and Recreation Center front desk and Maucker Union Administrative and NISG office.  Call2recycle boxes located in these areas are strictly for used cell phones, rechargeable tool batteries, computer batteries.  These containers are provided by the Recycling Reuse Technology Transfer Center and mostly used by the student population. (University staff are strongly encouraged to use the recycling services provided by the University Physical Plant.)  Batteries collected in these boxes must be placed in the supplied plastic bags.
  • ITT 120. Small rechargeable (esp. computer batteries) and non-rechargeable batteries.  This container when full will be turned into the University Physical Plant Electric Shop.
  • The Physical Plant Electric Shop.  Batteries including lead acid, rechargeable tool, computer, leaking or otherwise deformed batteries, campus radio batteries and non-rechargeable batteries such as alkaline and zinc. 
  • Car pool. Collection of automotive batteries.

For batteries collected in ITT 120, the electric shop, and the motor pool shop, the battery leads must be taped with electric tape or covered according to DOT regulations.  Leaking or otherwise deformed batteries must be placed in their own individual container and appropriately labeled.  

Lamps, Mercury Containing Items, and Pesticides

Fluorescent lamps, LCD projection lamps, mercury containing items, and pesticides are considered universal waste. Fluorescent lamps are collected by building custodians and placed in their original shipping containers for recycling.  LCD projection lamps should be packed in their original containers and shipped to the Warehouse-0196 for recycling.  Mercury containing items and pesticides are designated ‘Universal Waste’.  These wastes should be properly packaged, sealed and collected for transport to the permanent waste storage facility (SB-1). Universal waste labels (shown below) should be affixed to the container.

Light Ballasts

Light ballasts collected by university staff should be placed in properly labeled containers and transported to the Electric Shop. The ballasts will be transferred to SB-1 for sorting PCB and Non-PCB ballasts.  PCB ballasts will be disposed of using UNI’s approved vendor. Non-PCB ballasts are collected by a local vendor for recycling.

Oil Waste

When disposing of oil and associated oil waste in the laboratories, such waste should be placed in suitable plastic or safety tins and labeled as “Used Oil” and collected for transport to the permanent waste storage facility (SB-1).  Used oil generated as a result of vehicle or building maintenance should be collected in suitable plastic pails or drums and labeled as “Used oil.”  Oil filters shall be punctured and drained and will be placed in a 55 gallon drum labelled as “Used oil filters”. Oil and filters from maintenance will be picked up at a later date by an approved vendor.

Miscellaneous Waste
Appliances and Laboratory Equipment

Nonworking appliances such as stoves, microwaves, refrigerators and freezers must be thoroughly decontaminated by user prior to disposal.  Arrangements for pickup must be made through Transportation Services.  Under NO CIRCUMSTANCES are these items to be disposed of in University dumpsters. If the appliance was used in radionuclide research use with Biohazard materials or for storage of such material or for use with Biohazard materials, disposal must be approved by the University Radiation Safety Officer.  Laboratory Equipment such as centrifuges, analytical equipment and heating equipment are considered an appliance and will be disposed of in a similar fashion. The Department of Residence maintains its own program for disposal of appliances.

Ink Cartridges

Empty or obsolete ink cartridges from ink jet printers and plotters should be sent to the University Warehouse at mail code 0196 in order to be recycled. Please mark the cartridge with the word “recycle” prior to sending it.                                                                       

Laboratory Sharps and Biohazardous Material

Please follow the University Laboratory Sharps and Biohazardous Waste Procedures

When disposing of broken glass, syringes, needles and infectious material.


Antifreeze found to be contaminated with other hazardous material (often found in laboratory equipment such as immersion coolers and recirculating chillers) will be collected by EH&S. Used antifreeze generated that is known not to be contaminated with other chemicals or is part of building or automotive maintenance will be collected in 55 gallon drums labeled as “Used antifreeze” in the motor pool maintenance area. The contents of the drums will be picked up at a later date by an approved vendor.

Hazardous Waste Satellite Accumulation Area Requirements

Satellite Accumulation Area Posting

The Environmental Protection Agency defines a Satellite Accumulation Area as a storage area near the point of generation and under the control of the operator of the process generating the waste.  In order to be compliant with this definition, waste accumulation can only occur in the laboratory or in the same suite of laboratories where the waste is generated.

All areas where hazardous waste will accumulate and be stored will be posted with the sign ‘Hazardous Waste Satellite Accumulation Area’ which contains emergency contact information, container compatibility rules, requirements for labels, UNI EH&S contacts and proper disposal procedures.  Hazardous waste needs to be accumulated in the same area (either the same lab or lab suite) in which they are generated.  Such areas should be locked when not manned.

At the University of Northern Iowa in order to be compliant with EPA regulations and to maintain a safe working atmosphere the following rules have been established.  These rules must be posted in all designated Satellite Accumulation Areas.

Hazardous Waste Satellite Accumulation Area

Rules and Responsibilities

Generator Responsibility

  • The generator is responsible for making hazardous waste determinations.  If assistance is required contact EH&S.
  • The generator will provide the necessary SDS sheets for each type of hazardous waste generated.
  • The generator will provide the necessary shipping containers in order for Transportation to transfer hazardous waste to the permanent hazardous waste storage facility (SB-1).

Accumulation Containers

  • Ensure waste is accumulated in proper containers (Check Hazardous Waste Manual).
  • Ensure container is properly closed when not in use.
  • Ensure Accumulation Containers are allowed adequate “head space.”
  • Ensure outside of waste containers are kept clean.
  • Liquid waste containers should be in secondary containment.

Label All Containers

  • Label containers with approved waste labels.
  • Identify hazardous materials/constituents of containers (Do not use generic or trade names).
  • Write date when satellite accumulation begins. Notify EH&S that accumulation has begun and the size of the accumulation for that container.

Accumulation time

  • Never accumulate more than 55 gallons of hazardous waste or 1 quart of acutely hazardous waste on site.
  • The generator is responsible for ensuring waste is moved to the permanent hazardous waste storage facility (SB-1).
  • Where possible transfer full containers to the permanent hazardous waste storage facility (SB-1) and lab storage areas are transferred to the permanent hazardous waste storage facility (SB-1).

Satellite Accumulation Area Requirements

  • Satellite Accumulation Areas must have readily available spill kits.
  • Satellite Accumulation Areas are at or near the point of generation
  • In room or same suite of rooms
  • Room must be locked

Generator control

  • If one or more generator shares the same satellite area, each generator is responsible for their waste.


For questions regarding waste determination, lab cleanouts or training contact the University EH&S Office


Program in PDF Format

Manual originated 6/2008

Updated 10/2017