Hazardous Waste
Hazardous waste rules are governed by the Resource Conservation and Recovery Act at the federal level, and various state-level regulations.
Anyone generating waste (even just copier paper) on behalf of the University of Houston-Downtown has a responsibility to determine the regulatory status of the waste. This means classifying whether the waste is a hazardous waste, and which (if any) characteristics or listings in the rules apply to a specific waste. The standard procedures for hazardous wastes generated at UHD can be found in the UHD Hazardous Waste Manual.
Anyone generating waste on behalf of UHD must determine the regulatory status of the waste. This includes:
- Classifying whether the waste is hazardous.
- Identifying applicable hazardous waste characteristics or listings.
- Maintaining documentation of the waste determination.
The EHS Office is available to assist with classification decisions and documentation management. Contact EHS at ehs@uhd.edu preferably before beginning waste-generating activities.
Characteristics of hazardous waste can include ignitability, corrosivity, reactivity, and toxicity. All of these terms have a narrowly-defined meaning that may not match information on product labels, safety data sheets, or other sources of information directly. These characteristics can apply to both used and unused wastes, and any physical or chemical changes entailed in use can make a difference in the characterization.
Toxicity is a particularly peculiar aspect to characterization because it really means certain quantities of contaminants or constituents are either present or absent based on a standardized analytical test. Not all toxic materials are characteristic for toxicity, and not all materials that are characteristic for toxicity would be considered toxic.
F-listed wastes are generally used materials, spent solvents (although some are materials that were produced using certain equipment that also produces particularly toxic and persistent materials).
K-listed wastes are from specific industries, the University is generally not involved in any of these industries, but some research may use wastes that would be K-listed if they were not sent to the University for research.
P-listed wastes are acutely hazardous wastes that apply only to unused materials, or portions of a material that are unused.
U-listed wastes are hazardous, and apply to unused materials as well. There may be more than one applicable U-listing for a waste, in contrast to P-listed wastes that generally may only have one at the point of generation except in special circumstances.