Hazardous Waste Generation & Management
I. The Issue:
The proper management of hazardous materials and waste is necessary to promote occupational safety and to prevent environmental degradation. Unfortunately, the issue is frequently left to chance in many local schools. As a result, students and faculty are routinely placed at risk by dangerous storage and handling practices, and often times hazardous chemicals are released to the environment via improper disposal to sanitary drains or as solid waste. Many of these problems can be readily resolved by educating your students and staff so that they can identify hazardous materials which require special handling and disposal. In addition, each school system should establish a standardized set of procedures for coordinating the collection and disposal of hazardous waste generated by all departments within the school district. As part of this effort, the school system should also review and investigate methods available for reducing or eliminating the generation of waste in the first place. The following is a discussion of the steps taken to improve hazardous waste management within the Burlington school system.
II. The approach taken:
Our effort began with a comprehensive assessment of the chemical inventories maintained by each section of the school system as well as the waste streams generated by their activities. This enabled us to determine the types and volume of waste being generated by the school system. At the same time, we also made efforts to learn how the school department had historically managed these materials.
Based on this initial analysis, we noted a general lack of staff knowledge with regard to the needs and requirements associated with hazardous waste management. We also determined that hazardous waste could potentially be generated by nearly all divisions of the school system. Most importantly, we realized that the school department did not have a standardized and consistent method for identifying, consolidating and properly disposing of its hazardous waste.
In response, a centralized hazardous waste collection program was adopted by the school department along with procedures promoting the safe and proper disposal of these materials. As part of this effort, a central secured hazardous waste storage area was established to promote the consolidation and storage of these items outside the areas frequented by the students. In addition, we provided the staff with training in terms of how to identify potentially hazardous waste as well as a description of safe and appropriate methods of disposal.
III. Observations made:
Records indicate that the high school science department may have routinely disposed of their chemical waste via the sanitary sewers. In 1971, the science department sought information from local agencies describing the local sewer system with the purpose of optimizing the dilution of materials they discharged via the sanitary sewer system. In 1986, an explosion occurred at Burlington High School when aluminum phosphide, a water reactive material, was discarded via a lab sink. This explosion damaged the sanitary drains and a cinder block wall at the school. In addition, poisonous phosgene gas was generated by this reaction and released into the school.
During our review, we were unable to locate any records which indicated how the school department disposed of hazardous waste prior to 1991. Part of this problem is related to poor records management, but a portion of the problem was that chemical wastes were not routinely managed in a controlled manner.
Initial surveys of the staff indicated that many had a limited understanding of the health and safety concerns, and regulatory requirements associated with hazardous waste management. As a result, past hazardous waste management activities may have impacted indoor air quality and occupant safety, or resulted in an environmental release.
Another observation was that the school department did not have standardized disposal procedures or guidance for staff use. Chemical disposal was left to individual interpretation and initiative, consequently, a variety of methods were used by the staff to manage the chemical waste generated by the school system. The development of a standardized hazardous waste management plan assisted our efforts to consolidate and safely dispose of the chemical wastes generated by the school department.
The completion of a comprehensive chemical review allowed us to consolidate and coordinate the disposal of similar waste streams. This approach allowed us to increase the efficiency of our chemical disposal activities and to reap additional cost savings by improving the efficiency of our waste disposal activities.
A complimentary process has been the slow conversion to less or nontoxic alternatives along with increased chemical recycling and the adoption of microscale science programs. The implementation of these practices has enabled us to reduce our waste streams. In addition, this approach has improved the health and safety of school occupants, enhanced indoor air quality, decreased chemical disposal costs, and decreased long term liability for the town.
IV. Problems or concerns noted:
- Existing information suggests that the school department may have inappropriately managed their chemical wastes prior to 1991.
- A lack of guidance and training may have prompted the staff to develop and utilize a variety of creative and questionable disposal practices.
- The lack of hazardous waste disposal guidance also prompted some staff members to store and accumulate hazardous waste in their classrooms.
- In addition to chemical wastes, many other classroom items may need to be properly managed or recycled due to potentially hazardous components (e.g. fluorescent lights, computer components, ballast's and capacitors, mercury switches). This needs to be considered before obsolete equipment is discarded.
- The failure to coordinate waste disposal activities resulted in the issuance of multiple generator identification numbers to the school department. This could have resulted in a variety of compliance problems for the school district.
V. Actions taken:
A. Evaluated existing waste disposal practices and developed new hazardous waste disposal practices. Historically, hazardous waste disposal had been left to the creativity and initiative of each individual staff member. As a result, many byproducts were either managed inappropriately or were accumulated within the local schools. We resolved this problem by developing a centrally coordinated hazardous waste disposal plan. Our approach requires each department to identify and properly collect and label their hazardous waste. Where possible these materials are temporarily stored in a secure satellite hazardous waste storage area located within each department or school. Then at periodic intervals these materials are relocated to a central hazardous waste storage area in the high school which is located away from the areas frequented by the students. Hazardous wastes are immediately transported to the central storage area for those departments where temporary storage is not possible. This approach has improved our ability to properly dispose of the hazardous waste generated by the school department in a safe and cost effective manner. This method has also enable us to establish departmental responsibilities as well as identify potential problem areas.
B. We trained the staff with regard to the need to and method for managing hazardous waste. During our evaluation, we found that the staff had a limited understanding in terms of what was a hazardous waste and how and why it should be managed. We provided the staff with training in how to identify and manage their wastes. As a compliment to these efforts, we have also promoted the adoption of nontoxic or less toxic alternatives as a means to reduce the volume or toxicity of the waste generated by the school department.
C. We established a central hazardous waste storage area. We have designated a secure storage area located away from the student population as a hazardous waste accumulation area. This approach enables us to coordinate the consolidation and efficient disposal of all the waste streams generated by the school system. We have also been able to improve school health and safety by reducing the risk of accidental contact with the materials while also reducing the potential impact on indoor air quality.
D. We have incorporated the management of universal wastes with our hazardous waste disposal program. As required by state and federal regulation, we have included the management of all universal wastes (e.g. fluorescent lights, ballast's and capacitors, mercury switches, computer components) with our routine hazardous waste disposal activities. This approach will enhance our ability to promote regulatory compliance and decrease the risk of a release to the environment.
1. If you don't provide the staff with guidance describing how to identify and manage their hazardous waste then they will develop their own methods. The creativity and ingenuity of the staff may not always be safe or legal.
2. We found that hazardous waste is generated at each local school regardless of grade level. As a result, your hazardous waste management plan and training efforts must be comprehensive in order to include all materials generated by your local schools.
Tips and suggestions:
1. Identify all your waste streams and remember to include universal waste items.
2. Store your hazardous wastes in a secure storage area located away from areas frequented by the student population.
3. Review and inspect obsolete equipment prior to disposal to ensure that it does not contain hazardous components that need to be recycled or disposed of as hazardous waste. Potential items of concern include: batteries, ballasts, capacitors, mercury switches, cathode tubes, computer components, and lamps.
4. Train and inform your staff of your hazardous waste management procedures. Their support and participation is necessary for your efforts to be successful.
5. Promote methods to eliminate, conserve or recycle the hazardous materials in your inventory as a means to decrease the volume of hazardous waste generated by your school system. This approach can improve the health and safety of your schools while also decreasing your disposal costs.
State environmental and public health agencies, and the regional office of the U.S. Environmental Protection Agency are valuable resources when reviewing this issue. Due to regional differences in hazardous waste management requirements, both state and federal agencies should be contacted to determine what requirements apply to your school district. Furthermore, local businesses, universities, and environmental groups may also be able to provide additional support and assistance.
prepared by Todd H. Dresser, Environmental Engineer
Burlington Board of Health, 29 Center Street, Burlington, MA 01803