Overall Rating Gold
Overall Score 72.89
Liaison Tom Twist
Submission Date Nov. 8, 2023

STARS v2.2

Bates College
OP-20: Hazardous Waste Management

Status Score Responsible Party
Complete 1.00 / 1.00 Tom Twist
Sustainability Manager
Facilities
"---" indicates that no data was submitted for this field

Does the institution have strategies in place to safely dispose of all hazardous, special (e.g. coal ash), universal, and non-regulated chemical waste and seek to minimize the presence of these materials on campus?:
Yes

A brief description of steps taken to reduce hazardous, special (e.g. coal ash), universal, and non-regulated chemical waste:

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:

Elimination: Physically removed the hazard—is the most effective hazard control.
Substitution: Involves replacing something that produces a hazard (similar to elimination) with something that does not produce a hazard.
Engineering Controls: These do not eliminate hazards, but rather isolate people from hazards (i.e. fume hood)
Administrative Controls: Changes to the way people work through programs, policies, and procedures.
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.

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.

Compressed Gas Cylinders
Compressed gas cylinders must be properly labeled and stored securely in accordance with guidelines specified in Appendix J. The label must indicate the type of gas. Empty cylinders must labeled as empty. All cylinders, including empties, must be secured to a wall or to the bench top. Incompatible gases must be stored.

When a cylinder is not in use for extended periods of time, close the valve, relieve pressure in the regulator, remove the regulator*, and screw the protective cap onto the cylinder.

* Exception: Lecture Bottles – regulators must not be removed until the lecture bottle is emptied and purged.

Segregate empty cylinders from full cylinders or, if possible, return them to the supplier within one business day. Segregate cylinders from other hazardous chemicals. Return unused gas cylinders to the supplier when finished with them.

Toxic Chemicals
Work areas in which toxic chemicals are used must be labeled with warning signs, for example “CAUTION – Reproductive Toxin Storage” or “CAUTION: Cancer-Suspect Agent Storage”. Access to areas where toxins are used must be controlled. Quantities of toxic chemicals must be kept to minimum. Highly toxic chemicals must be stored in a ventilated storage space within secondary containment. A current inventory list of highly toxic chemicals must be maintained and readily accessible.

Highly Reactive Chemicals
Follow the recommendations on the Safety Data Sheets when determining appropriate storage of highly reactive chemicals. Label and date each reactive chemical upon receipt. Labels must include the word “DANGER: Highly Reactive Chemical. Minimize the quantity of reactive chemicals stored in the laboratory. Store chemical containers within secondary containment with enough volume to hold the entire contents. Dispose of highly reactive chemicals before their expiration date. Do not use reactive chemicals after their expiration date.

Storage of Oxidizing Chemicals
Follow the recommendations on the Safety Data Sheets when determining appropriate storage of Oxidizing materials. Label and date each container of oxidizing chemical upon receipt. Labels must include the following wording “DANGER – Oxidizing Chemical”. Organic peroxides are some of the most dangerous oxidizing chemicals. If crystals or precipitate are present, do not open liquid organic peroxide or peroxide formers. Peroxides in this form are extremely unstable and could cause serious injury or death. Contact the CHO/EC for assistance in arranging for proper packaging, removal and disposal.

Since liquid peroxides are sensitive during phase changes, store organic peroxides at the lowest possible temperature consistent with avoiding the freezing point. Inspect and test peroxides periodically.

Store perchloric acid bottles in glass or ceramic trays.

Thermally unstable chemicals must be stored in a laboratory grade refrigerator or freezer with appropriate labeling, indicating the intended purpose.

Water Reactive Chemicals
Water reactive chemicals must be segregated from water sources. Refer to Safety Data Sheets for specific suggestions on storing water-reactive chemicals. Label and date each container of water-reactive chemicals upon receipt. Labels must include the following wording “DANGER: Water-reactive chemical”.

Maintain separation of reactive chemicals as follows:

Pyrophoric compounds separated from flammables
Oxidizing chemicals separated from reducing agents and combustibles
Perchloric acid separated from reducing agents
Strong reducing agents separated from readily reducible substrates
Storage of Hazardous Waste
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.

Walking and Working Surfaces
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.

Personal Protective Equipment
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.

Emergency Equipment
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.
Signs and Labels
All hazards, real or potential, must be clearly marked with appropriate OSHA, DOT, or NFPA labels and signs. 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.

Lockout/Tagout (LOTO)
Prior to any work on machines or equipment that could injure an employee by unexpected release of stored energy or unexpected startup or energization, lockout/tagout (LOTO) procedures must be followed.

The laboratory supervisor is responsible for developing a LOTO procedure for each piece of energized equipment and training students and other staff within their laboratory on the procedure. A template procedure in included in Appendix H.

LOTO ensures that all energy sources are removed, and prevented from re-energization so that work or adjustment on equipment or machines can be conducted safely. LOTO is required if an employee is required to remove or bypass a guard or other safety device, or if an employee is required to place any part of their body into an area on a machine or piece of equipment where work is actually performed (point of operation) or where an associated danger zone exists.

NOTE: LOTO is not required when the equipment can be unplugged from the energy source and the plug is under the control of the employee performing the servicing or maintenance. See 29 CFR 1910.147(a)(2)(iii)(A) for additional information on exemptions.

Use of lockout (de-energization) will be prioritized. If impossible, tagout (communication) will be utilized. Barricades or attendants will be utilized as necessary to protect employees or students from electrical contact hazards.

Please refer to the Bates College LOTO program or Appendix E for additional information.

Bloodborne Pathogen Exposure Control
Universal precautions shall be observed to prevent contact with blood or other potentially infectious materials. If it is not possible to determine the type of fluid, all bodily fluids shall be considered to be infectious materials. The lab supervisor will establish and train staff and students on engineering and work practice controls to eliminate or minimize employee exposure, with PPE being used if risk still remains after other controls are implemented. Staff and students will also be familiarized with the Bates Bloodborne Pathogens Exposure Control Plan.

All procedures involving blood or other potentially infectious materials shall be performed in such a manner as to minimize splashing, spraying, spattering and generation of droplets. Mouth pipetting/suctioning is prohibited.

Lab supervisors will ensure that all employees and students wash their hands immediately or as soon as feasible after removal of gloves or other PPE, and after any potential exposure or contact with potentially infectious materials.

Eating, drinking, smoking, applying makeup and handling contact lenses inside the lab is not permitted. Food and drink is not permitted to be stored near where blood or other potentially infectious materials are present. This includes refrigerators and freezers.

Specimens or samples containing blood or potentially infectious materials will be stored and transported in properly labeled, leak-proof containers. Labels will include the work BIOHAZARD and the biohazard symbol, and will be fluorescent orange or orange-red, with the letters and symbols in a contrasting color.

The lab supervisor will ensure that proper PPE is provided, replaced when necessary, cleaned or disinfected, and removed prior to leaving the lab.

Annual training for affected faculty and staff
Audits and inspections
Clear policy and program
Regulatory oversight

https://www.bates.edu/environmental-health-safety/health-safety/environmental-compliance/hazardous-waste-management/

https://www.bates.edu/environmental-health-safety/


A brief description of how the institution safely disposes of hazardous, universal, and non-regulated chemical waste:

Hazardous and universal waste is transported and disposed of via approved vendors, in accordance with DEP, EPA and DOT requirements.
Electronic waste is recycled (when feasible) with a local vendor.


A brief description of any significant hazardous material release incidents during the previous three years, including volume, impact and response/remediation:

None


A brief description of any inventory system employed by the institution to facilitate the reuse or redistribution of laboratory chemicals:

Both science buildings have a chemical stock room where available products are stored ready for use.
Staff members are available to assist faculty and students.
Inventory is maintained by staff, and updated regularly.


Does the institution have or participate in a program to responsibly recycle, reuse, and/or refurbish electronic waste generated by the institution?:
Yes

Does the institution have or participate in a program to responsibly recycle, reuse, and/or refurbish electronic waste generated by students?:
Yes

A brief description of the electronic waste recycling program(s), including information about how electronic waste generated by the institution and/or students is recycled:

Bates uses a local nonprofit, Give It Get It, which refurbishes old electonics to school-age students of need.


Is the institution’s electronic waste recycler certified under the e-Stewards and/or Responsible Recycling (R2) standards?:
Yes

Website URL where information about the institution’s hazardous waste program is available:
Additional documentation to support the submission:
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Data source(s) and notes about the submission:
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The information presented here is self-reported. While AASHE staff review portions of all STARS reports and institutions are welcome to seek additional forms of review, the data in STARS reports are not verified by AASHE. If you believe any of this information is erroneous or inconsistent with credit criteria, please review the process for inquiring about the information reported by an institution or simply email your inquiry to stars@aashe.org.