Schools generate many types of hazardous wastes in different areas of the school. Examples include the following.
|School Department||Hazardous Materials|
|Science Rooms and Laboratories||Flammable liquids (acetone)
Reactives (picric acid)
Toxics (cyanides, phenol)
|Technology Education (Graphic Arts, Printing)||Developers
Petroleum based inks
|Industrial Arts (Wood and Metal Shops)||Degreasing solvents
Petroleum based solvents
Glues and adhesives
Oil based paints
Schools should try to reduce or eliminate as many of their waste streams as possible. If a school is not generating a hazardous waste, the associated disposal costs, potential spills, potential health and safety hazards, and record keeping requirements will not be applicable.
School staff should know if their school is connected to a septic system or a sewer (sewage treatment plant or publicly owned treatment works). Often, teachers will neutralize a chemical used in a science experiment and pour the solution down the drain. School staff should be sure that this pretreatment is sufficient, as septic systems may not be designed to treat wastes, and chemicals released to the septic system may enter the groundwater. Should you have any questions on this topic, please contact Mitch Locker, DES Water Supply and Engineering Bureau, 271-2858. If the school is connected to a sewer line, the school should request permission from the local Publicly Owned Treatment Works (POTW) to discharge potential wastes.
A summary of the applicable NH Hazardous Waste Rules are outlined below to give schools an overview of the regulations that may apply in managing their wastes. In depth clarification of the environmental rules should be referred to the RCRA hotline at (603) 271-2942. Schools can review the NH Hazardous Waste Rules online, or obtain a copy by contacting the DES Public Information Center at (603) 271-2975.
A hazardous waste is defined as a substance that is corrosive, ignitable, reactive or toxic. Hazardous wastes need to be managed from their initial point of generation until their ultimate disposal, known as "cradle to grave responsibility." Schools should realize that their liability does not end when the wastes leave the school, and school administrators must make sure they receive a copy of the shipping paper (manifest) stating that their wastes arrived at their destination (treatment/storage/disposal facility).
Schools should be aware of the following regulations pertaining to hazardous wastes.
EPA Hazardous Waste ID Number
Any school that generates hazardous wastes must notify the Department of Environmental Services, Reporting and Information Management Section, (603) 271-2921, and obtain an EPA Identification Number. This EPA ID number must be put on all manifests for tracking disposal of school wastes. The EPA ID number must be site specific for the address given, i.e., Green High School, and not Green School District.
What is a Hazardous Waste Manifest?
A manifest is a multi-page form that tracks a waste shipment from your school to a treatment / storage / disposal facility. The school is responsible to make sure that all information on the manifest is correct.
The school must keep a copy of the manifest for three years. A copy of the manifest is also retained by the facility that accepts the waste, the transporter, and DES's Reporting and Information Management Section (RIMS).
Small Quantity Generator Requirements
Most schools are considered small quantity generators (SQGs) of hazardous wastes. An SQG generates less than 220 pounds of hazardous waste per month or accumulates less than 220 pounds of hazardous waste at any one time. This is roughly less than one-half of a 55-gallon drum.
All hazardous wastes should be placed in containers that are in good condition, and kept closed at all times except when adding or removing wastes. Hazardous waste containers should be placed on an impervious surface (pavement, tile) without floor drains.
All hazardous waste containers must be labeled with the beginning accumulation date, the words "Hazardous Waste," words that identify the container contents, and the school’s EPA ID number.
Schools must keep records of each shipment of hazardous wastes for three years. These records must include the date of each shipment, the quantities of each shipment, and the name and address of the handler or facility where wastes were shipped. All of this information is on the manifest.
Any releases that pose a threat to human health or the environment must be reported immediately to DES at (603) 271-3899, Monday through Friday, 8 am to 4 pm or to the New Hampshire Department of Safety Hazmat Unit at (800) 346-4009, 24 hours/day and to the municipality in which the release occurred.
Hazardous wastes found in schools may include:
- Used Oil
Used oil is classified as a hazardous waste when it is mixed with a hazardous substance, exhibits hazardous waste characteristics as summarized in the NH Hazardous Waste Rules, or it is not recycled. When used oil is recycled and burned, it is subject to less stringent requirements. Containers of used oil must clearly be labeled with the words "Used Oil for Recycle" at all times. A NH permitted hazardous waste transporter must be used to transport the used oil for recycling, unless the school self-transports less than 110 gallons. Schools should refer their questions on used oil management to the DES Used Oil Program.
- Waste Photoprocessing Solutions
Some spent photoprocessing solutions are considered hazardous wastes. The Material Safety Data Sheet (MSDS) should list any hazardous components in the product. The spent solutions may have different characteristics than the unused product, therefore testing of the spent solutions may be required to determine if they are hazardous wastes. The DES fact sheet Management of Waste Photoprocessing Solutions answers commonly asked questions regarding the management of these wastes.
Solvent waste can be generated in many areas of a school, including the science laboratory (acetone), industrial arts shop (polyurethanes, stains), art rooms (paint thinners), and maintenance departments (oil based paints). If the solvent is a NH listed hazardous waste, (Env-Wm 402), the school must apply the rules outlined above for proper management and disposal.
- Laboratory Chemicals
Science laboratories may contain numerous chemicals that are considered hazardous, including acids, bases and heavy metals. Highly toxic chemicals include mercury and its compounds, formaldehyde, and cyanide compounds (potassium cyanide and sodium cyanide). Chemicals that are known human carcinogens include arsenic, benzene, asbestos and certain chromium compounds. Flammable compounds include acetone, ether and xylenes. Reactive or explosive compounds include picric acid, potassium or sodium metal, and perchloric acid.
School staff should maintain a complete inventory of all laboratory chemicals. In order to reduce the quantity of chemicals used in science experiments, schools should try to institute microscale chemistry experiments, and substitute non-hazardous materials.
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