Managing Hazardous Waste on Campus: A Guide for Colleges and Universities

Colleges and universities generate significant hazardous waste from labs, healthcare facilities, maintenance activities, etc. This blog entry is a guide for campus administrators regarding the safe and legally-compliant management of hazmat. Q&As include:

1. What kinds of hazardous waste are typically generated by colleges & universities?
2. How is campus hazardous waste classified?
3. What are listed wastes?
4. What is the EPA “F-list?”
5. What is the EPA “K-List?”
6. What is the EPA “P-List?”
7. What is the EPA “U-List?”
8. What are characteristic wastes?
9. What does the EPA mean by “toxicity?”
10. What should a campus hazardous waste management program look like?
11. What does the EPA mean by “cradle-to-grave?”
12. Which agencies regulate hazardous waste management?
13. What hazmat training services does Hazardous Waste Experts provide?
14. Where can you get comprehensive advice and help about RCRA training rules?

1. What kinds of hazardous waste are typically generated by colleges & universities?

Just as with any business, hazardous waste commonly found at colleges & universities include chemicals, solvents, oils, and cleaning agents. However, university hospitals & clinics generate regulated medical waste (RMW), a category of hazmat with its own peculiar laws & regulations. And since they typically operate a number of laboratories, chemicals can be more ubiquitous at colleges & universities than in other business or government enterprises.

2. How is campus hazardous waste classified?

This is important to remember: Hazardous waste is classified on college & university campuses the same way as in any factory or foundry—and subject to the same laws and regulations. Thus, the first priority in developing a campus-wide hazardous waste management program is classification. That said, hazardous waste is generally divided into two general categories. These are “listed wastes” (see Q.3) and “characteristic wastes” (see Q.9).

3. What are listed wastes?

A waste is “listed” if it appears on one of four lists published in the Code of Federal Regulations (40 CFR Part 261). (Thus, “listed wastes.”) For reasons likely lost to history, these are respectively named the F, K, P, and U lists. (See Qs.4, 5, 6, and 7)

4. What is the EPA “F-list?”

The EPA F-List consists of hazardous wastes that are generated from various industrial processes. Some examples (and their respective waste codes) are:

• F001: Spent solvents used in degreasing
• F002: Spent solvents from other processes, including those that contain specific chemicals
• F003: Certain spent solvents, like those from paint thinners and other applications
• F004: Wastewaters from specific industrial processes
• F005: Certain waste from the production of certain chemical substances

5. What is the EPA “K-List?”

The EPA K-List consists of hazardous wastes that are generated from specific industrial processes (as opposed to the F-list, which is more generalized with respect to origin). Some examples (and their respective waste codes) are:

• K001: Waste from the production of certain pesticides
• K002: Waste from petroleum refining processes
• K003: Waste from the production of organic chemicals
• K004: Waste from the production of inorganic chemicals
• K005: Waste from the manufacturing of certain metal products

6. What is the EPA “P-List?”

The EPA P-List consists of acutely hazardous wastes (aka, toxic) that are primarily discarded chemical products in pure or commercial form. The P-List has 24 members. Some examples (and their respective waste codes) are:

• P001: Acutely toxic substances like arsenic trioxide
• P002: Certain forms of cyanides
• P003: Specific chemical compounds such as formaldehyde
• P004: Certain pesticides and their residues

Note that the word “toxic” has a restricted meaning in EPA parlance. (See Q.9)

7. What is the EPA “U-List?”

The EPA U-List consists of typically discarded products that are non-acute hazardous wastes in their pure or commercial form. Unlike the P-List, the U-List includes substances that are hazardous but not classified as acutely toxic (see Q.9). The U-List has over 400 members. Some examples (and their respective waste codes) are:

• U001: Acetone
• U002: Benzene
• U003: Carbon tetrachloride
• U005: Chloroform
• U019: Certain forms of lead

8. What are characteristic wastes?

Characteristic wastes are those that fail to appear on the F-, K-, P-, or U-lists (see Qs.5-7), but might nonetheless be considered hazmat for exhibiting one or more of the following “characteristics.” (Thus, “characteristic wastes.”) These characteristics are:

• Ignitability—it catches fire under certain conditions. E.g., some paints, degreasers, or solvents
• Corrosiveness—it’s a significant acid or base. E.g., rust removers, certain cleaning fluids, or battery acid
• Reactivity—it’s prone to explode or release toxic fumes if heated, mixed with water, or pressurized. E.g., certain cyanides or sulfide-bearing wastes
• Toxicity—it’s harmful or fatal if ingested or absorbed, or it can leach toxic chemicals into the soil or ground water when disposed of on land. E.g., waste containing cadmium, lead, or mercury

9. What does the EPA mean by “toxicity?”

The terms “hazardous waste” and “toxic waste” are often used interchangeably. This is wrong, although even the hazmat cognoscenti often comingle the terms.

“Hazardous waste” is really an umbrella term. It covers many different kinds of industrial and household detritus, and “toxic waste” is but one “characteristic” among four (see Q.8).

10. What should a campus hazardous waste management program look like?

As in any industry—college, universities, hospitals, and clinics included—hazmat generators have different EPA-mandated training requirements depending on size.

Hospitals are generally considered either Very Small Quantity Generators (VSQGs) or Small Quantity Generators (SQGs).

• VSQGs are entities that generate less than 100 kilograms (about 220 pounds) of hazardous waste monthly.
• SQGs are entities that generate between 100 kilograms (220 pounds) and 1,000 kilograms (2,200 pounds) of hazardous waste monthly.

If your university, college, hospital, clinic, or laboratory is a VSQG, there are no explicit training requirements for your hazardous waste personnel, but they must be “thoroughly familiar” with proper waste handling and emergency response procedures. Thus, it’s important that they receive documented training, proof of which you can present to an EPA inspector should one show up on your campus for some untoward happenstance.

Minimally you should document dates and provide descriptions of hazmat training sessions for your VSQG personnel. Also, have sign‑in sheets to record which of your employees have attended them.

The requirements are similar if your university, college, hospital, clinic, or laboratory is an SQG. I.e., your personnel need only be “thoroughly familiar” with proper waste handling and emergency response procedures. So, although there’s no specific requirement for having documented proof of individual training, common sense dictates the need for it. Again, an inspector could ask for proof, and being able to present it on demand will testify to your compliance efforts.

(N.B. Hazardous Waste Experts training modules and educational resources are designed to familiarize your VSQG staff with safe hazmat handling & storage practices. We can also help you audit your facility for OSHA compliance and develop safety plans for emergency readiness. Find out more here.)

11. What does the EPA mean by “cradle-to-grave?”

One of the imperatives of the Resource Conservation and Recovery Act (RCRA) is that you’re responsible for any hazardous waste from “cradle-to-grave.” This includes its generation, transportation, treatment, storage, and disposal.

Bear in mind that the EPA makes it remarkably easy to be a hazardous-waste generator. E.g., the moment one of your instructors, scientists, students, or medical staff uncorks a can of solvent and uses it, you’ve joined the ranks.

True, you might only generate a single quart of waste solute per week. But the improper storage or disposal of even that small amount can land you squarely in the crosshairs of the EPA, which is not a good place to be.

In sum, you’re not only accountable for a hazardous waste from the moment it’s generated; you’re also legally responsible for its safe transportation to wherever it will be ultimately processed or disposed of. Consider:

• As to transporting hazmat: The EPA requires that it be transported in compliance with regulations ensuring proper labeling, packaging, and documentation, with the use of properly licensed & certified carriers.
• As to storing hazmat: The EPA mandates that hazardous waste be stored in labeled, leak-proof containers at facilities with proper security, safety measures, and compliance with specific time and space limitations to prevent contamination.
• As to treating hazmat: The EPA requires that hazardous waste be treated using approved methods to reduce its volume, toxicity, or hazardous characteristics, ensuring compliance with environmental safety standards and proper documentation.
• As to disposing of hazmat: The EPA mandates that hazardous waste be disposed of at licensed & authorized facilities using safe and compliant methods, ensuring proper containment and environmental protection throughout the process.

12. Which agencies regulate hazardous waste management?

Laws & regulations concerning hazardous waste management emanate from the EPA, OSHA, DOT, DEA, and—particularly—from the US state where your university, college, laboratory, hospital, or clinic is located. Among them:

• State laws & regulations. Many states have implemented specific laws & regulations dictating how hazmat should be tracked, stored, treated, and disposed of, and they tend to be more stringent than their federal counterparts.
• EPA. The RCRA is the primary law governing the disposal of solid and hazardous waste. Under RCRA, hazmat must be managed in accordance to specific rules for treatment, storage, and disposal.
• OSHA. The Occupational Safety and Health Administration requires employers to provide safe handling of hazmat by ensuring proper labeling, employee training, and the use of personal protective equipment (PPE). They also must implement emergency response procedures, maintain material safety data sheets (MSDSs), and ensure safe storage and disposal to minimize risks to workers’ health and safety.
• DOT. The Department of Transportation requires hazardous materials to be transported with proper classification, labeling, packaging, and documentation, using certified carriers, and ensuring safety through compliance with specific regulations for route planning, vehicle standards, and emergency response protocols.
• DEA. The Drug Enforcement Administration regulates the handling and disposal of certain controlled substances (e.g., hazardous medical waste) to prevent diversion, misuse, and environmental contamination. (See source.)

(Do you have different locations within & across states? Get expert advice.)

13. What hazmat training services does Hazardous Waste Experts provide?

We can help you prepare the required programs and associated documentation needed to satisfy OSHA, DOT, and EPA requirements such as:

• Accident Investigation Plans
• DOT Driver Plans
• Emergency Action Plans
• Fire Extinguisher Programs
• First Aid/CPR/Bloodborne Pathogen Plans
• Hazard Communication Programs
• Hazardous Waste Management Programs
• Personal Protective Equipment Plans
• Safety Manuals
• Stormwater Pollution Prevention Plans

Certain training must be completed annually while others are on two- or three-year cycles. We can help you with:

• DOT Training (3 years)
• Emergency Action Training (initial)
• Fall Protection Training (initial)
• Fire Extinguisher Training (annual)
• First Aid Training (2 years)
• Forklift Training (3 years)
• Hazard Communication Training (every 3 years)
• Hazardous Waste Training (annually)
• Respirator Training (annually)
• Stormwater Pollution Prevention Training (initial)

Find out more about Hazardous Waste Experts training services.

14. Where can you get comprehensive advice and help about RCRA training rules?

Hazardous Waste Experts is a leading provider of environmental health & safety (EH&S) and hazardous waste management training across the United States. Depend on us for custom-tailored, industry-specific training either onsite or online.

Remember, as they tend to come from more than one government bureaucracy, and at haphazard intervals, RCRA training regulations are plentiful, evolving, and challenging to track. Ignoring or misunderstanding them can subject you to pecuniary and even criminal consequences. Consider:

As of January 8, 2025, the maximum civil penalty for RCRA violations is $93,058, applicable to violations that occur or occurred after November 2, 2015. This is an increase of 1.02% from 2024 levels. (See source.)

As we’re wont to advise, it’s crucial to get expert advice.

So, contact us today. Or call us at our new number: 425.414.3485.

And thank you for reading our blog!