Last Revised: March 29, 2023


  • Purpose and Applicability
  • Definitions and Scope
  • Roles and Responsibilities
  • Procedures
  • Key References


1.1  This policy is designed to ensure that every effort is made to minimize the generation of hazardous waste and that all hazardous waste is properly managed and disposed of in accordance with all applicable federal, state, and local regulations.

1.2  This policy applies to University employees, students, and contractors who engage in any University-sponsored activity either on the Philadelphia campus, at the New Bolton Center or the Morris Arboretum & Gardens.


2.1  "Hazardous Waste" is defined under federal law as a chemical waste that is specifically listed by the EPA as a hazardous waste or if it exhibits one or more of the following characteristics: ignitability, corrosivity, reactivity, and toxicity. For complete definitions of hazardous characteristics and listed wastes refer to the University Laboratory Chemical Waste Management Guidelines (see Key References and Resources below).

2.2  This hazardous waste policy does not include radioactive waste, biological waste or hazardous chemicals that are not spent, outdated, or unwanted.

2.3  "Satellite Accumulation Areas" are areas designated for hazardous waste collection and temporary storage near the point of generation. When containers are filled they are picked up by EHRS and transported to a Central Waste Accumulation Area.


3.1  The Office of Environmental Health and Radiation Safety (EHRS) has the overall responsibility for the Hazardous Waste Management Program, including waste collection, RCRA hazardous waste determination, packaging, storage, disposal, training, inspections, and record keeping.

3.2  Each Principal Investigator, Facilities Services Supervisor and contractor is responsible for the proper management of hazardous waste in their laboratory or work area, including labeling of containers, segregation, inspections and maintenance of the area.

3.3  Employees are responsible for participating in annual EHRS Hazard Communication or Lab Safety training which will include hazardous waste training. Employees are also responsible for the proper management of hazardous waste in their laboratory or area, including labeling of containers, segregation, inspections and maintenance of the area.


4.1 Satellite Accumulation Areas

Satellite Accumulation Areas must be managed in accordance with all applicable EPA and PADEP regulations. Each area must be labeled as a 'Satellite Accumulation Area'. Waste chemicals must be stored in secondary containment bins to collect spills and prevent mixing of incompatible chemicals. Details on the management of accumulation areas can be found in the University's Laboratory Chemical Waste Management Guidelines (see Key Reference and Resources below).

4.2 Central Accumulation Area

Hazardous waste that is collected from the campus by EHRS is stored, consolidated, and packaged for disposal at a central accumulation area. This building is a secure area that is marked with signs indicating the hazards present, and is inspected weekly. In the event of a spill or accidental release, spill kits are available onsite to facilitate a timely response and cleanup.

4.3 Emergency Response Plan (ERP)

The Emergency Response Plan is established to formalize the University's response to and mitigation of incidents involving hazardous materials. The plan is designed to minimize hazards to human health, the environment and property. The plan contains detailed emergency information and must be updated annually. Copies of the plan are available from EHRS.

4.4 Training

Hazardous waste training is provided by EHRS for all University faculty, staff, and students who may generate waste chemicals. Refresher training is also required annually. Additional training is required for EHRS staff involved in the packaging and disposal of hazardous wastes. Additional training includes 40-hour hazwoper, 8-hour DOT hazardous materials training and an annual refresher for each.

4.5 Waste Minimization Plan

The University has a written Hazardous Waste Minimization Plan that describes methods employed to reduce the volume of waste generated. This plan is updated annually and is available from EHRS.

4.6 Recordkeeping

The following records are maintained by EHRS: all permits, licenses, hazardous waste shipping documents, inspection logs, training records, and regulatory agency correspondence. These documents are kept on file for a minimum of three years.

5.0 Key References

University Chemical Hygiene Plan (Laboratory Safety Manual)

University Laboratory Chemical Waste Management Guidelines

US EPA HW Management Regulations 40 CFR 260

Pennsylvania Code Title Chapters 260-270 HW Management Regulations

Prudent Practices in the Laboratory, National Research Council. ISBN 0-309-05229-7