Important MSU EHS Hazardous Waste Changes

October 28, 2021 - S. Horn

On August 3, 2020, the Michigan Department of Environmental, Great Lakes, and Energy (EGLE) adopted the Hazardous Waste Generator Improvements Rule as promulgated by the United States Environmental Protection Agency (EPA) on November 28, 2016.  As part of the new Generator Improvements Rule, there are two main changes that pertain specifically to hazardous waste generated by MSU laboratories and facilities. 

Revised Hazardous Waste Tags

First, you will notice that EHS has revised their hazardous waste tag that will need to be attached to all hazardous waste containers.  The waste tag now contains the Global Harmonization System (GHS) symbols that identity chemical hazards, and associated check boxes to indicate those hazards are present in the waste container.  These check boxes must be filled out as the waste is being generated in the container in the lab.  See photo below for an example of how the waste tag should look as waste generation is in progress.  If your location is in need of a stock supply of new hazardous waste tags, please contact EHS Waste staff at hazwaste@msu.edu and we will swap out new tags and take the old.

 

Quick Reference Posting

Second, each area where hazardous waste is stored now needs to have a Quick Reference Guide posted.  Prior to Covid, EHS staff were working on posting these signs throughout each Satellite Accumulation Area (SAA) on and off campus.  A SAA is a location where hazardous waste is generated and stored and can include labs, clinics, farms, mechanical spaces, janitorial spaces, etc.  Signs were posted on the inside of the entry doors of each SAA, or as close to the entry door as possible, to be easily identifiable during lab inspections.  If you notice that your lab or space does not have the full 11 x 17” sign (pictured below) posted on the inside of the door, please contact EHS Waste staff at hazwaste@msu.edu and signs will be provided to you.  As part of the new hazardous waste regulations, this full 11 x 17” sign must be posted on or near the entry door to your SAA. However, for those of you wishing to post the bottom half of the sign (Figure 1) in closer proximity to your hazardous waste storage area, EHS has made this Figure 1 sign available on the Labeling and Signage webpage for you to print off and post.  Please note that this sign must replace any earlier versions of hazardous waste storage signs in your SAA.

EHS is currently revising internal guides, documents, and trainings to reflect these new changes, as well as making changes to the hazardous waste webpage and pick up request pages. 

***Please note that if during a Federal or State hazardous waste inspection the inspector identifies waste tags without the GHS symbols properly checked, or notices a missing sign in a lab, it is within the inspector’s purview to issue a monetary fine to the PI and/or department of up to $76,764 per violation, per container, per day***

Please feel free to contact the MSU EHS Hazardous Waste Group Staff, or email hazwaste@msu.edu for further assistance with hazardous waste questions.