EHS maintains an online chemical inventory to facilitate state and federal regulatory reporting (ex. Department of Homeland Security, Environmental Protection Agency, Right to Know, etc.). The chemical inventory provides EHS with lab specific chemical hazard information and this, in-turn, helps EHS provide site specific training. In addition, the chemical inventory provides local emergency response crews with hazard information.

No. EHS does not expect researchers to update quantities in the database each time a chemical is used. EHS encourages you to update your chemical inventory to the Chemical Inventory Database when:

• You receive a chemical.
• You transfer a chemical to a new location, either external or internal to your lab.
• You use up a chemical.

Upon arrival at Central Receiving, packages with chemical markings are opened. Each chemical in your package will be barcoded into the EHS Chemical Inventory System and securely placed back into its original packaging. Currently, the Chemical Inventory Program barcodes the majority (>90%) of your chemical containers.

Upon receipt into your lab, your chemicals need to be recorded into the online Chemical Inventory System.

You can either:

• Go into the Chemical Inventory Database and delete the chemical out of your inventory yourself.
• Email a list of your chemicals’ barcode numbers to the CMU. EHS will delete the chemicals out of the Chemical Inventory Database for you.
• Submit your empty containers to the Hazardous Waste Database as an eRFD. EHS will pick-up your empty containers and will delete the chemicals out of the Chemical Inventory Database for you.

A Chemical Inventory Audit involves:

• Scanning each of your chemicals’ barcodes.
• Adding and replacing barcodes.
• Adding chemical locations and sub-locations, as needed or requested.
• Helping with chemical organization, such as locating acids away from bases.

If your building/lab will be experiencing a remodel or a move, EHS will be in touch to schedule a Chemical Inventory Audit with you.

If you are interested in having a Chemical Inventory Audit conducted in your lab, please contact EHS.

EHS will collaborate with you during the entire process to answer any questions you may have and to provide suggestions for your lab’s improvement.

If a chemical you have does not have a barcode fill out the CSU Self-Audit and Barcode Request Form.

This is located under the chemical management tab and under the publications or click this link: CSU Self-Audit and Barcode Request Form

Fill out the sheet with the correct info and then send it to chemmgt@colostate.edu

1. If you witness an incident where hazardous materials may be involved, call 911 and/or pull the alarm station in the building. At CSU the responders are:

   CSU Police Department

   Environmental Health Services Emergency Responders

   Poudre Fire Authority

2. If you hear a siren or note unusual activity in your building, contact your supervisor, office manager, or building proctor for further information. Follow all instructions carefully.
3. If you hear a building alarm evacuate the building immediately according to the established evacuation routes. Contact your supervisor, office manager, or building proctor for further information.
4. Stay away from the incident site and try to keep others from going into the area to minimize the risk of contamination.
5. If you are caught outside during an incident, try to stay upstream, uphill and upwind. Hazardous materials can quickly be transported by water and wind. Initially, try to go at least 100-200 yards from the danger area. You may need to go much further.
6. If you are in a car, close the windows and shut off ventilation. This will reduce the risk of contamination.
7. If you are asked to evacuate a building or area, please cooperate with officials and follow all instructions carefully.
8. If requested to stay in your office or at any other site, please follow all instructions carefully.
9. Avoid contact with any spilled liquid materials, airborne mist, or condensed solid chemical deposits. Keep your body fully covered. Wear gloves, socks and shoes. These measures may offer some protection.
10. Do not eat or drink any food or water that may have been contaminated.
11. If you have been contaminated, or suspect you may have been, minimize contact with the hazardous material as much as possible. Use any means available such as an eye-wash, safety showers, and removal of contaminated clothing. Notify the first emergency responder you see.
12. Do not return to your home, office, or work area until officials say it is safe.
13. Follow directions given by the emergency responders. Upon returning, open windows and vents if possible. Turn on fans to provide ventilation.
14. A person or item that has been exposed to a hazardous chemical may be contaminated and could contaminate other people or items. If you have come into contact with or have been exposed to hazardous chemicals, you should: follow decontamination instructions from the emergency responders, seek medical help if unusual conditions develop, place exposed clothes & shoes in a plastic bag, and contact university officials for proper disposal methods.
15. Find out from university officials how to clean up your work area and dispose of the contaminated materials. If an incident should occur at your residence, you can contact Larimer County Department of Natural Resources Household Hazardous Waste Program at (970) 498-5773 for disposal options.
16. Report any noticeable odors or any other hazards or concerns to EHS at (970) 491-6745.

If you work with hazardous waste, you are required to take the Hazardous Waste Generator Training

If you work with controlled substances, you are required to take the Controlled Substances Training

If you work with formaldehyde, it is recommended that you take the Formaldehyde Hazards in the Workplace Training

If you work with methylene chloride, it is recommended that you take the Methylene Chloride Hazards in the Workplace Training

All EHS Chemical Management Unit trainings are offered online. If your group is interested in taking an online training in-person, please contact EHS.

No, but you can print the certificate for your own records.

Annually

• Hazardous Waste Generator Training
• Controlled Substances Training

One-time, no renewal needed

• Formaldehyde Hazards in the Workplace Training
• Methylene Chloride Hazards in the Workplace Training

• Adhere to EPA, CDPHE, CSU, and EHS hazardous waste requirements.
• Complete the Hazardous Waste Generator Training and complete retraining at least once every 12 months.
• Determine if waste material can be shared, reused, or minimized.
• Conduct a waste determination. Is the material a hazardous waste, non-hazardous waste, or universal waste? If the material is a hazardous waste, is it corrosive, ignitable, reactive, and/or toxic?
• Label hazardous waste properly in plain English.
• Safely contain, store, and secure all hazardous wastes in a Satellite Accumulation Area (SAA) registered with EHS. All containers must be in good condition and compatible with the waste.
• Utilize appropriate personal protective equipment (PPE) while performing procedures that involve the use of hazardous chemicals or materials. PPE includes lab coats, gloves, and safety glasses or goggles.
• Prepare Electronic Request for Disposal (eRFD) forms via EHS website.
• Perform required weekly of Satellite Accumulation Areas (SAAs) inspections.
• Review procedures to see how waste may be minimized in the future.
• Spread the word. Encourage responsible waste management.

• Ensure all employees have training.
• Register your Satellite Accumulation Area (SAA) with EHS. There can only be one SAA per lab location, but SAAs can be shared with other PIs. Make sure assigned employees are completing required weekly SAA inspections.
• Register your active projects with EHS. Please provide a general description, accumulation date, and end date for each project. You can combine all of your projects into one.
• Ensure all safety procedures are being followed. This involves:
• Educating all employees on chemical hazards.
• Making sure that all employees are following lab safety procedures.
• Ensuring that personal protective equipment (PPE) is available for lab members.

No! It is not permissible by state and federal regulations to take waste that is the end product of a process and treat it to render it "non-hazardous." Also, federal regulations state that the mixing of a hazardous waste with a non-hazardous waste creates waste that is still considered hazardous. So you cannot dilute a waste with water to make it non-hazardous.

If your waste contents ONLY contain materials from page 14 of the Hazardous Waste Manual, you may dump your waste down the drain or into the dumpster. If ONE OR MORE of the contents is not on page 14 of the manual, then you MUST submit your waste to EHS as a hazardous waste. If you have any questions about this, please contact EHS.

There are federal Environmental Protection Agency (EPA) and Colorado regulations for hazardous waste.

Federal EPA regulations:

• Resource Conservation & Recovery Act (RCRA) of 1976
• Purpose: to protect human health and the environment as well as promote energy/natural resource conservation, waste reduction, recycling, and proper management of waste. The "Cradle to Grave" responsibility was founded under RCRA.
• Hazardous & Solid Waste Amendments (HSWA) of 1984

Colorado is an Agreement State under EPA. CSU’s primary hazardous waste regulators are the Colorado Department of Public Health and Environment (CDPHE) and the Colorado Hazardous Waste Regulations 6 CCR 1007-3. CSU’s secondary hazardous waste regulators are the EPA and EPA 40 CFR Parts 260.

The main takeaway from the regulations is that improper disposal can result in civil and criminal prosecution of the individual responsible: $15,000/day/violation and a civil penalty of $25,000/day/violation. You must comply with the CSU, federal, and state regulations!

Hazardous Waste Manual

The initial hazardous waste labels have changed as of August 2019!

Initial Hazardous Waste Labels

Non-Hazardous Waste Labels

Used Oil Labels

Although not required, feel free to use the hazardous waste log sheet for your own records.

You must label non-hazardous wastes when these wastes are contained within your hazardous waste SAA. Outside of this area, your non-hazardous wastes do not need non-hazardous waste labels. This is to ensure that auditors do not classify any unlabeled wastes within your SAA as a hazardous waste, resulting in potential violations for your lab.

Although non-hazardous wastes do not need to be labeled if they are outside of your SAA, it recommended that you label non-hazardous wastes with their contents.

• The words HAZARDOUS WASTE
• List of chemical contents (NO ABBREVIATIONS)
• Quantity/percentage of each chemical content
• The hazard characteristic(s) of the waste
• Name of the generator (responsible person’s name)
• Accumulation start date (the date when the material was first declared a waste)

• List of chemical contents (NO ABBREVIATIONS)
• Quantity of the waste
• Name of the generator (responsible person name)
• The words NON-HAZARDOUS WASTE

If the contents of a container are truly unknown, the responsible PI or the department will have to pay to have the contents identified. If the contents can be reasonably inferred through communication with previous users or lab notebooks, that information needs to be included on the eRFD and EHS will pick up the container.

How: Submit an Electronic Request for Disposal (eRFD). Print your eRFD labels and attach each label onto your containers. Place all items with a volume up to 4 liters into a box with newspaper packaging material. Place all submitted, packaged wastes in your Satellite Accumulation Area (SAA). When: Check the confirmation email that was sent to you when your waste was submitted, or login to the eRFD website to find the date when EHS will pick-up your waste. Your waste will typically be picked up by that date (usually a Tuesday or Thursday).

Your waste must be submitted to EHS at most 2 weeks prior to the 90 days after accumulation of waste began in that container. This is to ensure your waste does not exceed 90 days from EHS pick-up. For example, if you place the first drop of a hazardous waste into a container on January 1st, 2023, then you must submit this container to EHS 2 weeks prior to April 1st, 2023.

See the Electronic Request for Disposal (eRFD) Video

Due to state and federal regulations, EHS is prohibited from picking up unknown wastes. For safety, health and disposal purposes, EHS must only accept waste properly identified by chemical name or its hazardous characteristics.

It is the responsibility of the generator's department to identify the waste. The two best methods are:

1. Determine who generated the waste, who operated the lab in which the unknown waste was found, or who may have knowledge of the activities conducted in the lab. Ask them to identify the waste for you.
2. Contact EHS to have a small sample analyzed at a cost of $100 per sample.

You should NEVER guess at the waste contents. Since most of the materials picked up by EHS are combined into bulk containers, reactions can occur if the waste is improperly labeled.

Thousands of tax dollars are spent each year disposing of latex paint as hazardous when, in fact, it is not hazardous. Use it up!

If you still want to get rid of your paints, please contact EHS. EHS does recycle latex paints as well as bulk flammable paints with our hazardous waste solvents.

Please open and read the following PDF Document.

How to dispose of latex paint

EHS creates the pick-up schedule on Tuesdays and Thursdays before 9 am. If EHS receives the eRFD’s before these days on a current week, the items will be picked up on those respective days.

No, you do not need to submit an eRFD for each item. An eRFD (electronic Request for Disposal) is a collection of waste containers located in a single waste site. You do not need to submit separate eRFDs but rather for each separate container generate waste containers pickup labels. For example: If you have a case of the same item, 20 bottles of KCL and it is contained in a single box then you can generate a single waste container label. Otherwise each container needs separate labels.

If a mistake is made on an eRFD and the eRFD needs to be deleted, contact EHS, and we will delete the eRFD. You may submit another one with the correct information. Until you submit the eRFD, you are able to edit/delete it. After submission, EHS will have to delete.

Volumes up to 4 liters should be packaged in boxes, preferably surrounded by newspaper. You can place multiple items in the same box only if they fit and will not be damaged during transport.

Containers with larger volumes, such as 20 liter metal cans, 5 gallon paint buckets, and 5 gallon carboys do not need to be packaged in boxes. Make sure lids are tight.

There are two reasons:

1. Styrofoam tends to build up static electricity, which makes it difficult to get them off containers.
2. Styrofoam does not have the same absorbency characteristics as other packaging materials, in the case a container leaks or breaks during transit.

Please package your waste items with newspaper!

If EHS has boxes available, EHS can provide you with boxes. The best way to request boxes is for you to provide a note in the comments section of an active eRFD. EHS will do our best to supply you with boxes for your next hazardous waste pick-up, but not for any active hazardous waste pick-ups. When you complete a hazardous waste submission, you certify that your waste is properly packaged for pick-up. If your hazardous waste is not in a box at the time of pick-up, EHS will not pick it up until it is properly boxed.

EHS does not bring boxes to package your waste for you!

If EHS has the desired containers, they can be provided to you free of charge. EHS keeps stock of 4 liter bottles, 20 liter metal cans, 5 gallon carboys, and 5 gallon buckets. However, it is the responsibility of the generator’s department to provide all additional equipment and supplies necessary for proper waste disposal.

EHS does have 55 gallon drums, but rarely does a generator actually need one. In addition, several safety factors must be in place to store 55 gallon drums, such as secondary containment up to 55 gallons and fire sprinklers.

Remember, once you put a drop of hazardous waste in a container, you have 90 days until you must submit it for disposal. Few generators can fill a 55 gallon drum in 90 days. It's best to pick a container that you will fill in about 75 days (11 weeks).

See the resources below for how to perform your SAA inspections. You must perform SAA inspections weekly.

Satellite Accumulation Area Weekly Inspections Video

Print Instructions for Weekly Inspections

First, check if any of your trained Hazardous Waste Generators will be able to perform the weekly inspection for you. If you have no trained generators or your trained generators are also unable to perform the inspections, login to Hazardous Waste Online and inactivate the SAA site.

During the inactivation, you are declaring that no hazardous waste is present or will be generated. You will not be able to submit waste from an inactive site. Please submit all hazardous waste before inactivating your site!

No, if you are using a shared waste site, meaning you drop your waste off in another PI’s location for EHS pick-up, you are not responsible for inspections of this site. You are only responsible for inspecting those sites which are listed directly under you or your PI.

The Notice of Non-Compliance is our way of keeping track of:

• Who is not completing their weekly SAA inspections.
• SAA inaccuracies found by EHS during EHS SAA audits.

Notice of Non-Compliances are saved to your permanent record. This record is given to the Colorado Department of Public Health and the Environment and the Environmental Protection Agency during their inspections. EHS cannot remove a Notice of Non-Compliance from your record once it has been issued.

EHS members perform unannounced SAA audits in all labs on campus. The purpose of these audits is to ensure that SAA inspections completed by labs are accurate. The best way to prepare for these audits is to complete your weekly SAA inspections thoroughly and accurately and make any needed corrective actions. During SAA audits, EHS will evaluate your SAA based on the weekly SAA inspection criteria in which you evaluate your site.

If you don’t have any waste in your site, you can inactivate your SAA for the time being. But, once you start generating more waste, you must reactivate your SAA.