University Policy on Unknown Chemicals

From: Manuel A. Esteban, President

Subject: University Policy on Unknown Chemicals

UNIVERSITY POLICY ON UNKNOWN CHEMICALS

Background

Unknown chemicals are generated on campus when state and federal regulations in labeling chemical containers are not followed. All chemicals have the proper label when they are purchased directly from a vendor. However, a problem arises when a chemical is transferred to a secondary container and not properly labeled or a label becomes worn and unreadable. These chemicals are eventually reported to the University Office of Environmental Management, Health and Safety (EMHS) as "unknowns," which the department then requests be removed as hazardous waste. We are unable to dispose of unknowns because they may not be transported on public roadways and must be identified through laboratory analysis before a disposal company will accept them. Unknown chemicals may be generated in campus laboratories and in other nonacademic areas. EMHS discourages the generation of unknown chemicals by providing training on proper labeling, providing labels when requested, and distributing booklets and flyers on proper labeling protocol. However, the campus continues to generate large volumes of unknown wastes. Each unknown waste product costs the University from $200 to $3,500 for a chemical analysis. This cost covers only the laboratory analysis and does not include the cost of handling and disposal. During 1994, CSU, Chico spent approximately $15,000 to determine the identities of 43 unknown chemicals.

Incorrect labeling not only leads to the generation of unknown chemicals but it is also in violation of specific state and federal laws and it can be extremely costly. Therefore, the University is implementing a cost recovery policy to encourage use of proper labeling techniques.

Policy

Beginning July 1, 1995, costs directly associated with the identification of an unknown substance will be charged to the department that generated the unknown waste. The charge will be for the cost of laboratory analysis and shipping. A department is not responsible for the cost of EMHS handling and the disposal fee. This policy applies to all hazardous materials generated on campus.

This policy will not be invoked when containers of hazardous materials comply with state and federal labeling requirements that include the following information:

• Name of the substance
• Hazard category
• Manufacturer

The law requires all items listed above to be on a chemical container. All containers of biohazard substances shall be at least labeled with the name of the substance.