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Hazardous Materials and Hazardous Waste Management



01.01   Hazardous materials and hazardous waste can pose a threat to students, employees, visitors and the environment if managed improperly. To minimize the possibility of such threats, appropriate practices and procedures are essential. The purpose of this policy is to establish a hazardous materials and hazardous waste management program.


01.02   Environmental Health, Safety & Risk Management (EHS&RM) has primary responsibility for the university’s hazardous materials and hazardous waste management program. The director of EHS&RM (or designee) is authorized to take action to assure compliance with applicable regulations and policies and to minimize physical and environmental threats on university property (whether owned or leased). This includes having delegated authority from the university president to order the cessation of activities or operations, as needed, to administer this policy.


01.03   The university is registered as a hazardous waste generator by the Environmental Protection Agency (EPA) and the Texas Commission for Environmental Quality (TCEQ). Procedures outlined in this policy are designed to promote the protection of health and the environment by compliance with applicable regulations.


01.04   Hazardous materials and hazardous waste that are not properly packaged and labeled may not be transported.  


01.05   University employees who transport regulated quantities of hazardous materials or hazardous waste are required to maintain a valid Texas commercial driver’s license. Employees at Texas State authorized to transport chemicals are Materials Management staff and EHS&RM staff.  Hazardous materials transported by government employees for non-commercial purposes are not subject to the Hazardous Materials Regulations in 49CFR Parts 171-180.


01.06   Non-compliance with hazardous materials and hazardous waste regulations can result in violations being charged against the university by regulatory agencies, as well as the assessment of fines and other costs. Disciplinary action may be taken against university personnel or students who do not comply with this policy and associated regulations.




02.01   Hazardous Materials – any materials that may present a health or physical hazard to individuals when handled in the normal course of their work.  Hazardous materials become hazardous waste when they are discarded or no longer needed or used for their intended purpose.


02.02   Hazardous Waste – any substance identified or listed as a hazardous waste by the administrator of the United States Environmental Protection Agency, 40 CFR 261, Identification and Listing of Hazardous Waste. 


02.03   Biohazard Waste – any contaminated waste material that is capable of transmitting disease to workers or handlers.


02.04   Departmental Hazardous Waste Generator – any department or activity associated with the university with processes or experiments resulting in a hazardous waste.


02.05   Management Program – related to this policy, management encompasses the functions of acquisition and use of hazardous materials and disposal of hazardous waste.


02.06   University Hazardous Waste Management Unit – a university facility that is registered with TCEQ for storage of hazardous waste prior to shipment for disposal.


02.07   Spill Prevention Plan – a written policy that includes emergency procedures for spill prevention and cleanup of hazardous materials or hazardous waste. 


02.08   Chemical Hygiene Plan – a written program developed and implemented by the department that sets forth procedures, equipment, personal protective equipment, and work practice that 1) are capable of protecting employees from the health hazards presented by hazardous chemicals used in that particular work place, and 2) meet Occupational Safety and Health Administration (OSHA) requirements.


02.09  Departmental Hazardous Materials Coordinator – an individual who is designated by the academic department chair or account manager to act as liaison with EHS&RM for proper management of hazardous materials used or hazardous waste generated by their department.




03.01   Hazardous materials or materials that may become hazardous waste must be handled in such a way as to protect that health and safety of university students, personnel, property, and the environment. (See also Hazard Communication Program policy.)


03.02   Purchase of Hazardous Materials


a.   Hazardous materials should be purchased in a manner that minimizes the quantity of hazardous materials in the work area and hazardous waste generated. Any request for purchase of a hazardous chemical from any department must be approved through the EHS&RM department. EHS&RM will review the purchase request and provide approval if the chemical is not being requested in large quantities or is a chemical having high regulatory consequence. These chemicals may be regulated by more than one program, have high toxicity or high legal consequences for mismanagement.


b.   Because of federal and state regulations regarding the procurement of hazardous materials, all such purchases must be approved through the university’s purchasing system. Use of alternate approved university procurement methods, including procurement cards (P-cards) to purchase hazardous materials is strictly prohibited.


c.   Departments should coordinate their hazardous material purchases with other university departments, to minimize individual departmental quantities ordered and stored.


03.03   Hazardous materials must be stored in a safe and secure area that cannot be accessed by unauthorized individuals. 


03.04   Appropriate supervision and training is required for all situations in which hazardous materials are utilized at the university. (See also Hazard Communication Program policy.)




04.01   Management of hazardous waste for disposal is strictly limited to EHS&RM. University departments or areas that handle hazardous materials and hazardous waste are not authorized to undertake disposal procedures without contacting EHS&RM.


04.02   The disposal of hazardous waste by hazardous waste generators is strictly controlled by local, state and federal regulations. All university departments utilizing hazardous materials shall be familiar with and comply with applicable regulations regarding the safe handling, labeling, and disposal of hazardous waste. These include:


a.   31 TAC Chapter 335, Industrial Solid Waste, and Municipal Hazardous Waste Regulations; TCEQ.;


b.   40 CFR, Parts 260 through 265, Identification and Listing of Hazardous Waste; EPA.;


c.   29 CFR, Part 1910; Occupational Safety and Health Standards Act (OSHA).;


d.   Hazard Communication Program; and


e.   City of San Marcos Wastewater Pre-treatment Ordinance.


04.03   Biohazard waste generated at the university is to be collected in approved biohazard bags or containers. Biohazard waste requires special treatment on site at the generation point, when feasible. If treatment cannot be performed on site, EHS&RM will assist departmental generators in securing an appropriate means of disposal.


04.04   Time frame for disposition of hazardous waste – Hazardous waste must be removed from the university’s Hazardous Waste Management Unit within 90 days of placement in the unit. Departments or areas that have hazardous materials or materials which may become hazardous waste must contact EHS&RM to arrange for disposal.


04.05   Hazardous waste will be stored in a designated university Hazardous
Waste Management Unit where an authorized contractor can remove the waste for disposal. Alternatively, EHS&RM may arrange for the authorized contractor to pick up hazardous waste directly from a university department or activity. Hazardous waste must be properly characterized prior to removal from the generating department or area.


04.06   Departmental hazardous waste generators must continually monitor the hazardous waste being generated in their area and coordinate with EHS&RM to have the waste removed as it is generated.




05.01   EHS&RM has primary responsibility for the following duties associated with the management program for hazardous materials and hazardous waste:         


a.   Act as the custodian of required regulatory records for EPA, Department of Transportation (DOT), and TCEQ;


b.   Provide, as office of record, all necessary reporting requirements to local, state, or federal agencies as it pertains to the management of hazardous materials and hazardous waste;


c.   Coordinate disposal of all university hazardous waste, including acting as liaison between the hazardous waste generator (university department or activity) and the hazardous waste disposal contractor. EHS&RM also develops specifications and obtains bids, in accordance with university purchasing guidelines, for the university’s hazardous waste disposal service;


d.   Assist department heads, account managers and other university personnel in managing their departments’ hazardous materials and waste. This includes interpreting applicable regulations, coordinating or conducting personnel training, and establishing coordinated inspections of work areas;


e.   Identify university departments or activities that are hazardous waste generators based on the use of hazardous materials in the work area that are not consumed and that require disposal. EHS&RM will also ensure that each hazardous waste stream is properly characterized for inclusion in the university's Notice of Registration (NOR) to the TCEQ. University activities that have been identified as hazardous waste generators are identified in the List of Generators;


f.    Coordinate with TCEQ, EPA and DOT, as required, to resolve matters relating to the regulation of hazardous waste; and


g.   Assist departmental hazardous materials coordinators to develop spill prevention plans, chemical hygiene plans, prepare hazardous waste for disposal, and assist emergency response agencies to control a spill or potential chemical hazard.


05.02   Department Heads and Account Managers – All university department heads, account managers, and other personnel who are responsible for a department or activity in which hazardous materials are utilized or in which hazardous waste is generated have primary responsibility for assuring that applicable federal, state and local regulations and university policies and procedures are followed. Other responsibilities include:


a.   Maintain a Work Area Chemical List (WACL) and Material Safety Data Sheet (MSDS) file. Identify those chemicals that contain hazardous ingredients and require the use of appropriate personal protective equipment (PPE), while insuring that storage, handling, and disposal is performed in accordance with university procedures. (See also Hazardous Communication Program);


b.   Confer with EHS&RM to assure that their department’s hazardous materials and waste management practices conform to applicable regulations and policies;


c.   Assure that personnel and students who are involved in the acquisition, handling, use, experimentation, or disposal of hazardous materials or hazardous waste are properly supervised and trained. This includes ensuring that these individuals use appropriate protective clothing and equipment, are informed about the materials involved, and know proper spill control prevention procedures;


d.   Assure proper identification of waste chemicals, containerization, labeling, and storage within the department;


e.   Report hazardous chemicals to be processed for disposal to EHS&RM for coordination of pick up, storage, transport, and disposal. To facilitate removal and disposal of the hazardous materials or hazardous waste from the work area the following requirements must be met:


1)   Prepare a Chemical Removal Request Form (Waste Pick Up) listing each chemical item to be disposed of. The request form will be forwarded to EHS&RM.


2)   Unknown chemicals will have to be tested to characterize the waste stream.

            f.    Designate a departmental hazardous waste coordinator.


05.03   Environmental Health Specialist (EHS) – Designated EHS&RM personnel may perform a variety of duties associated with the university’s Environmental Health and Safety Program. With regard to the management and disposal of hazardous materials and hazardous waste, this may include the following:


a.   Provide chemical labels (Hazardous Waste Label) to the departments. These will be applied to the containers as waste in initially generated and collected by the generators;


b.   Inspect waste collection and storage areas in departments to ensure compliance to TCEQ and EPA regulations; and


c.   Collect waste containers from the generator departments on a weekly basis and transport them to the university’s Hazardous Waste Management Unit.




06.01   All spills of hazardous materials or hazardous waste must be immediately reported to EHS&RM. Spills of hazardous materials will be handled in accordance with the instructions on the respective MSDS (information provided with each chemical purchased from the manufacturer).


06.02   All departments or activities with hazardous materials and hazardous waste must have a spill prevention plan implemented within the work area. All personnel in the work area will be familiar with the plan. At a minimum, the spill prevention plan will:


a.   Require posting of the following information next to telephones that may be used to summon emergency assistance. This shall include the:


1)   name and telephone number of the emergency coordinator (EHS&RM and representative from the department); 


2)   location of fire extinguishers, eye wash stations, and emergency showers;


3)   location of spill control material and cleanup supplies; and


4)   the telephone number of the San Marcos Fire Department.


b.   Require training of all personnel in spill prevention and cleanup procedures for the hazardous materials and hazardous waste being generated;


c.   Require availability of necessary spill control materials to contain the spill;


d.   Require use of personal protective equipment (PPE) in the use and cleanup of hazardous materials or hazardous waste; and


e.   Require personnel to report spills to their supervisor, the University Police Department and to EHS&RM.


06.03   A copy of the department or activity spill prevention plan must be readily available to EHS&RM for their review and approval. It is suggested that consideration be given to posting the spill prevention plan on the departmental website.


06.04   Spill prevention plans may be specific to individual departments or activities, or may be standardized for an entire college or division or other area with common needs and activities. Standardization of plans within colleges, departments, or areas can be beneficial to their employees, as well as to EHS&RM.




07.01 The university’s Hazardous Materials and Hazardous Waste Management Program include initiatives to reduce the quantity of hazardous waste generated. The Source Reduction/Water Minimization Plan (SR/WM) as presented in Pollution Prevention Plan is prepared to comply with Senate Bill 1099 and includes the components required by the Texas Commission of Environmental Quality in TAC 35 Subchapter Q.




08.01 Reviewers of this policy include the following:


Position                                                            Date


University Safety Committee


Dean, College of Health Professions      October 1 E3Y


Associate Vice President for Research   October 1 E3Y

and Government Relations




This policy has been approved by the following individuals in their official capacities and represents Texas State policy and procedure from the date of this document until superseded.


Director, Environmental Health, Safety & Risk Management


Vice President for Finance and Support Services