Hazardous waste rules are governed by the Resource Conservation and Recovery Act at the federal level, and various state-level regulatory packages. Most University of Houston facilities generate some quantity of hazardous waste, but the way in which this is handled varies by location. Regardless of your location, if you cannot manage your waste under a different set of rules such as laboratory rules, used oil, or universal waste, you will be required to comply with hazardous waste rules. 

Anyone generating waste (even just copier paper) on behalf of the University of Houston has a responsibility to determine the regulatory status of the waste. This means classifying whether the waste is a hazardous waste, and which (if any) characteristics or listings in the rules apply to a specific waste. There is a further requirement to maintain documentation of this decision. EHS is available to assist in both the decisionmaking process as well as in maintaining documentation of the decision. 

Generally, hazardous waste can be either characteristic or listed. 

Characteristics of Hazardous Waste

Characteristics of hazarous waste can include ignitability, corrosivity, reactivity, and toxicity. All of these terms have a narrowly-defined meaning that may not match information on product labels, safety data sheets, or other sources of information directly. These characteristics can apply to both used and unused wastes, and any physical or chemical changes entailed in use can make a difference in the characterization. 

Toxicity is a particularly peculiar aspect to characterization because it really means certain quantities of contaminants or constituents are either present or absent based on a standardized analytical test. Not all toxic materials are characteristic for toxicity, and not all materials that are characteristic for toxicity would be considered toxic. 

Listed Hazardous Wastes

F-listed wastes are generally used materials (although some are materials that were produced using certain equipment that also produces particularly toxic and persistent materials). 

K-listed wastes are from specific industries, the University is generally not involved in any of these industries, but some research does use wastes that would be K-listed if they were not sent to the University for research. 

P-listed wastes are acutely hazardous wastes that apply only to unused materials, or portions of a material that are unused. 

U-listed wastes are hazardous, and apply to unused materials as well. There may be more than one applicable U-listing for a waste, in contrast to P-listed wastes that generally may only have one at the point of generation except in special circumstances. 

Assistance

EHS is available to provide assistance in waste classification for the University. Start by contacting EHS, preferably before you've started your waste-generating work.