EVALUATION OF THE
HAZARDOUS MATERIALS HANDLING FACILITY
AT THE UNIVERSITY OF WATERLOO
ERS 285 SPRING 1997
Julie Ellison, Jennifer Niece, Gerard Reuss
TABLE OF CONTENTS
FIGURE 1. WASTE TREATMENT SYSTEM AT THE UNIVERSITY OF WATERLOO
FIGURE 2. HAZARDOUS MATERIAL FLOWS THROUGH CAMPUS
Should Be Actors
4.1.4 Health and Human Safety
Sustainability is an important concept in the field of environmental
studies, and it can be worked towards in many different ways. In order
to assess sustainability, the systems involved in day to day lifestyles
must be understood. One of these systems, present on the University of
Waterloo campus, is the disposal of hazardous waste.
The irresponsible treatment of hazardous materials can pose health risks
to humans both in and outside of the workplace. Hazardous waste has the
potential to contaminate ecosystems, thereby entering the food chain and
affecting human health and ecosystem integrity. Diligence is necessary
in handling these materials to prevent such contamination.
The University of Waterloo's Hazardous Materials Handling Facility (HMHF)
is designed to accept and deal with all hazardous materials that are generated
in on-campus labs, studios and health care facilities. An audit was performed
on the HMHF to ensure that hazardous materials on campus are being handled
in the safest manner possible, in accordance with government protocols.
The audit was based on applicable municipal by-laws, the Fire Code of Canada,
and the Environmental Protection Act, the Atomic Energy Control Act, and
Guidelines for the Management of Biomedical Waste in Canada. Results of
this study were based on personal observations and interviews with the
HMHF and U of W Safety Office staff. For the purposes of this study, it
was assumed that the government standards were designed to promote sustainability.
Additional information to supplement the survey was collected through
three tours of the facility, and attendance on a weekly pickup around campus.
The tours were guided by both Safety Office staff and HMHF staff on separate
occasions, and the pickup was led by Scott Paterson of the HMHF.
Results of personal observations during the tours and pickup, as well
as survey results were compiled to create an overall understanding of the
strengths and weaknesses of the hazardous materials handling system. The
HMHF was found to be in compliance with 64.7% of the standards evaluated.
Areas for improvement include the storage of waste oil, storage of flammable/combustible
materials and safety precautions involving the transportation of hazardous
materials. Recommendations have been made to assist the HMHF to improve
the rate of compliance with the standards evaluated in this study.
1.0 Identification of System
This study will address the University of Waterloo's Hazardous Waste
Management System. In particular, it will focus on the Hazardous
Materials Handling Facility which deals with three major classes of
waste generated in lab, studios and health care facilities on campus: 1)
chemical wastes; 2) biological wastes; and 3) radioactive wastes.
of the System Study to the Sustainability of the Campus
Hazardous chemicals are important in our everyday lives. North Americans
have become dependent on petroleum and chemical products to maintain their
lifestyles. Concern should, however, be raised about the potential negative
environmental effects of hazardous wastes, and the accidental spilling
or discharge of these chemicals into sewers. As a research facility, the
University of Waterloo must be especially diligent in its compliance with
federal, provincial and municipal policies governing environment and safety
because of the variety and quantities of hazardous wastes produced on campus.
A sustainable University of Waterloo campus is dependent on the support
of sustainable subsystems within it. Creating a sustainable campus community
includes reducing waste products of all types and at all levels of activity
within the campus. A sustainable University of Waterloo would have less
hazardous materials entering the campus and those materials purchased would
be treated responsibly during their use. Students, staff and faculty would
be educated concerning the hazardous wastes generated on campus, and would
understand and follow University of Waterloo policies governing the correct
disposal of such wastes. As part of sustainable management of hazardous
materials, up to date techniques for the disposal of hazardous wastes would
be available on site or from outside contractors who specialize in the
disposal of hazardous materials.
An effective hazardous waste handling facility is an important step
for the university to move toward sustainability by diverting this waste
from landfills and sewers. A handling facility which complies with applicable
regulations ensures that the university contributes to sustainability by
diverting hazardous wastes from municipal landfills and sewers.
Past groups of ERS 285 students have also examined hazardous waste issues
on campus. In the winter term of 1995, a group of ERS 285 students undertook
a project entitled Chemical
Disposal in Science Labs at the University of Waterloo. The researchers
set out to discover if hazardous materials were being disposed of
into sewer systems, and if so, why. Education was identified as
a major component in the safe disposal of chemicals. Recommendations were
made to increase the level of training that students and teaching assistants
receive in preparation for conducting experiments involving potentially
hazardous materials. In the Winter 1997 term, a second group of ERS 285
students examined the Fine
Arts facilities on campus. They examined the types of solid and liquid
waste being produced, as well as alternative methods of disposal of the
waste. Increased education concerning the disposal of hazardous materials
was once again recommended for students using the Fine Arts facilities.
In both reports, students questioned the degree of compliance with University
of Waterloo Policy #34 and suggested that further study should be conducted
in this area.
The Hazardous Materials Handling Facility (HMHF) is designed to receive
all chemical, biological and radioactive wastes that are potentially harmful
to humans or the environment. This includes substances from all levels
(undergraduate, graduate and post-graduate) of laboratories and studios
on campus. The Safety Office must ensure that the HMHF complies with the
Protection Act, Regulation 309, as well as the University's Policy
#34, which adds stringent regulations to the federal policy (Fraser, pers
It is not within the boundary of this study to evaluate the sustainability
of government and university standards for the disposal of hazardous wastes.
This evaluation implicitly assumes that the higher authorities responsible
for creating these standards were knowledgeable concerning environmental
health and safety issues. However, it must be acknowledged that this assumption
is not necessarily correct. Not all regulatory standards were designed
specifically to promote sustainable practices.
The purpose of the HMHF is to collect wastes that are potentially hazardous
to human and/or environmental health and prevent them from entering traditional
waste streams. It provides a cost free outlet for hazardous waste generators
to send their waste materials where they will be safely disposed of either
at the university or off site. While not an endpoint of sustainability,
the diversion of hazardous materials from traditional waste streams helps
to prevent contamination of soil and groundwater resources and prevents
the exacerbation of ecosystem damage.
Procedures within the HMHF have been refined since it commenced operations.
Hazardous materials that can be reclaimed for use elsewhere are redistributed
within the academic community, decreasing both the unnecessary disposal
of usable materials and the demand for their creation (thus reducing the
energy, time and material resources consumed in their production, marketing
and distribution. A second sustainable development of the HMHF operation
is volume reduction of some hazardous materials; for example, salt solutions
containing metal ions, by evaporating water from the solution. This reduces
the resources required during the off campus decommissioning of these wastes
and recovers harmless substances (i.e. water vapour) that would otherwise
be removed from natural ecosystem cycles. This volume reduction was implemented
primarily as a cost saving measure for the safety department. In this economy-based
society, the correlation between decreased environmental impact and decreasing
costs will only encourage the continuance and expansion of such programs.
1.2 Background Information
The University of Waterloo is one of the larger hazardous waste generators
in the Region (Fraser, pers comm). This is a result of the university's
high full time student enrollment, (approximately 17,000), and its large
and active research programs. In an effort to effectively dispose of the
university's hazardous materials in a sustainable fashion, the Hazardous
Materials Handling Facility (HMHF) was established in 1992 (Fraser,
The Hazardous Materials Handling Facility is designed to receive all
chemical, biological and radioactive wastes that are potentially harmful
to humans or the environment. This includes substances from all levels
(undergraduate, graduate and post graduate) of laboratories and studios
on campus. The Safety Office must ensure that the HMHF complies with the
Canadian Environmental Protection Act Regulation 309, as well as the University's
Policy # 34, which adds stringent regulations to the federal policy (Fraser,
The HMHF is located in the Earth Sciences and Chemistry building, and
is serviced by Chemistry Stores. Hazardous wastes from labs in adjoining
buildings are delivered directly to the HMHF by lab personnel (e.g. TAs,
grad students) between 11am and 12pm, Monday to Friday. The completion
of inventory sheets and correct labeling are checked upon delivery. Additionally,
the HMHF provides a collection service for all hazardous wastes produced
on campus that cannot be delivered to the facility. Hazardous materials
are collected Tuesday afternoons at each of the following locations; B.C.
Matthews Hall, Environmental Studies, and Engineering 1. Additional pickups
may be made upon request. In order to be collected, materials must be in
a suitable container, supplied by the HMHF, and the containers must be
properly labeled. Proper labeling includes the name of the hazardous substance,
the department from which the substance is came, and the name of the supervisor
who has authorized the disposal of the substance. Once the materials are
received, they are cataloged and the best method of disposal or treatment
is determined (Fraser, pers comm).
Costs for the disposal of hazardous materials are covered fully by the
University's Safety Office. Over the past few years waste contractor disposal
costs have dramatically decreased from $90,000 in 1989 to $13,000 in 1995.
This significant decrease can largely be attributed to the evolution of
the hazardous waste management program. Wastes are now treated to decrease
their volume and toxicity before disposal, thereby reducing disposal costs.
Reusable hazardous substances have also been made available for redistribution
on campus and to other academic institutions and businesses around North
America. This allows the University of Waterloo to save money on the disposal
and purchase of chemicals (Fraser, pers comm).
A large number of policies, regulations, codes and laws must be followed
by the university. Some of the most applicable of these include: the Ontario
Environmental Protection Act, Regulation 309, which addresses general waste
management issues; Municipal by-law (1-90), which regulates sewer use;
National Fire Code, Section 4 (1994), which addresses the treatment of
flammable and combustible liquids; and the University of Waterloo Policy
34 (1993), which addresses issues of health and safety for employers, supervisors,
and workers .
1.3 Study Rationale
The handling and disposal of hazardous materials frequently raises questions
about human health effects and potential environmental consequences. Hazardous
materials disposal technologies support a large industry that supplements
more traditional waste disposal systems and helps to divert potentially
harmful substances from municipal landfill sites and waste water treatment
The disposal of hazardous wastes created in campus laboratories has
previously been a controversial issue between WATgreen, the Faculty of
Science, and the Faculty of Environmental Studies. In order to resolve
differences in opinion, concerned parties have held extensive meetings.
While these meetings have not reached a solution to appease all involved,
a potential cause for environmental and legal concern has been identified.
It is clear that the disposal of hazardous wastes requires further investigation.
1.4 Context of the System
The context of the hazardous waste system entails the university as
an educational institution, and as a integral part of the community. Additionally,
the university has legal obligations set by municipal, and federal governments,
and moral responsibilities to consider.
2.0 Objectives of the Project
The goal of this report is to assess the University of Waterloo's Hazardous
Materials Handling Facility to evaluate performance to standards of the
policies and regulations concerning the transportation, handling, storage
and disposal of hazardous wastes on campus. In particular, this report
will focus on activities in the Hazardous Materials Handling Facility on
UW campus to find out:
- if the HMHF is in compliance with all applicable policies (federal,
provincial, municipal and University of Waterloo)
- what safety and quality control procedures are in place to deal with
- what emergency response procedures are in place in case of accidental
This report may clarify the validity of current procedures or conversely,
may expose any deficiencies or breakdowns in the system. If problems do
exist, viable recommendations will be presented to improve the situation.
3.0 SYSTEM DIAGRAMS
FIGURE 1. WASTE TREATMENT SYSTEM AT THE UNIVERSITY OF WATERLOO
Figure 1 illustrates the governing structures that influence waste
treatment at the University of Waterloo and the sources and flows of waste
through campus operating systems. Red boxes refer to off campus policies
and regulations. Blue boxes are on-campus waste sources and administrative
bodies. Green boxes represent options for diversion and disposal of wastes
while the purple box is the system directly under investigation (The Hazardous
Materials Handling Facility).
FIGURE 2. HAZARDOUS MATERIAL FLOWS THROUGH CAMPUS
Figure 2 illustrates the generation and flow of hazardous materials
though the HMHF system. It outlines the collection system which brings
hazardous materials to the HMHF and decision making process for the classification
of hazardous materials after they enter the HMHF. As in Figure 1, blue
boxes represent on campus administrative bodies and sources of waste. Purple
represents all components and decision making within the HMHF while green
represents components that are involved once the materials have left the
The Hazardous Materials Handling Facility is the system boundary for
this study. This system exists within the larger system of waste management
on campus. The HMHF is the waste-management system designed to safely deal
with hazardous materials generated on campus. The functions of the HMHF
include the collection, treatment, storage and removal of hazardous chemical,
biological and radioactive wastes. Components involved in these functions
are lab equipment, ventilation mechanisms, emergency response protocols
and equipment, storage facilities, and containers.
In defining this system study, it is essential to identify all core,
supporting, and should-be actors. These include:
- Chemistry Stores employees, are responsible for conducting pick-ups
and supervising the drop off of hazardous wastes from generators on campus.
This includes ensuring that all inventory sheets and packaging labels are
properly completed at the time of receipt. Scott Paterson evaluates all
materials that come into the facility to determine their characteristics
and the most appropriate method of handling (i.e. disposal or reuse). For
chemicals that can not be reused, Paterson carries out any reactions or
volume reduction procedures that condense the amount of wastes to be disposed
of, optimizing the cost and efficiency of disposal. When no further treatment
on campus can be carried out, Paterson initiates and supervises the removal
of wastes by authorized hazardous waste removal companies such as Laidlaw
Inc. or S.B. Meyers.
- Safety Office employees serve as environmental health and safety
resources for all members of the University of Waterloo community to meet
the standards of a safe and healthy campus. The HMHF is under the directive
of the Safety Office.
- Teaching Assistants, Lab Coordinators and Research Technicians
are responsible for ensuring that hazardous wastes produced in labs and
studios on campus are delivered to the HMHF. Those working in instructional
positions are also responsible for ensuring that all hazardous materials
are safely collected during the procedures.
- Hazardous Materials Disposal Companies (eg: Safety Kleen, Laidlaw,
Gananoque Incinerator) are contracted by the University of Waterloo Safety
Department to safely remove and dispose of specific hazardous wastes as
- Chemistry Stores works with the HMHF to provide storage space
for some materials from the HMHF. Chemistry Stores is also the clearing
house for reusable chemicals isolated during HMHF classification procedures.
Should Be Actors:
- Students should be taking an active role in ensuring the correct
disposal oft hazardous materials used and/or generated in educational labs
- Chemical manufacturers should ideally take responsibility for
the full life cycle of their products, including the provision of material
safety data sheets concerning the handling and use of hazardous materials
as well as providing environmentally safe disposal methods.
4.1 Major Issues Involving
There are many expenses involved in the proper disposal of hazardous
wastes, some include; transport, handling, and storage.
There are environmental concerns associated with the improper disposal
of hazardous wastes affecting the ecosystem and its inhabitants. These
relate to air pollution, surface and groundwater pollution, and ozone depletion.
The university must uphold its positive reputation. This includes a
high level of ethical and academic standards.
4.1.4 Health and Human Safety:
It is the responsibility of HMHF staff to ensure proper disposal of
hazardous wastes. This must be done to protect students, faculty and staff
from the adverse effects of radioactive, chemical, and biological wastes
produced on campus.
It is the responsibility of the university to ensure that those in contact
with hazardous wastes on campus are educated on proper handling and disposal
Federal, provincial, municipal, and institutional laws govern the practices
of the HMHF. It is imperative that these laws are adhered to and enforced.
5.0 Criteria to Evaluate
As a means to evaluate the HMHF, the following criteria must be considered:
- Compliance of HMHF with provincial, municipal and university policies,
regulations, codes and laws
- knowledge of the HMHF staff regarding safety measures, storage facilities
(i.e. ventilation), personal protective equipment, and emergency procedures
(i.e. spill response)
- effectiveness of safety measures, storage facilities, personal protective
equipment, and emergency procedures (i.e. spill response)
- quality control procedures
- condition and integrity of HMHF equipment and storage containers
The above information is critical to the evaluation of the HMHF as it
allows for both qualitative and quantitative results to be examined and
6.0 Means to Collect Data
In order to perform an assessment of the HMHF, various related experts
were contacted, and information on policies, regulations and laws regarding
proper hazardous materials disposal was collected. After the necessary
information was gathered, the facility was then audited to determine if
the governing structures are adhered to. Specifically, data collection
- reviewing published and internet documentation of federal, provincial,
municipal and university policies, regulations, codes and laws;
- creating a checklist based on applicable municipal policies/by-laws
to be used as an instrument for the audit;
- using the checklist to evaluate compliance with accepted standards;
- interviewing Safety Office personnel and HMHF staff.
Data was collected based on a "snapshot" of tours and attendance
at a pickup. It is believed that additional tours of a similar nature would
not have provided any extra information. It should also be noted that the
audit was performed based on this snapshot of information, and no efforts
were made to extrapolate what may have occurred in the past or what may
occur in the future.
7.0 Key Contacts
- Ian Fraser, Angelo Graham, Kevin Stewart (Safety Office staff)
- Scott Paterson (Runs HMHF)
Based on Survey Results
1. An oil spill occurred on morning when survey was conducted. This
could have been caused by a variety of factors such as the questionable
integrity of the storage drum, combined with the particularly corrosive
materials inside (most of the drums contain corrosive materials). There
was also evidence of previous spills (e.g. stains on the floor) that were
overlooked during the initial tour of the HMHF because they were covered
with full drums which were sent for treatment just before the survey. Fortunately,
the recent shipment of materials facilitated access to the leaking drum.
The leaking drum was scheduled to be removed in a shipment, before the
end of the summer, its contents were transferred to a new container and
will be disposed of in the next shipment.
2. Although Scott Paterson does not have all by-laws memorized, they
are accessible and he appears to diligently consult the appropriate documentation
if he is unsure as to the proper disposal of a substance.
3. Solutions with multiple components are disposed of according to the
most dangerous component.
4. PCBs are not considered "waste" until they are shipped
(e.g. light ballasts).
5. "Flammable Materials" stickers on cabinet doors are damaged
/ difficult to read.
6. Biomedical waste is not compacted.
7. 45 gallon drums are not labeled as flammable or combustible.
8. 45 gallon drums in lab are not closed, but are ventilated to the
9. Waste oil tank room is not identified on the outside with "Waste
Oil Tank of 230L inside" for fire fighting purposes.
10. Waste oil tank is not labeled on two sides, must have overflow protection,
rust coating, drip tray, and should be opened only when needed.
11. Waste oil tank is not vented to the outside (cap is always open,
therefore ventilation occurs into the storage room).
12. Biomedical waste is not separated into specified categories and
colour coded according to these categories. (Biomedical waste is not treated
after it is received from the original generator.)
13. Facilities do not exist to store biohazardous waste below 4 degrees
Celsius. However, biohazardous waste is generally kept frozen at the department
of origin until it is transported to the HMHF just before a shipment out.
14. Although the Transportation of Dangerous Goods Act does not apply
at U of W because it is private property, Certificates of Approval as required
under section 13 of the Environmental Protection Act, Regulation 309 are
not obtained for the transportation of hazardous materials on campus.
15. The vehicle transporting dangerous goods does not comply with all
safety standards, e.g. the body is not leak proof.
16. Someone is not present with the hazardous materials at all times
during pickups (based on personal communication).
17. Not all rooms in the HMHF contain drainage systems that terminate
where a potential spill will not create a risk to the environment or to
human health and safety.
18. Containers with flammable or combustible liquids are sometimes left
open when not in use (but these are ventilated).
Note: With regards to recommendations 7-11, 17-18, Section 4 of the
Fire Code is still only proposed in Ontario, and is not yet law. In anticipation
of this Code becoming law in the future, it is important to comply with
it to minimize future changes.
Results of the audit indicate that the University of Waterloo's Hazardous
Materials Handling Facility is in overall compliance with 55/85 or 64.7%
of the by-laws and regulations included in this study. The audit itself
was divided into four sections: Handling/Disposal, Storage, Transportation,
and General Safety Measures of the HMHF. The facility was found not to
be in compliance with 23/85 or 27.1% of the questions posed, while 7 questions
(8.24%) were either not answered or were deemed inapplicable to the study.
Specifically, the HMHF was found to have high compliance rates in the
areas of Handling/Disposal (86.4%), and Safety Measures (85.7%). In general,
the HMHF procedures are very sensitive to regulations for the treatment
of radioactive materials, the disposal of hazardous solutions into sewage
systems as well as spill response preparedness within the facility. Compliance
is met in obtaining permission for the professional disposal of bulk volumes
of hazardous substances. Although not addressed specifically during the
HMHF audit, it should be noted that improvements have been made in recent
years to increase the reclamation of reusable materials and to reduce the
volume of hazardous wastes that must be disposed of from on campus activities.
The facility was found to be less compliant in the areas of Storage
(50% compliance), and Transportation (69.2%). Major areas of concern surround
the storage of waste oil and flammable materials. Protocols for the transportation
of dangerous goods were also found to be frequently not in compliance.
(Transportation issues do not involve the Transportation of Dangerous Goods
Act which is not applicable on private property but are stipulated in Regulation
309 of the Ontario Environmental Protection Act.)
Based on the assumption that the applicable laws and policies promote
sustainability, the University of Waterloo's Hazardous Materials Handling
Facility cannot be considered sustainable because of its low rate of compliance
in the areas of storage and transportation.. However, other components
of the system, such as safety measures, and handling/disposal are well
in compliance. A sustainable system would have a high rate of compliance
in all areas. As sustainability is considered to be a process, and not
a measurable endpoint, the Hazardous Materials Handling Facility is currently
promoting many sustainable practices.
Handling/Disposal of Hazardous Waste:
- Develop and implement the use of criteria for the acceptance/rejection
of 45 gallon drums based on integrity of building materials.
- Reorganize storage of 45 gallon drums in room "154" (solvent
storage room) into rows to provide access to all drums in the event of
a spill. Conduct daily/periodic inspections of outside/underside of drums
to check for leaks. Include a diagram of current and suggested layout.
Storage of Hazardous Waste:
- Warning stickers for cabinets containing flammable materials should
be replaced as they are faded.
- Drums and pre-packaged containers for flammable or combustible liquids
should be labeled to indicate that the material is flammable, that it should
be kept away from heat, sparks, and open flames. Additionally, the container
should be closed when not in use. ( Fire Code: section 126.96.36.199 (1) )
- The labeling of containers must be done upon delivery to the HMHF rather
then just at pick-up.
- All containers with flammable and combustible substances should be
closed when not in use (in accordance with the fire code).
- The HMHF should use a yellow "flame resistant" cabinet to
store flammable materials.
- Hazardous materials should not be stored above eye level.
- The outside of the room containing the waste oil tank should be labeled
with the identification of the liquid and capacity of the storage tank.
- The connections for the openings in the tank should be liquid and vapor
- A tank with overflow protection and rust protection should be used.
- Proper identification should be used (i.e. clearly identify on at least
two sides what is in the tank)
- The tank should be vented to an outside location at a distance of not
less then 1.5m from any building opening. (in accordance with the fire
code section: 188.8.131.52 (1))
- All containers of flammable or combustible liquids should be closed
when not in use.
- Biomedical waste should be separated into the following categories
and colour coded:
- human anatomical waste
- microbiology laboratory waste
- human blood and body fluid waste
- waste sharps
- Proper refridgeration facilities (at or below 4 Celsius) should be
provided for the storage of biomedical wastes.
Transportation of Hazardous Waste:
- The HMHF should review section 13 "Standards for Waste Management
Systems" of the EPA, regulation 309. This section discusses transport
- The body of the vehicle used for collection of wastes should be made
leak proof and covered to provide protection against odor emissions.
Safety Measures (Within the HMHF):
- All rooms in the HMHF should be connected to a drainage system that
terminates at a location where the spill will not create a risk to public
health or safety.
10.1 General Recommendations:
- A future study should examine each area of waste (biological, radioactive,
chemical) as individual units.
- The sustainability of the various policies, regulations, by-laws, guidelines
which were used for the creation of the questionnaire should be evaluated.
- The positive attributes of the HMHF should be further publicized and
shared with other institutions that handle and dispose of hazardous materials.
- There should be more qualified and knowledgeable staff to assist Scott
Paterson (possibly a co-op student).
- All containers supplied to the waste generators for storage of hazardous
material on campus should be of good integrity (tight fitting lids, sturdy,
- Pick-ups of hazardous waste should be further coordinated with Wilfrid
Laurier and U of W to increase the frequency and efficiency of the pick-ups.
Atomic Energy Control Act - Transport
Packaging of Radioactive Materials Regulations; SOR/83-740 (as am. By SOR/89-426;
90-172; 90-192;91-304; and 92-150)
Fire Code of Canada. Section 4.
Fraser, Ian. University of Waterloo Safety Office. Personal Communication.
Guidelines for the Management of
Biomedical Waste in Canada. February, 1992.
Government of Ontario. Environmental Protection Act, October 1990. Revised
Statutes of Ontario, 1980, ch141 and Regulation 308, Revised Regulations
of Ontario, 1980 as amended to O.Reg.90/90.
Government of Ontario. Environmental Protection Act, Regulation 309.
Paterson, Scot. University of Waterloo Hazardous Materials Handling
Facility. Personal Communication. June 12, 1997.
Regional Municipality of Waterloo. By-Law #1-90. Sewer Use By-Law.
Theisen, Eric J.. Driver's Guide to the Transportation of Dangerous
Goods Act, 3rd Edition. Carswell Thomson Professional Publishing. copyright
A: Criteria to Evaluate the Hazardous Materials Handling Facility:
Questions to Answer Through Personal
Observation and Communication with
HMHF and Safety Office Staff
NOTE: Yes/no and multiple choice answers in
red are the ones given by Scott Paterson, or have been observed in the
HMHF. Questions which are green, were left blank because they were not
answered or were deemed inapplicable to the study.
(1) HANDLING/DISPOSAL OF HAZARDOUS WASTE
(a) Chemical Waste:
How are solutions containing hydrogen sulfide, carbon disulfide, reduced
sulfur compounds, amines or ammonia disposed of? (Regional
Municipality of Waterloo, By-Law #1-90 section 6(1)2(b)
- They remain in the containers they come in, and are lab packed with
Does water, other than storm water ever enter
the HMHF? YES NO
If so, how is it disposed of? (Regional
Municipality of Waterloo, By-Law #1-90, section 6(1)-2d)
How are solutions with pH less than 5.5 or greater than 9.5 disposed
of? (Regional Municipality of Waterloo, By-Law #1-90, section
- They are disposed of according to the above By-Law, and when they
cannot go down the drain, they are packed in either halogentaed or non-halogenated
packs. The following twelve questions relating to the concentrations of
chemical solutions were answered in the same manner. Solutionsare disposed
of in bulk drums in accordance with the Municipal By-law.
How do you handle and dispose of solutions:
containing phosphorus? At what concentrations?
(b) 5-10 mg/L
(d) >20mg/L (Regional Municipality
of Waterloo, By-Law #1-90, section 6(1)-2k)
containing Kjeldahl nitrogen? At what concentrations?
(d) >150mg/L (Regional Municipality
of Waterloo, By-Law #1-90, section 6(1)-2l)
containing phenolic compounds? At what concentrations?
(d) >1.5mg/L (Regional Municipality
of Waterloo, By-Law #1-90, section 6(1)-2m)
containing two or more distinct liquid layers? (Regional
Municipality of Waterloo, By-Law #1-90, section 6(1)-2n)
- Disposed of according to the most dangerous contents.
containing Cl or SO4? At what concentrations?
containing Al or Fe? At what concentrations?
containing F? At what concentrations? ________________________________________________________________________________________________________________________________________________
containing Sb, Bi, Cr, Co, Pb, Mn, Mo, Se, Ag,
Sn, Ti, V? ________________________________________________________________________________________________________________________________________________
At what concentrations?
containing Cu, Ni, Zn? At what concentrations?
containing CN? At what concentrations? ________________________________________________________________________________________________________________________________________________
(b) 0.5-1 mg/L
containing As? At what concentrations? ________________________________________________________________________________________________________________________________________________
containing Cd? At what concentrations? ________________________________________________________________________________________________________________________________________________
(a) <0.25 mg/L
(b) 0.25-0.5 mg/L
(c) 0.5-1 mg/L
containing Hg? At what concentrations? ________________________________________________________________________________________________________________________________________________
(d) >1.5mg/L (Regional Municipality
of Waterloo, By-Law #1-90, section 6(1)-2p)
How are fuels disposed of? (Regional Municipality of
Waterloo, By-Law #1-90, section 6(1)-2q)
- Gasoline and keroseneare packed in a drum containing halogenated
How are PCBs disposed of? (Regional Municipality of Waterloo,
By-Law #1-90, section 6(1)-2q)
- PCB's are stored at North Campus (Bauer Warehouse) which is diked
and fenced. It contains 90 drums of PCB's.
How are pesticides disposed of? (Regional Municipality
of Waterloo, By-Law #1-90, section 6(1)-2q)
- They are lab-packed in their
(b) Biological/Biomedical Waste including:
Is biological waste destined for off-site disposal compacted? YES NO
(c) Radioactive Waste:
How are radioactive wastes handled and disposed of? (Regional
Municipality of Waterloo, By-Law #1-90, section 6(1)-2s - substances as
defined in Regional Municipality of Waterloo, By-Law #1-90, section 1)
- Long-lived: goes to Chalk-River
- Short-lived (half life of 15-20
days): stored at the HMHF until decomposed , then sent to a landfill
(2) STORAGE OF HAZARDOUS WASTE
(a) Chemical Waste Not Including Waste Oil:
How many flammable/combustible materials are stored in, or adjacent
to exits, elevators or principle routes that provide access to exits? (Fire
Code, Section 184.108.40.206)
Are flammable/combustible liquids with individual capacities of less
than 230 L stored in either polyethylene drums, stainless steel drums or
metal aerosol containers? YES NO
How many? (Fire Code - Container Storage and Handling,
- Varies depending on the shipment size.
How many drums and pre-packaged materials for flammable/combustible
liquids are marked with warning labels to indicate that the materials are
flammable? (Fire Code - Marking or Labels, section 220.127.116.11)
- This is done by the shipping companies. The fire department knows,
or assumes that all the material is flammable.
What is the quantity (in L) of flammable/combustible liquid in each
cabinet? (Fire Code-Container Storage and Handling, section
- Unknown quantity.
- Quantities vary.
- Air reactives and water reactives are kept separate.
How many cabinets containing flammable/combustible liquids are labeled
with "flammable materials-keep away from open flame"? (Fire
Code-Container, Storage and Handling, section 18.104.22.168)
How many L of flammable/combustible liquids are contained in rooms,
but not in a cabinet? (Fire Code-Container Storage and Handling,
- Indeterminate, there is a room for redisributables.
Are the contents of rooms storing flammable/combustible liquids arranged
to provide aisle widths of not less than 1m? (Fire Code sec
How many containers used for the storage of flammable/combustible liquids
in the laboratory are more than 5L in capacity? (Fire Code
- Many containers are (lab packs).
Are flammable/combustible liquids stored in cabinets or rooms separated
from other dangerous goods? (Fire Code sec 22.214.171.124)
Is the room containing a storage tank made liquid-tight where the walls
join the floor? (Fire Code sec 126.96.36.199(1)(c)) YES
Is there a minimum clear space of 550mm maintained between the walls
of the room and the sides of the storage tank? (Fire Code
sec 188.8.131.52) YES NO
Are placards identifying the liquids stored and the capacities of the
storage tanks posted in a conspicuous location outside of the room, and
is that information included in the fire safety plan? (Fire
Code sec 184.108.40.206) YES NO
Are all connections for all openings in the tank liquid and vapor tight?
(Fire Code sec 220.127.116.11(1)) YES NO
Are connections to the tank through which liquid can flow provided
with valves located as close as practical to the tank? (Fire
Code sec 18.104.22.168(2)) YES NO
Is the cap or cover used for measuring protected against overflow and
vapor pressure by means of a spring-loaded check valve? (Fire
Code sec 22.214.171.124(2)) YES NO
Do fill pipes terminate within 150mm of the bottom of the tank to minimize
the possibility of generating static electricity? (Fire Code
sec 126.96.36.199(1)) YES NO
Is the storage tank equipped with devices to prevent overflow? (Fire
Code sec 188.8.131.52) YES NO
Is the tank identified clearly as to its contents on at least 2 sides?
(Fire Code sec 184.108.40.206) YES NO
(b) Waste Oil:
Is the waste oil tank coated with rust-resisting material compatible
with the tank to act as corrosion protection? (only if the tank is made
out of any ferrous substance) (Fire Code sec 220.127.116.11)
Are tank supports installed on firm foundations designed to minimize
uneven settling of the tank and to minimize corrosion of the part of the
tank resting on the foundation? (Fire Code sec 18.104.22.168(2))
Does the tank contain a cap or cover which is opened only when the
liquid level is being measured? (Fire Code sec 22.214.171.124)
Are the base and walls of the dike constructed and maintained to provide
impermeability? (Fire Code sec 126.96.36.199(1)) YES
Is the tank supported in a manner that will prevent
the allowable design stress of the tank from being exceeded? (Fire
Code sec 188.8.131.52(4)) YES NO
The waste oil tank rest on the ground on foundations or on supports
made of: (Fire Code sec 184.108.40.206(1))
Is the vent pipe outlet for the tank located outside the building,
not less than 3.5 m above the adjacent ground level, not less than 1.5m
from any building opening and discharged so that flammable vapors will
not enter the building or be trapped near any part of the building (only
if waste oil is flammable)? (Fire Code sec 220.127.116.11(1)) YES
Do vent pipe outlets discharge outside buildings not less than 2m above
the adjacent ground level and not less than 1.5m from any building opening
(only if waste oil is combustible)? (Fire Code sec 18.104.22.168(2))
(c) Biological / Biomedical Waste (all
questions were taken from the "Guidelines for the Management of Biomedical
Waste in Canada" , Feb. 1992)
Is biomedical waste segregated from the general waste streams? (Section
3.3) YES NO
Is biomedical waste separated into the following categories: (Section
3.3) YES NO
(a) human anatomical waste?
(b) microbiology laboratory waste?
(c) human blood and body fluid waste?
(d) waste sharps?
Is biomedical waste labeled with a biomedical waste symbol? (Section
3.5) YES NO
Are plastic holding bags sturdy enough to resist puncture under conditions
of use and to the point disposal? (Section 3.5) YES
Are containers for biomedical waste colour-coded according to the following:
(Section 3.5) YES NO
human blood and body fluids waste....................................yellow
If complete compliance is not met, what percent of containers are not
colour-coded? (Section 3.5)
10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Is biological waste stored in an area totally enclosed
and separate from supply rooms or food preparation areas?(Section
What temperature is un-preserved bio-medical waste stored
at (if stored for more than four days)? (Section 3.7)
(a) 0-4 C
(b) 5-7 C
(c) 8-10 C
(d) >10 C
How many facilities, used to refrigerate or freeze stored
biohazardous waste, have locks and biohazardous symbols?
(d) NONE ( N/A: there are no freezers)
(3) TRANSPORTATION OF HAZARDOUS WASTE
(a) Chemical Waste (Documentation):
When are Part A and B of the manifest for transportation
completed and submitted to the director of the waste management branch?
(a) 1-3 working days after transfer
(b) 1 week after transfer of wastes
(c) 10 days after transfer of waste
(d) 1 month after transfer of waste (Handbook
of Environmental Compliance in Ontario, 2nd Edition. Section 4.5 - Manifest
System for Subject Wastes. 1994)
How long are copies of the manifest retained after a
pick-up? (Handbook of Environmental Compliance in
Ontario, 2nd Edition. Section 4.5 - Manifest System for Subject Wastes.
(a) two months
(b) 6 months
(c) 1 year
(d) two years (and plus)
Is hazardous waste leaving campus always transferred
to a waste transportation system operating under a Certificate of Approval?
(EPA Regulation 309, Section 16 - Manifest - Generator
Requirements) YES NO
Does the HMHF complete a manifest in respect to the waste
in accordance with Regulation 309?
Is a certificate of approval granted
for the transport of hazardous materials? (EPA Regulation
309, Section 13) YES NO
Is the U of W vehicle clearly marked with the name and
number that appears on the Certificate of Approval that authorizes the
transportation of materials? (EPA Regulation 309,
Section 13) YES NO
Is there a copy of the Certificate
of Approval in the vehicle? (EPA Regulation 309, Section
(b) Radioactive Waste (Documentation &
How much of the hazardous waste received by the HMHF
is radioactive material?
Before the transportation of radioactive material, is
it ensured that:
(1)All closures, valves or other openings of the package
are properly closed in accordance with instructions set out by the designer,
manufacturer or distributor of the package? (Section
(2) The intended recipient of the material has been informed
of the nature of the material, and the appropriate certificates of approval
have been obtained? (Section 17 (d))
Is radioactive material ever transported in packaging
with other material that has the potential to react / is not normally used
in conjunction with the radioactive material? (Section
What other precautions are taken
concerning the safe transport of radioactive material on campus? (AECA,
Section 14) Source: Ecolog - Canadian Pollution Legislation - Federal;
p.Can 40.50; no.4 - July 1992 Atomic Energy Control Act - Transport Packaging
of Radioactive Materials Regulations; SOR/83-740 (as am. By SOR/89-426;
90-172; 90-192;91-304; and 92-150) _________________________________________________________________________________________________
(c) General Safety Measures
of the Vehicle Transporting the Hazardous Waste:
Is the body of the waste collection vehicle, and waste
carrier, able to withstand abrasion and corrosion from wastes intended
for transport? (EPA Regulation 309, Section 13)
Is the body of the waste collection vehicle leak proof?
(EPA Regulation 309, Section 13) YES
Is the substance storage area of the vehicle covered
to prevent odour emissions? (EPA Regulation 309, Section
Are substances within the vehicle protected from falling,
or being blown out of the vehicle during transport? (EPA
Regulation 309, Section 13)
Is one of the driver, receiver,
or generator of waste, present with the waste at all times? (EPA
Regulation 309, Section 13) YES NO
(4) SAFETY MEASURES (within the HMHF)
(a) Spill Response:
Are potential spills (of flammable or combustible liquids)
prevented from entering public sanitary, storm sewers or natural waterways?
(Fire Code -Spill Control, Section 22.214.171.124)
Are there non-combustible sills, curbs or dikes of sufficient
height to contain a spill in a room containing hazardous material? YES
If so, how many rooms have them? (Fire
Code - Spill Control, Section 126.96.36.199)
(a) EVERY ROOM
(b) MOST ROOMS
(c) SOME ROOMS
In rooms where hazardous material are stored, are the
floors sloped to divert any spills to a drainage system ? (Fire
Code - Spill Control, section 188.8.131.52) YES
Is there a drainage system designed to drain a spill
of flammable or combustible liquids? YES NO
If so, does this system terminate at a location where
the spill will not create a risk to public health or safety (e.g. through
fire, contamination of drinking water, contamination of storm or sanitary
sewers)? YES NO
If so, how many rooms contain such a drainage system?
(Fire Code - Drainage Systems, Section 184.108.40.206)
(a) EVERY ROOM
(b) MOST ROOMS
(c) SOME ROOMS
Is there a ventilation system in the enclosed area where
class 1 and class 2 liquids are processed, dispensed or used? (Fire
Code - Section 220.127.116.11 (1 (a) (b) ) ) YES
Is mechanical ventilation used if flammable liquids are
dispensed within the storage room? (Fire Code, Section
Does mechanical ventilation in storage rooms provide
at least 18m3/h of exhaust air per square metre of room area, but not less
than 250m3/h? (Fire Code, Section 18.104.22.168 (3))
Is the make-up air for a natural ventilation system supplied
directly from outside the building from a source that is remote from any
discharge outlet? (Fire Code, Section 22.214.171.124(6))
(c) Fire Safety/Protection:
How many rooms used for storage of flammable or combustible
liquids have portable fire extinguishers? (Fire Code,
- Most rooms have fire extinguishers, but all rooms have a fire suppression
Are containers of flammable or combustible liquids left
open when not in use? (Fire Code, Section 126.96.36.199(2))
(b) SOMETIMES (but
Is the room containing a storage tank separated from
the rest of the building by a fire separation having a fire-resistance
rating of at least 2h? (Fire Code, Section 188.8.131.52(1)(a))
YES NO (3/4 - 1.5 hours)
B: Interview Notes With Scott Paterson
INTERVIEW NOTES FROM JUNE 12, 1997 MEETING WITH SCOTT PATERSON, HMHF
- Spill Response Team for UW was trained in a one day practical training
course by Spill Management Inc. Additional courses will be taken by team
members at Lambton College in Sarnia in August 1997.
- Members of Spill Response Team are from Physics, Safety Office, Chem
Stores, and the UW Police.
- contains lockers with spill response equipment, radiation equipment
(meters), and a freezer of chemicals which must remain cold taken from
a departed lab instructor.
- the facility is protected with an alarm system equipped with a motion
sensor. The alarm system is linked to Chem Stores.
- floor throughout the facility is epoxy coated, and doorways have sills
to contain spills.
Room 150 - Receiving Lab
- everything from labs brought here regardless of concentration.
- people dropping off to sign in and label containers unless product
in original container.
- contains 2 sensors to release CO2 into room in case of fire.
- rain monitored by MOEE.
- photochemical recycling, boiling off groundwater, vented out through
fumehoods, solvents bulked here.
Room 152 - Lab Pack Area & Redistribution Area
- items separated into oxidizers, base, paint, dry organic and acids,
then packed in vermiculite for absorption.
- in the past, $80,000 - $100,000 was spent in disposal
- new practices of recycling photochemicals, selling redistributables
and boiling off water decreased costs.
- room contains SCBA equipment and CO2 cylinders linked to sensor system
for fire response in all rooms.
Room 153 - Radioactive Material, Chemical Lab Packs
- room contains liquid and lab packed radioactive waste, 45-gallon aqueous
waste drums, both full and empty, lab packed biological waste, and lab
packed chemical waste.
- cardboard boxes for biological waste have 2 plastic liners.
- Laidlaw pre-approves the lab packs through inventory sheets before
- Laidlaw labels containers before shipment.
- room contains radioactive P32, S35, C14, H3 (tritium), I125, Cr5, Fe59.
- C14, H3 to Chalk River.
- others left to decay for 10 half lives then tested by landfill staff
- floor slanted toward epoxy coated dry sump with capacity of 1-2 drums.
Room 154 - Bulk Solvents, Oil for Recycling
- room contains 500 gallon waste oil drum, varsol, bulk solvents, explosion-proof
lighting, location of Chem Stores dispensing
- clay and stones with solvent are "dried" and sent to landfill
(after passing "slump test")
- 45 gallon oil drums reused until they start to appear old. Then used
for solvents, and sent out in shipment.
- empty solvent drums (new from manufacturer) used to supply Chem Stores
are used for bulking, or new drums are bought.
Room 155 - Class I Explosion-Proof Room
- contains blowout panels to reduce force of blast.
- labeled as room with radiation hazard.
- contains equipment used for groundwater analysis.
- steep slope toward troughs.
- originally had only one trough leading to storm sewer, redesigned in
case of spill.
- now 2 troughs, original for spill (blocked off) and second for rainwater
(to storm sewer).
- lab hazardous chemicals to be brought to HMHF, and HMHF staff will
decide treatment/disposal method.
- many TAs are accustomed to other practices in other countries.
- Sr. Demonstrators know that nothing is to go into drain, emphasized
through informal communication with Scott.
- each room contains sills and grounding.
- Transportation of Dangerous Goods regulations regarding plackarding
of vehicles and manifesting waste do not apply to UW because waste is being
moved on private property, and amounts are below guidelines.
- MOEE regulates transportation through manifests.
- HMHF ships two times per year, but getting approval from receiving
company takes a long time.
- floor drains in mail hallway between rooms drain into sanitary sewer
I have read the above document, and will attest to its accuracy.
Scott Paterson HMHF Staff
C: Interview Notes With Ian Fraser
CONVERSATION WITH IAN FRASER, HEALTH AND SAFETY
- Ian is a biologist, working as Radiation Safety
Officer. Has been working at UW since 1975, with H&S since 1989. Worked
for nuclear plants previously.
- HMHF takes all haz waste produced by UW.
- Hazmat defined by EPA reg 308: anything that
can't go to landfill, sewer or air.UW's Policy 34 adds to this.
- UW produces around 6 chem/month that have never
been used before.
- Municipal sewer bylaw follows Env Can model bylaw.
Not all inclusive, but good as a guideline.
- sample chems: athidium bromide (genetic fingerprinting
- HMHF established in 1991
- they are storing 91 drums of PCBs now. Pickup
in June (?). PCBs sent to Rollins N.C. for destruction
- they have a detailed inventory of chem wastes
- UW is not responsible for the waste at the transfer
- Safety Office pays 100% for disposal. Most research
grants do not include chem disposal.
- Radiation safety course and virtual tour of HMHF
- Costs decreased from $90,000 in 1989 to $13,000
- They want spills cleaned up immediately, don't
worry about spill kits. Some spill kit powder reacts with chems.
- Every Tues pickup at 4 buildings. Containers
are supplied by HMHF if needed. Chems must be labelled and someone must
be at loading dock with chems.
- Scott Patterson (chemist) does all the packing
and treating & receives chems from 11-12 weekdays.
- hazmat labelled with stickers when it comes to
HMHF. Stickers include: chem name, dep't & name of supervisor. Label
info entered into computer.
- Chems that can be reused are sold for cheap to
"recognized institutions" or profs. listing of avail chems on
net. This saves on disposal, and generates revenue. profits to Chemstores
for storage/admin costs.
- chems that can be treated are done so in the
lab based on previously documented processes, prudent practices, standardized
methods (ie: cyanides treated with bleach - still toxic, but costs less
to dispose of . Photographic soln's - silver separated and sold to make
money. Silver will wipe out sewage treatment bacteria. Recycle acetone,
the n dumped into container - redistilled and used again. Salts: glass
coil boils off water, then sent out as waste.
- Non-hallogenated solvents separated from hallogenated.
- Non-hallogenated can be reused as fuel.
- Hallogenated are more dangerous (methylene chlorine
must be burned in cement kilns. produces furans when burned).
- Compressed gas cylinders are stored due to high
disposal costs. Taken apart on site if safe.
- Waste is shipped out, manifest signed by company,
sent to Env Can
- Radioactive waste sent to Chalk River. If short-lived
(15-20 days), kept for a year with radioactivity measured weekly.
- Biological waste goes to the incinerator in Gananoque
for $.40/lb. (type not important). Used to be burned on campus.
- Ian inspects transfer sites for quality control
and to ensure job is being done right.
- Waste stays at a transfer site for a max of 30-90
days (dependent on contract & type of waste) usually 3 days.
- Security system, linked with Chemstores
- Suits, gloves, spill kits, pads (sold in chemstores),
booms, peat, freezer with unknowns.
- CO2 fills room if fire alarm.
- ventilated storage for acids and flammables.
- fume hoods.
- silver separation - Greenflow (1-800-287-5416)
- company in Montreal comes to get silica, refines
it for free and sells it back to us.
- bulk solvents (ventilated) chlorinated &
- NiCad batteries, expensive to dispose of ($50/lb)
- reg batteries supposed to go to landfill
- no explosion-proof lights
STORAGE AREA - ASSORTED CHEMS
- drums packed with vermiculite, similar chems
- shelves organized in alpha order. mostly (80%)
dry chems, no explosion-proof lights
OIL STORAGE ROOM
- explosion-proof lights, ventilated, bermed, sloped
floor to catch basin. secondary containment?
- 45 gal drums in storage for disposal - not on
- waste oil from GSC, tested for PCBs b/c we're
a university. Safety Kleen to dispose
- soils with solvents removed. from groundwater
labs in Eng, Earth, ES, Columbia & Phillip
- bio waste (not kept for long b/c it smells!)
- liquid radioactive waste
MULTIPURPOSE STORAGE ROOM
- walls blow out if explosion
- explosion-proof lighting
- extra lead containers for transporting radioisotopes
I have read the above document, and will attest
to its accuracy
Ian Fraser Safety Deparment, UW
Last updated July 22, 1997. jmb