Safety & Loss Prevention

Acute Hazardous Waste

Definition

Acute hazardous waste are comprised of listed hazardous wastes with certain waste codes. These codes are:

  • From "F list" hazardous waste from non-specific sources F020, F021, F022, F023, F026 and F027.
  • From "P list" acute hazardous commercial chemical products and manufacturing chemical intermediates
  • All "P list" waste codes are acute hazardous wastes. Note that this applies only to unused materials that are pure, technical grade, or formulations in which the listed chemical is the sole active ingredient.

The full descriptions appear in the hazardous waste regulations in Ch. NR 605, Wisconsin Administrative Code.

Campus and UW System facility considerations

In general, any P-list chemical can appear as a waste at a UW campus, depending on the instructional and research needs of your campus faculty.

As a practical matter, F027 is the only one of the acutely hazardous F-list chemicals that has been noted to appear as a waste at UW campuses. In Wisconsin, this includes only unused formulations containing tri–, tetra–or pentachlorophenol or compounds derived from these chlorophenols .

Acute hazardous waste is a particularly important waste management concern for campuses or facilities that are Very Small Quantity Generators ( VSQGs ) or Small Quantity Generators ( SQGs ), since 1 kg ( appx . one quart) of accumulation will change your status to Large Quantity Generator. This change will increase costs and add work, including requirements that you must:

  • ship waste within 90 days of first accumulation (shorter for both VSQG and SQG)
  • have a written contingency plans (additional for VSQG and SQG)
  • maintain written job titles, list of personnel filling those positions, and job descriptions for waste facility personnel (additional for VSQG and SQG)
  • train your waste personnel annually (additional for VSQG)
  • document training (additional for VSQG)
  • file an annual hazardous waste report with WDNR (additional for VSQG)
  • have a designated emergency coordinator (additional for VSQG)
  • have a record of agreement with off-site emergency responders (additional for VSQG)
  • comply with other prepared and prevention items (additional for VSQG).

If you are conducting a large waste cleanup project (i.e., cleanup associated with building remodel) and expect to generate more than 1 kg of acute hazardous waste, you might be able to minimize the regulatory impact of this infrequent episodic generation. For assistance with these circumstances, contact Ralph North at UW System Administration.

The best way to avoid headaches from acute waste is to limit your generation of these wastes . For assistance in dealing with potential acute waste issues, contact Ralph North at UW System Administration.

Other Resources

Highly Recommended: Tips for acute waste identification and minimization are available at:
http://www2.fpm.wisc.edu/chemwasteinfo/AcuteHW.htm

(Thanks to Dave Drummond, UW–Madison)

 

Updated August 12, 2008

Page content maintained by Ralph North

This publication was prepared for environmental, health and safety staff at University of Wisconsin System campuses, to assist in finding resources and information for regulatory compliance. It is not intended to render legal advice. (Click here to read full legal disclaimer.)