Green Action Plan
Hazardous Waste

A waste is defined as any useless, unwanted or discarded substance or material, whether or not such substance or material has any other future use and includes any substance or material that is spilled, leaked, pumped, poured, emitted, disposed, emptied or dumped onto land, water or ambient air.

A Hazardous waste is a substance or material that meets the criteria of the above mentioned definition of a waste and must be either;

  • Flammable
  • Corrosive (pH = 2.0 or = to 12.5)
  • Reactive
  • A waste that would fall under the Toxic Characteristic Leaching Process (TCLP)

Bates College is a large quantity generator of hazardous waste. This means that Bates College produces, on average, more than 220 lbs. of hazardous waste per month. Currently, all of the hazardous waste at Bates is removed from campus and disposed of, or recycled by, certified hazardous waste services.

Current Status
The hazardous waste stream at Bates is currently divided into several categories: Physical Plant, the Department of Biology, the Department of Chemistry, the Olin Arts Center and the Health Center. Each department's hazardous waste supervisor retains all the records of all the hazardous waste that is produced within his/her respective department.

Every year the Physical Plant Engineer is responsible for collecting each department's hazardous waste records. The collection of all three departments' hazardous waste records yields the College's Hazardous Waste Manifest (HWM). The State of Maine requests a HWM from Bates once every two or three years. The departments' hazardous waste totals are currently only tallied for the Bates HWM when the state of Maine requests the manifest. (The yearly waste records of each department are filed at Physical Plant in case the state requests a Bates HWM from an earlier year.) Bates' most recent HWM was written at the State of Maine's request in 1996. The records indicate that the average monthly hazardous waste generation at Bates in 1996 was 465.93 lbs. per month.

On any college campus there are two departments that are responsible for the majority of hazardous waste generation, and Bates is no different. These two sources are the science labs (particularly chemistry and biology) and the Physical Plant. The art department and the Health Center contribute lesser amounts of hazardous waste. The lab sciences contribute a wide range and variety of chemicals, radioactive waste and other substances. The Physical Plant contributes contaminated rags, motor oil, solvents, transmission fluids, paints and pesticides, to name a few. The art department contributes paint, photographic chemicals and solvents. The Health Center produces a minimal amount of biologically hazardous medical waste.

Currently, Bates' hazardous waste is taken off site and disposed of (generally incinerated or recycled) by Clean Harbors, Maine Lab Pack or Safety Kleen. These are all certified hazardous waste disposal services. Although these companies remove and dispose or recycle Bates' hazardous waste, Bates remains fully responsible for the safe and proper transportation and disposal or recycling of its hazardous waste.

The majority of hazardous waste generated at Bates is disposed of in a manner consistent with regulations. There are two known areas of the campus in which hazardous waste is not properly managed. The Director of Safety and the environmental coordinator have been working this year with the photography lab this year to set up a system that will eliminate hazardous chemicals from going down the drain. The system has been functional since spring semester, 1998.

The other area where management of hazardous waste is difficult to control is in the laboratories of Dana and Carnegie science buildings. Improper hazardous waste disposal can be the result of insufficient student education in many science classes and labs, particularly chemistry. It is unclear whether students, professors and teaching assistants are all aware of what substances may be considered hazardous waste. It is also unclear whether they are cognizant of the proper means of disposal for each hazardous waste. Knowledge regarding the proper treatment of hazardous waste in the classroom is crucial to ensuring that Bates properly disposes of all its hazardous waste, and it is not uniformly dispensed or available.

The only way to address the potential for other incidental "down the drain" disposal is to focus on insuring that all employees who come into contact with any hazardous material have been educated about its proper disposal.


  • Record Keeping
    The organizational and record keeping aspects of hazardous waste at Bates are functioning smoothly. All the records for any known hazardous waste generated at Bates are available and well organized in the Physical Plant engineer's office. The biology department stock manager and the chemistry department stock manager handle the primary record keeping for hazardous waste removal in their respective departments.

  • Review of Current Services
    Hazardous waste service is an expensive and complex process. To date, each department at Bates that generates hazardous waste has contracted out its own vendor. Currently, Bates is serviced by Clean Harbor, Maine Lab Pack and Safety Kleen. These companies were chosen by various individuals using a variety of criteria, but they were not contracted by bid process. Since Bates has never systematically assessed or compared its hazardous waste removal services in terms of efficiency, cost or environmental criteria, that process is currently underway.

  • Source Reduction
    As a large-quantity hazardous waste generator, Bates clearly needs to take a second look at its sources of hazardous waste creation. Use of some material that later becomes hazardous waste is unavoidable. However, there are strategies to reduce waste on nearly every front. Trucks, boilers, cars and machines all require oil or other substances that result in hazardous waste after use. However, this waste can be recycled and returned to use as motor oil, thus closing the loop. The amount of waste generated is significantly reduced in this manner. Additionally, there is ample opportunity for wastes to be reduced in the sciences.

    It is imperative that Bates commit to an annual reduction in hazardous waste generation. A reduction in the hazardous waste stream would not only make Bates more environmentally friendly, but also it would save on procurement costs and service costs of removal. In order for this to happen, the College needs to review its HWM each year, in conjunction with a consultant, to identify areas for reduction.

    A. Physical Plant: A large source of waste in the Physical Plant is paint. In 1996, Bates generated 1,986 lbs. of paint waste. This number also takes into account all of the old paint taken from properties that Bates had recently acquired, such as Shortridge. This phenomenon of inheriting hazardous wastes poses the greatest difficulty in reducing our hazardous waste stream.

    B. Chemistry and Biology Laboratories: Students, teaching assistants and professors should begin to look at new methods and procedures to reduce the amount of laboratory hazardous waste. Bowdoin and Colby have adopted microscale chemistry, as have hundreds of other institutions. This is the most modern form of biological and chemical laboratory testing and analysis. Many workshops and materials are presently available for teaching microscale. Microscale chemistry is now used in most commercial and industrial laboratories for many reasons. The science departments at Bates should do a systematic analysis of microscale options in terms of their effectiveness as academic pedagogy. It is becoming more commonplace in the "real" world of chemistry, it does not affect the outcome of chemistry instruction and it significantly reduces the hazardous waste stream. Some of the other benefits of microscale include:

    • Reduced chemical costs
    • Improved air quality
    • Reduced exposure to toxic materials
    • Curtailed waste generation
    • Use of a wider variety of chemicals
    • Shortened experiment times
    • Limited chances of fire or explosion
    linkSee Appendix D for qualities of a "Green Lab."

    C. Art Department: Options exist for art departments to use citrus-based solvents, in lieu of hazardous petroleum-based solvents. The art department should systematically review this possibility during the 1998-99 academic year.

    Tactical Recommendations 1. The following recommendations may further strengthen the organization and availability of hazardous waste records.

    a. The Physical Plant engineer, should compile all of Bates' yearly records since 1990 (regardless of whether it was requested by the State) into a comprehensive Bates Hazardous Waste Manifest. This annual manifest will aid greatly in measuring and comparing the quantity and types of hazardous waste that Bates generates.

    b. Bates' Annual Hazardous Waste Manifest should be analyzed and reviewed every year at a meeting consisting of the director of safety, plant engineer and the biology and chemistry stock managers. It should be reviewed for accuracy, possible methods of reduction and trends (in terms of the preceding manifests of the last five years).

    c. The manifest should be made available to all members of the community whose operations contribute to the hazardous waste stream. It should be presented in a comparative format in relation to past data.

    2. The following recommendations regarding the status of our hazardous waste service at Bates should be addressed.

    a. The director of safety, plant engineer and biology and chemistry stock managers should conduct a competitive bidding process to find the company or companies best suited to dispose of all the hazardous waste generated at Bates. The criteria for the hazardous waste service qualities should consist of:

  • Accessibility of company for rapid pick-up, spill response and information
  • Track record of company on how it handled past spills, its previous customer satisfaction and lawsuits
  • Means of disposal: Can one service recycle a hazardous waste product that another service tends to incinerate or landfill? This aspect of the bidding is most important to upholding the character and integrity of Bates as an environmentally conscious College. This may result in learning that one company provides hazardous waste treatment for oil by recycling while a different company treats our paint waste by recycling. This approach will require us to "shop" for the most environmentally sound disposal process for our wastes.
  • Cost: Hazardous waste service is a growing market. If a company bids higher than another, seek out the reasons such as better disposal methods, e.g. recycling. If it costs a small amount more to use a service that recycles rather than incinerates, our committee recommends using the service that is more environmentally sound.

    3. Factor into the purchase price of a house or building the removal costs of all hazardous waste remaining in the facility.

    4. As a matter of policy, use latex instead of the more toxic and combustible oil-based paints, and store the waste separately.

    5. Begin testing the use of recycled paint in low-traffic spaces.

    6. Seek alternatives to traditional petroleum-based solvents (e.g. citrus or aqueous-based).

    7. The Hazardous Waste subcommittee will work, in conjunction with Physical Plant and the science departments, with the new hazardous waste service vendor to find sources where our hazardous waste generation could be reduced through a new or different method.

    8. Establish a surplus chemical exchange program to collect hazardous materials in labs that are no longer needed and make them available to other users so they are not discarded.

    9. In academic year 1998-99, establish a microscale task force to study the feasibility of switching to microscale chemistry. The task force should include faculty, students, stock room managers and administrators. The task force will issue a report prior to the end of Short Term in 1999. If action is warranted, implementation will begin in the fall of 1999.

    10. Inventory the hazardous substances used, including paint, chemicals and solvents.

    11. Use citrus-based instead of petroleum-based solvents for cleaning brushes and pallets in the art department.

    12. The following recommendations address the vital issue of improved training.
    a. Training should be provided for faculty so that they have knowledge of the current hazardous waste disposal methods within their buildings or departments. (The training could be provided in-house or contracted through our service vendor.) This knowledge should then systematically be conveyed by the professors to their students. It is important that no classroom experiment concludes by dumping a hazardous waste down the drain.

    b. Students will be required to successfully demonstrate competence in hazardous-waste management before being allowed in the lab. The safety director and science stock room managers will work with appropriate faculty to develop this competency test.

    c. All personnel who handle hazardous substances will receive yearly in-house training on the best management practices for handling waste.


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    Last Modified 6/10/1999 by tan