February 17, 2015

Reducing or eliminating chemical hazards in schools has two key aspects: safe disposal of un-wanted or waste chemicals, and revised or improved practices for pollution prevention (curriculum shifts, safe storage and handling, and changes in purchasing practices). Disposal of chemicals and their resulting chemical waste must be done in compliance with local and state regulations as well as with the Resource Conservation and Recovery Act (RCRA – see Appendix IV). In addition to meeting regulatory compliance, proper disposal according to RCRA standards also helps to ensure minimization of harmful chemical exposure to students and staff, environmental destruction, and substantial expenses due to accidents.

In this Toolkit, the Inventory worksheets are linked to the Disposal worksheets, so that any surplus products or waste chemicals identified through the inventory can be tracked through the disposal process. EPA requires records of hazardous waste to be kept for three years. The Disposal worksheets can be found in each of the respective school Department-Specific sections. Each worksheet provides guidance about chemical handling for some or all of the items listed, as well as columns to identify the amount of the product to be disposed of, and to check-off steps taken to assist the school-wide disposal procedures. As provided, the Disposal worksheets list the same chemicals or products listed in the Inventory worksheets, but the electronic file for the Disposal worksheet may be amended to list only those items actually found in the Inventory.

Designated school sector personnel (relevant classroom teachers, lead custodian etc.) should first complete the relevant inventory worksheet, and then, after adapting the relevant disposal worksheet according to what was found in the inventory, fill out the disposal worksheet. Note that if recycling of a material is feasible, it is always preferable to disposal. Recycling of hazardous waste materials exempts waste generators from EPA regulations. Many materials listed in the inventories do not necessarily require hazardous waste handling, but neither are they automatically regarded as benign by landfill operations. Each landfill can set its own guidelines for what is and is not acceptable. Hence the guideline for disposal of any school chemicals that are not ordinary household items, is to clear their disposal with the local landfill first.

The school’s disposal point person should gather these school sector worksheets and use the information on them to compile a complete disposal plan for informing and working with a hauling company.

In the Disposal sub-section within the Administration section of this Toolkit, the disposal point person will find the following helpful documents:

  • Disposal Planning Guidance
  • Disposal Planning Table
  • Instructions for Keeping Records
  • Package and Hold Guidelines for intermediate storage at the school
  • Specific instructions for Contaminated Clothing and Rags
  • A list of Utah Hazardous Waste Haulers with state contracts that the school may contract with, and alternatively, questions to ask in Finding a Qualified Disposal Vendor
  • PDF documents that depict and explain the use of the Uniform Hazardous Waste Manifest and Manifest Continuation Sheet which should be used to track any chemical removal and hauling, including the Utah Uniform Hazardous Waste Manifest Information, federal EPA Manifest Instructions and Manifest Codes.