A hazardous materials incident may be a spill or release of chemicals, radioactive materials, or biological materials that endangers people or the environment. Simple spills that can be managed by the user and do not endanger people or the environment can be cleaned up by an individual who has been trained pursuant to the Chemical Spill Response Plan, the Chemical Hygiene Plan, and/or the Radiation Safety Manual, as applicable, and do not constitute an emergency situation for purposes of this Plan.

Initial Response

  • Assess the situation to identify immediate hazards. (See below Waste Type and Hazardous Materials)

  • If it can be done safely, isolate the area, but do not walk into or touch any spilled materials and avoid inhalation of gases/fumes/smoke.

  • If the spill occurred inside of a building, evacuate the area. (See Evacuation Plan)

  • Call 911 and provide as much information as possible from the list below about the hazard, making sure to report any person(s) unable to evacuate the area due to illness/injury.

  • Contact the Environmental Health and Safety Director at extension 1189, or 931.636.3787 from off-campus providing as much information from the list below, making sure to report any person(s) unable to evacuate the area due to illness/injury.

  • When reporting a hazardous materials incident, provide the following information about the hazard, if known:

    • Name and quantity of the material.

    • Location and time of the release of the material.

    • Any exposures or injuries to persons.

    • If any fire or explosion is involved.

    • Your name, phone number, and location.

    • Present the Material Safety Data Sheet of the hazardous material involved to emergency responders if it is available.

  • Follow the General Instructions below.

  • The EHS Director, SVFD, and SPD will assess and investigate the situation, as appropriate.

  • In the event that there are any individuals injured or ill as a result of a hazardous materials incident and unable to evacuate the area, the SPD will either assist in evacuating such individuals, if safe to do so, or contact other University personnel or local emergency responders for assistance in responding to the injured/ill individual(s).

  • SPD will notify EHS director, the Chemical Hygiene Officer, or other appropriate University personnel, as appropriate.

  • Depending on the nature and degree of the hazardous materials incident, other support agencies, resource units, or specialized contractors may be brought in for service or assistance.

  • Await and follow instructions from SPD, EHS or the SVFD.

General Instructions

  • Do not walk into or touch any spilled materials.

  • Avoid inhalation of all gases, fumes and smoke; stay up wind. Do not assume gases/vapors are harmless because they lack odor.

  • If it can be done safely, isolate the area by closing doors and windows.

  • Make no attempt to clean up hazardous materials.

  • Evacuate or shelter in place if instructed. (See Evacuation Plan & Shelter in place.)

  • If safe to do so, assist any person who has been injured or who is overcome from exposure and cannot evacuate or shelter in place without assistance. Administer basic first aid when possible and appropriate. If not safe to do so, or if the extent of injury is serious, call 911.

  • If instructed to shelter in place:

    • Move to a location that is above ground level, if possible.

    • Close and lock all windows and exterior doors.

    • If possible, turn off all ventilation systems such as air conditioners, heating units, exhaust fans, or air handlers.

    • If there is a danger of explosion, close any shades, blinds, or curtains.

  • Await and follow instructions from SPD, EHS or the SVFD, other University personnel, or support agencies.

Special Considerations

  • A hazardous materials incident may develop into a fire. If this occurs, see the Fire Response.

  • In the event of a threat of hazardous materials such as a bomb threat or suspicious package/mail, see the Bomb Threat section or the Suspicious Packages/Mail section, as appropriate.

  • Always follow instructions listed on the chemical’s Safety Data Sheet. For chemical burns, flush chemicals off of the surface of the skin under cool running water for 20 minutes or more, remove any contaminated clothing or jewelry, and wrap burned area with a clean, dry cloth.

  • If lab animals are at risk as a result of a hazardous materials incident, contact the Biology Department Chair.

Waste Type and Hazardous Material

Hazardous Waste: Hazardous waste is waste that poses substantial or potential threats to public health or the environment. In the United States, the treatment, storage, and disposal of hazardous waste are regulated under the Resource Conservation and Recovery Act (RCRA). Hazardous waste are either RCRA “listed" or "characteristic" waste. A characteristic waste exhibits the characteristic of being: ignitable, corrosive, reactive, and/or toxic.

Universal Waste: Universal Wastes are hazardous wastes that pose less of a risk to people and the environment than other hazardous wastes. As such, provided that they are properly managed (typically through recycling) they are not subject to the same stringent regulations as other hazardous wastes. The most common universal waste at the University of the South is fluorescent light bulbs, but metal halide bulbs, small lead-acid batteries (e.g. emergency lighting), and rechargeable Ni-Cd batteries – among others, are also universal wastes.

Non-Hazardous Waste: In general, if a waste is not a RCRA "listed" waste or does not exhibit the "characteristics" of a hazardous waste it will be non-hazardous/ non-regulated. A waste that passes the EPA Toxicity Characteristic Leaching Procedure (TCLP) is typically considered a non-hazardous waste.

Hazardous Materials: Hazardous materials are defined and regulated in the United States primarily by laws and regulations administered by the U.S. Environmental Protection Agency (EPA), the U.S. Occupational Safety and Health Administration (OSHA), the U.S. Department of Transportation (DOT), and the U.S. Nuclear Regulatory Commission (NRC). Each has its own definition of a "hazardous material."

OSHA Hazardous Materials: OSHA's definition includes any substance or chemical which is a "health hazard" or "physical hazard," including: chemicals which are carcinogens, toxic agents, irritants, corrosives, sensitizers; agents which act on the hematopoietic system; agents which damage the lungs, skin, eyes, or mucous membranes; chemicals which are combustible, explosive, flammable, oxidizers, pyrophorics, unstable-reactive or water-reactive; and chemicals which in the course of normal handling, use, or storage may produce or release dusts, gases, fumes, vapors, mists or smoke which may have any of the previously mentioned characteristics.

EPA Hazardous Materials: EPA incorporates the OSHA definition, and adds any item or chemical which can cause harm to people, plants, or animals when released by spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping or disposing into the environment.

DOT Hazardous Materials: DOT defines a hazardous material as any item or chemical which, when being transported or moved in commerce, is a risk to public safety or the environment, and is regulated as such under its Pipeline and Hazardous Materials Safety Administration regulations (49 CFR 100-199), which includes the Hazardous Materials Regulations (49 CFR 171-180). In addition, hazardous materials in transport are regulated by the International Maritime Dangerous Goods Code; Dangerous Goods Regulations of the International Air Transport Association; Technical Instructions of the International Civil Aviation Organization; and U.S. Air Force Joint Manual, Preparing Hazardous Materials for Military Air Shipments.

NRC Hazardous Materials: The NRC regulates materials that are considered hazardous because they produce ionizing radiation, which means those materials that produce alpha particles, beta particles, gamma rays, x-rays, neutrons, high-speed electrons, high-speed protons, and other particles capable of producing ions. This includes "special nuclear material," byproduct material, and radioactive substances.

General Labeling Requirements

Chemicals removed from the original container must be labeled with product identifier; signal word; hazard statement(s); precautionary statement(s); and pictogram(s); and name, address and telephone number of the chemical manufacturer, importer, or other responsible party.

Note: If the chemical is a waste to be sent for disposal through a waste vendor, the container must be labeled as outlined in waste storage requirements section.

Waste Storage Requirements

Note: The waste profile (if an existing identified waste) will identify if the waste is a Hazardous Waste, Universal Waste, or Non-Hazardous Waste.

Hazardous Waste Storage Requirements

  1. Containers: Hazardous waste must be placed in US DOT approved containers. Containers must be securely closed - except when waste is being added, and must be stored and handled in a manner to prevent damage or rupture.

  2. Labeling: When hazardous waste is placed in a container for disposal, the container must be properly labeled. The label shall denote “Hazardous Waste” and contain the following:

    1. The name or a description of the waste,

    2. Applicable waste code(s), if known,

    3. University’s EPA I.D. number,

    4. University’s name and address,

    5. DOT information, if known, and

    6. Date of accumulation (the date the container was filled and lid secured).

  3. Storage Areas: Hazardous wastes must be stored in a secure and contained location. Limiting access to unauthorized individuals is preferred. Emergency contact numbers must be posted in the area and spill response equipment should be maintained in close proximity to the storage area.

  4. Satellite Drums/Accumulation Areas: For areas such as laboratories or print shops, a satellite accumulation drum for adding small amounts of hazardous waste over a period of time may be used. The drum must be labeled as hazardous, must identify the waste being added, and be used only for a specific waste stream. The lid must always be in place, except when adding waste. No more than 55 gallons of hazardous waste may be stored at each accumulation area. When the drum is full it should be removed, dated and placed in the hazardous waste storage area for proper disposal.

Universal Waste Storage Requirements

  1. Containers: The container for each type of UW must meet the following criteria:

    • the container remains closed;

    • the container is structurally sound;

    • the container is compatible with the UW;

    • the container lacks evidence of leaks, spillage or damage that could cause leakage.

  2. Labeling: All containers or accumulation areas or individual items must be labeled appropriately (i.e. Used Lamps, Used Batteries, etc.)

  3. U-waste containers must be closed at all times, except when adding waste to the containers.

  4. Each container or item of U-waste must have an accumulation start date. This is the date that the first item is placed into the U-waste storage container. Lift truck batteries should bear the date the battery was deemed spent.

  5. U-wastes must be shipped off-site for recycling within one year of the accumulation start date.

Non-Hazardous Storage Requirements

  1. Containers: Non-Hazardous waste must be placed in US DOT approved containers. Containers must be securely closed - except when waste is being added, and must be stored and handled in a manner to prevent damage or rupture.

  2. Labeling: When non-hazardous waste is placed in a container for disposal, the container must be properly labeled. The label shall denote “Non-Hazardous Waste” and contain the contents of the container and the date of generation.

  3. The containers of waste should then be placed in a designated storage area prior to disposal or recycling.