Chapter 2 - Responsibilities

All chemical users have a legal and moral responsibility to ensure the proper disposal of any hazardous waste generated. There are various state and federal regulations that govern the disposal of chemical wastes. There are also criminal and civil penalties that can result from improper disposal of these wastes. In addition to potential citations, fines, and imprisonment, improper waste disposal can also result in national media attention and damage to the University’s reputation.

YOU CAN BE PERSONALLY HELD LIABLE FOR “WILLFULLY AND KNOWINGLY” VIOLATING THESE REGULATIONS.

You also have a moral responsibility to properly dispose of chemicals that can pose a present or potential hazard to human health or the environment.

The Cornell University management procedure for the policy on environmental health and safety can be found in the Environment, Health and Safety Policy 8.6. The following outlines the liability issues, potential penalties, and specific responsibilities for the management of hazardous wastes.

2.1 Liability

Cornell University faculty, staff, and students who follow all published EHS hazardous waste disposal requirements are covered under the University’s Indemnification Policy 4.9.

Work groups or units that fail to comply with the regulations or EHS hazardous waste disposal requirements will be responsible for paying any fines associated with their non-compliance.

Individuals who knowingly choose to ignore the regulations may face civil or criminal proceedings and may not qualify for indemnification from the University.

2.2 Penalties

EPA regulators are authorized to fine non-compliances at a rate up to $37,500 per violation per day of occurrence. In general, EPA fines are much larger than any other federal agency.

Waste generators that fail to follow the EHS hazardous waste requirements are liable for the costs created by the disposal of their wastes, in addition to any regulatory fines that may be incurred.

For academic waste generators, the Provost’s Office has stated in a letter to campus that individual units will be responsible for paying fines associated with non-compliances in their areas.

2.3 Waste Generator Responsibilities

Individual investigators, supervisors, workers, students, laboratory staff, visitors, etc. are considered the actual originators (generators) of these regulated materials. Therefore, it is the responsibility of each generator to identify any and all hazardous wastes that he or she might be producing, and to assure the waste is handled in a manner consistent with the EHS requirements listed in this document.

Where EHS requirements identify solvents that must be collected separately for distillation and reuse, the waste generator must make every effort to segregate those solvents from their regular hazardous waste collection containers.

2.4 Principal Investigators / Functional Supervisors Responsibilities

For laboratories, the principal investigator (PI) or his/her designee, and for other campus work areas, the functional supervisor, have the responsibility to ensure the personnel working under their direction follow all policies and procedures established in this manual. General responsibilities include:

Attending Chemical Waste Disposal Training - either live or online.
Proper identification and labeling of chemicals.
Collecting all chemical wastes in accordance with established guidelines.
Cleaning up incidental spills (with the proper training and spill equipment).
Maintaining good housekeeping in waste generation areas.

2.5 Students / Employees Responsibilities

Cornell students and other university personnel working with hazardous chemicals must follow the requirements and guidelines presented in this manual. These responsibilities include:

Attending Chemical Waste Disposal Training - either live or online.
Proper identification and labeling of chemicals.
Collecting all chemical wastes in accordance with established guidelines.
Identifying all spent or surplus materials using the technical knowledge within the department.
Packaging, labeling, and storing all chemical wastes in accordance with established guidelines.
Consulting with supervisors and/or EHS regarding the safe handling and proper disposal of hazardous waste chemicals when they are unsure or have questions.

2.6 EHS Responsibilities

Cornell University EHS is registered with the EPA as the generator of hazardous waste. The Environment, Health and Safety Policy 8.6 establishes EHS as having the primary responsibility for administering Cornell’s chemical waste management program and establishing policies and procedures for proper chemical waste management. Elements of the chemical waste management program include:

Developing a written Hazardous Waste Disposal Manual and an online program detailing university policies related to hazardous waste and material management.
Developing and maintaining a RCRA Contingency Plan for all Cornell University 90 Day Accumulation Areas.
Providing both live and online waste management training to all required campus personnel. Training will be tailored to meet both federal and state requirements. The level of training required for trainees is a direct function of the work related to waste management.
Acting as an information resource for campus personnel with hazardous waste related questions.
Providing pickup and transport of chemical hazardous waste from campus Satellite Accumulation Areas to the campus main 90 Day Accumulation Area.
Providing periodic inspections of campus 90 Day Accumulation Areas.
Acting as point of contact with all regulatory agencies related to waste management issues.
Preparing and maintaining records, reports and manifests as required by regulation.
Acting as Stewards for university hazardous waste contracts, providing quality control and payment approval for waste related invoices.
Initiating programs and guidance to minimize the generation of hazardous wastes.
Keeping up-to-date with current regulations and best practices.

2.6.1 EHS Personnel

EHS personnel are available to assist campus personnel in the identification and handling of chemical wastes. These staff members manage the collection and proper disposal of the chemical waste generated at Cornell.

2.7 Departments That Choose To Collect and Consolidate Waste

Departments that choose to collect hazardous wastes in a central location must ensure that the central location meets the 90 day area requirements and that staff who collect the waste have annual 90 day area worker training. EHS discourages the creation of 90 day areas on campus due to the additional responsibilities required to maintain a 90 day area. However, if you think you generate enough waste to justify having a 90 day area, then please contact EHS at askEHS for more information.

Environment, Health and Safety