Northwestern University, Research Safety News, July, 2000

Comment: As EPA promotes the disposal of hazardous chemical biological waste, including sewage sludge
biosolids, as a safe fertilizer soil amendment for your food crops and lawns, it targets colleges and
universities who may disagree with its position. Yes, EPA promotes the disposal of sewage sludge biosolids
on your lawn as an unlabelled soil amendment which can not be disposed of in a
part 503 sludge landfill

The Environmental Protection Agency (EPA) recently announced that colleges and universities are its top enforcement
priority this year. In keeping its word, EPA has hammered institutions in the Northeast with sizable fines for violations of
environmental regulations. Just recently, the the University of Michigan, was subjected to a two-week inspection by a
team of eleven federal and state agents. The outcome of the inspection has yet to be determined.

Across the country, colleges and universities have been sporadically targeted by EPA for the last decade. In one of the
most widely publicized cases, Stanford University was fined over one million dollars for hazardous waste violations in
1994. The results of inspections at other major institutions in the last four years have resulted in fines in the tens to
hundreds of thousands of dollars. Most of these inspections have focused on compliance with hazardous waste disposal
regulations but some have included other areas under EPA jurisdiction such as air or water emissions and oil and
solvent storage.

Agents may request laboratory visits to see how chemicals and wastes are handled. All containers of chemicals,
including wastes, shall bear labels indicating contents and associated hazards. Chemicals, especially solvents, shall be
dated upon receipt in the lab and upon opening. Chemicals, including wastes, shall be stored only with other compatible
materials. Flammable liquids, including wastes, shall be stored in flammable-liquid cabinets if a lab contains a total of ten
gallons or more. All chemical containers and especially waste containers shall be kept securely closed except when
extracting or adding material.

Chemical stocks should be inspected periodically, at least annually, and any old or unwanted chemicals should be
removed from the inventory. Whenever possible, every effort should be made to find other uses for unwanted
chemicals. Sharing chemicals is a good way to save on purchase costs as well as avoiding costly disposal.

It is a federal and state offense to dispose of chemicals improperly. Remember, it is a violation of both safety and
environmental regulations to pour chemicals down the drain unless they are first treated or neutralized and local
regulations allow them in the sanitary sewer system. Failure will result in a minimum fine of $25,000.00