Hazardous Waste Summary of Requirements

Summary Of Requirements

The following summary of requirements provides a general overview of regulatory requirements applicable to most generators of hazardous waste.


Waste Identification:

Hazardous waste includes materials destined for disposal that possess hazardous characteristics (i.e. toxic, ignitable, corrosive or reactive), or substances that are listed as hazardous waste by the EPA or DEP. Unknown materials that require EHS services to identify will be the financial responsibility of the DLC. Chemical compatibility is an extremely important aspect of hazardous waste collection and storage for the safety of those generating the waste and those handling it until final disposal.



Containers, which store hazardous waste, must be properly and clearly labeled. Labels must include:

  1. the words "Hazardous Waste";
  2. the container contents (e.g. "Waste Oil,Ethanol,Acetone,etc.");
  3. the hazards associated with the waste (e.g. "TOXIC”). Once a satellite accumulation container becomes filled, the date must be written on the label;and collected within three days (Consecutive)
  4. the approximate percentages (%) for mixtures, if possible, should be provided.
  5. Bldg/Room#,Generator,PI


The EHS Office Environmental Program (EMP) provides HW labels (red tags), however other labels might be used as well with EMP approval.


Accumulation & Storage:

Hazardous waste regulations establish a two-tiered waste accumulation and storage system: satellite accumulation and storage areas.


Satellite Accumulation: Hazardous waste accumulation, which is at the point of generation and under the control of the person generating the waste, is called satellite accumulation (SAA). Chemical compatibility is critical in waste management, both within the collection container and within the secondary containment containers in these accumulation areas. Regulations allow a maximum of 55 gallons of hazardous waste or 1 quart of acutely hazardous waste at each satellite accumulation area. Only one container is allowed per waste stream. Satellite accumulation containers must be closed unless waste is being added to the container. Full containers of hazardous waste, which are then dated, can be stored in the satellite accumulation area for a maximum of 3 days before being transferred to a storage area. Once the full container is dated and a request for removal is placed, a new container of the same waste stream can be started. Bottles of hazardous waste, which are properly labeled, must be stored in an appropriate secondary container in a designed SAA. The EHS Office provides green SAA stickers for such purposes. Satellite accumuation areas are visually inspected by the lab each week to ensure compliance.


Storage Areas: MIT can store hazardous waste on site for up to 90 days, or 180 days in some cases, before sending waste materials for final disposal. The storage areas must meet the same requirements as the satellite accumulation areas, with a few exceptions which are generally more stringent. As in satellite accumulation areas, hazardous waste containers must be properly labeled, contain compatibile constituents, be closed unless waste is being added to the container, be stored within secondary containment and inspected weekly. That said, there are no limits to the amount of hazardous waste stored in these areas, dates are required on the labels once the first drop of waste is added to the container and documented inspections are required weekly. These locations also meet more stringent requirements with respect to state regulatory Contingency Plan documentation requirements, which EHS manages. If your lab or DLC requires one of these storage locations, contact the EHS Office and a representative of EMP Hazardous Waste Program will provide guidance and training, as well as, inspect your storage area on a weekly basis.



Where available, full hazardous waste containers can be transferred from the satellite accumulation area to the storage area.

If your DLC does not have a storage area you can request one by following this link.

A waste chemist will come to your lab and pick up your waste.  Please be VERY specific about the waste (you can add notes in the comments section), and also say specifically where the waste is in the lab.  You can also request supplies you may need through the chemical waste pick up form, like replacement five gallon pails, secondary containers, or labels/red tags.


Emergency Preparedness & Prevention:

In accordance with regulatory requirements, the Institute maintains Hazardous Waste Contingency Plan for the Cambridge campus. MIT has also implemented preparedness and prevention procedures to minimize threat of fire or explosion and has developed hazardous waste contingency plan addressing emergency response.

Be aware of the dangers associated with each hazardous waste stream you generate and know the locations of spill control equipment available in your area. Familiarize yourself with your site-specific emergency response and evacuation plan.  For spill kit information please refer to the Spill Kit link on the EHS website under waste management.




Anyone involved in the management of hazardous waste must complete a training program, which covers applicable hazardous waste regulations. EMP provides hazardous waste training sessions.



Regulations require that hazardous waste areas (satellite accumulation areas and storage areas) be inspected on a weekly basis. Personnel managing satellite accumulation areas are responsible for conducting their area’s inspection. EMP conducts the weekly inspection of all less than 90-day storage areas.