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Hazardous Materials

The use of hazardous materials at the University of Houston – Downtown (UHD) creates a variety of environmental and safety concerns. Many of the academic, research, and facility support departments throughout UHD use hazardous materials and therefore generate a wide variety of hazardous and non-hazardous wastes. It is the intent of UHD Environmental Health & Safety Office (EHS) to evaluate these concerns prior to the purchasing of hazardous materials and thereby avoid, to the extent feasible, adverse consequences and in accordance with SAM 03.B.01 Purchasing Guidelines.

Hazardous materials are defined and regulated in the United States primarily by laws and regulations administered by the USEPA, Occupational Safety and Health Administration (OSHA), United States Department of Transportation (DOT), Texas Commission on Environmental Quality (TCEQ), Texas Department of State Health Services (TDSHS), The State Office of Risk Management (SORM), Department of Homeland Security (DHS), Drug Enforcement Agency (DEA), and Nuclear Regulatory Commission (NRC). The Resource Conservation and Recovery Act (RCRA) gives EPA the authority to control hazardous waste from manufacture to final disposal. This includes the generation, transportation, treatment, storage, and disposal of hazardous waste.

Hazardous Materials Purchasing Guidelines

These guidelines apply to all purchases of chemicals or other hazardous materials that will be used by the UHD community. All persons who make these purchases should observe these procedures, and also includes hazardous materials which are obtained as free samples, gifts, and donations.

The rationale for having Hazardous Materials Purchasing Guidelines is to improve the cataloging of hazardous materials being ordered and brought to UHD and help to reduce the overall quantity and/or toxicity of chemicals on campus. The American Chemical Society (ACS) urges people who work with chemicals to adopt the motto, “Less is Better.”

When purchasing hazardous materials, individuals must consider not only the quality and cost of purchases, but also the social and environmental factors related to purchases. The purchase, use, storage, and disposal of a hazardous material may present many challenges for UHD including health and safety risks, operational and disposal costs, and increased potential for regulatory penalties. Each carefully made purchase will help UHD provide a safer work environment, promote a more sustainable campus environment, and reduce overall costs associate with maintaining compliance with environmental, health, and safety regulations. It is important that each individual purchasing hazardous materials understands and accepts responsibility for the purchases by:

  • Becoming familiar with prohibited and restricted purchases;
  • Researching alternatives;
  • Correctly tracking purchases and avoiding unnecessary purchases (i.e. excessive volumes);
  • Properly managing the materials after they are on-campus;

Hazardous materials purchases will be reviewed, before purchase, by the UHD EHS Office who are knowledgeable about relevant environmental and safety issues. These individuals will prevent unnecessary purchases and suggest alternatives to reduce risks, wastes or regulatory burdens.

Official determination of the definitions presented may be found in laws and related regulations published in the federal register, state and local laws, and scientific/technical documents. Specific information for a hazardous material may typically be obtained from a Safety Data Sheet (SDS). Contact the UHD EHS Office for additional information or assistance with the determination of hazardous materials.

All chemicals, including many common household cleaners, paints, and construction materials are considered “Hazardous”, unless otherwise specified. A hazardous material is a material that, because of its quantity, concentration, or physical or chemical characteristics, may pose a physical, environmental, or health risk. Examples include chemicals that are toxic, corrosive, flammable, highly reactive, explosive, and/or emit ionizing radiation. Some common terms used when describing hazardous materials include:
  • Chemicals of Interest: A list of chemicals and their corresponding screening threshold quantities developed by the DHS (Appendix B). Institutions, including colleges and universities that possess a chemical of interest at or above a regulatory screening threshold quantity must complete and submit a consequence analysis (i.e., Top-Screen) to the DHS as part of the Federal Chemical Facility Anti-Terrorism Standards.
  • Hazard: A chemical, biological, radioactive, or physical agent, which may cause an adverse effect on the human body. Hazards may be acute, toxic, or chronic.
  • Acutely Toxic: A material that has the potential to produce a lethal dose or lethal concentration to living tissues under certain conditions.
  • Toxic: Materials that may present an unreasonable risk of injury to the health of living things or the environment.
  • Toxin: A chemical agent that adversely affects the human body. These may include hepatotoxins, nephrotoxins, neurotoxins, and reproductive toxins. Examples of chemical toxins include dibromochloropropane, halogenated hydrocarbons, mercury, lead, and carbon tetrachloride.
  • Carcinogen: An agent capable of causing cancer.
  • Irritant: A chemical, which is not corrosive, but which causes a reversible inflammatory effect on living tissue by chemical action at the site of contact.
  • Sensitizer: A chemical that causes a substantial proportion of exposed people or animals to develop an allergic reaction in normal tissue after repeated exposure to the chemical.
  • Shock-Sensitive: Materials that may undergo sudden explosion with movement, friction, or heat. The label and SDS will indicate if a chemical is shock-sensitive. Some chemicals become more shock-sensitive with age. Unless the manufacturer has added an inhibitor, most shock-sensitive materials should be disposed within a year.
  • Peroxide Forming Chemicals (PFCs): Chemicals that can “auto-oxidize” with atmospheric oxygen under ambient conditions to form organic peroxides (contains an -O–O- bond). Peroxide formation can be initiated by exposure to air, self - polymerization, or solvent impurities. Once formed, organic peroxides are sensitive to thermal or mechanical shock and can be violently explosive in concentrated solutions or as solids.

The following below are the responsibilities of the UHD EHS Office:

The UHD EHS Office will review the purchase to ensure that all safety and environmental considerations have been addressed according to all applicable federal, state, and local regulations.

If for some reason the purchase is not approved, the concerns of the UHD EHS Office will be resolved before purchase.

The UHD EHS Office will keep a record of all hazardous materials purchases.

The UHD EHS Office will ensure that a SDS is available for every hazardous material purchased.

All gifts and donations of hazardous materials must be approved in advance by the UHD EHS Office. A SDS and/or equivalent safety information must accompany the donated hazardous material.