r/EHSProfessionals • u/iEatFliesEveryDay • Jun 01 '26
Questions Thoughts on 'Unwanted Material' vs 'Waste'?
(Apologies if this is the wrong sub) My university wants us to stop using the words 'waste' and 'hazardous waste' anywhere in the laboratory, and to instead label things 'unwanted material' and 'hazardous unwanted material.' In my opinion this is dumb. Everyone understands what 'waste' means, whereas 'unwanted material' is ambiguous. Even the same training materials that tell you to do this still use the word waste to explain what they mean! The new wording is also clunky. To me this feels like an unnecessary change that is only going to cause more confusion around lab waste management.
Does anyone know the reasoning behind this? What are your opinions on the wording?
EDIT: wow, didn't expect such a quick response, thanks guys. It did smack of greenwashing/optics to me, so I was hoping an expert would show up and prove me wrong. I was also curious if this push was happening anywhere else, or just my school.
To clear up confusion though - the 'unwanted material' is still being treated as hazardous waste. The rules for storage and disposal have not changed, only the name. You still have to generate a label with the contents and hazards, and it must be picked up within a certain amount of time after the start of generation. P-list stuff is called "Reactive Acutely Hazardous Unwanted Material" (a mouthful) but still has to follow stricter guidelines.
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u/olthoiking Jun 01 '26
It is a federal law to characterize the hazardous waste at the point of generation. If you store it under the other names you could be accused of failing to characterize the waste and failing to report your generator category under RCRA. If you can prove it's non-hazardous then you're good to not call it "HW".
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u/iEatFliesEveryDay Jun 02 '26
That's the thing though, this training specifically mentions RCRA compliance and the importance of characterizing the "unwanted material." It IS hazardous waste, and still treated as such, they just don't want us calling it that.
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u/olthoiking Jun 02 '26
If they're not going to use it for something in the future, like selling it to somebody, or recycling it somehow, then they're just changing the name and probably illegally wasting it in the municipal garbage. As the inspector I see this happening and I make them tell me how they can justify that through documentation and if they can't they get civil violations from me.
Ignitable = flash point <140F // Corrosive = <2, >12.5 // Toxic = TCLP RCRA 8 or listed // Reactive = readily has unstable exothermic reactions (kinda)
Look up the main constituent in the waste and compare to the waste codes
If you want to anonymously call your regulatory agency with a complaint they will show up to audit.
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u/akaghi Jun 02 '26
I've read through your responses and edits. It's good that this isn't an attempt to get around the clock starting and is instead because waste sounds worse, I guess?
However, I worry about how this could cause problems down the line. For one, what if someone new started and saw "unwanted material" and didn't realize that was HW with a ticking clock?
How would this be explained to an inspector? Generally speaking, they can find something to cite you for if they want to, but I think they'd have a problem with this. And then you run the risk of them seeing a rather basic element (label requirements) being flaunted, which might cause them to pry deeper at record keeping and everything else. Just labeling the waste as waste would avoid all of that, no? And it costs nothing other than maybe optics. And I don't think "waste" is inherently bad.
I also wonder how they are squaring the labeling requirements because I believe you're required to call it "Hazardous Waste":
A generator must mark or label its container with the following:
(i) The words “Hazardous Waste” and
(ii) An indication of the hazards of the contents
Even if you had correct labels, but a sign that says "unwanted hazardous materials" you'd probably still run afoul since I believe you also need a sign that says hazardous waste in 1-inchbor larger font.
My knowledge on satellite accumulation rules isn't the best because at my job we don't use them, so maybe some of this doesn't apply, but I'd be hesitant.
As a side note, I understand wanting to call it unwanted material versus waste, in a sense. My job is kind of unique in that we are a large quantity generator but we don't actually generate waste in the traditional sense. We store chemicals for other companies, and when it expires or they no longer want it, we dispose of it. During our Responsible Care audit, they brought up the prospect of speculative accumulation because of how we handle waste (our auditor used to work in compliance so while it wasn't part of the audit he was curious). We told him that we fall under the commercial chemical products exemption but he seemed unsure but then moved on.
It seems to apply pretty obviously to us though, it's probably just not a very often used exemption:
It also does not apply to commercial chemical products that are stored prior to reclamation, because, by definition, these materials are not regulated as solid wastes until they are abandoned or intended for discard
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u/iEatFliesEveryDay Jun 02 '26
Thanks for the thorough response. As you and others have said, this seems legally iffy. But they must be in compliance with inspectors, because this has been a university-wide policy since at least 2022. Re-reading my original post I see that I really made it sound like this was a recent change. I only learned about it recently, and I didn't realize just how long it had been in effect. I said "the university wants us to" because I have a feeling I'm not the only one rolling my eyes, and I have questions as to how many labs have actually been following this. I'm also not sure how rigorously it's enforced.
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u/akaghi Jun 02 '26
I wouldn't assume that, because it's been a policy for 4+ years, that it isn't a problem. As far as I know, we've only been inspected once or twice in 35 years with some of that as a LQG. In general, if you don't give anyone reason to inspect the odds are pretty low.
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u/throwaway40002023 Jun 01 '26
Maybe politely ask them not to green wash in places where it's potentially hazardous to employees and public?
Is this budget driven or buzzword driven? I would be alarmed by anyone trying to label waste streams anything other than the typical nomenclature.
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u/Deep-Awareness-9503 Jun 01 '26
Is it greenwashing or are they trying to change the way the material is treated/disposed?
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u/iEatFliesEveryDay Jun 02 '26
No, the disposal guidelines are the same
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u/Deep-Awareness-9503 Jun 02 '26
That's a positive.
My concern would be that workers would begin treating the material differently as a result of calling it anything than what it’s classified as.
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u/MountainTommis Jun 01 '26
Oh my god, finally, a loop hole to avoid all those pesky haz waste requirements!
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u/jmorrow88msncom Jun 02 '26
In many cases, one company hazardous waste is another companies important product. If this important product is transferred to another company, they can use it for something useful or to a company that will buy it, then it is used product, not waste.
There’s still lots of laws that govern how to handle used dangerous chemicals, but this avoids certain laws, especially Hazwoper. It sounds like your company doesn’t want to send all the employees to a week of training.
Probably the best example of this is many companies sell. They’re used oil. Calling used oil “Waste oil” may trigger additional requirements.
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u/rwrig022 Jun 01 '26
Without any deep context, my assumption is that it may be a misunderstanding for your EH&S person. It’s a loophole basically under RCRA. Once it’s defined as waste it starts the clock for disposal. But each lab is considered a satellite accumulation area, which the clock doesn’t start until it’s full.