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INTRODUCTION TO

HAZARDOUS
WASTE
MANAGEMENT

University of Alaska Fairbanks


Environmental, Health, Safety, and Risk Management

May 2017
COURSE OUTLINE

 Overview of hazardous materials regulations


 Hazardous waste at UAF
 What is hazardous waste?
 What do I do with my hazardous waste?
 Emergency response

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OVERVIEW OF
HAZARDOUS
MATERIALS
REGULATIONS

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HAZARDOUS MATERIALS
REGULATIONS
Hazardous materials are regulated by three primary
government agencies:
Department of Transportation (DOT)
 Title 49, Code of Federal Regulations (49 CFR)
Occupational Safety and Health Administration (OSHA)
 Title 29, Code of Federal Regulations (29 CFR)
Environmental Protection Agency (EPA)
 Title 40, Code of Federal Regulations (40 CFR)

The International Fire and Building Codes also regulate hazardous materials

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HAZARDOUS MATERIALS REGULATIONS
(CONT.)
 DOT regulations direct us how to properly package, identify, and
label hazardous materials and hazardous wastes for transportation
 OSHA regulations tell us how to protect ourselves from the
effects of hazardous materials in the workplace
 EPA regulations tell us how to protect our environment

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DOT REGULATIONS
DOT classifies hazardous materials into 9 primary hazard
classes which are subdivided into multiple subsidiary risk
groups. You don’t need to memorize these, but the
primary hazard classes are: Class 1: Explosives
Class 2: Compressed Gases
Class 3: Flammable Liquids
Class 4: Flammable Solids
Class 5: Oxidizers
Class 6: Poisons and Toxics
Class 7: Radioactive materials
Class 8: Corrosives
Class 9: Miscellaneous hazardous materials
that don’t fit any other hazard class…
(i.e. dry ice)

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OSHA REGULATIONS
OSHA regulations include the following standards:
 Hazard Communication Standard (Hazcom, Right-to-Know)
 Occupational Exposure to Hazardous Chemicals in Labs,
including requirements for Chemical Hygiene Plans
 Respiratory Protection Standard
 Confined Space Entry Requirements
 Asbestos Standard
 Lead (Pb) Standard
 Bloodborne Pathogen Standard
 Formaldehyde, Benzene, and Methylene Chloride standards
OSHA also establishes Permissible Exposure Levels (PELs) for hazardous chemicals

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EPA REGULATIONS
Congress placed into law several acts that the EPA uses
to establish regulation to protect our environment:
Resource Conservation Recovery Act (RCRA)
Clean Air Act
Clean Water Act
Toxic Substances Control Act (TSCA)
Emergency Planning & Community Right-to-Know Act
(EPCRA)
Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA)

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HAZARDOUS WASTE REGULATIONS

EPA regulates hazardous waste in Alaska by authority of


the Resource Conservation Recovery Act. RCRA controls
include:
Identification of hazardous wastes
Tracking wastes from “cradle to grave”
Setting standards for generators of wastes, transporters of wastes,
and Treatment, Storage & Disposal Facilities

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PRIMARY RCRA REQUIREMENTS
RCRA requires that you:
 Label containers with a description of their contents
 Store only the permissible volume of waste in your lab
 Ensure lids and caps are securely fastened at all times, (exceptions
apply)
 Ensure all materials are properly segregated
 Use containers that are compatible with your waste
 Use intact containers (no cracks, holes, etc.)
 Ensure that spills and overfills do not occur
 Ensure that mismanagement does not occur

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RCRA REQUIREMENT FOR
TRAINING
The purpose of this training is to comply with requirements
set forth by the EPA under 40 CFR 265.16 (Personnel
Training)

The scope of the training is to ensure that UAF personnel who


use chemicals:
1. Understand how to identify hazardous wastes
2. Understand how to package and label hazardous wastes
3. Understand how to have their hazardous materials disposed
4. Know how to respond effectively to emergencies

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RCRA REGULATORY INSPECTIONS

 EPA conducts unannounced Compliance Evaluation


Inspections
 In the past, UAF facilities have been inspected annually
 Our goal is to comply with all regulations

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HAZARDOUS
WASTE AT UAF
An overview of sources of hazardous
waste at UAF, and its ultimate fate…

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SOURCES OF HAZARDOUS WASTE
AT UAF
Sources of hazardous wastes (HW) at UAF include:
 Research and academic laboratories
 Shops and repair facilities
 Art and theater departments
 Facility maintenance and grounds
 Power Plant operations
 Experimental Farm operations

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HAZARDOUS WASTE GENERATORS
The RCRA definition of a HW generator is:
Any person, by site, whose act or process produces
hazardous waste identified or listed in 40 CFR 261.3.

Generators are classified by the volume of HW that they produce


per month:
VSQG = Very Small Quantity Generator
SQG = Small Quantity Generator
LQG = Large Quantity Generator > 1000 kg/month non-acute hazardous
waste or >1 kg/month of acute hazardous waste

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UAF’S WASTE GENERATOR STATUS

 The UAF main campus is regulated as a Large


Quantity Generator
 UAF’s extended sites are regulated as Very Small
Quantity Generators
 Examples: Toolik Field Station, Palmer Research Farm,
Kodiak Seafood & Marine Science Center, Seward
Marine Center, Lena Point Fisheries Facility (Juneau)

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HAZARDOUS WASTE
MANAGEMENT AT UAF
 EHSRM assists UAF waste generators with waste disposal
needs
 Hazardous Materials Facility (HMF) stores waste and
serves as UAF’s Central Accumulation Area (CAA)
 RCRA-regulated hazardous wastes are shipped
 Every 90 days from the HMF
 By EPA-permitted transporters to EPA-permitted treatment, storage, and
disposal facilities
 Annual costs: $150,000 for disposal; $400,000 total cost of hazmat
program at UAF

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WHAT IS
HAZARDOUS
WASTE?

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EPA DEFINITION OF A SOLID WASTE
 EPA begins by defining all waste as a “solid” waste
(including solids, liquids, gases, and semi-solids)
 40 CFR 261.2 provides the definition of “solid waste:”
 (a)(1) A solid waste is any discarded material that is not
excluded under § 261.4(a) or that is not excluded by variance
granted under §§ 260.30 and 260.31 or that is not excluded by
a non-waste determination under §§260.30 and 260.34.
 (2) A discarded material is any material which is:
 (i) Abandoned, as explained in paragraph (b) of this section; or
 (ii) Recycled, as explained in paragraph (c) of this section; or
 (iii) Considered inherently waste-like, as explained in paragraph (d)
of this section; or
 (iv) A military munition identified as a solid waste in 40 CFR
266.202.
No need to memorize that!

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EPA DEFINITION OF A HAZARDOUS
WASTE (CONT.)
 If the waste material meets certain criteria, and is not
somehow exempted or excluded from regulation, it may
be a RCRA-regulated HW
 The legal definition of HW is found in 40 CFR 261.3
 (a) A solid waste, as defined in §261.2, is a hazardous waste if:
 (1) It is not excluded from regulation as a hazardous waste under
§261.4(b); and
 (2) It meets any of the following criteria: (continue to next slide)

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EPA DEFINITION OF A HAZARDOUS
WASTE (CONT.)
 (i) It exhibits any of the characteristics of hazardous waste identified in
subpart C of this part. However, any mixture of a waste from the extraction,
beneficiation, and processing of ores and minerals excluded under
§  261.4(b)(7) and any other solid waste exhibiting a characteristic of
hazardous waste under subpart C is a hazardous waste only if it exhibits a
characteristic that would not have been exhibited by the excluded waste
alone if such mixture had not occurred, or if it continues to exhibit any of
the characteristics exhibited by the non-excluded wastes prior to mixture.
Further,
 (Continue to next slide)

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EPA DEFINITION OF A HAZARDOUS
WASTE (CONT.)
 for the purposes of applying the Toxicity Characteristic to such mixtures,
the mixture is also a hazardous waste if it exceeds the maximum
concentration for any contaminant listed in table I to §  261.24 that would
not have been exceeded by the excluded waste alone if the mixture had not
occurred or if it continues to exceed the maximum concentration for any
contaminant exceeded by the nonexempt waste prior to mixture.
 (Continue to next slide)

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EPA DEFINITION OF A HAZARDOUS
WASTE (CONT.)
 (ii) It is listed in subpart D of this part and has not been excluded from the
lists in subpart D of this part under §§  260.20 and 260.22 of this chapter.

You don’t need to memorize the definition of


a hazardous waste either!

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SO, IS YOUR WASTE A HAZARDOUS
WASTE?
 EPA regulations (40 CFR 261.2) require that a hazardous waste
determination be made on a solid waste which has been generated
 An accurate hazardous waste determination for each solid waste must be
made at the point of waste generation
 A person must determine whether the solid waste is excluded from
regulation under 40 CFR 261.4

 (Continue to next slide)

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SO, IS YOUR WASTE A HAZARDOUS
WASTE? (CONT.)
 If the waste is not excluded under 40 CFR 261.4, the person must then use
knowledge of the waste to determine whether the waste meets any of the
listing descriptions under subpart D of 40 CFR part 261.
 The person then must also determine whether the waste exhibits one or
more hazardous characteristics as identified in subpart C of 40 CFR part
261 by following the procedures in paragraph (d)(1) or (2) of this section,
or a combination of both.

 (Continue to next slide)

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SO, IS YOUR WASTE A HAZARDOUS
WASTE? (CONT.)
 (d)(1) The person must apply knowledge of the hazard characteristic of
the waste in light of the materials or the processes used to generate the
waste.
 (d)(2) When available knowledge is inadequate to make an accurate
determination, the person must test the waste according to the applicable
methods set forth in subpart C of 40 CFR part 261 or according to an
equivalent method approved by the Administrator under 40 CFR 260.21
 Persons testing their waste must obtain a representative sample of the
waste for the testing, as defined at 40 CFR 260.10.

Let’s look at the different categories as defined by the


EPA

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CATEGORIES OF HAZARDOUS
WASTE
Hazardous waste determinations are based upon whether
the material is a:
Characteristic waste
 Listed on the D-list or TCLP (Toxicity Characteristic Leaching Procedure)
Listed waste
 Materials specifically identified on one of the following lists: F, K, U or P lists
Universal waste
 Batteries, lamps, pesticides, mercury from thermometers

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CHARACTERISTIC WASTES
 D001 – Ignitable Wastes (flashpoint is less than
140º F) includes oxidizers
 D002 – Corrosive Wastes (pH less than or equal to
2 or greater than or equal to 12.5)
 D003 – Reactive Wastes (water reactive,
normally unstable materials, cyanides &
sulfides, etc)
 D004 – TCLP Wastes

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LISTED WASTES

 F-listed wastes are from non-specific sources


 Example: halogenated solvents used to degrease equipment

 K-listed wastes are from specific sources


 Example: petroleum refining or pesticide manufacturing

 U-listed wastes are toxic wastes


 P-listed wastes are acute hazardous wastes

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EXAMPLES OF U-LISTED WASTES
Acetaldehyde 1,4-Dioxane
Acetone Ethyl acetate
Acetonitrile Ethyl ether
Aniline Formaldehyde
Benzene Methyl alcohol
Bromoform Methylene chloride
1-Butanol Phenol
Chloroform Toluene

U-listed chemicals are commonly found in UAF labs

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EXAMPLES OF P-LISTED WASTES
Allyl alcohol Osmium tetroxide
Ammonium vanadate Phenylthiourea
Arsenic acid Potassium cyanide
Arsenic trioxide Sodium azide
Carbon disulfide Sodium cyanide
2,4-Dinitrophenol Thiosemicarbazide
Fluorine Vanadium oxide
Nitric oxide Vanadium pentoxide

P-listed chemicals are also fairly common in UAF labs

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UNIVERSAL WASTES

 Universal wastes include the following materials


that are commonly found in the workplace
 Batteries
 Fluorescent lamps
 Pesticides
 Thermometers (containing mercury)

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UNIVERSAL WASTES:
BATTERIES
 Used Battery collection containers (white 5-gallon
buckets) are available at many locations on campus
 Contact your Lab Manager, CHO, Shop Supervisor
or EHSRM for more information

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UNIVERSAL WASTES: FLUORESCENT
LAMPS
 UAF recycles fluorescent and other lamps
 Lamp shipments are made periodically to EcoLights Northwest

 The Facilities Services Electric Shop does the vast


majority of lamp replacement on campus
 EHSRM can provide lamp collection boxes and
labels to you
 Boxes must be labeled with the words, “Universal Waste Lamps”,
“Waste Lamps”, or “Used Lamps” to identify the contents

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UNIVERSAL WASTES: PESTICIDES

 If you have waste pesticides:


 Fill out an online UAF Non-radioactive Hazardous
Materials Transfer Request. Don’t know how? Go
to slide #45.

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UNIVERSAL WASTES:
MERCURY THERMOMETERS
 If you break a mercury thermometer:
 DO NOT try to clean it up yourself ---- Call UAF Hazmat at 474-
5617 immediately for assistance
 Evacuate the area and keep traffic from walking through the spill site
 NEVER throw the material in the trash or dump it down the drain
 Don’t need your mercury thermometers or wish to exchange
unbroken thermometers for similar, non-mercury
thermometers, free of charge? Call EHSRM at 474-5617 to
get more information.

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OTHER WASTE: AEROSOL CANS
 Aerosol cans are considered hazardous waste under the definition of
“Characteristic Reactivity”
40 CFR Part 261.23: “….capable of detonation or explosive reaction if it is
subjected to a strong initiating source or if heated under confinement.”
 Often contain hazardous materials, either as the product or as the
propellant
 Most aerosol cans, regardless of contents, can never be completely
emptied of propellant
 Aerosol cans become a waste when…
 their contents are used up,
 malfunction (i.e. fail to spray), or
 when the contents are no longer needed

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OTHER WASTES: USED OIL
 Used oil means:
any oil that has been refined from crude oil, or any synthetic oil, that
has been used and as a result of such use, is contaminated by physical
or chemical impurities (40 CFR 279.1)
 Used oil must be:
 Collected in clean containers in good condition (no leakers)
 Storage and transfer containers must be marked with the words
“Used Oil”
 Never add solvents, part washer fluids, carb cleaners, or glycol to
your used oil

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OTHER WASTES: USED OIL (CONT.)
 Keep the “used oil” container closed (lid in place
and secured) except when adding or removing used
oil
 If you use a funnel for transfers, the funnel must be
removed when not in use and the container capped
 See slide #45 to make on online request to have
your used oil removed

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WASTE IN YOUR
LAB
What do I do with my wastes and
unwanted chemicals?

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SATELLITE ACCUMULATION AREAS
 Each lab that generates waste is referred to as a
“Satellite Accumulation Area” (SAA)
 A generator may accumulate hazardous waste in containers at
or near any point of generation where wastes initially
accumulate which is under the control of the operator of the
process generating the waste
 When EHSRM removes the waste from a SAA, it is
transferred to the UAF Hazmat Facility or “Central
Accumulation Area”

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WASTE STORAGE LIMITS FOR SAAS

 For SAAs, the waste storage limits are:


 Up to 55 gallons of non-acute hazardous waste
 Up to 1 quart (liquid) or 1 kg (solid) of an acute hazardous
waste (P-listed waste)
 50 gallons of waste at a SAA will likely be in violation of
Fire & Building Codes

Note: you do not need to accumulate 55 gallons or 1quart / 1 kg


of a P-listed waste before requesting waste removal!

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SAA CONTAINER MANAGEMENT
 A container holding hazardous waste must be closed at all times during accumulation,
except:
 (i) When adding, removing, or consolidating waste; or
 (ii) When temporary venting of a container is necessary
 (A) For the proper operation of equipment, or
 (B) To prevent dangerous situations, such as build-up of extreme pressure.

 (Continue to next slide)

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SAA CONTAINER MANAGEMENT
(CONT.)
 A generator must mark or label a container holding hazardous waste
with the following:
 (i) The words “Hazardous Waste” and
 (ii) An indication of the hazards of the contents (examples include, but
are not limited to, the applicable hazardous waste characteristic(s) (i.e.,
ignitable, corrosive, reactive, toxic); hazard communication consistent
with the Department of Transportation requirements at 49 CFR part 172
subpart E (labeling) or subpart F (placarding); a hazard statement or
pictogram consistent with the Occupational Safety and Health
Administration Hazard Communication Standard at 29 CFR 1910.1200;
or a chemical hazard label consistent with the National Fire Protection
Association code 704).

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TO MAKE A WASTE REMOVAL
REQUEST
 As of April 2012, the Division of Hazardous Materials at EHSRM is
using an online hazardous waste pick up request. Please discontinue
using the old triplicate paper hazardous waste transfer request forms.
 If you have not been trained in the use of the online request, call
474-7889 to schedule a training session. Or go to the EHSRM
website for more information:
http://www.uaf.edu/safety/laboratory-safety/chemical-inventory/

Remember: There is no charge to your lab for chemical waste disposal

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TAKE-HOME
MESSAGES
What you need to remember…

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WASTES: CONTAINERS AND STORAGE
 Only use containers that are compatible with the materials to be
collected
 Always label containers with a description of their contents
 Don’t store incompatible materials together
 Do not store wastes in the fume hood. Store in the appropriate
storage cabinet (e.g., flammable, acid)
 Provide secondary containment for liquid wastes
 Always keep the container closed (lid firmly secured)
 A funnel in an open bottle is NOT a lid
 Check waste storage areas regularly (weekly).
 Inspect containers to make sure they aren’t getting brittle or starting to
crack

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BEFORE YOU START A PROJECT
 Plan ahead
 Is there a product or procedure available that will accomplish the
task w/o generating a hazardous waste?
 Strive for waste minimization
 Only make as much solution as you need
 Substitute less hazardous chemicals if possible
 Use microscale chemistry techniques
 Before purchasing chemicals, log onto your EHS Assistant
online inventory and click on the “Surplus Chemicals” button at
the top of the main page. Contact EHSRM at 474-5617 to
request transfer of surplus chemicals.

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OTHER THINGS TO THINK ABOUT

 Check the P-list - if you plan to generate a P-listed


waste, contact your Chemical Hygiene Officer, Lab
Manager or EHSRM
 Never combine wastes
 If you don’t generate them together as part of a procedure, then do
not mix them.
 May create hazardous reactions in the bottle (worst-case scenario),
or make it more expensive for us to dispose of it (not a good
scenario, but at least it didn’t blow up)

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EMERGENCY
RESPONSE
Chemical spills, release of hazardous
materials, fires, and evacuation

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CHEMICAL SPILLS
 Report all spills to UAF Dispatch (474-7721) or call 911 if
there is an immediate threat of harm to life or property
 Dispatch will call EHSRM Hazmat Section or the FNSB
Hazmat Team, if necessary, to request assistance with spill
cleanup
 Depending on the nature of the spill, you may be asked to
complete the UAF Oil and Hazardous Substance Spill
Reporting Form (available from EHSRM)

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CHEMICAL SPILLS (CONT.)
 If you have not been trained and/or do not have the
appropriate personnel protective equipment, please call for
assistance!
 Never put yourself or others at risk to cleanup a spill!

If you don’t know…don’t go

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EMERGENCY PROCEDURES:
FIRE
 Activate the nearest fire alarm pull station and call 911
 Evacuate the building and go to the Evacuation Assembly
Point or designated area of safe refuge
 Advise emergency personnel of anyone still inside the
building
 Do not re-enter the building until authorized by emergency
personnel

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EMERGENCY PROCEDURES: RELEASE OF
HAZARDOUS MATERIALS

 Call 911 in the event of an emergency or if anyone is in


danger
 Move away from the site of the hazard to a safe location
 Follow the instructions of emergency personnel
 Alert others to stay clear of the area
 Notify emergency personnel if you have been exposed or
have information regarding the release

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EMERGENCY PROCEDURES: EVACUATION
 Know the evacuation procedures and evacuation route information for your
area
 Evacuate the building using the nearest safe exit
 Do not use elevators!
 Take personnel belongings (keys, purses etc., but don’t put yourself or others
at risk by delaying evacuation)
 If possible, secure any hazardous materials or equipment
 Follow the directions given by emergency personnel
 Go to Evacuation Assembly Points (EAPs) designated on the emergency
evacuation sign for the building
 Assist persons with disabilities
 Do not leave the area/campus until your status has been reported to your
supervisor or instructor

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FOR MORE INFORMATION…

Environmental, Health, Safety, and Risk Management

Visit our website at: www.uaf.edu/safety

Or call us at 474-5413

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