Satellite Accumulation Areas

Satellite Accumulation Areas

A Satellite Accumulation Area (SAA) is where hazardous waste is accumulated and stored prior to its transport to the Hazardous Waste Central Accumulation Area (CAA) by EHS. As well as being required by Maryland's Code of Maryland Regulations (COMAR), SAAs make it easy for EHS staff to locate and pickup your waste as well as being easily identifiable for first responders in case of an emergency.

A recent major revision to COMAR 26.13.03 (Standards Applicable to Generators of Hazardous Waste) has prompted EHS to launch this informational page and outreach program for labs that generate and store hazardous waste.

This information applies to any lab generating hazardous waste.

Who To Contact

Any questions or concerns can be directed to the Chemical Hygiene Officer or Environmental Programs Manager. 

Shannon Sussman
Chemical Hygiene Officer
410-706-7055

Kevin Nichol
Manager, Environmental Programs
410-706-7055

Frequently Asked Questions (FAQ)

Do I need an SAA? ▾

Any lab generating hazardous waste is required to have a designated SAA space. If you use hazardous chemicals in your lab, you likely generate hazardous waste. 

What do I need to do to set up an SAA? ▾

Nothing! EHS will be making appointments with each lab to mark off the SAA area. If you have a location where hazardous waste is already collected, we will do our best to honor that location.

Can I put my SAA in the fume hood? ▾

Your SAA cannot be located inside fume hoods, unless the fume hood is used solely for hazardous
waste storage and there in no sink drain inside the hood. If you currently store hazardous waste in a fume hood, EHS will work with you to find an appropriate location for your SAA.

Should biological and radioactive waste also be kept in the SAA? ▾

SAAs are only required for chemical waste. While other categories of waste such as biological and radioactive waste can be placed there, it is not required. Controlled substances must never be stored in an SAA and must be kept locked in your approved storage cabinet. 

When should I put my waste in the SAA? ▾

Place your waste in the SAA when you are finished with the container, or when it is ready for pickup.  

What about containers attached to HPLC machines? ▾

One requirement of hazardous waste storage containers is that containers remained closed. Modifications can be made to the cap so that the tubes empty waste into the container while still be considered closed. Use of closed loop caps also prevent spillage, leaking, and potential venting of harmful vapors. 

What kind of container can I use to accumulate my waste? ▾

Material incompatibilities can be found on the chemical's safety data sheet (SDS).

Is the SAA the responsibility of a principal investigator, department, or is linked to the physical room? ▾

In shared spaces, each lab group will have their own SAA that is the responsibility of that principal investigator and research group.

Can I move waste from one SAA to another? ▾

Waste cannot be moved from one SAA to another, even if they are in the same room or under control of the same generator or principal investigator. Waste must be accumulated at or near the point of generation (COMAR 26.13.03.03-3B1).

Do I still need to inventory these chemicals in my SAA?  ▾

The parent chemicals should be represented in your ChemTracker inventory as the full quantity or volume that you purchased. As you use the parent chemical, you do not need to edit your ChemTracker inventory. If you completely empty the parent chemical bottle, or are submitting the remainder of the parent chemical bottle for hazardous waste disposal, you can remove that container from your ChemTracker inventory after EHS has picked it up and it is no longer is your labspace.