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Attendees will have a chance to ask questions. This webinar will be recorded and made available.
Schools in Washington face a growing challenge managing vape waste. As vaping has grown more popular, schools must learn to safely manage confiscated or discovered vapes on school property. Vapes pose serious risks to human health and the environment because they contain:
Toxic chemicals
Lithium-ion batteries which can cause fires
To help schools manage their current stockpiles of vape waste, we’ve issued an Interim Policy for Vape Waste in K-12 Schools. The interim policy gives schools an opportunity to remove and consolidate large stockpiles of nicotine vape waste for disposal without having to meet more stringent regulatory requirements.
Vaporizers (or, vapes) are battery-operated devices that heat a liquid and produce an aerosol. They go by many names such as e-cigarettes, e-cigs, vape pens, and others. They come in many shapes and sizes and mostly contain nicotine or cannabis.
Once vapes are confiscated from students or discovered on school property, they become dangerous waste, and subject to the Dangerous Waste Regulations (Chapter 173-303 WAC).
This includes:
Nicotine vapes (even if empty).
Cannabis vapes that contain e-liquids over 10% THC (tetrahydrocannabinol) concentration.
Batteries in vape devices (separated or embedded).
The problem with nicotine
Nicotine is a P-listed acute hazardous waste (P075), which means it’s more toxic than cannabis under the Dangerous Waste Regulations. Even empty nicotine vapes are considered dangerous waste. Schools can only accumulate 2.2 pounds of it before stricter regulations are required.
The problem with cannabis
Cannabis is a dangerous waste under the Dangerous Waste Regulations and a Schedule I controlled substance under federal regulations. Schools can accumulate 220 pounds of this type of dangerous waste before stricter regulations are required.
The interim policy is meant to help schools reset so they can begin managing vape waste properly from a place of zero accumulation. School districts will determine if schools within their district will follow the Interim Policy for Vape Waste in K-12 Schools. If you are a school, contact your school district to coordinate use of the interim policy.
Choose your consolidating school
School districts choose a school in their district to be the consolidating school. This is the location where all vape waste from other schools (referred to as "generating schools") will be delivered and collected for disposal.
Get an EPA/State ID and notify as a health care facility
The consolidating school must fill out the School District Interim Policy Notification Form. You will need your EPA/State ID number and names of all generating schools in the district that will participate.
Gather, store, and label vape waste properly
Each school (both generating and consolidating) must gather their nicotine vape waste and store it in closed metal containers labeled as “Hazardous Waste Pharmaceuticals” or “Dangerous Waste Pharmaceuticals” with the date the first vape waste was added.
Transport vape waste to the consolidating school
Generating schools transport their vape waste to the consolidating school. The consolidating school keeps records of vape waste shipments from each generating school for 5 years.
Send consolidated vape waste for disposal
The consolidating school sends all consolidated and self-generated nicotine vape waste to a permitted treatment, storage, and disposal (TSD) facility.
Submit a Dangerous Waste Report
The consolidating school must submit a Dangerous Waste Report by March 1, the calendar year after receiving their EPA/State ID number.
All schools manage vape waste properly going forward
Schools can continue to manage vape waste the same way as the interim policy except generating schools must count and log this waste. This is Option 1 in the Dangerous Waste Vape Management Options for Schools. Schools may choose other options, but Option 1 is likely the easiest.
This option essentially lets schools continue the same process they operated under during the interim policy (i.e., generating schools take their vape waste to the consolidating school, the consolidating school coordinates disposal).
However, Option 1 has additional requirements for generating schools. Each generating school must:
Count and log their vape waste.
Deliver their nicotine vape waste to the consolidating school before accumulating 2.2 pounds of nicotine on-site to maintain their status as a small quantity generator (SQG).
Note: Consolidating schools do not need to count vape waste or other pharmaceutical waste. However, they are required to count non-pharmaceutical dangerous waste to determine their generator category.
Your generator category is determined by how much dangerous waste you generate per month.* Each generator category has a dangerous waste and acute hazardous waste threshold (the amount you’re allowed to generate on-site) which determines if you are a:
Small quantity generator (SQG)
Medium quantity generator (MQG)
Large quantity generator (LQG)
Generating schools are required to remain small quantity generators (SQGs) to continue consolidating vape waste under Option 1. Consolidating schools aren’t required to remain SQGs, but it’s advisable. Larger generator categories come with more oversight and regulatory requirements.
For SQGs, these are the waste generation limits per month:
Nicotine and other acute hazardous wastes (2.2 pounds). If you exceed this, you become subject to LQG rules.
Cannabis and other dangerous wastes (220 pounds). If you exceed this, you become subject to MQG rules.
Be aware that:
1 milliliter (mL) of nicotine = 1 gram.
2.2 pounds = 998 grams of nicotine.
*Consolidating schools do not need to count vape waste or other pharmaceutical waste. However, they are required to count non-pharmaceutical dangerous waste to determine their generator category.
Questions about the interim policy
Find answers to common questions about the interim policy.
A consolidating school is the school where all other schools within the district will transport their vape waste. To follow the interim policy, consolidating schools need to:
Gather, store, and label your school’s vape waste properly.
Keep records of vape waste shipments from generating schools for 5 years. When generating schools transport their vape waste to you, your records must show:
Name of the generating school.
Date the vape waste was received at your (consolidating) school.
Weight or amount of vape waste received (consolidating schools may have to weigh this since generating schools don’t have to count their vape waste under the interim policy).
Send all consolidated and self-generated vape waste off-site within one calendar year of the earliest vape waste accumulation start date (either consolidated or self-generated, whichever has the earliest accumulation start date).
Work with a commercial permitted treatment, storage, and disposal (TSD) facility to ship the consolidated vape waste on a hazardous waste manifest.
Submit a Dangerous Waste Report by March 1, the calendar year after receiving their EPA/State ID number.
The interim policy is based on pharmaceutical rules, which is only available for facilities that meet the definition of a health care facility (WAC 173-303-555). Schools typically meet this definition when they have a nurse's office that administers medications or a person on call who can administer medications. Consolidating schools have to notify as a health care facility in order to consolidate vape waste from generating schools.
The interim policy requires that the consolidating school location meet the definition of a health care facility (WAC 173-303-555). School district administrative offices and maintenance shops likely don’t meet this definition. Schools are unique in that they have a nurse (or one on call) that dispenses medications, therefore meeting the definition of a health care facility.
To follow the interim policy, generating schools need to:
Gather all nicotine vape wastes and store them in closed metal containers.
Label or mark these containers with as “Hazardous Waste Pharmaceuticals” or “Dangerous Waste Pharmaceuticals” with the date the first vape waste was added.
Deliver their containers of nicotine vape waste to the consolidating school within 60 days of completing the steps above (gathering and labeling).
Yes, however the interim policy benefits multiple private schools that are owned by the same entity versus private schools that operate entirely alone.
For multiple private schools owned by the same entity
In this case, the owner of the private schools acts as the “school district” and selects one of its private schools to be the consolidating school (Step 1). The other private schools owned by the same entity would be the generating schools. Follow all steps outlined in the interim policy.
Metal containers with lids can be found at many hardware or online stores. Waste service providers also sell these.
Labels can be written on the container, made with any labeling materials you may have, or you can print our free "Hazardous Waste Pharmaceuticals label."
Questions about cannabis and vape devices
Learn how schools can manage cannabis and how to identify the different types of vape devices.
For cannabis vape waste, schools can talk with their school resource officers who may be able to dispose of cannabis vape waste through a conditional exclusion for controlled substances (WAC 173-303-071(3)(nn)) that are held in the custody of law enforcement agencies.
Cannabis vape waste needs to be:
Separated from nicotine vape waste.
Stored in its own separate metal container.
Counted and logged separately from nicotine if it’s not managed under the conditional exclusion above. For simplicity, schools can count the entire weight of the cannabis vape device. Cannabis has a higher accumulation threshold (220 pounds) than nicotine (2.2. pounds).
Have a school resource officer manage cannabis vape waste or a waste service provider remove and separate the batteries from the devices.
Throw the cannabis portion into the trash, provided the school has maintained their status as a small quantity generator (SQG).
If a school becomes a medium or large quantity generator (MQG or LQG), they can dispose of the cannabis portion as special waste at a local solid waste landfill that will accept it. Read the Focus on: Special Waste Exclusion for more details.
There are generally two types of vape devices. Either type can contain nicotine or cannabis.
Single-use vapes (or disposable vapes) are all-in-one devices with embedded lithium-ion batteries, designed to be discarded after the liquid is depleted. They don’t have components that can be replaced or in most cases refilled. They are often opaque, meaning you cannot see inside. The container is usually hidden within the vape housing.
Reuseable vapes (or refillable vapes) are vape devices with rechargeable lithium-ion batteries that can be separated. They have components that can be replaced or refilled. These vapes often have a transparent window, meaning you can see the tank that holds the e-liquid (nicotine or cannabis-containing liquid). They are also generally bigger than disposable vapes, but not always.
Cannabis vape liquids are generally thicker and darker in color (like honey) than nicotine vape liquids, which are generally thinner and lighter in color (more like water).
If the contents aren’t visible or you’re unsure, you can use the label on the vape device to look it up online.
