Managing vape waste in K-12 schools

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.

For more information on how to count, log, and properly manage vape waste, refer to the Dangerous Waste Vape Management Options for Schools.

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.

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:

• Obtain an EPA/State Id Number and notify as a health care facility. Follow the instructions in How Schools Apply for an EPA/State ID and Notify as a Health Care Facility.
• Fill out the School District Interim Policy Notification Form. 
• Determine a location at the school to safely accumulate the vape waste from generating schools. The storage location must be secured, such as a storage shed, shipping container, cargo box, or other school building with limited or restricted access.
  Note: Do note store containers of vape waste near other ignitable or combustible materials.
• Gather, store, and label your school’s vape waste properly. Place each nicotine vape in a separate clear, sealed plastic bag (such as a sandwich bag) to prevent the batteries from possibly short-circuiting and catching fire. Store these vapes together in a closed metal container lined with a plastic liner or bag. You may choose any size metal container, but we recommend no larger than 5 gallons.
• 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. Alternatively, you can hire a hazardous waste transporter or broker to assist with transporting vape waste to a commercial TSD facility.
• Submit a Dangerous Waste Report by March 1, the calendar year after receiving their EPA/State ID number.

All schools must learn to properly manage vape waste going forward. We recommend schools choose Option 1 in the Dangerous Waste Vape Management Options for Schools.

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 that are physically separate from schools 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:

• Determine a location at the school to safely accumulate vape waste prior to sending it to the consolidating school. Do not store containers of vape waste near other ignitable or combustible materials.
• Gather and store all nicotine vape wastes. Place each nicotine vape in a separate clear, sealed plastic bag (such as a sandwich bag) to prevent the batteries from possibly short-circuiting and catching fire. Store these vapes together in a closed metal container lined with a plastic liner or bag. You may choose any size metal container, but we recommend no larger than 5 gallons.
• Label or mark each metal container as “Hazardous Waste Pharmaceuticals” or “Dangerous Waste Pharmaceuticals” and with the date the first vape waste was added.
• Deliver your containers of nicotine vape waste to the consolidating school within 60 days of completing the steps above (gathering and labeling).

All schools must learn to properly manage vape waste going forward. We recommend schools choose Option 1 in the Dangerous Waste Vape Management Options for Schools.

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.

For singular private schools 

See the Dangerous Waste Vape Management Options for Schools for management options for individual private schools with no other common owner entity.

Devices with lithium-ion batteries get surprisingly heavy even in small amounts. This is why we recommend metal containers with lids no larger than 5 gallons.

We can’t promote any specific container, product, or brand. However:

• Metal containers with lids and plastic liners or bags can be found at many hardware, online stores, or from your waste service provider.
• Plastic sealed bags for individual vapes can be any size sandwich bag. Most vapes are quite small, so “snack size” sandwich bags will often be big enough. You can find these at grocery or online stores.
• 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" (pictured).

For generating schools

Once you remove the initial stockpile of vape waste under the interim policy, the amount of nicotine vape waste you accumulate going forward (under Option 1) should be able to easily fit into a single 5-gallon metal bucket with a lid.

For consolidating schools

Consolidating schools can do any of the following:

• Keep the original containers received from generating schools. 
• Consolidate vape waste from generating schools into 5-gallon metal containers with plastic liners or bags already on-site and return the empty container to the generating school for reuse.

Remember to remove old accumulation start dates from reused containers.

For cannabis vape waste, schools can work with their school resource officers if they are law enforcement (not contracted security) who may be able to dispose of cannabis vape waste through a conditional exclusion for controlled substances (WAC 173-303-071(3)(nn)).

Cannabis vapes need to be:

• Separated from nicotine vape waste.
• Placed in individual sealed plastic bags (like sandwich bags), then stored together in a metal container lined with a plastic liner or bag.
• 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).

See the cannabis section of the Dangerous Waste Vape Management Options for Schools.

How to dispose of cannabis vapes when batteries are removed

If the battery is separated or removed from cannabis vape devices, schools can:

• Manage the batteries as universal waste. To prevent the batteries from short-circuiting and catching fire, place each individual lithium battery in a separate clear, sealed plastic bag or put non-conductive [JM10.1]tape on the battery terminals.
• Throw the cannabis portion into the trash, but only if the school is a small quantity generator (SQG).
• Dispose of the cannabis portion as special waste at a local solid waste landfill that will accept it if the school is a medium or large quantity generator (MQG or LQG). Read the Focus on: Special Waste Exclusion for more details.

For cannabis vape waste, schools can work with their school resource officers if they are law enforcement (not contracted security). School resource officers may be able to dispose of cannabis vape waste through a conditional exclusion for controlled substances (WAC 173-303-071(3)(nn)). However, this exclusion does not apply to nicotine vape wastes, nor does this exclusion provide a pathway for disposal at the school since the law enforcement drug waste (cannabis) must be incinerated per the regulation.

Read the Focus on: Pharmaceutical Waste Conditional Exclusion for Washington State Law Enforcement Publication for more information.

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.