Regulation of Hazardous Waste

In California, hazardous waste is regulated by the Department of Toxic Substance Control (DTSC), a division within the California Environmental Protection Agency (Cal/EPA).  Federal EPA regulations also govern certain aspects of hazardous waste management, since most of our waste is treated and disposed out of state. These hazardous waste regulations are part of the Resource Conservation and Recovery Act, or RCRA.  Local enforcement authority is administered by the Los Angeles County Health Hazardous Materials Division.

Hazardous Waste Program

The EH&S Hazardous Materials Program manages the shipment and disposal of all hazardous waste generated on campus.  Each laboratory user must comply with the campus Hazardous Waste Management Program requirements and all applicable regulations.  A scheduled weekly pick-up service is provided to most research buildings containing wet labs, and pick-ups are available upon request to other locations where hazardous waste is generated (Pick-up schedule). Laboratory personnel are responsible for identifying waste, labeling it, storing it properly in the laboratory, and transporting waste to the designated pick-up location on time. Laboratory clean-outs and disposal of high hazard compounds (e.g. expired peroxide-forming chemicals, dried picric acid, or abandoned unknown chemicals) must be scheduled in advance, and a fee/recharge for these services is sometimes applied. The PI/Laboratory Supervisor is responsible for coordinating the disposal of all chemicals from his/her laboratories prior to closing down laboratory operations. This is an integral aspect of lab decommissioning. 

Definition of Hazardous Waste

EPA regulations define hazardous waste as substances having one of the following hazardous characteristics:

• Corrosive:  pH < 2 or >12.5
• Flammable:  liquids with flash point below 38º C or 100º F [e.g. Methanol, Acetone, Ethanol, Isopropyl alcohol etc.]
• Reactive: unstable, explosive, reacts violently with air and/or water, or releases a toxic gas when in contact with water [e.g., Sodium metal]
• Toxic: Determined by toxicity testing [e.g., Mercury] 

The EPA definition of hazardous waste also extends to the following items:

• Abandoned chemicals
• Unused or unwanted chemicals
• Chemicals in compromised containers [e.g., with broken caps, ruptured, punctured, corroded]
• Empty containers that have visible residues
• Containers with conflicting labels (dual labeling)
• Unlabeled or unknown chemicals

Chemicals not in frequent use must be carefully managed to prevent them from being considered a hazardous waste.  This is especially true for certain compounds that degrade and destabilize over time require careful management so that they do not become a safety hazard (see the section below titled “Wastes that Require Special Handling”).

Extremely Hazardous Waste

Certain compounds meet an additional definition known as “extremely hazardous waste”.  This list of compounds includes carcinogens, pesticides, and reactive compounds, among others (e.g., cyanides, sodium azide, and hydrofluoric acid).  The Federal EPA refers to this waste as “acutely hazardous waste”, but Cal/EPA has published a more detailed list of extremely hazardous waste.  Both the State and the Federal lists are included in the EH&S list of extremely hazardous waste. NOTE: While there is some overlap with the list of Particularly Hazardous Substances, such as the examples listed above, the extremely hazardous waste list is specific to the hazardous waste management program.

Proper Hazardous Waste Management

Training

All personnel who are responsible for handling, managing or disposing of hazardous waste must complete hazardous chemical waste training. This training is a component of the Laboratory Safety Fundamental Concepts course found on https://worksafe.ucla.edu/. 

Waste Identification

All the chemical constituents in each hazardous waste stream must be accurately identified by knowledgeable laboratory personnel. This is a critical safety issue for both laboratory users and the waste technicians that handle the waste once it is turned over to EH&S. Mixing of incompatible waste streams has the potential to create violent reactions and is a common cause of laboratory accidents.  If there is uncertainty about the composition of a waste stream resulting from an experimental process, laboratory workers must consult the PI/Laboratory Supervisor, the Chemical Hygiene Officer or the Hazardous Materials Manager.  In most cases, careful documentation and review of all chemical products used in the experimental protocol will result in accurate waste stream characterization. 

The manufacturer’s SDS provides detailed information on each hazardous ingredient in laboratory reagents and other chemical products, in addition to the chemical, physical, and toxicological properties of that reagent/product.  UC Risk and Safety Solutions provides an extensive library of research chemical SDS’s.  Waste streams that have a large percentage of ingredients listed as proprietary information should be discussed with the Hazardous Materials Program Manager.

Labeling

UCLA utilizes the UC system-wide Waste Accumulation Storage Tracking electronically (WASTe). Information on how to create a WASTe tag and a factsheet on the WASTe system can be found online. 

WASTe tags must be created and affixed to each container of chemical waste before waste is added to it. During the creation of the waste label, the waste generator must make a waste determination of the characteristics of the waste per 40 CFR 262.11. This is done by determining if the material is hazardous and if the waste is listed (P-, U-, or F-listed) or by classifying the waste in one of the following four categories:  ignitable, corrosive, reactive, or toxic.

• Ignitable: Liquids which have a flash point of less than 140°F (60.5°C)
• Flammable solids
• Flammable compressed gases
• Oxidizers/Peroxides

Corrosive:

• pH ≤ 2
  • Inorganic acids - digestion wastes, acid baths
  • Organic acids - HPLC liquids, (formic, glacial acetic, trifluoroacetic)
• pH ≥ 12.5
  • Bases/Alkalines - base baths
  • hydroxides, lysis buffers

Reactive:

• Compounds that are normally unstable and readily undergo violent change without detonation (diethyl zinc, organometallic substances)
• Compounds that react violently with water to liberate flammable or corrosive gases (anhydrous metal salts, alkali metals, metal hydrides, silanes)
• Cyanide and sulfides which can generate toxic gases, vapors, or fumes
• Compounds capable of detonation or explosion, either when initiated or due to decomposition or reaction at STP

Toxic:

Waste containing ppm (0.0001%) levels of any of the following:

Solid materials such as gloves, paper, filters, or soil that become contaminated with any of the toxic constituents also should be identified and collected.'

Online Tag Program

How to Create a WASTe Group

Waste Accumulation Storage Tracking electronically (WASTe) groups are maintained under the name of the PI (see https://ucla.box.com/s/04f9vzioil626lzjb2c1im7ioow1mk0s). Employees should check if a group already exists for their PI and associated laboratory(s). If a new group account needs to be established please contact the Hazardous Waste Manager at hazardousmaterials@ehs.ucla.edu.

How to Use WASTe
 

• Once a group has been established, employees can print tags from their laboratory's
  printer, and then affix the tag to the waste container by sliding it in the plastic envelope
  provided by EH&S
• Each tag must be completely accurately, and updated as the contents of the waste
  container change. Product names or abbreviations or chemical formula for waste
  container ingredients should not be used on the tag. Each individual container should
  have a WASTe tag with a unique tracking number. Employees may save a profile in
  the program for waste streams that are frequently generated
• When EH&S collects the waste, the tags are scanned and the containers are
  transferred from the lab's inventory to the inventory for the campus' waste
  accumulation area

Storage

The hazardous waste storage area in each laboratory is considered a Satellite Accumulation Area (SAA) by the EPA. According to EPA requirements, this area must remain under the control of the persons producing the waste.  This means that it should be located in an area that is supervised and is not accessible to the public.  Other SAA requirements include:

1. Hazardous waste containers must be labeled with a WASTe tag at all times (i.e., right from the first drop of generation/first point of waste collection in the receptacle. The same is applicable for the hazardous sharps waste receptacle and dry hazardous waste bags.)
2. Waste must be collected and stored at or near the point of generation.
3. According to State law, the maximum amount of waste that can be stored in a SAA is 55 gallons of a hazardous waste or 1 quart (0.96 liter) of extremely hazardous waste. If you reach these volumes for a specific waste stream, you must dispose of the waste within 3 days.
4. The maximum amount of flammable solvents allowed to be stored in a laboratory outside of approved flammable storage is 10 gallons; this figure also includes waste solvents.  Individual containers of flammable solvents greater than 1 gallon (4L) must be stored inside of a flammable storage cabinet.
5. All hazardous waste containers in the laboratory must be kept closed when not in use.
6. Hazardous waste streams must have compatible constituents, and must be compatible with the containers that they are stored in [e.g., do not use glass containers for hydrofluoric acid (HF) waste; do not use metal containers for waste containing corrosive or oxidizing chemicals]. 
7. Hazardous liquid waste containers must be stored in secondary containment at all times, irrespective of where they are being stored.
8. Containers must be in good condition with leak-proof lids.
9. Containers must be less than 90% full.
10. Dry wastes must be double-bagged in clear/transparent/see through, 3-mm plastic bags (these do not require secondary containment when storing).
11. All waste sharps (e.g. needles, razor blades) which are not biohazardous must be disposed in non-biohazard sharps containers which are NOT red. Affix an online hazardous waste tag on the non- biohazard sharps container and dispose of when about 2/3rd full or within 90 days, whichever is sooner. Do not recap the needles after use. Recapping could lead to serious needle stick injuries. Discard them directly into the designated rigid sharps container.
12. Liquid waste containers must be decontaminated and cleaned on the outside, prior to drop off at the weekly EH&S waste pick-up.  To prevent chemical spills/drippings on the outside of the waste receptacle, please use a proper funnel to transfer/pour contents.

Segregation

All hazardous materials must be managed in a manner that prevents spills and uncontrolled reactions.  Stored chemicals and waste should be segregated by hazard class. Examples of proper segregation are:

• Segregate acids from bases
• Segregate flammables from oxidizers 
• Segregate organic acids from inorganic acids 
• Segregate oxidizers from organics 
• Segregate cyanides from acids
• Segregate halogenated from nonhalogenated 

Segregation of waste streams should be conducted in a similar manner to segregation of chemical products. 

Incompatible Waste Streams

Mixing incompatible waste streams, or selecting a container that is not compatible with its contents, is a common cause of accidents in laboratories and waste storage facilities.  Reactive mixtures can rupture containers and explode, resulting in serious injury and property damage.  All chemical constituents and their waste byproducts must be compatible for each waste container generated.  Waste tags must be immediately updated when a new constituent is added to a mixed waste container, so that others in the laboratory will be aware and manage it accordingly.

Some common incompatible waste streams include:

• Oxidizers added to any fuel can create an exothermic reaction and explode.  The most frequent is acids oxidizing flammable liquids, such as nitric acid added to ethanol.  For this reason, all flammable liquids are pH-tested before they are consolidated.
• Piranha etch solution is a specific waste stream that contains sulfuric acid and hydrogen peroxide, which form a reactive mixture that is often still fuming during disposal.  For this waste stream, and other reactive mixtures like it, vented caps are mandatory.

Wastes that Require Special Handling

Unknowns 

Unlabeled chemical containers and unknown/unlabeled wastes are considered unknowns, and additional fees must be paid to have these materials analyzed and identified.  These containers must be labeled with the word “unknown”.  A $75 per container charge (irrespective of the size of the container) is incurred for disposal of unknown wastes.  Never mix unknowns for any reason. When disposing of these chemicals, the laboratory must complete a recharge order request or P39 form.  

Peroxide-forming Chemicals

Peroxide-forming chemicals, or PFCs, include a number of substances that can react to shock or spark or heat or friction, react with air, moisture, or product impurities, and undergo a change in their chemical composition during prolonged storage.  Peroxides are not particularly volatile and thus tend to precipitate 

out of liquid solutions. It is particularly dangerous to allow a container of these materials to evaporate to dryness, leaving the crystals of peroxide on the surfaces of the container.

Each container of peroxide-forming chemicals should be marked with the date received and the date first opened. There are four classes of peroxide-forming chemicals, with each class having different management guidelines (See Chapter 3).

Ensure containers of PFCs are kept tightly sealed to avoid unnecessary evaporation, as this inhibits the stabilizers that are sometimes added.  Visually inspect containers periodically to ensure that they are free of exterior contamination or crystallization.  PFC containers must be disposed of prior to expiration date. If old containers of peroxide-forming chemicals are discovered in the laboratory (greater than two years past the expiration date or if the date of the container is unknown), do not handle the container.  If crystallization is present in or on the exterior of a container, do not handle the container.  Secure it and contact the EH&S Hotline at 310-825-9797 for pick-up and disposal.  Disposal of expired peroxide-forming chemicals may incur a charge of $100 per container (irrespective of the size of the PFC container).  When disposing of these chemicals, the laboratory must complete a recharge order request or P39 form.

In some cases, it might be desirable to remove peroxides from chemicals rather than dispose of the entire chemical. This can be done safely for relatively low levels of peroxides (less than 100 ppm). Scrubbing of concentrations greater than 100 ppm may pose an unacceptable hazard, depending on the chemical involved. Scrubbing of discolored, crystallized, or layered peroxide formers is certainly too hazardous and should not be attempted. These severely peroxidized compounds should be treated as potential bombs. For those chemicals, where peroxide concentrations are >100 ppm, notify EH&S immediately to discuss the best course of action.

Method 1

Hydroperoxides can be removed by passing the solvent through a column of activated alumina. This method works for water-soluble and water-insoluble chemicals. The washed solvent should be retested to ensure that it has been cleaned adequately. The alumina apparently catalyzes the degradation of some peroxides, but in some cases the peroxide may remain intact on the alumina, making it potentially shock sensitive. The alumina can be deactivated by flushing with a dilute acid solution of potassium iodide or ferrous sulfate (description of ferrous sulfate solution below). The amount of alumina required depends on the quantity of peroxide. As a start, a column containing 100 g of alumina should be used for 100 mL of solvent. More alumina or passage through a second column may be required to eliminate peroxides. This method is relatively slow and expensive, but it avoids shaking the solvent and does not add water. It will not reliably remove dialkyl peroxides, although there is some controversy about this

Method 2

Peroxides in water-insoluble chemicals can be removed by shaking with a concentrated solution of ferrous salt; 12 g FeSO4, 12 mL concentrated H2SO4, and 210 mL water are a standard solution (always add acid to water). The peroxide-former is extracted two to three times with an equal volume of the reagent. Drying over sodium or magnesium sulfate can be used to remove dissolved water. Shaking should be very gentle for the first extraction. This method has repeatedly shown to be quite effective for most peroxides, but it is not reliable for removing alkyl peroxides. For water-soluble solvents such as tetrahydrofuran (THF), this ferrous sulfate solution can also be used to neutralize the peroxide concentration through stirring.

Dry Picric Acid

Picric acid (also known as trinitrophenol) must be kept hydrated at all times, as it becomes increasingly unstable as it loses water content.  When dehydrated, it is not only explosive but also sensitive to shock, heat and friction. Picric acid is highly reactive with a wide variety of compounds (including many metals) and is extremely susceptible to the formation of picrate salts.  Be sure to label all containers that contain picric acid with the date received, and then monitor the water content every 6 months.  Add distilled water as needed to maintain a consistent liquid volume. 

If an old or previously unaccounted for bottle of picric acid is discovered, do not touch the container.  Depending on how long the bottle has been abandoned and the state of the product inside, even a minor disturbance could be dangerous.  Visually inspect the contents of the bottle without moving it to evaluate its water content and look for signs of crystallization inside the bottle and around the lid.  If there is even the slightest indication of crystallization, signs of evaporation, or the formation of solids in the bottle, do not handle the container and contact the EH&S Hotline at 310-825-9797 orhazardousmaterials@ehs.ucla.edu immediately.  Secure the area and restrict access to the container until it can be evaluated by EH&S personnel. 

Explosives and Compounds with Shipping Restrictions

A variety of other compounds that are classified as explosives or are water or air reactive are used in research laboratories. These compounds often have shipping restrictions and special packaging requirements. When disposing of these compounds, employees must ensure that they are stored appropriately for transport. Flammable metals must be completely submerged in oil before they are brought to a waste pick-up. Chemicals classified by the Department of Transportation (DOT) as explosives (e.g., many nitro- and azo- compounds) will require special packaging and shipping, and may require stabilization prior to disposal. Consult with the Chemical Hygiene Officer and the Hazardous Materials Program Manager for disposal considerations of these compounds.

Chemotherapy Waste

Pourable chemotherapy/oncology chemicals should be left in their original container and may be brought to the hazardous waste pick-up. Place the bottles in the designated plastic container for bulk chemotherapy waste (usually a five-gallon, sealable bucket), and bring it to hazardous waste pick-up.

Medical devices and supplies that are associated with patient treatment, including tubes, empty containers, syringes, and sharps that are also contaminated with chemotherapy drugs should not be brought to the hazardous waste pick-up; these are disposed via the medical waste program.  Because chemotherapy drugs are potent toxins, special yellow barrels are available for these materials, which are usually located in medical waste storage areas. For more information, contact the Biosafety Program at 310-206-3929 or biosafety@ehs.ucla.edu.

Waste Containing Particularly Hazardous Substances

Waste containers which contain one or more particularly hazardous substances must be stored in a designated area during the accumulation period. They should only be opened within a fume hood, and may never be opened outside of a designated area. Funnels used to help transfer particularly hazardous substances into a waste container should be dedicated for this purpose. The exterior of these waste containers should be decontaminated periodically, and must be decontaminated prior to drop off at the weekly EH&S waste pick-up.

Managing Empty Containers

Empty containers that held Extremely Hazardous waste must be managed as hazardous waste, and brought to the waste pick-up. Do not rinse or reuse these containers. Empty containers greater than 5 gallons should also be managed as hazardous waste, and brought to a hazardous waste pick-up.

All other empty chemical containers, if they are less than or equal to 5 gallons in size, should either be reused for hazardous waste collection, or should be cleaned and discarded or recycled. Proper cleaning involves rinsing the container three times with water, with the first rinsate collected as hazardous waste.  The original/previous labels should be completely defaced or covered up.  If not reused, dispose of completely defaced and triple-rinsed plastic containers as regular trash. If not reused, dispose of completely defaced and triple-rinsed glass bottles in cardboard boxes.

Transportation

It is a violation of DOT regulations to transport hazardous waste in personal vehicles, or to carry hazardous waste across campus streets that are open to the public.  As a result, EH&S provides pick-up services for all hazardous waste generators.  These routine waste pick-ups are for routinely generated research wastes. Special pick-ups and laboratory clean-outs are available upon request for large volumes (more than 30 containers or 50 gallons). Labs that are located in buildings which are not on the routine pick-up schedule must call 310-206-1887 for a pick-up.

When transporting waste to the pick-up location, inspect all containers to make sure that they are safe to transport. Verify that each container has an accurate online waste tag affixed, the containers are clean and free of residue and do not show any signs of bulging, fuming, or bubbling.  Use only a stable, heavy-duty cart with built-in secondary containment for transporting waste. Containers should be segregated on carts based on waste compatibility, by using smaller individual trays. Do not overload a cart or stack containers more than one level high. Never leave the waste unattended after departing the laboratory. Employees/lab personnel must wear long pants and closed toe shoes – basically no skin exposed below the waist) when transporting waste. An appropriate lab coat, gloves and eye protection must be carried as a spill response measure but should not be worn while transporting waste.

Disposal

Frequent disposal will ensure that your waste satellite accumulation areas (SAA) in labs are managed properly, and that maximum storage volumes are not exceeded. UCLA policy states that hazardous chemical waste can be stored in a laboratory for up to 90 days. Once a waste container is 90% full or it is near the 90-day time limit, it should be brought to the next designated pick-up. Once an experiment or process is completed, all partially filled containers should be brought to the next scheduled pick-up for that building. Basically, dispose of the chemical waste containers within 90 days or when full, whichever is sooner.

Carboys and large solvent containers can be used for waste disposal and returned for reuse.

For information about pick-ups and what we receive see: https://ehs.ucla.edu/waste/services/hazardous-waste-schedule

• Wastes that will not be accepted at a routine pick-up location include: 
  • Biohazardous Waste (see https://ehs.ucla.edu/waste/services/medical-waste)
  • Radioactive Wastes (see https://ehs.ucla.edu/waste/radiation-disposal)
  • Controlled Substances (see https://ehs.ucla.edu/controlled-substance-waste)
  • Reactive waste streams without a properly vented cap, or containers that are bulging, fuming or bubbling
  • Leaking, overflowing, or contaminated containers, or containers that are compromised
  • Bags that have protruding glass or other sharps, or bags that are ripped or punctured
  • Wastes that require special handling procedures or have shipping restrictions
  • Waste streams in incompatible containers
  • Unknowns and expired PFCs without a recharge ID

A current pick-up schedule can be found on the EH&S Hazardous Waste page:https://ehs.ucla.edu/waste/services/hazardous-waste-schedule

Hazardous Waste Minimization

UCLA is a large quantity generator of hazardous waste.  In order to meet our permit obligations and our sustainability mission, EH&S has developed a Hazardous Waste Minimization Program. The purpose of this program is to minimize the costs, health hazards, and environmental impacts associated with hazardous waste disposal.

Administrative Controls

Administrative and operational controls can be implemented to reduce the amount of chemical waste. For example, periodically reviewing chemical processes may lead to modifications that reduce the generation of hazardous waste. 

Purchasing Control: Check the ‘inventory’ of the Surplus Chemical Redistribution Program - before new products are ordered. When ordering chemicals, be aware of any properties that may preclude long term storage, and order only exact volumes to be used.  Using suppliers who can provide quick delivery of small quantities can assist with reducing surplus chemical inventory.  Consider establishing a centralized purchasing program to monitor chemical purchases and avoid duplicate orders. 

Inventory Control: Rotate chemical stock to keep chemicals from becoming outdated.  Locate surplus/unused chemicals and attempt to redistribute these to other users, or investigate returning unused chemicals to the vendor.

Operational Controls: Review your experimental protocol to ensure that chemical usage is minimized. Reduce total volumes used in experiments; employ small-scale procedures when possible.  Instead of wet chemical techniques, use instrumental methods, as these generally require smaller quantities of chemicals. Evaluate the costs and benefits of off-site analytical services.  Avoid mixing hazardous and non-hazardous waste streams.  Distill and reuse solvents if possible.  Spent solvents can also be used for initial cleaning, using fresh solvent only for final rinse.  Use less hazardous or non-hazardous substitutes when feasible. Some examples include: 

• Specialty detergents can be substituted for sulfuric acid/chromic acid cleaning solutions
• Gel Green and Gel Red are recommended in place of ethidium bromide

Drain Disposal

UCLA does not permit drain disposal of chemical wastes, unless a specific neutralization method for a consistent waste stream has been reviewed and approved by EH&S.  Only aqueous solutions within a pH range of 5.5 to 11, and which do NOT contain the following in any amount may be drain disposed: arsenic, cadmium, chromium, copper, cyanides, sulfides, lead, nickel, silver, zinc, gasoline, mercury, total identifiable chlorinated hydrocarbons, kerosene, naphtha, oil/grease, benzene, toluene, xylene, ethers, alcohols, ketones, aldehydes, peroxides, chlorates, perchlorates, bromates, carbides, hydrides, solvents, any substances that are flammable, reactive, explosive, corrosive, or radioactive, solid or viscous materials which could cause obstruction, toxic pollutants in quantities that may cause injury, noxious or malodorous substances, mineral oil products, pharmaceutical and medical wastes.   Acid and base neutralization is considered waste treatment, a process that is strictly regulated by the EPA (see “Bench Top Treatment” below).  Contact EH&S for specific questions about drain disposal or to have a neutralization protocol approved.

Drain disposal of properly disinfected infectious or bio-hazardous liquids is acceptable, if disinfection is conducted as specified by the EH&S Biosafety Program, and the liquids disposed contain no other hazardous constituents.

Bench Top Treatment

Bench top treatment is rarely necessary. Nearly all hazardous wastes can be collected at routine hazardous waste pickups. Wastes that are too hazardous to be collected by EH&S should not be handled by laboratory personnel. However, EPA regulations do allow some limited bench top treatment of certain chemical waste streams in laboratories provided that specific procedures are followed.  Due to the stringent nature of these requirements, any treatment of hazardous waste in labs must be reviewed and approved by EH&S in advance. 

Benchtop treatment requirements:

• Waste to be treated is a laboratory or radioactive hazardous waste. 
• Treatment is performed using recommended procedures and quantities for treatment of laboratory wastes published by the National Research Council (Prudent Practices in the Laboratory: Handling and Management of Chemical Hazards, Updated Version (2011) or procedures for treatment of laboratory wastes published in peer-reviewed scientific journals. 
• Treatment is performed in a container. 
• Treatment is performed as close as practical to the location where the hazardous waste was generated. 
• Individual treatment batches must be from a single procedure or set of procedures that are part of the same laboratory process.   
• Individual treatment batches do not exceed the greater of five gallons or 18 kg OR, if less than five gallons or 18 kg, the quantity limits recommended in the procedures published by National Research Council or in other peer reviewed scientific journals. 
• Treatment is performed within 10 calendar days of initial waste generation. 
• Treatment of radioactive hazardous waste is performed under a Radiation Use Authorization (RUA).
• Records of training and treatment are maintained and accessible for regulatory inspection for at least three years following the last use of a benchtop treatment procedure.

Benchtop treatment training requirements: 

Personnel performing treatment must have knowledge of the laboratory hazardous waste being treated, including knowledge of the procedure that generated the laboratory hazardous waste, and have completed in WORKSAFE: 

• LAB-CHP “Chemical Hygiene Plan” and
• LAB-LSFC-OL “Laboratory Safety Fundamentals” (or LAB-LABPI “Laboratory Safety for PIs and Lab Supervisors” and/or LAB-LABOR “Lab Safety Fundamentals Refresher” as appropriate) and 
• RAD-NRWQ “New Radiation Worker Qualification” (or RAD-MC-OR “Minimizing Contamination Refresher Training” as appropriate) if waste is radioactive, and 
• Lab-specific training to the treatment procedure being performed that includes, at a minimum, how to conduct the treatment, manage the treatment residuals, and respond effectively to emergency situations.

Benchtop treatment waste management requirements: 

• Manage treatment residues in full compliance with federal and state regulations and UCLA policies. 
• If allowed discharge nonhazardous, nonradioactive treatment residues to the sanitary sewer system in compliance with written authorization from EH&S. 
• If sanitary sewer discharge is not allowed, tag treatment residues using the WASTe system 
• Adequately characterize the residues for waste pickup using the processes outlined in this chapter of the Chemical Hygiene Plan. 
• For residues produced in the benchtop treatment of characteristically hazardous corrosive or reactive wastes, identify potential underlying hazardous constituents (UHCs) reasonably expected to be present in the treatment residues (Appendix B).

Laboratory Benchtop Treatment Process Steps 

1. Prepare a benchtop treatment procedure.   
   1. Ensure information on how all the requirements given in this document and all the information required on the template is included in the benchtop treatment procedure.
   2. Identify potential UHCs in the wastes to be treated using the information in Appendix B and include the information on the potential UHCs and their concentrations in the benchtop treatment procedure.
   3. Obtain assistance from EH&S to arrange any sampling and analysis necessary to obtain approval to dispose of the treatment residues to the sanitary sewer system.
2. Obtain an RUA for benchtop treatment of radioactive hazardous waste, if not already authorized. 
3. If benchtop treatment residues are to be disposed in the sanitary sewer system, obtain written authorization from EH&S. 
4. Complete lab-specific training on the benchtop treatment procedure for personnel who will be performing the benchtop treatment.
   1. Ensure all training records are maintained as specified in the approved benchtop treatment procedure.
5. Prepare for and perform the benchtop treatment in accordance with the approved benchtop treatment procedure and the following requirements.
   1. Perform the treatment as close as practical to the location where the laboratory hazardous waste is generated.
   2. If the treatment is being performed to address a safety issue, perform the treatment as soon as possible following generation of the hazardous waste, and prior to placing the waste into an accumulation container.
   3. For all other hazardous wastes, perform the treatment within 10 calendar days following the date the hazardous waste was first generated.
   4. Do not exceed the treatment batch limits included in the approved benchtop treatment procedure. 
   5. Complete a benchtop treatment log during or immediately upon completion of the treatment procedure for each batch of waste treated.
   6. Maintain all records produced by the treatment as outlined in the benchtop treatment procedure, and present to EH&S upon request.
   7. Maintain all documentation from the benchtop treatment and waste characterization, as necessary, to accumulate and dispose of the waste. 

Recordkeeping

The following records will be maintained by EH&S in Worksafe to support benchtop treatment of hazardous waste:

• Training records for completion of LAB-CHP “Chemical Hygiene Plan” 
• Training records for completion of LAB-LSFC-OL “Laboratory Safety Fundamentals” or LAB-LABPI “Laboratory Safety for PIs and Lab Supervisors” and/or LAB-LABOR “Lab Safety Fundamentals Refresher”
• Training records for completion of RAD-NRWQ “New Radiation Worker Qualification” and/or RAD-MC-OR “Minimizing Contamination Refresher Training”
• The RUA authorizing sanitary sewer discharge, if applicable (maintained by the Radiation Safety Officer).

The following records must be maintained by each laboratory which performs benchtop treatment of hazardous waste, and presented to EH&S upon request:

• Training records for lab-specific training to the benchtop treatment procedure
• Approved benchtop treatment procedure and completed benchtop treatment log and all associated process knowledge and analytical data used in the hazardous waste determinations for the waste to be treated and waste residues produced
• Written authorization to discharge treatment residues to the sanitary sewer if applicable

EH&S may revoke authorizations for laboratories which do not adequately maintain these records.

Mercury Thermometer Exchange Program

Cleaning up spilled mercury from a broken thermometer is the most frequent EH&S Hazardous Materials response. Mercury is a potent neurotoxin and environmental contaminant, and UCLA has a goal of having a mercury-free campus. EH&S will exchange mercury thermometers with non-mercury thermometers free of charge. Double bag the ‘intact mercury thermometer’ (using clear/transparent/see through bags that are properly tied/sealed).