During the pre-construction phase all potential waste containing hazardous materials and its disposal must be identified. This ensures proper identification, handling, and disposal of hazardous materials generated during construction activities. 

Check to see you have a pre-construction document such as Construction Specification for Hazardous Materials section 1.1 A of the 02 8100: "Transportation Disposal Specifications" completed.

For assistance with identification of hazardous material, contact us at: hazardousmaterials@ehs.ucla.edu.

Project and site managers must work with environmental consulting firms (e.g., Global, Citadel) to identify hazardous waste through: 

• Environmental Regulated Materials (ERM) surveys
• Comprehensive hazardous materials surveys
• Sample Material Testing: Testing may be required to determine if materials meet hazardous waste criteria, particularly for Characteristics of Toxicity.
  Common tests include:
  • TCLP (Toxic Characteristic Leaching Procedure)
  • WET (Wet Extraction Test)
  • Regulated Metals Testing

General Labeling Requirements:

• Accumulation Start Date: the start date of each accumulation period must be clearly marked and visible for inspection on each accumulation container.
• Labeling During Accumulation: during accumulated on site, each generator tank or container must be labeled or clearly marked with the words, “Hazardous Waste". 
• Used Oil Labeling: used oil (as defined in HSC section 25250.1,), the container or aboveground tank must be labeled with the words “USED OIL”. See also DTSC’s Used Oil Generator Requirements webpage.

Specific Labeling Requirements for Hazardous Waste Containers and Tanks:

• Each container and portable tank in which hazardous waste is accumulated must be labeled with the following information:
  • Composition and Physical State of the waste.
  • Hazard Properties: Statements that call attention to the particular hazardous properties of the waste (e.g., flammable, reactive)
  • Generator Information:
  • Name and address of the generator.

Reference: [HSC 25123.3]

TSDF: Prior to the transport of hazardous waste, it is essential to verify the Treatment, Storage, and Disposal Facilities (TSDFs) and the transporters. It is critical to only use those TSDFs that will accept the specific waste stream.

Waste Profile Worksheet: This document lists all the characteristics of the waste so that TSDFs (Treatment, Storage, and Disposal Facilities) have the information they need to receive the waste

Uniform Hazardous Waste Manifest

• Hazardous waste is tracked from the point of generation (your site) to its final destination by using manifests.
• Each party in the chain of shipping, including the generator, signs and retains one of the copies, creating a “cradle-to-grave” tracking of the hazardous waste. ID numbers are needed by all parties on the manifest.

Hazardous waste may be stored onsite in containers, tanks, drip pads, or containment buildings. 

Below are key requirements for containers and tanks: 

Containers:

Comply with 22 CCR division 4.5, chapter 15, article 9 (Use and Management of Containers). Key requirements include:

• Good Condition: must be maintained in good condition.
• Compatibility: must be compatible with the contents.
• Closed Containers: must be kept closed except when adding or removing hazardous waste.
• Rupture and Leak Management: must be managed to prevent ruptures or leaks.
• Weekly Inspections: must be inspected weekly by site.
• Proper Labeling: must be labeled correctly.

Tanks:

Comply with  22 CCR division 4.5, chapter 15, article 10 (Tank Systems Standards), except for sections 66265.197(c) and 66265.200. 

Requirements include:

• Daily Inspections: must be inspected daily.
• Proper Labeling: must be properly labeled.
• Design Standards: must be designed to hold hazardous waste without collapsing or leaking.

For a more detailed explanation on accumulation requirements, read DTSC’s “Accumulating Hazardous Wastes at Generator Sites” webpage.

What is an EPA ID Number?

An EPA ID number is issued by U.S. Environmental Protection Agency (EPA) or Department of Toxic Substance Control (DTSC) for business that generate or handle hazardous waste It's purpose is to track waste from origin to final disposal referred to as "cradle to grave". 

UCLA holds several EPA ID numbers for sites that routinely handle hazardous waste. 

For locations that do not routinely handle hazardous waste 

Sites that do not routinely handle hazardous waste may request a temporary EPA ID number, valid for 90 days. For construction projects, the type and timing of the EPA ID request depends on the waste generated and disposal plans.

Only EH&S has the authority to execute permits on behalf of UCLA

• UCLA DA 750.01 Negotiation and Execution of Environment, Health and Safety Permits and Licenses

Compliance and Standards:

All hazardous waste identification and handling processes comply with federal and state regulations and standards

• EPA "Defining Hazardous Waste: Listed Characteristic and Mixed Radiological Waste  Listed Waste 40 of the Code of Federal Regulations (CFR) in part 261.
• California Waste Codes and Descriptions

For a detailed explanation of how hazardous waste is defined and managed, visit the DTSC - Defining Hazardous Waste webpage.

For assistance, contact us at: hazardousmaterials@ehs.ucla.edu.