Environment, Health & Safety

Construction Specification for Hazardous Materials

Section 02 8100: Transportation and Disposal

All potential waste containing hazardous materials must be listed in this section 1.1 A of the 02 8100 "Transportation and Disposal Specification". This ensures proper identification, handling, and disposal of hazardous materials generated during construction activities.

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

Identifying Waste as Hazardous

Project managers and site managers collaborate with Environmental Consulting Services to identify hazardous waste generated from projects. Proper identification is crucial for ensuring compliance with environmental regulations and safe disposal practices.

Identification Process:

Collaboration:

• Project managers and site managers work closely with Environmental Consulting Services to accurately identify all hazardous waste materials.

Testing of Sample Material:

• Sample materials may require testing to determine if they are classified as hazardous waste. Common tests include:
  • Toxic Characteristic Leaching Procedure (TCLP): Determines the potential of waste to leach hazardous substances into groundwater.
  • Wet Extraction Test (WET): Assesses the leachability of inorganic contaminants from waste materials.
  • Regulated Metals Testing: Identifies the presence and concentration of regulated metals in the waste.

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.

By adhering to these identification procedures, we ensure that all hazardous waste generated from projects is properly managed, reducing environmental impact and enhancing safety. 

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

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.

What is a TSDFs?
All hazardous waste needs to be tracked from cradle to grave. The TSDF is the final link in the waste management activities this is the final disposal or treatment facility. UCLA-approved TSDFs can be found in sections 3.3 - 3.7 based on material being disposed.

Verification

• Provide the name and EPA ID of the transporter or TSDF to EH&S for verification

Draft Shipping Documents

• 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. The manifest or e-manifest is the shipping document that travels with hazardous waste from the point of generation, through transportation, and to the final treatment, storage, and disposal facility (TSDF). 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. 
  • Contact EH&S to request the site EPA ID number for waste transportation and disposal. Our team will provide review and onsite support for manifest verification and signature. However, the responsibility for manifesting lies with the company focused on hazardous waste disposal. Draft document to be provided to EH&S prior to waste shipment.
• Review, Approval, and Manifest Signing 
  • Project managers must submit draft shipping documents to EH&S for final review and approval before coordinating with the waste transporter. Any shipping documents with discrepancies will be returned for correction. EH&S cannot sign manifests or waste profile applications until the documents are accurate.
  • Please allow up to 7 business days for the review of profiles and shipping documents, provided there are no discrepancies. Plan accordingly for university-observed holidays.

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

1. Pre-construction: submit construction specifications to EH&S for the review including section 02 8100 " Transportation and Disposal Specification" listing hazardous waste in section 1.1 A.
2. Hazardous waste identification and testing
3. Establishing a waste satellite accumulation area (SAA) on site
4. Prepare draft shipping documents for waste transport
5. Load waste for transport and manifest sign off (by EH&S). Any shipment that does not match the manifest will be rejected.

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. 
  [HSC 25123.3]

Labeling During Accumulation:

• While being accumulated on site, each generator tank or container must be labeled or clearly marked with the words, “Hazardous Waste.” [HSC 25123.3]

Used Oil Labeling:

• For used oil (as defined in HSC section 25250.1,), the container or aboveground tank must be labeled with the words “USED OIL”. Reference: [22 CCR section 66279.21(b)]. 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]

Hazardous waste can be accumulated onsite in various generator accumulation units such as containers, tanks, drip pads, or containment buildings. Below are the specific requirements for each type of unit:

Containers:

When hazardous waste is accumulated in containers, a generator must comply with 22 CCR division 4.5, chapter 15, article 9 (Use and Management of Containers). The requirements include:

• Good Condition: Containers must be maintained in good condition (22 CCR section 66265.171).
• Compatibility: Containers must be compatible with the contents (22 CCR section 66265.172).
• Closed Containers: Containers must be kept closed except when adding or removing hazardous waste (22 CCR section 66265.173).
• Rupture and Leak Management: Containers must be managed to avoid ruptures or leaks (22 CCR section 66265.173).
• Weekly Inspections: Containers must be inspected weekly (22 CCR section 66265.174).
• Proper Labeling: Containers must be properly labeled (22 CCR section 66262.34(f)).

Tanks:

When hazardous waste is accumulated in tanks, a generator must comply with 22 CCR division 4.5, chapter 15, article 10 (Tank Systems Standards), except for sections 66265.197(c) and 66265.200. The requirements include:

• Daily Inspections: Tanks must be inspected daily (22 CCR section 66265.195).
• Proper Labeling: Tanks must be properly labeled (22 CCR section 66262.34(f)).
• Design Standards: Tanks must be designed to hold hazardous waste without collapsing or leaking (22 CCR section 66265.192).

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

• Identify Hazardous Waste: Project managers and site managers collaborate with Environmental Consulting Services to identify hazardous waste generated from projects. Testing of sample material may be required such as a Toxic Characteristic Leaching Procedure (TCLP) or regulated metals testing. 
• Specifications: All potential waste containing hazardous materials and Treatment, Storage, and Disposal Facilities (TSDFs) must be included in section 02 8100 of the "Transportation and Disposal" specification,
• EPA ID and Shipping Documents: Asset Management has designated staff to review and provide onsite support for manifest verification and signature.
• Soil Importation and Exportation: For any activities involving the importation and exportation of soil, Asset Management must contact construction@ehs.ucla.edu.
• Review, Approval, and Manifest Signing: Draft shipping documents must be submitted to the Asset Management contact for final review and approval before coordinating waste transport.
• EH&S Assistance: EH&S can assist with verifying UC-approved designated waste facilities and provide guidance on hazardous waste questions. For assistance, contact us at: hazardousmaterials@ehs.ucla.edu. or construction@ehs.ucla.edu.
• Training for AM Site Contact: Annual  "Waste Manifest Online Training" is required for the Asset Management site contact and is available through WORKSAFE. 
  
  Asset Management Contact:
  Michelle Morales
  AM Director
  mmorales@re.ucla.edu 

For off-site projects, follow the construction activities service request process as described above.

The timeframe for off site services, such as manifest signing, must be coordinated to allow for EHS staff to travel to your site.

To ensure effective collaboration, please communicate with us early and allow 6-10 business days to make these arrangements, depending on the distance from campus.

contact us at: hazardousmaterials@ehs.ucla.edu. or construction@ehs.ucla.edu.

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. 

Sites that do not routinely handle hazardous waste 
A temporary EPA ID number can be requested for sites that do not planning on normally handling hazardous waste. These temporary EPA ID numbers are only valid for 90 days. In a project with construction activities identifying the waste being produced and planning for disposal determines what type of EPA ID number is requested and when it is requested. 

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

EH&S services associated with construction activities are not core services of the Hazardous Waste Program. Activities such as EPA ID generation, specification reviews and modifications, shipping document review and approval, and manifest signoff incur a cost to the project.

An FAU (Full Accounting Unit) is required for these services. 

Rates and Fees