Chapter 20


Approved by David Kestell
Revised 07/14

20.1 Policy
20.2 Scope
20.3 Applicability
20.4 Exceptions
20.5 Roles and Responsibilities
20.6 Definitions
20.7 Required Work Processes
Work Process A. General Requirements
Work Process B. Training Requirements
Work Process C. Waste Identification and Characterization
Work Process D. Generator Waste Storage
Work Process E. Generator Waste Treatment
Work Process F. Waste Disposal
20.8 Source Requirements

Appendix A. Waste Management Flow Diagrams

    1. Overview – Generator Management of Hazardous Waste
    2. Overview – Generator Management of Radioactive Waste
    3. Overview – Generator Management of Mixed Waste
    4. E-Waste Management
    5. Medical/Biohazardous Waste Management


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20.1 Policy

Lawrence Berkeley National Laboratory (LBNL) applies work controls to ensure wastes are managed in a manner that is protective of human health and the environment and complies with all applicable laws and regulations.
The Waste Management Group (WMG) establishes the programs implementing controls for LBNL wastes. All personnel at the Laboratory must comply with the waste management programs.

20.2 Scope

The LBNL waste management programs encompass:

The WMG is composed of the Waste Services Team and the Waste Operations Team. The Waste Services Team is responsible for the LBNL waste management services provided to LBNL divisions and facilities. Generator Assistants are the primary contact and resource for LBNL waste generators and other staff. These are provided by the Waste Services Team, which also performs waste certification and compliance activities. The Waste Operations Team operates the HWHF and the waste storage, treatment, and shipment activities performed there. HWHF trained technicians perform waste pickup, packaging, and transfer activities at LBNL and at off-site locations.

LBNL waste management services are provided to all facilities/programs on the LBNL campus as well as alloff-site facilities that generate waste. These include (but are not necessarily limited to) the Donner Facility at the University of California at Berkeley, which is contiguous with the LBNL site, and the following noncontiguous facilities:

The scope of the waste management programs broadly addresses all LBNL discarded materials to ensure that those identified as wastes will be managed, stored, recycled, treated, and disposed of in compliance with the applicable requirements and regulations for:

Municipal solid waste and liquid sanitary wastes are typically excluded from the scope of waste management programs.

20.3 Applicability

The waste management programs apply to all employees, affiliates, and subcontractors.

20.4 Exceptions


20.5 Roles and Responsibilities



All employees, affiliates, and subcontractors

  • Follow LBNL waste management requirements, policies, and procedures
  • Perform assigned duties involving handling of waste, as trained and within acceptable operating standards
  • Take immediate action to stop unplanned releases of wastes and report all instances of such releases to the Protective Services Department

Supervisors and work activity owners

  • Ensure LBNL waste management requirements, policies, and procedures are followed
  • Ensure their employees receive required waste management training necessary to perform their job duties in compliance with requirements
  • When planning work activities and as needed, request assistance from the Generator Assistants to ensure requirements applicable to wastes are identified and strategies for managing the wastes are developed and implemented
  • Ensure work processes do not generate wastes that pose a health or safety hazard due to ongoing chemical/physical reactions or chemical incompatibility
  • Consult with the Generator Assistant prior to generating any waste with no-path-to-disposal
  • Notify the Protective Services Department immediately of any unplanned or accidental releases of wastes

Waste generator

  • Completes all required training necessary to safely/compliantly manage specific wastes to be generated
  • Takes overall responsibility for the characterization of generated wastes. Provides initial waste stream information to the Generator Assistant
  • Arranges for the Generator Assistant’s support or assistance in waste characterization, procuring waste containers, and compliant storage and removal of waste
  • Ensures wastes are generated, handled, and stored in a compliant manner that is protective of human health, the environment, and LBNL/DOE property
  • Sets up and maintains work area waste storage and accumulation areas as needed to manage generated wastes. As necessary, seeks assistance from and coordinates these activities with Generator Assistant personnel.
  • Ensures all hazardous wastes are labeled with a HAZARDOUS WASTE label that has been completely and accurately filled out with required information
  • Generates and submits disposal requisitions for hazardous, radioactive, and mixed wastes requiring removal from the work area
  • Ensures disposal requisitions are submitted in a timely manner so waste in accumulation areas do not exceed applicable quantity and time limits

Facilities Division

  • Coordinates demolition, construction, and renovation activities, and office/laboratory space moves with the Waste Services Team Leader to identify requirements applicable to wastes, excess chemicals, and salvage materials. Develop and implement, with assistance from the Waste Services Team Leader, compliance strategies for managing these items.
  • Coordinates with the Waste Services Team Leader to implement compliant, cost-effective, and customer-friendly strategies for handling salvage materials and universal wastes (e.g., fluorescent lamps and discarded electronics)

EHS Division groups

  • Coordinate with the Waste Management Group on the inclusion of waste management requirements in EHS programs and documents (e.g., the Chemical Hygiene and Safety Plan)
  • Provide Waste Services Team Leader access to information and sampling and analysis data collected under EHS programs which are applicable to waste (e.g., from asbestos, beryllium, and lead hazards assessments; soil management activities; and radiation surveys)

Waste Generator Assistants

  • Assist waste generators in all matters regarding waste including identification, characterization, labeling, storage, packaging, and safe and compliant management in the workplace
  • Develop and provide training to waste generators and other staff including online and classroom based courses and individual training at different facilities
  • Prepare and disseminate detailed waste characterization and management guidelines for different waste types generated on-site
  • Provide online information links for generators to find information, required signs, labels, containers, secondary containment, and other supplies.
  • Provide commonly used labels and signs and when necessary, DOT approved waste containers to waste generators
  • Provide support to facilities with Waste Accumulation Areas (WAAs), including performing and documenting weekly WAA inspections
  • Periodically inspect generator Satellite Accumulation Areas (SAAs) and medical/biohazardous waste storage areas to assist waste generators with compliant accumulation and storage of waste in work areas
  • Initiate review and authorization of laboratory benchtop treatment procedures
  • Ensure generators have properly characterized requisitioned wastes by reviewing requisitions and supporting documentation (e.g., accumulation log sheets or analytical data)
  • Identify and initiate needed sampling and analysis for wastes that generators cannot sufficiently characterize. Evaluate the laboratory analytical data generated in the waste analysis.
  • Initiate quality assurance (QA) verification of hazardous, radioactive, and mixed wastes. As necessary, initiate QA Exception Reports and Nonconformance Corrective Action Reports.
  • Work with waste generators to resolve any discrepancies or issues identified during QA verification, and inspections of waste containers and waste storage and accumulation areas
  • Upon request by staff, initiate testing and removal of time-sensitive materials (such as reactive peroxide-forming compounds) from work areas
  • Work with Facilities Division to designate locations and provide containers for accumulation of universal wastes (e.g., fluorescent lamps, e-wastes, batteries, and aerosol cans)
  • Track or monitor universal waste to ensure compliance

20.6 Definitions



Acutely hazardous waste

Any wastes defined as acutely hazardous by the California Code of Regulations (CCR), Title 22, Division 4.5, Chapter 11, Article 4. These are the P-listed wastes.

Asbestos waste

Wastes that are asbestos-containing materials, including waste materials that contain friable asbestos in an amount of 1% or greater by weight, area, or count, and asbestos-contaminated materials (e.g., protective clothing and equipment). Wastes containing 1% or greater friable asbestos are California-only hazardous waste.

Benchtop treatment

State of California–authorized hazardous waste treatment activity for treating small quantities of laboratory hazardous waste produced from laboratory chemical procedures conducted for the purposes of education; research; chemical analysis; clinical testing; or product development, testing, or quality control (California Health and Safety Code, Section 25200.3.1(c )

Biohazardous waste

Waste defined in the California Medical Waste Management Act (California Health and Safety Code, Section 117600 – 118360). Examples of bio-hazardous waste include fluid blood or fluid blood products from animals known to be infected with diseases that are highly communicable to humans; waste containing discarded materials contaminated with infectious secretions; microbiology and surgery specimens; cultures or stock wastes from medical, pathology, research, and industrial laboratories; and animal parts or animal fluids contaminated with infectious agents known to be contagious to humans.

California-only hazardous waste

See Non-RCRA hazardous waste

Combined waste

Radioactive waste that also contains California-only hazardous waste

Discarded material

Material that has been relinquished, recycled, or is inherently waste-like


  • Any unwanted electronic device or cathode ray tube (CRT). Classified as universal waste (if not reused), e waste frequently contains hazardous materials, predominantly lead and mercury.
  • A type of universal waste, including electronic devices such as telephones, cash registers, computers, computer peripherals, stereo equipment, videocassette players/recorders, tape players and recorders, compact disc players, calculators, microwave ovens, etc. In general, if a nonfunctioning item has a printed circuit board or a CRT, it is e-waste. Examples of CRTs are computer monitors, oscilloscopes, and televisions.

Extremely hazardous waste

Any hazardous waste or mixture of hazardous wastes whose exposure to humans could likely result in death, a disabling personal injury, or a serious illness because of its quantity, concentration, or chemical characteristics (CCR Title 22, Section 66260.10)

Hazardous material

Any substance or material that could adversely affect the safety of the public, handlers, or carriers during transportation. All Department of Transportation (DOT) hazardous materials are listed in the DOT's Hazardous Material Table.

Hazardous waste

Solid wastes designated hazardous by California regulations. (CCR Title 22, Section 66261.3). For the purposes of this definition, a solid can be a solid, semisolid, liquid, or contained gas. Hazardous waste includes acutely hazardous waste, extremely hazardous waste, California-only hazardous waste, RCRA hazardous waste, special waste, and universal waste.

Medical waste

Waste defined in the California Medical Waste Management Act (CCR 22, Section  117690 – 118360)

Mixed waste

Waste that meets the definition of a radioactive waste and the definition of an RCRA hazardous waste

Mixed transuranic waste

Waste that meets the definition of a transuranic waste and the definition of a RCRA hazardous waste

Mixed Waste Satellite Accumulation Area (MWSAA)

SAA used for the storage of mixed and mixed transuranic waste

Nanomaterial-bearing waste

A waste material that has come into contact with dispersible engineered nanomaterials (and that has not been decontaminated)

Non-RCRA hazardous waste

A waste that does not meet the federal criteria for a hazardous waste, but which meets California specific state regulatory criteria for a hazardous waste. These include waste defined as a corrosive solid in CCR Title 22, Section 66261.22(a)(3) or 66261.22(a)(4); waste defined as toxic for anything except for federal toxicity as defined in CCR Title 22, Section 66261.24(a)(1); waste excluded under federal regulation, but exhibiting any characteristics of a hazardous waste defined in CCR Title 22, Chapter 11, Article 3 (ignitable, corrosive, reactive or toxic); mercury-containing wastes as defined in CCR Title 22, Chapter 11, Article 4.1; and containers that are “RCRA empty” but not empty by California regulation.

No-path-to-disposal waste (NPDW)

Any waste for which no treatment and/or disposal facility currently exists

Polychlorinated biphenyl (PCB) Waste

Any waste containing PCBs in a concentration meeting or exceeding applicable 40 Code of Federal Regulations (CFR) 761 or CCR Title 22, Section 66261.24 criteria.

Peroxide-forming compounds

Materials that react with oxygen to form peroxides that can explode with impact, heat, or friction. See “Control Procedures for Peroxide-Forming Compounds” in the Chemical Hygiene and Safety Plan.

Process knowledge (also referred to as acceptable knowledge)

  • That body of information used in addition to or in place of sampling and analysis to determine whether a waste is hazardous (or biohazardous, asbestos wastes, etc.) and to classify it in order to meet treatment, storage, and disposal requirements.
  • Process knowledge must be adequate to ensure the characterization is sufficient to withstand scientific and legal challenges relative to management of the waste. Types of process knowledge information include, but are not limited to:
  • Chemical/material composition specifications. Chemical specifications from purchase specifications of the chemical in question, product information provided by the manufacturer, label information, or standard chemical reference materials. For metals, plastics, and other materials manufactured to certain grades or alloy specifications where the material contents and characteristics are well known (for example, Type 304 stainless steel), standard material composition reference tables may supply the required information.
  • Material safety data sheets (MSDSs). MSDSs provide chemical specifications and related information. An MSDS may not always be an appropriate reference for determining whether a material is a hazardous waste. Manufacturers are not required to identify constituents at concentrations below 0.1% (1,000 ppm). Therefore, a waste may contain RCRA toxicity characteristic constituents or underlying hazardous constituents above regulatory levels without being identified on the MSDS.
  • Process description. Pertinent details of the process generating the waste and the chemicals used must be described. This information is critical for determining whether the waste is a listed hazardous waste. Depending upon the complexity of the process, this information could range from a simple sentence to very detailed process flow diagram.
  • Process reference materials. These could include laboratory logbooks, strip charts, correspondence, chemical analyses, and reports.
  • Analytical results. Analytical results from a non-required method for waste characterization (e.g., SW-846 prescribed methods) or from a noncertified laboratory, but having adequate procedures and records available for review by the Generator Assistant.

Radioactive sealed source

Radioactive material that is permanently bonded or fixed in a capsule or matrix designed to prevent release and dispersal of the radioactive material under most accidental conditions, normal use and wear for which it was designed.

Radioactive waste

Any garbage, refuse, sludge, and other discarded material, including solid, liquid, semisolid, or contained gaseous material that must be managed for its radioactive content

Resource Conservation and Recovery Act (RCRA) hazardous waste

  • Waste that meets the federal criteria for listed wastes (F,K,P,U lists), ignitable wastes, corrosive wastes, reactive wastes, or toxic wastes. Waste that has not been delisted or excluded under federal regulation.
  • All hazardous wastes are presumed to be RCRA hazardous waste unless or until the generator determines that the wastes are non-RCRA hazardous waste in accordance with CCR Title 22, Section 66261.101

Satellite Accumulation Area (SAA)

An area where, following initial generation, 55 gallons of each compatible hazardous waste stream or 1 quart of each compatible acutely or extremely hazardous waste are accumulated in compliance with CCR Title 22, Section 66262.34


Devices having acute rigid corners, edges, or projections capable of piercing or cutting the skin. These include sharps regulated as medical waste, sharps with non-medical waste contamination and un-regulated, un-contaminated sharps that pose a safety hazard. Examples include drill bits capable of piercing or cutting the skin (thin bits like hypodermic needles), needles, razor blades, scalpel blades, syringes with needles, small shards of plastic, and glass.

Transuranic waste

Waste containing 100 nCi/g or more alpha-emitting transuranic isotopes (atomic number >92) with half-lives greater than 20 years. Excepted from this definition are: (1) high-level radioactive waste; (2) waste that the Secretary of Energy has determined, with the concurrence of the Administrator of the Environmental Protection Agency, does not need the degree of isolation required by the 40 CFR 191 disposal regulations; or (3) waste that the Nuclear Regulatory Commission has approved for disposal on a case-by-case basis in accordance with 10 CFR 61.

Treated wood waste (TWW)

Wood treated with a chemical preservative for protection against pests and environmental conditionals. Treated wood may be regulated as a hazardous waste in California.

Universal waste

Hazardous wastes that are exempted from the traditional hazardous waste management requirements, provided generators follow regulatory-defined management requirements for ensuring safe handling, recycling, and disposal. Universal wastes are defined in CCR Title 22, Section 66261.9, and include batteries, cathode ray tubes (CRTs), CRT glass, electronic devices, aerosol containers, and mercury-containing devices (thermometers, thermostats, relay switches).  

Used oil

Oil refined from crude oil, or synthetic oil, that has been used, and, as a result of use, extended storage, or spillage is contaminated with physical or chemical impurities.

Waste Accumulation Area (WAA)

A regulated storage area designed for the accumulation of hazardous wastes for up to 90 days in quantities that can exceed the quantities allowed for storage in an SAA

Waste characterization

The identification of waste components and properties through a review of process knowledge or by nondestructive examination, nondestructive assay, or sampling and analysis, as necessary to comply with applicable storage, treatment, handling, transportation, and disposal requirements.

Waste generator

Any person, by site, whose act or process produces reusable property, recyclable material or waste, or whose act first causes a hazardous waste to become subject to regulation. It is the individual responsible for the process that generates the waste, typically the principle investigator, project manager, or qualified designee. The generator brings a waste stream to the attention of the Generator Assistant and provides waste process knowledge information to that person. Generally, the Waste Management Group then assumes many of the responsibilities of the generator as defined in RCRA and state of California regulations. Where subcontractors are performing work at LBNL, the facility or project manager who requested the work assumes responsibilities of the generator, and assumes ownership of all waste generated by the subcontractor as a result of that work.

20.7 Required Work Processes

The WMG has developed work processes for personnel to use to compliantly manage wastes and other discarded materials. The Waste Services Group has assigned waste services specialists called Generator Assistants to each LBNL division or facility. The Generator Assistants are available to advise and assist personnel in meeting all of the requirements of the waste management work processes. Click here to see who your Generator Assistant is. Additionally detailed Generator Guidelines have been prepared to assist generators. Click here to find the Generator Guidelines and other waste management resources.

Work Process A. General Requirements

To ensure compliance with applicable regulations, DOE orders, and LBNL policies, personnel must follow these requirements to identify, characterize, store, treat, and dispose of waste.

  1. Identify work scope and determine if waste will be generated.
  2. Waste Identification and Characterization. The owners of work activities, facility operations, or experimental procedures must identify the types of wastes they are or will be generating.
    1. Identify discarded materials or wastes generated by your work activities.
      1. Materials not discarded may also be waste.
        1. If the material is mislabeled or inadequately labeled, it is considered waste unless the label is corrected within 10 days.
        2. If a container is deteriorated or damaged, it is considered a waste unless the container is repackaged within 96 hours.
    2. Evaluate identified discarded materials and waste from your work processes, using Work Process C, Waste Identification and Characterization.
    3. Ensure that the evaluation is adequate to
      1. Determine how you must contain, label and store your waste in the work area
      2. Determine whether the discarded materials or wastes are hazardous wastes.
      3. Identify and plan implementation of waste minimization and prevention strategies.
    4. An unlabeled and unidentifiable discarded material it is considered an “unknown.”
      1. Management and disposal of unknowns is expensive and can pose safety risks. Avoid the potential for unknowns by
        1. Maintaining inventory control of the products and chemicals used in the work area.
        2. Ensuring all containers of products and chemicals are labeled with information on the contents.
        3. Frequently doing physical inspections of the product and chemical containers to ensure they are legibly labeled.
      2. If you find an container of unknown material you suspect is hazardous,
        1. Contact your safety representative if the container cannot be safely handled.
        2. If it is safe to do so, mark the container with
          1. the date of discovery
          2. the words “Unknown Waste - pending characterization”
          3. any known compositional or hazards characteristics (e.g. “liquid” or “oily solid with solvent odor”)
        3. Contact your Generator Assistant
          1. As directed by the Generator Assistant put the labeled container in a designated Waste Accumulation Area.
          2. Provide the Generator Assistant as much assistance as possible in determining the generator and identity of the unknown waste.
        4. The Generator Assistant will initiate any required sampling and analysis of the waste and ensure proper management of the waste upon completion of the waste characterization and hazardous waste determination.
  3. Waste Training. Waste generators and other staff must complete specified training for their anticipated wastes to ensure safe and compliant management of those wastes.
    1. See Work Process B, Training Requirements.
    2. The Waste Services Team develops and provides training to waste generators and other staff. These include online and classroom-based courses, as well as individual training.
    3. Additional training may be required by divisions.
    4. On-the-job, procedure-specific training is required for performing laboratory benchtop treatment of hazardous waste.
  4. Waste Storage. Waste generators are responsible for setting up and maintaining necessary waste storage or accumulation areas.
    1. See Work Process D, Generator Waste Storage.
    2. The Generator Assistants will, as needed, help waste generators in identifying, setting up, and maintaining waste storage areas.
  5. Waste Inspections. All waste storage areas should be periodically inspected for housekeeping, safety, and compliance. For some types of waste, environmental or health and safety regulations define waste and storage area inspection frequencies and criteria.
    1. The WMG performs waste container and storage area inspections that are specified in state and federal regulations.
    2. Waste generators and line management are encouraged (and sometimes required by individual divisions) to perform inspections of SAAs and MWSAAs for compliance with LBNL requirements.
      1. Document inspections as required by the division.
    3. Generator Assistants perform periodic medical/biohazardous waste area and SAA/MWSAA inspections for quality assurance purposes.
  6. Waste Transportation. Some types of waste, including radioactive, hazardous, biohazardous, and medical wastes, may be classified as hazardous materials for the purposes of transportation by the DOT.
    1. For transportation of DOT hazardous materials other than waste, see the Transporting and Shipping Hazardous Materials policy in the Requirements and Policy Manual (RPM).
    2. DOT-regulated wastes will be packaged in compliance with DOT requirements.
      1. For DOT-regulated wastes to be placed in shipping containers by the waste generator, use containers obtained and filled per Generator Assistant instructions to ensure DOT compliance.
    3. Wastes will be transported from waste generator storage areas only by Waste Operations Team personnel or WMG-contracted or approved vendor personnel.
    4. Where WMG shipments deviate from any applicable DOT requirements, the WMG will generate an approved Transportation Safety Document as required by DOE and/or obtain a Special Permit from DOT to specifically authorize the deviation.
      1. In addition to transporting waste, the WMG assists Transportation Services and LBNL personnel by transporting previously opened containers of other hazardous materials between non-adjacent buildings on the LBNL campus and between the UC Berkeley Donner facility and the buildings on the LBNL campus.
      2. Contact your Generator Assistant for more information.
  7. Waste Treatment
    1. Laboratory hazardous wastes may be treated near the point of generation, using a benchtop treatment procedure to safely and most efficiently manage some wastes.
    2. See Work Process E, Generator Waste Treatment, for information on how to perform benchtop treatments, including those required to treat certain nitric acid waste posing a safety hazard when stored in SAAs.
  8. Waste Disposal. Removal of most wastes from generator areas is initiated by the waste generators using waste requisitions.
    1. See Work Process F, Waste Disposal.
  9. See Appendix A for flow diagrams illustrating generator management of the following wastes:
    1. Hazardous waste
    2. Radioactive waste
    3. Mixed waste
    4. E-waste
    5. Medical/biohazardous waste


Work Process B. Training Requirements


Specified Training

Generators of hazardous waste

EHS-604, Hazardous Waste Generator Training

Generators of radioactive and/or mixed wastes

EHS-622, Radioactive and Mixed Waste Generator Training

Waste Accumulation Area managers

EHS-610, Waste Accumulation Area Supervisor's Training

Personnel who handle universal waste

EHS-611, Universal Waste Regulatory Training

Generators of medical/biohazardous waste at LBNL

EHS-730, Medical and Biohazardous Waste Training

Personnel who perform benchtop treatment of laboratory hazardous waste

EHS-348, Chemical Hygiene and Safety Training and EHS-353 refresher as needed; EHS-604, Hazardous Waste Generator Training; and benchtop treatment procedure-specific training on how to conduct the treatment, manage treatment residuals, and respond effectively to emergency situations

Personnel who either handle or who may be exposed to particularly hazardous substances

EHS-348, Chemical Hygiene and Safety Training and EHS-353 refresher as needed, or EHS-345 for Facilities personnel

Personnel managing asbestos (including asbestos waste)

See Chapter 36 of the ES&H Manual

Personnel managing lead- or beryllium-metal-contaminated materials (including wastes, e.g., PPE)

See Chapter 37 and Chapter 38 of the ES&H Manual

Personnel managing radioactive materials (including wastes)

See Chapter 21 of the ES&H Manual

Work Process C. Waste Identification and Characterization

  1. During work planning activities identify materials that will be discarded and wastes that will be generated.
    1. Identify and plan implementation of waste minimization and prevention strategies.
    2. Identify how you must contain, label and store your waste in the work area.
  2. Discarded materials that are reused, salvaged for reuse, or recycled (including e-waste) are generally managed through the Facilities Division in coordination with the Waste Services Team.
    1. Contact your Generator Assistant or review the salvage guidelines found on the Facilities Division Property Reuse Web page.
    2. Review the E-Waste Management flow diagram in Appendix A.4.
  3.  Characterize waste based on process knowledge.
    1. If the process knowledge is not adequate to completely characterize a waste (or if a waste generator cannot be identified), the waste must be sampled for laboratory analysis.
      1. Contact your Generator Assistant to initiate this process.
      2. The WMG identifies the sampling and analysis requirements for characterizing a waste or a waste stream, performs the required sampling and sample shipments, and evaluates/validates the analytical results produced.
      3. The division generating a waste is responsible for any costs associated with sampling and analysis to characterize the waste.
  4. If the waste is from an area where radioactive contamination or activation may occur, certify the waste as "nonradioactive" OR manage it as a radioactive waste.
    1. Certification is done in accordance with applicable WMG and Radiation Protection Group procedures. See more information here.
  5. Use the links and information below for characterizing (and managing) different types of wastes.
  6. Asbestos waste (See also Chapter 36 of the ES&H Manual)
  7. Empty containers
  8. Epoxy waste materials
  9. Gas cylinders are typically returned to the supplier. For gas cylinders that cannot be returned, contact your Generator Assistant for assistance.
  10. Hazardous waste
    1. Typical hazardous wastes include:
      1. Corrosive waste
      2. Ignitable waste
      3. Reactive waste
      4. Toxic waste
      5. Listed waste
    2. Ensure characterization of hazardous waste includes all required information to requisition a waste for disposal.
    3. Characterization of hazardous waste may also need to include identification of underlying hazardous constituents.
      1. These are waste constituents other than those causing the waste to be hazardous, but by regulation also require treatment.
  11. Medical/biohazardous wastes
    1. Sharps waste is managed under the medical/biohazardous waste program.
  12. Nanomaterial-bearing wastes are typically managed as a hazardous waste.
  13. Over-the-counter drugs, pharmaceuticals and controlled substances:
    1. Contact your Generator Assistant if you have over-the-counter drugs or pharmaceuticals you no longer need.
    2. Contact the Industrial Hygiene organization for requirements applicable to disposal of controlled substances.
  14. PCB waste (See also Chapter 63 of the ES&H Manual)
    1. If you have or suspect you have a PCB waste, contact your Generator Assistant.
    2. Waste oils and all liquids suspected of containing PCBs must be sampled and analyzed to determine the PCB concentrations.
      1. Contact your Generator Assistant to initiate the sampling and analysis.
  15. Peroxide-forming compounds
    1. Peroxide-forming compounds that have been stored either beyond useful shelf life or for which age and history cannot be determined are considered unsafe and must be characterized and managed as a hazardous waste.
      1.  Click here for more information on peroxide-forming compounds.
      2. Contact the Industrial Hygiene Group for assistance with testing these materials and your Generator Assistant for help dispositioning the tested materials.
  16. Radioactive wastes
    1. Prior to generating a nondefense-related transuranic waste or a no-path-to-disposal waste, obtain authorization from the Waste Services Team.
      1. Contact your Generator Assistant to initiate the process.
    2. Identify and characterize other components of radioactive wastes such as medical/biohazardous, PCB, asbestos, sharps, or hazardous waste components.
    3. Links for characterization of typically generated radioactive wastes:
      1. Radioactive dry waste
      2. Radioactive liquid waste
      3. Scintillation vials
      4. Radioactive lead waste
      5. High-efficiency particulate air (HEPA) Filters
      6. Radioactive animal tissue
      7. Radioactive empty containers
      8. Combined wastes — These are radioactive California-only hazardous wastes.
      9. Mixed wastes, including transuranic mixed wastes
      10. Radioactive sealed sources — If a radioactive sealed source that is no longer needed cannot be transferred to a new owner or returned to the vendor, it is a waste.
        1. Characterize the sealed source for disposal as a radioactive or mixed waste (EWRP02 Technical Note: Sealed Source Classification and Disposal).
  17. Treated wood wastes
  18. Universal wastes are:
    1. Aerosol cans (with exceptions)
    2. Batteries (with exceptions)
    3. Fluorescent lamps
    4. Mercury-containing equipment
    5. E-waste — Find more information on e-wastes in the Generator Guidelines, and see the E-Waste Management flow diagram in Appendix A.4 of this program.
  19. Used (waste) oils. Used oil is a California-only hazardous waste.
    1. Examples of used oils are crankcase, transmission, hydraulic, turbine, transformer, and compressor oils.
    2. Examples of what are not used oils include antifreeze, solvents, brake fluid, fuels, grease, and cooking oils.
    3. Oil containing 5 parts per million (ppm) or more PCBs or more than 1,000 ppm total halogens are not used oils. These are, however, also hazardous wastes.
    4. Never mix your used oil with any other waste.
    5. Contact your Generator Assistant for more information on classification of used oil and oil filters.
  20. Contact your Generator Assistant as needed to complete characterization of your waste.

Work Process D. Generator Waste Storage

  1. When wastes are first generated, they are accumulated or stored at or near where they were generated and are the under control of the waste generator or other designated personnel.
  2. Perform waste-generating processes and waste-handling activities in accordance with applicable health and safety requirements.
    1. Contact the Industrial Hygiene Group if your waste-generating activities involve asbestos or finely divided or powdered toxic metals (e.g., lead, beryllium, cadmium).
      1. For health and safety purposes, additional labeling and, in some cases, packaging requirements apply to waste containing asbestos, loose lead, beryllium, or cadmium contamination.
    2. Contact Radiation Protection Group personnel if your waste generating activities involve radioactive materials.
    3. Consult the Chemical Hygiene and Safety Plan and the Laboratory safety coordinator to determine safety requirements applicable to your laboratory activities.
  3. Medical/Biohazardous Waste Storage. Store as outlined in the Medical and Biohazardous Waste Generator’s Guide (part of the Biosafety Manual).
  4. Hazardous and Mixed-Waste Storage. Store hazardous waste in closed containers in one of the following: 
    1. SAA
    2. WAA — see WAA Guidelines.
    3. Store mixed waste in an MWSAA.
    4. Place hazardous/mixed waste in an SAA, WAA, or MWSAA container with a properly completed “HAZARDOUS WASTE” label as soon as possible following generation. Mixed waste also require a radioactive material tag.     
    5. Use only SAA, WAA, or MWSAA containers and secondary containment that are in good condition and made of materials compatible with the stored waste.
      1. Container compatibility information can be found at and in the Chemical Hygiene and Safety Plan.
    6. Segregate and separate incompatible waste according to its hazard category.
      1. Chemical compatibility information can be found at and in the Chemical Hygiene and Safety Plan.
    7. Store all glass hazardous waste containers and all liquid hazardous waste in secondary containment.
    8. Do not store any hazardous/mixed waste that poses a safety hazard in an SAA, WAA, or MWSAA.
      1. Ensure the wastes are accumulated in compliance with applicable National Fire Protection Association (NFPA), Cal OSHA regulations, and LBNL health and safety requirements.
      2. Contact the Division Safety Coordinator with questions regarding safety issues.
    9. Ensure containers of hazardous waste are securely closed except when adding or removing waste.
    10. Ensure hazardous-waste accumulation quantity limits are not exceeded.
      1. Do not exceed the maximum storage quantities allowed in an SAA or MWSAA. These are 55 gallons of each compatible hazardous-waste stream or 1 quart of each compatible acutely or extremely hazardous waste.
      2. Store larger quantities of hazardous waste in WAAs.
    11. Store hazardous wastes within applicable time limits.
      1. LBNL policy dictates that hazardous and mixed wastes stored in SAAs or MWSAAs on the LBNL campus must be requisitioned for pickup within 275 days of initial generation, and
      2. Hazardous waste stored in WAAs on the LBNL campus must be requisitioned for pickup within 60 days of generation.
  5. Universal Waste Storage
    1. Store each type of universal waste (e.g., batteries, aerosol cans, etc.) separately.
    2. Complete and attach a universal waste label to each container of universal waste.
    3. Keep universal waste containers closed except when adding or removing wastes.
    4. Do not store universal waste in the work area for more than one year from the date of generation.
  6. Radioactive Waste Storage
    1. Attach (or post nearby) a radioactive material tag, properly filled out, on each container of radioactive or combined waste once the first item is placed inside the container. 
      1. Contact your Generator Assistant for radioactive material tags.
    2. Keep containers of radioactive waste securely closed when not in use.
    3. Contact the Radiation Protection Group regarding other requirements applicable to radioactive material storage.
    4. Do not store radioactive and combined waste in the work area for more than one year after initial generation.
  7. PCB Waste Storage
    1. Label and store PCB wastes as hazardous waste in an SAA or WAA.
    2. Do not store PCB wastes (>50 ppm) for more than 30 days in the work area.
    3. Mark PCB waste (>50 ppm) containers and the entrances to the buildings where they are stored with a PCB mark.
  8. Asbestos Waste Storage
    1. Label and store friable asbestos wastes as a hazardous waste in an SAA or WAA.
    2. Additional packaging and labeling requirements for asbestos wastes are given in Chapter 36 of the ES&H Manual.
  9. Used Oil Waste Storage.Label and store used oil as a hazardous waste in an SAA or WAA.
  10. Contact your Generator Assistant for guidance on storage of other wastes.

Work Process E. Generator Waste Treatment

  1. Waste of any kind cannot be treated without first consulting your Generator Assistant. Even if allowable by law, changes in a waste’s physical or chemical characteristics or composition may make the waste more expensive or difficult to dispose of, or create an unacceptable environmental, health, or safety hazard.
  2. California regulations allow hazardous-waste treatment without a permit under limited scenarios and only in accordance with stringent regulations.
    1. Laboratory benchtop treatment is one such allowable treatment that can be utilized within laboratory facilities.
  3. It is LBNL policy that benchtop treatment be used to treat any laboratory experimental-reaction waste mixture or waste aqueous solution that contains nitric acid (HNO3) if the following conditions occur:
    1. The nitric acid solution is >5% by weight (0.8 M or pH<1).
    2. Organic constituents are present and the solution contains nitric acid at any concentration.
  4. Consider using a laboratory benchtop treatment in cases where it will:
    1. Reduce the hazards and facilitate handling of a hazardous or mixed waste
    2. Reduce the costs of treatment and disposal of a hazardous or mixed waste
    3. Eliminate generation of a hazardous or mixed waste with no-path-to-disposal
  5. Plan, obtain authorization, and perform laboratory benchtop treatments of hazardous waste as outlined on the Waste Management Group home page.
    1. Perform benchtop treatment within 10 calendars days following the day the hazardous waste was initially generated.
    2. Treat wastes (using an approved benchtop treatment procedure) posing a safety hazard when placed in an SAA untreated as soon as possible following generation and before transfer to a SAA container.

Work Process F. Waste Disposal

  1. Removal of most wastes from generator’s work locations is initiated by the generator (or designee) and coordinated through the Waste Management Group.
    1. Sink disposal of hazardous materials is strictly prohibited unless specifically authorized.
    2. Medical/Biohazardous Waste Disposal. Follow the instructions in the Medical and Biohazardous Waste Generator’s Guide (part of the Biosafety Manual).
    3. Hazardous Waste Disposal. Use the Electronic Hazardous Waste Requisition System to initiate waste disposal.
      1. You must have completed EHS-604 Hazardous Waste Generator Training to submit a completed hazardous waste requisition. .
    4. Radioactive and Mixed Waste Disposal. Use the Radioactive/Mixed Waste Disposal Requisition form.
    5. Use the Generator Guidelines or contact your Generator Assistant for information necessary to disposal of other wastes (e.g., universal waste).
  2. The WMG encourages personnel to periodically remove unwanted chemicals from the work area.
    1. Peroxide-forming compounds that have been stored either beyond useful shelf life, or for which age and history cannot be determined, are considered unsafe.
      1. If found, have these tested and then requisition as a hazardous waste for pickup. Contact your Generator Assistant for help.
    2. Personnel leaving LBNL must determine the fate of any remaining work chemicals they used (see the LBNL Space Management Policy).
      1. Abandoned chemicals present compliance and safety liabilities.
      2. Characterization of abandoned chemicals or unknowns may incur significant costs to the division.
      3. Be aware of any specific rules and requirements the division has regarding disposal of unwanted chemicals before you leave LBNL.
    3. General procedure to remove unwanted chemicals:
      1. Determine whether any other researcher in the area wants the chemicals. If so, transfer custody to them and update the Chemical Management System.
      2. If the chemicals are to be disposed of, use the Chemical Management System link to the electronic hazardous waste requisition system to initiate the waste disposal process.
      3. Contact Waste Services Generator Assistants for additional guidance.
  3. When buildings or areas within a building are to be decommissioned or demolished, all building materials must be assessed and managed appropriately.
    1. Supplies, products, apparatuses and equipment, trash, hazardous and other regulated wastes, and waste containers must be removed prior to vacating the space. This includes:
      1. All chemicals and chemical-related products such as cleaning compounds, surplus chemicals, stock solutions, and experimental products
      2. Waste and waste containers including hazardous waste SAA containers, universal waste containers, and containers for sharps, medical wastes, etc.
      3. Radioactive equipment, sealed sources, radioactive waste, mixed-wastes and radioactive waste containers, etc.
    2. For transportation of materials other than waste, contact Transportation Services.
      1. For transportation of DOT hazardous materials other than waste, see the LBNLTransporting and Shipping Hazardous Materials policy.
    3. For building construction, renovation, and demolitions, control and management of hazardous materials and wastes must be addressed in the demolition scope of work.  
      1. Contact the Waste Services Team Leader for assistance.
  4. Manage cleanup materials from a spill or decontamination (e.g., wipes, absorbent pigs, etc.) as a hazardous waste.

20.8 Source Requirements

Other Driving Requirements

Appendix A. Waste Management Flow Diagrams

    1. Overview – Generator Management of Hazardous Waste
    2. Overview – Generator Management of Radioactive Waste
    3. Overview – Generator Management of Mixed Waste
    4. E-Waste Management
    5. Medical/Biohazardous Waste Management


A.1. Overview – Generator Management of Hazardous Waste






A.2. Overview – Generator Management of Radioactive Waste






A.3. Overview – Generator Management of Mixed Waste









A.4. E-Waste Management






A.5. Medical/Biohazardous Waste Management




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