OEH&S Chemical Waste

All hazardous chemical waste are identified, classified, and transported in a manner to ensure compliance with Federal, State and local regulations. It is recognized that some waste materials present classifications problems and inconsistencies during this process. In order to avoid these inconsistencies and ensure compliance, the laboratories must follow OEH&S waste classification procedures to characterize the waste for vendor transportation and disposal.

UCSF departments requesting such services submit a Project Request/Approval form. The Request for Services form defines the scope of work and initiates the start of OEH&S involvement. OEH&S involvement starts upon receipt of a completed Request for Services form that contains, specifically, the department’s account and fund numbers, department expense authorization signature, and a floor plan. A cost estimate is provided by OEH&S for the requested project.

OEH&S classifies waste as follows:

1. DOT Classification

1. All waste material is classed as to the transportation hazard they pose. All classifications are in strict compliance with either the hazardous material table (HMT - 49 CFR) or in accordance with the definitions of DOT hazard classes found in 49 CFR Part 173.
   
2. OEH&S ensures that the material being classified is chemically and physically consistent with any labeling or marking present on the outer container. Material not consistent with labeling shall be subject to review before it can be accepted for OEH&S pick-up.

3. Classification follows the following hierarchy:

1. By proper chemical name
2. By family name
3. By hazard class definition
4. By end use.

4. If the material is not listed by name or chemical family in the Hazardous Material Table, OEH&S determines if the material meets the definition of any hazard class found in 49 CFR part 173.

5. Should the material being offered for disposal fail to meet any of the following criteria, the material is classed as DOT non-hazardous.

1. Not listed by proper chemical name or family in the HMT.
2. Does not meet the strict definition of any hazard class.
3. Is not a hazardous waste according to 40 CFR.
4. Is not a hazardous substance in a reportable quantity.

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2. RCRA Identification

1. All waste materials offered for disposal are examined to determine if they:

1. are listed hazardous waste subject to 40 CFR regulations or the California Hazardous Waste Regulations.
   
2. exhibit hazardous characteristics or properties regulating them as hazardous waste under 40 CFR Part 261 or applicable California Hazardous Waste Regulations.

3. Laboratory Analysis

1. Unknown Material - For small quantities of unknown or questionable waste
   (< 2 gallons), refer to OEH&S Unknown Chemical Determination procedure.
   
2. Accredited Chemical Laboratory - For larger quantities of unknown or questionable waste (> 2 gallons), laboratory analysis is needed to ensure that all compatibility, regulatory and Treatment, Storage, Disposal facility criteria are met.

See also Chemical Safety Manual