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Hazardous Waste Generator Briefing�ETA0014

Energy Technologies Area

Ron Scholtz, CHMM

January 8, 2026

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EHS0604 Waste Generator Training

You must complete EHS0604 ”Hazardous Waste Generator” training prior to completion of this briefing.

Completion of EHS0604 gives access to the Hazardous Waste Requisition system:
https://ehs.lbl.gov/service/waste-management/wms/

This ETA hazardous waste generator briefing is a supplemental training to assist with preventing common problems found in the lab areas.

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What is a Hazardous Waste?

Flammable (Ignitable)- Flashpoint less than 60^oC or 140^oF (many solvents, thinners, cleaners)
Corrosive- pH less than 2 or greater than 12.5 (acids and bases)
Reactive- unstable under normal conditions. Creates explosions, toxic gas, reacts with air/water
Toxic- harmful if ingested or absorbed. (poisons)
California Regulated- specifically regulated by California (paints, adhesives, pump oil)

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Satellite Accumulation Area (SAA)

Each lab area has a Satellite Accumulation Area (SAA) established for hazardous waste accumulation.

Identified with the yellow SAA label
Lab area Principal Investigator is considered the owner
Use secondary containment trays
No special permit or authorization required

The SAA must be located at or near the point of waste generation.
Do not store non-waste items in the SAA (chemicals).
All containers must be kept closed when not adding waste.
Segregate wastes by hazard in separate trays.
Maximum waste accumulation time should be less than 6 months (ETA policy) for any containers.

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Hazardous Waste Label

Each container of hazardous waste must have a hazardous waste label affixed.
A waste label is generated when initiating a hazardous waste requisition.

Print out the label and insert it in a plastic sleeve.
Affix the plastic sleeve with label on to the container.
Ensure all sections are completed.

Accumulation Start Date- The date you first placed waste into the container.

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Hazardous Waste Label

Label holder sleeves are available on the main hallway label bulletin board

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Accumulation Log

Flammables cans (flam cans) and other containers used to collect waste mixtures must have an associated “Waste Accumulation Log.”
Each time waste is added to the container, an entry needs to be made on the log.
The log is used for determining the waste constituents and approximate concentrations when requisitioning the container for disposal.

Scan and send a copy of the accumulation log to the Waste Generator Assistant each time a requisition is submitted. You can also snap a photo of the log.
Missing or inaccurate accumulation logs can result in delays for your waste pick-up.

Start a new log each time a new container is started.

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Waste Accumulation Log

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Waste Containers

Containers used for collecting wastes must be compatible with the contents.

Flammables- flam can ( 1 gal, 2.5 gal, 5 gal)
Corrosives- plastic containers
Wipes- sealable baggies or cans with lids

Size the container to the volume expected for collection within 6 months or less.
Containers must be kept closed when not in use (including baggies).
Containers >60ml must be labeled/bagged separately. Do not place in a baggie together with a single label!

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Flammable Wastes

Generally, wastes with >10% flammable solvent are considered flammable waste.
Always use a red flam can for flammable wastes. Do not use for aqueous non-flammable wastes.
Red flam cans can be requested from Waste Management.

They will replace flam cans when picking up.

Do not re-use glass 4L bottles for collection of flammable wastes.

< 1 pint glass containers (473 ml) are acceptable for small volumes.

Do not overfill flam cans.
Make sure flam cans are closed when not in use.
Identify empty flam cans stored in the lab area by placing tape over the spout and label “empty” or “MT”

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Corrosive/Aqueous Waste

Take a pH measurement of aqueous wastes prior to submitting a requisition. Indicate the pH on the waste label and waste requisition.
Nitric Acid >5% must be neutralized prior to disposal

You must be assigned to a nitric acid neutralization work activity
Follow the written procedure
Complete the neutralization log
Waste description should include the neutralized salt, not “neutralized nitric acid.” Example: Magnesium Nitrate (if using magnesium hydroxide)
Include your treatment work activity number in the requisition waste description.

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Example Corrosive/Aqueous Waste Collection Containers

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Wipes and Debris

Wipes contaminated with hazardous materials must be collected and disposed as hazardous waste.

Solvents, corrosives, pump oil, nanomaterials, toxic metals, etc.
Collect in sealable baggie or jar
Identify with a hazardous waste label
Place in the SAA

Non-hazardous wipes can be disposed of in the regular trash.

Clearly identify with writing “NON-HAZARDOUS WIPES” or “TRASH ONLY”
Do not identify with the word “waste.”
Place in the regular trash bins

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Glove Boxes

Hazardous wastes generated inside glove boxes must be identified with a completed hazardous waste label.
Hazardous wastes inside glove boxes must not be accumulated for more than 6 months.

Remove from glove box and place in lab area SAA
Do not change the accumulation start date
Best Practice- write the accumulation date on the bottle cap so it is easy to identify

Gloves/wipes that are not hazardous must be clearly identified as “non-hazardous trash.”

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Samples

Sample containers must be clearly labeled for contents.
Prior to leaving LBNL, ensure that all samples are accounted for and requisitioned for disposal.
Sample containers <60ml that contain the same constituents can be collected together in baggies and disposed as a batch.
Do not mix liquid samples with solids samples. When possible, segregate liquids from solids. Pour the liquid wastes into a separate container such as a flam can or collection bottle.

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Old Chemicals

Only purchase quantities that are needed. Check your inventory for first.
Time sensitive chemicals- peroxide formers ( > 2 years)
Containers can become brittle over time
Remove RFID tag number from CMS database after disposing
Regularly dispose of expired or unwanted chemicals
Periodic chemical inventory clean-out events will be arranged

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Empty Chemical Containers

Empty chemical containers can be placed in the regular trash if:

The container is less than 5 gallons in size.
The container did not contain an extremely or acutely hazardous material.
Without rinsing, the container contains no drainable or pourable liquid when held in any orientation.
Without rinsing, the container contains no removable solids other than a thin film, uniform layer of dried material or powder.
The original label must be crossed out or marked with the word “EMPTY” to notify the custodial staff that it no longer contains hazardous materials and can be disposed in the regular trash.

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Intentional Evaporation of Hazardous Liquids in Hoods

Discharge or evaporation of hazardous liquids, wastes, vapors, gases, fumes and dusts to the atmosphere is not permitted. Laboratory hoods may not be used to evaporate materials from open chemical containers or bags of contaminated debris. Intentional evaporation of hazardous waste inside a fume hood, intentional dilution, or unapproved neutralization of a hazardous chemical for the purpose of avoiding collection of that chemical as a hazardous waste are not permitted.

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Empty Gas Cylinders

Most gas cylinders can be returned to the vendor

Affix valve cap
Attach “EMPTY” label to cylinder
Place in cylinder cage empties rack

Some cylinders are not returnable and must be disposed through Waste Management

Lecture bottles
Butane/Propane cans
Some small calibration gas cylinders

Notify the Division Safety Coordinator and arrangements will be made (may be 6 months or more)

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Sharps

Sharps (syringes, needles, razors) should be disposed in designated sharps disposal containers:

Non-Regulated Sharps- no hazard other than there is are sharps than can stick, cut or puncture

Use sharps container, but clearly identify as “non-regulated sharps”

Hazardous Waste Sharps- contaminated with hazardous chemicals.

Label as hazardous waste (red label)
Container must be sealed (cap or lid)
Regular sharps containers do not completely seal.

Bio-Hazard Sharps- contaminated with biological material (blood, bodily fluids, virus, bacteria)

Bio-hazard sharps containers
Dispose as biohazardous waste

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Broken Glass Boxes

Place broken glass in the cardboard “broken glass” box located in the lab area.
Once the box is full:

DO NOT overfill
Close the plastic inner liner with duct tape
Secure the box top and bottom with duct tape

Affix a non-hazardous waste label to the outside of the box.
The box is disposed in the regular trash bins for landfill.

Make arrangements for janitorial staff to move to the bin outside
Use a dolly and move to the bin yourself

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Non-hazardous waste labels available on the hallway bulletin board

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Universal Waste

Batteries, empty aerosol cans, mercury thermometers, and fluorescent lights are considered “universal waste.” They should not be placed in the trash.
Batteries can be placed in the green battery disposal cans located in the hallways.
Request pick-up of empty aerosol cans by a Waste Management service request: Technical Assistance Request Form
Fluorescent lights will be picked up by Facilities for proper disposal. Submit a Facilities Work Request.

Apply a purple “Universal Waste” label to the bulbs.
Store in a manner that prevents breakage.

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Labels are available on the main hallway bulletin board

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Regulatory Requirements

Hazardous waste handling is highly regulated. Failure to follow requirements can result in violation notices and even fines.
Each SAA is inspected by the Waste Management/DOE at least quarterly to ensure hazardous wastes are being handled properly.

Problems are regularly identified which are easily preventable.
Corrective Action Requests are generated and tracked.

City of Berkeley inspects LBNL operations at least annually.