Hazardous waste management

Hazardous waste is waste that has substantial or potential threats to public health or the environment. Hazardous waste must be recycled or disposed of so that it does not cause any harm or damage.

What is hazardous waste?

Waste is considered 'hazardous' under environmental legislation when it contains substances or has properties that might make it harmful to human health or the environment. It may not be an immediate risk to health, although some waste can be. The regulations cover the storage, handling and documentation for the transfer of hazardous waste from the point of generation to the final disposal.

Waste needs to be correctly identified to ensure that it is handled safely and disposed of in the most sustainable manner possible. Departments are responsible as the "producer" of hazardous waste until such time as it enters the appropriate waste stream.

Departments must have a Hazardous Waste Management Plan to ensure that staff and students know how to manage hazardous waste so that it is correctly classified, labeled and stored before it enters the waste stream.

Responsibilities

UCL

UCL will (via UCL Estates and the Waste Manager):

Pick up waste from the designated waste collection points either via the cleaning staff or by competent waste contractors
Publish waste procedures on how each type of waste is to be labeled and packaged - see Step 5 of the Hazardous Waste Classification Process

> Hazardous waste classification process

Safety Services

Safety Services does not manage waste directly, however, the safe storage and handling of waste is part of having a suitable safety management system. Safety Services will:

Provide advice on legislation where it interacts with safety management
Include the waste as a hazard when reviewing departmental safety management for Target 100
Include waste management in inspections and audits

Head of Department

The Head of Department must ensure that the department has a Hazardous Waste Management Plan.

They must ensure that the following responsibilities have named holders who are detailed in the department's Hazardous Waste Management Plan:

A point of contact for safe packaging and labeling for each waste stream
A point of contact for ordering items such as sharp bins, coloured waste bags etc
A point of contact for liaison between UCL Estates (waste management) for the provision of the labels (if produced) and to be aware of estimated delivery times for such items and current stock within the department
A named person for dealing with departmental waste
Departments may produce waste without a clear producer, for example, chemicals that go out of date while in stores, there should be a named person in the Hazardous Waste Management Plan that covers this

The Head of Department must ensure the following are available:

Safe collection points for each waste stream
Designated areas to place the waste which are clearly marked with the type of waste and the date of the next collection

Principal Investigator/Supervisor

The PI is the person who is managing research, teaching or supporting activities that produce hazardous waste. They are responsible for ensuring the following:

Providing the department with management information on all regular hazardous waste to complete and update the Hazardous Waste Management Plan
Everyone who reports to them has the correct information, instruction and training related to waste management
That all activities they oversee have an authorised risk assessment that signposts the management of waste for the activity, including emergency situations e.g. spills etc
That activities and people have the correct level of supervision to ensure that the risk assessment is followed

Risk assessment

Activities at UCL must have an authorised risk assessment and that risk assessment should consider how hazardous waste is going to be managed. Staff and students producing hazardous waste, including waste products, will refer to the departmental Hazardous Waste Management Plan to ensure that the hazardous waste is classified, labeled, stored and enters the appropriate waste stream in line with the departmental Hazardous Waste Management Plan.

The risk assessment should consider the following (list not exhaustive) by referring to the departmental Hazardous Waste Management Plan:

Safe packaging of the waste
Labelling of the waste
The appropriate storage method
Control measures for spillages
If a container is used for storage at the point of generation for waste, whether it must be placed in a secondary bund, for example within a fume hood
Breakage and other emergency situations including fire precautions
Whether spill kits and spill training are required – if required include the spill plan including where the kit is kept and who is responsible for it

The requirement for spill kits including training in their use has to be considered. This can be a standard spill or a specialised kit for the specific waste. Every spill procedure must have the following information:

Owner
Location
What training is required
Description of contents of spill kit

> Responding to chemical spills
> Spills

As the information should be contained in the departmental Hazardous Waste Management Plan, when completing a specific risk assessment for the research or teaching task, the control measure should read as follows.

The hazardous waste is part of the LoW code [insert LoW code] and will be managed in accordance with the procedure for this waste as listed in the departmental Hazardous Waste Management Plan

The hazardous waste is part of LoW code [insert LoW code] and as there is not a specific waste stream to manage this, in following the departmental guidance for such waste including:
- The correct packaging is [insert relevant description]
- The waste will be labeled with the following information [insert relevant description]
- It will be stored while in the department [insert relevant description]
- The emergency plans including spillage are [insert relevant description]

> Read about LoW codes

Last updated: Wednesday, May 18, 2022