Safety Services


Hazardous waste management plan

Departments must have a Hazardous Waste Management Plan to ensure that hazardous waste produced by the department is correctly classified, labelled and stored before it enters the waste stream.

The departmental Hazardous Waste Management Plan describes, in detail, the amount and type of waste produced by a department and how it will be reused, recycled or disposed of. Our step-by-step guide will aid departments in completing their Hazardous Waste Management Plan.

Safety Services has prepared a template that departments can use. Departments do not need to use this template but the Plan must include all of the steps below.

> Download the Hazardous Waste Management Plan template

Step 1 - classify the type of waste

Test tubes of liquid
The Safety Data Sheet will identify whether a substance is hazardous or contains any hazardous substances. If the SDS identifies hazardous substances, you must classify the waste before it is sent for recycling or disposal.

The waste classification code, also referred to as LoW (List of Waste) code, provides classification codes for common types of waste. Each grouping or type of waste has a unique code and is placed into one of four categories

  • Absolute Hazardous (AH)
  • Mirror Hazardous (MH)
  • Mirror Non-hazardous (MN)
  • Absolute Non-hazardous (AN)

> LoW codes for common hazardous waste found at UCL

Departmental Hazardous Waste Management Plans will identify the hazardous substances that the department creates, including waste products.

Step 2 - calculate the hazardous properties

Test tube expanded
Once you have classified the type(s) of waste the department creates, you must identify the hazardous properties and thresholds.

Each of the hazardous groups has a different threshold. For example, sodium fluoride threshold concentration is 0.2% while the threshold for organic peroxides depends on whether there is hydrogen peroxide present and its concentration.

UCL treats the disposal of any discarded unused chemicals as above the threshold. If you are producing waste from research that is assigned as Mirror Hazardous, you must consult UCL Estates before assigning the waste stream in the risk assessment.

Mirror Non-hazardous (MN) and Mirror Hazardous (MH) waste that is below the threshold may be disposed of through dilution down designated sinks. 

> Read more about sink disposal

Departmental Waste Management Plans must identify the different waste streams, including sink disposal, for waste with different thresholds.

Step 3 - storage of hazardous waste

three jars with labels
The fewer the number of chemicals associated with hazardous waste, the more economical is the disposal method for that waste. Chemical waste storage should follow good laboratory practice in the separation of reactive substances (see the SDS). 

Incompatible chemicals can be kept in the same store but must be physically separate e.g. in different parts of the store. This is only acceptable if the materials are not likely to leak or come into contact. For example, oxidising and corrosive substances. 

Glass containers are suitable for storing many types of liquid hazardous waste. Always consider:

  • Weight – empty glass containers can be heavy and when filled they can be heavier than expected
  • Manual handling – glass containers do not always have suitable handles or pick up points
  • Prevention of breakages – store on the floor or in the carrier to minimise the opportunity to drop the container
  • Emergency situations – spill kits should be able to deal with broken glass waste as well as the hazardous material

Solid waste containers:

  • Manual handling – cardboard boxes may be suitable but always consider the centre of gravity and how the box is going to be moved
  • Double bagging – especially for gels, but for all dry solids, if dropped there is a risk of creating an inhalable dust cloud. By using a suitable waterproof plastic bag, such as a labelled clear bag, the waste is contained. One box can contain several double bags of waste

Departmental Hazardous Waste Management Plans must specify the waste containers that should be used and the storage location of different types of hazardous waste.

Step 4 - packing and labelling the waste

test tubes on a certificate
Hazardous waste should be contained at the point of production and packaged and labelled in such a way as to indicate that it is hazardous waste. Labels need to be readable and to stay attached to the waste throughout its journey in the waste stream. One type of label is not suitable for all types of waste.

Departments must have a standard method of labelling each type of waste. The information required will depend on the type of waste but, as a minimum, must contain the following:

  • The full chemical name (no formulas, abbreviations or structures)
  • The full common name (if different from the chemical name)
  • If a mixture the label must detail the estimated percentage of each component
  • Used/discarded waste or waste product
  • Total volume/weight
  • The full location of where the waste was produced (room if possible)
  • The name of the research group and the named individual (the "Producer")
  • If accumulated, the waste date started and date stopped
  • Hazard information
  • Waste stream

Departmental Hazardous Waste Management Plans must specify the method the department uses to pack and label the different types of hazardous waste and the named person responsible for providing labels.

Step 5 - collection of hazardous waste

Silhouette of someone collecting hazardous waste
To ensure that UCL follows best practices and complies with relevant legislation, UCL Estates manages the activities of all waste management
UCL Estates will:
  • Collect waste from designated waste collection points either via the cleaning staff or by competent waste contractors
  • Publish procedures on how each type of waste is to be labelled and packaged 
    • Glass – leaf
    • Chemical waste procedures
    • Clinical waste procedures
    • Radioactive waste procedures
    • Laboratory waste – unknown hazards

Departmental Hazardous Waste Management Plans must specify how UCL Estates will be informed that hazardous waste is available for collection.

    Step 6 - waste streams

    Bin with circles all around it
    Waste streams are the complete flow of waste from its source through to recovery, recycling or final disposal. Waste streams are managed by UCL Estates.

    Different types of hazardous wastes have different streams. The Laboratory Waste Stream details the separate streams for some hazardous waste, however, several departmental streams may feed into a UCL waste stream.

    UCL has a waste stream for bulk chemicals and a specific procedure for solvents. Departments will have similar but separate waste streams for:

    • Organic – halogenated solvents
    • Organic – non-halogenated solvents
    • Inorganic solvents

    The departmental Hazardous Waste Management Plan should contain information so that the user can keep waste separated by the risk groups and match the waste to the correct UCL waste stream.

    Department waste streams may include:

    • Clinical – blood
    • Non-hazardous – sink disposal
    • Non-hazardous – recycle 
    • Sharps – non-hazardous
    • Sharps – hazardous 
    • Hazardous chemicals – bulk
    • Hazardous chemicals – "lab smalls"
    • Laboratory glass
    • Electrical waste
    • Mercury waste 
    • Clinical waste – noxious (non -infectious)
    • Clinical waste – infectious
    • Clinical – pathological

    Last updated: Wednesday, May 18, 2022