Hazardous Waste Please note this is interim guidance and subject to change after an internal audit of waste management.

Guidance on radioactive waste and healthcare waste is available at http://www.leeds.ac.uk/safety

Introduction
For chemical and solvent waste matters, contact Health and Safety Services. For asbestos waste, contact William Harper in Estates Services (ext 35968).

The Hazardous Waste regulations and List of Wastes regulations came into force on the 16 July 2005. The Regulations set out procedures to be followed when disposing of, carrying and receiving hazardous waste. They require that waste movements are tracked from cradle to grave using consignment notes and specifies which materials are to be considered hazardous. . The Regulations also require for any producer of hazardous waste (with some exceptions) to register with the Environment Agency. These regulations do not apply to household waste, with the exception of asbestos removed from domestic properties. The University of Leeds recognises its responsibility to ensure that all campus activities involving hazardous materials and hazardous wastes are conducted in a manner that provides for the safety and security of employees, students, the general public and the environment. In addition the University understands its obligation to conduct these operations in compliance with all applicable European Union and United Kingdom Regulations. In order to fulfil these responsibilities and obligations specific procedures have been developed. The guidelines detailed in this manual are designed to provide for the safe management of hazardous materials and hazardous wastes throughout UOL. This policy is produced in an effort to achieve the following objectives: Ensure a safe and healthy work environment for employees, students and visitors. Protect the environment by using sound principles of handling, treatment, storage and disposal of hazardous chemicals. Minimise the generation as well as cost of handling and disposing of hazardous materials. 1

Part A provides an overview of general hazardous waste guidance including characteristics and classifications. Part B details consignment and documentation requirements and follows with Part C which explains UOL chemical and solvent waste procedures. Part D continues with miscellaneous waste requirements concluding with Part E Payment and Contractor information.

Functions and Responsibilities

The management of Hazardous chemicals and waste at UOL requires a partnership approach; functions and responsibilities are defined below. Directors, Deans and Head of Schools and Services Should disseminate this policy within their area of responsibility and ensure its implementation by providing support and advice to their managers and staff. Employees The success of the UOL managing waste requires all laboratory/workplace personnel and individuals who work with hazardous waste to follow the guidelines presented in this policy. Individuals have a responsibility to: - Collect all chemical wastes in accordance with established guidelines - Identify all spent or surplus materials - Package and label all chemicals in accordance with established guidelines - Consult with Safety Co-ordinators, Safety Managers and Health and Safety Services regarding the safe handling and proper disposal of Hazardous chemicals. Supervisors The primary responsibility of the supervisor, principal investigator or instructor is to ensure that the guidelines established in the policy are followed by personnel under their supervision, e.g. - Chemical identification and labelling - Waste accumulation, logging and handling - Minor spill clean up - Housekeeping Estates Services Estates (Environment section) are responsible the Environmental Management System (EMS), built on our existing good practices, fostering an environmental culture and leading and co-ordinating environmental activities. Health and Safety Services is responsible for the development and implementation of standards and procedure for hazardous chemical wastes and hazardous materials. The service functions are to: - Develop and implement standards with regard to hazardous waste and material management; - Help ensure that UOL standards and regulatory guidelines regarding the 2

proper disposal of hazardous chemical wastes and hazardous materials are followed; - Prepare, submit and maintain records, reports as required by regulation; - Audit chemical waste management practice and disposal procedures; - Develop and co-ordinate programmes that minimise the generation of hazardous waste.

General Hazardous Waste Guidance Definition

Hazardous Waste is defined by reference to the European Waste Catalogue (EWC). The official definition of Hazardous has been extended to include wastes which are classified as Hazardous in the EWC but have not in the past been seen to present a risk. These include fluorescent tubes, old computers, television sets and scrapped cars. Hazardous waste is subject to additional controls under several regulatory regimes, including IPPC, the Landfill Regulations, the Incineration Regulations and the Transfrontier Shipment Regulations. In England, the EU definition of hazardous waste has been brought into force by the List of Wastes (England) Regulations 2005 (SI 2005 No. 895), as amended by SI 2005 No. 1673 and Hazardous Waste (England and Wales) Regulations 2005 (SI 2005 No. 894), Appendix 1. The Hazardous Waste Regulations introduce new consignment procedures which come into force on 16 July 2005. In Scotland, the term "special waste" is still used, but it now refers to hazardous waste as defined by the European Union. The regulations make the following qualifications to the definition of hazardous waste: Domestic waste is normally non-hazardous. However, asbestos waste from households is hazardous, where it is produced in the course of building, modification or demolition work. Radioactive waste is hazardous if it also possesses one of the 14 hazardous properties listed in the regulations. As from 1 September 2006, agricultural waste and waste from mines and quarries can qualify as hazardous (at present it is not covered by the regulations). Prescription-only medicines are only hazardous if they meet the EU criteria (formerly, all such medicines were Special waste). The final decision on whether a disputed waste stream is hazardous lies with the Secretary of State. DEFRA can also classify a waste as hazardous even if it is not marked with an asterisk on the EWC, provided it possesses one of the 14 hazardous properties. Conversely, a waste marked with an asterisk can be 3

deemed non-hazardous by DEFRA, if the waste does not possess one of the hazardous properties.

Classification
A guide to classifying hazardous waste can be viewed in the Environment Agency's official guidance document, Hazardous Waste: Interpretation of the Definition and Classification of Hazardous Waste (Technical Guidance WM2). Appendix 2 contains the key aspects of this guidance, and a summary is given below. 1. Find the waste category in the European Waste Catalogue (EWC). 2. If Waste is marked with an asterisk (*) waste is hazardous. 3. If there are mirror entries, you must ascertain whether the waste possesses one of the 14 hazardous properties. 4. Look up the potentially dangerous constituents of the waste in the ASL (or other information source). 5. Note the category of danger and risk phrases for each dangerous substance. 6. Compare the concentration of each type of dangerous substance with the threshold levels given in the guidance. If the threshold is exceeded, the waste is hazardous. 7. If there are no thresholds for a particular category of danger, consult the guidance. Specialist assistance, e.g. from Health and Safety Services or from UOL hazardous waste contractor, may be required in order to carry out the assessment, particularly if the waste contains more than one hazardous substance.

Consignment of Hazardous Waste

The Hazardous Waste (England and Wales) Regulations 2005 (SI 2005 No. 894), which came fully into force on 16 July 2005, introduces new duties for waste producers and replaces the consignment note system which applied under the Special Waste Regulations (now revoked). The regulations apply mainly to England, although there are provisions relating to cross-border consignments.

Prohibition on mixing
Regulation 19 prohibits the mixing of hazardous waste with:

- a different category of hazardous waste; - non-hazardous waste; - any other substance or material.

Notification
Regulation 21-32 Producers of hazardous waste have a new duty to notify their premises to the Environment Agency each year. This duty applies to all producers of industrial waste. Retail, office, dental, medical, veterinary and agricultural premises are only required to notify the Agency if they produce more than 200kg per annum of hazardous waste. The Agency must be notified every 12 months, and a fee is payable. After receiving the notification, the Agency will issue a premises code. It is an offence to remove waste from premises which are neither notified nor exempt. Exempt premises are still required to ensure that waste is removed only by an authorised person, e.g. a registered carrier. Health and Safety Services keeps a list of all Registered Sites and will inform registered sites on an annual basis.

Movement-consignment note procedure

The waste producer is responsible for giving each consignment of hazardous waste a consignment code, using a system set up by the Agency. Under the 2005 Regulations, there is no longer a requirement to pre-notify the Agency of consignments of hazardous waste.

Collection of Hazardous Waste Standard Collection

Three or four copies of the consignment note are required, depending on whether the producer and consignor are the same person. The consignment note is reproduced in Schedule 4 to the Regulations. 1. The waste producer fills in Parts A and B of the consignment note, and gives all the copies to the carrier. 2. The carrier completes Part C, and gives all three copies back to the waste producer (or consignor). 3. The waste producer or consignor completes Part D, then (i) One copy is kept by the producer (ii) One copy is kept by the consignor (if different) (iii) Two copies go to the carrier.

4. The two carrier's copies travel with the waste, and the carrier gives them to the consignee (i.e. waste management contractor). 5. The consignee completes Part E, then (i) One copy is kept by the consignee (ii) One copy goes back to the carrier. Schedule of Carriers (reg. 37)

Multiple Collections
There are different rules for where more than one carrier transports the consignment and for multiple collections, please contact Health and Safety Services for further guidance where applicable.

Records and Returns

Regulations 47-60 govern records and returns.

Disposal records Contractor Responsibilities

At a landfill site, the contractor must keep records to show where hazardous waste has been deposited. The deposits are identified by: - EWC code and description; - Description of composition; - Consignment note; - A site plan showing the location of the waste. At transfer stations and sites where waste is recovered or disposed of other than by landfill, similar records are required. The records should include information on the quantity, nature and origin of the waste, its hazardous properties, the recovery method and the location of the waste. At transfer stations, the records must be updated a maximum of 24 hours after the consignment is received, stored or removed. All these records must be kept for a minimum of three years, or until the permit is surrendered or revoked.

Producer Responsibilities
The producer or holder and (if different) the consignor shall keep a record of the following information regarding the hazardous waste consignment: - Quantity - Nature - Origin - Destination - Frequency of collection - Mode of transport, including identification of carrier - Treatment method.

The records must be kept for at least three years after the transfer of the waste.

Carrier Responsibilities
These contain the same information as the producer's records described above. They must be kept for at least 12 months after the delivery of the waste to its destination.

Returns from the consignee

The consignee must send a return to the producer to prove that the waste has been disposed of or recovered. Alternatively, copies of consignment notes can be returned to the producer. A return should be sent to the producer within one month of the end of the quarter in which the waste was accepted. The Environment Agency can request documentary evidence to show that, for example, disposal has been carried out. The Agency is entitled to request any of the records which are kept under these regulations.

Emergencies and Offences Emergencies

In the event of an emergency part 9 of the regulations covers the actions to be taken. The waste holder is allowed to breach the regulations if this is necessary to avert or mitigate an emergency or when waste must be removed from a site that has not been notified. The Agency must be notified of the emergency. It is the waste holder's duty to take all reasonable and lawful steps to avert or mitigate grave danger. The regulations specify that once hazardous waste is released, the emergency is not "averted" even if the holder believes that the waste has all been destroyed or rendered harmless.

Offences
The following offences are punishable by a fine at level 5 on the standard scale, or by a fixed penalty of 300: - Failure to notify premises; - Removal of waste from premises which are neither notified nor exempt; - Incorrect notification; - No consignment code on the consignment note; - Failure to produce a consignment note; incorrect information on the note; - Failure to issue consignee or self-disposal quarterly returns; - Failure to supply information when requested.

The following more serious offences are punishable by the statutory maximum fine, or by a maximum of two years' imprisonment, or both: - Mixing hazardous waste (unless allowed by a permit); - Failure to avert an emergency, or to notify the Agency in the event of an emergency; - Giving false information in response to a request.

Waste Management Procedure

This waste management procedure provides a framework for schools and services generating hazardous waste. It must be used alongside school rules, procedures and Control of Substances Hazardous to Health (COSHH) assessments. If hazardous waste is produced the risk assessment of the work activity must have been completed within your school/service. Overall direction, guidance and information will be supplied by Health and Safety Services, who will co-ordinate all hazardous waste disposals on site. The provisions of the Health and Safety and Work Act 1974 applies to all types of waste. The general duty under section 2 of the Act requires that appropriate care is taken during all activities connected with wastes. Types and amounts of waste generated by academic and service departments should be analysed and minimised as far as possible by exploring options such as: - Limiting stocks of hazardous materials; - Modifying processes; - Substituting or changing produce specifications; - Recovery-re-use of material; - Detoxifying or rendering less harmful by chemical, physical or biological treatments utilising safe approved laboratory disposal techniques.

Waste Laboratory Chemicals

This section provides guidelines for collecting, labelling, segregating, completing a hazardous waste chemical form and packaging chemical waste. Waste disposal begins with the generator (laboratory/office) personnel who first decide if the chemicals are still needed. Chemicals which are no longer of use should not be considered waste until other alternatives such as redistribution or recovery have been considered. Waste laboratory chemicals are collected by nominated persons (refer to section 1) in each school who must closely liaise with Health and Safety Services.

The six steps to preparing waste for collection Step 1 Evaluate Step 2 Collect Step 3 Form Completion Step 4 Segregate and package Step 5 Label Step 6 Sign.

Step 1: Evaluate the Waste

Determine if unwanted chemicals (whether pure or in mixtures) fall under the category of hazardous waste as per General Hazardous Waste Guidance.

Step 2 Collect the Waste

Hazardous waste collection bottles must be kept; capped, properly labelled and stored in a safe location in the laboratory. Collection bottles and lids must be compatible with the chemicals stored in them. Drums should not be stored with an open bung or a funnel in them. Waste containers should be stored in appropriate locations, i.e. flammable liquid or acid storage cabinets. Bottles of waste must be labelled as they are generated in the laboratory. Unused or outdated chemicals that are in their original containers with labels identifying the contents are suitable for waste collection. If the label appears faded or illegible, affix a new label to the bottle.

Step 3 Complete UOL Waste Forms

All Schools/services who wish to dispose of laboratory chemical waste must complete the Appendix 3 which contains the following information: - School/service name - Account Number - Date of submission - Name of person completing the form - Contact Details; telephone and E-mail - Chemical name - Location where the chemical is kept - Quantity in Kilo/gram/Litres Hazard classification Grid (which is completed by the contractor): Appendix 3 refers. Chemicals of an unknown nature and sometimes an unknown origin can present difficult handling and disposal problems. Please contact Health and Safety Services for further advice. A preliminary Analysis checklist may be used to collect as much information as possible, Appendix 4 refers.

Once the list is completed it is sent direct to Simon Turner, Enviroco Ltd, at Simon.Turner@enviroco.co.uk. A copy is also sent centrally to Health and Safety Services safety@leeds.ac.uk Please note once the list is submitted, schools cannot add new substances. The form will be returned with appropriate hazard classifications, Appendix 5 refers. You must package your chemicals according to this classification and compatibility, i.e. all TOL* will be packed in the same drum, all FL* will be packed in another drum, etc. Chemicals must be segregated according to compatibility - for example: - Mercury or mercury contaminated material from any other waste - Dioxin or dioxin containing material from any other waste - Peroxide forming chemical from any other waste - Oxidiser from organic compounds, flammable, combustible and reducing agents (e.g. zinc alkaline metals). - Aqueous waste from organic solvents - Inorganic acids from organic materials - Caustic and active metals such as sodium, magnesium and potassium - Chemicals which can generate toxic gases upon contact e.g. sodium cyanide and iron sulphide.

Step 4 Packaging
Once the chemical bottles have been properly labelled, package the waste for transportation by carrying out the following procedures: Containers must comply with UN certification for hazardous products 10, 30, 60 litres are available upon request from UOL waste contractor. Enviroco Ltd, Simon.Turner@enviroco.co.uk If you believe that the use of a supplied drum is inappropriate for a particular item please contact Health and Safety Services to obtain permission to use an alternative.

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All bottles must be tightly capped and packed in an upright position. Use appropriate cushioning or absorbent material to separate the inner containers, acceptable material is vermiculite.

Quarter fill the drum.

Place the first layer of bottles/containers within the drum ensuring they are placed apart. When the drum is lifted no clinking or contact must be made with others within the drum.

Completely cover with vermiculite

Place a second layer of chemicals ensuring they are well cushioned from first layer. Repeat if space permits. Finally fill with vermiculite ensuring complete coverage. You must keep a list of chemicals you have packed within each keg or container.

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Step 5 Labelling
The first stage in the labelling process is simple. Affix a self-adhesive white label on the lid of the drum. Number each drum along with the classification as below. Complete labelling form at Appendix 6. The UOL waste contractor will affix appropriate hazardous transport labelling to the keg, please ensure that this labelling is correct, Appendix 7. Any old labels or incorrect markings on drums must be removed. At no time must you let unlabelled containers leave the premises.

Store chemicals safely, do not put waste containers in hallways or other public locations. Ensure that all chemical waste containers are closed securely.

Winchesters can be re-packed in the original UN boxes.

Step 6 Signing the Consignment Note

It is important you sign the consignment note, refer to notes in Part B of this guidance. Please ensure all details are correct If in doubt contact Health and Safety Services on 0113 343 4201 Take a copy of the note for your records and send the original to Health and Safety Services, Worsley Building Level11, Leeds, LS2 9JT.

Solvent Waste
Bulk solvents are waste laboratory solvents either bulked up from smaller amounts or the result of a production process. Typically they are stored in 25 litre UN approved for hazardous liquids drums (see photo below), with Halogenated and Non Halogenated solvents being stored in separated drums. Drums can be purchased via UOL waste contractor. All bulk solvent drums are stored in outbuilding or licensed petroleum stores. The following procedures should be carried out to ensure proper labelling, safe handling and collection of solvents: 1. Attach the label to the container as soon as the bottle is used as a collection container. Record the starting date on the label. 12

2. As ingredients are added to the container, maintain a separate list recording the ingredients and amounts added. The list must be kept next to the container. 3. Containers in the process of being filled must be kept closed and stored in a safe location; storage location should be selected based on the characteristics of the contents. 4. When submitting the container for disposal the following information must be recorded on both the label and waste packaging form: - ingredients and percentages; - pH of aqueous solutions, or for organic liquids, the pH of and aqueous solution containing 10% of the organic mixture.

Unknown Hazardous Waste In Case of Uncertainty

If you are not sure whether a substance can go into a batch in case of some contamination, contact Health and Safety Services direct. In case of gross contamination with specific substances it may be necessary to treat the material as laboratory chemical waste. Complete Solvent waste form, Appendix 8 and send to Simon Turner at Simon.Turner@enviroco.co.uk A summary of both Laboratory Chemical and solvent waste procedure can be viewed in Appendix 9.

Miscellaneous Hazardous Waste Gas Cylinders

Empty or no longer used cylinders must be returned to the supplier. It is essential that an inventory is kept as corrosive gases degrade over time. The Current UOL waste contractor will accept gas cylinders which cannot be returned to the original suppliers. However recommended disposal and transportation guidance must be followed as per British Compressed Gases Association (BCGA) The Safe Handling of Gas Cylinders at Waste Facilities.

Batteries
The disposals of batteries containing lithium, cadmium, mercury, lead acid type or rechargeable must be disposed of via the hazardous waste stream.

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Aerosol Cans
Aerosol cans must be treated as hazardous waste and the same procedure as chemical and solvent waste must be followed. List the ingredients, company name, and hazard information on the can.

Waste Oils
Waste oils can originate from a variety of sources e.g. engineering workshops, research laboratories. These oils must be categorised as hazardous waste and the disposal route must follow the same procedure as per chemical and solvent waste.

Fluorescent Light Tubes

Old Fluorescent light tubes will be removed by Estates Services Staff. Tubes are stored in special containers prior to being recycled.

Laboratory Equipment and Furniture

Special arrangements for disposal apply if the equipment contains asbestos or radioactive source. For Asbestos-containing equipment contact Health and Safety Services and refer to the Universitys Asbestos policy. For disposal of radioactive sources contact the Radiation Protection Advisor or Technical staff in Health and Safety Services.

Silica Gel
Silica Gel that is grossly contaminated with solvents must be disposed of as hazardous waste. If large quantities of silica gel are generated Leading Solvent Supplies can supply departments with appropriate containers.

Payment and Penalties Payment for Disposal

Departments must currently meet 25% of the costs for waste removal. The remaining 75% will be met by the University Centrally. Each Laboratory chemical is costed by the UOL waste approved waste contractor.

Penalties
If schools fail to forward the relevant documentation and do not follow the procedures outlined in this document, then the department will be required to meet the full cost of that particular disposal.

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Contractor Queries/Problems
Schools/services should contact Health and Safety Services if problems cannot be rectified.

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Hazardous Waste: Appendices

Appendix 1: Consolidated EU Waste Catalogue Appendix 2: Summary of the Environment Agency Methodology for classifying hazardous waste Appendix 3: Laboratory Chemical Waste Form Appendix 4: Unknown Preliminary Analysis Checklist Appendix 5: Classification Codes Appendix 6: Summary Label Form Appendix 7: Transport Danger Signs Appendix 8: Solvent Waste Form Appendix 9: Summary Flowchart Chemical and Solvent Waste Procedure

Last updated: July 2008

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