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Waste Management

1. Hazardous Wastes

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Never dispose of hazardous substances down sink drains unless specifically authorized. Contact your Generator Assistant for more details.

1.1      How Do I Know If My Waste Is Hazardous?

A waste is a by-product of your work or research that has no further use. If you work with chemicals, you are probably a hazardous-waste generator. A hazardous waste is any waste regulated by the Environmental Protection Agency (EPA) or the state of California.

Some examples of hazardous waste are:

  • Flammable liquids, such as nonhalogenated solvents
  • Corrosive liquids, such as strong acids and bases
  • Solid oxidizers
  • Wastes that contain heavy metals and halogenated organics
  • Greases and oils

The first step in determining if you have a hazardous waste is to understand the materials that go into your process, how the materials are used, and how they flow into and out of the process. You must be aware of any potential reactions that might occur that could change the nature of the chemicals you are using. It is quite possible that your process could change hazardous materials into materials that are no longer hazardous, e.g., neutralization or complexing of an acid or base with a buffer compound. Though less common, you should also be aware of the potential to create hazardous materials during your process.

One important information source that can help you determine if your waste is hazardous is the Material Safety Data Sheet (MSDS) for each chemical you use. Before working with any chemical, you should review the MSDS and understand the hazards of the material. More information on working with hazardous materials can be found in the Chemical Hygiene and Safety Plan. As a general rule, you should never work with hazardous materials and generate hazardous waste without being properly trained in safe handling and management practices for such work. Once you have an understanding of the materials in your waste, you can proceed to evaluate the waste as hazardous for possible regulation. Your first responsibility as a hazardous-waste generator is to complete appropriate training. The Hazardous Waste Handling Facility (HWHF) will accept waste only from generators who have completed the training course EHS 604: Hazardous Waste Generator Training. There are provisions for visitors or guests who will be on site for <90 days and will be generating hazardous waste. These guests must complete the Web-based EHS 623: Hazardous Waste Generator Training for Visitors/Guests. This class is not a substitute for EHS 604.

Once a by-product of your work/research is created, you must declare that it is waste, or have determined recycling or reuse options prior to its generation. Recycling and reuse requirements can be very complicated and must be developed prior to the generation of the waste; otherwise, you may be storing waste illegally.

A waste is regulated as hazardous based on a comparison with criteria found in both federal and state of California hazardous-waste regulations. When the EPA developed regulations for the management of hazardous waste, it based its regulations on two general criteria: (1) characteristics of the waste and (2) waste on specific lists. Waste Management (WM) personnel use these criteria in determining the storage, treatment, and disposal of hazardous waste.

If any of the definitions below apply to your waste, the container must be labeled as “Hazardous Waste,” and managed accordingly. If you are unsure whether your waste is hazardous, you may simply label the waste, and then call your Generator Assistant. There is no penalty for labeling waste that may later be determined to be nonhazardous waste.

Once you have determined that your waste is hazardous, sink disposal is strictly prohibited unless specifically authorized. Contact your Waste Generator Assistant for more details.

1.1.1     Characteristic Waste

Characteristic waste is considered hazardous based on specific properties of the material. The four basic properties that can define a characteristic waste are ignitability, corrosivity, reactivity, and toxicity.   Ignitability

A waste is ignitable if:

(1) it is a liquid with a flash point of less than 140°F, unless the liquid is an aqueous alcohol solution with less than 24% alcohol by volume; (2) it is not a liquid and is capable of causing fire through friction, absorption of moisture, or spontaneous chemical changes; (3) it is an ignitable compressed gas; or (4) it is an oxidizer.

Examples of Ignitable Waste

Ignitable liquids: acetone, acetonitrile, benzene, hexane, methanol, ethanol, isopropanol, toluene, xylene, methyl ethyl ketone, lacquer thinner.

Ignitable compressed gases: hydrogen, methane, acetylene, propane, butane, spray-paint cans.

Oxidizers:  ammonium persulfate, sodium nitrate, potassium permanganate, sodium perchlorate, hydrogen peroxide (aqueous solution greater than or equal to 8%), potassium peroxide.   Corrosivity

A waste is corrosive if:

(1) it is aqueous and has a pH ≤2 or ≥12.5, as measured by a pH meter; (2) it is a liquid and corrodes steel at a rate greater than ¼-inch per year in a standard corrosivity test; (3) it is not aqueous, and when mixed with an equivalent weight of water, produces a solution having a pH ≤2 or ≥12.5 (in California only); or (4) it is not a liquid, and when mixed with an equivalent weight of water, produces a solution that corrodes steel at a rate greater than ¼-inch per year in a standard corrosivity test (in California only).

Examples of Corrosive Waste

Corrosive aqueous liquids: hydrochloric acid, sulfuric acid, nitric acid, perchloric acid, acetic acid, sodium hydroxide solution, potassium hydroxide solution.   Reactivity

A waste is reactive if:

(1) it is normally unstable and readily undergoes violent change without detonating; (2) it reacts violently with water; (3) it forms potentially explosive mixtures with water; (4) it generates toxic gases, vapors, or fumes when mixed with water; (5) it contains cyanides or sulfides and can generate toxic gases when exposed to pH conditions between 2 and 12.5; or (6) it is explosive under standard temperature and pressure conditions, or it can explode if subjected to a strong initiating source or heated under confinement.

Examples of Reactive Waste

Sodium metal, potassium metal, lithium metal, concentrated sulfuric acid, picric acid, trinitrobenzene, metal azides, amides, benzoyl peroxide.   Toxicity

A waste is toxic if:

(1) it can release sufficient amounts of specific toxic metals or organics in standard leaching or extraction tests (there are more vigorous extractions and more constituents of concern in California); (2) it contains sufficient total amounts of specific toxic metals, organics, or asbestos (California only); (3) it has an acute oral LD50 less than 2,500 milligrams per kilogram (California only); (4) it has an acute dermal LD50 less than 4,300 milligrams per kilogram (California only); (5) it has an acute inhalation LC50 less than 10,000 parts per million as a gas or vapor (California only); (6) it has an acute aquatic 96-hour LC50 less than 500 milligrams per liter in a standard aquatic toxicity test (California only); (7) it contains specific known human carcinogens in a single or combined concentration equal to or exceeding 0.001% by weight (California only); (8) it has been shown through experience or testing to pose a hazard to human health or the environment because of carcinogenicity, acute or chronic toxicity, bioaccumulative properties, or persistence in the environment (California only).

Because of the unknown and potential hazards associated with nanomaterials, these wastes must be managed as “nanomaterial-containing waste streams” with the characteristic of toxicity.


Examples of Toxic Waste

Waste containing the following metals or inorganics above specific limits: antimony, arsenic, barium, beryllium, cadmium, chromium, cobalt, copper, lead, mercury, molybdenum, nickel, selenium, silver, thallium, vanadium, zinc, asbestos, fluorides.

Waste containing the following organic constituents above constituent-specific limits:  benzene, carbon tetrachloride, chlorobenzene, chloroform, cresols, 1,2-dichloroethane, methyl ethyl ketone, nitrobenzene, pyridine, tetrachloroethylene, trichloroethylene, PCBs.

If you are not sure whether your waste is hazardous due to a regulated characteristic, consult with the Generator Assistant assigned to your division or building.

1.1.2     Listed Waste

The definition of a “listed waste” is more convoluted. At Berkeley Lab, the listed wastes that create the most questions are typically solvents. EPA regulations require us to consider how the solvent was used in the process. EPA considers listed waste to be hazardous, regardless of its concentration or physical characteristics.

Generally, the waste generator is the only person who can provide enough information for us to make this determination. The following examples are meant to illustrate the information required by the Berkeley Lab Waste Management Group in order to comply with EPA and state regulations.

Example 1: A Waste Is Described as 50% Acetone and 50% Hexane

Case 1—Assume your experimental procedure requires that you mix acetone and hexane in a 50:50 ratio, and that this mixture is used in your process. In this case, the listed-waste criteria would not apply, because the acetone was not at 100% before you used it in your process; instead, it was 50%. Therefore, only the characteristic criteria would apply.

Case 2—Suppose you use pure acetone as a solvent in one process, and pure hexane in a separate process. One day, you add 1 gallon of used or “spent” acetone to your waste container; the next day, you add 1 gallon of used or “spent” hexane. This waste is also a 50:50 mixture of acetone and hexane, but now since the acetone was at 100% when it was used in your process, the entire waste has to be managed as a listed waste.

Example 2: A Waste Is Described as 4% Methylene Chloride, 48% Phenol, and 48% Chloroform

Case 1—Assume your experimental procedure requires a mixture of methylene chloride, phenol, and chloroform in a 4:48:48 ratio prior to use in your experiment. After use, this is added to your waste container. In this case, because the methylene chloride added to the mixture was less than 10% before use, only a characteristic waste code applies.

Case 2—Assume that this mixture occurred after the experimental process. One day, 2,400 mL of a 50:50 mixture of phenol chloroform is added to your waste container. A few days later, 100 mL of used 100% methylene chloride is added to this same container. In this scenario, the entire waste container is subject to the listed-waste rule, because the concentration of methylene chloride was greater than 10% when it was added to the waste container.

These examples also illustrate the need to maintain an accurate accumulation log (see Figure 1-1). Follow-up phone calls by your Generator Assistant can be minimized or avoided by doing the following:

1.            Review the list of chemicals in Table 1-1; use nonhazardous substitutes, if possible.

2.            List the concentrations of all waste constituents.

3.            Fax copies of detailed accumulation logs.

4.            Tell Waste Management if the material is used or surplus unused material.

5.            Discuss your generating process with your Generator Assistant.

Interpretation of the regulations has limited the treatment options, and thereby disposal options, for listed waste. Once a listed chemical used as a solvent enters a waste stream, it may carry that designation, regardless of the fate of the originally listed molecule. Furthermore, any other waste that is mixed with that waste, no matter what the final concentration, may also be designated as listed hazardous waste. Many surplus, unused, or off-specification chemicals are also considered listed waste when discarded. Avoiding listed chemicals is a good way to enhance waste minimization. For example, substituting ethanol for methanol in many chemical processes might cost more initially, but it could greatly reduce the complications and costs associated with disposal.

If, after review of this concept and the associated lists, you are unsure whether you have a

listed or characteristic waste, consult with the Generator Assistant assigned to your

division or building.

1.1.3              Chemical Compatibility

Incompatible chemical wastes should never be mixed together. Uncontrolled chemical reactions may endanger your safety and the safety of those around you. The act of mixing together separate wastes may also result in a regulatory violation for unpermitted treatment. Benchtop treatment may be an alternative if your goal is to avoid mixed-waste charges or you are generating nitric acid wastes subject to Chapter 20, Section of the Berkeley Lab Health and Safety Manual (PUB-3000). Also see Benchtop Treatment in Sections 1.2.4 and 3.5 of this document. If you are not sure whether to add a particular chemical mixture to your waste container, please contact your Generator Assistant.

Additional information may be found at


Figure 1-1. Example of a completed hazardous-waste accumulation log.

Table 1-1. EPA F-Listed Hazardous Wastes

F-Listed hazardous wastes include spent solvents used in degreasing or other solvent operations, and various spent solvents that are no longer useful for their original purpose.


Federal Listed Hazardous Wastes*



F001 (large-scale degreasing) 
³ 10% before use)

F004 (³ 10% before use)




cresylic acid

methylene chloride




carbon tetrachloride

F005 (³ 10% before use)

chlorinated fluorocarbons



methyl ethyl ketone

F002 (nondegreasing) (³ 10% before use)

carbon disulfide



methylene chloride













*This summary does not include listed waste from certain nonspecific sources and specific sources (industrial processes) not pursued at Berkeley Lab, nor does it include listed waste from discarded unused commercial chemical products.



F003 (100% before use)



ethyl acetate

ethyl benzene


ethyl ether


methyl isobutyl ketone


n-butyl alcohol








1.1.4     Excess Laboratory Chemicals and Laboratory Cleanouts

The Waste Management Group encourages you to periodically remove unwanted chemicals from your work area to maintain a safe and compliant workplace. It is of the utmost importance that if you intend to leave Berkeley Lab, you must determine the fate of any chemicals you leave behind [see RPM Section 1.20 (Space Management)]. Your division might have specific rules regarding remaining chemicals. However, abandoned chemicals present compliance and safety liabilities. If chemicals are left behind without proper documentation, significant costs will be charged to the division to characterize these items. To that end, we ask that you do the following:

1.            Determine if any other researcher in your area wants the chemicals. If so, please transfer custody to them and update the Chemical Management System.

2.            If your chemicals are to be disposed of, use the Chemical Management System link to the Electronic Hazardous Waste Requisition System to request waste pickup.

Stock solutions and experimental products can be added to the requisition with items from the Chemical Management System. Radioactive and mixed wastes cannot be submitted electronically at this time and must be requisitioned separately (see Section 2).

1.1.5     Unknowns

While we recommend that all excess chemicals be disposed of and that wastes be requisitioned and removed before the generator leaves the laboratory, this is sometimes not possible. It is not advisable to certify the waste if you are not the generator of that waste, since you may not be aware of certain constituents and fully informed about the generating process. In cases where the contents are unknown and the necessary information cannot be obtained from the generator, contact your Generator Assistant for guidance. Samples also can be sent for laboratory analysis to give us the best information available, but this is not the method of first resort. The Division is responsible for paying the costs of the laboratory tests.

1.2      I Know My Waste Is Hazardous. Now What?

Sink disposal of hazardous substances is strictly prohibited unless specifically authorized. This prevents violations of environmental regulations. Contact your Generator Assistant for more details.


The Importance of the Waste Generator

If you generate hazardous waste, you have an important role to play in assuring that we manage that waste in an environmentally conscious manner and in compliance with all regulations. The waste generator is the only person with reliable and credible knowledge of the waste constituents and of how the waste was created. We often have to ask questions about the waste-generating process, and the generator, not a third party, is the only source of that information.

Your first responsibility as a hazardous-waste generator is to complete appropriate training. The Hazardous Waste Handling Facility (HWHF) will accept waste only from generators who have completed the training course EHS 604: Hazardous Waste Generator Training.

As a generator of hazardous waste, you must understand the necessary steps to safely and compliantly accumulate waste. For typical waste accumulation in small quantities, i.e., less than 55 gallons, you will need to understand and follow all rules applicable to a Satellite Accumulation Area (SAA), which is an area at or near the point of waste generation. The requirements for waste accumulation and setup of an SAA are covered in Section 1.3 (Where Do I Store My Waste?) and in training classes EHS 604: Hazardous Waste Generator Training and EHS 614: Satellite Accumulation Areas Management. If you do not establish your own SAA but use one that is under the management of a designated SAA manager, you must coordinate use of the SAA with that responsible individual.

Hazardous-waste regulations dictate that you, as the generator, are responsible for the complete and accurate characterization of your waste. Precise characterization is essential to ensure

  • Safe handling
  • Protection of the environment
  • Compliance with federal and state packaging requirements
  • Compliance with conditions of Berkeley Lab’s HWHF Permit
  • Compliance with land-disposal restrictions
  • Acceptance of the wastes by appropriate recycling or disposal facilities

All wastes must be characterized fully, as directed by the criteria in Section 1.2.1, before they can be accepted for transport to the HWHF.

1.2.1     Characterization

Because most chemical waste is generated during specific processes in the course of your activities or experiments, you should know the chemical content of your waste from your “knowledge of the process” you used to generate it (see Section 1.1, [How Do I Know if My Waste Is Hazardous?]). In fact, the individual generating the waste is, in most cases, recognized as a more accurate source than certified analytical laboratories for specifying components and their concentrations in a given waste sample. Most hazardous waste generated at Berkeley Lab can be characterized through process knowledge. However, this approach must be supported by precise, documented information (see Section, [Hazardous Waste Characterization Criteria]). To use and justify process knowledge for characterization, you must

  • Know the hazardous properties of all chemicals used
  • Have a thorough understanding of how the chemicals were used
  • Understand the chemistry of the reaction to determine if hazardous chemicals were produced where none existed before
  • Know whether the process converted hazardous chemicals to nonhazardous ones   Hazardous Waste Characterization Criteria

Once you have determined that your waste is hazardous (see Section 1.1, [How Do I Know if My Waste Is Hazardous?]) and have identified the type(s) of hazard(s), all hazardous and nonhazardous components must be fully identified and documented. It is important to account for 100% of the contents of each waste container, including trace amounts of known hazardous components or other materials of concern (such as nanomaterials). A common problem is the failure to recognize that water and hydrogen ions (pH), if present, must be listed as components. Hazardous-waste characterization may be achieved in the following ways:

By maintaining records (logs) of accumulation that draw upon knowledge of the procedures and processes that generated the wastes. The logs contain an entry each time a chemical is added to a container (Figure 1-1), and a link to the forms. To use and justify process knowledge for containers with repetitive additions of various constituents, this record must be a timely and accurate reflection of what has been added to the container. When the container is no longer needed, this record becomes the basis to develop summaries, which will be provided as part of a pickup request. For waste that is collected in this manner, this record of accumulation must accompany all subsequent document submittals to the Waste Management Group.

By consulting an MSDS for each hazardous component, and listing quantitative information for all hazardous and nonhazardous components.

By developing a generic description when the material has a well-known standard composition (e.g., waste alkaline batteries or a broken mercury thermometer).

By using analytical results from a certified laboratory on known, unchanging waste streams (i.e., a waste profile), or by using complete analytical results from a certified laboratory for each waste. Analytical results from a noncertified laboratory may be used if adequate analytical records and procedures are documented and available to the Waste Management (WM) Group of the Environment, Health, and Safety (EH&S) Division, but will only be considered as a qualified form of your process knowledge.

Updated section flag start icon When a hazardous-waste requisition form (Figure 1-2) is submitted, each entry on the requisition should indicate whether the waste is process waste (i.e., waste from a research or operations process) or the remainder of an unused chemical in the original manufacturer’s container.



Haz Req Form

Figure 1-2. A hazardous-waste requisition form. Updated section flag end icon

1.2.2     Labeling of Waste Containers

As a hazardous-waste generator, you are responsible for assuring that any container used to accumulate hazardous waste is properly labeled in order to meet regulatory requirements and assure the safety of those around you. The labeling requirement applies from the moment the first drop of waste is placed in the container. At that point, you must fill out and attach a hazardous-waste label to the waste container. Figure 1-3 is an example of a properly completed hazardous-waste label. If you have multiple containers of the same waste stream, each of a 60 ml size or greater, they should be labeled separately. Smaller containers (<60 mL) can be grouped together in a larger container and labeled as a unit.

The hazardous-waste label identifies:

  • the waste generator,
  • the contents of the container,
  • information on the hazardous characteristic(s) of the waste, and
  • establishes the waste-generation start date.

The waste generator must fill in the start date when the first addition is made to the waste container. Each primary waste container must have a label attached, indicating the composition of the material. A manufacturer’s label does not serve this purpose, even if proper hazard information is on the label.

All entries on the hazardous-waste label must be legible. It is recommended that entries be made with a permanent marker or a pen containing permanent ink. Ballpoint pens, pens with water-soluble ink, or pencils should not be used to fill out hazardous-waste labels. For large primary waste containers such as carboys, the hazardous-waste label should be affixed to an area of the container that is easily visible for inspection and emergency-response purposes. A waste container that is too small for a label can be placed in a ziplock plastic bag, with a hazardous-waste label affixed to the bag. If this method is used, be sure there is a very clear association between the hazardous-waste label and the actual primary waste container.

The “Contents” section of the Label can be completed using one of the following three approaches:

1.      By chemical name. If the material is a mixture, identify at least two or three of the major constituents that contribute to the primary hazard(s), including nonhazardous constituents, if appropriate. For waste containing nanomaterials, the description must include “contains nanomaterials.”

Examples: 1 M hydrochloric acid, aqueous solution; used acetone; contains acetone, hexane, methanol. Remember, if the composition is changing due to repetitive additions of compatible waste materials, maintain an accumulation log for the container, and record each entry on the log.

Figure 1-3. Example of a properly completed hazardous-waste label.


2.      By manufacturer and specific product (for example, trade name or number, catalog number, etc.), including the primary hazardous materials listed in the MSDS for the specific product.

Example:  BioRad protein assay dye reagent contains methanol and phosphoric acid.

Chemical identification information of manufactured products may also be found in the Aldrich Catalog of Fine Chemicals; the NIOSH Registry of Toxic Effects of Chemical Substances; and The Merck Index: An Encyclopedia of Chemicals, Drugs, and Biologicals.

3.      By complete generic description of the material, only if the material is a mixture with a well-known standard composition. The description should indicate whether the material is new, has exceeded its shelf life, is spent, etc. If the material is a process waste, such as a cleaning agent or an etching bath, list all of the potential contaminants from the process in addition to the known constituents. For machine coolants, identify the metals for which the coolants were used. The generic description must be sufficiently complete to adequately characterize the waste material.

Example: Chromic acid dip-tank waste with copper. “Photochemicals” is insufficient because a wide variety of chemicals are used in photoprocessing. The description must be more specific, such as “alkaline photo developer” or “used photo fixer with chromate bleach.”   When Is a Solid Actually a Liquid?

            The physical form of the waste (solid, liquid, gas) is critical to the characterization and acceptance of the waste to the off-site treatment and disposal facility. If a waste container contains both a solid and any amount of free liquid (liquid not bound by an absorbent), it is a “liquid.” It is permissible to mark the label as both a “solid” and a “liquid.”

1.2.3     Waste Container Acceptability

As a waste generator, you must assure that any container you use for waste meets certain minimum requirements. First and foremost, you must assure that the container and its closure are compatible with the waste placed in the container. You must also assure that the container is kept closed at all times except when adding waste. It is a regulatory violation to accumulate and subsequently store hazardous waste in an open container. Container compatibility information can be found at and in the Chemical Hygiene and Safety Plan.   Flammable Wastes

Accumulation of flammable wastes must be in accordance with the National Fire Protection Association (NFPA) and Occupational Safety and Health Administration (OSHA) safety guidelines. NFPA 45, Fire Protection for Laboratories Using Chemicals, Table 10.1.4 (2004 Edition), and OSHA 1910.106d, Table H-12 restrict the sizes and types of containers that can be used for storage of flammable liquid waste in the workplace.

Flammable or ignitable wastes may not be accumulated in plastic containers of any type other than a listed and approved safety can (Figures 1-4 and 1-5 show examples of flammable waste cans). Approved, reusable safety cans are available from the Waste Management Group in 5-, 2.5-, and 1-gallon capacities. If you have small amounts of flammable waste, glass containers may be used, but the maximum allowable waste quantity in a glass container is 1 pint for Class IA liquids, and 1 quart for Class IB liquids (Figure 1-6).[1] Table 1-2 lists the appropriate containers for small quantities of flammable liquids.

can image

Figure 1-4. A 5-gallon flammable waste can.



Figure 1-5. A 2.5-gallon flammable waste can.



Figure 1-6. Glass bottles suitable for Class 1A flammable liquids (1 pint) or Class 1B flammable liquids (1 quart).


Various containers are available from Waste Management, or a variety of laboratory-supply vendors.

Information on the classification of flammable liquids can be found in the Berkeley Lab Chemical Hygiene and Safety Plan.

In some instances where your building has an appreciable amount of flammable and combustible liquids, you may be required to store flammable and combustible wastes in flammable liquid safety cabinets to comply with California building and fire codes. Please refer to the Chemical Hygiene and Safety Plan for more information or contact the Berkeley Lab Fire Marshal at ext. 6370.


Table 1-2. Appropriate Containers for Small Quantities of Flammable Liquids

Flammable Liquid Category

Waste Quantity


Class IA—Flash point below 73°F (22.8°C), and a boiling point below 100°F (37.8°C) (e.g., acetaldehyde, diethyl ether, pentane)

≤1 pint


>1 pint

1 pint, glass


1-gallon safety can

Class IB—Flash point below 73°F (22.8°C), and a boiling point at or above 100°F (37.8°C) (e.g., acetone, acetonitrile, carbon disulfide, cyclohexane, 1,2-dichloroethane, diethylamine, ethyl alcohol, heptane, hexane, isopropyl alcohol, methyl alcohol, methyl ethyl ketone, tetrahydrofuran, toluene)


≤1 quart


>1 quart


1-quart glass


2.5- or 5-gallon safety can

Class IC—Flash point >73°F, but <100°F (e.g., p-xylene)

≤1 gallon


>1 gallon

1-gallon safety can

5-gallon safety can

* Without regard to container type, surplus unused flammable liquid in the original manufacturer’s container is acceptable.   Solvent-Contaminated Rags

Fire code requires that large containers (>1 quart) for the accumulation of solid ignitable wastes (e.g., solvent-contaminated rags) have self-closing lids that are sufficiently tight to restrict the supply of oxygen. As a waste- minimization or pollution-prevention alternative, please consider the Reusable Rag and Absorbent Program.   Acids or Bases

To prevent accidents and injuries, liquid corrosive wastes should be accumulated in polyethylene or plastic containers that are known to be compatible with acids or bases.

1.2.4     Benchtop Treatment

Benchtop treatment refers to a process used by research labs to perform authorized treatment of wastes per California regulations. Benchtop treatment is often used to neutralize corrosive mixed wastes to avoid treatment charges. However, any experimental reaction mixture or waste aqueous solution that contains nitric acid (HNO3) must be neutralized or diluted if the following conditions occur:

  • The nitric acid solution is >5% by weight (0.8 M or pH<1) and has no organic or metal constituents.
  • Any concentration of nitric acid solution has organic or metal constituents.

Either process must be authorized through an approved benchtop-treatment procedure. Neutralization or dilution will properly treat these wastes for safe storage. It will also prevent safety hazards in the laboratory caused by inadvertently mixing such wastes with incompatible materials.

Nitric acid solutions <5% by weight that do not contain organic or metal constituents do not need to be neutralized prior to storage in an SAA. Please see the Berkeley Lab Health and Safety Manual (PUB-3000) for more details.

There are several regulatory requirements that must be met before a benchtop-treatment authorization can be approved. After working with you to ensure all requirements are met, your Generator Assistant will obtain all needed signatures. See Section 3.5 for more information about benchtop-treatment requirements.

1.2.5     Waste Segregation

As a waste generator, you must assure that wastes are collected in a manner that segregates chemicals that could potentially react when mixed. In general, you should have separate containers for each compatible waste stream. Collect acids with acids, bases with bases, etc. Keep oils with known or suspected PCB content separate from non-PCB-containing oils.

1.3      Where Do I Store My Waste?

Prior to pickup by Waste Management Group staff, or while you are accumulating waste from your process, the container must be stored in an SAA or Waste Accumulation Area (WAA). This section discusses both types of storage.

1.3.1     Satellite Accumulation Area (SAA)

An SAA is an area in a laboratory, shop, or other facility designated by the generator for the accumulation of hazardous waste. It requires no formal authorization from Waste Management. Even a single small bottle of a hazardous waste requires establishing an SAA in your laboratory or work area.

The SAA manager is responsible for enforcing proper waste accumulation at the SAA. This requires that the SAA manager take EHS 604: Hazardous Waste Generator Training. The waste generator is responsible for assuring that his/her containers are properly labeled and kept closed unless adding waste, and that proper accumulation records are maintained. If your work area has an existing SAA, ask the SAA Manager if you can use it. If there is no SAA in your area, details for setting up, using, and maintaining an SAA are provided in Sections SAA Manager guidelines can be found in Section, (Managing Containers in the SAA), or in the training course EHS 614: SAA Management.   Setting Up an SAA

Hazardous-waste regulations require the SAA to be located at or near the point of waste generation, and that it be under the control of the generator. The SAA must be at or near the site where the waste is generated so the SAA can be controlled by staff while they are working. Your SAA must be located in the room where the waste is generated, or in an immediately adjacent room (with no intervening hallway). The intent of this requirement is to provide virtually full-time monitoring of the SAA by the individual(s) generating the waste.

Regulations and best-management practices require that the SAA be located away from all exit doors or areas where it could hamper egress in the event of a fire or spill. Appropriate spill-cleanup materials should be located near your SAA, especially if large amounts of wastes (up to 55 gallons) are accumulated.

The SAA must be clearly designated by the yellow sign shown in Figure 1-7. The “Name,” “Bldg/Room,” and “Extension” fields refer to the SAA responsible manager. If there is uncertainty regarding the boundaries of the SAA, the area should be clearly marked off with tape, arrows, and other signage to clearly define the SAA boundary (Figure 1-8).

All hazardous wastes must be stored in the SAA. Maximum storage allowed is 55 gallons of any particular hazardous-waste stream, or up to 1 quart of acutely or extremely hazardous wastes (see Appendices II and III, respectively). If you wish to accumulate more than 10 gallons (and fewer than 55 gallons) of liquid ignitable waste in an SAA, fire code requires that your SAA be located in a metal flammables cabinet. This determination might also be influenced by storage of other flammable liquids in the vicinity of your SAA. If you have questions concerning application of the fire code in your work area, please contact the Berkeley Lab Fire Marshall at ext. 6370.


Figure 1-7. A properly completed SAA sign.

Figure 1-8. Hazardous waste stored in an SAA.   Managing Containers in the SAA

All wastes must be in containers compatible with the waste. Accumulate liquid corrosive wastes in polyethylene or plastic containers that are known to be compatible with acids or bases. Flammable or ignitable wastes may not be accumulated in plastic containers of any type other than a listed and approved safety can. Approved, reusable safety cans are available from the Waste Management Group in 5-gallon, 2.5-gallon, and 1-gallon capacities. If you have small amounts of flammable waste, glass containers may be used, but the maximum allowable glass-container size is 1 pint for Class IA liquids, and 1 quart for Class IB liquids (see Section, [Flammable Wastes], for further discussion of flammable liquid waste storage).

Various containers are available from Waste Management, or a variety of laboratory-supply vendors via Ebuy.

Information on the classification of flammable liquids may be found in the Berkeley Lab Chemical Hygiene and Safety Plan at

Keep primary waste containers tightly closed at all times except when you are adding waste. The container may be opened up to 15 minutes while you add waste. A funnel in a container opening is not considered closed unless the funnel itself seals to the container, preventing spillage. Container closures must be secure. Cork, rubber, or ground-glass stoppers; aluminum foil; and polyethylene film or parafilm are not allowed. Plastic bags used as containers must be closed (twist-tie, ziplock, tape, staple, or spring clamp). Do not add waste to a hazardous-waste container after you have submitted the pickup requisition for that container to the HWHF.

Prepare and label all waste containers with red-and-white hazardous-waste labels. Labels must be complete and correct at all times. Figure 1-3 is an example of a properly completed hazardous-waste label. If the container is too small for a label, place it in a ziplock bag and attach the label to the bag.

Note: If your experimental protocols require the use of materials that may continue to react at the conclusion of your process (e.g., oxidizing materials), these protocols must be treated by an authorized benchtop-treatment process.  More information on these materials may be found at Once these reactions are quenched using an authorized benchtop-treatment process, the materials may be added to the appropriate waste container.   Secondary Containment

Secondary containment is required for all liquid hazardous wastes and all wastes accumulated in glass containers. The secondary containers must be compatible with the chemicals they contain. The requirement for secondary containment of waste containers in an SAA or a Mixed Waste Satellite Accumulation Area (MWSAA) is a best-management practice throughout industry and government. Secondary-containment capacity of 110% of the largest container being stored is an industry standard. The secondary-containment requirement does not depend on the actual volume of waste being stored, only the largest container in storage. Remember that physical space and segregation of incompatible chemicals in secondary containment are important as well. Each container should be stored safely.

Metal containment is acceptable for noncorrosive wastes.

Example 1:  A lab SAA contains three 1-liter bottles of waste. Secondary containment should be able to contain 110% of 1 liter or 1.1 L. In this case, an 8” × 10” plastic photo tray is acceptable. (8” × 10” × 1” = 80 cubic inches or 1.3 liters).

Example 2: A lab SAA contains a 5-gallon flammable waste can, two 1-pint bottles, and a 20 mL vial. Secondary containment should be able to contain 110% of 5 gallons or 5.5 gallons (20.8 L). In this case, a polyethylene, 5-gallon, 18” × 26” × 6” Rubbermaid tote is appropriate (18” × 26” × 6” = 2,808 cubic inches or 46 L).

Example 3:  A lab MWSAA has a collection container for scintillation vials. The typical storage configuration is a plastic bag inside a 12.2 gal container. A full bag is approximately 750 vials (20 mL each) or 15 liters of liquid. Secondary containment should be able to contain 110% of 15 liters or ~4.4 gallons. The secondary-containment requirement is satisfied by the plastic bag inside a 12.2-gallon container. Waste Management provides the plastic bag and 12.2-gallon container.

Secondary-containment tubs and trays are available from several suppliers with whom Berkeley Lab has system contracts that facilitate ordering. Other plastic trays and tubs are available from suppliers such as VWR with a two-day delivery time. Appropriate containment options can be found in the Labels/Supplies section of this Web page.   Additional SAA Requirements

Keep incompatible wastes physically separate, in secondary containment as well as in the primary container (e.g., acids and bases, oxidizers and organics, water reactives and aqueous wastes).

California regulations allow waste accumulation for up to one year in an SAA; however, under Berkeley Lab policy, waste may be accumulated in SAAs for up to 275 days (nine months). This is not an HWHF Permit condition. To comply with Berkeley Lab policy, waste must be removed from the SAA within the 275-day timeframe. Waste containers should be requisitioned for pickup as soon as they become full, and must be removed from the SAA within three days after reaching the 55-gallon accumulation volume limit. Waste remaining in an SAA longer than one year may subject the Laboratory to fines from regulatory agencies.

Do not store chemicals, empty bottles, or other items in your SAA because these items might be mistaken for unlabeled hazardous waste. Good housekeeping practices should also be implemented to provide easy access to your SAA.

Waste may be stored in Potter Street SAAs for more than 275 days, provided that the waste has been requisitioned by the generator and processed by Waste Management technicians. Waste from Potter Street is shipped directly to the off-site treatment and disposal facility several times during the year.

Several poster-type summaries of SAA requirements are available on this Web site under Generator Resources/SAA Management Tools (here and here). These can be posted at or near the SAA to assist you in maintaining a compliant SAA.

1.3.2     Waste Accumulation Area (WAA)

A Waste Accumulation Area (WAA) is a storage area designed for the accumulation of hazardous wastes for up to 90 days, in total quantities that can exceed 55 gallons (208 liters) of hazardous waste, 1 quart (0.946 liter) of extremely hazardous waste, or 1 quart (0.946 liter) of acutely hazardous waste. Berkeley Lab policy allows the accumulation of hazardous waste in a WAA for a maximum of 60 days to assure compliance with state regulations. This is not an HWHF Permit condition. The 60-day storage period begins on the date (called the “WAA receival date” or the “accumulation start date”) when waste is first placed in the container.

WAAs offer benefits to large-quantity waste generators. They provide a single area for the accumulation of large quantities of waste, and in the event of a spill, they prevent hazardous materials from entering the environment by means of required secondary containment. In addition, they contain emergency equipment in the event of a spill or release. The actual need for a WAA is best determined through consultation between the waste-generating organization and the Generator Assistant. A WAA cannot be established without prior EH&S approval.

The physical requirements for WAAs include:

  • Secondary containment
  • Shelter from the elements
  • Controlled access
  • Appropriate signs
  • A method to separate incompatible wastes
  • Sufficient access to allow pickup of waste
  • A washable surface (e.g., concrete or asphalt)

Where possible, the WAA should be a distance of approximately 50 feet from sanitary sewers or storm drains. The WAA must also be located at least 50 feet from the facility property line if flammable or reactive waste is being accumulated.

The following safety equipment must be maintained at or near all WAAs:

  • Portable fire extinguisher and/or fixed fire-suppression system
  • Emergency spill kit
  • Emergency eyewash and safety shower
  • Telephone (either at the WAA or nearby, with a sign indicating the direction to the nearest phone)
  • Personal protective equipment (e.g., gloves, safety glasses)
  • Appropriate hazard warning signs (e.g., “Flammables,” “Hazardous Waste Area”)
  • Posted contingency plan for dealing with spills and other accidental releases of hazardous wastes
  • Posted names and telephone numbers (day and night) of responsible individuals (WAA manager and alternate)

When no further waste needing a WAA is to be generated, it must be closed according to state regulations.

For more information about WAAs, please consult Guidelines for the Management of Waste Accumulation Areas (WAAs) at Berkeley Lab (LBNL/PUB-3093).

1.4      How Do I Get Rid of My Hazardous Waste?

Sink disposal of hazardous substances is strictly prohibited unless specifically authorized. This prevents violations of environmental regulations. Contact your Waste Generator Assistant for more details.


You should request a pickup of your hazardous waste:

    When your container is full,

    When the age of the container is approaching 275 days (nine months),

    When you no longer need the container to accumulate waste, OR

    As often as you wish.

All hazardous-waste requisitions must be completed and sent in electronically. The Electronic Hazardous Waste Requisition System can be accessed via Allow two weeks for pickup.

1.4.1     Electronic Hazardous Waste Requisition System

The Electronic Hazardous Waste Requisition System is available at or by clicking “Hazardous Waste Req” on the Quick Links section of the LBNL Waste Management Web page. It is also available on the “A to Z” index. Look under “H” for “Hazardous Waste Requisition.” The online user manual will guide you through all the information necessary to notify us that you have waste ready for pickup. If you have any questions or problems, please contact your Generator Assistant.

The Electronic Hazardous Waste Requisition System allows waste-generator designees to enter information into the database. The information is then sent to the waste generator for review and certification. The waste generator may also enter data about his or her own waste.

Please be sure to accurately identify your waste. The Waste Management Group makes important treatment and shipping decisions that may increase Berkeley Lab’s liability if the waste is mischaracterized. Electronically sign the requisition indicating that, to the best of your knowledge, the chemical composition is complete and correct. The discovery of inaccurately characterized waste by a regulatory agency could result in fines and/or criminal penalties for the Laboratory, and could jeopardize the operation of the HWHF and the specific research project involved.

Generators who make characterization errors that could compromise Berkeley Lab's commitment to protect the environment, the safety of colleagues, and other LBNL staff may be required to pay for certified analytical information for all their hazardous waste in the future. For more information on inaccurate waste characterization, please see Section 1.8 (Quality Assurance Testing).

Once you have submitted your electronic requisition, label any supporting documentation, such as the accumulation log or analysis results, with the “Q” number that appears on your hazardous-waste requisition receipt, and fax it to Waste Management at ext. 4838. Waste from a Radioactive Materials Area

There are three steps to determining that hazardous waste from a Radioactive Materials Area (RMA) is not radioactive:

Step 1. If this waste is from a Radioactive Materials Area, then your hazardous waste must be certified by the generator to be free of internal radioactive contamination before the waste can be removed. By signing the RMA waste certification form (Figure 1-9), you certify that you have not added any radioactive material to this waste as a part of your process. This completed form will be faxed to Waste Management with any other information about your hazardous waste. Note that naturally occurring radioactive material (NORM) that has not been added as part of your process may be certified as nonradioactive.

Step 2. As part of the RMA release process, your Radiological Control Technician (RCT) will survey the outer surfaces of the container and attach a “green” release tag no more than 48 hours prior to pickup. This survey assures the Waste Management Group that the outer surfaces are not radioactively contaminated..

Step 3. After the waste is picked up, a minimum of one container of a sampleable matrix will be internally sampled for radioactivity as part of a quality-assurance check.

If you cannot certify that your waste is free of radioactivity (other than NORM), additional testing and analysis of the waste will be needed. Since your waste might require sampling and analysis, please allow an extra two to four weeks for pickup. If you cannot certify that your waste is free of radioactivity, submit your hazardous-waste requisition form to the Waste Management Group early enough to comply with the 275-day accumulation time limit.


Figure 1-9. A completed RMA waste certification form.


1.5      Universal Wastes

Universal wastes include batteries, fluorescent lamps, aerosol cans, mercury-containing equipment, electronic devices, cathode-ray tubes, and broken cathode-ray tube glass. Because properly managed universal waste poses a lower immediate risk to people and the environment, section flag it section flag can be handled and transported under more relaxed rules than hazardous wastes. However, universal wastes do contain hazardous materials and must therefore be taken to a designated handler or recycler and processed in compliance with universal waste regulations.

1.5.1 Batteries

Waste Management provides green collection buckets for used nickel-cadmium; nonspillable, nonleaking lead acid; and alkaline batteries. Place your batteries in the green collection bucket (Figure 1-10). All 9-V batteries and batteries with terminals on the same side must have the leads taped to prevent the possibility of fire or sparking. The buckets are emptied once per quarter or as needed. Automotive batteries (lead acid) can be sent to salvage as long as the caps are intact and the body is not damaged or cracked. Only batteries should be placed in the green bucket. Other items such as computer parts or mercury-containing devices present safety hazards and should be collected elsewhere.

If you have leaking lead-acid batteries, these are regulated as hazardous waste and must be requisitioned in the normal process.

Figure 1-10. A used-battery collection bucket.


1.5.2 Fluorescent Lamps

Lamps such as fluorescent, neon, mercury vapor, section flag high-pressure section flag, sodium, metal halide, and high-intensity discharge are also examples of universal waste. At section flag Berkeley Lab section flag on-site locations, employees can contact the Facilities Work Request Center to manage any lamp.

At Berkeley Lab off-site locations, room lights are managed by the landlord. Burned-out lamps of section flag Laboratory-owned section flag equipment located at off-site, section flag Laboratory-leased section flag facilities are managed by Waste Management (call ext. section flag 4644 section flag or 6337, or your Generator Assistant for assistance). The lamps must be protectively packaged to prevent breakage, and labeled with a universal-waste label.

1.5.3 Aerosol Cans

Waste aerosol cans are managed as universal waste and no longer require hazardous-waste labeling, requisitions, etc. These aerosol cans are primarily used in Facilities and Engineering divisions and contain paints, degreasers, lubricants, penetrants, glass cleaners, etc. Collection points for Engineering and Facilities staff have been identified; however, if you are outside of these organizations and have an aerosol can you wish to dispose of, contact your Generator Assistant or Waste Management (ext. section flag 4644 section flag or 6337) for instructions. Note that aerosol cans with pesticides, herbicides, or catalysts cannot be managed as universal waste and must be submitted through the hazardous-waste  requisition process.  

1.5.4 Mercury-Containing Equipment

Unbroken thermometers, mercury-containing switches, thermostats, and other mercury-containing equipment should be placed in a container with packaging material to prevent breakage and labeled with a universal-waste label. A waste requisition is not required. Notify either your Generator Assistant or the Waste Management Group (ext. section flag 4644 section flag or 6337) for pickup. Store in a safe location until pickup.

1.5.5 Electronic Devices, Cathode Ray Tubes (CRTs), and CRT Glass (from Broken CRTs)

Electronic devices include telephones, cash registers, computers, computer peripherals, stereo equipment, videocassette players/recorders, tape players/recorders, compact disc players, recorders, calculators, microwave ovens, etc. In general, if a nonfunctioning item has a printed circuit board, it is e-waste. Examples of section flag CRTs section flag are computer monitors, oscilloscopes, and televisions.

At Berkeley Lab, we provide “reuse and recycle” services at Buildings 904 and 79. However, at this time, only fully functioning units can be reused.

For nonfunctioning electronic devices:

  • Apply a universal-waste label (Figure 1-11) to the nonfunctioning item. Label the item as “Universal Waste — Electronic Device(s)” or “Universal Waste — CRTs” when applicable.
  • If the item has a section flag Berkeley Lab/DOE section flagproperty-number sticker, fill out a Facilities Work Request; the Facilities Division will remove the item from your property record.
  • If the nonfunctioning item does not have a DOE property number, contact the Waste Management Group (ext. section flag4644 section flagor ext. 6337).

For functional and reusable electronic devices:

Figure 1-12 outlines whom to call for pickup of your unwanted electronics.

Never leave electronics or universal waste outside without adequate containment or cover.

Remember to follow your division’s process to remove the item from your property record.

Should you accidentally drop a cathode-ray tube and break the glass, safely sweep section flag up section flag the broken glass, contain it in a sturdy container, and label it as “Universal Waste — Broken CRT Glass.” This waste stream is managed by the Waste Management Group (call ext. section flag 4644 section flag, 6337, or your Generator Assistant).


Figure 1-11. A properly completed universal-waste label.



section flag

Figure 1-12. Process for managing electronic waste and cathode-ray tubes. Workrequest URL  section flag

Figure 1-12. Process for managing electronic waste and cathode-ray tubes.




Figure 1-13. Nonfunctioning CRTs such as computer monitors should be disposed of as e-waste.



Figure 1-14. Nonfunctioning section flag electronic devices section flag such as microwave ovens should be disposed of as e-waste.



1.6      Special Wastes

1.6.1     Empty Containers

Certain empty containers that previously held hazardous materials are exempt from hazardous-waste regulations and can be discarded as solid sanitary waste (trash) under the following conditions:

  • The container must be <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, uniform layer of dried material or powder.

If your container meets the criteria listed above, the container may be thrown in the trash, and the following steps must be completed:

1.       The container must be deleted from the Chemical Management System, and the bar code must be removed from the container.

2.       The original label must be crossed out or marked with the word “EMPTY” to notify custodial staff, recyclers, or sanitary-waste engineers that it no longer contains hazardous materials, and can be discarded as solid sanitary waste.

The decision tree shown below in Figure 1-15 can assist you in deciding how to properly dispose of your empty container.

1.6.2     Polychlorinated Biphenyls (PCBs)

Before federal regulations limited PCB production and use, PCBs were commonly used in a variety of commercial products, including:

  • Adhesives
  • Liquid-filled cable
  • Transformers
  • Gasketing and dampening felt
  • Large high- and low-voltage   capacitors
  • Switches and electronic equipment
  • Liquid-cooled electric motors
  • Voltage regulators
  • Hydraulic systems
  • Vacuum pumps
  • Heat-transfer systems
  • Microwave ovens
  • Fluorescent light ballasts
  • Microscopy mounting media
  • Electromagnets
  • Immersion and optical oils


These uses of PCBs are no longer authorized under federal and state regulations; however, PCB use is allowed under specific conditions, in limited scenarios. Waste generators must remember that old equipment might still contain PCBs, even if it has been flushed out several times. If a piece of oil-containing equipment is to be disconnected and not reused, please contact Waste Management early in the planning stages so we can set up the WAA and arrange shipment to meet regulatory requirements.

If the waste is known to have PCBs ≥50 parts per million (ppm) or contains waste from a PCB spill, the accumulation time in the generator SAA/WAA is 30 days (Ref: 40 CFR 761.65 (c)(1))

All high-risk oils will be tested at the HWHF for PCBs prior to shipment off site for treatment and disposal. When preparing a requisition for waste oil, please note whether the oil contains known or suspected PCBs.

Figure 1-15. The decision tree for the management of empty containers.

1.6.3     Over-the-Counter Drugs, Pharmaceuticals,
or Controlled Substances

While not common, some divisions use over-the-counter drugs, pharmaceuticals, or controlled substances in their research or operation. Regardless of their use, the disposal of the unused portion of these items is strictly controlled. Waste Management maintains a contract with a registered disposal company. If you have these items, please contact your Generator Assistant for more information. For additional information on the management of controlled substances, please refer to the Controlled Substances Protocol.

1.6.4     Epoxy Materials

As obtained by the manufacturer, epoxy materials come in two parts. In most instances, Part A is the resin, and Part B is the hardener. Once blended together, any excess, unused material is nonhazardous and can be disposed of in the sanitary trash. If there are unwanted, unused portions of the Part A and Part B materials remaining in the original containers, these require management as hazardous wastes. If the Part A and Part B are in separate containers, bag them separately and manage each as hazardous wastes in your SAA. If they are in a single unit, be sure to secure the stopper in place to prevent comingling of the resin and hardener. Place the unit in a bag and manage it as hazardous waste.

1.6.5     Waste from Subcontractor Activities

Regulated hazardous waste generated as a result of subcontractor activities such as lead and asbestos removal must be managed by LBNL to assure proper treatment and disposal.  If you anticipate that a subcontractor will generate either hazardous or universal wastes, please contact your Generator Assistant.

1.7      Waste Review Process                                  

When your requisition, accumulation log, and supporting documentation are received by the Waste Management Group, the information you’ve provided will be entered into our tracking system and reviewed by your Generator Assistant. She or he will be looking for completeness and accuracy based on your accumulation log. She or he will assign the proper verification sampling, HWHF storage location, and waste stream based on this information. Once the review is complete, the waste pickup will be scheduled according to the pickup schedule for your building.

1.8      Quality Assurance Testing                            

Each item entering the HWHF is subject to random verification sampling. A computer-generated random-selection program chooses which wastes will be sampled for verification of the generator’s characterization. If, on review of the laboratory analysis results, it is determined that there is a discrepancy between the generator’s characterization and the analysis results, you will be contacted by your Generator Assistant.


[1] Surplus, unused flammable liquid in the original manufacturer’s container is acceptable.