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A Guide to California’s Hazardous Materials Business Plan Program

Introduction.

California is home to a diverse range of industries, many of which handle hazardous materials as part of their operations. Manufacturers may use hazardous chemicals as raw materials throughout their production processes or produce them, construction companies use hazardous solvents, and oil and gas companies involved in extraction or refining of oil and gas use a variety of regulated hazardous chemicals such as diesel fuel. These use cases, as well as others within the agriculture, automotive, and healthcare industries among others are all around us, helping to provide us the creature comforts we’ve come to appreciate. 

Ensuring the safety of these operations and the well-being of the surrounding communities is of paramount importance to California’s governing bodies, and the Hazardous Materials Business Plan (HMBP) Program is a key initiative designed to achieve this goal. In this blog post, we will provide a comprehensive overview of California’s HMBP Program including: how to comply, common challenges during compliance, and potential exemptions.

Understanding California’s Hazardous Materials Business Plan Program

The Hazardous Materials Business Plan (HMBP) Program is a state-mandated program that aims to protect public health, safety, and the environment by ensuring that businesses handling hazardous materials in California have adequate emergency response and training plans in place. These plans outline how hazardous materials are stored, handled, and disposed of, in addition to providing crucial information to first responders in the event of an emergency, so that they can respond in the safest and most effective manner. 

The California Environmental Reporting System (CERS) serves as the central reporting portal for HMBPs, which allows businesses to electronically submit their HMBP information, ultimately delivering it to the relevant Certified Unified Program Agencies (CUPAs).

The HMBP Program is implemented statewide in California, and compliance is enforced by the local CUPAs. Businesses located in different regions of the state will submit their HMBPs to the appropriate local CUPA, which will then review the plans and conduct inspections to ensure compliance with HMBP. In order to ensure compliance, organizations may consider implementing enterprise compliance software .

What are the steps to maintain compliance with California’s Hazardous Materials Business Plan Program?

There are several steps that businesses must follow to meet hmbp compliance requirements: .

• Identifying hazardous materials: The first step towards compliance is for businesses to identify and inventory all hazardous materials present at their facility.
• Developing an HMBP: Once a business has identified all hazardous materials on site, they must complete the HMBP that outlines business activities, facility information, hazardous materials inventory, site map, emergency response plan, and an employee training program.
• Submitting the HMBP to the local CUPA: Businesses must submit their HMBP to the appropriate local CUPA via the California Environmental Reporting System (CERS) by the applicable due date.
• Facility inspections: Local CUPAs conduct regular inspections of facilities to verify HMBP compliance and ensure that businesses are adhering to safety standards, meaning that an organization must maintain ongoing compliance.
• Updating the HMBP: Dependent upon the facility’s operations, businesses must review and update their HMBP annually, once every three years (if the facility is not regulated under EPCRA or APSA), or whenever there are significant changes to their hazardous materials inventory or processes. These requirements can also change based on the CUPA’s discretion.
• Employee training: As part of HMBP compliance, businesses must provide ongoing training to employees responsible for handling hazardous materials or responding to emergencies.

While this list covers the requirements of the program, it is an exhaustive list of activities, as each individual requirement may necessitate many additional steps. Working with an expert to identify exactly what your business needs to comply is a great way to get started.

What are the challenges of complying with HMBP?

As you may have guessed, each of the above requirements can present many challenges to organizations, which are made up of many different functions and departments that may experience turnover, etc.

Some common challenges organizations face are:

• Keeping up with regulatory changes: The regulations governing hazardous materials are constantly evolving to address new risks and improve safety standards. Businesses must stay up-to-date with these changes to ensure ongoing compliance with HMBP requirements.
• Accurate identification and inventory management: Properly identifying and tracking hazardous materials can be a complex task, especially for businesses that handle a large variety of chemicals or experience frequent changes in inventory. Implementing enterprise software can help businesses maintain accurate records and comply with HMBP requirements.
• Developing and maintaining a comprehensive HMBP: Creating a plan that addresses all required elements, including facility information, an inventory of hazardous materials, a site map, an emergency response plan, and an ongoing employee training program, can be time-consuming and challenging. Businesses may need to invest in training or hire experienced professionals to ensure they maintain HMBP compliance.
• Ensuring employee training and awareness: Training employees on the safe handling, storage, and disposal of hazardous materials, as well as emergency response procedures, is essential for HMBP compliance. However, employee turnover, time constraints, and a lack of training resources can make it difficult for businesses to maintain a well-trained workforce.
• Navigating local variations: The implementation and enforcement of the HMBP Program can vary between local CUPAs, leading to differences in requirements and interpretations of the regulations. Businesses operating in multiple jurisdictions may find it challenging to navigate these variations and ensure compliance across all locations.

It’s critical to note that, regardless of how challenging the company’s situation, it doesn’t mean they’re exempt from complying with HMBP.

So, what can be done? To help overcome these challenges, organizations should consider the following:

• Designate a compliance officer or team responsible for staying up-to-date with regulatory changes and ensuring that the HMBP is revised accordingly.
• Implement software to accurately track hazardous materials and maintain up-to-date records.
• Invest in training or software to develop and maintain a comprehensive HMBP that addresses all required elements.
• Allocate resources for ongoing employee training and establish a system to track and document training completion.
• Consult with local CUPAs to understand any variations in requirements and ensure compliance across all locations.

Are there any exemptions to the Hazardous Materials Business Plan Program?

Certain businesses may be exempt from the HMBP requirements based on specific criteria. While this post includes a list of exemptions, you should always check with your local CUPA to confirm subjectability to regulations.

Some common reasons a facility may be exempt from complying with HMBP are:

• Small quantities of hazardous materials: Businesses that handle hazardous materials below specified threshold quantities may be exempt from HMBP requirements.
• Retail facilities: Retail facilities that primarily sell hazardous materials to the general public for personal, family, or household purposes may be exempt from HMBP requirements.
• Temporary storage: Businesses that temporarily store hazardous materials during transportation and do not store them at a facility for more than 30 days may be exempt from HMBP requirements.
• Household hazardous waste collection events: Facilities or events that collect household hazardous waste from the public for proper disposal or recycling may be exempt from HMBP requirements.

California’s Hazardous Materials Business Plan Program and the California HMBP re is a vital initiative designed to protect public health, safety, and the environment from the potential dangers posed by hazardous materials.

By understanding the program’s requirements, implementation, and compliance processes, businesses can effectively participate in the HMBP Program and contribute to the safety of their communities. Although there are some exemptions to the HMBP requirements, it is crucial for businesses to consult with their local CUPA to ensure they fully understand their obligations.

California’s HMBP Program serves as a comprehensive framework for businesses to safely manage hazardous materials and mitigate the associated risks. By adhering to the program’s guidelines, businesses not only fulfill their legal obligations but also promote a safer and more sustainable environment for all Californians. To learn how Encamp can help your organization maintain compliance with HMBP, drop us a line here .

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How To Create A Hazardous Materials Business Plan

A Hazardous Materials Business Plan (HMBP) is an important document that contains information about hazardous materials used on site at a facility. 

In California, some companies are required to create a hazardous materials business plan, depending on the amount or type of hazardous waste on the facility’s premises. 

The purpose of this plan is to provide important information about hazardous materials on site to first responders when there is a threat to public health and the environment. It also satisfies federal and state Community Right-to-Know Act laws that require industries to report on the storage and use of hazardous materials.

If your company is required to create an HMBP based on how much hazardous waste that is generated in your facility, below are the steps you will need to take to meet federal, state and local laws. 

Know Your County’s Specific Requirements

• 55 gallons in liquid form
• 500 pounds in solid form
• 200 cubic feet of compressed gas

Your facility must also create a HMBP if the materials being used are considered to be “extremely hazardous substances,” per Section 355.61 of Title 40 of the Code of Federal Regulations.

Additional state and federal requirements are outlined in this Governor’s Office of Emergency Services document . It’s important to note that some counties in California have stricter requirements such as the amount of a chemical that must be included in a facility’s plan. Facilities located in counties that do not have threshold amounts can refer to the California Health and Safety Code for guidance.

Compile And Submit The Plan

California’s Health and Safety Code establishes standards that must be included in a HMBP. Because local authorities may have additional requirements, it is important to check with your local government agency to determine any additional components that must be included in a plan.

In general, HMBPs include four elements:

• Business activities and owner identification
• Hazardous material inventory
• An emergency response plan and employee training

Business Activities And Owner Identification

This part of your HMBP should be pretty straight-forward and is a form found in the facility information section of the California Environmental Reporting System (CERS). This form includes business activities conducted at the facility, as well as information about the owner/operator. 

Hazardous Material Inventory

This portion of your HMBP is a list of all the hazardous materials present at your facility that are subject to reporting. These inventory forms must be completed and submitted through CERS as well. 

Your list must include all hazardous substances on site and stored in underground tanks. One way to recognize any inventory that is hazardous is by the Safety Data Sheets (SDS) that are provided by the manufacturer, as required by law. SDS documents contain:

• The substance’s chemical composition
• Fire and explosive potential
• Any health hazards
• Reactive characteristics
• Emergency procedures
• Special protection and precautions that should take place

Reported inventory also must include extremely hazardous substances that are in quantities equal to or greater than the “Threshold Planning Quantities,” which are established in the Federal Register or on the EPA website.

Facilities must develop a site map in the event that an emergency occurs and responding personnel must locate hazardous materials. This map, which must be submitted to Certified Unified Program Agencies (CUPA) through CERS, should include items such as: 

• Loading areas
• Internal roads and adjacent streets
• Storm and sewer drains
• Access and exit points, including driveway entrances and parking lots
• Emergency shutoffs
• Evacuation staging areas
• Hazardous material handling and storage areas
• Fire hydrants and other connections
• Emergency response equipment, such as fire extinguishers and spill kits

Indicate on the map the North direction, and be sure to label any adjacent properties, especially if they are schools, parks or residential areas.

Check with your local county for rules on using color versus black and white, and whether there are any requirements on whether maps must be drawn on a computer or by hand.

Emergency Response Plan And Employee Training

This portion of the HMBP outlines the facility’s emergency training program and a plan that should be put into action if an emergency occurs. 

According to the Health and Safety Code, employees should be trained in disaster preparedness when they are first hired and should be given annual refresher training courses.

Training programs should ensure employees are familiar with the facility’s emergency response plan and should include notification procedures should an emergency occur. The facility’s emergency response plan should include procedures to mitigate harm to employees, the public and the environment.

Not having a proper plan in place can be costly and lead to major fines. Our article, No Hazardous Waste Contingency Plan Leads To Big Fine For Manufacturer , shows why it is important to adequately train staff and have an emergency plan in place.

Review Accuracy 

Businesses change, and so may the amount of hazardous materials stored on site. After initially submitting a HMBP through CERS, companies should review the accuracy of their plan on an annual basis. 

This is important because any change in hazardous material use or location could impact an emergency response.

Government hazardous materials divisions that inspect facilities will compare materials on site with what is outlined in the HMBP. If any parts do not align, a facility will need to update its HMBP within a certain time period or face fines. 

A Critical Component

Facilities that generate hazardous waste and store hazardous materials on site are responsible for these substances from the moment they are generated to their final disposal . Called cradle to grave , this responsibility is critical to ensure the safety of the public and environment. 

Creating a hazardous material business plan is a critical component of this requirement since it outlines information about each substance at the facility in the event an emergency occurs. Not having an HMBP can be costly - not only to your facility in the form of fines, but to the safety of employees and first responders as well. 

If you need help, contact a hazardous waste disposal company. They can help you create a plan and review your processes to make sure you aren't in violation of any regulations. 

§ 2650. Purpose. [Renumbered]

19 ca adc § 2650 barclays official california code of regulations.

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Frequently Asked Questions About Hazmat Training

Why do i need to comply with hazmat shipping regulations.

Between the inherent hazards of the job and the repercussions of violating federal training regulations, regular hazmat training is a clear necessity. CHEMTREC's online hazmat training helps meet training requirements by keeping industry professionals informed of changing regulations and updated on required practices for handling, shipping, and packaging of hazardous materials.

Companies must comply with hazmat shipping regulations to arrange the safe transport of hazardous materials, protect the public's safety and the environment, and to facilitate efficient emergency response in case of an incident. Non-compliance can result in severe consequences including legal penalties and reputational damage. 

Since the need for proper education before handling, packing, shipping, or transporting hazardous materials is so important, the U.S. Department of Transportation issues training regulations under the Pipleline and Hazardous Materials Safety Administration's Title 49 of the Code of Federal Regulations (49 CFR). 

Who needs hazmat training?

Every employer that deals with materials regulated under the U.S. DOT Hazardous Materials Regulations in any way is responsible for training its own employees, with no exceptions for the size of the business. Even a self-employed individual under these guidelines must comply with training requirements.

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DOT Hazardous Materials Transportation Training: Online Certification Course

Our online DOT Hazmat course covers the fundamentals of shipping hazardous materials by ground. Our 10-step approach encompasses the activities which must be addressed when preparing a hazardous material for shipment. Participants will learn how to classify hazardous materials, select proper packaging, mark and label containers, and prepare required shipping documents, all in accordance with the USDOT regulations. New requirements enacted over the past year are highlighted throughout the course. The USDOT requires training for anyone who handles hazardous materials, including individuals who ship or receive hazardous materials, prepare hazardous materials for transportation, mark and label containers, complete shipping documents, select packaging and load or unload hazardous materials. This hazardous materials shipping training course is designed to meet the training requirements as specified in 49 CFR 172.700 Subpart H, which specify that employees must be trained at least once every three years. At the completion of the course, participants will receive a certificate which includes the participant’s name, completion date, and copy of the test scores. The certificate includes the name and address of the trainer as required for recordkeeping. Our DOT training course is based on the requirements for training as specified in 49 CFR 172 Subpart H, including testing of participants. This hazmat training is also referred to as HM-181 training, Subpart H training, and hazmat training. While this course is meant to satisfy DOT's general training requirements, it does not go into detail on the shipping of radioactive materials. This course does not cover driver training as required for each hazmat employee who will operate a motor vehicle.

DOT Hazmat Training Course Details

This DOT hazmat training course will prepare you to safely transport hazardous materials by ground, providing comprehensive information on safety precautions and regulations. Providing real-world industry examples, multimedia presentations, and interactive activities, the course will equip you to handle all hazmat training scenarios.

When you complete the course, you will receive a certificate indicating compliance with the DOT Hazardous Material training requirement. This DOT hazardous materials transportation course also fulfills the DOT Hazmat refresher requirement.

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Hazardous materials (hazmat) training now applies to any individual who:

DOT hazardous materials transportation training is essential for any individual who is involved with hazmat transportation at any stage. Whether you are preparing, processing, loading, managing, or actively transporting hazardous materials, you must complete DOT hazmat training, otherwise known as HM-181 or HM-126 training.

Eduwhere’s course satisfies DOT training requirements for hazardous material shipping training in accordance with the agency’s regulations for hazmat employees. When you complete our course and pass the associated test, you can rest assured that you are in compliance with national safety standards and prepared to transport hazardous materials.

Do You Ship Hazardous Materials?

According to the DOT, a hazardous material is "a substance or material that is capable of posing an unreasonable risk to health, safety, and property when transported in commerce, and has been designated as hazardous under the federal hazardous materials transportation law."

You may be surprised to learn how many materials fall under this definition. Under the umbrella of hazardous waste, you’ll find not only obviously dangerous materials such as explosives and flammable substances, but also everyday items such as aerosols, house paint, pesticides, and cleaning solutions. Electronic items such as computer components also often qualify.

Whether you’re working directly with a company that directly transports hazmat or for a third-party delivery service such as UPS or FedEx that occasionally ships hazardous materials, you likely need hazardous material shipping training. Failure to complete required DOT hazmat training and pass the exam may make your company liable in the event of a shipping accident that results in personal injury or environmental damage. By completing Eduwhere’s DOT hazmat training course, you’ll cover all the bases and set yourself up for career success.

Do You Prepare Hazardous Materials for Transportation?

DOT hazmat transportation training is essential for employees who package, label, mark, or otherwise prepare dangerous materials to be shipped. Attention to safety during each part of the shipping process is essential to carry out hazmat transportation best practices, so all individuals who perform preparation tasks are required to complete training.

Do You Receive Hazardous Materials in Your Department?

If you work in a shipping or receiving department that handles hazardous materials, you likely need hazardous material training even if you don’t directly transport the materials. If you play any part whatsoever in the process of hazmat shipping–signing off on paperwork, or receiving incoming shipments, for example–you are required to complete DOT hazardous materials transportation training.

Industries that Require DOT Training Courses

Curious if your profession will require DOT training for hazmat transportation? Employees in a diverse set of industries are required to pass DOT hazmat training courses. These include:

If you’re considering changing professions or starting your own business in an industry such as these, find out whether DOT hazmat training certification will be required. As a job candidate, having this certification will make you an attractive candidate for numerous positions. If you’re a business owner, you can build a strong reputation by requiring employees to be certified and thus avoiding fines or other consequences in the event of an accident.

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Course Objectives

Upon completion of this online course, participants should be able to:

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Contact hours.

4 Contact Hours This represents the estimated time to complete the online course, including exercises. Actual times may vary from user to user.

Training Requirement

Citation: 49 CFR 172.704 (Subpart H)

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Refresher Training Required: Every 3 year(s).

Why Choose Eduwhere for Your DOT Hazmat Training Classes?

Hazmat training is a must for compliance with DOT and OSHA standards for safety. For over 25 years, Eduwhere has been a leader in online compliance training. As pioneers of online education, we know what it takes to make online courses as successful as their in-person counterparts. We know that there’s no room for shortcuts when it comes to safety, so you can rest assured that our DOT hazmat training course will prepare you for any contingency.

Whether you work in shipment preparation, transportation, or receiving of hazardous materials, you must pass the required safety courses. When you complete your HM-181 or HM0126 course, you’ll have the tools you need to excel in your professional role.

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Is this course "certified" by the dot, but i've seen dot "certified" courses elsewhere... what's up with that, if i take this course, will i be certified, your dot hazardous materials transportation course is 4 contact hours. is this comparable to the 2 day dot course other providers offer.

The course fee entitles a single user to participate in the online course for at least six (6) months. Requests for additional time will be considered on a case-by-case basis, but are almost always honored. Hardcopy certificates are mailed (first class for domestic locations/standard airmail for international locations) and included in the course fee. Expedited shipping costs are additional.

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Part 400: Hazardous Materials Disposal Procedures

400.01 General

400.05 Unacceptable Hazardous Materials Management Practices

400.10 Special Accumulation and Packaging Instructions

Table 2: Special Accumulation and Packaging Requirements

400.20 Hazardous Materials Container Selection

• 400.30 Accumulation and Storage

400.40 Chemical Waste Disposal Request Completion Procedures

400.50 Hazardous Materials Collection by EHS

400.55 Hazardous Waste Inventory

400.60 Used Oil Disposal Procedures

400.70 Lead-acid Battery Recycling/Disposal

400.80 Universal Waste Handling Procedures

400.90 Hazardous Household/Consumer Commodities Disposal Procedures

• Following these procedures will help ensure that containers of hazardous materials are properly labeled, containerized and stored according to state and federal hazardous waste regulations. Adhering to these procedures will also help expedite the safe collection and disposal of hazardous materials by EHS personnel.
• First investigate whether or not processes using hazardous materials can be eliminated; or determine if alternative methods exist for processes that do not use hazardous materials.
• Attempt to reduce the quantity, toxicity or other hazardous characteristic of materials being generated from processes that cannot be eliminated or substituted for by an environmentally safe process.
• Evaluate hazardous materials characteristics to ensure that incompatible materials are not combined or stored near one another.
• Do not dispose hazardous materials to the sanitary sewer system, atmosphere (i.e., evaporation), or solid trash receptacles (please see Part 400.05 - Unacceptable Hazardous Materials Management Practices).
• Insure that proper containers are available to accumulate each waste stream in advance of actually conducting research, analyzing samples or starting a chemical process.
• Properly label containers with words that accurately identify each container's contents.
• Keep track of accumulations to the container (all constituents and their concentrations). A log book with entries referenced to unique container numbers is helpful.
• Containers must always be kept closed between accumulations.
• Minimize the accumulation of hazardous materials in your area by submitting materials and full containers promptly to EHS for disposal. Never accumulate more than 55 gallons of hazardous materials or one (1) liter of acute hazardous waste in a given area.
• Submit all chemicals and hazardous materials to EHS for final characterization, collection and proper disposal.
• Disposal - The disposal of hazardous wastes to the sanitary sewer system, a solid waste receptacle, or directly to the environment ( including evaporation ) is illegal. EPA regulations require that generators determine (either by knowledge or through chemical analysis) whether or not a material is a hazardous waste before it is discarded.
• Transport - Do not deliver discarded hazardous materials to the EHS office, either in person or via campus mail. Delivery of discarded hazardous materials to the Hazardous Materials Storage Building (HMSB) is also not authorized. These materials will be returned to the individual, and will not be accepted for collection until proper protocols have been followed.
• Treatment - Treating hazardous waste to reduce its toxicity or make it less reactive without an EPA permit and/or a “waste analysis plan” is a violation of EPA regulations. Treatment includes but is not limited to heavy metal precipitation and oxidation/reduction. NOTE - simple neutralization of corrosive materials is allowed, as long as no other constituents (e.g., toxicity characteristic (TC) materials or spent solvents) are present in the waste stream that would make it a hazardous waste even if neutralized. Report quantities of corrosive materials neutralized to EHS.
• Waste Stream Dilution/Evaporation - The dilution or evaporation of hazardous waste to "lessen" its toxicity is not permitted by the EPA. Hazardous wastes containing characteristic waste constituents above TCLP regulatory levels cannot be diluted or evaporated down to below regulatory levels and disposed of to the sanitary sewer system. (e.g., a 2 mg/L mercury solution cannot be diluted to below 0.2 mg/L and discarded to the sewer system for disposal. Also, a material containing benzene CANNOT be allowed to evaporate in order to achieve benzene concentrations below regulatory levels).
• Storage - Storing more than 55 gallons of hazardous waste and/or one kilogram of acute hazardous waste (P-listed waste) in a given storage area is not allowed. Removing waste from one room or building to another room or building without approval from EHS personnel is also not allowed. Hazardous materials must be stored in a physically sound and chemically compatible container with its closure on at all times (see (1) above) between accumulations and during storage.
• Due to reactivity, toxicity, and disposal restrictions, certain materials can only be accumulated in certain size containers or must be packaged to reduce a potentially violent reaction or prevent exposure to water, air and/or personnel. Table 2 lists hazardous materials requiring certain stipulations that must be followed to facilitate their collection and disposal.

• Properly preparing hazardous materials will help facilitate their safe and expedient collection and disposal by EHS personnel and meet applicable state and federal regulations.
• Proper Containers - A proper container is one that has retained its integrity and can be sealed tightly. Containers should be resistant to chemical degradation and corrosion. Liquids must be stored in containers designed for liquids, not solids.
• Openings - Containers must not have a spigot (e.g., carboy), valve, or other opening in addition to the main opening on top.
• Plastic Bags - Plastic bags are not acceptable as primary containers for the containment or storage of hazardous materials or wastes. They can only serve as secondary containment. Plastic bags can never be used to contain sharps (see (v) below).
• Liquids - Use containers designed to hold liquids (i.e., wide mouth containers that were manufactured for solids should not be used for the containment of liquid waste).
• Solids - Containers holding solids must be capable of forming a tight seal. Containers not forming a tight seal must be transferred into a new container capable of forming a tight seal, or over-packed in another proper container.
• Sharps - Sharps (e.g., needles, broken glass, wire, razor blades, etc.) must be contained in strong, tight, puncture-proof containers. Plastic bags are not acceptable;
• Gas Cylinders - Gas cylinders must have their valve protection caps included for disposal purposes. Leaking cylinders will not be collected by EHS personnel, but must be evaluated for safe disposal options. Contact EHS if you discover a leaking cylinder.
• Container Size - Plastic and metal containers up to five gallons in size, and glass containers up to one gallon in size are acceptable for routine liquid and solid hazardous materials collection and disposal. Larger sized (e.g., drums and barrels, etc.) containers require prior approval from EHS personnel before being used to contain hazardous materials.
• Closures - Containers containing liquids must have screw cap closures that form a tight seal. Stoppers, septums, wax paper, etc., are not acceptable as closures and such containers will not be collected until the contents have been transferred to a proper container.
• Surface Contamination - All containers must be relatively void of chemical residue on the surface. Contaminated or excessively dirty waste containers will not be collected for disposal until cleaned.
• Mineral Bases - Sodium hydroxide, etc., are usually best stored in glass or plastic containers without glass stoppers.
• Mineral Acids - Hydrochloric acid, sulfuric acid, etc., are best stored in glass or heavy plastic containers, depending on the material’s compatibility with glass and plastic. Exception: hydrofluoric (HF) acid, which attacks glass, must be collected and stored in plastic containers.
• Chlorinated Organic Solvents - Methylene chloride, chloroform, etc., are best stored in glass containers.
• Polar Organic Solvents - Acetone, ethanol, etc., are ideally stored in glass or metal containers. However, plastic may be acceptable for short term storage.
• Non-polar, Non-chlorinated Organic Solvents - Hexanes, ethyl ether, benzene, etc., are best stored in glass or metal containers. Avoid plastic containers.
• Organic Peroxides - Benzoyl peroxide, etc., are usually stored in plastic containers. Check with the manufacturer's recommendations for the specific material you are using.
• Oxidizers - Potassium permanganate, sodium nitrate, bleach, etc., are best stored in glass containers. Note: Avoid containers with metal caps for the containment of corrosive materials. Many waste streams and hazardous materials will have mixtures of the above wastes; when in doubt use glass containers.
• Rinse "empty" containers first with acetone or other appropriate solvent (these rinsates will most likely be hazardous waste and must be submitted to EHS for disposal);
• Rinse with water if acetone was used in step one (1), or rinse with acetone, then water if a different organic solvent was used [combine with rinsates from step one (1)];
• Allow the container to thoroughly drain into the waste collection container for the rinsates. The reagent container is thoroughly drained when rinsate ceases dripping from the inverted container; then,
• Air dry the reagent container.
• Rinse container thoroughly with water (or appropriate solvent) followed by acetone and then again with water (submit rinsates for disposal);
• Air dry the container.
• If chemical residue is still evident, repeat steps above.
• Deface the label and other markings on the original container.
• Reuse for waste containment, discard as normal trash, or donate to EHS personnel.
• Make sure the cylinder is empty (atmospheric pressure);
• Remove the valve;
• Rinse cylinders out with an appropriate solvent, collecting the rinsate as a hazardous waste;
• Deface the label(s) and other markings;
• Recycle the metal.
• Proper accumulation and storage of hazardous materials will be determined by the material's toxicity, physical and chemical characteristics, space availability, and convenience. Space availability and convenience factors should not dictate storage locations at the expense of safety.
• Adequate Chemical Descriptions - Example, use "potassium permanganate" instead of just "permanganate" ; or "lead nitrate" instead of just "Pb +2 " ; do not use acronyms, chemical formulas, etc.
• Constituent Concentrations - Note the concentrations for each constituent in percent (%) or parts per million (ppm) and total quantity of each addition to the container to calculate final concentrations of each constituent in the material.
• Accumulation - All containers must remain closed between accumulations (i.e., an open container with a funnel resting in its mouth is not considered closed by EPA regulations).
• Location - Waste must be stored within the same area, laboratory or room that it was generated.
• Quantity Limitations - No more than 55 gallons of hazardous waste or one (1) liter of acute hazardous waste can be accumulated in any one area.
• Secondary containment - Use secondary containment, such as a small plastic tub, to hold the waste containers. Segregate by compatibility groups (see Section 620.10).
• Full Containers - When the container is full (leave room for expansion), calculate the concentrations for all constituents.
• Disposal Request - Complete an online waste disposal request for the container, and submit it as soon as possible.
• Departmental offices must have computer access to the online waste disposal request system. Instructions are available on the Environmental Health and Safety website where disposal requests are completed. Below are guidelines that will aid in completing the request and expediting the collection process:
• Carefully enter each request to avoid errors;
• Fill out one request for each container unless instructed otherwise by EHS personnel;
• Small vials and bottles should be placed in a re-closeable plastic bag and the form label attached to the bag;
• If disposing a stock bottle of chemical, do not obscure a container's original label. NOTE: Fill out one (1) collection request for each container unless instructed otherwise by EHS personnel.
• Log in with your U of I/MyUI username and password.
• Complete the Chemical Waste Collection Request form.
• Review the information you have entered. If necessary, you may edit the entries. If it is correct, click the Submit Request button and a confirmation message will appear. Click OK or Cancel as appropriate. NOTE: The system performs some error checking and displays an asterisk next to the field that requires correction; a message appears just above the Generator Information block to explain what action you must take.
• A new page will appear with the instruction “Please print the label below and attach to the container.” Select the highlighted Print button and a new window will open for printing the label. IMPORTANT!! This label is specific to the container for which you entered the information. You must submit a new request and print a new label for each container.
• Close the print window.
• Log Out to exit the Chemical Waste Collection Request system;
• Submit another request for a different waste material;
• Submit another request for an identical container , which allows you to submit another waste container with a waste composition similar or identical to the one previously submitted. Edit the new entry as necessary.
• Check your email inbox for a receipt of your waste collection request. Though not the preferred method, you may print a copy of the email receipt to use as a label if you forget to print the label immediately after submitting the request. REMEMBER: The Chemical Waste Collection Request system will accept only one container per request. Additional containers require additional requests.
• Hazardous materials will not be collected prior to EHS personnel receiving completed chemical waste collection requests. EHS makes every effort to collect the waste in a timely manner, dependent on the hazardous characteristics of the material and the likelihood of consolidating similar materials for cost-effective, off-campus shipment.
• Individuals using hazardous materials and generating chemical wastes will be required to complete an inventory of waste streams not yet submitted to EHS as collection requests. Inventories will be used to meet the Idaho DEQ requirement of periodically reporting all hazardous waste that is generated. Normally, the reporting cycle is each January. The inventory includes waste being accumulated but not yet submitted to EHS for disposal purposes. Unused discarded chemical products (i.e., chemicals still in their original containers) do not need to be reported to EHS.
• Individual generators will not dispose of used motor oil by draining or pouring oil into the sanitary sewer or storm drain systems, a sump, or onto the ground/road. Used oil can only be offered to EHS for off-site shipment. Only used engine oil (including synthetic oil), hydraulic oil, transmission oil, and other oils approved by EHS are to be accumulated in drums provided by EHS and labeled "USED OIL." These oils may be combined into the same drum. Antifreeze, refrigerant oil, vacuum pump oil, brake fluid, paint and paint thinners, parts cleaners, and other solvents ARE NOT TO BE ADDED OR MIXED WITH USED OIL (OR EACH OTHER) . Accumulate these materials separately and submit to EHS for disposal as hazardous materials. Used oil is not to be collected in an underground or aboveground storage tank without prior EHS permission.
• Collection Containers - Initially, individual generators will be provided with a 30-gallon drum for collecting and storing used motor oil. Smaller containers may be provided as appropriate.
• Containers must be in good condition and not leaking.
• Collection and Disposal of Full Drums/Other Containers - Submit a collection request using the online Chemical Waste Collection Request system. On the submittal under Chemical Name/Constituents, describe the material as “Used oil.” NOTE: Drums must not be overfilled and surfaces must be clean of oil.
• Filter Removal - Remove filters from engines at operating temperature. "Hot-drain" the oil from the filter by puncturing either the filter anti-drain back valve or the filter dome and drain for 12 hours. A filter is drained when it no longer drips any oil.
• Filter Disposal - Discard drained filters (as previously described) as normal trash. NOTE: For the management and disposal of other automotive fluids, oils, or parts cleaner fluids not mentioned in this section, please contact EHS.
• Non-leaking automotive, marine, tractor, and other lead-acid batteries, including sealed lead-acid batteries, will be managed by the Facilities Surplus/Recycling/Solid Waste Division. Call 208-885-2091 for additional information.
• Leaking lead-acid batteries must be plastic in a plastic container such as a tub or 5-gallon pail. Submit a Chemical Waste Collection Request for disposal through EHS.
• Lamps. Separate TCLP Compliant lamps from Non-TCLP Compliant lamps.
• Place the lamps in a box or other container that can be closed. The original packaging box is a good choice. Keep the box closed except when adding lamps.
• Mark on the box “TCLP Compliant Lamps”.
• When full, deliver the box to Facilities Surplus/Recycling/Solid Waste. NOTE: Occupants of University Housing or Idaho Student Union and Bruce M. Pitman Center should contact their building representative to determine where used TCLP Compliant lamps should be taken.
• Broken TCLP Compliant lamps . Scoop or sweep up the glass fragments and powder and dispose as you would broken glass.
• Place used lamps in a box or other container that can be closed. The original packaging box is a good choice. Keep the box closed except when adding lamps.
• Mark on the box “Universal Waste — Lamps”
• Mark on the box the date you placed the first used lamp in it.
• When full, or within six (6) months of the date marked on the box or container, whichever comes first, deliver the box to Facilities Surplus/Recycling/Solid Waste.
• This procedure is applicable to situations where only one lamp is broken. In all other situations, leave and secure the area, and contact Environmental Health and Safety, 208-885-6524.
• Wearing gloves, carefully pick up or scoop up the glass fragments and powder with a stiff piece of paper or cardboard.
• Use sticky tape (e.g. duct tape) to pick up fragments or powder.
• If a hard surface, wipe the area clean with a wet paper towel.
• Place all items in a plastic bag, seal the bag, then put the bag in a strong, tight container such as a 5-gallon plastic pail. Mark on the pail “Broken Universal Waste — Lamps.”
• Submit a Chemical Waste Collection Request to EHS.
• Alkaline — dispose in normal trash;
• Lead-Acid — manage in accordance with 400.70 above;
• Lithium and Lithium ion; manage as universal waste.
• All others including Ni-Cad, NiMH, mercuric oxide, silver oxide, button cell batteries, and other rechargeable type batteries; manage as universal waste.
• Tape the electrodes on universal waste batteries or place each battery in a re-sealable plastic bag.
• Place the taped or bagged universal waste batteries in a box or other container.
• Mark on the box or container “Universal Waste — Batteries”.
• Mark on the box or container the date you placed the first battery in it.
• When full, or within six (6) months of the date marked on the box or container, whichever comes first, deliver the box or container to Facilities Surplus/Recycling/Solid Waste.
• If a universal waste battery shows any evidence of leakage, spillage, or damage, follow the steps above except that you must place the battery in a re-sealable bag, placed in a compatible container such as a 5-gallon plastic pail, and submitted to EHS for disposal . Follow the instructions in 400.40 for completing a Chemical Waste Collection Request.
• Do not remove mercury ampules from thermostats or other electrical switches.
• Place the MCE in a re-sealable plastic bag.
• Mark the bag “Universal Waste — Mercury Containing Equipment.”
• Mark the date on the bag when you decided to discard the MCE.
• Submit all MCE to EHS for recycling/disposal. Follow the instructions in 400.40 for completing a Chemical Waste Collection Request.
• If an MCE is broken, leave and secure the area and contact EHS at 208-885-6524.
• Once or twice each year, the Idaho Department of Agriculture sponsors a pesticide collection day as part of its Pesticide Disposal Program. Collection sites are located at several sites in the state of Idaho. EHS will send notice to the campus community, including facilities located outside of Moscow, in advance of these collection days.
• Stocks of unused pesticides, including dilutions and rinsates, are acceptable.
• If you have stocks of recalled pesticides, contact EHS at 208-885-6524 as soon as you are aware that the pesticide has been suspended or canceled.
• If the pesticide container is structurally sound, securely close it. Opened bags or boxes of pesticides should be taped closed.
• If the pesticide container is not structurally sound (e.g. tears in bags or boxes, degraded plastic bottles), place the pesticide container in a heavy plastic bag and securely close it.
• Mark on the container “Universal Waste — Pesticide.”
• Mark on the container the date when you decided to discard the pesticide.
• Submit all pesticides to EHS for recycling/disposal. Follow the instructions in 400.40 for completing a Chemical Waste Collection Request.
• Preparation for Disposal - Many cleaners, solvents, lubricants, paints, degreasers, etc., sold under a trade name are hazardous materials and must be disposed of properly. Household type hazardous materials submitted for disposal must be accompanied by a current Material Safety Data Sheet (MSDS) for that product.
• How to Obtain an MSDS - MSDSs can be obtained through the vendor or manufacturer of a given product or contact EHS for assistance. Most MSDSs are now available online.
• EHS will accept materials that were purchased for University of Idaho business. Products that were purchased for personal use (e.g. at your private residence) can be disposed at the Latah County Solid Waste Processing Facility.