Hazardous Waste Management Plan - Health and Safety Objective

UCL safety objective

The requirement for departments to have a Hazardous Waste Management Plan is one of the UCL Safety Objectives 2021/22. This objective will ensure that UCL has oversight of waste that could cause harm to human health or the environment. The aims of this objective are to:

• Establish what types of hazardous waste are being produced and where 
• Ensure that waste streams meet the needs of UCL
• Understand whether any waste streams are department specific

Hazardous waste management plan

Departments currently ensure that hazardous waste is removed from their department and enters the appropriate UCL waste stream by transporting the waste to the agreed locations for UCL's waste contractors to remove for treatment.

The Hazardous Waste Management Plan will document the department's procedures for the treatment of hazardous waste from the point of production until it is collected by UCL's waste contractors.

The plan will help UCL to:

• Reduce situations where hazardous waste may cause harm to people or the environment
• Reduce the risk of emergencies by ensuring there is sufficient and suitable storage and positioning of spill kits in the most useful locations
• Reduce the impact of hazardous waste by having an integrated management approach by working with UCL Sustainability

The Hazardous Waste Management Plan does not require any new information from the department or individuals. There is no specialised knowledge required to complete the Hazardous Waste Management Plan. It is about collating information that is already available and ensuring that there is good communication within the department so that all hazardous waste generated within the department is treated safely until it can be managed by UCL Estates.

Departments are not required to provide information about waste management companies or specify what they require from a waste management company – this is the role of the Waste Management team within Estates.

A single place for departmental procedures

The Hazardous Waste Management Plan will describe, in detail, the amount and type of waste produced by a department and how it will be reused, recycled or disposed of. The plan will ensure that staff and students know how to manage hazardous waste so that it is correctly classified, labelled and stored before it enters the waste stream.

Risk assessment

Staff and students producing hazardous waste will refer to the Hazardous Waste Management Plan when completing the risk assessment for their activity.

• Identify the hazardous waste they are producing and include this in the risk assessment
• Record in the risk assessment the actions required from production of the waste to the storage of the waste in the department's own space such as a lab
• Ensure that control measures are in place for the waste they are producing, such as training on the spill procedures
• Who to contact if they believe the hazardous waste they are producing is not covered in the plan

Further guidance

To help departments complete their Hazardous Waste Management Plan, Safety Services has produced a suite of information and a downloadable template.

• Hazardous waste management This webpage provides more in-depth information about hazardous waste and why UCL needs to manage the lifecycle of hazardous waste
• Hazardous waste management plan This webpage has guidance on the roles and responsibilities of people in the department and a template plan which can be downloaded
• Classification of common hazardous waste codes at UCL This webpage allows everyone to be aware of why different hazardous substances can be grouped together for waste management purposes and explains why not all waste involving substances is automatically hazardous waste. For example, most lab chemicals fall under a single waste type (List of Waste Code LoW) and are only considered hazardous dependent on the amount and concentration, only substances such as mercury are considered hazardous waste no matter the amount
• Disposal of hazardous waste via sinks This webpage has information about how small quantities and low concentrations of many chemicals are rarely considered hazardous waste and therefore do not need to enter a hazardous waste stream. However, some chemicals may become hazardous if not disposed of safely. Departments need to have a good understanding of when disposal via the sinks is good practice and have clear guidelines for staff and students. When it is suitable it should be confirmed in the risk assessment

• Environmental Management - Waste This Gov.UK webpage gives detailed information on the requirements for waste management in the UK