Every 3 years, the Yolo County Hazardous Materials Division (CUPA), inspects each department on campus that handles hazardous waste to ensure we are in compliance with the Hazardous Materials Business Plan(HMBP). 

Listed below are the top 5 CUPA violations here on the UCD campus. These 5 violations cover 99% of the violations we receive each year.  Take care of these issues, and your inspection should be quick (< 5 minutes) and painless.   

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1.  Training

The HMBP requires documentation of initial and refresher training for all campus personnel that handle hazardous materials on the following subjects for the past 3 years:

• Emergency Evacuation Procedures
• Emergency Notification Procedures
• Spill Response and Cleanup Procedures

Compliance Tips:  The Emergency Protocol-Evacuation and Emergency Protocol-Alert and Notification sections of your Emergency Action Plan (EAP) will often cover the training requirements for Emergency Evacuation and Notification. If you haven’t developed your own Spill Response Protocol,  Safety Net #13 Guidelines for Chemical Spill Control can be used to fulfill the Spill Response Training Requirement.  

There is a saying regarding safety inspections: “If you don’t have all your records, at least have some records.”  So, if you’ve missed a year of training, or can’t find the records, make sure you have current training.   The inspector will typically not issue a violation as long as you have training within one year of the inspection date.

2.  Hazardous Waste Container Labeling

The HMBP requires all hazardous waste containers to be marked with the following information:

• The words “Hazardous Waste”
• Composition
• Hazardous Properties
• Accumulation Start Date
• Name and Address of Generating Facility

Compliance Tips: As soon as you put 1 drop of hazardous waste in a container, use WASTE, the campus online waste management system, to create a hazardous waste label for the container. The WASTe system will not allow a container label to be generated until all required information is entered.  Widespread adoption of the WASTe system has reduced the annual number of this violation from 50 to less than 5. 

3.  Hazardous Waste Container Accumulation Time Limit

We must ship hazardous waste offsite within 1 year of the date of initial accumulation. We allow labs and facilities to store most types of hazardous waste for 270 days. This allows the waste to be removed from campus within the 365-day limit.

Compliance Tips: Use the WASTe system for waste labeling and inventory control. The system will flag a container after 270 days of accumulation, send you a notification email, and submit the container for pickup. This will help ensure no container is left in your lab for more than 365 days. Before WASTe, this was the most common violation on campus. In the last calendar year, the inspector found two overdue containers.

4.  Open Hazardous Waste Containers

Hazardous Waste Containers must be closed unless actively being filled.   

Compliance Tips: If you have lines running from an instrument into a waste bottle, you must use either a cap with fittings or a cap with tight-fitting holes drilled into it. Wrapping the lines and the top of the bottle with aluminum foil is a violation. If you have drip/drain pans or some other type of container that has to be open due to the nature of the machine or the waste process, please contact me so we can discuss the best way for you to stay in compliance.  

5.  Lamps and Batteries

Lamps and Batteries are hazardous waste in California. They can be managed as Universal Waste or regular Hazardous Waste. Any container that contains them needs a hazardous or universal waste label and must be disposed of within 1 year. Yes, even the coffee can on a shelf with all your old batteries in it. I suggest using the universal waste function of WASTe to label and request a pickup for battery and lamp containers. 

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Please feel free to Dan Orovich with any questions at +530-752-4035 or deorovich@ucdavis.edu

If you are going through your first inspection, Dan will be glad to come by and take a look at your records and waste management.