Stanford University

Hazardous Materials Handling and Disposal

Hazardous waste (general)

Contractor shall make every effort to minimize the amount of hazardous waste generated from construction activities. The University reserves the right to require substitution of products that generate toxic waste (e.g. paint strippers, degreasers, etc.) with products of lesser toxicity.

  • Unless otherwise specified, all generated hazardous waste shall be disposed of through the EH&S Environmental Protection Program (EPP).
  • Contractor shall properly contain and label such waste as it is generated.
  • Contractor shall notify the Project Manager at least one week in advance to request waste containers and/or labels, if necessary.
  • Contractor shall not begin generating hazardous waste until proper waste containers and labels are on site.
  • Contractor shall store waste containers in a secure location on the job site with lids closed.
  • Contractor shall notify the Project Manager to request pickup of hazardous wastes.

Universal waste recycling

  • Contractor shall comply with California DTSC regulations pertaining to universal waste.
  • Unless otherwise specified, Contractor shall carefully remove regulated devices and building components scheduled for demolition intact and segregate them from other construction debris.
  • Contractor shall arrange for packaging, labeling, pickup, transport, and recycling of all universal wastes identified in this subsection, and shall submit to the University receipt(s) that document compliance with this provision.
  • Contractor shall only use recycling vendors that have been pre-approved by the University.

Light tubes, bulbs, and lamps

Fluorescent light tubes and bulbs, high intensity discharge (H.I.D.), metal halide, sodium, and neon bulbs contain mercury vapor. Such lamps scheduled for demolition shall be removed from their fixtures unbroken and recycled through the following vendor: Inc.
30677 Huntwood Ave.
Hayward, CA 94544
Telephone: (510) 429-1129
Fax: (510) 429-1498

Mercury-containing devices

Thermostats, fire alarm pull stations, switches, thermometers, pressure, and vacuum gauges may contain mercury. All mercury-containing devices scheduled for demolition shall be removed intact, segregated from other construction debris, and recycled through Inc. (see above).


Batteries may contain lead, mercury, lithium, cadmium, and other toxic metals. Contractor shall remove batteries from devices scheduled for demolition, including emergency lighting and alarms, communication systems, security systems, etc. Batteries shall be removed intact, segregated from other construction debris, and recycled through a vendor pre-approved by the University.

Electronic devices (e-waste)

Electronic devices and components, including televisions and computer monitors, computers, printers, VCRs, CD and DVD players, telephones, radios, microwave ovens, communication, security, fire protection, lighting, and mechanical system components may contain heavy metals such as lead, mercury, chromium, and cadmium. Electronic devices and components scheduled for demolition shall be removed intact and recycled through a vendor pre-approved by the University.

Treated wood waste (TWW)

‘‘Treated wood’’ is wood that has been treated with a chemical preservative for purposes of protecting the wood against attacks from insects, microorganisms, fungi, and other environmental conditions that can lead to decay of the wood, where the chemical preservative is registered pursuant to the Federal Insecticide, Fungicide, and Rodenticide Act (7 U.S.C. § 136 et seq.).

Treated wood includes wood treated with alkaline copper quaternary (ACQ), copper azole (CA-B), copper boron azole (CBA-A), chromated copper arsenate (CCA), ammoniacal copper zinc arsenate (ACZA), creosote, pentachlorophenol, and copper naphthenate.

Contractor shall manage, handle, store, label, transport, track, and dispose of treated wood waste (TWW) in accordance with DTSC requirements.

Contractor shall not reuse TWW, and shall store TWW on-site as follows:

  • Covered and off of the ground, in a secured area
  • In closed, water-resistant containers
  • Inside a weather-tight structure
  • Covered on a pad that is protected from run-off

Contractor shall ensure that any size reduction of TWW is conducted in a manner that prevents the uncontrolled release of hazardous constituents to the environment, and that conforms to applicable Cal/OSHA worker health and safety requirements. All sawdust and other particles generated during size reduction shall be captured and managed as TWW.

Disposal of TWW is restricted to landfill(s) pre-approved by the University. Contractor shall provide to University a bill of lading or other documentation with an acceptance signature by the landfill for all TWW shipments.

Asbestos-containing materials

If applicable, University shall provide to Contractor a facility survey report that contains an inventory of confirmed asbestos-containing materials (ACMs) known to be present at the project site.

ACMs that will be impacted (disturbed) by renovation or demolition shall be removed prior to, or phased with, other construction activities. No one shall remove, repair, disturb, or handle any asbestos-containing materials, except Universityapproved, registered Asbestos Abatement Contractors working in compliance with the University’s Asbestos Abatement Specification.

Contractor may encounter hidden ACMs during demolition activities, such as asbestos-insulated pipes or ducts inside wall cavities, etc. If Contractor observes such ACMs in poor or damaged condition, or if Contractor inadvertently damages or disturbs previously identified ACMs or suspected ACMs, the Project Manager shall be notified immediately.

Contractor shall post asbestos warning signs or labels upon discovery of hidden ACMs. Contractor may request assistance with posting asbestos warning signs or labels from the University.

Polychlorinated biphenyls (PCBs)

Fluorescent light ballasts

All fluorescent light fixture ballasts manufactured prior to 1978 are assumed to contain PCBs and shall be disposed of as hazardous waste. With the exception of electronic ballasts, all ballasts manufactured after January 1, 1978, and specifically labeled “No PCBs,” may be disposed of as non-hazardous construction debris. All ballasts that do not contain a “No PCBs” label shall be removed from light fixtures, segregated from other construction debris, and disposed of as hazardous waste.

Insulating oils

Insulating oils associated with high-voltage equipment may contain PCBs. Equipment containing PCB-insulating oils shall be decontaminated prior to demolition. Extraction of PCB-containing oils and decontamination of equipment shall be performed in accordance with Cal/OSHA worker protection requirements. Recovered oil containing PCB shall be disposed of as hazardous waste.


Paint and other surface coatings

Unless otherwise determined by approved testing methods, all paints and surface coatings (e.g. varnish, shellac, stain, lacquer, etc.) applied to University structures are presumed to contain some amount of lead.

Contractor shall take all necessary precautions to protect Contractor employees, subcontractors, students, visitors, University employees, and the environment from exposure to lead-containing dust and debris. Contractor shall comply with the Cal/OSHA lead standard for the construction industry, which applies to any construction activity that may release lead dust or fume, including manual demolition, manual scraping, manual sanding, heat gun applications, power tool cleaning, rivet busting, abrasive blasting, welding, cutting, or torch burning of lead-based coatings.

The University shall provide existing lead analysis data of surface coatings, where available. However, these data are not intended, and do not represent, an evaluation of all potential lead-containing coatings at the project site, and Contractor is solely responsible for determining lead content for purposes of Cal/OSHA compliance.

Painted debris resulting from demolition may qualify as hazardous waste and must be evaluated by EH&S prior to transport and disposal.

Where feasible, Contractor shall clean sheet plastic used for regulated work area isolation (containment) or drop cloths and discard as non-hazardous waste.

Power washing

Contractor shall protect soil and storm drains from paint chip debris during power washing of building exterior surfaces. All paint chips shall be collected and disposed of as hazardous waste. Contractor shall be responsible for all direct and indirect costs associated with remediation of soils found to be contaminated with lead-containing paint chips resulting from non-compliance with this provision.

Elemental lead

Products containing lead metal, such as plumbing components, lead bricks, counterweights, and sheet goods (e.g. roof flashing, X-ray shielding, drain pans, etc.) may be encountered during demolition. Unless otherwise specified, Contractor shall remove and segregate lead metal scheduled for demolition from other construction debris and transport it to a scrap metal recycling facility pre-approved by the University.

Mechanical system fluids

All fluids associated with mechanical systems and equipment scheduled for demolition or retrofit shall be removed and recycled, or disposed as hazardous waste. Contractor shall arrange for recycling of petroleum-containing fluids, such as hydraulic fluids, lubricating oils, and non-PCB-containing insulating oils.

Refrigerants shall be removed from equipment and managed by a certified refrigerant technician, pursuant to 40 CFR 82.161 (Type I for small appliances, Type II for high-pressure equipment). Venting of refrigerant to the atmosphere is not allowed. All refrigerant removed must be reclaimed, recovered, or recycled, in accordance with 40 CFR 82.150-166 and Appendices.

Laboratory decommissioning and closure

The University’s laboratory decommissioning protocols require removal of all hazardous chemical, radioactive and biohazardous materials and associated wastes, followed by decontamination of surfaces and equipment, prior to transfer of such project areas to Contractor. Facilities that have housed radioactive material, or that contain materials activated by radiation beams, must be surveyed and cleared by the University prior to release to Contractor.

A hazardous materials closure permit is required prior to the renovation or demolition of any designated (permitted) chemical use or storage area, which includes both laboratory and non-laboratory facilities. Depending on project location, closure permits are issued either by the PAFD Hazardous Materials Compliance Bureau or the Santa Clara County Department of Environmental Health. The University is responsible for securing and managing all closure permits, and Contractor shall not start work until notified that a closure permit has been obtained.

Laboratory sink P-traps are presumed to contain mercury contamination as a result of thermometer breakage. P-traps scheduled for demolition shall be removed by Contractor, placed in leak-tight containers, and transferred to the University for disposal.

Unless otherwise specified, Contractor shall not demolish or disturb building components used for chemical transport, treatment, or storage, unless such systems have been inspected and released by EH&S. Such building components may include fume hood and local chemical exhaust ducts, acid vent and neutralization piping, lab waste piping, toxic gas system equipment and piping, and chemical or chemical waste storage tanks. If Contractor encounters potentially hazardous materials on the project site, such as abandoned chemical reagents, containers or equipment with radioactive labels, biohazard (red) disposal containers, or syringes, Contractor shall contact the Project Manager immediately.

Radioactive building materials

Emergency exit signs scheduled for demolition may contain tritium, a radioactive material. Contractor shall carefully remove such signs intact and transfer them to the University for disposal. A label on the lower edge of the sign that features a radiation symbol can be used to identify tritium exit signs.

Smoke detectors may contain small amounts of Americium, a radioactive element. Contractor shall carefully remove smoke detectors scheduled for demolition intact and transfer to the University for disposal.


Unless otherwise specified, if Contractor encounters significant quantities (greater than ten square feet) of mold growth on the project site, Contractor shall report such condition to the Project Manager.

Contractor shall protect the project site and new construction products from exposure to excess moisture and shall ensure that construction products are adequately dry prior to installation. Contractor shall remove and replace all porous building materials and replace or disinfect all non-porous building materials that display visible mold growth resulting from moisture intrusion, unless such moisture intrusion was caused by circumstances outside of Contractor’s control.

Miscellaneous hazardous materials

If Contractor encounters potentially hazardous materials or waste on the project site not previously addressed under this section, such as abandoned paint containers, pesticides, compressed gas cylinders, etc., or if Contractor encounters any unusual odors or colors (staining) during drilling or excavation of soils, Contractor shall report such conditions to the Project Manager.

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