Hazardous Waste Determination Form

Hazardous Waste Determination Forms (HWDF) 

COMAR (40 CFR 262.11) requires generators to make an accurate determination, at the point of generation, as to whether a waste is a hazardous waste and to maintain records for at least 3 years from the date the waste was last sent for treatment, storage, or disposal. 

EHS has created an online submission and review form

Please fill out sections A through C to the best of your knowledge and submit. EHS will evaluate your submission and you will receive a confirmation to the email address of the submitter as well as that of the principal investigator (if different from the submitter).

This form needs to be filled out for each type of waste mixture generated in your lab, once per mixture, not per submission. This does not need to be submitted for pure, vendor-supplied, un-mixed waste.

As the online submission and review form is new, EHS has created the below FAQ for common questions. 

Who To Contact

Any questions or concerns can be directed to the Chemical Hygiene Officer or Environmental Programs Manager. 

Shannon Sussman
Chemical Hygiene Officer

Kevin Nichol
Manager, Environmental Programs

Frequently Asked Questions (FAQ)

Do I need to fill out a HWDF for all my waste? 

A HWDF must be filled out for any spent waste (not in original container) with more than one chemical component (excluding water). For example, 35% HCl 65% water would not require a HWDF but 35% HCl 45% water 20% EtOH would require a HWDF. 

What constituents do I need to include on the HWDF? 

Every chemical in the waste should be included on the HWDF with a percent (%) concentration so that the total concentration adds up to 100%. This includes all nonhazardous components such as water, PBS, etc. If the exact percentage is not known, an approximate percentage is acceptable.

What if I do not know the constituents of my waste? 

The constituents of the waste are whatever chemicals are going to the waste stream and should be the same as the chemicals on the waste label. If unlabeled, unknown waste is found, please submit a chemical pickup request as soon as possible so that EHS can handle the waste.

What if I do not know the characteristics of my waste?  

If you are unsure of the characteristics of your waste, leave that field blank and EHS staff will determine the characteristics.

Do I need to test for the characteristics of my waste? 

No, EHS will conduct any characteristic testing if it is needed.

What happens after I complete the form?  

You will get a confirmation email that it has been submitted. Once EHS has looked over the form and made a determination, you will get an emailed copy of the completed form including the designation.

I submitted, but don't have a confirmation email.  

The confirmation and determination emails may have been sent to your junk or spam folders. Please check there. The email sender may appear as "safe-no-reply@umaryland.edu" with subject line "A new Hazardous Waste Determination Form has been submitted to EHS" after you submit. After someone from EHS has reviewed your form, you will receive another email with subject line "Hazardous Waste Determination Form- EHS Evaluation Complete." 

If you still can't find the emails, you may have mistyped some information or there may be a technical error. Reach out to the Chemical Hygiene Officer or Environmental Programs Manager above. 

What should I do with the determination emails? 

Keep this information on record. This form should be kept on file for at least three years after the final generation of the waste. It does not need to be printed out, but should be easily accessible on the computer.

If my waste is deemed “nonhazardous”, can I pour it down the drain? 

No. All chemical waste needs to be processed through EHS regardless of status.

When do I need to submit a new HWDF? 

Each time a new waste stream is created, or an existing waste stream is changed.

What if the constituents of the waste do not change, but the percentage does? 

A new HWDF should be submitted with updated information. The determination may change.