9.4 Waste Management (X09), Pest Management and Pesticide Use (X10) & Cleaning Products and Protocols (X11)
Key Takeaways
- X09 Waste Management requires a plan covering batteries, pesticides, mercury-containing lamps and equipment, and electrical and electronic equipment, with each waste category separately contained in clearly labeled receptacles and removed from the building within one year.
- X10 requires an integrated pest management plan covering indoor and outdoor spaces, with pest tolerance thresholds, control strategies, monitoring records and annual evaluation of plan effectiveness.
- Each periodic pesticide used under X10 must be Pesticide Research Institute Hazard Tier 3, or on San Francisco's Reduced Risk Pesticide List, or low-risk or approved plus WHO Class U in the EU Pesticides Database.
- X10 requires occupant notification at least 24 hours before pesticide application and signage posted from at least 24 hours before until at least 24 hours after application, naming the pesticide, registration number, location, date and applicator.
- X11 requires a cleaning plan covering extent and frequency, disinfection surfaces and thresholds, documentation, PPE and color-coding of cloths, bleach storage separation, HEPA-filtered vacuums, and a staff training program.
9.4 Waste Management (X09), Pest Management and Pesticide Use (X10) & Cleaning Products and Protocols (X11)
Core Exam Takeaway: These three optimizations govern daily operations rather than construction purchasing. X09 (1 pt / Core 2 pt) = hazardous waste plan with the one-year removal rule. X10 (1 pt / Core 2 pt) = integrated pest management with the 24-hours-before / 24-hours-after notification regime and four acceptable low-hazard pesticide lists. X11 (2 pt / Core 1 pt) = a cleaning plan whose most quotable requirements are colour-coded cloths, bleach stored away from other products, and HEPA-rated vacuum filters.
Feature X09: Waste Management — Optimization (1 pt / WELL Core 2 pt)
Intent: mitigate environmental contamination and associated exposure to hazards present in certain wastes.
X09 Part 1 — Implement a Waste Management Plan
Scope — five waste streams present or expected during building operations: batteries, pesticides, lamps that may contain mercury, other mercury-containing equipment including thermostats and thermometers, and electrical and electronic equipment.
The plan is developed and implemented and contains:
- (a) Identification of roles, responsibilities and vendors for implementing the plan.
- (b) Identification of the sources of waste, estimation of rates of generation and strategies to minimize waste generation.
- (c) Strategies for waste collection. Each of the categorized wastes is separately contained in clearly labeled receptacles and removed from the building within one year.
- (d) Protocols for cleaning spills of mercury (including broken fluorescent lamp tubes), pesticides and battery electrolyte fluid, including sealed containment of residues as applicable.
- (e) Protocols to track, measure and report waste stream flows.
- (f) Protocols for off-site shipment of wastes.
WELL Core guidance: whole building.
[!IMPORTANT] X09 is not a recycling feature. It targets hazardous waste streams specifically — the ones that create human exposure if mishandled. General recycling, composting and diversion are addressed elsewhere in WELL (N10 requires garbage, recycling and/or compost bins in eating areas), and municipal diversion rates are a LEED concern. Do not answer X09 questions with recycling-rate content.
[!TIP] The one-year removal rule in (c) is the number to hold, and the reason is practical: hazardous waste accumulating in a back-of-house storeroom is a slow-motion exposure event. Note also that (d) names broken fluorescent lamp tubes explicitly — a single broken T-8 releases its full mercury charge into the room, which is precisely why X01 Part 2 tabulates maximum mercury per lamp type.
Feature X10: Pest Management and Pesticide Use — Optimization (1 pt / WELL Core 2 pt)
Intent: reduce the presence of pests primarily through integrated pest management (IPM) principles, favouring non-toxic pest control and, where pesticides are necessary, selecting those less hazardous to humans.
X10 Part 1 — Manage Pests
An IPM-based management plan is implemented for all indoor and outdoor spaces:
(a) The plan contains five elements:
- List of roles and responsibilities for program development, implementation, maintenance and education
- Pest management objectives, including protocols for identification of pests and metrics of progress
- Design and operational measures to prevent conditions that may attract pests
- Pest tolerance thresholds and control strategies — including methods and response times — for when tolerance thresholds are exceeded, attending to the safety of the applicator, the occupants and the environment
- Records of pest monitoring data, pest events, pesticide applications, control actions and emergency responses
(b) Each pesticide used for periodic (non-emergency) application is listed in the plan and meets one of:
- Evaluated by the Pesticide Research Institute (PRI) with a Hazard Tier ranking of 3 (least hazardous)
- Listed in the most recent City of San Francisco's Reduced Risk Pesticide List
- All active substances catalogued as "low-risk" in the EU Pesticides Database
- All active substances marked "Approved" in the EU Pesticides Database and either classified as Class U or not classified in the latest WHO Recommended Classification of Pesticides by Hazard
(c) For pesticide application, periodic or emergency, the plan includes:
- Paper or digital notification to all building occupants on the protocol for pesticide use
- Notification to all building occupants at least 24 hours prior to application, and signage posted at the site of application from at least 24 hours prior until at least 24 hours after application
- Notifications include the pesticide name, registration number, treatment location, date of application and applicator. For emergency application, information on the type of emergency or reason for unplanned use
(d) The plan's effectiveness is evaluated on an annual basis. (e) The plan, records of its implementation, Safety Data Sheets (SDSs) of pesticides and results of inspections are available to occupants and owners.
WELL Core guidance: whole building.
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| X10: THE IPM HIERARCHY, AND WHY IT IS ORDERED |
| |
| 1. PREVENT Design and operational measures that stop conditions |
| attracting pests -- sealing entry, removing food and |
| water sources, managing waste |
| |
| 2. MONITOR Identify pests, record events, measure against |
| TOLERANCE THRESHOLDS -- not zero, but a defined level |
| |
| 3. INTERVENE Only when a tolerance threshold is exceeded, and using |
| the least hazardous effective method |
| |
| 4. IF PESTICIDE Only substances on one of FOUR recognized low-hazard |
| IS NEEDED lists, with 24-HOURS-BEFORE notice and signage from |
| 24 hours before to 24 hours after |
| |
| The tolerance-threshold concept is what makes IPM different from |
| scheduled spraying: intervention is TRIGGERED, not calendared. |
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[!IMPORTANT] "Pest tolerance thresholds" is the conceptual heart of IPM and a favourite exam target. Conventional pest control sprays on a schedule; IPM defines an acceptable pest level, monitors against it, and intervenes only on exceedance. That single change eliminates most routine pesticide application, which is why WELL treats the plan — not the product list — as the primary requirement.
[!TIP] The 24/24 notification rule — notice at least 24 hours before, signage from 24 hours before until at least 24 hours after — applies to both periodic and emergency application. Emergency use does not waive notification; it only adds a requirement to state the type of emergency or reason for unplanned use.
Feature X11: Cleaning Products and Protocols — Optimization (2 pt / WELL Core 1 pt)
Intent: provide cleaning effectiveness by selecting less hazardous products and establishing adequate cleaning protocols and practices.
X11 Part 1 — Improve Cleaning Practices (1 pt / Core 0.5 pt)
The project develops and implements a cleaning plan that:
- (a) Details: extent and frequency of cleaning; cleaning responsibilities of building occupants and cleaning staff; cleaning supplies available to occupants and where they can be accessed; and a process to evaluate and document adherence to the plan.
- (b) Identifies: surfaces that require disinfection (e.g., high-touch surfaces); frequency and/or other thresholds for disinfection (number of hours, number of users of a space, results from a swab test); applicable governmental registration and directions of use including contact time and dilution rates; and other non-chemical tools used for disinfection, if any.
- (c) States documentation procedures: record keeping for cleaning and disinfection activities; the chain of communications with building occupants; and a system to log feedback from occupants and cleaning staff.
- (d) Specifies for cleaning materials and PPE: PPE requirements for general cleaning and specialized tasks such as disinfection or chemical dilution; colour-coding for reusable and disposable cleaning cloths; and separate cleaning of reusable cleaning materials from other clothing or products.
- (e) Includes storage precautions: an identifiable, fit-for-purpose storage space per manufacturers' directions, with bleach stored away from other products; and colour-coding and labeling of bleach-based and ammonia-based products indicating they are not to be mixed.
- (f) Specifies for tools and equipment: HEPA-rated filters for vacuum cleaners; where carpet and woven upholstery are present, a cleaning methodology based on manufacturer recommendations favouring hot water extraction where technically feasible; and protocols for cleaning, maintenance and handling of waste accumulated in equipment such as used vacuum bags.
- (g) Includes operational aspects: use of cleaning and disinfection products including dilutions and ventilation requirements; on-site availability of current Safety Data Sheets in languages spoken by the cleaning staff; precautions to avoid slip hazards during and after floor cleaning; and safe disposal of waste including soiled materials and PPE.
- (h) Outlines a training program covering cross-contamination prevention via hand hygiene, PPE, cleaning cloth replacement, cloth handling techniques and carrying systems to separate clean tools from dirty ones, delivered to all relevant staff.
WELL Core guidance: non-leased spaces.
[!IMPORTANT] Two requirements in X11 are safety-critical and highly quotable. First, bleach must be stored away from other products, and bleach-based and ammonia-based products must be colour-coded and labeled as not to be mixed — mixing hypochlorite with ammonia generates chloramine gas, a genuine and recurring cause of occupational injury among cleaning staff. Second, Safety Data Sheets must be available in the languages spoken by the cleaning staff — an equity provision recognizing that the people most exposed to cleaning chemicals are often not served by English-only documentation.
[!TIP] Colour-coding appears twice in X11 — for cleaning cloths in (d) and for bleach and ammonia products in (e) — and serves the same purpose both times: preventing a mistake that language and literacy differences would otherwise make likely. Colour-coded cloths prevent a restroom cloth reaching a kitchen counter; colour-coded bottles prevent a lethal mixture.
[!TIP] Note the disinfection threshold language in (b). WELL asks projects to define when to disinfect — by hours elapsed, by number of users, or by swab test results — rather than to disinfect everything constantly. Over-disinfection has its own costs: chemical exposure for staff, respiratory irritation for occupants, and residue on high-contact surfaces.
How the three operational features connect back to the rest of the standard
| This feature | Connects to |
|---|---|
| X09 hazardous waste, mercury lamps | X01 Part 2 mercury lamp limits; A11 chemical storage separation |
| X10 pesticides, indoor and outdoor | W07 moisture management (moisture attracts pests); project boundary rules that bring outdoor space into scope |
| X11 cleaning products and protocols | W08 hygiene support and fragrance-free soap; A01/A05 VOC thresholds that cleaning chemicals can breach; annual submissions for proof of maintenance |
Under X09, how must hazardous waste streams be handled?
Which pesticide qualifies for periodic application under X10 Part 1(b)?
What notification does X10 require before and after pesticide application?
Which storage requirement does X11 impose on cleaning chemicals?