Universal Waste Case Study

1. Universal Waste Case Study University of Rochester Strong Memorial Hospital Marvin Stillman, Manager Environmental Compliance

2. Universal Waste • Are already regulated as Hazardous Waste • HW batteries • Thermostats • HW recalled pesticides • HW mercury lamps

3. The Choices • Manage • Under full HW Rules • Manage • Under relaxed Universal Waste Rules • Do Not Manage • Face penalties for non-compliance

4. Background • Hopelessly Large Quantity Generator • HW = 21 TPY entire university • Share EPA ID with University • Large Medical Research Complex • Graduate/Undergraduate campus • Share EH&S with University

5. Collection Considerations • Collection Points set up • Convenience is important • Incorporate into existing handling processes • Follow labeling requirements

6. Battery Collection Points • Facilities & Services • At point where new batteries are picked up • Clinical • Soiled utility cart for later segregation • Special bin in cart cleaning area • General Public and Staff • Service desks such as Page Office or Information desk

7. Battery Collection Con’t • Service Shops • Medical Engineering • Photo Illustration • Option to call for direct pickup by Hazardous Waste Management staff

8. Used Battery Collection

9. Batteries Awaiting Shipment

10. Lamps • Separate collection was set up in an area on the way to the dumpster. • Brought to central University Hazardous Waste Facility for ultimate disposal. • Hauler exchanges large cardboard tubes for 4’ lamps • The rest are in boxes on pallets

11. Reusable Lamp Containers

12. Lamps Shipment Container

13. Recalled Pesticides • Avoided through Integrated Pest Management • Managed as HW if there is any for disposal • All pesticides are handled by central pest control department • Universal Waste option for recalled pesticides is not really beneficial for our situation

14. Computers • Regulated as Hazardous Waste • Throwing away is not an option • Not Universal Waste----yet • NYSDEC scrap metal ruling for NY • Managed through a local electronics recycling firm

15. Computer Collection Area

16. Challenges • Change staff thinking through education • These cannot be thrown away • Items are seen as common and non-threatening • Incorporate new policy into training classes • Write articles in campus publications • Get supervisors to enforce

17. Challenges 2 • You get no more staff • Incorporate separation and collection into existing materials flow • Computers and lamp collection areas are located near other trash dumpsters • The same staff that used to pick them up still do • They now keep them separated • Or collect used when new items are picked up

18. Challenges 3 • Sell to administration • This has not been a problem • Special management is legal requirement • Cost-effective contracts were negotiated • Existing operations used to manage where possible • Credibility of Environmental staff not questioned • Success tracked and reported • Sell minimal compliance before addressing going beyond compliance

19. Examples of Mercury Items Used for Training

20. Benefit • UR to stay below 25 tons per year HW • Proposed NYS generator tax hike of $4,000 year if over 25 tons • Longer storage time for certain HW batteries such as button to fill container • Other institutions may be able to lower generator status to minimize regulatory impact

21. Minimal Operational Benefit to UR • Thermostats • Shipped with other HW • Recalled Pesticides • No reason to hold on to these