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 Cont 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