|TO:||The University Community|
|FROM: ||Marvin Stillman, manager of environmental compliance, University Facilities & Services|
|RE:||Hazardous Waste Management|
There has been a lot of discussion over the past year about an impending United States Environmental Protection Agency inspection of universities and colleges across New York State. This follows on the heels of a number of violations recorded and fines levied against colleges and universities in New England over the last two years. As a result of comprehensive inspections, many of these institutions lost oversight over their programs to the dictates of outside agencies. Generally speaking, these institutions lacked a culture of compliance. A relatively large number of "minor" issues simply added up to a large fine. What can we do to help avoid the same fate?
Safe and legal waste management starts out with some easy and cost-effective steps that should be followed exactly to avoid non-compliance:
- Collect hazardous waste in a suitable container. Do not drain.
- Label each container with the words "hazardous waste" along with a description of the contents.
- Always keep the cap on a container unless waste is being added. No funnels are to be kept in the bottle.
- Store waste in a manner that reduces the possibility that the material will be released into the environment or drain. A secondary containment tray that can hold 110 percent of the volume of the largest container will suffice as long as it is stored in a secure location. Label the area "hazardous waste accumulation area."
- Store incompatible materials (i.e., acids/bases, flammables/oxidizers, etc.) separately in secondary containment trays.
- When waste containers are filled, attach a completed hazardous waste tag and either call for a waste pickup or take the waste to the designated collection area in your department (this last option applies to the Laboratory for Laser Energetics and the biology and chemistry departments).
- Do not keep chemicals that are outdated or for which there is no further use.
- Do not allow unknowns to come into existence: Replace worn, faded, or missing labels before you forget what is in a container.
- Train and expect everyone to follow these steps in your area of responsibility.
The University's Hazardous Waste Management Unit, x5-2056, can offer further assistance.
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