Environmental Health & Safety

Universal Waste Management Policy and Procedures

    This Universal Waste Management Program has been instituted in accordance with Alfred University's Environmental Health and Safety Policy. It shall be reviewed and updated annually by Alfred University Environmental Health and Safety. The waste referred to in this policy applies to Alfred University owned materials only.

The purpose of this Universal Waste Policy is to ensure that Alfred University follows the regulations of the Universal Waste Rule 40 CFR part 273. The EPA, as an amendment to the Resource Conservation and Recovery Act (RCRA), promulgated this rule. It is designed to reduce the amount of hazardous waste items in the municipal solid waste stream and encourage recycling and proper disposal of certain common hazardous wastes – lamps such as fluorescent, mercury vapor, metal halide and high pressure sodium, non PCB containing lamp ballasts only, batteries such as rechargeable nickel-cadmium, nickel metal hydride, lead-acid, lithium and mercury-containing button type, and pesticides meeting certain conditions for being unwanted, recalled, suspended or cancelled, termed as "Universal Wastes".

  • Disposal, dilution or treatment of Universal Waste is prohibited;
  • Universal Waste must be handled in a way that will prevent a release to the surrounding environment;
  • Broken lamps, pcb light ballasts, mercury containing devices and leaking batteries must be managed as hazardous waste;
  • Storage containers must be structurally sound, kept closed and compatible with the contained waste;
  • The collection/storage container or the individual item must be labeled with the proper Alfred University Universal Waste label and the start date (date it became a waste) must be clear and visible - there are separate universal waste labels for NYSCC and AU, the labels can be found on the EHS web site;
  • Full containers of Universal Waste cannot be stored for more than one year in a centralized location;
  • Alfred University may not transport more than 500 lbs. of Universal Waste at one time;
  • A Bill of Lading (BOL) shall be kept for three years for every shipment of Universal Waste sent to another facility. The BOL should show the name and address of the handler, destination facility, quantity of each type of universal waste sent and the date the shipment left the generator facility.
  • All employees who handle universal waste or have some responsibility for universal waste must be informed of proper handling and emergency procedures.
  • It is the responsibility of Alfred University to participate in the Universal Waste Management Program by reading and adhering to this policy.
  • Each University department is responsible for setting up a proper battery storage area, if necessary.
  • Both Physical Plants are responsible for setting up and maintaining at least one proper lamp and lamp ballast collection area in each of their respective buildings.
  • Both Physical Plants are responsible for setting up and maintaining proper mercury containing device collection areas in their respective building, if necessary.
  • Both Physical Plants are responsible for the proper labeling and handling of all collected universal waste and its proper transport to a central consolidation/storage location, including palletizing and clear-wrapping universal waste containers and properly labeling palettes in preparation for shipment. EHS will manage the shipping of Universal Waste and will maintain the Bill of Lading (BOL) for three years.
  • Notify EHS whenever there is a change in personnel managing universal waste.

Universal Wastes are prohibited from landfill (trash, and dumpster) disposal:

Batteries (40CFR 273.2)

Contact EHS x2190 with Hazardous Waste questions.

Type of Waste What to do Who should do it
Nickel-cadmium (Ni-Cd)

Small sealed lead-acid (SSLA) batteries found in electronic equipment, cordless/mobile phones portable computers and emergency backup lighting.
Collect and store in a properly labeled container (5 gallon UN approved plastic pail with a lid). Use the Universal Waste Rechargeable Battery Label.
Store in your area along with your used electronic equipment.
The Physical Plant will pick up batteries when they pick up your electronic equipment.
Carefully put leaking batteries into a leak-proof container. Affix a properly filled in Hazardous Waste Label and bring to your Hazardous Waste Central Accumulation Area.
All employees
Alkaline batteries manufactured before 1992 Alkaline batteries, manufactured after 1992, can go in the non zero sort trash. All employees
Unsealed lead acid batteries are excluded from management under Universal Waste if reclaimed. Reclaim with an auto parts store or take to the county transfer station. No need to label. Motor Pool employees
Lamps (40CFR 273.5)

Contact EHS x2190 with Hazardous Waste questions.

Type of Waste What to do Who should do it
Fluorescent
High Intensity Discharge
Neon
Mercury vapor
Place old lamps in the properly sized and labeled container (heavy cardboard drum or box with a lid) in your area. No 8ft. lamps in 3ft. containers. Use the Universal Waste Lamps Label. Physical Plant personnel
High-pressure Sodium
Metal halide
Inform your supervisor when the container is full. Contact NYSCC Physical Plant x2460
Incandescent bulbs are not Universal Waste and can go in the non zero sort trash Call your supervisor for properly labeled boxes and drums as needed. Enter start date on label when the first used lamp is placed in the container Contact AU Physical Plant x2154
Carefully clean up all spill debris from broken lamps and place in a plastic bag. Then place bag into a 5 gal. UN approved plastic pail with lid. Affix a properly filled in Hazardous Waste Label and bring to your Hazardous Waste Central Accumulation Area.
Lamp Ballasts
Type of Waste What to do Who should do it
No PCB
PCB Containing - manage as hazardous waste. Use hazardous waste label.
Place ballasts in a properly labeled container in your area (5 gallon UN approved plastic pail with a lid). Make sure ballasts with no PCBs are stored and properly labeled in containers separate from those which contain PCBs.
Non-PCB ONLY lamp ballasts will be sent out with lamps. PCB containing ballasts will be transferred to the appropriate CAA when a hazardous waste removal has been scheduled.
Electricians & Physical Plant Supervisors
Mercury Containing Devices - e.g. thermostats. Use hazardous waste label. Place mercury containing devices in a properly labeled container in your area (1/2 gallon or larger UN approved plastic pails with a lid). Use the Hazardous Waste Label and contact EHS when full.
Mercury containing devices will be transferred to the appropriate CAA when a hazardous waste removal has been scheduled.
In the event of a small mercury spill, carefully clean up the spill using a mercury spill kit. Mercury spill kits can be obtained from EHS. Affix a properly filled in Hazardous Waste Label and bring to your Hazardous Waste Central Accumulation Area.
Electricians & Physical Plant Supervisors


Contact EHS x2190 with Hazardous Waste questions.
Pesticides
Type of Waste What to do Who should do it
Any & All All pesticides should be brought to the appropriate Central Accumulation Area and will be managed by EHS as a Universal Waste under regulation 40 CFR Part 273. Physical Plant personnel

Note: A Pallet Contents List must be submitted to EHS as least two days prior to the scheduled transport of the universal waste for each pallet of universal waste being shipped. The Pallet Contents form and appropriate pallet label may be downloaded from the EHS web site.

If a spill or volume of breakage is beyond your ability to clean up:

  • Ensure that all individuals immediately evacuate the affected area
  • Call AU Public Safety x2108 and EHS x2190
  • Tend to any injured personnel once in a safe location
  • Ensure that no one enters the affected area until help arrives
  • Account for any missing people or people still in affected area
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