Office of Environmental Health and Safety

Universal Waste Management Plan

In October, 2001, the State of Connecticut adopted the U.S. Environmental Protection Agency's rule governing the management of certain hazardous wastes. Although still considered "hazardous," this "Universal Waste" rule provides for reduced management and record keeping requirements regarding those specific wastes.

What is "Universal Waste?"

In Connecticut, the following waste materials are considered Universal Waste:

• Fluorescent light tubes (mercury, lead)
• Fluorescent lamp ballasts* (oil, possibly PCB's) (Oil containing ballasts only. Provided there are no other hazardous components, dry capacitors/ballasts may be discarded into the regular trash.)
• High Intensity Discharge (HID) lamps (mercury, cadmium, antimony)
• High pressure sodium vapor lamps (mercury, cadmium, chromium)
• Mercury vapor lamps (mercury, cadmium, antimony)
• Thermostats (mercury)
• Lead acid batteries (lead, sulfuric acid)
• Nickel cadmium (NiCd) batteries
• Some types of button batteries (mercury, cadmium, lithium or silver)
• Used electronics, including but not limited to Computer Monitors/Televisions and CPU's lead, possibly cadmium, chromium, barium and mercury)

http://dep.state.ct.us/wst/mercury/uwrule.htm

The Director of Environmental Health and Safety is responsible for ensuring that all hazardous waste is properly managed, stored, packaged, labeled and disposed of by an approved contractor, and is the only person authorized to schedule shipments of wastes described in this plan, and to sign manifests and/or bills of lading. He may, when necessary, delegate this authority to a properly trained alternate.

Proper Management of Universal Wastes

Fluorescent Light Tubes and High Intensity Discharge Lamps:

1. Note: Physical Plant has an employee whose primary job is to change light fixtures. If you have a light bulb or tube that needs replacing, call the Work Control Desk at extension 2253.
2. When changing fluorescent light tubes, high-pressure sodium vapor, or mercury vapor lamps, takes care not to break the lamp.
3. Place the spent tube into the cardboard box or the sleeve the replacement tube came in.
4. Transport spent tubes/bulbs to the Stockroom at Physical plant. There, the tubes will be sorted by size and type, and placed in special cardboard tube barrels, provided by the disposal contractor.
5. The Stockroom Coordinator will ensure that each tube barrel is properly marked with a fluorescent green "Universal Waste" label. (See below for labeling requirements.)
6. The barrel will be moved to the hazardous waste storage facility within 72 hours upon being filled.
7. On a regular basis, the contractor will take the accumulated mercury containing lamps for recycling.

Batteries:

1. Batteries containing hazardous components are collected in a similar manner as mercury containing light tubes. Physical Plant tradesmen collect spent rechargeable batteries from a variety of sources such as from campus vehicles, emergency lights, generators, and portable power tools.
2. The batteries are to be brought back to the Stockroom at Physical Plant, where they will be segregated by type. Smaller NiCds and NiMH batteries will be placed in covered plastic pails, while larger Lead Acid batteries are stored on secondary containment inside the 180 day Hazardous Waste facility.
3. A "Universal Waste" label must be affixed to the plastic container when the first battery is deposited. A label must be affixed to every lead acid battery placed on the secondary containment in the hazardous waste storage facility.
4. Ordinary alkaline batteries may be discarded into the regular trash.

Thermostats (Mercury Containing)

1. Thermostats are to be placed in a covered pail in the Physical Plant Stockroom. When full, the pail will be moved to the hazardous waste storage facility.
2. As with other universal wastes, a properly filled out label must be affixed to the container from the moment the first thermostat is deposited.

Computers and Other Electronics

1. Contact Physical Plant at ext. 2253, or email workreq@conncoll.edu to request a pickup of computers and other electronics. They are collected and stored in the basement of Hamilton Hall until disposal.
2. A "Universal Waste" label must be affixed to each monitor or electronic component, with the date discarded recorded.

Labeling Requirements

As previously discussed, labels that are clearly marked with the words "Universal Waste" must be affixed to the plastic pail, cardboard barrel, or to each battery or electronic component placed in storage pending disposal. The date of disposal must be annotated on the label. (This label will be affixed at the waste storage area.) Universal Waste rules state that we have 1 year from that date to ship the waste offsite for proper recycling and disposal.

Disposal

Used electronics (and most other "Universal Wastes") are sent to recycling companies where the hazardous constituents (lead, mercury cadmium, etc.) are processed, and are eventually reused in new products. 

Spill Procedures

When a fluorescent lamp or tube is broken, most of the mercury vapor is released. But because some mercury remains in the phosphorus powder, Connecticut has determined that broken lamps and tubes are no longer "Universal" waste, but becomes "Hazardous Waste". The following procedures address management of damaged universal waste streams:

Mercury Containing Fluorescent Lamps

• Do not throw fluorescent lamp tubes or high intensity discharge lamps, broken or unbroken into the regular trash.
• Ventilate area where breakage occurred.
• Wear appropriate PPE. At a minimum wear a pair of latex gloves .
• Do not vacuum debris  from a broken fluorescent lamp  with a standard vacuum cleaner! ( Only vacuums designed specifically for hazardous waste may be used.)
• Instead of vacuuming, carefully pick up the larger glass fragments. Thoroughly clean the spill with a damp disposable sponge or paper towels , to remove  the mercury containing phosphorus powder and any remaining glass fragments .
• Dispose of clean up materials, used gloves and lamp remnants in a closed container. Or double bag, and place in a cardboard box.)
• Take the container to the stockroom manager at the Service Building.  Alternatively, give the container to a custodian for transport to Physical Plant.
• Contact the Director of EH&S for at extension 2252 for assistance.

Broken Lead Acid Batteries:

• Don appropriate PPE (At a minimum, heavy duty nitrile gloves and splash goggles).
• Prevent the spread of sulfuric acid by creating a berm around the spill with kitty litter or "Speedi-dri".
• Place the broken battery into plastic pail that has a tight fitting cover/lid.
• Neutralize the acid with baking soda, found in the chemical spill kit.
• Use an absorbent pad or speedi-dri to soak up the spilled liquid.
• Place the absorbent pad , contaminated kitty litter, baking soda and neutralized acid into the pail with the broken battery.
• Affix a properly completed hazardous waste label and place in the Hazardous Waste Storage Facility.
• Contact the Director of EH&S for assistance at extension 2252.

Broken Computer Monitors or televisions:

• Wear personal protective attire appropriate to prevent injury when cleaning up broken CRT glass and debris. Recommended attire includes safety glasses, puncture resistant gloves (e.g. leather or other heavy duty work gloves), protective clothing such as long sleeve shirt and pants.
• Sweep up the broken glass and dispose of in large heavy duty plastic bags. Double bag the waste. If possible, place the bag into a cardboard box, and tape it shut. Do not attempt to remove any portion of the CRT from its housing or television cabinet.
• Fill out an orange "Hazardous Waste" label and affix it to the bag(s) or box.
• Call the Director of Environmental Health and Safety to coordinate transport to the hazardous waste storage facility.
• Contact the Director of EH&S for assistance at extension 2252.

Important Note: Once the spill is cleaned, call the Director of EH&S, and provide details of the incident. The Director of EH&S will notify the Connecticut Department of Environmental Protection, which requires immediate notification of hazardous materials spills of any quantity.

Mercury Spills

Because of post-cleanup testing requirements, the Director of Environmental Health & Safety will respond to all elemental mercury spills. Determine the extent of the spill, evacuate and secure the area so the mercury does not get "tracked" or "kicked" around, then contact the Director of EH&S at extension 2252. (After hours call Campus Safety at extension 2222.

The Director of EH&S will:

• Don proper personal protective equipment (Nitrile gloves and safety glasses).
• Utilizing a mercury vacuum pump and "Hg Absorb" powder, collect all loose globules of mercury.
• Test the spill area with "Mercury Test Swabs."
• Sprinkle "Mercury Vapor Adsorbent," and allow time for the powder to absorb any remaining mercury vapors.
• Place the mercury, cleaning materials and gloves into an appropriate container (glass or plastic, with a tight fitting lid/cap), properly label with a Hazardous Waste Label (See the Hazardous Waste Management Plan) and place in the Hazardous Waste Storage Facility.

For comments or questions, contact 
Steve Langlois, Director of Environmental Health and Safety, (860) 439-2252