Universal Waste

Saint Joseph ’s University (SJU) considers environmental responsibilities in making universal waste decisions. SJU will purchase materials (when possible) that are:

Recyclable. If not recyclable, disposed of safely

• Non-toxic or minimally toxic, preferably biodegradable
• Highly energy-efficient
• Made from raw materials that have been obtained in an environmentally sound, sustainable manner
• Subject to minimal or no environmental damage during normal use or maintenance
• Shipped with minimal packaging (consistent with care of the product), preferably made of recycled and or recyclable materials

Definition

Universal Wastes are wastes that do meet the regulatory definition of hazardous waste, but are managed under special, tailored regulations. These wastes include:

• re-chargeable/hazardous batteries
• pesticides
• lamps/fluorescent bulbs
• mercury-containing equipment/thermostats

Waste should be stored in a manner that prevents discharge into the environment. For example, rechargeable/hazardous batteries should be stored so that acids will not enter the environment. Lamps should be protected from breakage and exposure to the environment.

The number of Universal Waste storage areas should be limited. Identification of new Universal Waste locations must be reported to the Department of Environmental Health and Radiation Safety within 30 days of installation.

Labeling of all Universal Waste is required immediately when stored. Storage is permitted only in designated areas marked “For storage of Universal Waste Only”. Labels must include the following words:

1. Universal Waste
2. Waste description
3. The date first stored.

For example, "Universal Waste - Mercury Containing Equipment"; or "Universal Waste - Lamps" 

Labels must be placed on each waste item or on the container holding multiples of the same items. Universal Waste Labels can be easily ordered or printed for specific wastes by the stockroom or may be provided by our waste vendor. 

Specific Item Labeling and Storage Requirements

Lamps:

• All used lamps will be stored in a closed container or box. Containers must be dated (and labeled) when the first bulb is placed inside. Example: A carton of spent fluorescent bulbs should be labeled “Universal Waste-Fluorescent Bulbs or Lamps"-00/00/00 (Month/Day/Year) when the first bulb is stored in the carton. (Accumulation start date)
• A preventive maintenance work order will be issued to all zone mechanics every 60 days to remove used containers. On University City, there is a storage location in the 4140 Building Warehouse.

All used lamp containers will be sealed and transferred to the Sullivan Garage on a regular basis for pick up by the waste disposal contractor. On UC, all bulbs should be sealed and transferred to the 4140 Building Warehouse for storage and disposal. These will also be picked-up by the waste disposal contractor.

Re-Chargeable Hazardous Batteries:

• All Facilities Management and Information Technology personnel will return out-of-service re-chargeable batteries to the Overbrook stockroom before replacement. Batteries will be separated and stored in sealed containers.
• A preventive maintenance work order will be issued every 60 days to the Stockroom Manager to move used batteries to Sullivan Garage for scheduled pickup.
• On UC, smaller (easily moved) hazardous batteries shall be separated (e.g., nickel-cadmium, lead-acid, lithium, etc.) and brought to the Griffith Hall Central Stockroom for storage and disposal. These will be stored in a closed container and labeled/dated properly prior to disposal. 
• Large batteries that are difficult to relocate may be stored properly in the 4140 Warehouse.  Store the batteries on pallets, each pallet labeled properly as “Universal Waste – Batteries”, with the accumulation start date, as mentioned. Do not stack batteries.
• Pallets or containers must be dated (and labeled) when the first battery is placed inside a container or on the pallet.

Pesticides:

• Pesticides use is outsourced to a contract exterminator.
• The Facilities grounds crew does not use pesticides.
• The Fieldhouse pool uses bromine which is installed by Main Line Pools. The Aquatics Director must have a current pesticide license. A copy of this license is available in the pool area.

Mercury-Containing Devices:

The Facilities Department has replaced most mercury thermostats with pneumatic e-Electronic devices. If a mercury thermostat switch or other device is encountered, the Associate Director for Facilities Management or designee should be contacted for removal and transfer to the approved Science Center (HH) or Griffith Hall stockroom (UC) locations for recycling. Hazardous projector bulbs may be brought to the storage location in a closed, plastic secondary container. Move containers on a cart. 

These will be stored in a closed container, labeled properly as Universal Waste - Mercury Containing Equipment, and with the accumulation start date. Containers must be dated (and labeled) when the first device is placed inside.

Computers/Electronic Devices:

All electronics, computers, computer monitors, TVs, computer components, printers, cathode ray tubes, tablets, etc. must be recycled and never thrown in the regular trash.  Recycling and proper storage and labeling of these is the responsibility of the Information Technology Department. 

• Intact (not damaged or broken) cathode ray tubes and leaded glass do not have specific labeling requirements when recycled, however, it is good practice to label the area “used computers” or “used CRTs”.
• Intact cathode ray tubes and leaded glass must be recycled on a regular basis and not be allowed to accumulate.  Bottom line is that if these and other electronic devices are removed for recycling prior to one year, the university will be in compliance and not have to comply with hazardous waste regulations.
• Broken cathode ray tubes/leaded glass must be stored separately from intact glass and CRTs. Place these in a leak-proof/puncture-proof container (tub) and keep the container closed to minimize releases during storage and transport. Do not store outside.
• Each container housing broken CRTs/leaded glass must be labeled with one of the following phrases:

      "Used cathode ray tubes – contains leaded glass, do not mix with other glass materials"; or

      "Leaded glass from televisions or computers, do not mix with other glass materials". 

• Broken CRTs/leaded glass must only be stored on-site for less than one year before recycling. 

Maintain certificates of recycling to show compliance.  IT should contact EHRS if there are any questions.

Inspections:

Personnel with Universal Waste responsibilities should conduct routine inspections of the areas to:

• Confirm that all items/containers in Universal Waste Storage locations are properly labeled/dated and containers closed.
• Inspect buildings to insure that Universal Waste is not stored in areas not designated for this purpose or are timely moved to the storage locations.
• Check that dumpsters do not contain Universal Waste.

Disposal

Transfer of Universal waste from building storage areas to the disposal contractor pick-up location is arranged by the building Facilities representative or the relevant department. This transfer is recommended no more than 90 days from the start date of accumulation. Universal waste should be removed from the campus pick-up location no later than 6 months from the date of generation.

Disposal contractors are required to dispose of all waste according to EPA and Pa DEP requirements and guidelines.

Universal waste must always be disposed (removed from the campus) within one year of the starting date indicated on the storage container or item.

Facilities, EHRS or the Stockroom(s) accept most types of batteries, owned by the university, for Universal Waste disposal with the exception of alkaline and household batteries. These types include Lithium, Mercury, Nickel Cadmium (NiCad) and Nickel Metal Hydride.

Definitions:

Alkaline (carbon-Zinc): These are common non-rechargeable batteries that most people use. Alkaline batteries are not regulated as hazardous waste and can be disposed of in the regular trash or sent to be recycled.

Lead-Acid batteries: These include automotive and smaller gel-cell batteries commonly use in emergency lighting systems. Lead-Acid batteries contain regulated amounts of lead and must be recycled.

Lithium Batteries: These batteries come in a variety of shapes and sizes, and are commonly used in computer clocks, cameras, watches, and other equipment.

Mercury batteries: These are usually small and button shaped. Mercury batteries contain regulated amounts of mercury and should be handled as hazardous waste. These batteries are no longer available in the United States although they may still be found in older equipment.

Nickel-Cadmium: These are the most common rechargeable batteries and are commonly found in cellular phones, and other types of rechargeable equipment. NiCd batteries contain regulated amounts of cadmium and should be handled as hazardous wastes.

Nickel Metal Hydride: These are rechargeable batteries that are commonly used in cordless hand tools and other types of equipment.

Pickup of Universal Waste is coordinated by the Director of Environmental Health & Safety at 610-660-3037 on HH and the Director of Environmental Health and Radiation Safety on UC at 215-596-8925.