Universal Waste Policy
New York has adopted "Standards for Universal Wastes" for mercury thermostats, batteries, pesticides, and lamps pursuant to 6 NYCRR 374-3.
Universal wastes must be managed in a way that prevents releases of mercury or other hazardous constituents to the environment during accumulation, storage, and transport. Small Quantity Handlers (SQHs) of universal waste are defined as generators who do not accumulate more than 5,000 kilograms of universal waste at any time. Large Quantity Handlers (LQHs) of universal waste accumulate more than 5,000 kilograms of universal waste at any time. SUNY Canton is a SQH of universal waste, generating universal waste batteries and lamps.
The following storage and management requirements apply to both SQHs and LQHs (unless otherwise noted):
- Universal waste lamps or container holding waste lamps must be labeled with the words: "Waste Lamp(s)".
- Containers holding universal waste batteries must be labeled with the words: "Waste Batteries."
- Universal waste pesticides must be labeled with the words: "Waste - Pesticide."
- Universal waste thermostats must be labeled with the words: "Waste Mercury Thermostats"
- Universal wastes (lamps, batteries, thermostats, and pesticides) must be managed in a way that prevents releases to the environment. Universal waste lamps must be stored in containers or packages that are closed, structurally sound, adequate to prevent breakage, compatible with the contents, and lack evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions. SUNY Canton has provided heavy fiber drums for this purpose. Three types of drums are available for waste lamps 4 8 and a miscellaneous drum. All HIDs, compact fluorescent, circle line fluorescent and U tubes are to be stored in the miscellaneous drum. Incandescent light bulbs are not considered universal waste and should be placed in the trash.
- Batteries must be managed in a way that prevents releases to the environment. Large size 12 volt automotive type batteries are not considered to be universal waste, as they are managed for recycling. These batteries will be stored on containment pallets within the Hazardous Materials Storage Building. The recycling will be handled by the storehouse.
All other types of batteries, small lead acid, alkaline, Ni Cad, lithium will be co mingled in plastic 5 gallon pails labeled for this type of collection. The collection point will be the Hazardous Materials Storage Building. Campus staff may drop batteries off at Cooper Service Complex or use campus mail to deliver them to the storehouse.
- Mercury containing thermostats and switches are principally handled by the HVAC Dept. As these items are removed from use, they will be stored in 1 gallon plastic pails in the hazardous materials storage building.
Universal waste cannot be accumulated for more than one year. In order to demonstrate accumulation time, SUNY Canton has adopted the following method:
Label the container holding the universal waste with the date waste was first placed in the container. All universal waste will be stored in the Hazardous Materials Storage Building at Cooper Service Complex. The only exception to this rule is waste lamps. Waste Lamps must be stored in an approved satellite accumulation area. When the waste lamp container is full it will be relocated to the Hazardous Material Storage Building, at Cooper Service Complex, where it will be held pending disposal.
The approved satellite waste lamp storage areas are as follows:
- French Hall 118B
- Cook Hall 215
- Payson Hall 104
- Miller Campus Center 113
- Faculty Office Bldg - Wicks 033C
- Wicks Hall 033C
- Dana Hall 205
- Southworth Library 007
- Nevaldine Hall - NS 114B
- Cooper Service Complex 120B
- University Police - Cooper Service Complex 120B
- Newell Veterinary Science 116F
- Chaney Dining Hall - Large Store Room
- Smith Hall 013
- Mohawk Hall 013
- Rushton Hall 013
- Heritage Hall 013
Any releases of universal waste or universal waste residues must be immediately contained. Batteries, thermostats, pesticides, and lamps that show evidence of leakage, spillage, or damage must be stored in containers that are closed, structurally sound, adequate to prevent breakage, compatible with the contents, and lack evidence of leakage, spillage, or damage that could cause leakage under reasonably foreseeable conditions. Any release not cleaned up could constitute illegal disposal and may be required to be reported under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) if reportable quantity thresholds are exceeded. In addition, universal waste handlers must determine whether any materials resulting from a release is a hazardous waste and, if so, manage the hazardous waste in compliance with all applicable state and federal provisions.
SQHs are not required to maintain records of shipment. SUNY Canton will keep a listing of all materials disposed of as universal waste for a period of three years. These records will be compiled and maintained by the Physical Plant.
SQHs must inform all employees who handle or have responsibility for managing universal waste of proper handling and emergency procedures appropriate for the universal waste. All Physical Plant staff who handle universal waste as well as other necessary campus staff will be trained annually.