Don't Overlook Hazardous Waste

• By Mike Rozembajgier
• 01/01/16

Institutions with well developed sustainability programs can benefit from a rigorous approach to sustainability in an often overlooked area: waste management. Operating a campus waste management program is inherently complex, with multitudes of locations across a widespread area; access and transportation considerations; and local and state compliance laws governing collecting, categorizing and disposing of waste.

Adding to this complexity is the fact that due to size and population on most campuses, these institutions are also generators of hazardous waste, which can include routine consumer items such as batteries, aerosols and alcohol-based personal care products to industrial cleaning solutions, herbicides, motor oil and toxic chemicals used in research labs. Hazardous waste management differs from general waste in that it must be handled, separated, transported and recycled or destroyed according to strict federal and state laws, for the protection of the environment and the safety of citizens.

What Generator Status Is, and Why It Could Change

Higher education institutions can vary greatly in terms of size, geography and the types of waste that they may generate. Overall, the EPA classifies waste genetrators in three ways:

• Conditionally Exempt Small Quantity Generators (soon to be known as Very Small Quantity Generators): those that produce less than approximately 220 pounds of hazardous waste per month.
• Small Quantity Generators: those that produce less than approximately 2,200 pounds of hazardous waste per month.
• Large Quantity Generators: those that generate more than approximately 2,200 pounds of hazardous waste per month.

Other conditions may also impact the generator status of an institution. Enforcement of compliance with hazardous waste laws falls to state agencies under the federal Resource Conservation and Recovery Act (RCRA). Recently, the EPA has modernized and taken a more data-driven approach to its operations, and is also revisiting the generator rules to determine if new classifications are warranted.

The refocused effort by the EPA to use data to help federal and state agencies refine their approach to hazardous waste management may lead to greater scrutiny for significant waste generators like universities and colleges. For instance, in October, the EPA fined the University of Missouri at Kansas City almost $33,000 related to its storage and handling of hazardous waste.

The unique intersection of faculty, employees, students and visitors moving about a typical U.S. college campus, combined with great variety of types of hazardous waste and a lack of awareness of how to handle or dispose of this waste, together make for ripe conditions for hazardous waste violations to occur frequently.

Waste Not: Reduce, Reuse, Recycle

Any organization, particularly those that generate chemical waste, must face the simultaneous challenges of managing its waste, maintaining compliance and minimizing environmental impact. It’s important to remember that for both hazardous and non-hazardous waste, destruction and disposal are not the only options.

Many waste types can be recycled, reused or repurposed in various ways, some of which constitute disposal, according to the EPA. Incorporating this into an institution’s sustainability program can bolster its annual goals and can even help create energy from material that would otherwise be considered waste, reducing its long-term risk profile and protecting its brand. Examples include:

• Alternate uses for hazardous waste (use constituting disposal): for example, some hazardous waste can be converted into new petroleum products.
• Incorporating hazardous waste into other products (use constituting disposal): using waste material to make other materials, such as asphalt.
• Reclamation of waste to recover usable components: examples include recovering mercury from broken thermometers; distilling used solvents to re-purify them; and reclaiming metals, paint and batteries.
• Direct use or reuse of a waste as an ingredient in a product or substitute product: for example, latex paint can be mixed with ash to make cement mix for concrete.
• Combustion for energy recovery: using wastes either as a fuel or as a heat-producing ingredient: oily wastes, for example, can be used to generate steam or electricity.

In the face of budget cuts, a complex regulatory environment and increasing visibility of incidents by the media, the education sector should consider hazardous waste management a priority in sustainability planning and budgeting in 2016. Managing hazardous waste is critical for ensuring safety, maintaining compliance and protecting a university’s brand.

This article originally appeared in the issue of .