Hazardous Waste Management Policy

Hazardous Waste Management Policy

Directions: 

This document provides project teams with a policy that can be used as a template and adopted in full to comply with requirements of the Fitwel Hazardous Waste Management Policy. Project teams can either use the exact content of this document to establish new policies, or update existing policies by adding any missing components from the below. Official policies must include policy duration dates and be on company letterhead. 

A qualifying Hazardous Waste Management Policy Must include all of the following:

Section 1: Implementation

A qualifying Hazardous Waste Management Policy must apply to all waste generated by the project.

Section 2:

Universal Waste is commonly generated waste that displays any of the following characteristics or is contained in one of the types of listed universal waste identified below:

  • E-waste, including:
    • All electronics, including computers, monitors and TVs
    • Batteries
  • Sharps, including:
    • All glass and breakable items
    • Knives, scissors and sharp utensils
  • Tanks and Cylinders
  • Chemicals and Solvents, including:
    • Pesticides
    • Cleaning products and solvents
    • Lawn and garden care products
    • Oil-based paint
    • Latex based paint
    • Antifreeze
  • Automotive, including:
    • Tires
    • Motor oil and transmission fluid
    • Gasoline
  • Flammables
    • Aerosol cans
    • Mercury containing equipment, including:
      • Lamps
      • Thermometers and thermostats
  • Fluorescent tubes and CFLs
  • Appliances, including:
    • Microwaves
    • Fans
    • Irons
    • Air conditioning units
    • Refrigerators
    • All appliances containing CFCs (such as some older refrigerators or air conditions)

Section 3: Universal Waste Management 

  • Waste Minimization
    • Implement practices to minimize the accumulation of waste, such as
      • Selecting products that have a manufacturer’s lifecycle assessment
      • Inventory and track end of life products
      • Purchasing electronics with universal chargers
      • Purchasing electronic products with manufacturer take back programs
      • Implement a formal recycling process
  • Waste Collection and Storage
    • Universal waste must be collected, managed and/or stored in a way that prevents releases to the environment. Implement all of the following waste collection and storage practices:
      • Store universal waste for a maximum of one year
      • Clearly label all products and group waste materials of a similar type
      • Package and contain waste in leak-proof containers that are tightly sealed
      • Place all containers upright
      • Package all “sharps” in labeled, puncture-resistant containers
      • Utilize separate sealed bags or boxes for all broken glass waste
      • Ensure that all aerosol cans are empty prior to recycling ▪ Inventory and track end of life products
      • Provide a storage and collection area specifically for e-waste and batteries
      • Donate electronics in working order
    • Provide educational materials to tenant and/or occupants on e-waste that includes information of any of the following:
      • Electronic donation programs
      • Manufacturer take back programs
      • Local municipality disposal guidance
      • Third party e-waste collection vendors
  • Safe Waste Disposal
    • Implement all of the following safe waste disposal practices:
      • Provide PPE to all occupant handling waste
      • Utilize a pickup and collection log that clearly identifies the dates and times of waste pickup and collection
      • Ensure scheduled pickups for e-waste and batteries
        • E-waste includes all electronics, including computers, monitors, TVs and batteries

Section 4: Hazardous Chemical Waste Definitions

(Include this section if applicable to the project)

Hazardous chemical waste is any solid, liquid, or gaseous material that displays any of the following characteristics or is contained in one of the four separate types of “listed hazardous chemical waste” below.

  • Hazardous Waste Characteristics
    • Ignitability: liquids with a flash point of 140°F or below, oxidizers or spontaneously combustible materials (D-Codes)
    • Corrosivity: PH ≤ 2 or ≥12.5, (D-Codes)
    • Reactivity: materials that readily explode or undergo violent reactions (D-Codes)
    • Toxicity =: wastes likely to leach dangerous concentrations of toxic chemicals into groundwater (D-Codes)
  • Listed Hazardous Chemical Waste
    • Listed Hazardous Wastes from Nonspecific Sources (F-Codes)
    • Listed Hazardous Wastes from Specific Sources (K-Codes)
    • Listed “Acutely Hazardous” Waste, from discarded commercial products (P-Codes)
    • Listed “Toxic” Waste from discarded commercial chemical products (U-Codes)

Section 5: Management of Hazardous Chemical Waste

(Include this section if applicable to the project)

  • Hazardous Chemical Waste Minimization
    • Implement strategies to minimize the mount of hazardous waste generated, such as the following:
      • Centralizing purchasing of chemicals through a single entity
      • Ordering the smallest quantity of chemical materials required
      • Purchasing mercury-free instruments
      • Substituting hazardous chemicals with non-hazardous chemicals whenever possible
  • Hazardous Chemical Waste Management
    • Implement all of the following strategies to management hazardous waste:
      • Provide training and PPE to those handling hazardous waste
      • Provide relevant safety information to all occupants
      • Label all hazardous waste in containers with material, date and safety information
      • Log pickup, collection and storage dates
  • Hazardous Chemical Waste Generation + Storage
    • Provide access to ‘Satellite Accumulation Area’ (SAA) where up to 55 gallons of non-acutely hazardous waste (non P-Waste) or up to one quart of P-Waste may accumulate and be stored.
    • Hazardous chemical waste below the maximum limits (55 gallons or 1 quart) may be stored in SAAs for up to one year, if the following guidelines on container use, management and labeling are met
      • Hazardous waste must be placed in containers that are washed and in hood condition where leaking is not possible
      • Hazardous waste must be compatible with their containers, i.e., containers storing hazardous waste must be made of or lined with materials that will not react with and are otherwise compatible with the hazardous waste being store
      • The containers holding the waste must always be closed securely during storage, except when it is necessary to add or remove waste
      • Chemical waste must be segregated by general waste type and arranged so that incompatible substances will not mix. The following principles must be followed for safe hazardous waste storage:
        • Store acids and bases separately
        • Keep acids apart from cyanides or sulfides
        • Acids should never be put into steel containers
        • Water-reactive agents must be stored apart from water, aqueous solutions and acids
        • Oxidizing agents must be kept apart from reducing agents and organic compounds
        • Water-reactive, strong acids such as organic halides, organic acid anhydrides, inorganic acid anyhydrides and strong acidic salts must be kept apart from both alkalis and water
        • Air-reactive materials must be packed in containers that are sealed off from the atmosphere
      • Containers must be marked with the words “Hazardous Waste” and with the information identifying the contents of the containers
      • Containers must be arranged so that identification is readily visible
      • Satellite accumulation start dates (the date the container first started holding hazardous waste) are marked on all containers
      • If the amount of waste exceed the maximum limits (55 gallons or 1 quart), the following guidelines are met:
        • The generator must mark the container with the date the limit was reached
        • The excess waste must be removed from the SAA within three days
      • Hazardous Chemical Waste Disposal
        • Disposal of hazardous chemical waste into sinks, drains, commodes or other sewage disposal channels is prohibited
        • Hazardous chemical waste must be safely shipped to a certified Hazardous Waste Management Facility for disposal