This plan aims to inform interested persons that Fort Lewis College is complying with Colorado Department of Public Health & Environment (CDPH&E) requirements for handling universal wastes (UW).
This plan applies to all departments and laboratories where materials identified as universal wastes are used. Universal wastes in Colorado include the following materials:
Fort Lewis College is a Very Small Quantity Generator (VSQG) based on the definitions of the CDPH&E. Fort Lewis College will follow the UW Small Quantity Handler (SQH) guidelines relative to training, record keeping, storage, and shipping to protect the campus community and environment surrounding the campus.
The universal waste plan is intended to minimize the hazards to human health or the environment from improper handling or disposal of these wastes in landfills. Written procedures for handling universal wastes set standard practices for daily, weekly, monthly, and even annual clean-up.
The Environmental Health & Safety (EH&S) Department is responsible for developing and maintaining this program and any records generated while managing this program to ensure compliance with the CDPH&E rules and regulations. A copy of the plan may be reviewed by employees online. Fort Lewis College encourages suggestions from our faculty, staff, and students for improving the program. Goals for this plan include a better understanding of the laws, safe behavior from associates involved in handling universal wastes, and active involvement in the plan from every campus level.
Fort Lewis College intends to ensure that accumulations of universal wastes are monitored and disposed of properly. Specific activities on campus generate universal waste, including the use of:
Spent universal waste batteries are handled in a manner that prevents releases to the environment. Examples include:
Suspended, canceled, obsolete, and recalled pesticides are handled to meet one of the following conditions:
Spent mercury-containing equipment is handled to prevent releases of mercury into the environment. Examples include:
There are numerous types of mercury-containing lights on campus. These include fluorescent, neon, mercury vapor, high-pressure sodium, metal halide, and other hazardous waste lamps. When handling spent lamps and bulbs we:
Electronic devices and components that might fail the EPA toxicity test are collected by the Information Technology department and sent to the City of Durango recycling center.
Aerosol cans sometimes need to be discarded before they are empty. This occurs for various reasons, including when the spray mechanism no longer operates as designed, the propellant is spent, or the product is no longer needed or used. It is our responsibility to determine if the materials in an aerosol can are hazardous. Aerosol cans containing hazardous materials that are still in use are not considered hazardous wastes. If the contents of the aerosol cans are hazardous, they must be managed in compliance with the Colorado Hazardous waste regulations. We use equipment designed to puncture the cans and drain what is left into a 55-gallon drum. Aerosol cans that are empty or punctured and contain materials that are not considered hazardous wastes may be thrown in the regular trash.
Although we take every precaution to prevent any spills of battery acid, pesticides, mercury, or other hazardous materials, we are prepared in the event one should occur. We are careful about the containers we select to store and ship our spent batteries, pesticides, or mercury-containing equipment. We have appropriate containment and personal protective equipment available for response personnel.
As a VSQG we are:
UW must be labeled in one of three manners. Using spent batteries as an example, the options are:
If UW is stored in an accumulation container, then only the container must be labeled. Waste containers must be maintained in good condition; if leaking, they must be placed in an over-pack container or removed and placed into a container that is in good condition. Any item showing signs of leakage must be stored in an over-pack container.
SQHs are not required to notify the CDPH&E of their UW management activities. A representative from the federal EPA or CDPH&E has access to all records upon request.
SQHs must inform all employees who manage universal waste about the proper handling and emergency procedures appropriate to the types of universal waste at the facility. Under our plan, employees will be informed of proper handling techniques for batteries, pesticides, mercury-containing equipment, electronic devices, and aerosol can. Additionally, training will include methods for handling UW during maintenance activities, proper packing and storage practices before disposal, and shipping protocol. In addition, they will receive appropriate hazard communication training for the hazardous substances in the universal wastes found on campus.
SQHs are required to immediately containerize and manage any spills or residues from releases of UW. Any waste generated from a spill is considered newly generated waste, and a hazardous waste determination is required. If determined to be hazardous waste, it must be managed as hazardous waste and not as a UW.
For our recycling efforts to succeed, we must follow CDPH&E’s requirements for universal waste being shipped to treatment/disposal facilities. The EH&S department is responsible for coordinating shipments of universal waste. This process includes ensuring UW is appropriately stored, tracking the amount of accumulated UW, retaining a licensed UW contractor for pickup and shipment, and tracking receipt of shipped waste from the state-approved Treatment, Storage, and Disposal (TSD) facility.
The EH&S department is responsible for the following:
Updated December 2022