Subject: Waste Minimization and Pollution

Effective Date: February 1, 1997

Approved: Robert Martin, Vice Chancellor - Policy: 8

PURPOSE AND BACKGROUND

The Pollution Prevention Act of 1990, as enacted by the United States Congress, sets forth a national policy requiring that pollution to the environment be prevented or reduced at the source. Under this legislation, Congress established a hierarchy of criteria in managing wastes. These criteria, in descending order of preference, include:

- Prevention through source elimination or reduction

- Environmentally-sound recycling

- Environmentally-sound treatment

- Environmentally-sound disposal.

The United States Environmental Protection Agency, the Indiana Department of Environmental Management and the Marion County Health Department have collectively adopted policies that, whenever and wherever feasible, the generation of waste be reduced or eliminated.

In addition, IUPUI, as a generator of hazardous chemical waste, has an obligation under federal and state regulation to reduce the volume and toxicity of the hazardous wastes generated on campus to the fullest extent economically practicable.

The Administration of Indiana University-Purdue University at Indianapolis (IUPUI) recognizes the principles of the Pollution Prevention Act of 1990 as a key cornerstone in the protection of both human health and the environment.

IUPUI Administration, by the adoption of this policy, shares the responsibility of practicing waste minimization with all staff, faculty, students and guests of the University community.

SCOPE

As the generation of waste is an integral part of the day-to-day operations of the University, and as virtually all employees produce waste as part of their University activities, this policy applies to all staff, faculty, students and guests of the University.

This policy also, by definition, applies to all University personnel that purchase or otherwise obtain chemical products whether the material be liquid, solid, or gaseous at room temperature. The policy applies to stock chemicals most frequently associated with laboratory environments and chemical-based products utilized in the maintenance of University buildings, grounds, property, equipment and supplies.

POLICY

- WASTE MINIMIZATION COORDINATOR
Each department shall assign a representative to serve as waste minimization coordinator(s) for specific areas, sections, laboratories, etc. within the department. Coordinators shall serve as resources for other departmental staff, facilitate implementation of waste minimization techniques within the area and may monitor and evaluate the effectiveness of the waste minimization program.

- WASTE MINIMIZATION TECHNIQUES
All University employees should objectively evaluate waste minimization opportunities in their work area. The following waste minimization techniques are to be considered when evaluating opportunities for minimizing the volumes of waste produced:

- PURCHASING CONTROL
- Order only the volumes of materials necessary to complete the desired activity or project.

- Purchase smaller lots of materials on a more frequent basis. Purchase only volumes that can be utilized during a defined period of time (e.g. every 3 or 6 months) Utilize suppliers that can offer quick delivery of needed materials.

- Purchase chemicals in smaller containers for easier management of unused chemicals unless it is known for certain that bulk volumes can be used expeditiously.

- Be aware of any physical property of the material or chemical that may preclude long- term storage of the material. (e.g. peroxide formation).

- Establish a centralized purchasing system within the department or area to monitor chemical purchase in an effort to avoid duplicate orders.

- INVENTORY CONTROL
- Attempt to redistribute unused materials and chemicals to other campus users. Objectively evaluate the potential use of chemicals offered for redistribution by other campus users.

- Attempt to return unused, unopened materials to vendor for credit.

- Ensure all containers containing chemicals, whether virgin or waste, whether in the original or secondary container, are labeled at all times.

- OPERATIONAL CONTROLS
- Periodically review each experimental or research protocol to assure that chemical usage is minimized.

- Reduce chemical usage in experimentation through the use of microscale techniques whenever practical.

- Evaluate less hazardous substitutes whenever feasible.

Examples include but are not limited to:

- Making double-sided photo copies when practical.

- Promoting the use of recycled and recyclable materials such as non-glossy, non-colored paper stock.

- Utilizing water-soluble, biodegradable scintillation fluids in place of solvent-based fluids.

- Utilizing specialty, biodegradable glass cleaning detergents in place of sulfuric acid/chromic acid cleaners.

- Utilizing a heat gun in place of chemical-based paint strippers.

- Utilizing specimens preserved in less toxic preservatives in place of those preserved in formaldehyde-based preservatives where feasible.

- Utilizing aqueous-based degreasers in place of chlorinated solvent or petroleum-based degreasers where feasible.

- Avoiding wet chemistry techniques when practical.

- Reclaim and reuse materials when feasible (e.g., utilizing spent solvent for initial gross cleaning step and utilizing fresh solvent only for the final rinse).(e.g. Having a naphtha- based parts washer serviced by a reputable service company that reclaims the spent degreaser).

- Neutralizing corrosive wastes as a final step of an experiment or procedure.

- Avoid mixing hazardous and non-hazardous wastes.

- RECYCLING
- Participating, to the fullest extent possible, in University-sponsored recycling programs. These programs include:
- Paper recycling
- Beverage can recycling
- Cardboard box recycling
- Nickel/Cadmium and larger lead/acid battery recycling
- Fluorescent light tube recycling

- NONCOMPLIANCE/PENALTIES
The Department of Environmental Health and Safety may, at its discretion, refer costs incurred from the disposal of wastes generated by actions contrary to the principles of pollution prevention and waste minimization back to the producing or generating department.

In the event the University is cited and fined by federal, state or local regulatory agencies for actions or activities contrary to waste minimization or pollution prevention regulations, the department(s) involved in the citation may be accountable for payment of the issued fine.

Staff, faculty, students and guests of the University whose willful actions violate pollution prevention and waste minimization regulation may be held criminally and civilly liable for their actions.

Any person affected by any such cost or fine assessment may appeal the assessment provided that a written request for such a review is submitted to the current Chairperson of the IUPUI Environmental Safety Committee within thirty (30) days of issuance of the assessment.

Department of Environmental Health and Safety will provide a written, itemized assessment of the incurred penalties to the responsible department or party(ies) and a copy of the IUPUI Environmental Safety Committee Appeals Procedures.

All appeals will be acted upon and reviewed in accordance with the established IUPUI Environmental Safety Committee appeals review procedures.

In addition, the University may initiate disciplinary actions, up to and including dismissal, against any staff or faculty found to be in violation of this policy.

PROGRAM OVERSIGHT AND EMPLOYEE ASSISTANCE

The Department of Environmental Health and Safety will serve as a technical resource for waste minimization activities. The Department will also serve to oversee the development and implementation of recycling activities on campus.

The Department of Environmental Health and Safety will provide program materials and guidance to Waste Minimization Coordinators, assistance for general waste minimization activities and assistance in recycling activities. Resources may be obtained by calling 274-2005.

Chemicals in sealed, unopened containers which do not have limited shelf lives, are routinely advertised in the quarterly-published University newsletter Lab Notes. Information on the exchange program is available by calling 274-4351.