Toxic Use Reduction Plan - University Campus

I. Promulgation Statement

This document and its attachments are promulgated as required by Maine’s Toxics Use and Hazardous Waste Reduction Law, 38 M.R.S.A. §§ 2301 et seq. (“TURA”). In the 1990’s, the University of New England (UNE) began generating enough hazardous waste to qualify as more than a “Small Quantity Generator” and is now subject to the hazardous waste reduction planning and reporting requirements of TURA.

This Pollution Prevention Plan (the “Plan”) is adopted as University policy by and prepared under the direction of the vice president for business and finance. The Plan describes UNE’s on-going efforts to minimize hazardous waste generation and assure its proper handling.

This document is authorized by the senior official with management responsibility for the person or persons completing the plan.

Bernard G. Chretien
Vice President for Business and Finance

II. Management Policy

UNE is committed to excellence in protecting the environment and the environment of its faculty, staff, students, and the University community. In keeping with this policy, our objective is to reduce waste and emissions, and to minimize adverse impacts on the air, water and land. By successfully reducing waste and emissions, we have maintained a safe and healthy campus. We will continue to look for opportunities to prevent pollution and minimize hazardous waste. UNE’s environmental guidelines include the following:

The University believes that all faculty, staff, administration, students, and patrons are entitled to a safe and healthy campus. To ensure this ideal, UNE will commit resources to aggressively remove recognized hazards, provide education and training, provide appropriate personal protective equipment, as well as hold administrators, faculty, staff, students, and patrons responsible for good health and safety practices.

Reducing the generation of hazardous waste should be an important consideration in operation of the University and research and educational activities. UNE is committed to identifying and implementing reduction opportunities through encouraging and involving faculty and staff and, where possible, students.

Technologies and methods, which substitute non-hazardous materials and utilize other source reduction approaches will be given priority in addressing all environmental issues.

UNE seeks to demonstrate its responsible citizenship by adhering to all environmental regulations, including those promoting hazardous waste minimization.

III. Hazardous Waste Minimization Planning

A. Identification of Wastes

Hazardous wastes currently generated at UNE include waste solvents, laboratory wastes, light bulbs, formalin, motor oil, and mercury.

Hazardous wastes generated by UNE that are not subject to minimization requirements under TURA include (1) wastes from the treatment of water used for human consumption, such as the swimming pool water, and (2) hazardous wastes sent off site generated as a result of facility clean ups and wastes shipped out to protect public health and the environment.

B. Analysis of Minimization Techniques

UNE has evaluated several methods of reducing hazardous waste, and implemented them effectively. These will be continued on the possibility that they may continue to be effective as described further below. These methods are:

Changes in Processes and Activities. UNE has phased out its embalming process. UNE has ceased performing it’s own embalming and accepts cadavers that already contain formalin (the emblaming solution). UNE will continue to investigate whether it can change other processes to reduce hazardous waste.

Recycling. UNE recycles light bulbs and waste oil. UNE also collects silver from photographic processes and sends them for recycling.

Ballast replacement. PCB containing ballasts are no longer used at the University. These ballasts have been replaced by better, environmentally friendly units.

III. Facility Goals

UNE has engaged in hazardous waste minimization under the Plan and reduced its waste generation before becoming subject to TURA. In light of the reductions already achieved, UNE sets the following hazardous waste reduction goals: 2002 – 0%; 2004 – 0%; 2006 0%.

IV. Strategy and Schedule for Reduction Implementation

UNE will evaluate reducing the volume of hazardous waste during the year 2000 and subsequent years using the following means:

1. Use of alternative substances. UNE has empowered the chemical hygiene officers to review laboratory chemical purchases and the environmental health and safety coordinator to review general facility purchases of chemicals in advance of placing orders and to explore alternative substances and substitutes that will not generate hazardous wastes. That may not be possible in many cases, particularly where specific chemicals must be used and specific experiments must be conducted as part of University education.

2. Reduction of Hazardous Waste Solvents. UNE will make serious attempts to switch to non- hazardous waste solvents, and will investigate those alternatives through suppliers and other means.

Changes in Processes and Activities. UNE will continue to investigate whether it can change other processes to reduce hazardous waste.

Recycling. UNE will investigate further recycling opportunities for the hazardous waste that it generates. UNE may consider on-site recycling of hazardous waste, including solvents, in particular.

Segregation. UNE will determine whether its wastes may be mixed such that segregation will allow UNE to reduce waste.

In addition, the environmental health and safety coordinator will undertake an annual review and evaluation, including the annual review of waste management issues including costs and work with the chemical hygiene officers on waste minimization.

V. Plan Updates and Reporting

Pollution prevention progress reports will be submitted as required by TURA. This pollution prevention plan will be updated at two-year intervals, when required by TURA. Employees will be notified six-months prior to the planning update deadline, when applicable.

VI. Records

Records relating to hazardous waste are maintained in accordance with hazardous waste rules. Records related to the costs of disposal of hazardous waste are available through records maintained by the Accounting Department.

A complete copy of this plan, annual progress reports and supporting documentation will be maintained at the facility for at least five years.

VII. Unit of Product

The business of the UNE is education. For purposes of TURA reporting, UNE establishes the number of students registered for any class at the Biddeford campus as the “unit of product” by which it will evaluate reductions. The Westbrook College Campus of UNE is considered a small quantity generator and therefore does not fall under the TURA regulations.

VIII. Employee Training and Awareness

Employee training is addressed several ways. First, hazard communication training at the University includes awareness of the wastes that may be generated and includes training on the benefits and means of hazardous waste reduction, and on this plan. Second, the annual hazardous waste training required by hazardous waste rules also includes training on the benefits and means of hazardous waste reduction, and on this plan.

Updates to this plan will be announced to the employees through an open letter or similar announcement six months before updates are required.
    
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