Drew University
OP-21: Hazardous Waste Management

Drew University will make every effort to reduce the amount of non-hazardous, universal, medical, and hazardous waste on campus. This will include, but is not be limited to, maintaining an inventory control system to avoid the unnecessary accumulation of chemicals. EPA has established guidance recommending six key elements that should be incorporated into a waste minimization program. These key elements are: • Top management support; • Characterization of waste generation and waste management costs; • Periodic waste minimization assessments; • Cost allocation system; • Encourage Technology transfer; and • Program implementation and evaluation. Complying to regulations associated with being a large quantity hazardous waste generator, Drew University practices the key elements recommended by EPA in the following ways. 1. Top management support • This Waste Management Plan was requested by and submitted to the upper management of Drew University • Drew University trains appropriate employees annually on the waste generated and associated impacts resulting from the way associates conduct their work procedures. 2. Characterization of waste generation and waste management costs • Waste is characterized according to Section 4 of this Plan. • Waste generation is accounted in the Waste Accumulation Log as described in Section 6 of this Plan. • Waste costs are maintained by the purchasing department of Drew University. Waste agreements and contracts are maintained in the Environmental Files. 3. Periodic waste minimization assessments • Drew University continuously strives for process improvement and optimization to reduce waste and thus reduce costs. • Drew University recycles waste when possible. 4. Cost allocation system • Drew University maintains invoices for not only the cost to dispose of hazardous waste, but also the cost of contractors to manage their hazardous waste activities. 5. Encourage Technology Transfer • Drew University is a member of the Association of Independent Colleges and Universities of New Jersey (AICUNJ). Through the association, Drew University participates in a peer audit program where peers not only audit each other’s campus, but also share best management practices, success stories, and opportunities for improvement. 6. Program implementation and evaluation • As appropriate, opportunities to reduce waste and optimize efficiency are implemented. This element combines the principals of each of the elements listed above.

All waste vendors used by Facilities to dispose of Universal and Hazardous waste are licensed waste haulers, permitted by the state. Presently we use Veolia Environmental Services. All of Drew's Hazardous, Universal and other chemical waste disposed of by Veolia is tracked through a manifest system (also known as a "Cradle to Grave" system) so that every container is tracked from the time the waste is generated until it is destroyed at some point later in time. Drew is considered a "Large Quantity Generator" of hazardous waste by the NJ DEP and EPA. Because of this designation, Drew must ensure that all hazardous waste is managed in accordance with the applicable regulations. As described in the Waste Management Plan, hazardous waste is collected in two main types of areas; Satellite Areas and Central Accumulation Areas (CAA's). Satellite Areas are areas such as lab hoods were waste from an experiment is collected and or consolidated (labeled). There are volume limits in the Satellite areas so at some point the waste is moved to the several designated CAA. Waste from CAA's must be removed/taken off site at least every 90 days. All CAA's are inspected at least weekly to ensure that the integrity of containers and proper labeling of containers is maintained. Additionally personnel involved in the handing and inspection of the waste in these areas must receive our Hazardous Waste Training and also training on what to do in the event f an emergency (Emergency Contingency plan).