New York University
OP-21: Hazardous Waste Management

NYU uses the following strategies to ensure wastes generated from NYU buildings (research, academic and facilities related) are managed and disposed of properly: 1. Policy – NYU has a Hazardous Waste Minimization and Disposal Policy which outlines the stakeholders, responsible parties, and procedures that must be followed for the safe handling and disposal of hazardous waste. This policy provides information to the stakeholders so proper identification of various wastes and how to manage them can be made. The policy provides regulatory citations, which this policy follows, along with internal processes. The University retains one vendor to provide consulting and proper disposal of hazardous and non-hazardous wastes. This vendor is overseen by the Department of Environmental Health and Safety. Waste is picked up periodically from various locations about all campus locations/satellite facilities. Certain waste (batteries, various light bulbs that contain hazardous components and mercury containing devices) are managed as Universal Waste, a subset of Hazardous Waste. Certain allowances are made available to building owners to recycle this waste rather than dispose of it as hazardous waste because of how common these items are in buildings. NYU’s policy can be found here: https://www.nyu.edu/life/safety-health-wellness/environmental-health-and-safety/safety-policies.html 2. Training – all personnel who generate hazardous waste or oversees employees who generate hazardous waste are required to attend an annual hazardous waste training. Notifications of upcoming trainings are posted on the EHS website and pushed through a compliance tool called BioRAFT for the research community. Live and online training are available to the University community, dependent upon employee designation (research, academic, facilities/service staff). Information for trainings can be found here: https://www.nyu.edu/life/safety-health-wellness/environmental-health-and-safety/training.html 3. Assessment – periodic assessments (at least annual) are performed by EHS, and at times with the assistance of a third party vendor, to ensure hazardous and non-hazardous wastes are managed and disposed of properly. Assessments may also identify inherent wastes, which would be disposed of properly through the University’s hazardous waste vendor. Waste minimization (e.g., using less toxic/hazardous chemicals and performing experiments on a smaller scale) is outlined in the Policy and discussed during annual hazardous waste training. An example of reducing hazardous waste from an experiment with hazardous components is to add steps in experiment protocol to render end products non-hazardous (especially from teaching labs). Another example is to share unopened chemicals amongst researchers rather than discarding virgin chemicals, if stock is no longer needed in a particular lab. The University is working on trying to streamline the latter process across different research communities (Chemistry, Biology, etc.). When it comes to research facility renovations, Environmental Health and Safety partners with the Office of Construction Management to ensure that any chemicals left behind are either repurposed to another lab or disposed of properly. In addition, decontamination of affected surfaces in the research facility is arranged for prior to demolition. This is to protect the construction personnel as well as protect the environment (construction landfills and recycling facilities). Although not considered Hazardous Waste, the University manages Regulated Medical Waste (RMW) Program with a policy that outlines the stakeholders, responsible parties and procedures for the safe handling and disposal of Regulated Medical Waste. Like Hazardous Waste, there are trainings provided to employees who work with and generate RMW. The waste removed from the University is manifested.

The Department of Environmental Health and Safety oversees the management of hazardous, non-hazardous, and universal wastes for the University; all wastes are disposed of through the University's vetted vendor to end disposal facilities that have been vetted. A regulatory mandated manifesting system is used to track waste from “cradle to grave”. Routine waste removed from the University does not leave the U.S. Training is provided to the University generators to ensure wastes are properly handled and stored for disposal; disposal is done per applicable regulations.

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The University’s research community and facilities use a compliance tool called BioRAFT. Chemical owners upload their chemical inventory into this program. Currently, there is no formal chemical sharing program across the various University research departments. The feasibility of some type of chemical sharing module may be looked at in the future. The Department of Environmental Health and Safety does encourage chemical users to notify others if they have a surplus of chemicals for repurposing, rather than going straight to disposal. For waste minimization, research staff are instructed not to over-purchase, as this may lead to unnecessary disposal of virgin chemicals (due to expiration and unwanted chemicals).

NYU Grounds and Waste Management manages the Recycling Program for the University. In the past, the hazardous waste vendor would also recycle certain electronic waste deemed Universal Waste due to heavy metal components (computers and monitors) and other electronics when recycling was in its infancy. In recent years computers have been re-categorized as electronic waste (e-waste) and techno scrap, and can be recycled.description of the electronic waste recycling. Students are able to recycle e-waste and technoscrap via segregation bins provided by the University. NYU also offers e-waste pickups for all departments and areas of the University. The waste is picked up and recycled by NYU's Responsible Recycling Certified recycler. This is available to staff, faculty, and students.