Seattle University
OP-21: Hazardous Waste Management

--Seattle University continues to be rated as a Small Quantity Generator under chemical waste regulations WAC 173-303 Dangerous Waste Regulations. This status is maintained by having an aggressive and comprehensive recycling program within the Facilities Services Department. The EHS Manager and the Recycling Coordinator interact with the campus community to encourage use of best practices and provide education and manager vendor services (Stericycle and 3R Technology). --SU submits an annual report to the Dept of Ecology that documents the steps SU follows to reduce its “dangerous” waste. --Members of the campus community may ask for a Waste Assessment which includes evaluation for alternative management strategies as well as a Risk Evaluation using a risk mitigation tool. These are program enhancement tools designed to engage and educate the campus community to consider alternative strategies and reduce impacts and risk. --The Chemistry department reassessed all their labs in summer 2015 with the target of further reducing the use of hazardous materials. Chemistry students participate in Safety Teams during chemistry classes: they are active participants in planning, hazard analysis, documenting and verifying laboratory procedures and participating in safety awareness training activities. --The Dept of Engineering completed their ABET accreditation in October 2017 (preliminary findings were favorable). --SU is no longer using radioactive isotope materials in research. As for radioactive sealed sources, SU began leasing these types of materials which then allows them to be reactivated by the manufacturer and doesn’t require waste disposal via a regulated waste disposal site managed by SU personnel. --SU is a member of Practice Greenhealth. This is a membership organization for greening the healthcare sector. SU is classified as a Community Health Center membership. This is a category designed to support College/University Student Health Centers and academic teaching allied health activities. Practice Greenhealth produces an annual benchmark report that details trends from numerous organizations across the country. It is a way to convene a conversation for those who understand the opportunities and challenges of working in a research and learning environment. Topics include how to connect with your board of directors, communicating successes, Earth Day activities, green building as a staff retention strategy, and new employee orientation as an educational opportunity, https://practicegreenhealth.org. --SU is also a member of CSHEMA (Campus Safety, Health and Environmental Management Association); this is a membership organization for enhancing health & Safety and Regulatory compliance within the higher education sector. SU is committed to building, and maintaining environmental health programs using the Small College and Universities Complete Environmental Health & Safety Program guidelines, http://www.cshema.org/. --SU is a new member of the Campus Consortium for Environmental Excellence (since FY2017). C2E2 supports the continuous improvement of environmental management in higher education using information exchange, developing resources and tools, and the development of innovative regulatory models, http://www.c2e2.org/AboutUs.aspx. --SU is re-evaluating its waste management program and exploring opportunities that may exist within Subpart K to RCRA. In 2008, EPA added a new subpart, subpart K, to the Resource Conservation and Recovery Act (RCRA) hazardous waste generator regulatory requirements in Title 40 of the Code of Federal Regulations (CFR) in Part 262. Subpart K is applicable to eligible academic entities. The rule establishes an optional, alternative set of regulations that allow eligible academic entities some regulatory flexibility. Washington State adopted the subsection and codified in WAC 173-303-235. This rule is expected to result in safer laboratory practices and increase awareness of hazardous waste management requirements. The EHS Office has reached out to the Department of Ecology to explore a regulatory partnership to develop additional implementation guidance for academic operations in the region. The target peer institutions have less than 3 EHS professional on staff.

Chemical waste is managed through PSC Environmental Services. Biological waste is managed through Stericycle Inc. Universal waste is managed through a variety of recycling outlets.

No releases have occurred in the previous three years.

--A general excel spreadsheet is used to maintain chemicals inventories for low volume users on campus. These are hosted in BioRAFT, a tool to manage all environmental and health and safety information management needs. Preliminary uses target space usage, bio safety program management needs, and document management, http://www.bioraft.com. --The Chemistry Department uses Vertere Inventory Management software. --Engineering Departments, Facilities, and University Recreation had their HazMat inventories externally audited, using a third party vendor.

--The Facilities Services Department oversees the electronics recycling program for Seattle University. This effort is supported by guidance provided by King County and Washington State Department of Ecology. --Seattle University is shifting from Total Reclaim to 3R Technology for its campus-wide electronic waste recycling needs. They are R2 Certified, a member of WSRA, and an E-Cycle program member.