The University of Memphis
Hazardous Waste Reduction
The University of Memphis follows the requirements of the Tennessee Hazardous Waste Reduction Act of 1990, TCA § 68-212-301 et seq, and calls for positive commitment to its objectives by administrators, faculty, and staff to continually seek opportunities to reduce the volume and toxicity of any hazardous wastes generated.
The primary objective of the University of Memphis Hazardous Waste Reduction Policy is to reduce all hazardous waste to the minimum quantity that is technically feasible and economically practical within the goals of the University. This policy is also intended to continue in perpetual effect as an instrument that will:
Hazardous waste conforms to the definition of a hazardous waste as contained in 40 CFR 261.3 and/or Tennessee Rule 0400-12-01-.02, including exhibiting a characteristic of a hazardous waste and/or being listed as a hazardous waste.
|Duties and Responsibilities|
|Description of the Plan|
Administrative support for the Hazardous Waste Reduction Plan will be provided by the Environmental Health and Safety Office with oversight by the University Standing Committee on Safety. Duties of the Committee associated with the Plan will include:
1. Training and Worker Involvement
Waste reduction will be incorporated into the existing training curriculum wherein employees are trained on the general nature of chemical hazards, safe operating procedures, and use of Safety Data Sheets (SDS). Employees will be required to evaluate their own area’s waste streams and be provided with resource materials that describe the technology available and currently used for reduction of waste streams of similar nature or in similar processes. Major emphasis will be on preventing waste generation by improved procedures, material substitution, and process changes.
Employees should participate in tracking the costs of the wastes they generate and should be expected to use this information to continuously improve processes.
2. New Processes, New Products, and Major Changes
New processes, purchase of new products, or major changes likely to impact waste generation within departments will be initiated only after an analysis of the waste stream impact. New processes and major changes will require an estimate of the type and volume of the waste generated, its environmental impact, and related costs. Departments will be required to assess waste impact early in design considerations. Any significant additional waste generated will require a challenge to the design before work proceeds. Waste reduction teams will be apprised early in the development as to the nature of the required process and asked for input on the anticipated waste streams’ impact. Departmental groups will have a strong incentive to challenge changes and the addition of new products because they are ultimately responsible for managing the costs associated with their waste streams.
3. Waste Management Cost Accounting System
Hazardous waste cost information will be maintained by the Environmental Health and Safety Office and disseminated to appropriate departments. Data will be compiled at least annually to provide guidance in waste reduction efforts.
The above costs will be tracked through the appropriate expenditure account (74492, Hazardous Waste Disposal) in addition to estimates of personnel time provided by generating and support departments. Expenditure account 74492 is assigned exclusively to track the following expenditures associated with hazardous waste:
This account should also be used to cover items such as supplies associated with waste disposal, which would otherwise be charged to other accounts.
UM1622 - Issued: February 22, 2013|
UM1622 - Revised: October 6, 2015
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