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Administration: Office of Environmental Health & Safety

Lehman College Universal Waste Management Plan

Copies of this plan will be made available to all members of the campus community with potential to generate universal waste.



The purpose of this document is to present procedures to be followed in complying with federal and New York State regulations as they apply to universal wastes. This document compiles in one location many of the items necessary to document compliance. This document is also written to comply with the City University of New York (CUNY) ­Environmental Health and Safety Policy Manual, specifically the Universal Waste Management Policy and Procedures.

The management of Universal Wastes falls under the requirements of both federal and state regulatory programs. Federal laws which pertain to the management of Universal Wastes include the:

  • Resource Conservation and Recovery Act (RCRA)
  • Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)
  • Superfund Amendments and Reauthorization Act (SARA)
  • US Department of Transportation Universal Material Transportation Act (HMTA)
  •  Toxic Substances Control Act (TSCA)
  • Clean Water Act (CWA)

In New York State the Department of Environmental Conservation (NYSDEC) has been delegated the authority to administer the federal Universal Waste management program. Accordingly, the state has adopted laws and regulations that emulate the federal laws and regulations.


Lehman College administrators, faculty, staff, students, contractors and other parties on campus who may handle or generate universal wastes will be required to properly handle, store and label universal wastes and to comply with applicable federal and state regulations. All who use or handle universal wastes will be responsible for following the policies and procedures set forth in this Universal Waste Management Plan. The Lehman College Environmental Health & Safety Officer (EHSO) and campus administration will be responsible for ensuring that all appropriate parties on campus comply with these requirements. It is the responsibility of all to see that universal wastes will be managed in a safe and environmentally sound manner.

Under federal and state regulations, generators of universal waste are accountable for the management of these wastes. Civil and criminal penalties may result from failure to comply with these requirements. At Lehman College generators of universal wastes may be academic facilities and campus facilities operations. While Lehman College will be responsible for maintaining compliance, a student, faculty member, staff person, supervisor, or department head could also have individual liability in the event of a violation of regulatory requirements. Federal or state regulatory personnel have the authority to inspect the facilities and related locations for compliance with applicable regulatory requirements at any time.

Within the CUNY/Lehman College system the following general responsibilities are identified.

Lehman College’s President will be responsible for:

  • Implementation of the CUNY Universal Waste Management Policy and Procedures.
  • Communicating the importance of the CUNY Universal Waste Management Policy and Procedures.

Lehman College’s Vice President for Finance and Administration will be responsible for:

  • Providing adequate resources to ensure compliance with universal waste regulations and the CUNY Universal Waste Management Policy and Procedures.
  • Tracking and reviewing universal waste compliance performance.

Lehman College’s EHSO will be responsible for:

  • Reading and understand federal, state, and city laws, rules, and regulations relating to universal waste and staying current with changes in the laws, rules, and regulations.
  • Implementing Lehman College’s Universal Waste Management Plan which achieves the goals of the CUNY Universal Waste Management Policy and Procedures and which addresses the particular needs of Lehman College with respect to the management of universal wastes.
  • Maintaining required documents and the records of universal waste training, generation, shipment, and disposal.
  • Training faculty, staff, students and contractors at Lehman College for the performance of their tasks relating to universal wastes in an efficient and competent fashion and providing instruction regarding the potential impact that incorrectly performed activities may have on the environment.
  • Regularly inspecting areas where universal wastes will be stored to ensure that universal wastes will be properly identified, labeled, segregated, and stored for collection and disposal.
  • Awareness of the current legal requirements concerning universal waste disposal and contacting the CUNY Office of General Counsel when questions arise.
  • Arranging universal waste pickups and ensuring safe and complete disposal.

Universal Waste Generators

Lehman College personnel who use or generate universal materials or wastes will be required to:

  • Read and understand, to the extent appropriate to their work, CUNY’s Universal Waste Management Policy and Procedures, Lehman College’s Universal Waste Management Plan and associated Resource Conservation & Recovery Act (RCRA) documentation.
  • Be familiar with the properties, health risks, and precautions associated with handling universal material/waste from their respective work areas.
  • Select and use appropriate personal protective equipment (e.g., gloves, goggles, labcoat, or other measures as may be applicable) required to safely work with universal material/waste.
  • Contact the EHSO with questions including training, waste identification, regulations, reference materials, or other aspect of universal waste management.

DASNY (Dormitory Authority of the State of New York)

DASNY also has responsibility for universal waste that it and its contractors may encounter, or have the potential to encounter. For activities DASNY performs on campus, DASNY will be required to:

  • Coordinate with the EHSO to evaluate environmental implications of activity and to establish specific environmental regulatory responsibilities with respect to a given project.
  • Plan for removal of universal waste in accordance with CUNY’s Universal Waste Management Policy and Proceduresand Lehman College’s Universal Waste Management Plan. If appropriate, written protocol to address universal waste to be prepared, subject to the direction of the EHSO.
  • Documentation of management of the universal waste to be presented to the EHSO.

Universal Waste Management

The Lehman College EHSO is responsible to oversee waste management services. These services

Include waste pickup, accumulation, and shipment and training. Lehman College is a Small Quantity Generator of Universal Waste which means the college does not accumulate 5,000 kilograms or more total of universal waste (batteries, pesticides, thermostats, or lamps, calculated collectively) at any time


The management of Universal Wastes falls under the requirements of both federal and state regulatory programs. The federal and state regulations provide definitions of what constitutes a Universal Waste. Under RCRA, the broad term solid waste is defined as essentially any material that is unwanted, abandoned, has no further use, and is to be discarded. Hazardous waste is a sub-set of solid waste and includes solid, semi­solid, liquid, and gaseous materials resulting from industrial, commercial, and other activities and which exhibits properties that make it dangerous or potentially harmful to human health and the environment. Universal Wastes are subsets of hazardous wastes. Materials identified as Universal Wastes must be handled in compliance with applicable federal and state Universal Waste regulations and Lehman College's Universal Waste Management Plan. Until determined otherwise, it is Lehman College's policy that all batteries, lamps, thermostats, and recalled pesticides that are intended for disposal should be considered to be Universal Wastes. The College EHSO will make the Universal Waste determination according to specific criteria as set forth in applicable regulations.

Universal Waste Identification

There are four (4) categories of Universal Wastes.  

  • Hazardous Batteries – Considered as universal waste are: Nickel-Cadmium (Ni-Cd) use in smoke alarms and tools, lead -acidlithium ion used in computers and cameras, mercury used in medical equipment, zinc used in hearing aid, pages and cameras and electronic equipment such as  mobile telephones and emergency back up lighting, and silver oxide used in calculators, watches and cameras. Since 1993, domestically produced alkaline and carbon zinc batteries contain no added mercury and are essentially mercury-free. Therefore not considered a universal waste are AA, AAA, C, D, and 9V batteries which can be discarded in the regular trash
  • Mercury Thermostat.
  • Lamps - most waste fluorescent bulbs are hazardous wastes due to their mercury content. Other examples of lamps that, when spent, are commonly classified as hazardous waste include: high-intensity discharge (HID), neon, mercury vapor, high pressure sodium, and metal halide lamps which typically contain mercury and sometimes lead.
  • Hazardous Pesticides - that have been recalled or banned from use.
    Examples of some common types are DDT, Dursban, and Chlordane.

Waste Collection and Disposal

NYSDEC strongly recommends recycling of hazardous waste lamps to reduce the accumulation of mercury in the environment. A list of fluorescent and HID recyclers is available in Appendix A.

  • Batteries - All batteries that are to be recycled should be placed in a container with tight fitting lid and labeled “UNVERSAL WASTE­ USED BATTERIES".Please see Environmental Health & Safety Office , Extension 8988 for container. Coordinate pickup with a vendor on state contract.
  • Thermostats - All used mercury thermostats must be placed in a container with tight fitting lid and labeled “UNIVERSAL WASTE USED MERCURY THERMOSTATS".  Call theEnvironmental Health & Safety Office for pick-up at Extension 8988.
  • Pesticides - All pesticides marked for disposal must be labeled," UNIVERSAL WASTE- PESTICIDES”. Notify the Environmental Health & Safety Office (8988) for pick up.
  • Lamps - All used lamps will be picked up and packaged up by the Building and Grounds Department during regular maintenance. Building & Grounds will secure lamps in original containers and assure that lamps are repackaged to prevent breakage. When storage containers are filled they should be removed to the accumulation storage area. All storage containers must dated and labeled “UNIVERSAL WASTE ­USED LAMPS OR BULBS”. B&G will notify Campus Facilities when the storage limit time requires a recycling pickup. There is a one year maximum storage limit.

Universal Waste accumulation time limit

All labeled and dated universal waste containers have a storage limit of no longer than one year from the date the universal waste is generated.

Spills and broken lamps

All releases or spill of universal wastes and other residues from universal wastes must be immediately contained. IF A LAMP SHOULD BREAK IT MUST BE TREATED AS HAZARDOUS WASTE.  

Please Use the following Procedure for cleanup .

Once a mercury lamp is broken the small amount of mercury within the bulb is immediately vaporized and cannot be captured. However, EPA requires that the remaining debris be treated as a hazardous waste.  Therefore you are required to do the following:

  • All material must be swept up and collected in a container with tight fitting cover.
  • Affix Hazardous Waste label to the container and label with the wording “Broken Mercury Lamp”.
  • Notify the Office of EHS for pick up or assistance. (8988).


Lehman College ensures that all employees are thoroughly familiar with proper waste handling and emergency procedures, relative to their responsibilities during normal facility operations and emergencies. Annual training includes universal waste procedures.

Record Keeping

Lehman College as a small quantity handler of universal waste is not required to keep records of shipments of universal waste

Information and Contacts

  • City University of New York; Environmental Health and Safety Policy Manual
  • USEPA, Universal Waste Management: Title 40 Part 273
  • New York Environmental Conservation Law, Article 27, Title 9, Sections 0900 - 0925 (ECL 27, §§ 0900 - 0925)
  • New York Codes, Rules, and Regulations, Title 6, Sections 370 - 374 and 376 (6 NYCRR, Parts 370 - 374 and 376)