By Mark Lennon and Katrina Rideout
Published in the September 2007 issue of Today’s Facility Manager
Waste regulations are not consistent across the board. Some states have adopted specific rules; others rely on federal precedents. (Photo: Institution Recycling Network.)
While many people know Ralph Waldo Emerson (RWE) as an American essayist, poet, and leader of the Transcendentalist movement, few recognize the connection to current recycling efforts. Indeed, RWE was one of the country’s very first environmental pioneers.
But more to the point of operational purposes, the author’s initials, RWE, can be used as an effective mnemonic for any manager looking to set up or expand a recycling program. For facility professionals looking to establish a recycling program or expand a program that’s already active, RWE stands for Regulation Weight Economics—three fundamentals for successful recycling.
R For Regulation
Regulatory compliance is critical for all facility managers. From a recycling perspective, this means removing from the waste stream all materials that are restricted from disposal.
The most critical regulated materials are hazardous, radioactive, and biohazardous wastes. Every facility manager needs to understand these wastes and ensure they are managed in full regulatory compliance. In terms of legal exposure, liability, public relations, and job retention, they are the most important wastes in any facility.
One step below these toxic items are universal wastes—materials that could be classified as hazardous but are so common that strict regulation is impractical. Furthermore, universal wastes can be handled safely with common sense precautions.
Some materials classified as universal waste are televisions and computer monitors with cathode ray tubes (CRTs), fluorescent lamps and other mercury containing lighting [for more on this subject, see the TFMAugust 2007 article, “Why Recycle Used Bulbs?” by Jennifer Dolin.], fluorescent ballasts that have PCBs, and rechargeable batteries.
Universal waste regulations vary from state to state. Regardless of the geographic location, universal waste practices typically spell out requirements for storage and handling, packaging, transportation, disposition, spill control, recordkeeping, and reporting.
A number of states, mostly in the Northeast and on the West Coast, also regulate some recyclable solid wastes. For example, Massachusetts bans disposal of paper and cardboard, glass, metal, and plastic containers, appliances, tires, lead-acid batteries, and leaf/yard waste. This is a fairly typical set of materials for the states that regulate recyclable wastes.
In 11 states (ME, VT, NY, MA, CT, DE, MI, IA, OR, CA, and HI), facility managers need to comply with container deposit or “Bottle Bills.” The explosion in popularity of non-carbonated bottled water, juices, and teas—not covered by most Bottle Bills—has caused significant upheaval in some areas. The result has left some facility managers in a difficult (and expensive) position, since it requires them to manage a dual stream of redeemable and non-redeemable containers.
Finally, but hardly least important, are local recycling requirements enacted by many municipalities (some of them located in states with no statewide recycling mandates). From a facility manager’s perspective, these are often the most sensitive, because waste is a quite visible part of a facility’s local impact. Needless to say, maintaining good community relations is an important part of the manager’s job.
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