RECYCLING & UNIVERSAL WASTE HANDLING
Region 8 Sustainability & Environmental Management System
1.0
Purpose & Scope
To streamline the collection of recyclable materials by utilizing an improved management
system that incorporates gathering data from the waste hauler and from annual waste
analysis reports. This will ensure that the Denver Federal Center meets EPA guidelines,
become a leader in the public sector for recycling and waste diversion efforts and is
considered a great neighbor in the local community.
2.0
Activities & Departments Affected
Property Managers, Project Managers, Real Estate Specialists, Facility Managers and
Contracting Officers
3.0
Exclusions
All Federal agencies are responsible for implementation and operation of their own
recycling programs as defined by Executive Order 13514. GSA is primarily a service
provider to ensure everyone can maintain a successful recycling program in all federal
facilities.
4.0
Forms Used & Permits Required: (include reporting requirements)
Federal and State Forms and Permits: There are no federal or state forms or
permits required for the collection of materials for recycling. Since the material still has a
usable life, it is not considered a waste.
PERMIT / FORM / REPORT
Sustainable Practices Report:
Green Purchasing, Waste
Management, and Chemicals
Management (1, 2, 3)
SUBMITTED TO:
FEDERAL OR STATE AGENCY
Office of the Federal Environmental
Executive (OFEE)
SUBMITTAL
FREQUENCE
Region Report
for Fiscal Year
(1) Reporting requirements began with fiscal year 1992, under Section 502 of the Resource Conservation
and Recovery Act (RCRA), in accordance with section 6002(i) of RCRA (42 U.S.C. 6962(i)) and Section
9002 of the Farm Security and Rural Investment Act. Various Congressional Acts and Presidential
Executive Orders (i.e., 13101, 13424) since the inception of the original reporting requirement have
maintained this requirement; November 2, 2006, letter from the Office of Federal Procurement Policy
(OFPP) and the OFEE to Federal Agency Environmental Executives and Agency Senior Procurement
Officials. The last changes occurred with Instructions for Implementing EO 13423 was presented by the
Council of Environmental Quality on March 28, 2007.
(2) The title of the report form changes per the requirement of the newest regulatory requirement; for
example in 2008 and 2009 the report was called ―E.O.13423 Sustainable Practices: Green Purchasing,
Waste Management, and Chemicals Management‖. The three Parts include: Green Purchasing, Solid Waste
Management (Reduction, Recycling, Electronics Management), and Toxic and Hazardous Chemicals
Management.
(3) The report form is completed yearly by the Regional Solid Waste, Recycling Program Manager.
In-house GSA Region 8 and Contractor Forms:
Rev. 06/10/2010
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GSA Region 8 SEMS Environmental Procedure
RECYCLING & UNIVERSAL WASTE HANDLING
Region 8 Sustainability & Environmental Management System
Battery Log Form
5.0
Acronyms, Abbreviations, and Definitions
Acronyms
CASU
CDPHE
CEQ
CFR
CO
DEQ
DFC
COR
EO
EPA
GSA
ISO
O&M
OFEE
PBS
RCRA
Meaning
Cooperative Administrative Support Units
Colorado Department of Public Health and Environment
Council of Environmental Quality
Code of Federal Regulations
Contracting Officer
Department of Environmental Quality
Denver Federal Center
Contracting Officers Representative
Executive Order
Environmental Protection Agency
General Service Administration
International Standards Organization
Operations and Maintenance
Office of the Federal Environmental Executive
Public Building Services
Resource Conservation and Recovery Act
Definitions:
Authorized Agency Representative: An employee or contractor of a Federal agency whom
the agency has designated to be responsible for contacting the Contractor for calling the
recyclable paper contractor for pickup of materials and for completing and signing the
PBS Wastepaper Delivery Order.
Aerosol can: A container in which gas under pressure is used to aerate and dispense any
material through a valve in the form of a spray or foam.
Batteries: Includes dry cells (alkaline batteries), rechargeable batteries, and wet cells
(vehicle type batteries).
Cooperative Administrative Support Units (CASU) Program: An interagency network of
Federal entrepreneurial organizations that provides the full range of "best value" support
services to Federal agencies on a cost reimbursable basis. Located throughout the United
States, the National CASU Network meets customer agency needs by providing high
quality, low cost services, with quick turn-around. Through partnering arrangements, the
Network is national in scope and can deliver services to Federal government offices and
posts of duty anywhere in the country.
Certificate of Destruction: A certificate provided to the government documenting the
witnessed destruction of confidential documents.
Coated Paper: Any paper or paperboard that has been coated, usually with a clay or
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Region 8 Sustainability & Environmental Management System
starch coating.
Computer Printout: Consists of white sulfite or sulfate papers manufactured for use in
data processing machines. This grade may contain colored stripes or bars, as well as
impact or non-impact (e.g., laser) printing.
Contractor Containers: Those containers provided by the Contractor and approved by the
COR to store and transport recyclable materials at the holding agency’s storage area to the
loading dock at each location identified in Exhibit 1.
Contractor Payment: Payment, made by the Contractor to the U.S. Government, for the
removal of wastepaper and other recyclable materials from locations.
Corrugated Containers: Baled or un-baled corrugated containers having liners of test
liners, jute or kraft. Commonly known as ―cardboard‖ or ―OCC.‖ No more than five
percent (5%) out-throws or prohibitive materials by weight.
Electronic Devices: Means electronic equipment which contains electronic circuit boards
and includes but not limited to computer monitors, televisions, computers, cell phones,
laptops, printers, terminals, mainframes and stereo equipments.
File Stock: Consists of discarded correspondence files and record files without limitations
as to prohibitive materials, including some carbon paper.
Ground wood: A substance found in paper material that has been processed by a
minimum of 10% mechanical pulping. Ground wood contains virtually the whole,
unbleached wood, including lignin.
Heavy Books: Consists of dry, clean, used and over issued books; stitchless stock; quire
waste; and similar printed matter. This category grade may contain bleached sulfite and
sulfate books adulterated with fine ground wood.
Holding Agency: The Government agency and location which has been identified in
Exhibit 1 and which has the right to store and request, by their authorized representative
(COTR), pick up by the Contractor of wastepaper as required.
Lamp: The bulb or tube portion of an electric lighting device.
Lignin: The brown, insoluble polymer that binds the cellulose fibers of woody plants.
Loading Dock: The Government designated service location identified in Exhibit 1 where
the Contractor trucks are to pick up and empty the recyclable paper material containers
when requested by the holding agency’s authorized representative.
Magazines: Coated periodicals and catalogs containing print, as well as black-and-white
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Region 8 Sustainability & Environmental Management System
and/or colored photographs.
Mercury Containing Device: Electrical switches, fluorescent bulbs, vacuum pumps,
thermostats, gauges, flow regulators, etc.
Miscellaneous Ledger: Consists of printed or unprinted sheets, shavings and cuttings of
colored or white sulfite or sulfate ledger, bond, writing or other papers which have a
similar fiber and filler content. This grade must be free of treated, coated, padded or
heavily printed stock.
Mixed Paper: Various grades of paper, including miscellaneous ledger, file stock, wet
strength, heavy books, magazines, slick-coated paper, colored paper, carbonless paper,
ground wood printing and copier paper, and contaminated high grade paper, or any
combination thereof. No more than ten percent (10%) out throws or prohibitive materials
by weight.
Newsprint: Consists of newspapers containing less than 5% of other papers. No more
than five percent (5%) out throws or prohibitive materials by weight.
Notification: The request by the authorized agency representative to the Contractor for
scheduling the removal of recyclable paper material from the holding agency.
Out throws for Paper: All paper products that are so manufactured, treated or formulated
so as to be unsuitable for consumption as the grade specified.
PBS Wastepaper Delivery Order: R8 Form 1359, in quadruplicate (4 copies), which shall
be completed in part by the Contractor and in part by the Government representative each
time recyclable paper material is removed from a holding agency’s loading dock when
requested by the authorized agency representative.
Pesticide: – Includes both chemicals used to control or eliminate pests, or plant regulator,
defoliant, or desiccant.
Prohibitive Materials: Any materials, which by their presence in packing of the
recyclable paper material in excess of the amount allowed, will make the packing
unusable as the grade specified; or any materials that may be damaging to equipment.
RCRA: Resource Conservation and Recovery Act; A Federal law enacted in 1976 to
address the treatment, storage, and disposal of hazardous waste
Recycling: A series of activities that includes collecting recyclable materials that would
otherwise be considered waste, sorting and processing recyclables into raw materials such
as fibers, and manufacturing raw materials into new products.
Sorted White Ledger: Consists of post consumer white ledger and computer printout
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Region 8 Sustainability & Environmental Management System
paper. This will include machine copies, laser and impact printer output, letterhead,
office stationery and a mix of the white and computer paper normally found in the office
environment. No more than five percent (5%) out throws or prohibitive materials by
weight.
Secure Shred: Confidential materials that shall be destroyed by pulping, shredding (5/16
in. strip or less), chemical process, or other qualifying methods proposed and approved by
the Contracting Officer/Contracting Officer Representative who is indicated in Part 1 or
in amendments to this contract.
Ton: The term ton, as used in this contract, means short ton, which is equivalent to 2,000
pounds.
Universal Wastes: Are hazardous materials that are generated by very small to very large
non-residential sources such as private businesses, government agencies and schools.
These wastes are subject to wide spread use which makes their disposal difficult to
control. Items that are considered universal wastes are: Batteries, pesticides, mercurycontaining devices, mercury-containing light wastes, aerosol cans, electronic devices and
components.
6.0
Procedure
State Specific Procedures & Requirements [refer to individual State Legal Reviews for
details on Statues, Laws, and Rules]:
Each state has its own rules regarding universal wastes, however to be progressive and to
help move the Presidential mandates forward, we need to have all buildings through out
the region ensure that all universal wastes are recycled and not landfilled. It shows good
faith to our customers and community that GSA is doing the right thing for the right
reasons.
STATE
Colorado
Montana
North Dakota
Rev. 06/10/2010
REQUIREMENT
The only requirement is to ensure that all materials listed on the State of
Colorado's Universal Waste rule are collected for recycling and not placed in
dumpsters to be disposed of at local area landfills.
Adoption of Federal Universal Waste Rule (40 CFR 273). A generator of
universal waste may treat waste lamps on-site by crushing or intentional
breaking, if state regulations are followed. Administered by the Montana
DEQ Recycling and Waste Reduction Program. DEQ staff continues to work
with industry and businesses across Montana to develop markets that can
sustain and expand recycling programs across the state.
Similar to Federal Universal Waste Rule (40 CFR 273). A concern is
expressed to recycle and reduce waste. Administered by the North Dakota
Department of Health, Environmental Health Section, Waste Management
Division through the Solid Waste and Pollution Prevention and Recycling
Programs.
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Region 8 Sustainability & Environmental Management System
STATE
South Dakota
Utah
Wyoming
REQUIREMENT
The standards for management of universal hazardous waste are those of
Federal Universal Waste Rule (40 CFR 273), inclusive (July 1, 2008).
Administered by the South Dakota DENR Division of Environmental
Services through the Waste Management and Recycling Programs.
R315-16: Standards for Universal Waste Management. The Utah DEQ
administers Green Choices, a waste reduction program to encourage waste
reduction and recycling.
Chapter 14, Standards for Universal Waste Checklist. The Recycling, Waste
Reduction and Beneficial Use Program is regulated by the Wyoming DEQ
through the Solid and Hazardous Waste Division.
Standardized Procedure:
6.1
Rev. 06/10/2010
General Facilities Materials
6.1.1
Annually, conduct a waste analysis for the building to determine what
materials are recyclable. Waste analysis surveys can be done through the
solid waste contractors for a fee or be inclusive of the contract. The
surveys can also be conducted by contractors who specialize in developing
surveys to promote increasing collection of recyclables. They can be hired
through the local recyclers, or through environmental firms that have
waste analysis services available.
6.1.2
Develop a management plan for the separation and collection of those
materials that are identified in the waste survey. Consider where the
material will be collected, where it will be stored until pick up, pest
control, etc.
6.1.3
Determine if the recycling services can be provided by the contract
administered by CASU. If not, add provisions to the janitorial contract to
manage the recycle materials. The value of the materials typically offset
building cleaning costs.
6.1.4
For paper, commingled containers and cardboard coordinate with the
building occupant on style, placement and purchase costs for collection
containers for recyclables. Success of recyclable material collection relies
on its simplicity. Collection containers should be well marked (i.e. photo
of acceptable material) and labeled. Location selection should be in areas
where people congregate i.e. lunch rooms, kitchenettes, copy centers, etc.
The janitorial service will be responsible for collecting the materials in the
described locations and taking it to the loading dock area. The building
occupants are responsible for placing their materials in the centralized
bins. Desk to Desk service for recyclable materials collection can be done,
however it will add a significant increase in the cleaning contract. Educate
the tenant’s facilities managers on the associated costs in waste materials
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Region 8 Sustainability & Environmental Management System
management to ensure they select the best service to their needs keeping
their bottom line costs in mind. Keep tenants informed on recycling
alternatives that are available for their excess goods (i.e. computers, chairs,
old furniture, toner cartridges, ink jet cartridges). Document any training
provided to the tenant regarding the recycling program.
6.2
6.1.5
Provide a dedicated area on or near the loading docks of buildings for
adequate storage of recyclable materials. For paper products, there must
be enough space to store a minimum of four 95 gallon totes. All totes
must have lids for fire safety and to keep out pests. Buildings that produce
at least 1,000 lbs of recycled paper products per week should have bailers
installed to manage the material. Bailed cardboard has a high resale value
bailed up compared to sitting loose in a Gaylord or similar container.
Provide a separate storage area for non-paper recyclables until the volume
is large enough to ship out to a recycler that provides a volume cost
savings to the government.
6.1.6
For tenants who enter into the commingled container recycling program,
ensure the lidded totes are marked and stored in an area where pest control
is effective.
6.1.7
Ensure that copies of the weight slips provided by the recycling contractor
are kept on file in the buildings property manager’s office.
6.1.8
Submit a quarterly report to the Regional Recycling Coordinator of the
total volume of materials collected.
Universal Waste
Universal wastes include:
o Batteries
o Electronic Devices
o Mercury Containing Devices
o Pesticides
o Aerosol cans
o Lamps
Batteries
Batteries have been divided into two major groupings: wet cells and dry
cells. Dry cells are all rechargeable and alkaline batteries. Wet cells are
found in motor vehicles, track hoes, fork lifts, etc. Batteries will be
shipped out once there is a sufficient amount to cover the costs of shipping
or once a year which ever comes first. A Battery Collection Log is used to
track shipments. EPG will be responsible for tracking this effort.
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GSA Region 8 SEMS Environmental Procedure
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Region 8 Sustainability & Environmental Management System
Wet Cells –
o At the DFC: Will be collected by EPG and stored in Building 11 in
secondary containment until a sufficient quantity is collected to
warrant transporting them to an auto supply store, which will
currently recycle the batteries..
o Region 8 GSA locations other than DFC: Wet cell batteries will be
stored in approved storage containers until there is a sufficient
amount for best value to the government for disposal. Containers
need to be approved by the Regional Fire Marshal before being
placed into use.
Dry Cells – A designated collection container will be provided. Lithium
batteries will have the ends taped. If in doubt about the type, tape the end
of the dry cell battery.
Documentation – Copies of weight slips or counts of batteries that are
shipped to a recycler will be provided to the EPG and the Regional
Recycling Coordinator.
Electronic Devices
Used electronic devices that are excess government property will be
transferred to GSA Federal Acquisitions Service or CASU for sale at
government auction. Non-working equipment will be bundled with other
products and either transferred to FAS or stored in a secure location until
there is sufficient material to ship to an electronics recycler.
Data Security – Any device that contains privacy act or sensitive data must
be destroyed prior to recycling. Electronics recyclers offer a data
destruction service. Ensure that documentation of the destruction is
provided to the Regional Recycling Coordinator.
Documentation – Copies of shipping manifests and weight slips will be
provided to the Regional Recycling Coordinator.
Mercury Containing Devices
The majority of mercury containing devices within GSA are fluorescent
light tubes. These tubes are required to be recycled by the building O&M
contractor responsible for the building. Mercury switches and other
mercury containing devices are the responsibility of the O&M contractor
for proper disposal. Shipping manifests and certificates of reclamation
will be provided to the Regional Recycling Coordinator.
Documentation – Copies of shipping manifests will be provided to the
EPG and the Regional Recycling Coordinator.
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GSA Region 8 SEMS Environmental Procedure
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Region 8 Sustainability & Environmental Management System
Pesticides
Pest control and landscape contractors are required under the Universal
Waste or Hazardous Waste regulations to appropriately handle and dispose
of unspent, unused, or expired pesticide. The contractor brings pesticides
to GSA controlled facilities and is contractually responsible for handling,
using, and disposing the chemicals.
Fluorescent Tubes (non mercury containing) and Lamps
All fluorescent tubes and lamps not covered under mercury containing
products procedure are to be recycled by the O&M contractor. Tubes and
lamps will be stored until there is a sufficient amount to be shipped to a
recycler in a secure location. Ship the material per recyclers’ requirements
and or recommendations.
Documentation – Copies of shipping manifests will be provided to the
EPG and the Regional Recycling Coordinator.
6.3
7.0
Construction Debris
6.3.1
For Construction Debris, ensure that there are sufficient roll off containers
provided to allow for source separation of recyclables.
6.3.2
Construction Wood waste can be ground on site and used as mulch or sent
to a facility that has composting capabilities.
6.3.3
All steel construction waste will be commingled in one roll off container
and shipped off to a local metals recycler.
6.3.4
For concrete, brick and other masonry type debris, segregate the material
to ensure the purity of the load from other construction debris.
6.3.5
Concrete, brick and other masonry debris can be ground onsite and hauled
off to a local recycler.
6.3.6
Weight slips must be signed by the demolition contractor and provided to
the following GSA personnel: Project Manager, Contracting Officer and
the Regional Recycling Coordinator.
6.3.7
For Landscaping wastes, ensure that all organic materials are utilized on
site as mulch.
Records Management
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GSA Region 8 SEMS Environmental Procedure
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Region 8 Sustainability & Environmental Management System
Waste Analyses
Management Plans
Weight slips
Quarterly Report
Battery Collection Log: Accumulation start dates will be tracked along with dates
of recycling shipments.
Shipping Manifests
8.0
References
CDPHE, Universal Waste Rule [Colorado Hazardous Waste Regulations 6 CCR
1007-3 Part 273], June 2003
Environmental Protection Agency, WasteWise Program
The National Recycling Coalition:
web site http://www.nrc-recycle.org
Council of Environmental Quality, Instructions for Implementing Executive Order
13423, ―Strengthening Federal Environmental, Energy, and Transportation
Management‖, March 28, 2007
Executive Order 13101: ―Greening the Government through Waste Prevention,
Recycling and Federal Acquisition‖, signed by President William J. Clinton on 14
September 1998.
Executive Order 13423: "Strengthening Federal Environmental, Energy, and
Transportation Management", signed by President George W. Bush on 24 January
2007.
Executive Order 13514: "Federal Leadership in Environmental, Energy, and
Economic Performance", signed by President Barack Obama on 5 October 2009.
Paul A. Denett, Administrator, Office of Federal Procurement Policy, and Edwin Piñero,
Federal Environmental Executive, Office of the Federal Environmental Executive,
Letter: FY 2006 Reporting on Implementation of the Resource Conservation and
Recovery Act, Section 6002, the Farm Security and Rural Investment Act, Section 9002,
and Other Environmental Purchasing Requirements, November 2, 2006
Resource Conservation and Recovery Act (RCRA), 40 CFR 239, Subchapter I—Solid
Wastes
U.S. Environmental Protection Agency [Administering Agency], Resource
Conservation and Recovery Act (RCRA) of 1976; 42 U.S.C. § 6901 et seq, as
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GSA Region 8 SEMS Environmental Procedure
RECYCLING & UNIVERSAL WASTE HANDLING
Region 8 Sustainability & Environmental Management System
amended by the Federal Facility Compliance Act. [Statute]; 40 CFR 148, 239- 282
{283-299 revised} [Regulation]; Section 6002 of RCRA (42 USC 6962)
9.0
Appendices
Attachment A: Recycling, Universal Waste & Construction Debris Flowchart
Attachment B: Battery Disposal Log
Document Control Information:
Recycling & Universal Waste “Month-DateYear”.doc
Approved & Dated:
June 10, 2010
Document Revision and Update:
Revision Date
Nature of Revision
Revision made by:
12/19/2005
03/16/2006
01/22/2010
Marion Rule (Buntyn)
Marion Rule (Buntyn)
Robert Melvin
03/19/2010
06/10/2010
Rev. 06/10/2010
Working Draft
Original Release
Add ISO 14001 Document Controls, add state
regulations, add Flowchart, and update to address
new federal regulations.
Include RCRA and Farm Security and Rural
Investment Act Report requirements
Region 8 requirements.
Page 11 of 13
Marion Buntyn, Robert Melvin
Marion Buntyn
GSA Region 8 SEMS Environmental Procedure
RECYCLING & UNIVERSAL WASTE HANDLING
Region 8 Sustainability & Environmental Management System
ATTACHMENT A: Recycling, Universal Waste & Construction Debris Flowchart
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Region 8 Sustainability & Environmental Management System
ATTACHMENT B: Battery Disposal Log
Accumulation start date – day 1st battery is placed in the storage area. Ship date is when
materials leave DFC (regulatory requirement is accumulation period can not exceed 12 months).
Accumulation
Start Date:
Rev. 06/10/2010
Ship
Date:
Responsible
Person:
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Shipped To:
GSA Region 8 SEMS Environmental Procedure
