Battery: Collection, Storage and Shipping Procedure: 8.41 Created: 09/16/2013

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1 A. Purpose To ensure that all spend batteries are collected and stored in a manner consistent with all applicable Federal, State, and Local regulations and Columbia University Spill Prevention, Control and Countermeasures. B. Applicability/Scope 1. Use of battery collection cans located throughout Columbia University Medical Center, Nevis, Lamont-Doherty, Morningside, Baker Field, and Manhattanville Buildings. 2. Replacement of batteries in machines and equipment requiring annual or semi-annual replacement of batteries, i.e., smoke detectors. 3. A service request with Facilities is required for the removal of large size batteries 11lbs or greater. 4. Any other activity that would cause batteries to enter the general municipal waste stream. C. Definitions D. Responsibilities 1. EH&S is responsible for: a. The maintenance and enforcement of this policy. b. Supply EH&S approved battery containers for the safe disposal of listed batteries and ensure monitoring and maintenance on all supplied battery containers, ensuring proper labels, taping/taping equipment, and routine empting service. 2. Contractors are responsible for: a. Notifying EH&S in advance of any projects that will result in the collection of used batteries. EH&S will supply a suitable amount of approved battery collection containers to project site. b. Maintaining the battery collection containers throughout the duration of the project ensuring they are properly closed and secure with original labels. c. Contacting EH&S for pick-up of used battery containers when full or no longer needed. EH&S or approved vendor will pick-up battery containers and transport said containers to a suitable waste storage area for processing and shipment. 3. Facilities is responsible for: a. For any non-project collection, Facilities should utilize the present battery collection containers throughout the Morningside and Medical Center campus buildings. b. Full or missing battery collection containers should be reported to EH&S immediately. 4. Project Managers are responsible for: a. Coordinating with EH&S for the pickup of heavy batteries such as lead acid. b. Notify EH&S when projects will generate numerous used batteries for collection. c. Providing an account chart string to a project for EH&S to bill back to charge costs associated with disposal of batteries that could not be recycled. Environmental Health & Safety Page 1 of 8

2 E. Procedures 1. Collection schedules: Effective April 16, 2014, battery collection will take place on a quarterly basis at all Columbia University Campuses. The collection event will be managed by the Hazardous Materials Team (HMT). Approximately a third of the collection containers on CU campuses will be visited each month on a rotating basis. This will result in all battery collection containers being emptied at least once each quarter. Depending on recycling activity, individual battery collection container(s) may need to be emptied more frequently. a. Attachment #1 reflects a sample service schedule for the Morningside Campus. b. In regard to the Morningside Campus, each color coded segment will to be collected by the last Monday of each calendar month or within one business day of service if an outside vendor is utilized. c. In regard to the Medical Center Campus, each color coded segment is to be collected by the last Thursday each calendar month or within one business day of service if an outside vendor is utilized. d. The HMT must ensure that all locations assigned for service for that particular month are visited and documented on the appropriate sheet as follows: i. Collection Schedules at Morningside are located on the P drive at: P:\HAZARDOUS MATERIALS\Battery Policy & General Info\Reports\Battery Collection Schedule MS.xls ii. Collection Schedules at CUMC are located on the P drive at: P:\HAZARDOUS MATERIALS\Battery Policy & General Info\ Reports\Battery Collection Schedule CUMC.xls. e. Note: Battery collection activities at CU locations other than Morningside or Medical Center, are not subject to the above service schedule. Battery collection utilizing outside vendors will follow the schedule in Attachment #2. 2. Inspections: Battery inspections will be performed monthly by a member of the HMT or outside vender who has been trained by the HMT to perform battery inspections. These inspections will follow the same schedule as the routine battery collections. The items reported on the inspection include: Condition of current tape dispenser assembly, location of collection container, (was the collection can moved), percentage of batteries taped, (rough estimate). Estimate of batteries collected at each location (percentage of collection container filled). 3. Collection Procedure: Any person authorized to perform battery pickups/inspections will where the proper personal protective equipment (PPE). This will include the use of lab coat, nitrile gloves, safety glasses, and steel toed boots. a. Batteries will be picked up using 5 gallon open top buckets on a cart. However, in the case where numerous small batteries or large heavy batteries are present, an open top 30 gallon drum secured to a dolly may be used. b. Anytime a battery collection container is emptied, the inspection sheet inside the container must be dated for the day the pickup being conducted. c. Tools should be carried at the time of battery collection in order to repair or reattach tape dispensers, marker, tape rolls, security ties, etc. Extra supplies should be carried on the cart in case any of the above items are missing. Environmental Health & Safety Page 2 of 8

3 d. If an authorized vendor is performing the battery collection/inspection and cannot make the above repairs/maintenance, than repairs/maintenance must be performed by a member of the HMT within two business days of inspection date. 4. Sorting and Taping: All batteries collected during each collection period are to be sorted by type and taped by the last Friday of the month. All batteries must be sorted, weighed, and documented prior to shipment. 5. Sending Out Selected Batteries to Call2Recycle. Selected batteries will be packaged as per Call2Recycle instructions and shipped off campus on a monthly basis. These batteries include rechargeable nickel cadmium, lithium ion, small sealed lead acid, nickel metal hydride and nickel zinc. Containers must be taped closed, labeled with EH&S address and must not exceed 40 pounds. 6. Collection Reports: Collect reports must include the following: battery type, weight of battery type, shipping status, and disposal outlet. This report is due the last Friday of every calendar month and is to be maintained by the HMT. 7. Associated reports with collections are due the last Friday of every month or within one business day if a University vendor is performing the collection/inspection on behalf of the HMT. Collection Schedule/Inspection Reports are located on the P drive at P:\HAZARDOUS MATERIALS\Battery Policy & General Info\Reports\Battery Collection Schedule MS.xls and P:\HAZARDOUS MATERIALS\Battery Policy & General Info\ Reports\Battery Collection Schedule CUMC.xls 8. Storage: After each collection event, sorted and taped batteries awaiting disposal will be stored in the following locations: a. Morningside Chandler Chemical Waste Storage Room; additionally, large wet chemistry lead-acid batteries and alkaline batteries from Facilities may be stored in the battery storage cage in the Grove. Alkaline batteries from this location must be sorted prior to shipment. b. CUMC ICRC Universal waste storage room; additionally, large wet chemistry batteries may be stored in the universal waste storage area nearest the building generating the waste. Rechargeable batteries may be temporarily stored in the ICRC Chemical Waste Room while awaiting packaging. All collected batteries must be placed in secondary containment while waiting sorting, taping, or shipping. At a minimum, a universal waste label must be placed on any container holding batteries awaiting disposal. The label must be properly labeled UNIVERSAL WASTE BATTERIES, (battery type) and dated with the oldest date from the original collection container from where the battery was originally collected. 9. Shipping: Members of the HMT must use the following guidelines for shipping collected batteries: a. Alkaline, lead acid (wet and sealed batteries greater than 11lbs), and lithium batteries will be recycled through the current universal waste vendor and vendor supplies will be used. b. All battery shipments should take place on scheduled universal waste shipment dates. Environmental Health & Safety Page 3 of 8

4 c. Alkaline, large lead acid and lithium batteries may be stored in CU Universal Waste Storage areas until full drums are accumulated for shipment. Stored containers must be dated when first utilized and may not exceed a one (1) year storage period. d. All universal waste must be invoiced separately from hazardous waste. 10. Procedures for Shipping Document recordkeeping: A member of the HMT will record all shipping documents as follows: a. Enter the EH&S share drive address as follows: i. P:\Hazardous Materials\Waste Data\Hazardous Waste\2010 Hazardous Waste Recordkeeping Guidance Document.docx ii. Enter data for the following categories: alkaline, rechargeable battery, lead acid (sealed, less than 11 lbs.), Lead Acid Batteries greater than 11 lbs, lithium ion, nickel cadmium, and nickel metal hydride. iii. Note: rechargeable battery, lead acid (sealed, less than 11 lbs.), lithium ion, nickel cadmium, and nickel metal hydride will be recycled through the Rechargeable Battery Recycling Corporation (RBRC) via Call2Recycle UPS mail back boxes. iv. Note: All rechargeable batteries must be shipped monthly. v. Morningside staff should leave containers at ChemStores in the Chandler Building for shipment with UPS. vi. CUMC should leave sealed shipping boxes on the Russ Berrie loading dock in the afternoon and must inform the building manager. UPS will pick up the following morning between 9 11am. 11. Maintenance: A member of the HMT will perform all maintenance of battery collection containers within two business days of discovery of any issue. A list of supplies for the battery management program is located on the H drive at: P:\HAZARDOUS MATERIALS\Battery Policy & General Info\Battery Signs & Charts\Battery Can Supplies.docx a. If an item is not available from a vendor or a vendor is no longer being used by Columbia, substitute a similar product with the same specifications (dimensions) if possible. Signage for all battery cans is located on the H drive at: P:\HAZARDOUS MATERIALS\Battery Policy & General Info\Battery Signs & Charts. This includes outer can signs, which must be laminated, and battery can inserts to be placed inside the lid of the container. b. Any new labels or signage created for the battery management program must be stored in this folder. Regulatory information on batteries is located on the H drive at: P:\HAZARDOUS MATERIALS\Battery Policy & General Info\Regulatory & Vendor Guidance. This file includes all accumulated information on battery regulations and vendor guidance. Any new information must be stored in this folder. 12. Vendor Management: When the hazardous/universal waste vendor is utilized to assist in the maintenance of the Battery Management Plan, it is the responsibility of the HMT to ensure that all aspects of the Plan are maintained. a. The specific roles of each HMT team member are as follows: Monthly collection of batteries is to be performed by the vendor at the Morningside and Medical Center campuses on the dates indicated: A form similar to Attachment #1 of this Plan is to be provided to the vendor indicating which collection containers will be serviced for the particular service event. Environmental Health & Safety Page 4 of 8

5 b. The vendor must complete the inspection form and return to the HMT at the end of the service day. The vendor will collect batteries at all location, perform an inspection of each collection can serviced, and provide documentation of each. c. Any deficiencies or maintenance required at any collection containers must be corrected within two business days of discovery by the HMT. d. The HMT must ensure the Vendor understands that they must complete both lines of the universal waste insert inside the top lid of the collection cans: the service date and the new start date of the can. This ensures that all cans are in compliance with universal waste regulations. e. If the current insert inside the can lid is completely full, it must be replaced and these replacement inserts must be provided to the vendor by the HMT prior to service. The vendor will bring all collected batteries to the storage location indicated in the Plan and prepare batteries for shipment as per the Plan. This includes weighing the batteries and submitting the weights to the HMT. The sorting and taping of batteries from drums in the CUF Cage in the Grove (MS) should be performed monthly by the vendor, time permitting. F. Emergency Contacts EH&S Morningside Campus EH&S Columbia University Medical Center Nevis Laboratory Lamont-Doherty Safety Department G. Medical Surveillance H. Recordkeeping In addition to the inspection and collection reports, a quarterly report summarizing the battery types collected, expected disposal outlets from the prior quarter must be submitted at the first Friday of January, April, July, and October. Format shall follow a format similar to the following table: CUMC 1st Quarter** 2nd Quarter Expected Disposal Outlet Current Contract Cost Lithium Ion C2R Lead Acid* TBD Nickel Cadmium, Nickel MH C2R Lithium (Non Rechargeable) 5 6 Veolia Alkaline Veolia Expected Disposal Cost Expected Savings *To be sorted: wet chemistry/sealed types 1st Quarter weights based on shipments and estimates of what was collected. I. Appendices Appendix #1: Used Battery Collection Container Locations/Status Appendix #2: Service Dates Battery Management Environmental Health & Safety Page 5 of 8

6 J. Forms K. References L. Acknowledgements Appendix #1: Used Battery Collection Container Locations/Status Environmental Health & Safety Page 6 of 8

7 Appendix #2: Service Dates Battery Management Environmental Health & Safety Page 7 of 8

8 2014 Veolia Service Dates Battery Management Morningside Campus Last Monday Medical Center Campus Last Thursday Environmental Health & Safety Page 8 of 8

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