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Subject:
Mercury Reduction/Elimination
Effective
Date: June 23, 2006
Approved:
Laboratory Safety Committee - Policy: 3
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PURPOSE
AND BACKGROUND:
Mercury is recognized by national public health experts as
one of the most significant environmental toxicants facing
the United States. The public health effects of mercury in
the environment are well researched and documented. The United
States Environmental Protection Agency and the Indiana Department
of Environmental Management have identified the elimination
of mercury sources and the proper disposal of mercury as priority
public outreach projects for each agency.
Further illustration of this concern occurred
in 1998 when the American Hospital Association entered into
a memorandum of understanding with the United States Environmental
Protection Agency requesting that all member institutions
commit to the elimination of all sources of mercury from their
facilities within a 5-year period. Due to difficulty in meeting
the 5-year deadline, the AHA withdrew its signature from the
memorandum of understanding but extended its commitment to
the concept of eliminating mercury sources within a reasonable
time period.
Mercury is the most commonly spilled chemical product on campus.
A significant expenditure of resources is expended each year
by University personnel in the remediation of these spills.
Improper disposal and/or unrecognized or unreported releases
of mercury pose a significant threat to the community and
can lead to significant regulatory consequences for the University.
In many, if not most cases, effective (from both a performance
and cost perspective) alternatives for mercury have been developed
and are readily available.
Indiana University – Purdue University Indianapolis,
as a generator of hazardous chemical waste, has an obligation
under federal and state regulation to reduce the volume
and toxicity, including mercury, of these wastes generated
to the fullest extent economically practicable.
The
Administration of IUPUI recognizes the threat presented
by mercury and is committed to reducing this threat to the
lowest level practical in as timely fashion as possible.
SCOPE:
By the adoption of this policy, Administration shares this
commitment with all staff, faculty, students and guests
of the University community.
POLICY:
All nonessential uses of elemental mercury or mercury-based
compounds are to be eliminated from campus laboratories
by December 31, 2007. Mercury and mercury-based compounds
being eliminated from chemical inventories are to be referred
to the IUPUI Department of Environmental Health and Safety
for proper disposal by means of the IUPUI
Hazardous Materials Manifest for Intracampus Transportation
available at the following link: http://www.ehs.iupui.edu/ehs/environment_manifestForm.asp.
Following
December 31, 2007, costs associated with the disposal of
mercury wastes will be referred back to the generating department.
In addition, all cost associated with the response and remediation
of a mercury release will be referred back to the department.
An
essential use of mercury is defined as that given circumstance
where no acceptable alternative for the current use can
be located or where it is found that implementation of the
alternative would create a significant, long term financial
hardship to the department or research project.
Effective
December 31, 2007, no mercury-containing device, elemental
mercury or mercury-based chemicals may be acquired without
the expressed written consent of the Laboratory Safety Committee.
Laboratories
wishing to maintain inventories of mercury products after
December 31, 2007 shall contact the IUPUI Environmental
Manager at 274-4351 and request an exception to this policy.
The Department of Environmental Health and Safety (EHS)
will take the request under consideration, will review all
appropriate documentation and will render an opinion in
writing as to whether the request, in the opinion of the
Department, is of merit.
In
the event of disagreement, EHS will offer an opinion in
writing the next regularly-scheduled Laboratory Safety Committee
meeting for consideration by the Committee at large. The
laboratory in question will be given an opportunity to present
a case in favor of the continued use of the material or
item. By means of a vote of a simple majority of those members
present at that meeting, a final decision as to whether
the proposed use is considered as essential will be rendered.
For
those uses found to be essential, the mercury is to be eliminated
from the laboratory’s inventory once an ongoing need
can no longer be demonstrated.
EHS
and the Committee will work in a cooperative fashion with
any department found to have an unusually large inventory
of mercury-based materials or items to allow for the phase-in
of alternatives without creating a financial hardship for
the department.
In
the event a significant need is evident, EHS will explore
grant opportunities to help offset the costs of acquiring
acceptable alternatives.
NONCOMPLIANCE/PENALTIES:
The Department of Environmental Health and
Safety may, at its discretion, refer costs incurred from
the disposal of wastes generated by actions contrary to
the principles of this policy back to the producing or generating
department.
Staff, faculty, students and guests of the
University whose willful actions violate existing federal
and state regulation may be held criminally and civilly
liable for their actions.
In the event the University is cited and
fined by federal, state or local regulatory agencies for
actions or activities contrary to applicable regulations,
the department(s) involved in the citation may be accountable
for payment of the issued fine.
In addition, the University may initiate
disciplinary actions, up to and including dismissal, against
any staff or faculty found to be in violation of this policy.
PROGRAM OVERSIGHT AND EMPLOYEE ASSISTANCE:
The Department of Environmental Health and
Safety will serve as a technical resource for the implementation
of this program. The Department will also serve to oversee
the development and implementation of mercury educational
materials as needed.
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