NYSDEC regulations require that solid waste generators determine if a solid waste is hazardous waste prior to disposal. NYSDEC allows an exemption from the Solid and Hazardous Waste Rules for scrap metal which is being recycled. Scrap metal is defined as, “bits and pieces of metal parts (e.g. bars, turnings, rods, sheets, wire) or metal pieces that may be combined together with bolts and soldering (e.g. radiators, scrap automobiles, railroad boxcars), which when worn or superfluous can be recycled.” The University generates various types of metal wastes from a variety of operations in various departments. Examples of items, equipment and devices that may be considered scrap metal include, but are not limited to:
- Office Furniture
- Lab Equipment
- Empty Cylinders
- Precious Metals
If the solid waste that is being disposed of as scrap metal is also a hazardous waste, the material is regulated by NYSDEC (6NYCRR 371.1(c) (7)). Scrap metals that could be considered a hazardous waste include, but are not limited to:
- Brass (lead content)
- Lab Equipment
- Solder (silver and/or lead)
- Lead (batteries, pipe, block)
- Painted Metal (lead paint)
- Batteries (lead acid)
- Silver (photographic fixer, solder, jewelry)
It is important to make an accurate hazardous waste determination on every solid waste prior to disposal.Some materials which are believed to be non-hazardous, such as brass keys, are “hazardous” (regulated) per NYSDEC regulations. If an item contains a regulated heavy metal, such as arsenic, barium, cadmium, chromium, lead, mercury, selenium, or silver, or is contaminated with regulated heavy metals or with other toxic material, solvents or PCB’s at levels as low as one part per million, the material may be regulated.
Items which contain or may otherwise be considered regulated waste may still be recycled or reclaimed as a scrap metal, but the University must do so in accordance with New York State regulations (6NYCRR 371.1(c)(7)). According to 6NYCRR 371.1(c)(7) prior to the reclaiming offsite of any regulated waste as scrap metal, the University is required to identify to the NYSDEC, the names and locations of the facilities that the University wishes to utilize for scrap metal recycling and reclamation of regulated material. In some particular cases (i.e. electronic equipment) the identified recycler must also provide written notice to NYSDEC and may be required to be “approved” prior to accepting “scrap metal” in conjunction with the hazardous waste scrap metal exemption.
Pursuant to the requirement, EHSS has submitted a “C-7” notification to the NYSDEC. Accompanying that notification was a list of facilities, which the University currently utilizes for recycling regulated scrap metal. The facilities listed on the EHSS website under Waste Management/Scrap Metalare the authorized facilities for the recycling of University generated regulated scrap metal. Only the facilities listed at may be utilized by University personnel for the recycling of regulated scrap metal.
The University is required by the NYSDEC to ensure that certain criteria are met when recycling hazardous materials. The University has an understanding with the authorized recyclers in which they acknowledge that they:
- Have the capacity and the necessary equipment to process the entire volume of the materials offered in any given shipment;
- Have a known market or disposition for the scrap metal received from the University;
- Will notify the University prior to the shipment of scrap metal to any facility owned or operated by their company of any limits on quantity per shipment or other such related restrictions; and
- Any subsequent facilities will reclaim, recycle, use or reuse the material received from the University.
“Scrap Metal” shipments do not have any special labeling, storage, recording, or special shipment requirements as specifically related to the aforementioned regulations.
Unregulated scrap metal can be sent to a recycler not on this list, and is not affected by this policy.
If a University Department/Organization wishes to utilize a company not listed for the recycling/reclamation of regulated scrap metal, the Department must notify EHSS six weeks prior to projected use. The notification should be made by completing the appropriate form found on the EHSS website under Waste Management/Scrap Metal. The Department may also notify EHSS by memorandum or e-mail, but the notification must include all of the relevant data.
The notification must include the following items:
- Company Name
- Company Point of Contact Name
- Company Phone Number
- Company Address
- Justification for addition of the new company
- Description and quantity of scrap metal
- Anticipated duration of the waste stream
EHSS will review each request to add additional recyclers considering all the relevant data. When warranted, a notice will be sent to the NYSDEC informing them of our intent to add the company to our former notification. EHSS will also send the recycler/reclaimer a letter and form to be returned. The form verifies that they will abide by the criteria listed above.
Regulated scrap metal shipments may not be made to any unlisted (unauthorized) recycler/reclaimer by the University Department/Organization until the EHSS has authorized use of the company.
Computer and Electronic Equipment
Computers, fax machines, printers, photocopiers, keyboards and other pieces of electronic equipment with circuit boards are regulated as hazardous wastes under the same regulation. These materials are regulated due to the lead content in the cathode ray tube and/or the lead content in the soldering on the circuit boards.
To recycle any electronic equipment, the generator must contact the University’s Excess Property. The employees at Excess Property will make arrangements with the generator to remove and dispose of unwanted electronic equipment. There may be a charge for this service, which will be the responsibility of the generator or department. The EHSS does not handle used electronic equipment.