Introduction:

Tufts University is required to eliminate mercury in the wastewater discharge from university owned and operated buildings and facilities. To improve compliance, Tufts has developed this Mercury Management Statement to provide instruction for users on requirements and best management practices.

Mercury is a naturally occurring element that is toxic to people and wildlife. When products containing mercury are broken or thrown in the trash, outdoors, or down the drain, mercury cycles through the environment, polluting air and water. For this reason, the Massachusetts Water Resources Authority (MWRA) and Massachusetts Department of Environmental Protection (MA DEP) has limited mercury discharge from all industrial users, including Tufts to a concentration of 1 part per billion

Mercury is present in many products routinely used at Tufts to support research and teaching. Mercury may be present in equipment including thermometers, thermostats, and some electrical switches and thus some users have received training on the proper storage, disposal, and cleanup of this material.  However, mercury is also present in very small amounts (trace) in many other products used at Tufts. Even these small, seemingly insignificant sources of mercury must be safely managed. The improper disposal of this material could result in mercury entering sewer systems and Tufts receiving notices of violation for exceeding discharge limits.

Therefore, IT IS THE RESPONSIBILITY OF ALL USERS TO UNDERSTAND THE CONTENT OF THIS POLICY AND TO FOLLOW THE BEST MANAGEMENT PRACTICES OUTLINED IN THIS POLICY AT ALL TIMES.

QUESTIONS AND ANSWERS:

Why does Tufts use any products that contain mercury?
Many products essential for research and teaching do not have mercury-free substitutes. When mercury-free substitutes are found, they are often used. Conversely, some products like compact fluorescent light bulbs are energy efficient and have long lives.

What products that I work with at Tufts may contain mercury?
Mercury may be found in batteries, fluorescent lamps, laboratory reagents, cleaning products like bleach and pre-packaged laboratory kits. Ask your Principal Investigator or Tufts Environmental Health and Safety (TEHS) for instruction on disposal BEFORE disposing any solution down a drain.  Attached is a document titled Mercury Containing Products which lists commonly used laboratory products and their level of mercury.

What happens to a mercury solution when it is poured into a sink drain?
The mercury will flow through the building’s plumbing system. The mercury may become trapped in the buildings pipes, traps, and neutralization tanks. The mercury will accumulate over time and may result in the need for expensive and invasive decontamination projects.

Mercury that is not trapped inside a building will discharge to the MWRA sewerage system (Boston, Medford/Somerville Campus) and municipal sewer system (Grafton Campus) before eventually discharging to the environment.

How will anyone know if I pour mercury down the drain?
Yes, with a discharge limit of 1 part per billion (ppb), almost any volume of mercury effluent will be detected.

To demonstrate compliance with Tufts wastewater discharge permits, Tufts is required to frequently sample many locations to ensure that mercury effluent is not disposed down a sink drain. In addition, the MWRA conducts unannounced sampling to confirm that mercury discharge limits are not being exceeded. For example, only 4 grams (0.14 ounces) of mercury can contaminate 1,000,000,000 (one billion) gallons of wastewater to a concentration slightly above the 1 ppb limit.

Failure to comply with discharge limits can result in Tufts being subject to fines and penalties.

If I cannot dispose of mercury down the drain, what do I do with it?
First, determine if a mercury-free alternate available before using a product that contains any level of mercury.  If use of a mercury-containing product is required, make sure you collect all waste products.  Manage and dispose of all material in accordance with the Tufts Hazardous Chemical Waste Management Plan.  Contact your Principal Investigator or TEHS with specific questions and requests for compliance assistance.

Summary:

In summary, mercury is present in many products used at Tufts. Managing proper mercury disposal is a collaborative effort between all member of the Tufts community and it is the responsibility of all users of Tufts’ buildings and facilities to understand and comply the content of this policy.  Specifically, users should be able to identify materials and solutions that contain mercury, even at trace amounts, and understand how to properly dispose of this material.  If you are unsure or have questions, please contact TEHS and we will be happy to advise on proper mercury management.

September 2012