EBOM 2009 MRc6: Solid Waste Management—Waste Stream Audit

Tim, I haven't done it but I have no reason to think that it wouldn't work.

I'm not sure about NC, however we have successfully used the requirements of MRc4 as part of a comprehensive waste reduction strategy for an ID point for a LEED CI project.

Q1: According to the reference guide, in order to achieve MRc6 you must analyze both the disposal waste stream (landfill or incineration) and the diverted waste stream (recycling, composting, reuse). If there is no diverted waste stream, I don't believe you can achieve MRc6.

Q2: Yes, that is appropriate. Hazardous medical waste should not be included in the audit.

I would defer to Brittany, but I am surprised—I think that if 100% of the waste stream is landfilled, you could audit that and earn the credit. However, you do have to identify opportunities for reducing waste going to the landfill, so if you intend to continue landfilling 100% of waste even after the audit, then the effort is wasted and you wouldn't be meeting the credit requirements.

Good point Tristan. I think it is unclear from the credit language in the reference guide to determine if it is acceptable or not to earn MRc6 if you don't have recycling in the project building during the performance. But it seems implied to me.

If the building has no recycling in place before the performance period starts, then theoretically you would have problems documenting MRp2: Solid Waste Management as well.

If the project building is in a location (for instance, in some locations outside of the U.S.) that does not have the infrastructure to support a recycling program, then I would imagine that some leniency would be granted for these credits.

Has anybody out there dealt with this situation before?

Interesting situation and I think both Brittany and Tristan have offered great insights here. As I see it, even with 100% landfill-directed waste, earning MRc6 should be feasible. The concept of a waste audit is fundamentally based on the idea that the first step towards improving diversion rates is to understand your waste stream - that principle should hold whether your current diversion rate is 90% or 0%.

That being said, I think Brittany's point about MRp2 is important. Although EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems. does not establish a minimum diversion rate for achieving certification, inherent in MRp2 is an expectation that a diversion program of some sort is in place. In some circumstances (outside the US, as noted) it may be difficult to divert even 5% of waste, but if your SWMP is going to fly, it should detail exactly how you plan to get at least some fraction of your waste stream out of the landfill.

I would also note one clarification on Tristan's response; although the credit does require that you identify opportunities for increased diversion, there is no corresponding requirement that you seize, or even consider seizing, those opportunities. The act of identifying the opportunities is enough, in much the same way that elsewhere in the rating system you are rewarded for simply metering resource consumption. In this instance, the credit is about data collection and analysis, not the actions or outcomes that result. In other words, MRc6 is sort of like metering for your trash. . .

Hope that helps,

Dan

I think this would be acceptable as long as you clearly demonstrate that each separate audit examined all of the waste (either trash or recycling) that was generated at the project building for an equivalent amount of time. So, your collection period should be the same for each audit (i.e. 1 day, 1 week, etc.). As long as you can show that each audit is representative of the total building waste stream, it should be fine.

Wendy, just a quick clarification: the 24-hour collection period is typical and definitely acceptable, however, you must include ALL waste generated in the project building in your audit. Sampling of the waste stream is not allowed in any form. So, you'll need to coordinate a pick-up of all desk-side bins as part of your audit procedure.

Thanks for the clarification. As we should not tell tenants about the audit, any suggestions on dealing with people who might need a document they have recycled? Could we just inform them that we will be collecting all waste for two days - but not state why?

I would want to avoid sending any signal that people should not recycle stuff on the day of the audit.

Do you have any reason to think that this is an issue. Recycling gets picked up from desks weekly so people must be used to seeing their stuff go away. If they are using the recycling bin as a file cabinet I think that's their issue, not yours.

Right now we currently only have weekly deskside trash pickup, not recycling. Deskside recycling is completely up to the tenant. They have to dump their own deskside recycling in the community recycling bins in the break rooms when they decide to. Unfortunately, its not a service we provide.

I know from personal experience that sometimes I'll put something in my deskside recycling and then decide I still need it and take it back out before I dump it, which is kind of why it is a grey area and letting people know might allow them to make sure they have only disposed things they really do not want. As it is something that tenants currently are responsible for it almost feels like a slight invasion of privacy.

I see—I hadn't realized that. If I were in your shoes I would let them know that as a one-time thing, desk-side recycling will be emptied by cleaning staff sometime in the next two weeks—giving them fair warning but probably not causing any change in behavior.

I like that approach. Thanks for working it through with me.

The sample provided in the documentation toolkit on LEEDUser is perfectly fine. Some waste management companies offer very detailed auditing services to help a client really fine tune the strategies needed to improve their recycling rates. Your best guideline is the categories listed on the LEED credit form. These categories are: metal, mixed paper, cardboard, glass, plastics, wet waste, and landscape waste. If your audit addresses these categories, you will be just fine.

In reading the documentation audit report, it states all landscape material and sensitive papers are excluded from the calculation as all of the landscape material is composted and all sensitive papers are recycled. Is it safe to state this for our reports or would we need to weigh our landscape waste material?

This leads into my next question for MRc7, again the sensitive papers/landscape material is 100% recycled or composted, are we required to weigh this or can we exclude it from our calculation?

For MRc6, it's fine to exclude shredded paper and composted landscape waste, since those materials are not collected for disposal by the building maintenance/janitorial staff.

For MRc7, leaving those materials out of your calculations is allowed, but consider your actions carefully, since including shredded paper and landscaping waste may actually help your overall performance level. Some companies that securely manage shredded documents are willing to share the monthly amounts (as long as they aren't asked to divulge any sensitive information) and if your landscaper is hauling landscape waste away from your site to compost somewhere else, they may have some way to measure the total amount.

Sounds to me like this describes items as part of a business process and not items that would be conventionally understood as "waste" generated by the building. If that sounds right, I would say that these items do not need to be tracked. But I would be curious what anyone else thinks?

I agree - this waste is not generated at your project site and therefore would not be included in a waste stream audit.

Kevin, it seems likely that the approach you're suggesting could work. A similar issue often occurs in LEED-NC MRc2: Construction Waste Management, and using the facility diversion rates works there.

Kevin,

The intent of the summary table is to help the building management understand what materials are generated at what rates, and also how effective occupants are at sorting their waste according the buildings separation strategy (presumably it's best when recyclables get into the recycling bags, because the sorting facility has a higher recovery rate/less contamination).

So, my opinion is that using the values that the hauler supplies is not the most useful here (though very useful for documenting MRc7). I would recommend entering the weights and types associated with the trash bags as "Landfill Stream" (even if some of the material gets sorted out and recycled eventually) and the weights and types associated with the recycling bags as "Diversion Stream".

Jenny and Tristan,

Thanks for your input. I will definitely follow the route that Jenny described.

100% of our building waste is sent to for off-site sorting that typically recycles 63% of all waste. In achieving this credit we may propose to our vendor to collect waste for a 24 hour period and then weigh the total. Then our vendor would sort and weigh the amount that could be recycled, and then subtract the recycled amount from the original total to what really is going to the landfill. Does this seem accurate?

I'm not totally sure what you mean by "then subtract the recycled amount from the original total to what really
is going to the landfill."

However, I would be concerned that this approach is not going to be really effective for your project. It sounds like you'd basically be asking your vendor to do what they normally do, and then report the numbers to you. It sounds more like they're auditing their own performance—which doesn't really make sense.

Rather than just using the overall % diversion rate, is their a better approach to this credit? My thought was: if there was 500 lbs sent to the sorting station we would have the vendor seperate the 500 lbs from all other waste and sort it out providing us with an actual weight that is being diverted from the landfill - lets say 200 lbs (recycled), we would then say only 300 lbs is being sent to the landfill and 200 lbs is being recycled.

You need to reports types of waste by weight or volume. There's a bunch more info on this above.

I still don't get why you would want your own vendor to do this for you. Seems like this would be a good chance to see how effective their service is at diverting waste. The whole goal of this credit is to improve waste diversion.

We may choose to do the sorting ourselves onsite to evaluate our vendor, perhaps we could even do it at their facility in our presence. I understand the goal is improve waste diversion but with our current structure, 100% of waste is lumped together and then sorted to recycle everything possible, I guess the one thing that could improve is creating a method to prevent tainting potential recycables.

I think that if you gave the same container of comingledA process of recycling materials that allows consumers to dispose of various materials (such as paper, cardboard, plastic, and metal) in one container that is separate from waste. The recyclable materials are not sorted until they are collected and brought to a sorting facility. waste to 10 different vendors, they would have several different diversion rates. I bet it would cluster around one rate, but there might be some outliers, good and bad. This seems like a chance to check up on how your vendor is doing.

Other things to improve on, as you allude to, might be recycling smaller volume recyclables that get lost, like e-goods, batteries, metals, etc.

Hi Rachael -

You are correct that all of the performance periods need to end at the same time, though this “alignment window” has been changed from 7 days to 30 days (see the Reference Guide Addenda at www.usgbc.org/ShowFile.aspx?DocumentID=6395).

The performance period for this credit has the same requirements as all other performance periods - it must be at least 3 months in length, but no more than 24 months in length. The actual waste audit you conduct must occur within that performance period, but your waste audit can be of a day's waste, or of a week's waste, or some time period in between. You do not need to audit all the waste produced during the performance period.

A waste audit is a one-time activity that gives you a snapshot of your waste streams and helps you identify methods to improve waste diversion. For credits such as MRc7 (Solid Waste Management - Ongoing ConsumablesOngoing consumables have a low cost per unit and are regularly used and replaced in the course of business. Examples include paper, toner cartridges, binders, batteries, and desk accessories.), on the other hand, you would need to quantify the waste diverted over the entire performance period; this credit focuses on quantifying ongoing performance. MRc6 (Solid Waste Management - Waste Stream Audit), on the other hand, is about analyzing your waste stream in detail and identifying opportunities for improvement. MRc6 is not concerned with your exact level of performance but instead focuses on processes to help you improve diversion rates.

My client had conducted a waste stream audit more than 2 years before the performance period. They have an efficient waste reduction and recycling that is documented and this has been in place over the past years. Will the audit conducted before the performance period be accepted by LEED since the practice has been consistent working on continued improvement, or is there a need to conduct another waste stream audit?

A compliant waste audit must be conducted during a qualifying performance period, so an audit conducted more than 2 years before the end of your performance period will not count. The good news is that your client has experience conducting these audits and has a good waste management program in place, so it should be relatively straightforward to conduct a new audit. Make sure that the new audit meets the credit requirements rather than just repeating the procedure used for the old audit; since they were not considering LEED certification at that time, the old audit may not have met all of the compliance criteria.

We have been asked to conduct a waste stream audit by the certification team after preliminary review (consequently, after the performance period).

My queries:

1) How does this affect the performance period if we do conduct one now?

2) Will it be acceptable to conduct one even if it is after the performance period for all other credits?

3) Do we need to move all the performance periods in order to get this point? Note: earliest credits and pre-requisites related to energy and atmosphere started Jan 2009 and closed Oct 2010, therefore the end of performance period for this intended credit if ever, will be more than 30 days compared to end of performance periods of the rest of the submitted documents.

Hoping for advise from anyone.

For this particular credit, you're allowed to conduct a new audit if requested by the review team in your preliminary review comments. You do not need to adjust any performance periods in your application. Just perform the new audit according to the instructions in your preliminary review and provide the revised documentation in your resubmittal.

I'm surprised to not see other Hospitality sector buildings on here...Our client is a Convention Center with an irregular waste stream that is based on show activity. Would you suggest we conduct the audit when the building is essentially unoccupied (with exception of staff) OR when there is a show in the building... if you recommend the latter, waste stream fluctuates before, during and after the show so would we want to capture the highest volume time? It is difficult to determine a "representative" set. Thank you!

So the good book says 'during the performance period', but when is that for you?. I suppose one could take the initiative and suggest that the audit is in fact completed when there is trash for auditing. This is where the book doesn't fit the actual operation of the building. My suggestion is to complete two audits.

Hi Barry, the performance period issue is OK but you brought up a good point that got me thinking on the 2 separate audits. The building has 2 concourses, for LEED purposes its one building, but for show activity its two. That said, the waste streams are unique and independent of each other during the time we are planning to conduct the audit. Could we justify doing two audits, 1 for each concourse? We would ofcourse follow some of the other suggestions posted here as to how we make this justifiable. Doing this would give the most accurate and representative data, which is the goal and the intent.

Each Concourse...not really. I'm assuming that the waste stream/recycling is in fact held in one holding area until pickup, that is a single recycling compactor, single trash bin, etc. You already said that it's one building for the purposes of LEED, don't give the GBCI room to manouver as to why you want to do two audits!!!!

There are 14 compactors and 6 open tops evenly divided among the 2 dock areas, which are on opposite sides of the building corresponding with the 2 concourses. Pick ups are done on separate days or with a fleet of trucks depending on if the show is taking up both concourses. So, since we are doing at a time where there are 2 separate shows and individual waste streams would this be justifiable

OK, I see that, but in reality if you have designed/written a comprehensive 'waste policy', then one, two or three locations shouldn't matter, they 'should' all be recycling at the same rate and therefore the two audits that you undertake 'should' have the same results. What may vary is that some shows will produce more of one type of trash item than another.
Ok, so do the two audits in the two separate shows...if the numbers are different be really clear as to why they are different.

Hi Reynaldo -

The Reference Guide states that "the audit must be conducted during the performance period." As long as this requirement is met, you should be fine, timing-wise. The maximum performance period length is 24 months, so as long as your waste audit took place during this time period, you can use data from a waste audit you've already completed.