EBOM-2009 MRp2: Solid Waste Management Policy

  • EBOM MRp2 Waste Management Diagram
  • Create and implement solid waste management policy

    This highly achievable prerequisite requires you to create and implement a solid waste management (SWM) policy aimed at reducing the amount of waste sent to landfill from your building. Most teams will be able to create a good SWM policy with in-house staff at little to no additional cost.

    Having such a policy in place will provide building staff with clear procedures for managing all categories of waste, and by having a written policy covering those areas, it paves the way for your project to achieve:

    • MRc7: Solid Waste Management—Ongoing Consumables;
    • MRc8: Solid Waste Management—Durable Goods;
    • and MRc9: Solid Waste Management—Facility Alterations and Additions.

    Document the policy, not the practice

    You are required only to create a SWM policy setting measureable goals and defining the procedures for managing the waste streams covered by credits MRc7, MRc8 and MRc9, as well as mercury-containing lamps. Actually documenting the policy in practice, or compliance with those credits, is not a requirement here.

    The SWM policy applies only to those waste streams that are directly within the control of building and site management; tenants using separate waste hauling contractors are exempt from the policy.

    Writing the policy—avoid common missteps

    A compliant SWM policy must adhere to USGBC’s “Program, Plan and Policy Model for LEED-EBOM” (see Resources). Project teams often make mistakes here by failing to establish quantifiable performance metrics or to assign a specific responsible party to perform key tasks.

    Other common missteps include failing to include policy language addressing the proper handling of furniture in the discussion on durable goods, which teams may mistakenly limit to electronic equipment. Including a quality control and quality assurance procedure in your SWM policy will help ensure that furniture and electronic goods are donated or recycled, not placed in regular dumpsters and sent to the landfill. 

    These questions will help orient your team 

    Recycling ContainersSet recycling goals, communicate them to building occupants, and provide easy access to recycling containers.What are the different components of the building waste stream and which waste streams are within the building and site management’s control?

    • Who will be responsible for managing and enforcing the SWM policy?
    • What actions are necessary for the SWM policy to take effect prior to the start of the performance period?
    • What are the goals for recycling, reuse, source reduction, and donation in the project building? How will targets be assessed?
    • How will the responsible parties track, measure, and evaluate recycling, reuse, source reduction, and donation?
    • What procedures and strategies will your team implement to meet the goals and intent of the policy?
    • How can you involve your waste haulers in supporting your recycling goals?

    FAQs for LEED-EBOM MRp2

    To comply with MRp2, the Solid Waste Management Policy must state goals associated with the requirements of MRc7, MRc8, and MRc9. Does the project team need to track the performance of these related credits’ goals during the performance period?

    The short answer is no, but it’s still good to do it. If the project team decides to pursue MRc7, MRc8 and/or MRc9, they will have to provide documentation and/or calculations demonstrating compliance for those credits. However, for this prerequisite (MRp2), demonstrating performance during the performance period is not required.

    Do the goals listed in the Solid Waste Management Policy need to match exactly the performance thresholds required for achieving MRc7, MRc8, and MRc9?

    No, these don’t need to match exactly. That said, for recycling of mercury-containing lamps, the target goal and performance must be 100% of all mercury-containing lamps are recycled. All other target goals listed in the policy can be set to any level that is appropriate for the project building.

    The project building has multiple tenants, and several of the tenants manage their own recycling or waste diversion. Does the SWM Policy need to address the diversion of waste from those spaces?

    No, for MRp2, the SWM Policy needs only to address the disposal of waste streams that are controlled by building management.

Legend

  • Best Practices
  • Gotcha
  • Action Steps
  • Cost Tip

Before the Performance Period

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  • Create an SWM policy that sets measureable goals for recycling and reuse of waste streams that are within the building and site management’s control. Make sure that the SWM policy specifically covers each aspect of the USGBC Policy Model. (See Resources.)


  • Before creating the SWM policy, conduct a waste stream audit, in conjunction with MRc6: Solid Waste Management—Waste Stream Audit, to assess current recycling rates in your building. Although not a prerequisite requirement, doing so will help identify strong or weak areas in existing practices, and help you to craft the SWM policy to address opportunities for improvements.


  • The SWM policy may be part of a larger building sustainability policy or a document that pre-dates the LEED project time period. If the SWM policy is part of a larger document, highlight the sections relevant to this prerequisite (and indicate which address each core element of the USGBC Policy Model) to help the LEED reviewer easily locate this language.


  • LEED-EBOM does not require your policy to commit to the compliance thresholds for SWM credits (such as 50% of ongoing consumables). For this prerequisite, diversion targets may be set to any level that is appropriate for your building, as long as they are publicly articulated in the SWM policy.


  • In-house staff can develop the SWM policy, thus avoiding additional costs.


  • The SWM policy must cover the waste streams that are within the building and site management’s control covered by these credits (see those credits for detailed descriptions of these waste streams): 

    • MRc7: Solid Waste Management—Ongoing Consumables
    • MRc8: Solid Waste Management—Durable Goods
    • MRc9: Solid Waste Management—Facility Alterations and Additions

  • The SWM policy must also address goals and procedures for recycling mercury-containing lamps, which are not covered by one of these credits (although their purchase is covered by MRc4: Sustainable Purchasing—Reduced Mercury in Lamps). 


  • Don’t forget to include a goal for recycling batteries.


  • Tenant waste that is handled by a separate waste hauler does not need to be covered in the policy, but project teams must identify in documentation which portions of the building are not governed by this policy.


  • Goals and procedures for recycling batteries must also be addressed by the SWM Policy.


  • The discussion about recycling of durable goods must cover furniture as well as electronics and office equipment, per MRc8. Project teams often make the mistake of focusing only on electronic equipment and ignore the importance of promoting reuse or donation of furniture.


  • The SWM policy should require the responsible party to verify that the contracted hauler is recycling electronic equipment in a responsible manner and is not sending these materials overseas for unsafe processing in developing countries. More information on selecting a responsible electronics recycler can be found through the e-Stewards organization. (See Resources.) 


  • The SWM policy should include a quality assurance and control procedure by which the responsible parties ensure that furniture is donated or recycled and doesn’t end up in the landfill stream and that electronic goods are not placed in regular trash dumpsters.


  • Don’t forget to include a responsible party—include a position title, or even better, the name of a person (and their position title) who will oversee the implementation of this plan. If there are multiple people involved, list as many as seem relevant.


  • Composting of landscaping waste may also be addressed by the SWM policy if applicable to your building and site.


  • Distribute copies of the SWM policy to all relevant personnel. Ensure that requirements are communicated to waste haulers and collaborate with haulers to identify best practices for waste collection and proper tracking of recycling rates. Engage haulers as early as possible to smooth transitions and identify opportunities.


  • Recycling and other waste diversion procedures should be added to occupant handbooks and employee orientation packets.


  • Hauling fees for recyclable materials will vary by region, but keep in mind that improved recycling rates will decrease the amount of landfill waste, thus reducing your garbage hauling fees. There may be additional costs associated with expanding collection efforts, ranging from purchasing additional receptacles to increased fees for pickup and transport of recyclables.


  • The plan must include a goal of 100% for recycling of mercury containing lamps. No other goal will be accepted for lamp recycling.

During the Performance Period

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  • Ensure that the SWM policy is in place and that responsible parties are using it as a guideline for any waste management decisions made during the performance period. The credit requires the policy to be implemented throughout the performance period. 


  • Implementation of the SWM policy does not require you to attempt compliance with MRc7, MRc8 or MRc9, but since you’ve done part of the work, it may be worth it.


  • Actively engage purchasing agents or other individuals overseeing procurement to ensure that reduction of packaging materials is a consideration when making purchases.

  • USGBC

    Excerpted from LEED 2009 for Existing Buildings: Operations & Maintenance

    MR Prerequisite 2: Solid waste management policy

    Required

    Intent

    To facilitate the reduction of waste generated by building occupants that is hauled to and disposed of in landfills or incineration facilities.

    Requirements

    Have in place a solid waste management policy for the building and site addressing the requirements of the waste management credits listed below as well as recycling of all mercury-containing lamps. This policy must adhere to the LEED 2009 for Existing Buildings: Operations & Maintenance policy model (see Introduction). At a minimum, the policy must cover the waste streams that are within the building and site management’s control.

    • MR Credit 7: Solid Waste Management—Ongoing Consumables
    • MR Credit 8: Solid Waste Management—Durable Goods
    • MR Credit 9: Solid Waste Management—Facility Alterations and Additions

    This prerequisite requires only policies, not ongoing actual sustainable performance.

    Potential Technologies & Strategies

    Evaluate the building’s waste stream and establish policies to divert materials from disposal in landfills or incineration facilities by encouraging the reuse and recycling of items, where possible.

Web Tools

USGBC Program, Plan and Policy Model for LEED-EB: O&M

USGBC provides a description of the definitions, requirements, and structure of a policy, program or plan as they relate to EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems. submittals.


LampRecycle.org

This useful website provides details on how to recycle spent mercury-containing lamps.


U.S. EPA Waste Wise Program

WasteWise is a free, voluntary EPA program that U.S. organizations can use to track, manage, and reduce their municipal solid waste and select industrial wastes.


e-Stewards

This organization provides information on global pollution associated with toxic materials in electronic equipment. e-Stewards helps consumers to find responsible electronics recyclers who pledge not to send equipment overseas to developing countries for unsafe landfilling and processing. 

Solid Waste Management Policy

The solid waste management (SWM) policy, the main requirement for MRp2, outlines the scope, goals, procedures, performance metrics and responsible parties for your building’s solid waste management program.

LEED-EBOM Policy, Program and Plan Models

Your LEED-EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems. plans must include all required elements of the Program & Plan Model, which is described in this USGBC document.

Sample LEED Online Form

This LEED Online form with sample data and tips demonstrates how to document MRp2.

LEED Online Forms: EBOM-2009 MR

The following links take you to the public, informational versions of the dynamic LEED Online forms for each EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems.-2009 MR credit. You'll need to fill out the live versions of these forms on LEED Online for each credit you hope to earn.

Version 4 forms (newest):

Version 3 forms:

These links are posted by LEEDuser with USGBC's permission. USGBC has certain usage restrictions for these forms; for more information, visit LEED Online and click "Sample Forms Download."

18 Comments

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Tristan Roberts LEED AP BD+C, Editorial Director – LEEDuser BuildingGreen, Inc.
Nov 27 2012
LEEDuser Moderator

LEEDuser's MRp2 template

We have updated the MRp2 template we offer through LEEDuser, adding a mention of mercury-containing lamps. Members can download this in the Documentation Toolkit.

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Jill Ziegler Program Manager for Sustainability Initiatives Forest City Enterprises, Inc.
Sep 14 2012
LEEDuser Member
145 Thumbs Up

tenant compliance required?

Can anyone elaborate on the following credit language? "At a minimum, the policy must cover the waste streams that are within the building and site management’s control." We are looking at EBOMEBOM is an acronym for Existing Buildings: Operations & Maintenance, one of the LEED 2009 rating sytems. for a mall. As the landlord and building manager, I would argue that we only control the common area and our own mangement offices. We bill our tenants for centralized waste collection; they are responsible for emptying their trash, separating cardboard, etc. Can we legitimately document during the performance period only the common area waste and exclude tenants?

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Barry Giles Founder & CEO, USGBC LEED Faculty, LEED AP O+M, BuildingWise LLC Sep 14 2012 LEEDuser Expert 1786 Thumbs Up

Great question. Here's some extra ones...if you own the bins, then you control what goes into them. If they own the bins and pay direct for the waste/recycling, then it can be their problem. However, in reality the majority of the waste from the mall is from the tenants, not the common areas and I would respectfully suggest that the onus for waste and recycling falls to you. At the end of the day the 'mall will get the plaque'

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Juliane Muench
Jan 09 2012
LEEDuser Member
254 Thumbs Up

No sorting possible

I have a project in a city, where there are no possibilities for sorting, as the municipality only gathers waste in one big chunk. So even if we would sort, it would just be put in the same container. Can we get a certification based on these premises, since no policy for sorting of waste can be done? A sorting of waste within the building does not make any sense, as it all ends up the same place.

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Brittany Bliffen Sustainability Manager, YR&G Jan 16 2012 LEEDuser Expert 231 Thumbs Up

Do you mean that all recycling is co-mingled but is still kept separate from the trash, or that all recycling and trash are co-mingled?

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Juliane Muench Jan 23 2012 LEEDuser Member 254 Thumbs Up

All trash and recycling are commingled when it is collected. It makes no sense to sort in plastic, metal, paper etc when it all is collected in one big chunk. What should we do?

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Barry Giles Founder & CEO, USGBC LEED Faculty, LEED AP O+M, BuildingWise LLC Jan 23 2012 LEEDuser Expert 1786 Thumbs Up

I'm making the assumption that this is not a US city....so taking that as the starting point I hope that I can at least point you in some directions. First wherever the total co-mingled ends up (usually at the transfer station), investigate if they have a separation plant that will divide up the recycle form the trash. If so gather details of how they do it (include pictures) and then gather results from the company showing the %'s of the different streams. If there is no such operation then I'm afraid that it is down to you. While you may feel that it makes no sense this is what market-leadership is all about (in any case you'll need to do an on-site dumpster dive to create the baseline "what's in the trash/recycle stream")....and you're going to have to sort on site, find recyclers to take the various items (every different stream will need weighing and recording). Yes, I know that sounds a lot, but what we're trying to do is move the marketplace and, I hope, that your work will be reported on and start the local process of separate stream recycling. (It's not easy being the market leader)

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Dionne Early Environmental Specialist - Municipal Green Building Program, City of San Jose Jul 23 2012 LEEDuser Member 6 Thumbs Up

I work for a municipality where all trash and recycled materials are gathered at each of the 300+ facilities owned and operated by the city and then sorted and weighed to arrive at numbers for the city facilities as a whole. We are currently attempting to design a protocol for LEED EB volume but if each buildings waste has to be accounted for at the building level we will not be able to participate in certification of any of our buildings using the LEED EB rating system on an individual or volume basis. Is it acceptable to submit a protocol for the entire organization and apply the percentage we arrive at for each building?

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Barry Giles Founder & CEO, USGBC LEED Faculty, LEED AP O+M, BuildingWise LLC Jul 23 2012 LEEDuser Expert 1786 Thumbs Up

Dionne, Ok, great question and I'm going to answer it not in the way that you think.
The difficulty of trash/recycling is that the generation of the same is dependent on each of the buildings. In a volume process we have, to quote both ends of the spectrum, one end where the recycling is 100% and there is no trash to speak of (a net-zero waste facility) to the other end where no-one in the building gives a tinkers cuss and the recycling is 1%. If we the combined these two buildings recycling and trash output then we would have a 50% recycling rate. But unless you were actually in the building recording the output from them you would have no idea which building was 100% and which building was 1%...(and of course we want to take all the great ideas and processes from the 100% building and instruct the 1% to create improvements)
So...sounds like to me you will need to perform 300 dumpster dives to gain a clear understanding of where each of the building stands...between 100% recycling and 1%.
This MIGHT be possible by getting the hauler to help you, but previous experience shows that they tend to 'round the numbers' and the accuracy leaves a lot to be desired.

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Pablo Fortunato Suarez Principal ESD Consultant/Architect GreenArc Sustainable Building & Architecture
Jul 05 2010
LEEDuser Member
2483 Thumbs Up

other related green practices

my client had been practicing ISO 14000 for several years (over 5 years). as such, they already had in place a related waste management policy. their performance is normally based on constant annual improvements albeit gradual and not as high as LEED targets (50-70% depending on type of waste).
are we supposed to put in place a new policy or ammend existing ones to meet LEED targets in order to get this pre-requisite and related credits? how does this affect the performance period declaration? will LEED consider past/on-going practice leading to relatively 'higher' targets or will it impose the same targets regardless of what has been/is being implemented?

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Tristan Roberts LEED AP BD+C, Editorial Director – LEEDuser, BuildingGreen, Inc. Jul 12 2010 LEEDuser Moderator

Your similar question is answered on the MRp1 forum. It's fine to amend the existing policy to meet the LEED targets. You will need to be in compliance for the performance period—the existing non-compliant policy won't work in this case.

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Pablo Fortunato Suarez Principal ESD Consultant/Architect, GreenArc Sustainable Building & Architecture Jul 14 2010 LEEDuser Member 2483 Thumbs Up

Thank you Tristan.

The client actually has a policy for 100% diversion for durable goodsDurable goods have a useful life of 2 years or more and are replaced infrequently or may require capital program outlays. Examples include furniture, office equipment, appliances, external power adapters, televisions, and audiovisual equipment., facility alterations/additions, batteries and mercury in lamps, and a target of 70-75% for total (including on-going consumables) which was actually exceeded in certain periods.

My other concern is that they lumped all items in a 'total target'. While mathematically this will in fact be higher than LEED targets, is it necessary that separate targets be created in a policy for on-going consumables? Will this target (70-75%) for all, including on-going consumables + 100% durable goods, facility alterations/additions, batteries and mercury lamps be sufficient?

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Tristan Roberts LEED AP BD+C, Editorial Director – LEEDuser, BuildingGreen, Inc. Jul 19 2010 LEEDuser Moderator

You do need specific, separate targets for each of the areas covered by MR credits 7 through 9.

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Asa Posner Senior Sustainability Consultant, Sustainable Investment Group (SIG) Aug 22 2011 LEEDuser Member 546 Thumbs Up

Just received comments (copied below) on an application where this prerequisite was pended because our goals were not high enough.

"However, the policy has a goal of recycling 95% of mercury-containing lamps. The Requirements section of MRp2 in the LEED Reference Guide for Green Building Operations and Maintenance, 2009 Edition (Updated April 2010) states that the policy must have a goal
of recycling 100% of mercury-containing lamps. TECHNICAL ADVICE: Please provide a revised Solid Waste Management Policy that includes a goal of recycling 100% of mercury-containing lamps."

I'm posting here because I cannot find this requirement stated anywhere in the reference guide, nor in any addenda. Even the sample policy published on page 248 (2009 edition-updated April 2010) quotes a 95% reduction for mercury-containing light bulbs.

I am revising the policy, because we need to earn the prereq. and a goal of 100% is a good idea, not very different from a goal of 95%. However, I feel that this comment is unfair and characteristic of LEED reviewers interpreting the rating system differently than the general public. Has anyone else has a similar experience?

To help out the rest of us, the following policy goals were approved:

Reducing the overall amount of waste generated for:
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. by 70%
Durable goodsDurable goods have a useful life of 2 years or more and are replaced infrequently or may require capital program outlays. Examples include furniture, office equipment, appliances, external power adapters, televisions, and audiovisual equipment. by at least 75%
Facility alterations/additions by 70%
Batteries by at least 80%

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Jacob Arlein Director of Energy Services, Environmental Building Strategies Aug 22 2011 Guest 564 Thumbs Up

Charlie,
I completely understand your frustration with this issue, and the easiest answer to this and other required documentation contradictions is to trust LEED Online as the final answer. The sample plan in the reference guide is very old, I think it may actually be from an earlier version of EB. I am not sure what version LEED Online form you used when submitting this project but I just checked a version 3 MRp2 LEED Online form and one of the required check boxes asked you to verify that the plan addresses the goal that all mercury containing lamps be recycled. The form version can be found at the bottom of each page of the credit form.

In general, when LEED rolls out new documentation requirements they do it via LEED Online updated forms, and don't necessarily note this in addenda. It is kind of a strange way to do it, but that has been my experience. I would also strongly suggest using the LEED User policy templates (you can download them in the documentation toolkit tab), which note that 100% of the lamps need to be recycled

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EBI Consulting EBI Consulting Aug 23 2011 LEEDuser Member 499 Thumbs Up

Under the "requirements" section in the reference guide (p. 245), it does say that "all" lamps have to be recycled, "Have in place a solid waste management policy for the building and site addressing the requirements of the waste management credits listed below as well as recycling of all mercury-containing lamps." The example plan that references 95% is probably just a carry over from older version as Jacob noted above. I would suggest submitting a comment on LEED online so they are aware of the discrepancy. We have submitted other discrepancy feedback on the LEED online feedback button and they have been pretty quick to respond. Good Luck!

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Janna Nash
May 08 2010
LEEDuser Member
316 Thumbs Up

Required Waste haulers

Can you tell me if contracts with waste haulers are required? My project is a small office building located on a college campus. Currently the office personnel or college students carry all recyclables to the city recycling collection points and do not receive a receipt. I know for compliance with MR credit 7-9 they will be required to quantify amounts, but can they do it themselves or are they going to be required to have a contract and pay a thrid party to do this? Thanks!

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Tristan Roberts LEED AP BD+C, Editorial Director – LEEDuser, BuildingGreen, Inc. May 11 2010 LEEDuser Moderator

Janna, for MRp2, the prerequisite you've posted this question under, you don't need to document compliance at all—you simply need to have a policy in place.

For MRc7, MRc8, and MRc9, you would need to collect some kind of documentation, but I think you could justify some kind of occupant-generated log system rather than receipts from a paid hauler. Perhaps a letter or something from the city confirming that this is how it's done would also help with the documentation package.

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