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Managing Mercury during Custodial, Maintenance, Construction,
or Renovation Activities

Policy and Procedure

Policy:  To ensure that mercury encountered during custodial, maintenance, or construction/renovation activities is handled in a safe manner and in accordance with all Federal, State, and Local regulations

Applicability:   This policy and procedure applies to Facilities Management, Contractors, Capital Projects          
Management (CPM), Project Managers, and Environmental Health & Safety (EH&S). 

Scope:   Due to the age of many buildings at Columbia University, workers may encounter mercury during their
work activities. These work activities affecting plumbing systems (e.g., pipes and traps) are of particular concern,
as these systems have a tendency to accumulate spilled mercury. Workers should be aware of the potential of encountering mercury during any work activity.  Mercury is a silvery, liquid metal that is fluid in its motion.  Mercury reflects light and will “shine” when light is directed at its surface, thus a flashlight should be shined directly at suspect mercury materials.  As a result of an accidental spill, mercury is usually found in small puddles or in very small droplets or beads. 

Procedure: Whenever mercury, or materials suspected of being or containing mercury, is encountered the following procedures shall be followed:

A.  If the material is uncontained or has spilled:

  1. Employee/Contractor shall immediately stop all work activities. 
  2. Employee/Contractor shall isolate the area (e.g., close door, string caution tape, etc.) to prevent the suspect material from being disturbed and dispersed and exit the area.
  3. Employee/Contractor must not attempt to clean-up or dispose of the suspect material. 
  4. Employee/Contractor shall provide Supervisor/CPM Project Manager with all pertinent information (include: the name of involved workers, location of work area, type of fixture containing mercury, estimated quantity of mercury observed, whether the mercury spread from its original location) and be available to meet/speak directly with EH&S to review the situation.
  5. Supervisors/ CPM Project Manager shall contact EH&S to apprise them of the situation. 
  6. EH&S shall assess the situation and determine what action is required. 
  7. EH&S shall coordinate all remediation activities in the work area. 
  8. Work shall not proceed until EH&S provides clearance for activities to commence.

B.  If you are opening or removing plumbing pipes or traps:

  1. Wear the appropriate Personal Protective Equipment (PPE) for the particular work activity.
  2. Place a bucket or suitable container under the opening of the pipe or trap to collect any liquid.
  3. Collect all liquids and check for visible mercury, as well as needles and glass slides in the liquid. Also using a flashlight, check the on the interior surface of the pipe and trap for visible mercury.
  4. If pipes, traps and liquid are free of visible mercury and/or needles and glass slides, drain dispose of the liquid and dispose of pipes and traps as general debris.
  5. If mercury and/or needles and glass slides are found, stop all work immediately and follow procedures 1 through 9 as set forth above.

Responsibility:  It shall be the responsibility of Facilities Management, Project Managers, Contractors, and  
Environmental Health and Safety to ensure this policy and procedure is followed.

CUMC 630 West 168th Street, Mail Box 8, New York, N.Y. 10032, 212.305.6780, FAX 212.795.5847
MS 500 West 120th Street, MC 2215 New York, NY 10027, 212.854.8749, FAX 212.316.4937

Created 2/02; Revised 7/09