Memorandum

							                                           50    years of service excellence


Memorandum
To:            Harvard University Project Managers
From:          Christine LeBlanc, EH&S
Date:          May 12, 2010
Re:            Off-Site Management of Gypsum Board

______________________________________________________________________________

This memorandum provides the requirements for the off-site management of gypsum
wallboard including cutoffs and scraps of gypsum wallboard from new construction, and
gypsum wallboard removed from demolition and renovation from Harvard projects.
As presented in the EH&S February 2, 2010 Off-Site Management of Construction and
Demolition Debris memorandum, C&D debris including gypsum wallboard, is regulated by the
Massachusetts Solid Waste Management regulations, policy and guidance. Where feasible,
Harvard University favors and promotes recycling and reuse above disposal options. In
addition, MassDEPs pending land ban on the disposal of cutoff and scrap gypsum from new
construction, slated for September 2010, further supports the following methods of off-site
management:

   •    New Construction: Cut-offs and Scrap Gypsum: Cut-off and scrap gypsum can be
        recycled at Gypsum Recycling America, LLC of Cambridge, MA or at GP Gypsum in
        Newington, NH.

   •    Demolition and Renovation Gypsum Wallboard: All used gypsum wallboard must be
        tested for lead-based paint and asbestos prior to off-site management (i.e.,
        processing/recycling or disposal). The Contractor is required to ensure that appropriate
        tests are conducted and meet the facility acceptance criteria prior to shipping the material
        off-site.

        ♦    Recycling: Used gypsum wallboard can be recycled at: Gypsum Recycling
             America, LLC in Cambridge, MA providing that the following specifications are
             met:
             1. Lead (Pb) is not present in excess of 100 mg/kg; and
             2. No asbestos is detected; a detection report of “less than 1%” for asbestos shall
               constitute a determination of the detection of asbestos in the material. The
               samples for asbestos testing must include areas of spackle, joint compound etc.


          Cambridge Campus: 46 Blackstone Street, Cambridge, MA 02139 617.495.2060
         Longwood Campus: 4 Blackfan Street, Room B84, Boston, MA 02115 617.432.1720
                                www.uos.harvard.edu/ehs
                                                                                         Page 2 of 2




       ♦     Disposal as Asbestos Waste: If the used wallboard contains asbestos at
             concentrations greater than 1%, the asbestos-containing materials must be managed
             off-site by a licensed abatement contractor as ‘asbestos waste’ and shipped to an
             asbestos-permitted landfill. EH&S’s website at:
             http://www.uos.harvard.edu/ehs/caps/asbestos.shtml provides details on asbestos
             waste management.
       ♦     Disposal as Solid Waste: If the used wallboard does not contain any detectable
             levels of asbestos (asbestos concentration is 0%), and the total lead concentration is
             greater than 100 mg/kg, but less that TCLP lead at 5 mg/L, then the materials can
             be managed off-site to a Massachusetts permitted landfill.
       ♦     Disposal as Hazardous Waste: If the used wallboard contains TCLP lead at a
             concentration at or greater than 5 mg/L, the contaminated wallboard must be
             managed off-site as a hazardous waste to a RCRA-permitted facility.

For projects involving the collection and off-site management, disposal, recycling, processing,
handling and incineration of solid waste materials including C&D debris, it is incumbent upon
the Harvard-designated Contractor to ensure that the off-site facility is appropriately permitted
and that supporting documentation of the facility’s permits, approvals, and/or licenses,
compliance history and certificate of insurance are provided to the Harvard Project Manager and
EH&S prior to the start of the project and before these materials are shipped off-site. The
Construction and Demolition Waste Management Specification outlines the requirements for
these submittals and available at:
http://www.uos.harvard.edu/ehs/construction/standard_specifications.shtml.

If you have any questions, please contact Christine LeBlanc at Harvard EH&S at 617.495.8259.




         Cambridge Campus: 46 Blackstone Street, Cambridge, MA 02139 617.495.2060
        Longwood Campus: 4 Blackfan Street, Room B84, Boston, MA 02115 617.432.1720
                               www.uos.harvard.edu/ehs